ML20209E389
| ML20209E389 | |
| Person / Time | |
|---|---|
| Issue date: | 04/01/1985 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20209D524 | List:
|
| References | |
| FOIA-85-409, TASK-PINC, TASK-SE SECY-85-112, NUDOCS 8505030512 | |
| Download: ML20209E389 (42) | |
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April 1, 1985 SECY-85-112 l
For: The Comisbne From: William J. Dircks Executive Director for Operations
Subject:
CRITERIA ON PERSONNEL 00SIMETERS FOR OFFSITE EMERGENCY WORKERS
Purpose:
To provide the Comission for review the criteria developed by the Federal Radiological Preparedness Coordinating Com-mittee (FRPCC) for dosimetry systems for offsite emergency workers.
Category: This paper covers a minor policy question.
Issue: Whether the criteria on personnel dosimeters proposed by the FRPCC is acceptable for offsite emergency preparedness at all nuclear power plants.
Alternatives: 1. The Comission can agree that the proposed FRPCC p personnel dosimeter criteria is acceptable for offsite emergency preparedness.
- 2. The Comission can disagree with the acceptability of the proposed criteria.
Background:
During Comission consideration of a full power operating license for the Susquehanna Steam Electric Station, Units 1 and 2, the issue of adequate personnel dosimetry for offsite emergency workers was raised. The Comonwealth of Pennsylvania contended during the Atomic Safety Licens-ing Board (ASLB) hearings that all emergency workers must be equipped with both direct reading dosimeters and ther-moluminescent dosimeters (TLDs) in accordance with the recommendations provided in the Federal Emergency Manage-ment Agency (FEMA) publication, FEMA-REP-2, " Guidance On Offsite Emergency Radiation Measurement Systems, Phase 1-Airborne Release," and NUREG-0654/ FEMA-REP-1, "Cri-teria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness-ih'5iipport'of Nuclear Power Plants." Copies of this guidance are pro' i
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'The Commissioners , ;
e vided as Enclosures 1 (FEMA-REP-2) and 2 (NUREG-0654). In
. affidavits given to the ASLB, both the NRC and FEMA staff stated that this guidance was not essential for offsite workers and that a system using only direct reading dosi :
meters with an effective administrative system to measure and control each worker's integrated radiation dose was an acceptable minimum to meet the rule under 10 CFR 50.47(b)
(11). This matter was never resolved in the hearing be-cause the applicant agreed to provide the Commonwealth with a TLD system for offsite emergency workers.
Because of these differing opinions and guidance, the Com-mission in NB20707B (Enclosure 3) requested a meeting with the staff, FEMA, States and others to discuss a generic resolution of the dosimetry system for offsite emergency workers. . In subsequent discussions among the staff, 0GC and the Secretary's staff, it was recognized that this is essentially an offsite issue for which FEMA has the responsibility and that FEMA had requested the FRPCC to resolve this issue. Therefore, it was decided that the staff should monitor FEMA's progress and report any de-velopments to the Commission.
On March 4, 1983, the FEMA Chairman of the FRPCC requested that the FRPCC Subcommittee on Offsite Emergency'Instrumen- .i n tation make recomendations on " preferred" and " accept-
'able" dosimetry systems for offsite emergency workers as-well as a number of other related issues. On November 8, 1983, the FRPCC Subcommittee responded to this request with
" ideal" and " minimum acceptable" dosimetry systems (Enclo-sure 4). On December 30, 1983, the FEMA Chairman of the FRPCC requested coments -and recomendations from the members
% of the FRPCC (Enclosure 5) on these proposed dosimetry sys-tems as well as the other items covered in the request to the Subcomittee. On May 21, 1984, July 23, 1984, and August 29, 1984 (Enclosures 6, 7, and 8), the staff re-
- sponded to the FRPCC concerning the ancillary issues and L stated .that the proposed criteria for dosimeters would be
, reviewed by the Commissioners prior to the staff providing . '
coments and recomendations to the FRPCC. On April 17, i 1984 FEMA issued the dosimeter criteria to State and local l governments as part of'a supplement to FEMA-REP-2 (Enclo-j- sure 9).
Discussion: Minimum Acceptable System:
l The proposed " minimum acceptable" criteria for a dosimetry j system for offsite emergency workers recommended by the I
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The Comissioners .
FRPCC (Enclosure 4)'provides for one direct reading dosi-meter and one permanent record dosimeter. The direct reading dosimeter.has a radiation response range which would give a readable indication of radiation exposure from a minimum of approximately 100 mR to a maximum of 5 R or approximately 400 mR to 20 R depending on which of the recommended ranges of dosimeters was selected by offsite authorities. (Direct reading dosimeter designs include a 0 to 5 R or 0 to 20 R in this general range of sensitivity.)
The FRPCC Subcommittee selected these ranges of sensitivity for two reasons: (1) it is unlikely that offsite emergency workers would receive a whole-body dose in excess of 20 rem for. the first two hours under severe accident consequences at a nuclear power plant; and (2) that,the minimum indication of exposure which would alert the worker to the fact that he or she is being irradiated should not exceed 400 mR. In additiun, this range of dosimeter was needed to accurately determine accumulated dose and the dose limit at which emergency workers are to take some remedial action to reduce their dose by modifying their activities unless they are assigned to a lifesaving mission which is usually 5 rem.
Emergency workers are instructed to observe the readings on their dosimeters several times an hour when working within the 10 mile Emergency Planning Zone (EPZ). Although the O to 5 R direct reading dosimeter does not provide a range capable of measuring the maximum anticipated dose, it was included because of its greater availability and the range should be adequate to cover the maximum exposure for approxi-mately 30 minutes under the most severe accident consequences.
Until very recently the only available supply of 20 R direct reading dosimeters was in the FEMA civil defense stocks which have been depleted. One comercial manufacturer is now building limited numbers of these dosimeters. The 5 R direct reading dosimeter is a connonly manufactured range which is also used by the nuclear Navy.
