GUIDANCE FOR EMERGENCY

RESPONSE DOSIMETRY

Adela Salame-Alfie, PhD

Stephen Musolino, PhD, CHP

Scientific Committee 3-1 Co-Chairs

National Council on Radiation Protection and Measurements

Health Physics Society Chapter Meeting

Atlanta, 2018

DISCLAIMER

The findings and conclusions in this report are

those of the authors and do not necessarily

represent the official position of their

employers

NCRP SCIENTIFIC COMMITTEE 3-1

Members

• Judith L. Bader - HHS

• Daniel J. Blumenthal - DOE

• Brooke R. Buddemeier - LLNL

• Helen A. Grogan – Cascade Scientific, Inc.

• William E. Irwin, III – Vermont DOH

• Gladys Klemic – DHS

• Gregory R. Komp – DoD (Retired)

• Ruth E. McBurney – CRCPD• Jeanine Prudhomme – NYC DEP

• Richard K. Schlueck – FDNY

• Jessica S. Wieder - EPA

Consultant

Billy Haley – Emergency Mgt

Services Int.

Staff Consultant

James M. Smith - NCRP

Co-chairsAdela Salame-Alfie, PhD

Stephen Musolino, PhD, CHP

TODAY’S PRESENTATION

▪ HIGHLIGHTS OF NCRP REPORT 179 (OCTOBER

2017)

▪ HIGHLIGHTS OF UPCOMING NCRP

COMMENTARY (ESTIMATED RELEASE SPRING

2019)

THE REPORT…▪ Provides guidance on the accrual and control of

radiation dose in the emergency phase of a radiological or nuclear incident and answers three questions:

• With minimal dosimetry resources, how do responders make decisions to

control the total dose and associated risk?

• How are doses assigned to responders when not every responder is

issued a dosimeter before exposure occurs?

• What is the regulatory framework for responders who are not trained as

radiation workers?

▪ Complements three previous NCRP publications that provide advice

on planning responses to radiological or nuclear terrorism incidents

(NCRP Reports 138, 165 and Commentary 19).

THE REPORT…▪ Bridges the gap between trained and equipped emergency

workers and the remainder community of responders.

▪ Defines Emergency Workers as those workers who would be called to assist with the response to a radiological or nuclear incident.

▪ Emergency workers are not traditional radiation workers.

• Most emergency workers have jobs that do not routinely expose them to radiation significantly greater than background levels.

▪ Although the OSHA Standard requires monitoring of emergency workers, there is no other regulation requiring that they be provided dosimetry.

REPORT CONTENTS▪ Dosimetry Needs and Key Concepts

▪ Operational Methods of Dose Determination and Estimation

▪ Recording, Tracking and Communicating Dosimetry Results

▪ Recommendations for Response Organization’s Radiological Capability

▪ Status of Emergency Workers with Regulations and Guidance

▪ Data Needs for Dose Reconstruction

▪ Appendices

• Conversion Units

• Biodosimetry

• Placing Doses in Perspective

• Example of a Robust Emergency Dosimetry Program

• Excerpts from Previous NCRP Documents

TOOLS, EXAMPLES AND

RECOMMENDATIONS

COMPARISON OF THE EFFECTIVE INSTRUMENT EXPOSURE RATE RANGES REQUIRED BY VARIOUS ANSI STANDARDS

To be useful in dose monitoring and exposure control - equipment must be

used within the instrument’s operational measurement range.

Notes:Variation in operational range for some currently available equipment capable of measuring accumulated dose. Bars correspond to capabilities of commercially available instruments and not to specific ANSI standards.Available products may not align with standard instrument categories, and capabilities may exceed the ranges required by the applicable ANSI standard.

VARIATION IN OPERATIONAL RANGE

FOR SOME CURRENTLY AVAILABLE EQUIPMENT

CAPABLE OF MEASURING

ACCUMULATED DOSE.

ADVANTAGES AND LIMITATIONS OF EQUIPMENT FOR EMERGENCY WORKER

DOSE MONITORING AND CONTROL

MATCH EQUIPMENT CATEGORIES WITH

MISSION/TASK APPLICABILITY

Useful (): Device was designed or intended for that mission.

