ML20247K182
| ML20247K182 | |
| Person / Time | |
|---|---|
| Issue date: | 08/23/1989 |
| From: | Jordan E NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Gunter W ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| NUDOCS 8909210102 | |
| Download: ML20247K182 (11) | |
Text
{{#Wiki_filter:_ M y q.;. bk vp el AUS 2 3 ]ggg h' '. [. Mr[ William Gunter, Director. ' Criteria and' Standards Division (ANR-460) Office.offRadiation Programs. Environmental Protection' Agency
- 401 M Street, S.W.
' Washington, D.C. 20460 i
Dear Mr. Gunter:
' This letter is in response to the May' 26,1989 4 request for comments on the May-1989 draft of the Manual of Drotective Action Guides and Protective Actions for Nuclear Incidents;(PAG Manual). The NRC has a keen interest in this document as it provides a significant basis for the onsite and offsite emergeacy response planning and.decisionmaking and is, therefore, a vital part of our regulatory. program. A letter from Mr.. James M. Taylor, Acting Executive Director for Operations, NRC to Mr. William G. Rosenberg, the Assistant Administrator for Air and Radiation of the EPA outlines our overall concerns with both the proposed revisions to the draft EPA Protective Action Guides and the process for approval and interim use of the EPA Manual. This letter provides detailed comments (enclosed) to you based on our analysis of the draft manual. We have recently received a letter from you dated August 8, 1989, indicating that_an additional 6-month comment period is being extended to all FRPCC members on applicability of the PAGs to nonreactor nuclear facilities. Although we will provide further comments on the applicability of the PAGs to nonreactors, in the interest of being prompt we are providing our comments in accordance with your initial request at this time. We appreciate your cooperation in the resolution of this important matter. If you have any. questions or comments, please feel free to call me at (301) 492-4848. Sincerely, W Sipted by: E.LJontan Edward L. Jordan, Director Office for Analysis and Evaluation of Operational Data
Enclosure:
NRC Comments on PAG Manual cc w/ encl: ~J. Logsdon, EPA 9$ t\\ 8909210102 890823 PDR ORG NEXD
MP NRC COMMENTS ON PAG MANUAL MAJOR COMMENTS Plume PAGs: The proposed Protective Action Guides (PAG) would result in protective actions being taken at a lower plume exposure than existing PAGs. No need or justification for this significant change has been given, though the implications and impacts are significant. For example, the i 4 PAGs are reduced from 1 rem to 0.5 rem for protective actions, and from the 1-5 rem range to 1 rem for evacuations. Our concern is that-protective actions taken based upon these lower values have not been justified and seem to be inconsistent with'the potential risks associated with evacuation. Further, although the principles. involved are similar to that of the international community, the proposed values are lower. In this regard, the doses above are reflected in the chart on table 2-1, recommending protective actions based on dose level without consideration for plant parameters as reflected in section 2.3. We recommend that the table be modified to be consistent with current philosophy. Flexibility: The flexibility in responding during the plume phase has been eliminated, and replaced with single values for specified protective actions. This flexibility is an important feature of the existing guidance, and, while useful in most accidents, it might be crucial in the most severe accidents where the area at risk could extend beyond the 10-mile plume exposure pathway EPZ. In these extreme cases, decisionmakers may need the flexibility of sheltering populations projected to receive doses up to 5 rem in the interest of expediting the evacuation of persons at greater risk closer to the plant. Implementation: We have major concerns about the " interim" guidance and these concerns ara amplified by EPA's implementation language, which states, in part: "The existing PAGs will continue to provide adequate protection for situations to which they have already been applied.
- However, these new PAGs are appropriate for incorporating into emergency response plana when they are revised or when new plans are developed."