It is generally agreed that offsite emergency workers must be equipped with some type of direct reading dosimeter to enable them to determine their accumulated whole-body dose while performing their responsibilities within the plume exposure pathway EPZ. Because of electrical leakage problems sometimes encountered in direct reading dosimeters (result-ing in false indications of exposure) and that improbable, but not impossible, radiation exposure to workers might exceed the sensitivity range of the dosimeter, the Subcom-mittee did not agree with the earlier NRC and FEMA staff
The Comissioners .
position that an effective administrative control system could be substituted for a permanent record, film badge dosimeter or TLD. In addition, the Subcommittee believed that the availability of a pennanent record dosimeter was essential to record the actual doses received by emergency workers during a nuclear power plant accident. This was to prevent ovr.rlooking significant doses due to administrative or other arrors and to prevent possible intentional altera-tion of the direct dosimeter readings. The exposure indica-tions af permanent record dosimeters are more difficult to charge since the readings of these dosimeters cannot be determined until they are processed.
In addition, the FRPCC Subcomittee criteria require that both the direct reading and permanent record dosimeters meet the applicable ANSI standards.
Ideal System:
The " ideal" dosimetry system for offsite emergency workers provides for two direct reading dosimeters with overlapping ranges. The low range dosimeter would have a range of 5 R or 20 R as discussed above. A high range dosimeter (100 or 200 R) provides a backup for doses of significance (greater than 2 to 4 rem) and extends the range of indication well
- above the anticipated doses for offsite emergency workers to cover doses which exceed the Environmental Protection Agency's Protective Action Guide for lifesaving missions (75 rem). This system also requires a multiple chip TLD as an accurate permanent record of emergency worker dose and that the dosimeters meet the ANSI standards'. This system is recomended for those States and localities wishing to pro-vide the best possible dosimetry system for offsite emergency workers and is almost identical to the system recomended in FEMA-REP-2 (Enclosure 1).
Staff Position:
While the staff generally agrees with the criteria for the
" minimum acceptable" system, it believes that the range of the 5 R direct reading dosimeter is not high enough for this application and that the range of the direct reading dosimeter should be 20 R. However, because of the limited quantity of 20 R dosimeters, it is realized that the 5 R dosimeter may have to be used. In this case, the staff believes that either a 100 R or 200 R range dosimeter should also be
1 The Commissioners .
u provided in the " minimum acceptable" system.. Therefore, it recommends that the " minimum criteria" should be modified to
-reflect this change. A table is provided as-Enclosure 10 illustrating a comparison between the FRPCC recommendations and the staff position.
Present Status:
.At the present time it is estimated that offsite emergency workers at approximately 80% of the operating nuclear power plants are already equipped with both a direct reading and a permanent record dosimeter. Most of these emergency workers are equipped with a 200 R and either a 20 R or a 200 mR direct reading dosimeter since .the 200 R and 200 mR dosimeter are more readily available in the FEliA civil defensd stocks. This is the result of the existing guidance in NUREG-0654/ FEMA-REP-1 (Enclosure 2) that has been applied
'by FEMA and the Regional Assistance Committees.
-Costs: The cost of direct reading dosimeters in quantities of'1,000 units 'is approximately $80 per unit. . Dosimeter chargers for
.these devices cost approximately-$100 each. To equip offsite emergency workers at a nuclear power plant site, assuming approximately 1,000 workers and a charger for every 50 dosimeters, would cost approximately $82,000. If 20 R 3-dosimeters are not available, then using the staff recomended changes in the " minimum acceptable" criteria would increase this cost to $164,000 since both a 0-5 R and a high range unit would be used. The cost of providing TLDs for these same workers is approximately $15 per TLD plus approximately
$10,000 for a TLD reading, recording and anhealing system or a total cost of approximately $25,000. This brings the total cost of the " minimum acceptable system" to approximately
$107,000, or $189,000 where 20 R dosimeters are not available.
The cost for providing a permanent record TLD for:offsite.
emergency workers increases the overall cost of the dosimetry system approximately 14% or 30%. These costs are applicable for the life of the plant excluding the cost of replacing lost or damaged dosimeters and repairs to dosimeter charger readers. The cost of providing the " ideal system" is ap-proximately three times the cost of the " minimum acceptable system" because of the need for twice as many direct reading dosimeters, if 20 R dosimeters are provided, and the higher cost of a more elaborate TLD.
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' The Commissioners .
Recommendation: Based on the ne'ed to provide an accurate record of offsite emergency worker's dose and the small increase in the total cost of providing a permanent record dosimeter, the staff recommends that the Commission agree with the inclusion of a permanent record dosimeter in the " minimum acceptable" personnel dosimetry system for offsite emergency workers proposed by the FRPCC. However, the staff suggests that the Commission recommend the " minimum a_cceptable" criteria -be changed.to include both a 5 R and either a 100 R or 200 R direct reading dosimeter when 20 R dosimeters are not avail-able as.well as a film badge dosimeter or TLD.
Note: The staff intends to advise FEMA that the NRC does not agree with the " minimum acceptable system" for direct reading dosimeter ranges within 10 working days of the da,te this paper is received by the Secretary unless otherwise instructed by the Connission. Enclosed is a draft memoran-dum from the NRC representative to the FRPCC recommending that the direc.t reading dosimeter ranges be modified-(Enclosure 11).
f
,r William . Dircks t Executive Director for Operations - i
Enclosures:
- 1. -Dosimetry criteria fr. FEMA-REP-2
- 2. Dosimetry criteria fr. NUREG-0654 '
. 3. : M8207078 dtd. 7/13/82
- 4. Memo fr. FRPCC Subcommittee dtd.11/8/83
- 5. Memo fr. Chairman FRPCC dtd. 12/30/83
- 6. Memo fr. Dir...DEPER/IE dtd. 5/21/84
- 7. Memo fr. Dir., DEPER/IE dtd. 7/23/84
- 8. Memo fr..Dir., DEPER/IE dtd. 8/29/84
- 9. - Supplemental Info. to FEMA-REP-2 dtd. 4/17/84
- 10. Dosimetry Comparison Table
- 11. Draft memo to Chainnan. FRPCC
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l SECY NOTE: In the absence of instructions to the contrary, SECY will notify the' staff on Tuesday, April 16, 1985 that the Commission, by negative consent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners.