Can be used effectively to perform the mission without modification of the device or

normal mode of use

Marginal (): Device can provide useful and relevant data in support of the

mission, but with modification to the normal mode of employment. Its use may create

a potentially unsafe condition to the user of the device.

Need for care in the interpretation of the data produced by device under the

circumstances

Not Useful (): While device is capable of detecting radiation, technical

performance characteristics or conditions of use are such that it is unlikely to be able

to provide useful information in support of the designated mission. Its use may create

an unsafe condition for the user of the device

EXAMPLE – MISSION ORIENTED

DETECTOR SELECTION

RADIOLOGICAL CAPABILITY GOALS

▪ Basic - appropriate for a small, rural community that is not within the planning zone for a nuclear facility or near

hazardous or radioactive materials transportation routes.

▪ Intermediate - goes beyond the NCRP recommendations and would be reasonable for most communities.

▪ Advanced - appropriate for a high threat area such as a large city or communities near a large city with the risk of

radiological or nuclear terrorism, or within the planning

zone of a fixed nuclear facility.

RADIOLOGICAL CAPABILITY RECOMMENDATIONS

Capability Basic Intermediate Advanced

An individual who is specifically assigned the responsibility for exposure control and dose

monitoring.

✓ ✓ ✓

First arriving responders have an instrument that can alert them when the exposure rate

reaches 10 mR h–1 (~0.1 mGy h–1 air kerma rate)

Non-alarming ✓ ✓

First arriving responders have an instrument that can alert them when levels are in excess

of 6,000 dpm cm–2 (100 Bq cm–2 ) alpha surface contamination or 60,000 dpm cm–2 (1,000 Bq

cm–2 ) beta surface contamination.

β detection only ✓ ✓

First arriving responders have at least one alarming device that actively measures exposure

rates up to 10 R h–1 (~0.1 Gy h-1 air kerma rate)

Non-alarming ✓ ✓

First arriving responders have at least one alarming device that actively measures

accumulated dose

Non-alarming ✓ ✓

First arriving responders have at least one alarming device that actively measures exposure

rates up to 1,000 R h–1 (~10 Gy h–1air kerma rate) with adjustable alarms for both exposure

and exposure rate.

✓

Individuals or groups are assigned some type of dose monitoring device (including pocket

ionization chambers or EPDs).

Limited number Individually

assigned

Individually

assigned

Individually assigned passive dosimeters meet NVLAP type testing criteria for the Accident

Category (I)

✓

REVIEW OF REGULATIONS AND

GUIDANCE FOR EMERGENCY WORKERS

AND DOSIMETRY (EMERGENCY PHASE)

Conducted review to understand the relevance and applicability

of existing regulatory requirements and guidance on:

▪ The definition of an emergency worker and

▪ Dosimetry in the emergency phase

Particular attention was given to whether the best available

science underlies these regulations and guidance as they apply to

an emergency worker.

REVIEW INCLUDED REGULATIONS AND GUIDANCE FROM:

NUCLEAR REGULATORY COMMISSION (NRC)

DEPARTMENT OF ENERGY (DOE)

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(OSHA)

ENVIRONMENTAL PROTECTION AGENCY (EPA)

INTERNATIONAL ATOMIC ENERGY AGENCY (IAEA)

RESULTS FROM REVIEW OF

REGULATIONS AND GUIDANCE …

NCRP has changed its position on the definition of an

emergency worker, and no longer recommends that a person

who falls under the definition of an emergency worker be

considered an occupational worker with the associated

training and qualifications.

EPA guidance provides the most scientifically sound and

protective approach, because it promotes the use of

current scientific methods to control exposure to and

assess dose retrospectively for an emergency worker.

… more on this later

RECOMMENDATIONS

USE WHAT YOU HAVE…BUT PLAN

▪ In a radiological emergency, a variety of radiation detection and

measurement tools can be used to support emergency worker

exposure monitoring and control.

▪ If the information is properly captured, it can also support emergency

worker dose assessment.

▪ The effectiveness of these tools will depend on the level of planning

performed to use them in an exposure control and dose management capacity.

Planning is necessary to repurpose and optimize

radiation monitoring equipment to perform emergency

worker dosimetry and dose management.

TRACK DOSE

▪ Have one device for each team working in close proximity.

