[ RadSafe ] Unacceptable Reason For A Dose

Perle, Sandy sperle at mirion.com
Sun Jun 19 22:22:24 CDT 2011

Excellent synopsis Dewey!



Sander C. Perle
Mirion Technologies
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On 6/19/11 6:31 AM, "Thompson, Dewey L" <DThompson3 at ameren.com> wrote:

>Steve, Jeff
> I read the article linked, as well as Steve¹s comments, and wish to
>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 ³as clear², 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 ³There were no KI Tablets stored in the Control
>Room².  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
>forwardŠŠŠŠŠ(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;
>³TEPCO 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 doses².
>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 Steve¹s 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 don¹t.  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 it¹s 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 ³Emergency Safety
>Features Actuation System².
>I would like to know more about similar requirements in the Japanese
>Of course in any core release, the first thing out is ³non reactive
>gasses² (noble gas), the second thing would be the ³reactive gasses²
>(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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