# Presentation: 921487

## Protective Action Guides(PAGs) Update

- SCAPA Meeting May 8, 2008
- Edward Tupin
- Radiation Protection Division

## Overview

- Milestones achieved since last year
- PAGs status and next steps
- Comparing 1992 and 2008 PAGs
- DHS RDD-IND PAG document
- FAQs development
- Outreach strategies

## Milestones Achieved Since Last Year

## Milestones Achieved Since Last Year

- New FRMAC-generated tables (9/06-2/07)
- Dose conversion factors (DCF) and derived response levels (DRL)
- ICRP 60 series basis
- Match FRMAC tools
- Four-hour workshop development (3/07-5/07)
- Refresher on PAGs, what is changing in the draft revision, calculation examples
- Presented at NREP and CRCPD meetings
- Scripted presentation online

**Notes:**
Remember a DRL is a measurable amount where the PAG is likely to be exceeded for a specific nuclide.  A DCF is a factor to multiply environmental measurements by to get a dose number.
The reason it’s neat the EPA numbers and the FRMAC tools match is it means the states are more comfortable working from both the Manual and the FRMAC tools – the goal in the future will be to keep our Manual tables current with ICRP...
The scripted workshop presentation is on the web (try searching for it!)  www.epa.gov/radiation/rert/pags.html

## Milestones (continued)

- Resolution of key issues (1/07-3/07)
- Benchmark table footnote
- Worker health and safety language
- Optimization details or not
- IND Appendix or not
- Interagency showstoppers review (4/07-5/07)
- Comments from DOE and NRC:
- Deletion of thyroid-driven evacuation
- OSHA worker health and safety language edits
- Worker guides TEDE with non-NPP nuclides

**Notes:**
*There was a bit of a contentious footnote regarding the table of possible benchmarks or starting points for the cleanup optimization process (from NRC, DOE, EPA) --- the footnote talked about CERCLA/Superfund and it took some long discussions to get everyone to agree it should be deleted.
OSHA provided a lot of new radiation emergency worker language for the DHS RDD/IND PAG document, and since it differed in wording (but not overall intent) from the 1992 PAGs language, we spent a lot of time editing that language.
We heard from many users of the DHS RDD/IND PAG document (where we got our Late Phase content – the optimization approach) that more information (or a cleanup number please?) would be helpful to implement the optimization thing.  We opted to stay with a process, but not provide too many details.
Several commenters remarked the DHS guide didn’t do a good job addressing the unique problems with IND response in the first few hours in particular – we agree!
Showstoppers from the multi-agency PAGs Subcommittee were few: We deleted the “thyroid and skin 5 and 50 times higher, respectively” footnote from the evacuation/sheltering table, declined to do further editing on the worker health and safety language, and discussed how to deal with high alpha or beta contributions from non-NPP source terms (but did not add any new guidance to the PAGs Manual, yet at least).

## Milestones (continued)

- Showstopper resolution (6/07-7/07)
- Tiered the comments
- Discussed substantive issues with Subcommittee
- Final, final, final federal review
- Completed in Aug. 2007

**Notes:**
Things that appeared as ‘showstoppers’ among the multi-agency PAGs Subcommittee are being highlighted in the Federal Register notice when the revised PAGs are published for public review and comment.

## Status and Next Steps

## Where Are They Now?

- OMB Review
- Submitted to OMB in November 2007
- Federal Register Notice of Availability
- Publication for review and comment
- 60-day comment period

**Notes:**
Our front office is treating this document as a regulation and putting it through the reviews as if it were.  We are really not sure how long the PAGs will be in review at OMB, nor how long it will take to get the Administrator’s signature once we have it back from OMB!

## What Next?

- Write response to comments document
- Incorporate comments
- Federal review(s)
- Finalize, publish, and print
- Continue outreach

**Notes:**
I hope we can finalize the Manual quickly after responding to the comments.  Outreach will continue forever!

## Future PAG Manual Possibilities

- PAGs Volume 1 and 2
- Vol. 1 -- user friendly summary
- Vol. 2 -- detailed technical basis
- Guidance on how to develop turnbacks
- Mission- and capability- specific
- More detail on how to do Optimization

**Notes:**
We have gotten many good suggestions on how to improve the PAGs Manual  -- like providing a more concise volume to use in emergencies, with the technical basis being reserved in a second volume.  (Yes, the PAGs Manual revision is 300 pages in a small font!)
We also might in the future add better information about worker protection, in the form of turnback levels, and there is still discussion of adding more optimization detail.