OGC.
OIA OPA' REGIONAL OFFICES EDO ELD ACRS ASLBP ASLAP SECY
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Dosimtry Criteria from FEMA-REP-2 Q. ,
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{3 Direct reading personnel dosimetry that accurately measures whole-body
- i gamma radiation dose below the minimum detectable level of the 0-20 1
roentgen direct reading pocket ionization chamber (i.e., about 400 mR) i's f, not considered essential for emergency workers such as police, firemen, etc. , who are not likely to ever be involved in another abnormal exposure to radiation.
{]s. However, more sensitive dosimetry will be required for the i
i occupational radiation worker. In these cases, the parent organization I.s ii of such personnel should provide the dosimetry currently being used for radiation protection purposes.
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This provision should be documented for tiiis category of emergency workers by the parent organization during the
, , formulation of the State Radiological Emergency preparedness plans.
ll-p li r.j In view of the above, it is recommended that all local emergency workers t
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be equipped with two direct reading gamma dosimeters; one with a range of O to 20 R and one with a range of 0 to 200 R.
These two dosimeters
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4' should provide for continuous coverage from 0.4 to 200 R which is well
- ,; beyond any anticipated whole-body gamma exposure. They will also provide LI
- some redundancy by their overlapping ranges (0.4 to 20 R and 4.0 to r
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- To offset the disadvantages of the direct reading dosimeter, all emergency
[. j workers could be provided with a thermoluminescent dosimeter as well as
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{ the two direct reading dosimeters. This dosimeter would also measure
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,' whole-body gamma radiation dose for the dual purpose of (1),providing a g redundant measurement of the accrued dose, and (2) providing a measurement
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of the accrued dose of less than as well as in excess of the range of the direct reading dosimetry (0.4 to 200 R). The thermoluminescent dosimeter could be incorporated into the information card. This information card could be issued to each emergency worker as he reported to the EOC or his emergency assignment location. The card would be completed by the worker, giving his name, o*ganization, social security number, etc. This informa-tion card would then serve as a means of determining the personnel assigned to the emergency work force and the information needed for individual exposure records. These dosimeter cards would be collected at the end of the individual's emergency assignment and evaluated to confirm total accrued gamma radiation dose: In order to reduce the State's cost, provision would b'e made to use a TLD which is compatible with an existing L TLDr'eader that can be m'ade available within about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the j start of the release. The TLD's should be calibrated and annealed periodically (approximately every 6 months) against this reader so that they are ready for distribution in the emergency locations. Alternatives to this recommended TLD system would be a conventional, commercial film badge or TLD service.
5.4 Other Dosimetric Devices _ _ _ . . _ . __
In addition to the four principal types of dosimeters given above, there are pocket size devices usually referred to as " alarming dosimeters" or
" personal radiation monitors." These devices are small transistorized.
- battery operated radiation detection instruments which usually use a 5-9
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as throughout the course of the incident by the use of personnel . [,
dosimeters as described in item b below. '.i 1
- b. Personnel Dosimetry for Emergency Workers should be as follows:
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- 1. One 0-200 roentgen and one 0-20 roentgen self-reading pocket ionization chamber should be available and assigned to each jf !
emergency worker to provide redundancy, self-reading ~ capability, k$
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. Worker PAG for whole-body gamma radiation exposure. Dosimeters -
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of this type and in the quantity required are available from O,
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- h. 2. More sensitive day-to-day personnel monitoring devices that
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might be available for occupational radiation workers should iy ,
be utilized. .
. 3. A means should be developed by the State for exposure record ' -
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documentation for all emergency workers.
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- 4. A thermoluminescent dosimeter should be provided for each :.
emergency worker. It is highly desirable that this be t' incorporated as part of the exposure record documentation. h it
- c. All emergency workers who may be exposed to the plume should be :.
.ij provided with protective measures to prevent the uptake of radioiodine ,
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Dosimetry Criteria from NUREG-0654 i
K. Radiological Exposure /C ontrol (continued) f
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-. . Evaluation Criteria Reference to Plans
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g Licensee State Local 3.a. Each organization shall make provision 7
' for 24-hour-per-day capability to determine '
the doses received by emergency personnel involved in any nuclear accident, including .-
volunteers. Each organization shallimake i I provisions for distribution of dosimeters,
.--.u both self-reading and permanent rccord devices. X X X s
- b. Each organization shall ensure that dosimeters are read at appropriate frequencies and provide for maintaining dose records for emergency workers involved in any nuclear j accident. --
X X X
&[Each State and local organization shall establish the decision chain for authorizing emergency workers to incur exposures in
workers-and-. lifesaving activities). X X 5.a. Each organization as appropriate, shall specify action levels for determining s
- -. ; the need for decontamination. X X X Each organization, as approp'riats, b.
shall establish the means for radiological decontamination of emergency personnel I wounds, supplies, instruments and equip- -
8 ment,- and for-waste disposal . X X X
- 6. Each licensee shall provide onsite contamination control measures including:
- % .- a. area access control; X
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- b. orinking water and food supplies; X
[ c. criteria for pemitting return of l
areas and items to normal use, see
-! Draft ANSI 13.12. X i
ENCLOSURE 2
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ENCLOSURE 3 --
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,r .c. IN RESPONSE, PLEASP.