Emergency response plans for NRC licensees and State and local governments within the plume and ingestion exposure pathways of commercial nuclear power plants are generally revised at least annually. EPA proposed that the new PAGs would be implemented when these emergency response plans are revised. Once the PACS are issued .. m navumn -_ a
,.y .y. t 3 for. implementation,'the method of implementing the above. document and the time scale for.doing so need careful consideration to avoid d, 'licenueesLand state / local governments from having to deal with two- -{ f sets-of! guidance during the. changeover., This:is 1 where multiple states are affected by.a licensee.particularlyEtrue .Since EPA accedes to the adequacy:of the existing-PAGs there seems to be no urgent need Lfor immediate implementation, thus thefnew PAGs, could be incorporated 'in a more orderly manner such as the procedure required for Presidential Guidance. Early Phase Defined'as'4 Days: In.Section 2.1. EPA defines the "early. phase" of the. accident as the period from initiation of an' atmospheric l release until 4 days after y the event occurs. EPA characterizes this in its guidance as "somewhat arbitrarily defined," then limits the PAGs for members of the'public ~ and emergencyLworkers.to this.4 day period. After this period, radiation exposure ~to members of the general public would'oe governed by the new lower relocation PAGs and radiation exposure'to emergency workers would be governed by Federal guidance for normal work situations. Both the accident at Chernobyl and severe accident' research indicate'that>some accidents may cause atmospheric releases over a period of several days. In some circumstances, decisionmakers would need the flexibility of having workers accept higher doses than normal'for more than 4 days in order to mitigate an ongoing accident. Protective actions for the general public could also extend over a period longer than 4 days. The rational for the 4 days should be-provided. Emergency Worker Definition: This revision of the EPA PAG document has discontinued the use of the-term " emergency workers" and'now refers to " workers performing emergency services." Because the document does not clearly differentiate between the-utility's emergency personnel and tnose for .the offsite organizations, there are questions of applicability with respect to the use of the term " workers performing emergency services." We suggest that this term be added to the Glossary, Appendix A. The definition should be definitive enough to resolve any questions of applicability. Need for Executive Summary: An executive summary would clearly be a useful addition to the . document. This summary should state why the PAGs contained in the 1980 Manual are being revised, identify in comparative form the major changes between the 1980 PAGs and those contained in thc c;rrent revision, and otherwise provide the reader with an overview of what is presented in the document. Focus on Reactors: 2
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The focus of the document is on nuclear ~ incidents at reactors. i
- currentlyi:thereDisno.apparentconsiderationto1applyingthePAGsfor'{
accidents 1at other types of facilities.- Since the need for j case-by-case development of implementation measures for'other types ofj facilities'is acknowledged-in the-implementation discussion, EPA should limit the scope'of-the manual and applicability of the.PAGs.ta rea'ctors until full: application is-more fully considered and similar evaluations for other licensees are: performed. m ( In considering application to other types of nuclear accidents,: SPA ahould consider NRC's recent (54 FR14051, April:7,: 1989) rulemaking'on emergency ' licensees. preparedness for fuel cycle and other radioactive material The supporting analyses and information on source terms,- j dose ~ conversion factors, and plausible scenarios contained.in 1 NUREG-1140: provide the basis for NRC+s rulemaking and should.be. .] helpful to EPA.. Level'of Presentation:. The presentation of material in the main body of the document is'in need of extensive-editing, both for consistency and to assure an-understandable document. In many cases, the text and its: supporting table: assurs c. level of health physics knowledge and familiarity with. new dose assessment techniques that may be unsupported for' State and local government officials _ charged with emergency response planning. The text should be revised or supported by other documents to provide a plain innguage explanation-of the basic concepts. Consideration of Organ Dose: Although the concept of a-Protective Action Guide ignores prior doses,., both prior and projected dosee should be considered in controlling;the i dose to any single organ to less than the 50-rem non-stochastic dose j limit. ] Too Prescriptive: I The manual, especially chapters 5 and 7, is overly prescriptive in l detailing how to implement the PAGs. This methodology is better left' / to the emergency planners. Cost Analysis: The idealized evacuation areas and relocation areas used by EPA result in a significant underestimation of the costs involved in these ) actions relative to the dose savings they provide. i Use of Effective Dose Equivalent: State and local agencies are likely to have difficulty using exposures expressed. in terms of committed effective dose equivalent and effective dose equivalent. These exposure terms are not described in simple terms ~in the manual. Application of these terms should be
