**NRC INSPECTION MANUAL** NMSS/IMNS/RGB

MANUAL CHAPTER 1302

FOLLOW-UP ACTIONS AND ACTION LEVELS FOR

RADIATION EXPOSURES ASSOCIATED WITH

MATERIALS INCIDENTS INVOLVING MEMBERS OF THE PUBLIC

1302-01 PURPOSE

To provide advice and guidance on a course of action to follow in case
of incidents involving radiation exposure to members of the public. The
guidance provided in this document is for U.S. Nuclear Regulatory
Commission (NRC) staff to use in responding to incidents that do not
require activation of the NRC Incident Response Program (Management
Directive (MD) 8.2). It is specifically for use after actions have been
taken to prevent the source of exposure from further affecting the
public, and it is intended for use as initial guidance, when situations
arise. This Manual Chapter (MC) should be used in conjunction with MC
1301, \"Response to Radioactive Materials Incidents That Do Not Require
Activation of the NRC Incident Response Plan.\"

1302-02 OBJECTIVES

To ensure that correct follow-up action is taken when there is an
incident involving radiation exposure to members of the public.

1302-03 DEFINITIONS

03.01 [Agreement State.]{.underline} A state that has signed an
agreement with the NRC under which the State regulates the use of
by-product, source and small quantities of special nuclear material
within that state.

03.02 [Member of the Public]{.underline}. Any individual except when
that individual is receiving an occupational dose

03.03 [Radioactive Material in the Public Domain]{.underline}. Any
radioactive material, subject to NRC or Agreement State jurisdiction,
for which control in accordance with NRC or Agreement State regulations
or with applicable license conditions is not being implemented, and
which may, or have already resulted in, radiation exposures to members
of the public.

1302-04 APPLICABILITY

This MC applies to the Office of Nuclear Material Safety and Safeguards
(NMSS) and the Divisions of Nuclear Materials Safety in the NRC regional
offices.

1302-05 RESPONSIBILITY

The responsible Region shall have the lead responsibility for follow-up
actions for incidents involving radiation exposure to members of the
public, with the following exception. NMSS may have the lead
responsibility when the incident involves several regional offices,
international entities, or when NRC management decides the incident
would be better handled by Headquarters to ensure a coordinated approach
among the various agencies and licensees involved.

05.01 [Director, Office of Nuclear Material Safety and
Safeguards]{.underline}. Develops policy and guidance for the
Headquarters and regional staff who respond to incidents involving
radiation exposures from licensed material to members of the public.
Develops and administers the program for NRC follow-up actions and
coordinates incident follow-up activities.

05.02 [Director, Office of Nuclear Security and Incident
Response]{.underline}. Maintains and staffs the NRC Operations Center at
NRC Headquarters. Receives and documents incident reports from NRC
regional offices, licensees, or other parties. Makes initial and
follow-up notifications within NRC, and to other Federal agencies and
State agencies, coordinating with NMSS.

05.03 [Regional Administrator]{.underline}. Completes incident response
activities according to the policy and guidance established by NMSS and
refers questions on policy matters to NMSS for resolution.

05.04 [Director, Office of International Programs]{.underline}.
Coordinates international aspects of incident follow-up activities with
the Department of State, International Atomic Energy Agency (IAEA),
foreign governments, and other international groups.

05.05 [Director, Office of State and Tribal Programs]{.underline}.
Coordinates applicable incident follow-up activities with State, local,
and Native American tribal governments.

05.06 [Director, Office of Public Affairs]{.underline}. Prepares,
coordinates, and disseminates information about incidents involving
radioactive material to the public and news media.

05.07 [Other Federal Agencies]{.underline}. Roles of other Federal
agencies in responding to incidents involving radioactive material are
summarized in MC 1301, \"Response to Radioactive Materials Incidents
That Do Not Require Activation of the NRC Incident Response Plan.\"

1302-06 GENERAL GUIDANCE

Incidents involving radioactive materials are, by nature,
event-specific. Because the conditions surrounding each incident are
unique, follow-up action must be developed on a case-by-case basis. The
information provided in this MC is meant to be a guide, and

should not be used in isolation of other guidance for incidents and
basic radiation safety principles.

Staff should use the guidance in MC 1301, \"Response to Radioactive
Materials Incidents That Do Not Require Activation of the NRC Incident
Response Plan\" in conjunction with the guidance provided in this MC
when responding to incidents involving radiation exposures to members of
the public. Manual Chapter 1301 provides detailed guidance for
responding to radioactive material incidents, including incident
assessment; dose assessment if individuals are exposed to radiation;
need for medical consultants; interaction with other Federal, State and
local government agencies; types of inspections, etc.

