United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 99: The following questions concern the

relationship of emergency plans for nuclear power plants to

10 CFR 20.1001 ("Purpose") and 10 CFR 20.1101 )"Radiation

Protection Programs"). (a) To what extent do radiation

protection programs need to be established such that during

emergency conditions, the revised Part 20 can be complied

with? (b) For example, in order to comply with the new EPA

"Manual of Protective Actions For Nuclear Incidents"

October 15, 1991, do germanium counting systems need to be

established to analyze air samples for iodines and

particulates, and computer programs to calculate CEDE, so

that CEDE can be added to external dose to get TEDE? (c)

Do emergency survey / plume chase teams need to wear

breathing zone air samplers?



Answer: (a) In general, the revised Part 20 contains no

new requirements that would make changes necessary in

existing radiation protection programs as they relate to

emergency conditions. 10 CFR 20.1001 includes the

sentence, "However nothing in this part shall be construed

as limiting actions that may be necessary to protect public

health and safety," and the intent of this sentence is

discussed in the statement of considerations (56 FR 23365,

first column). NRC requirements concerning emergencies at

NRC-licensed facilities (i.e., nuclear power plants and

fuel-cycle licensees) are contained in 10 CFR Parts 30, 40,

50, and 70, and no conforming changes to these requirements

were needed as a result of the revised Part 20. (b) and

(c) See answer to (a). With regard to the offsite emergency

workers such as fire fighters, law enforcement officers,

civil defense workers and environmental field team members,

the EPA manual provides guidance given in Table 2-2 titled

"Guidance on Dose Limits for Workers Performing Emergency

Services." In addition to the refinements in the dose

limits, the revised EPA Manual uses the CEDE and the TEDE

concept. There are no changes necessary with respect to

the monitoring of the external exposure levels of these

workers in the early phase of an accident except as noted

in the referenced table. The question is, therefore, how

to account for the inhalation dose of offsite emergency

workers to prevent them from exceeding their limits. Due

to the urgency of offsite response in the early phase of an

accident, it will not be practical to set up air samplers

at numerous locations and analyze those samples in a timely

manner. Air samples and radiation measurements taken by the

field monitoring teams will be valuable to determine the

dose to emergency workers after the fact, but will be of

little value during the actual performance of emergency

tasks, since some form of real time exposure rate

indication is needed. To create this real time indication,

a correction factor can be developed that when multiplied

by the emergency worker's dosimeter reading can provide a

conservative estimate of the inhalation dose. The NRC and

FEMA are currently investigating this issue. After

appropriate review the NRC and FEMA will provide guidance

for offsite agencies to use. (References: 10 CFR 20.1001,

10 CFR 20.1101)

Page Last Reviewed/Updated Thursday, March 29, 2012