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- clearsto all;decisionmakers/in-order to avoid pote.ntial delaya in j
%g' , protective action implementation attributed to a;1ack of a understanding.; ~ +;;. ' State:and1LocaljReview: ] a, ~ Tne NRCilicensees.and: State and: local governmentsEinitiW area:around; ?NRC-licensed: facilities have considerable experience in' implement'ationO tof emergency plans l based.in part onLthe EPA PAGs. 'Their comments-d 'should be. requested. Public.Use=of KI:.. n,
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- the administration of stable. iodine is listed e.sDL l ~ i" principal protective. action"1for the public. The. referenced previous 1 o i federal. guidance on the. administration of stable' iodine'hasl11mited
- recoraending its use to' workers and special' groupn not. the general-1public. !We..suggest'this be rencved as'a " principal protective'
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y' j g SPECIFIC COMMENTS s Page viii, Item 7-6, 2nd line, delete " Levels for Emergency Screeninc".- Page'l-3, Section 1.1, 3rd paragraph, 2nd line - delete " source and" as being superfluous. Page 1-4, 1st paragraph, line 3 - substitute " levels acceptable for unrestricted use" instead of " permanently acceptable' levels." An alternative would be " acceptable permanent levels." Page 1-4, 2nd paragraph, line 3 - last word substitute " showering" for ' " bathing." Item #2 suggest: "2. Potential delayed somatic and genetic effects should be minimized by restricting the collective (population) dose to the extent feasible." Note: " reasonably achievable" is probably not an adequate standard for_ protective actions as these actions may go beyond what would be otherwise " reasonable." Page 1-7, Section 1.3, lines 17 and 18 - insert " nuclear reactor" before " core-melt" in both places. Page 1-8, Referencec - references FE-85 is not used - delete. Page 2-1, Section 2.1, 2nd paragraph, line 5 - insert "radiciodine" between " block" and " update." Page 2-2, 3rd paragraph should be deleted. Although the plume pathway guidance doesn't supersede the old FRC PAGs, the FDA recommendations should - hence the older FRC guidance should be rescinded. Page 2-3, 1st paragraph, last line - suggest "... facilities, gamma radiation exposure may not be significant. In such cases the primary hazard may be inhalation of radioactive particulate." Page 2-3, 2nd paragraph sentence. We have seen calculations that indicate that this statement is not correct - very high skin doses may I result from beta irradiation. Either the statement should be ( qualified (i.e., "less important" on what basis?) or the "although" i should be omitted together with deleting the phrase beginning with I " generally." j i Page 2-3, 2nd paragraph, end, add: i i i "Other radionuclides, such as tritium and cesium-137, may be i evenly distributed among body organs." l 5 l. i
L ll0 s j L Page 2-3,-3rd paragraph, 2nd line - replace " settle out" with " deposit" as_there are other mechanisms tesides gravitational' settling involved in air-to-ground transfer. 4 In Section-2.3, EPA should provide a better explanation of the new PAG dose units (i.e., effective dose equivalent and committed effective dose equivalent) and how they differ from the previously used dose levels in the'1980 PAGs. The manual assumes that the reader ' understands the newer terminology and how it relates to previous dose. levels. Page 2-4,'3rd' paragraph, last line, suggest: " Higher dose levels may be justified under these conditions and continued sheltering.may be the preferred action." Page 2-4, 2nd paragraph, suggest alternative: " Persons in criminal correction institutions such as prisons may present a greater risk of escape during some protective actions such as evacuation. For this reason, slightly higher PAG thresholds for these actions may be warranted for this population group." Page 2-8, 1st paragraph, last line-reference should be made to the FDA recommendations on the use of KI. Page 2-8, 2nd paragraph, line 6 - change "These PAG's" to "The plume { exposure PAG's." Page 2-9, lines 4-6, suggest alternative: j "However, in those rare cases where the dose to individuals from plume exposure might exceed 25 rem, the dose contribution from { inhalation, ground shine, and ingestion should also be assessed so that the total dose can be evaluated and kept below 50 rems (the assumed threshold for acute effects). " These provide more concrete guidance on the conditions where multiple l pathways should be evaluated. I Page 2-10, it is not clear how EPA justifies lowering the PAG for lifesaving activities from 75 rea, external dose (1980 PAG manual) to 25 rem, committed effective dose equivalent in the current manual. If the reduction is based on new information regarding risk of health effects, why does EPA state that the use of 1980 PAGs is still acceptable. Page 2-11, Table 2 - 1st column " absorbed dose" is npot " rem", but " rad" l 6 i