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UNITED STATES NUCt. EAR REGULATORY COMMISSION REFER To:. M8207075
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July 13, 1982 cmcr or twr LIMITED DISTRIBUTION stemerAny T .. , , , ,
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MEMORANDUM FOR: Leonard Eickwit, Jr., Gen' Counsel
. FROM: Samuel J. Chilk, Secretar g ,
A SU3 JECT:
STAFF REQUIREMENTS - DISCUUsS N AND POSSIBLE-VOTE ON CONTESTED ISSUES IN S SQUIHANNA -
OPERATING LICENSE PROCEEDING, 2:00 P.M., .
WEDNESDAY, JULY 7, 1982, COMMISSIONERS' . . .
CONFERENCE ROOM (CLOSED MEETING)
The Corzdission was briefed' on the May 7,1982 OPE analysis of the ASLB initial decision which concludes that the Directer, NRR should be authorized to issue a full power operating ~1icense for Susquehanna Units 1 and 2, with certain conditions. _
The Commission voted unanimously to approve the -draf t order, s *~ ~ 'atrached jo~the May 7 OPE memorandum, as modified at the meeting,.~ ~
making the Board decision im:nediately effective;. the General ~
Counsel was instructed to circulate the revised Order prior to its release. Commissioner Gilinsky will attach separate views.
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(Subsequently, the Order "was circulated by the General Counsel/,'
on July 9, 1982.) .- .
In connect 5.on with his appr6 val, Commissioner Roberts stated-
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his preference not to take multiple ' votes in OL reviews. . ,1 ,
The comrission: .-
- 1. Requested a meeting with staff, FEMA, states' and others in the fall to discuss the question of-dosimeters for _
emergency workers (Commissioner Gilinsky would have pref erred a ineetin'g~ prior to voting on this order) ;
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L >. 2. Asked'the General Counsel to prepare a Commission proposal ,
for a generic resolution to the above question; l l
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' ENCLOSURE 3
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- 3. Requested staff to include in their briefing on uncontested issues in Susquehanna, the status of the public information brochures; and (NRR) (SECY Suspense: August, 1982)
- 4. Requested the Generkl Counsel advise the staff immediately if the Court mandate'in the S-3 case is issued.
(OGC) cc: Chairman Palladino --
Cc:nmissioner Gilinsky Comissioner Ahearne
- Comissioner Roberts Comissioner Asselstine - -
Commission Staff Offices
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'I ENCLOSURE 4
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Washington, D.C. 20472 November 8,1983 MEMGRANDUM FOR: Richard W. Krimm Chairman, Federal Radiological Preparedness Coordinating Committee (FRPCC) ,
FRbM: Carl R. Siebentritt Chairman, Interagencf
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pg ubcomp[t, j.0 see On Offs 1te Emergency Instrumentation
SUBJECT:
Dosimetry for Emergency Workers This is to provide a final response by the FRPCC Subcommittee On Offsite Emergency Instrumentation to your. memorandum dated March 4,1983, on the same subject. Your memorandum requested that recommendations be made by the subcommittee on the following: .
- 1. Definition of emergency worker; 3
- 2. The preferred (ideal) system of dosimetry for emergency workers;
- 3. The acceptable (minimum acceptable) system of dosimetry for emergency workers; ,
- 4. The ~ position of States with operating commercial nuclear power plants in meeting the recommended, preferred and acceptable systems;
- 5. The status of FEMA (and other Federal agencies) furnished dosimeters--their performance characteristics, availability, ,
and applicability for peacetime radiological _ emergency response;
- 6. Other sources of dosimeters--their applicability, performance, cost,. and availability for radiological emergency response.
The subcommittee recommendations for items 1, 2, and 3 are provided in Attachment I. The subcommittee response to the other items are as follows:
o Item 4: 25 of those States having a requirement for offsite planning for nuclear power plant accidents responded to the questionnaire which resulted in Attachment 4 of your memorandum.
All 25 States provided for emergency worker dosimetry. However, 4 States admitted to limitations in operational capabilities. Most of the States use direct reading dosimeters having a range of 0-200 mR ENCLOSURE 4
as a component of their emergency worker dosimetry. The subcom-mittee believes that this range is too sensitive for a practical system and recommends that the attached guidance on emergency worker dosimetry be provided to all States.
o Item 5: FEMA is the only federal agency which has provided instruments to the States. Large quantities were granted to the States starting
. in the 1950's. FEMA records show that the States have inventories
. of direct reading dosimeters as follows:
0-200 mR 0-20 R 0-100 R 0-200 R 80,000 97,000 65,000 2,100,000 t
(All figures are rounded - a breakout by State is available.)
FEMA experience with these instruments ~ has shown that they are capable of providing radiological information with' good accuracy if they are tested periodically in accordance with well-established FEMA guidance.
An improved capability for cal ~ibrating dosimeters will be provided in FY 1984 to the State Radiological Systems Maintenance Shops. Al so, FEMA has. advised the States that FEMA granted dosimeters found to be defective will be repaired (if possible) by the FEMA Emergency Management Systems Test Facility (EMSTF). Tests conducted recently by EMSTF on 500 recently refurbished 20 R dosimeters, originally manufactured in the 1950's, showed that these dosimeters are capable of. meeting the test and rarformance requirements specified in FEMA-REP-2 and ANSI N322-1977 " Inspection and Test Specifications for Direct and Indirect Reading Quat tz Fiber Dosimeters." A test report is available. The subcommittee knows of no federal agency furnishing TLDs or film badges.
o Item 6: Direct-reading dosimeters which meet the performance require-ments of FEMA-REP-2 and ANSI N322-1977 are available from the private secto r. The recomnendations of Attachment I indicate that thqStates should develop their procurement requirements around ASNI N3,7T-1977.-
Paragraph 4, Test Requirements of the ANSI standard should be included in the preparation of procurement specifications. In addition,'FEW4 has developed policy regarding dosimeters procured directly by the States. This policy is contained in the memorandum dated September 14, 1983,(Attachment'II).
