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)