As part of the guidance in MC 1301, procedures direct staff to: (1)
evaluate the potential or actual exposure of a member of the public, (2)
keep public exposures as low as possible, and (3) evaluate the potential
radiological consequences and personnel exposures. Staff should follow
the guidelines in MC 1301 for incident assessment and documentation.
With any incident, staff will be working closely with any known
licensees involved with the incident. If a responsible licensee is not
immediately known, general response procedures are outlined in MC 1301,
which include descriptions of which Federal, State or local entity would
be in charge under various circumstances. The purpose of MC 1302 is to
provide additional information and dose ranges/guidance if members of
the public are exposed to radiation. Also, there are additional
references in Attachment 1 regarding dose limits and radiation
exposures.

Some incidents may be considered abnormal occurrences. NRC submits an
abnormal occurrence report to Congress annually. The report, NUREG-0090,
\"Report to Congress on Abnormal Occurrences,\" includes the criteria
for abnormal occurrences. As part of an incident assessment involving
radiation exposure to members of the public, staff should also provide
information to Headquarters in accordance with current procedures for
submitting incidents considered possible Abnormal Occurrences.

06.01 Specific Guidance

The guidance in this MC is intended for incidents involving radioactive
material and not for routine, non-accident operations. The regulations
have specific limits for exposures to members of the public. The dose
limit for members of the public is given in Section 20.1301, \"Dose
limits for individual members of the public.\" Licensees are to conduct
operations so that the limits in Section 20.1301 are not exceeded for
members of the public. Currently, the public dose limit is 1 mSv (100
mrem). Section 20.1301(c) allows a licensee to permit visitors to an
individual who is undergoing medical treatment and cannot be released
under Section 35.75 to receive a dose not to exceed 5 mSv (500 mrem).
Note that any accidental exposures to members of the public may be
investigated, depending on the nature of the exposure, regardless of the
dose. However, exposures from routine operations, for example, when
material is disposed or released via effluents in accordance with the
regulations, would not be part of the scope of this MC.

If a licensee is required to report to the Commission, under Section
20.2202, \"Notification of incidents,\" and Section 20.2203, \"Reports
of exposures, radiation levels, and concentrations of radioactive
material exceeding the constraints or limits,\" the licensee is
responsible, in accordance with Section 19.13(d), for notifying and
providing an exposure report to any individuals that were exposed.
Depending on the circumstances of the incident, NRC may also notify the
affected individuals. For example, NRC might notify individual(s) if the
staff believes that the licensee response is not adequate, a responsible
licensee is not known at the time, or the staff wants to make sure the
individual(s) is(are) getting complete information. A list of the type
of information that should be included in any notification to a member
of the public is provided in Attachment 2. The actual doses to members
of the public are likely to be uncertain, especially during the initial
follow-up after an incident. Doses will usually be estimated in a dose
range or a maximum dose based on the circumstances of the incident. For
this reason, it is important to talk with exposed individuals because
this can help the staff in assessing the incident and in estimating the
dose.

Depending on the nature of the incident, further analysis of the
estimated dose may be necessary, using techniques such as bioassays,
whole body counting, and cytogenetic analysis, and should be considered
as the estimated doses approach 10-20 rem and up. In evaluating the need
for these types of analyses, staff should keep in mind that performing
the study can help reassure an individual who was exposed to radiation,
but it can also increase the anxiety about the exposure. Therefore,
staff should be sensitive to this and use their best judgement in
deciding when to recommend cytogenetic analysis. All cytogenetic
analyses should be coordinated with NMSS. NMSS is the lead for
coordinating testing through the testing laboratory and for obtaining
laboratory samples. Also note that other dose evaluations may need to be
coordinated with NMSS as well. Staff should follow current procedures
and guidelines.

Because people are often more anxious about radiation exposure than with
other hazards and risks, staff should be especially sensitive when
providing information about the incident and the estimated doses. Staff
must be as factual as possible about characterizing the dose based on
available information, without causing undue stress. Staff should not
discuss medical issues or provide medical advice to exposed individuals.
Instead, staff should refer individuals to their personal physicians.

