Information Notice No. 84-40: Emergency Worker Doses

                                                            SSINS No.:  6835
                                                            IN 84-40 

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                    OFFICE OF INSPECTION AND ENFORCEMENT 
                           WASHINGTON, D.C. 20555 

                                May 30, 1984 

Information Notice No. 84-40:   EMERGENCY WORKER DOSES 

Addressees: 

All nuclear power plant facilities holding an operating license (OL) or con-
struction permit (CP), research and test reactor facilities and fuel cycle 
licensees. 

Purpose: 

This information notice is provided to inform licensees of instances of mis-
understandings concerning the proper management of personnel radiation 
exposures in excess of regulatory limits occurring from emergency response 
activities. Guidance from the NRC staff is provided to clarify this issue 
and to inform potential emergency preparedness volunteer workers of possible 
post emergency work restraints subsequent to emergency response activities. 

Recipients are expected to review the information for applicability to their
training programs and instructions to personnel. Although no response is re-
quired, licensees are expected to correct instances of misinformation 
regarding NRC regulations supplied to potential emergency preparedness 
volunteer workers. 

Description of Circumstances: 

The NRC staff has recently become aware of several instances where misinfor-
mation concerning the handling of emergency personnel exposures was being 
presented during reactor operator and general employee training at nuclear 
power plants. 

Licensees are required [10 CFR 55.23(j)] to provide operator training in 
several areas, including the significance of radiation hazards at levels in 
excess of permissible regulatory limits. Emergency planning standards [10 
CFR 50.47(b)(11)] require a means of controlling radiological exposures to 
emergency workers consistent with the Environmental Protection Agency's 
(EPA) Emergency Workers and Lifesaving Activity Protective Action Guides (25 
rem whole-body dose for emergency workers and 75 rem for lifesaving 
activities). Several nuclear power plant licensees have misinterpreted these 
regulations and misinformed reactor operators and general plant employees 
that doses received as part of performing volunteer emergency duties are not 
included as part of the worker's current quarterly occupational exposure 
record and are not added to the previous accumulated occupational exposure 
record of the worker. 


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                                                            IN 84-40 
                                                            May 30, 1984 
                                                            Page 2 of 2 

Under current NRC regulations, all occupational doses including emergency 
doses are required to be included as part of a worker's' exposure history, 
and hence can affect the workers allowable exposure during the current 
quarter and subsequent quarters. For example, if a worker received a dose 
greater than 3 rem [10 CFR 20.101(b)(1)], the worker could not be allowed to 
receive any more occupational dose for the remainder of that quarter; and, 
that same worker, could not exceed 1.25 rem in any subsequent quarter until 
again permitted in accordance with the 5(N-18) dose-averaging equation to 
satisfy the requirements of 10 CFR 20.101(b)(2). 

Evidently, in the absence of definitive NRC regulatory guidance, footnote 2 
to 10 CFR 100.11(a)(1) has been misinterpreted. Referring to dose 
limitations on the sizing of exclusion areas for power reactor siting 
considerations, footnote 2 says, in part: 

          The whole body dose of 25 rem referred to above corresponds 
          numerically to the once in a lifetime accidental or emergency 
          dose for radiation workers which, according to NCRP recommen-
          dations may be disregarded in the determination of their radi-
          ation exposure status (see NBS Handbook 69 dated June 5, 1959). 

No endorsement of the NBS (National Bureau of Standards) Handbook 69 
emergency dose guidelines/recommendations nor application to 10 CFR 20 was 
ever intended. 

If you have any questions regarding this matter, please contact the Regional
Administrator of the appropriate NRC Regional Office or this office. 



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

Technical Contacts:      W. S. Cool, RES 
                         (301) 427-4579 

                         J. E. Wigginton, IE 
                         (301) 492-4967 

Attachment: 
List of Recently Issued IE Information Notices