The cost of direct-reading dosimeters are estimated to be on the order of $60 to $100 depending upon quantity.
TLDs and film badges which meet requirements for emergency worker dosimetry are widely available at reasonable cost. The system which employs these instruments should conform to ANSI N13.11-1,983,
" Personnel Dosimetry Performance - Criteria for Testing." .
Summa ry: The subcommittee believes that the foregoing and the attachments satisfy your requirements. This-information will be included in the update of FEMA-REP-2 as appropriate.
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Note: The subcommittee has received requests for the information given
. herein. . For example, K;rgaret,Reilly, Pennsylvania. would like to have the definition of emergency worker. Please advise in writing, if draft ' copies .
may be furnished in response to these inquirie's and, if so, any caveats that may apply.
-Attachments (2) e e
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Attachment I DEFINITION OF AN EMERGENCY WORKER An emergency worker is an individual who has a mission within the Plume Exposure EPZ which is essential to protect the health and safety of the public and who could be exposed to ionizing radiation from the plume or its deposition. This individual must be trained in the basic characteristics of ionizing radiation and its health effects. the individual must be able to determine his cumulative radiation dose with a direct reading dosimeter and know what to do when dose limits and turn-back values are reached.
Energency workers may include the following: radiation monitoring personnel, traffic 'contr'ol personnel, evacuation vehicle drivers, fire and rescue personnel, E0C personnel, personnel carrying out backup alerting precedures and essential services or utility personnel. Essential services or utility personnel are considered emergency workers only when their services are required to protect the health and safety of the public.
DOSIMETRY SYSTEMS FOR EMERGENCY WORKERS
- 1. The Ideal System: Two direct rea' ding dosimeters with different ranges that can adequately cover a range of radiation exposure from 1 R to 200 R.
The dosimeter with the lowest range should be able to measure radiation exposures of at least 5 R, but no more than 20 R. The dosimeter with the highest range should be able to measure exposures of at least 100 R.
The direct reading dosimeters should, as a minimum, meet ANSI Standard N322-1977, Inspection and Test Specification for Direct a'nd Indirect Reading Quartz Fiber Pocket Dosimeters and be certified. The dosimeters should be tested annually for calibration accuracy and electrical leakage.
The lowest range direct reading dosimeter allows the emergency worker to monitor his radiation exposure for turn-back values and/or, administrative do'se limits. The highest range dosimeter allows the emergency worker to monitor to above 75 rem whole-body dose which is the EPA lifesaving PAG .
for emergency workers. The reason for ~ recommending an upper limit of 200 R is that there are many direct reading dosimeters available with this range (e.g., CDV-742) and it has adequate sensitivity to measure approximately 2 R increments of exposure.
In addition a permanent record dosimeter consisting of a multiple chip TLD should be provided as a backup device for the direct reading dosimeters and to provide a legal record. The TLD should be read by a processor accredited by the National Voluntary Laboratory Accreditation l
Program (NVLAP) in accordance with ANSI Standard N 13.11-1983, Personnel l Dosimetry Performance-Criteria for Testing.
- 2. Minimum Acceptable System: One direct reading dosimeter with a minimum ~
range capable of measuring a radiation exposure of a least~ 5 R and a maximum range that shall not exceed 20 R. This dosimeter shall be certified, annually leak tested and meet ANSI Standard N 322-1977. In addition each emergency worker shall be provided a permanent record dosimeter which is read by an accredited processor under NVLAP.
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MEMORANDUM FOR: Regional Directors Au ins R 6 i:rd Circ:tcr - - -
FROM: Deputy Associate Director
,g State and 1.ocal Pro 5 rams and Support
SUBJECT:
Testing of Radiological Instruments Procured by the States for Radiological Emergency Preparedness.
Some States have received funding from utilities for use in procuring radiological instruments for emergency preparedness capabilities under NUREG 0654/ FEMA-REP-1. The Pennsylvania Emergency Management Agency (PEMA) procured 2,500, 0-20R dosimeters and requested that FEMA assist in quality assurance testing. Tests were performed by the FEMA Emergency Management Systems Test Facility and the results reported to
?. PEMA. Tests were also performed on a similar procurement by the State - -
of Maine. Other States have expressed the need of the same services.
Our experience with Pennsylvania and Maine indicates that such testing is very labor intensive and would constitute an overwhelming workload if continued. In addition, it is not an appropriate FEMA function'should the capability be available in the private sector. Therefore, FEMA will not
- accept any further requests for such testing.
FEMA has no objection if the State Maintenance and-Calibration facilities are used for quality assurance testing of instrumentation for REP and other contingencies, to the extent that the shop has the capability. To .
this end, FEMA will shortly be supplying the State shops with an improved dosimeter calibration fixture for use with the CDV-794 calibrators. If the~ State shops do not have the testing capability, the use of qualified private sector resources should be sought by the States.
Our experience also has revealed the need for a policy statement on instru-mentation procured by the States. This policy is as follows:
o FEMA will not provide quality assurance or acceptance testing sup-port to the States.
o FEMA will permit the use of the State Maintenance and Calibration shops, within the limitations of the capabilities and equipment, for such testing.
2 o Upon kritten request,. FEMA will provide technical advice to the States regarding quality assurance testing. Such requests should be submitted through Regions and endorsed to the attention of the
- Emergency Management Pro' g rams Office.
o FEMA will not assist in the preparation of, or evaluation and review of. State procurement specifications. Similarly, FEMA will not be a party to any determination relating to the Contractor's performance against State procurement specifications.
o Upon ~ written request, FEMA will repair all dosimeters which were originally procured by FEMA predecessor agencies and granted to the States. This includes' all models. However, it must be under-stood by the States that certain models will have low yields. In all cases the sane dosineters sent in for repair will be returned.