06.02 Dose Ranges and Guidance

a.  [Dose Range from 0 to 1 mSv (100 mrem)]{.underline}

> Exposures with estimated doses in this range are within the public
> dose limit in 10 CFR Part 20. There are no regulatory requirements
> requiring reporting and notifications. Typically, no further action is
> needed, but the need for additional action must be evaluated based on
> the specific incident.

b.  [Dose Range from 1 mSv (100 mrem) to 50 mSv (5 rem)]{.underline}

> In cases when the estimated dose is between 1 and 50 mSv (100 mrem and
> 5 rem), the incident needs to be evaluated following the guidance in
> MC 1301 and MC 1360, \"Use of Physician and Scientific Consultants in
> the Medical Consultant Program.\" Staff will need to determine if a
> medical consultant is necessary. If a medical consultant is necessary,
> the medical consultant will determine whether or not a medical
> evaluation of exposed individuals is necessary. Staff should not
> discuss medical issues with an individual who was exposed, or provide
> medical advice. Instead, if an individual expresses concern or wishes
> additional information on possible medical affects, staff should refer
> the individual to his/her personal physician or to the NRC's medical
> consultant, if NRC has consulted with one to analyze the incident. If
> additional assistance is needed, NRC staff can call the Radiation
> Emergency Assistance Center/Training Site (REAC/TS). Information on
> REAC/TS is provided below in Attachment 3, \"Medical Assistance in
> Radiation Exposure Emergencies.\"

c.  [Dose Range Greater than 50 mSv (5 rem)]{.underline}

> For estimated doses that appear to be over 50 mSv (5 rem), assess the
> incident following the guidance in 2. above. If the calculated
> effective dose equivalent is more than 100 mSv (10 rem), further
> medical evaluation should be considered. Depending on the
> circumstances of the incident, a medical consultant may be brought in,
> the exposed individual will be referred to his/her personal physician,
> and/or REAC/TS may be consulted for additional guidance. At dose
> estimates in this range, and approaching 200 mSv (20 rem), the need
> for further analysis of the dose, as discussed above, should be
> evaluated.

d.  [Members of the Public Who Are Pregnant]{.underline}

> Information regarding the disclosure of pregnancy must be on a
> voluntary basis because of issues involving individual privacy. If, in
> the course of evaluating an incident involving exposures to members of
> the public, staff is informed by a female member of the public that
> she is pregnant, the follow-up action is essentially the same as in 1.
> through 3. above, extending the evaluation to look at the impact on
> the embryo/fetus. A medical consultant will probably be asked to
> evaluate the incident and the likely dose to the embryo/fetus. As
> stated previously, staff should not discuss medical issues or provide
> medical advice to the woman, but should refer her to her personal
> physician. Additional information on exposures to the embryo/fetus can
> be found in: 1) Regulatory Guide 8.13, \"Instruction Concerning
> Prenatal Radiation Exposure,\" and 2) National Council on Radiation
> Protection and Measurements Report No. 128, \"[Radionuclide Exposure
> of the Embryo/Fetus]{.underline}.\" Additionally, staff may get
> additional guidance if needed from REAC/TS.

ATTACHMENT 1

REFERENCES FOR DEVELOPING GUIDANCE ON RADIATION EXPOSURE

ASSOCIATED WITH INCIDENT FOLLOW-UP

The following references may assist staff with incident follow-up. These
references provide additional information on recommended dose limits and
radiation exposures.

I. [U.S. Nuclear Regulatory Commission]{.underline}

> 1\. NRC\'s current 10 CFR Part 20 establishes an explicit dose limit
> of 1 mSv (100 mrem) per calendar year, resulting from any licensed
> activity, to any individual in an unrestricted area, with 5 mSv (500
> mrem) per year allowed in certain temporary NRC pre-approved
> situations. Part 20 also establishes a dose limit of 5 mSv (500 mrem)
> to the embryo-fetus during the entire pregnancy for the occupational
> exposure of a declared pregnant woman. If the fetal dose has exceeded
> that level before the pregnancy is declared, other limits apply.
>
> 2\. NRC\'s Regulatory Guide 8.13, Revision 3, \"[Instruction
> Concerning Prenatal Radiation Exposure]{.underline},\" Revision 3,
> June 1999, provides occupationally exposed women with guidance on the
> biological effects of radiation on the embryo-fetus and whether or not
> to declare pregnancy.
>
> 3\. Regulatory Guide 8.29, \"Instruction concerning Risks from
> Occupational Radiation Exposure,\" Revision 1, February 1996,
> describes the information that licensees should provide to workers
> about health risks from occupational exposure.