l 7 i 1. e The reference in footnote a, (NR-88), is not identified in Cn2 or in the list in Appendix C. v l The: text accompanying Table 2-3 should include sentences defining acute. health. effects as well as prodromal effects. :The table itself should also state that it is referring to effects experienced shortly after exposure. Chapter 3 - reference should be made to the existing guidance issued by HHS and FEMA (REP-13) until EPA guidance can be develcped. At the end of the first paragraph of,Section 4.1.2,.the phrase. " protection for all individuals" should be changed to " protection for the general population." on pages 4-7 and 7-6, EPA refers to a gradual return of individuals who have been relocated from the restricted zone. We believe that the concept of "a gradual return" seems vague and should be better defined. Page 4-8, line 2 and reference "EP the reference "EP-87" should read "PR-87 and instead of the " ENVIRONMENTAL PROTECTION AGENCY." "PR-87" should read "THE PRESIDENT OF THE UNITED STATES." The President, not EPA, issues Federal Guidance. Page 5-3, Section 5.2, Item #6 - the meaning of this phrase is unclear and should be rewritten. Page 5-3, Section 5.2.1, line 12 - insert " complete" between "the" and " isotopic mix" as some idea of the isotopes present is needed even for the cloudshine dcse calculation. Page 5-7, Section 5.4.1, 1st paragraph, 3rd and 4th lines - as noted earlier, some explanation ought to be given for the choices of "four days" and the "12 hours" for deposition. Page 5-7, Section 5.4.1, 2nd paragraph, 1st sentence is confusing and could be deleted. Page 5-10, Table 5-1, footnote a, Reference This reference indicates the data came from Kocher (KO-83); however, the list of references, page 5-26, indicates (KO-81) Kocher 1981 is the source. The latter should be changed to KO-83. Page 5-10, last paragraph, reference to Federal Guidance Report No. 11 (EP-88) - this reference is not incorporated into the list of references pages 5-25, 5-26. Page 5-12, 3rd partgraph, lines 1 estimation of beta skin doses f J from calculations is necessary for planning, however during an accident direct measurement would appear to be preferable to model 7 j I
I 1 e. calculations based upon assured plume concentrations and assumed deposition velocities. The contrary statement in this section should either be better justified or modified. Footnote "c" is not identified in Table 5-3 on page 5-14. The calculation for etfective dose on page 5-16 results in an answer of 0.76 rems, instead of 0.66 rems. The calculati6n for dose to the thyroid should be 16 rems, instead of 17 rems. Page 5-17, example at top of page - the example using DRLs does not use the data from updated Table 5-4. Therefore, the DRL values are incorrect. Page 5-20, Section 5.5.1 - no mention is made about evacuation of school children while schools are in session. Note: FEMA has issued-specific guidance in this area (GM EV-2) that, in part, indicates school children should be evacuated to a host facility at an emergency classification lower than that at which protective action is recommended for the general public. The following revision is suggested to replace the offsite notification requirements found in Section 5.2 (page 5.2, item 1). Currently as written, the second sentence is at some sites incorrect in stating that PARS are required to be provided to State and local authorities. They may only need to be provided to the State or local authorities. l "NRC regulations require that the facility operator notify predesignated State and/or local authorities within about 15 minutes of any emergency declaration. The initial notification message to State and/cr local officials for any General Emergency declaration must include a protective action recommendation." The following revision is suggested to replace current guidance found in the last part of the first paragraph of Section 5.2.2. " Additional areas in the remainder of the 10-mile EPZ, particularly downwind from the facility, may also be the subject of protective actions. These areas would be determined by the potential magnitude of the release, current and forecast meteorological conditions, and other factors." Page 5-23, Section 5.5.2, Item 3 - How can the individual know when to open the shelter and that the plume has passed? Since many square miles may be affected by a sheltering recommendation, it is not practical for a decisionmaker to determine on a micro-scale when the plume has gone. Consequently, the advisory must be to a general area, risking opening the shelter before the plume has completely gone, { or having people in a shelter for an additional several hours. (See also 1 page S-24, Section5.5.3, Item 7.b). In the latter individuals I following the advice to open shelters following plume passage are told to exit the shelters. Here they may risk not only the plume still in { 8 I J
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+ Q%' ,i N fPagesf5-23;-and~5-24',0Section 5'.5.3',Laddilittlelto(this-document since; "2 most:of it'iscrepetition1ofcmaterials.in Sections 25.5,y5.5.1'and o ' 5 '. 5 ~ 2. y t r;- @h fPages45525.iand 5-26 References 0 References.GR-85,1 GR-86!and.'SN-82 V ,p were not;usediand:should beideleted. j The second sentence;of the second paragraph in-Section.5.3'(page 5-5) disc;ussesLmeasuring(the exposure rate at ground' level. g< '" Ground. level" Q, .~is not.. defined in the glossary. ~Since'the: usual:use.of.thisLterm in; 37 this -kind ' of measurement refers;to a measurement at three.'(3)y feet L above the'levelEofLthe ground,.we:suggest'some explanation;within: parentheses beLadded following theLwords " ground level" tol assist the-reader in understanding'what' measurement:is being used. The=second full: paragraph ont page:7-4 discusses an example where the-restricted; zone.(area'4) is entirely'inside an evacuated areal (zone - t 2 ) '. TheLstatementJis made'that tha onlyypersons to:be relocated"are.