▪ Augment with non-alarming, self-reading devices [pocket ionization chambers, radio-chromic cards, or field readable

devices (TLD, OSL, or DIS) with portable readers]

▪ Check readings near the scene at responder rest intervals.

If you can’t provide an alarming electronic device

for each individual emergency worker, you can:

▪ Use what you’ve got… If you don’t have the “right instrument”

▪ Repurpose, repurpose, repurpose

Existing radiation detection equipment used for interdiction

can be repurposed for use in consequence - and dose

management provided planning is performed to ensure the

equipment does not exceed the operational range.

USE INCIDENT COMMAND STRUCTURE (ICS) FOR DOSE TRACKING AND COMMUNICATION

Key elements of ICS that facilitate reporting of doses to emergency workers and other uses of data:

▪ Check-in and responder accountability;

▪ Unity of command and chain of command;

▪ The Planning Section and in particular, the Documentation Unit;

▪ The Safety Officer;

▪ Information management; and

▪ Formal and informal communications

Use a single chain of command to communicate

dose from worker to supervisor and vice versa.

DO NOT USE SMART PHONES TO DETECT/MEASURE RADIATION

▪ As of the writing of this report, these types of devices have been

shown to be unreliable and may provide the user erroneous low

readings in a high radiation environment.(1)

▪ While smart phone radiation detectors are unreliable, they are good

at tracking people.

▪ The data about where people have been, how much time they spent

there, etc., could be useful for dose reconstruction if one had accurate information about the radiation field during that timeframe.

(1) WAGNER, E., SOROM, R. and WILES, L. (2016). “Radiation monitoring for the masses,” Health Phys. 110(1), 37–44.

CONCLUSIONS/RECOMMENDATIONS

▪ Monitoring of emergency workers does not require any specific equipment or device. Alternate techniques or approaches may be used for determining their dose.

▪ Emergency workers who receive a dose >50 mSv in an emergency should not be precluded from returning to work, provided that it is done voluntarily and the individual receives counseling from radiological protection and medical personnel regarding the consequences of their exposure.

▪ The dose accrued in an emergency situation should not be added to the “dose of record” for routine occupational exposure, nor should it preclude employment that would result in additional occupational exposure.

▪ An important responsibility for emergency managers

engaged in radiological emergency operations is

accounting for radiation doses of the responders.

▪ Key information to support this responsibility is strict

accounting of the amount of time and location for

each emergency worker.

▪ In the early phase of the emergency, it is acceptable to conduct operations with limited capabilities for

measuring responder doses provided ALARA is

practiced and use of available dosimetry resources is

optimized.

Conclusions/Recommendations

CONCLUSIONS/RECOMMENDATIONS

▪ Repurpose existing radiation detection equipment used for interdiction for consequence - and dose management. Plan to ensure the equipment does not exceed the operational range.

▪ Adhere to the National Incident Management System and Incident Command System (ICS).

▪ Use a single chain of command to communicate dose from worker to supervisor and vice versa.

▪ Establish dose tracking procedures throughout all facets of the response and work closely with Safety Officer to implement procedures.

CONCLUSIONS/RECOMMENDATIONS

▪ For smaller incidents, effective dose tracking can be

accomplished within the traditional ICS organization. For larger,

more complex incidents, establish a separate Dose Tracking

Unit or Data Management Unit.

▪ Be prepared to convey radiation dose information to

emergency workers before they enter an affected area and

afterwards.

• Inform workers before entering affected area - Before workers enter an

affected area, they need to receive messages emphasizing that steps will

be taken to keep their doses ALARA and below levels for acute health

effects and to minimize long-term cancer risks.

▪ Use an all-hazards approach - While emergency workers may

be the most concerned about radiation exposure, it will not be

the only hazard they are likely to encounter.

CONCLUSIONS/RECOMMENDATIONS

▪ Current regulations for dosimetry by OSHA are based on

obsolete recommendations from ICRP and do not facilitate the use of current scientific methods and

models to control and assess dose, especially for

emergency workers who may not be issued dosimetry in

the same manner as an occupational worker as defined

by NRC.

▪ Providing workers with dosimetry equipment when

available or using other tools to estimate worker doses, is always essential, even during emergencies.

▪ EPA guidance provides the most scientifically sound and protective

approach, because it promotes the use of current scientific methods to control exposure and to assess dose retrospectively for an

emergency worker.