Those that can not be repaired will also be returned if the State so requests. The repair will be performed by the FEMA Emergency Management Systems Test Facility.
All questions regarding this policy should be addressed to the Emergency Management Programs Office.
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. Washington, D.C. 20472 DED 301983 MEMORAND'ut FOR: Members of the Federal Radiological Preparedness Coordinating Co==ittee (FRPCC)
FROM: .
- Richard W. Krims Chair =an, FRPCC SU3 JECT: Dosimetry for Emergency Workers On March 4, 1983 I requested the Chairman of the Subco=.=ittee on Offsite E=ergency Instrumentation to =ake reco==endations on the following:
- 1. Definition of Emergency Worker;
- 2. The preferred (ideal) syste= of dosimetry for e=ergency workers;
- 3. The acceptable (minimum acceptable) system of dosimetry for e=argency workers; 4 The position of States with operating commercial nuclear power plants in meeting the recommended, preferred, and acceptable syste=s;
- 5. The status of Federal Energency Management Agency (and other Federal agencies) furnished dosi=eters--their performance characteristics, availability, and applicability for peacetime radiological emergency response; and
- 6. Other sources of dosimeters--their applicability, performance, cost, and availability for radioloEical emergency response.
The Subco==ittee has been working on this assign =ent and the Chairman provided a final written response to me dated November 8,1983,
Subject:
Dosimetry for Emergency Workers.
Please review the attached response fro = the Subcommittee Chair =an and provide your agency's ce==ents, reco==endation, and/or concurrence to me by January 26, 1984 In.particular, I request that you review and comment on Attachment I pertaining to the definition of an Emergency Worker.
Attachment As Stated ENCLOSURE 5
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. E. F. Williams, 'IE
[ksniQf, UNITED STATES -
F NUCLEAR REGULATORY C'OMMISSION f' E WASHINGTON. D. C. 20555
% . . . . . *' May 21,1984 MEMORANDUM FOR: Richard W. Krimm, Chairman Federal Radiological Preparedness Coordinating Committee
, State and Local Programs and Support Federal' Emergency Management Agency FROM: Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
EMERGENCY WORKERS AND EMERGENCY DOSIMETRY This is in response to your memorandum of December 30, 1983 on the above subjects. The original memorandum was not received due to an apparent mail distribution problem and was retransmitted to us on April 25, 1984. In the-future please ensure that I am provided a personal copy of all correspondence addressed to the FRPCC members.
r We will provide you with a reply by June 15, 1984-containing NRC recommendations en all of the items listed in your memorandum except for the ideal dosimetry system and the minimum dosimetry system for emergency workers. The Commission has taken a direct interest in these items and it may be necessary to obtain their review prior to providing you with NRC recommendations.
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saward L ordan, Director'.
Divis o of Emergency Preparedness andi ngineering Response Office of Inspection and Enforcement cc: See Attached CONTACT: Edward F. Williams, IE 492-7611 mO ENCLOSURE 6 1
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Richard _W. Krimm cc:. J. N. Grace, IE.
S..A. Schwartz, IE.
D. B. Matthews, IE C. R. Van Niel, IE
' F. Kantor, IE-E. F.. Williams, IE C. M. Bridgers - (Control No.-13471)
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~ MEMORANDUM FOR: Richard W. Krimm, Chairman Federal Radiological Preparedness Coordinating Comittee State and Local Programs and Support Federal Emergency Management Agency FROM: Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement
SUBJECT:
EMERGENCY WORKERS AND EMERGENCY DOSIMETERS As indicated in my memorandum of May 21, 1984 on this subject, we have the following comments and recommendations with regard to the responses of the FRPCC Subcommittee On Offsite Emergency Instrumentation as numbered in your
/ memorandum:
(
- 1. Definition of emergency worker. - We concur with this definition.
- 4. Position of States with operating comercial nuclear power plants in meeting the preferred and acceptable dosimetry systems for
- emergency workers. - We agree that the 0-200 mR direct reading dosimeters are too limited in range to be useful during accidents involving nuclear power-plants.
- 5. Status of FEMA furnished direct reading dosimeters. - It would appear that there are adequate supplies of FEMA direct reading dosimeters
'available to the State governments to cover the needs of offsite emergency planning if the 0-20R dosimeters are dedicated to that program and are located in States with operating commercial nuclear power plants or plants under construction. Since the report does not indicate where these dosimeters are located or whether FEMA has any control over their use, these questions need to be answered.
- 6. Other sources of dosimeters, their applicability, performance, cost and availability for radiological emergency response. - We recommend
- that FRPCC Subcomittee On Offsite Emergency Instrumentation develop i a generic procurement specification
- around ANSI N13.11-1983 which can be used by the States to procure and test their dosimeters using
- the equipment available to the State Maintenance and Calibration Shops.
- ,- Also, a list of qualified comercial vendors capable of testing direct reading dosimeters against ANSI N13.11-1983 should be provided.
l' ENCLOSURE 7
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Richard W. Krimm Our comments and recommendations with regard to the ideal and minimum acceptable dosimetry systems for emergency workers will be reviewed-by the Commission. We will provide these comments and recommendations to you following their review.
dward . Jordan, Dircctor Divisio f Emergency Preparedness and Engineering Response Office of Inspection and Fnforcement- ,
cc: J. N. Grace, IE S. A. Schwartz, IE D. B. Matthews, IE C. R. Van Niel, IE ,
F. Kantor, IE .
E. F. Williams, IE e
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y NUG' 2 S 1934 MEMORAlDUM FOR: ' Richard W. Krimm, Chairman Federal Radiological Preparedn'ess Coordinating Comittee State and Local Programs and Support
-Federal Emergency Management Agency.
FROM: Edward L. Jordan, Director Divis. ion of Emergency Preparedness
. and Engineering Response Office of Inspection and Enforcement
SUBJECT:
EMERGENCY WORKERS AND EMERGENCY DOSIMETERS
.-eTerence is made-to my memorandum of July 23, 1984 regarding this same subject.