## Comparing 1992 and 2008 PAGs

## 1992

Evacuation/Shelter 1-5 rem (10-50 mSv)
KI 25 rem (250 mSv) thyroid dose (adult)
Worker 5, 10, 25+ rem (50, 100, 250+ mSv) 

- 1992
- Evacuation/Shelter 1-5 rem (10-50 mSv)
- KI 25 rem (250 mSv) thyroid dose (adult)
- Worker 5, 10, 25+ rem (50, 100, 250+ mSv)

- 2008
- Evacuation/Shelter 1-5 rem (10-50 mSv) *
- KI  5 rem (50 mSv) thyroid dose (child)
- Worker 5, 10, 25+ rem (50, 100, 250+ mSv)
- * no more skin/thyroid footnote

**Notes:**
These slides are from the 4-hour workshop presentation.  Note the KI threshold is lower, a simplification of the FDA’s age, threshold and dosage-specific guidance because it might be hard to implement in an emergency, giving different aged people KI at different projected radiation doses AND in different milligram amounts!
Worker guides are the same numbers but with OSHA language from DHS RDD-IND document.
Keep in mind these 2008 items are all just proposed, and not yet out for public review and comment.  They are subject to change.

## Intermediate Phase

- 1992
- Relocate population
- ≥ 2 rem projected dose in the first year
- ≥ 0.5 rem projected dose in subsequent years
- ≥ 5 rem projected dose over  50 years
- Apply dose reduction techniques
-  < 2 rem (20 mSv)
- Food PAG (1982)
- Drinking Water PAG (promised)

- 2008
- Relocate population
- ≥ 2 rem projected dose in the first year
- ≥ 0.5 rem projected dose in subsequent years
- Apply dose reduction techniques
- < 2 rem (20 mSv)
- Food (1998)
- Drinking water
- 0.5 rem (5 mSv) first year CEDE

**Notes:**
Here the big difference is that per the DHS working group, we are getting rid of the 5 rem over 50 years relocation PAG.  Also, the Food PAG is updated and we added a new drinking water PAG.

## FDA Food PAGs

- 1992
- 1982 FDA guidance
- NCRP 39 methodology
- Preventive PAG 0.5 rem whole body and 1.5 rem thyroid
- Emergency PAG 10 times higher, depends on impact
- Dose level only, no activity levels provided

- 2008
- 1998 FDA guidance
- ICRP 56 & NRPB methodology
- One set of PAGs:
- 0.5 rem whole body dose or
- 5 rem to most exposed organ or tissue in the first year
- Derived Intervention Level (DIL) calculated for 28 radionuclides

**Notes:**
FDA – Food and Drug Administration
NCRP – National Council on Radiation Protection and Measurements
ICRP – International Commission on Radiological Protection
NRPB – National Radiological Protection Board
Note the FDA Food PAG is 0.5 rem for the first year only (like our water pag!)

## Drinking Water PAG

- 1992
- Promised

- 2008
- Applicable to drinking water from any source
- EPA Safe Drinking Water Act levels after first year
- Doses will be greatly reduced in subsequent years
- ‘Bridging language’ to explain FDA Food PAG (includes water) and EPA Water PAG relationship

## Late Phase Guidance

- 1992
- Promised

- 2008
- DHS RDD/IND Consequence Management Workgroup drafted current guidance
- January 3, 2006, *Federal Register* notice
- All radiological events covered (e.g., nuclear plant, dirty bomb, improvised nuke)
-  Optimization

## DHS RDD-IND PAG Document

## DHS Document Finalization

- Multi-agency workgroup meetings
- Response to comments
- Public comments
- Federal comments
- Minor changes to the document (next slide)
- OMB review
- Deputy Secretary-level approvals
- Final DHS document published in FR

**Notes:**
The Final DHS RDD/IND PAG document is at OMB now for review, then once it goes through some approvals it will be published in the Federal Register as final.  The final version explains how the RDD/IND guidance and Optimization approach are being incorporated into the forthcoming EPA PAGs Manual revision, so the DHS guidance will essentially go away when we publish our EPA PAGs Manual.

## Changes to the DHS document

- Enhance guidance for INDs
- Future effort with Office of Science & Technology Policy lead
- Public, workers, planners need guidance for first few hours
- Incorporate ICS/NIMS language
- DHS document drafted prior to NRP (now NRF)
- Technical and stakeholder working groups work under IC/UC
- Edit worker health and safety language
- Not adopting NCRP’s 50 rem for lifesaving
- Clearly state relationship to EPA PAG Manual
- DHS document to be incorporated into EPA Manual

## Blending DHS and EPA PAGs	

- Incorporate DHS changes into EPA PAG Manual after the public comment period
- New IND guidance also will be incorporated when it is finished
- FAQs and outreach to be done by EPA!