- those who were " missed in the evacuation process."- The lack of a.
istatement about any.special population who may have been sheltered in the. area.leavesTthe reader with questi~ons.concerning the discussion's; applicability totthe special population (s).. The' paragraph would be - improved: by: the addition of a sentence that' describes the handling.of-special1 populations under these circumstances.. ~ Page 7-13,' EPA refers to weathering factors which may affect dose m received from material deposited on the ground.. We believe that EPA should define-weathering factors and" explain how they.may;affact dose. s t Page 7-17,-Section 7.3.2,. equation 2: The last exponent-' appears to be' wrong.- Page 7-20 sis used twice. The page with Table 7-4 should be 7-19. Table 7-5 on page 7-20 should be clarified to state that the dose conversion ~ factors are based on the concentration of radionuclides deposited on the ground surface, not on the skin. ~ Accident type "SST-2" in section 7.6.2 on page 7-24 is not defined. The discussion of Principal Exposure Pathways on page C-2 should . include discussion of the ingestion pathway from material deposited on the ground surface. .The.1980 PAG Manual indicated that a Chapter 8 on " Application of PAG's for Transportation Incidents" was to be developed. This chapter l is not listed in the revised manual. this guidance? Is EPA still planning to develop < j 9 f1 h i_-E_-___-----..-__-___.l-----____ -.-d
q l Page 7-17, Section 7.3.2, last paragraph. _ Reference.NE-75 should be ty _NH-75. (See also page 7-18, where NR-75 is used as a reference for ) lambda 2 and lambda 3 and.on last line'of page.) Page 7-28 Reference - References FR-61, RI-82 and SN-82 were not used and should b e removed from this list. j 1 1 Page C-9, 2nd line - NAS should be NASA. i 1 Page C-14, Figure C absorbed dose is rads, not rems._ Note: the text on page C-13 (first full paragraph) refers.to the doses in Figure C-1 in rads. Page C the use of the unit RETS should be reconsidered in this manual. Although a definition is provided, RETS is not a universally accepted or used unit. Page C-17, Section C.2.1.4, last paragraph - this paragraph has no place in the EPA PAGs or their bases. The other portions of the Appendix discuss the effects of radiation on animals or man, that is, as symptoms or probabilities of biological damage. This paragraph does not follow that contaxt. It lists a number of authors who would' advocate abortion of a fetus if the mother has been exposed to 10 rads of radiation. Such a recommendation is D21 a biological effects but a very subjective, controversial decision. The effect of this paragraph is to imply the EPA (federal government) recommends abortion.if the mother was exposed to/might have been exposed to 10 rads of radiation. Further, such a " recommendation" would create undue stress on thousands of pregnant women, their families and doctors in the event of a radiological emergency, even if the exposures were well below 10 k rads and much more stress if the exposures were above 10 rads. ] Page C-34, Section C.4.4, middle of last full paragraph - Reference ] ) IC-84 should be IC-84a. Pages C-61 to 64, References - the following references were not used { in this chapter and should be deleted: BR-72b, DE-70, EP-86, FR-64, j and GR-68. In addition, several pages of information are missing to include many of the references. Appendix C, Section C.5.1.3 - we recommend that this section refer to risk and relate risks to " normal" human risks rather than put dollar 4 value on human life. Page F-16, footnotes a and b, and first line of last paragraph. Also see page F Reference NE-75 for WASH-1400 should be NU-75 to be q consistent with its use earlier in the manual. l 1 I 10 j}}