In reviewing th.is memorandum, we found that changes in item f6 are necessary.
This item should be revised to read:
s~ 5. Other sources of dosimeters, their applicability, performance, cost and availability for radiological emergency response. -- We recomend that the FRPCC Subcomittee On Offsite Emergency Instrumentation: develop a generic-procurement specification around ANSI N322-1977 which can te used by the States to procure and test direct reading dosimeters using the equipment
- available in the State Maintenance and Calibration Shops. Also, a list of qualified comercial vendors capable of providing. indirect reading dosimeters which meet ANSI N13.11-1983 should be provided.
We anticipate that the reco::mendations with regard to acceptable dosimetry systems will be presented to the Comission for their review before the end of:this month.
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Edwar . Jordan, Director Divi n of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement cc: J. - N. Grace , IE
- S. A. Schwartz, IE D. S. Matthews, IE C. R. Van Niel, IE: .
F. Tantor, IE-E. F. Williams, IE i
ENCLOSURE 8
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Federal Emergency Management Agency Washington, D.C. 20472 APR I 7124 s
SUPPLEMENTAL INFORMATION TO FEMA-REP-2 NUREG-0654/ FEMA-REP-1, Rev.1. " Criteria for Preparation and Evaluation of Radiological Emergency Response. Plans and Preparedness in Support of Nuclear Power Plants" requires offsite emergency radiation measurement systems. 'Ibe first of a series of guidance documents 'on offsite instrumentation was prepared by the Federal Radiological Preparedness Coordinating Committee, Subcommittee on Offsite Emergency Instrumentation, and published in September 1980 as FEMA-REP-2, " Guidance On offsite Emergency Radiation Measurement Systems, Phase 1 - Airborne Release."
FEMA-REP-2 is currently under revision by the Subcommittee. However, the Subcommittee believes that users of the guidance should be (1) aware of new information that has become available on the performance of the airborne radioiodine monitoring system discussed in FEMA-REP-2, and
. .'~ (2) provided clarification on the definition of an emergency worker and-
) acceptable dosimetry systems. This information is provided in the ~'
attachment entitled " SUPPLEMENTAL INFORMATION TO FEMA-REP-2".
The revision of FEMA-REP-2, projected for completion this fall, will discuss these topics in greater detail.
Chairman Federal Radiological Preparedness Coordinating Committee I
ENCLOSURE 9
APRIL 1984 SUPPLEMENTAL INFORMATION TO FEMA-REP-2 Instrumentation for use by St' a te and local jurisdictions for radiological emergencies associated with nuclear power plants is based on guidance
- developed in accordance with conceptualizations of how emergency operations would be conducted. Instrumentation is needed to detect radioactive releases offsite that could endanger the atmosphere.. water, and food. The first of a series of guidance documents on offsite instrumentation was published in September 1980 as FEMA-REP-2, " Guidance On Offsite Emergency Radiation Measurement Systems, Phase 1 - Airborne Release".
As stated in FEMA-REP-2, it was expected that the technology would evolve and changes in the document would be provided. FEMA-REP-2 is currently under revision. However, users of the guidance should be aware of recent developments with regard to the use of the guidance.
Based on continuing research and development, new information has become available on the performance of the airborne radioiodine monitoring system discussed in Appendix B. In addition, based on experience gained in numerous exercises in the application of the NUREG-0654/ FEMA-REP-1 evaluation criterial ,
clarification of some of the ancillary topics discussed in FEMA-REP-2 would appear to be useful. Both the additional information on the radioiodine monitoring system and the clarification of the ancillary topics are discussed ,
below. The revised version of FEMA-REP-2 will discuss .these topics in greater detail.
Radioiodine Monitoring System _ _ , _ _ ,
c At the time of preparation of FEMA-REP-2, an inexpensive system was described.
for monitoring airborne radioactive iodine in the field, which made use of existing civil defense survey meters for evaluation of radioiodine collected by the silver impregnated silica gel sample collector of the systes. Since the publication of FEMA-REP-2, new data have been published 2 ,3, copies of which are attached, and FEMA has gained experience and information on the performance of the GM tube used as the sample counter of the system, as well as other components
- of the system.
Air Mover: . . .
Reference 2 shows that the air mover motors in the air samplers originally reported in FEMA-REP-2 failed to operate at low temperatures in the direct current mode.
Since these motors had been operated in the system for an unspecified number of hours during the TMI incident, additional motors were procured from the commercial vendor of.this system. A recent paper 4, also attached, summarizes the results of the tests on the motors supplied by the commerical vendor of this system.
! Although the new motors operated successfully on AC voltage, their operation was unsatisfactory on DC voltage, and exhibited a short lifetime of about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.
Users of this system should assure themselves that the air mover motors in their equipment are capable of operation in accordance with the users procedures.-
['
GM Tubes:
The airborne radioactivity monitoring system uses a Victoreen 6306 probe which is an organically-quenched GM tube inside a specially constructed lead shield.
The inherent limited lifetime of such tubes could be a problem. In addition, a new procurement of these tubes had a very large rejection rate, due to causes including excessive background, lack of accuracy, excessive plateau slope, and short operating life.
More recent deliveries have shown a significant improvement with the exception of the inherently high background. This background count race, approximately 50 cym, does not prevent. these probes' from meeting the detection sensitivity required.
Adsorption Media:
3 Based on reported data , modifications are required in the procedures given in Appendix B of FEMA-REP-2. Prior to counting for radioiodine, the silver impregnated silica gel adsorption media must be purged with clean air for a short perd.od to remove radioactive noble gases. Since measurements made at the sample collection point may result in an elevated count rate from noble gas in the plume, the field team could perform the purge using the air mover, once they have moved outside the, plume. Based on relevant data 3 , however, it is possible that the small fraction of radioxenon, which is firmly bound, i.e., not removed by the clean air purge, could cause a false positive identification of radioiodine even when no radioiodine was in the plume. This circumstance could only occur in plumes of high noble gas concentration and with relatively short lived noble gas (less than 12-15 hours after reactor shutdown).
