[ RadSafe ] Unacceptable Reason For A Dose

Thompson, Dewey L DThompson3 at ameren.com
Sun Jun 19 08:31:01 CDT 2011

Steve, Jeff

 I read the article linked, as well as Steve’s comments, and wish to comment. 

First, the article.  In the US regulatory structure, it would not be acceptable to wear a respirator with temple bar eyeglasses.  

Per OSHA 29.CFR.1910.134, it is not allowed, and there is case law and OSHA rulings that support this.  For protection against radioactive materials, it is not “as clear”, but I think meets the same end.  10.CFR.1703.b.(3) requires a user seal check prior to each use, which would preclude temple bar eyeglasses.  Every manufacturer of a tight fitting respirator has to supply vision correction with the NIOSH approval process.  

IF the article is accurate (and that IF is questionable), it raises several questions to differences in regulatory structure and regulatory compliance between the US program and the Japanese program.  

The article states that “There were no KI Tablets stored in the Control Room”.  I know that at every US Nuclear Plant I am familiar with, there are KI tablets stored for Control Room personnel use.  

Also, there are requirements in 10.CFR.50 Appendix R for Control Room habitability.  For example, you have to supply not only filter respirators, but air supplied respirators with at least six hours of reserve air available.  

It would seem to me that TEPCO is being quite responsive now about the issue, intending to provide proper respiratory protection equipment going forward……………(yes, your sarcasm meter should at least twitch now). 

The article states that the worker took off their facemask to eat on station (at the Control Board).  Although unthinkable for anyone grown up under the US regulatory structure, I can see it.  Grab a drink and sandwich while in a high airborne area?  The main part of any uptake was from the mask not sealing, not from removing the respirator for two minutes for the sandwich. 

The article states that TEPCO is upgrading their dosimeter equipment; “TEPCO said it had taken additional steps to monitor the radiation exposure of workers at the plant, such as having them wear dosimeters while on duty that automatically record radiation doses”. 

This makes me wonder what dosimeters they were using.  Were they using ANY self reading dosimeters for Secondary Monitoring?  Wow.  

While Secondary Monitoring devices would generally NOT be required inside of control rooms at US facilities, again, the emergency plan would have to provide for such. 

As to Steve’s comments: The control room is generally NOT a Radiological Controlled Area, and in most US facilities one would not have to have a radiation dosimeter (primary or secondary) to be physically in the control room.  

Some US facilities badge everyone inside the Protected Area with a Primary Monitoring Device, however most don’t.  This has been part of ongoing cost reduction processes at most plants (why badge clerks that never go into the Radiological Controlled Area)?  

The regulations do not require monitoring if the expected dose is less than a fraction of the limit (I think it’s 10%).  

The Required Staffing (On Watch) Control Room Operators DO require Primary Monitoring Devices, and do require access to Secondary (self reading) Monitoring Devices. 

The Required Staffing (On Watch) Control Room Operators also do require access to respirators, and as such must be qualified to wear them, as I discussed above, that means they have to be fit tested to determine the proper mask size and be supplied with the proper vision correction (if the Control Room Operators license requires vision correction).  

I have personal experience with this, during NRC inspections, it is routine for an Inspector to come into the facility and check to ensure that the Appendix R Respirators are properly implemented (personnel have access to the correct size mask, and have their vision correction in the Control Room  and can locate it immediately). 

Your question about the nature of the uptake is on target.  Again, at US installations, there are quite a few rules on the habitability of the Control Room.  Facility design has closed circuit filtered ventilation systems, and ventilation isolation is part of the “Emergency Safety Features Actuation System”.  

I would like to know more about similar requirements in the Japanese program.  

Of course in any core release, the first thing out is “non reactive gasses” (noble gas), the second thing would be the “reactive gasses” (iodine and such).  

Since the reactive gasses actually uptake to the body, their dose fractions are much higher than for the non reactive gasses.  It sounds as if the Control Room Isolation at the Fukushima installation was not as robust as we in the US are used to. 

FWIW Dewey 
Sent using BlackBerry

----- Original Message -----
From: radsafe-bounces at health.phys.iit.edu <radsafe-bounces at health.phys.iit.edu>
To: The International Radiation Protection (Health Physics) Mailing List <radsafe at agni.phys.iit.edu>
Sent: Sun Jun 19 02:43:29 2011
Subject: Re: [ RadSafe ] Unacceptable Reason For A Dose

June 18

         This article doesn't make a particle of sense.

         When someone is hired to work in a reactor isn't he 
automatically issued a respirator?  Seems to me he should be.  If the 
employee wears eyeglasses shouldn't he be issued eyeglasses that fit 
under a respirator, or a respirator that will accommodate the eyeglasses?

         To what were these two workers exposed?  The article mumbles 
something about potassium iodide tablets but says nothing about 
radioactive iodine.

         The article says, "The men were so busy in the control 
rooms, they ate at their posts, which required removing their 
protective masks."  Isn't a control room a rad area?  If so, why were 
they eating in a rad area?  What is the point of wearing a respirator 
if you're going to take it off to eat?

         The article also says, "Tepco said it had taken additional 
steps to monitor the radiation exposure of workers at the plant, such 
as having them wear dosimeters while on duty that automatically 
record radiation doses."  About 15 years ago I worked on an UMTRA 
project which was barely above background and we wore dosimeters 
(TLD's) whenever we were on the site.  Why aren't the Tepco employees 
already wearing dosimeters all the time?

Steven Dapra

At 08:12 PM 6/18/2011, you wrote:
>I am sorry but this is inexcusable. You have to fit respirators, 
>before allowing someone into an airborne contamination area.

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