**Notes:**
There is no work underway on IND guidance, that we know of.  DHS’s Office of Health Affairs is working on public messaging for the first few post-detonation hours, though.
We are looking at it as an opportunity to be the ones providing the outreach and training on PAGs – but we need all our federal partners to help us out and spread the word about continuing to use the 1992 PAGs and providing comments on the new revision when it comes out.

## Outreach Strategies

## Outreach Strategies

- Improved PAGs web page – with timeline
- 	_www.epa.gov/radiation/rert/pags.htm_
- New FAQs under development
- Reach out to locals through emergency response, homeland security conferences

**Notes:**
NFPA National Fire Protection Association (NFPA 471 Response to Hazardous Materials Incidents)
IAFC International Association of Fire Chiefs has a Haz Mat response teams conference
IAEM International Association of Emergency Managers
Outreach methods can include road shows with the four hour workshops, train the trainer modules, webcasts, DVDs...

## Outreach Strategies

- Four- hour workshops at two conferences (NREP and CRCPD last April and May)
- What PAGs do and don’t do
- Refresher on how to use the Manual
- Feedback on updates and revision
- The scripted presentation is available for you to use
- On the PAGs web page

**Notes:**
Outreach methods can include road shows with the four hour workshops, train the trainer modules, webcasts, DVDs...
We are developing a PAGs web-based course now, using the four-hour workshop as content.
NFPA National Fire Protection Association (NFPA 471 Response to Hazardous Materials Incidents)
IAFC International Association of Fire Chiefs has a Haz Mat response teams conference
IAEM International Association of Emergency Managers

## Outreach So Far...

- National Radiological Emergency Preparedness Conference
- Conference of Radiation Control Program Directors
- Baltimore-Washington Chapter of the Health Physics Society
- Organization of Agreement States
- Office of Air and Radiation Assistant Administrators (x2)
- Tom Dunne, Office of Homeland Security
- Office of General Counsel (ARLO and SWERLO)
- Japan Atomic Energy Agency and Nuclear Security Agency
- Interagency Steering Committee on Radiation Standards
- T4 National Planning Seminar
- Federal Radiological Preparedness Coordinating Committee (x7)
- Armed Forces Radiobiology Research Institute Medical Effects of Ionizing Radiation Course
- Superfund National Radiation Meeting
- OSC Readiness
- Association of State and Territorial Health Officials

**Notes:**
This is not a complete list!

## Fabulous Fact Sheet

**Notes:**
We also brought paper copies to this meeting.  We are always looking for feedback on whether this fact sheet provides the information you need...

## Future Outreach Ideas

- Train the trainer modules
- Webcasts
- DVDs...

**Notes:**
Does anyone have another idea of good ways to reach the PAGs users effectively?

## FAQs Development

## Frequently Asked Questions

- Developing FAQs for PAGs web site
- Includes FAQs about DHS RDD-IND document
- Adding questions received at outreaches

**Notes:**
FAQs are a great place to say more than we can or should say in the Manual itself – we have more freedom to clarify, provide examples, and provide further guidance than exists in the Manual.  Also, FAQs don’t require the same level of review – and with DHS giving us the green light to do their outreach and FAQs for the RDD-IND document, we can help more people get more out of the PAGs and not make the book bigger at the same time!

## Activity: FAQs

- Activity:
- In teams of two people each, think of two FAQs and write them on cards
- Answers not required!
- Topic ideas:
- Pets, KI, reentry, return, decon runoff, dose modeling, SI units, packaged foods, Advisory Team, Federal Guidance, hot zone, public messages, contamination spread, KI for workers, turnback levels, ‘valuable property,’ OSHA enforcement
- Share a few of them

**Notes:**
Partner up with your neighbor – two per team.
Five minutes for thinking and discussing – two questions per team.

## How to Stay Sharp

- Web site
- _www.epa.gov/radiation_
- Give outreach presentations
- You don’t even have to write the presentation – you can use the one on the web page, or edit it to meet your needs!
- Exercise participation
- Nuclear power plant exercise evaluator or observer

**Notes:**
Ways to stay in touch with the PAGs... 

## Questions and Comments