A second type of radioiodine monitoring system, which is mentioned in FEMA-REP-2, but not discussed in detail, used silver zeolite as the iodine adsorption media and a pancake detector for field counting. The users of this system should be aware that trapped radioxenon would also be a problem and a clean air purge is required prior to counting. There are at least three commercial vendors. who supply silver zeolite adsorption media. A recent report 4, shows that there is a difference of a factor of 50 in the amount of radioxenon firmly bound, i.e.,
! not removed by a clean air purge, between tests of tha media supplied by two of
_the vendors. The difference in the amount of firmly bound radioxenon apparently
' is due to the degree of activation (dryness) of the media supplied by the two vendors.
Users of either radioiodine monitoring system should provide in their procedures
- or a clean air purge prior to counting and assure themselves that the adsorption media being used will not give a false positive radioiodine. indication due to the adsorption of radioxenon. Users must be aware that (1) the silver impregnated silica gel must be activated (dry) and (2) that the silver zeolite must not be
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Ancillary Topics Experience gained in numerous exercises indicates that clarification of some of 3
the ancillary topics covered"in FEMA-REP-2 would be useful. l Specifically, what l is the definition of an emergency worker and what is an acceptable dosimetry .
I system for an emergency worker? '
Definition of an Emergency Worker An emergency worker is an individual who has a mission within the Plume Exposure Emergency Planning Zone (EPZ) which is essential to protect the health and safety of the public and who could be exposed to ionizing radiation from the plume or its deposition. This individual must be trained in the basic characteristics of ionizing radiation and its health effects. The individual must be able to
' determine his cumulative radiation dose with a direct reading dosimeter and know what to do when dose' limits and turn-back values are reached.
i Emergency workers may include the following: radiation monitoring personnel, )
traffic control personnel, evacuation vehicle drivers, fire and rescue personnel,
- . emergency operating center personnel, personnel carrying out backup alerting i procedures and essential services or utility personnel. Essential services or utility personnel are considered' emergency. workers only when their services are required to protect the health-and safety of the public.
Dosimetry Systems for Emergency Workers _
- 1. The Ideal System: Two direct reading dosimeters with_diff.erent ranges
- that-can adequately cover a range of radiation exposure from 1 Roentgen (R) to 200 R. The dosimeter with the lowest range should be able to measure
- radiation exposures of at least 5 R, but no more than 20 R. The dosimeter
- with the highest range should be able to measure exposures of at least 100 R. The direct reading dosimeters should, as a minlaua,.neet the American National Standards Institute (ANSI) Standard N322-1977, Inspection and Test Specification for Direct and Indirect Reading Quartz Fiber Pocket Dosimeters-and be certified. The dosimeters should be tested annually for
! calibration accuracy and electrical leakage. The. lowest range direct '
reading dosimeter allows the emergency worker to monitor his/her radiation exposure for turn-back values and/or adminstrative dose limits. The highest range dosimeter allows the emergency worker to monitor to above 75 Rea whole-body dose which is the Environmental Protection Agency's lifesaving Protective Action Guides (PAG's) for emergency workers. The reasons for recommending an upper limit of 200 R is that there are many direct reading
- dosimeters available with this range (e.g., CDV-742) and it has adequate j sensitivity to measure approximately 2 R increments of exposure.
l In addition, a permanent record dosimeter consisting of a multiple chip i
Thermoluminescent dosimeter (TLD) should be provided as a backup device
- for the direct reading dosimeters and to provide a legal record. The TLD I
should be read by a processor accredited by the National Voluntary Laboratory j - Accreditation Program (NVLAP) in accordance with ANSI Standard N13.11-1983, j Personnel Dosimetery Performance-Criteria for Testing.
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2.1 Minimus Acceptable System: One direct reading dosimeter with a minimum range for measuring a radiation exposure of at least 5 R and a maximum
, range that shall not exceed 20 R. This dosimeter shall be certified, annually leak tested, and meet ANSI Standard N322-1977. In addition, each emergency worker shall be provided a permanent record dosireter
- which is read by an accredited processor under NVLAP.
References
- 1. NUREG-0654/ FEMA-REP-1,'Rev. 1 " Criteria for Preparation and Evaluation l .of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", November 1980.
- 2. NUREG/CR-1894/ENICO-1075, " Mechanical Reliability Evaluation of A Proposed Emergency Response Radioiodine Air Sampler", December 1982.
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of Silver Impregnated Silica Gel Media with Different Silver Loadings and
, Under Different Test Conditions", February 1983.
- 4. Measuring Radioiodine in the Environment After A Nuclear Power Plant Accident, l R. L. Huchton and B. G. Moces, pages 59-73 of NUREG/CP-0048, Vol. 6
" Proceedings of the U.S. Nuclear Regulatory Commission Eleventh Water Reactor Safety Research Information Meeting",-held October 24-28, 1983.
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ENCLOSURE 10 i - - .
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Comparison ~of' Dosimetry System Recommendations t ,
FRPCC Recommendations Staff Recommendations
" Ideal" System " Minimum" System " Minimum" System A multichip TLD with two A TLD or a film badge A TLD or a film badge direct reading dosimeters, and one direct reading and either one or two The direct reading dosi- dosimeter.with a range direct reading dosi-meters should have ranges of either 0-20 R or meters. If one direct of either 0-20 R or.0-5 R 0-5 R. reading dosimeter is and either 0-100 R or provided, it should
. 0-200 R. -
have a range of 0-20 R.
If a 0-5 R direct reading dosimeter-is provided, either a 0-100 R or a 1-0-200 R direct . reading
' dosimeter should also be-4
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