▪ Preplanning for emergency response dosimetry should reflect the

needs of the future dose reconstruction

CONCLUSIONS/RECOMMENDATIONS

* WORKING TITLE…

NCRP

PREVIEW OF COMMENTARY CONTENT

▪ Background

▪ Radiological Emergency vs. Nuclear Detonation

▪ Dosimetry for Regulatory Compliance vs. Emergency Response: The need for a new paradigm

▪ Summary of Previous NCRP Key Recommendations

▪ Key principles

▪ Operational Use of NCRP 179 Recommendations: Responder safety and dosimetry

▪ All responses

▪ Nuclear detonation

▪ Radiological Dispersal Device

▪ Emergency Worker Risk Comparison

DRAFT – DO NOT CITE

• Management of dose using ICS

• Dose tracking and recording using ICS

• Responder accountability

• Dosimetry record keeping

• Dose reconstruction and long-term follow-up

• Using ICS forms to capture data essential for dose reconstruction

• Using responder accountability to capture data essential for dose reconstruction

• Long-term follow-up

• Questions and Answers on Emergency Worker Dosimetry

• Appendices

• Dose Monitoring Considerations During Planning

• Dosimetry Considerations for Urban Search and Rescue Dogs During Radiological Incidents

• Use of Standard ICS Forms to Capture Dosimetry During a Radiological/Nuclear Incident

PREVIEW OF FOLLOW-UP COMMENTARY

DRAFT – DO

NOT CITE

EXAMPLE PRODUCTS

ICS Position(s) Activity

Operations and Safety Must recognize that there is a radiological hazard and a requirement for dose control and monitoring.

Operations and Safety Coordinate with Planning on dose control solutions for the radiological hazard.

Operations, Safety, and Planning Present strategies for dose monitoring to the Incident Command.

Operations and Resources Identify tactical resources with monitoring equipment.Identify monitoring equipment shortfalls.

Operations, Safety, and Planning Identify alternate strategies for monitoring responder doses without monitoring equipment.

Operations and Safety (maybe with Planning and Resources)

Allocate monitoring equipment to operational resources to maximize coverage.

Operations, Safety, and Resources Conduct operational planning to maximize and ensure dosimetry coverage.

Resources (with input from Operations and Safety)

Assigns specific resources to work assignments based on Operations

Section Chief resource requirements, ensuring maximum dosimetry coverage and keeping doses ALARA.

Safety Issues special instructions in the Incident Action Plan (IAP) on dose control and monitoring.

Operations and Safety (with Operations Section Supervisors)

Implement work assignment with group dosimetry; ensure “dosimetry groups” remain together to capture group dosimetry data.

Tactical Resources Stay together, track location, monitor dose throughout the Operational Period, debrief at end of the Operational Period.

Planning (with Safety) Establish a dosimetry tracking function within the Incident Management

Team (IMT); recommend this reside in the Planning Section. Maintain records for post incident analysis.

Logistics and Supply Order more dosimetry

• Who are emergency workers?

• Emergency workers are people called upon to assist in a radiological or

nuclear incident and who do not normally work in radiation environments.

• Emergency worker is a broad term that could include first responders to

utility repair personnel to bus drivers assisting with evacuees.

• Why does tracking responder dose matter to the response

effort?

• Emergency worker doses are tracked to:

• Protect those responding in an emergency by keeping doses as low as

possible and within EPA guidance.

• Reassure emergency workers who will likely have the same fear of

radiation as the general population.

• Ensure response personnel availability for the duration of the emergency

phase of the response.

DRAFT – DO NOT CITE

• How is dosimetry for emergencies different from dosimetry for

regulatory compliance in the workplace?

• Dosimetry for regulatory compliance requires proper dose tracking

instrumentation, active tracking of individual dose, and the ability to “stop

work” if there is any concern about doses received.

• In an emergency, activities may take place to save lives and restore

critical infrastructure when individual dosimetry is incomplete or

unavailable.

• In an emergency, lack of proper dosimetry is not a reason to stop work; it

is a reason to have a plan to mitigate the lack of or limited dosimetry

resources to track dose.

DRAFT – DO NOT CITE

Individual Dose Tracking using ICS forms Group/Team Dose Tracking using ICS forms

QUESTIONS?

ASalameAlfie@cdc.gov