II\. [NATIONAL COUNCIL ON RADIATION PROTECTION AND
MEASUREMENTS]{.underline}

> National Council on Radiation Protection and Measurements Report No.
> 128, \"[Radionuclide Exposure of the Embryo/Fetus]{.underline}\"
> provides information about radiation doses to the embryo/fetus and the
> effects of radionuclide exposure during pregnancy. The report includes
> information on approaches for estimating radiation doses to the
> embryo/fetus that result from radionuclide burdens or intakes by a
> pregnant woman that relate to medical, occupational and environmental
> sources of radioactive material. The dosimetry of external sources is
> beyond the scope of this report.

ATTACHMENT 2

[OUTLINE OF INFORMATION TO PROVIDE TO MEMBER OF PUBLIC]{.underline}

NOTE: THIS LETTER SHOULD NOT BE THE FIRST CONTACT TO AN INDIVIDUAL THAT
HE/SHE WAS EXPOSED TO RADIATION.

If the licensee is required to report to the Commission under Sections
20.2202 or 20.2203, the licensee is responsible, under Section 19.13(d),
for notifying and providing an exposure report to any individuals that
were exposed. Depending on the circumstances of the incident, NRC may
also notify the affected individuals, as discussed earlier in this MC.
Also, if NRC is on-site evaluating an incident, staff may have already
had interactions with members of the public who were, or were possibly,
exposed to radiation.

1.  State why the letter is being provided

    a.  Explain that NRC is conducting or has conducted an investigation
        of the incident

    b.  Explain that the individual is being notified because they
        received an exposure to radiation

    c.  Cite the regulations that require that they be notified

    d.  Provide details of the incident, such as location; any
        information about the incident; an estimate of the dose, along
        with an example for a comparison dose, i.e. chest x-ray is about
        10 mrem; etc.

2.  Refer individuals to their personal physician for any medical
    questions or concerns. Depending on the nature of the incident, NRC
    may request a medical consultant, who may evaluate individuals who
    were exposed. Refer to MC 1301 and MC 1360.

3.  Include information that the radiation dose information contained in
    this letter is exempt from disclosure in accordance with 10 CFR
    2.390(a). Include a copy of 10 CFR 2.390(a) in this notification.

4.  Include contact information for the primary NRC staff contact in
    case the individual or the individual's personal physician has
    questions or needs additional information.

5.  Signature: typically, the Regional Administrator or Division or
    Office level manager at Headquarters signs the letter.

ATTACHMENT 3

[MEDICAL ASSISTANCE IN RADIATION EXPOSURE EMERGENCIES]{.underline}

In the early stages of a response, NMSS may have to determine whether
medical evaluations are warranted for members of the public who are, or
who were potentially, exposed to radioactive materials. It should be
noted; however, that staff should not discuss medical issues with
members of the public or provide medical advice in cases dealing with an
exposure to radioactive material. Always refer any medical questions or
concerns about biological effects of radiation exposure to a physician.
For some incidents, a medical consultant may be used (see MC 1301 and MC
1360) to evaluate exposures to members of the public. Also, the
Radiation Emergency Assistance Center/Training Site (REAC/TS) is a
source of information on radiological effects.

If medical advice is needed, or if the exposed person\'s physician is
not trained in the effects of radiation exposure and the treatment of
such effects, and wants additional information or guidance, call or
refer the physician to the Radiation Emergency Assistance
Center/Training Site (REAC/TS). REAC/TS is a U.S. Department of Energy
(DOE) response asset that maintains a radiological emergency response
team consisting of physicians, nurses, health physicists, coordinators,
and necessary support personnel. It is on 24-hour call to provide
first-line responders with consultative or direct medical and
radiological assistance at the REAC/TS facility or at the accident site.
They have expertise in, and are equipped to conduct: (1) medical and
radiological triage; (2) decontamination procedures and therapies for
external contamination and internally deposited radionuclides, including
diethylene triamine pentaacetic acid (DPTA) chelation therapy; (3)
diagnostic and prognostic assessment of radiation-induced injuries; and
(4) radiation dose estimates by methods that include cytogenetic
analysis, bioassay, and in-vivo counting.[^1] The REAC/TS emergency
telephone number is 1-865-576-1005 (ask for REAC/TS). If the telephone
numbers have changed, the NRC Headquarters Operations Center should be
called for the new number at (301) 816-5100.

END

[^1]: REAC/TS website: www.orau.gov/reacts/resources.htm