United States       Air And         EPA 520/1-89-032
             Environmental Protection    Radiation         September 1989
             Agency         (ANR-459)
 &EPA      Protective Action Guides
             For Accidentally Contaminated
             Water And Food

             Proceedings Of A Workshop
             Held In Washington, DC
             —September 1989

          WATER AND FOOD


               SEPTEMBER 1989
               Office of Radiation Programs
             U.S. Environmental Protection Agency
               Washington, D C 20460



Introduction to Workshop	  1

List of Workshop Participants and Working Group Assignments	  3

Workshop Agenda	11

Speakers' Papers 	13

      Overview of Workshop Objectives, by Joe E. Logsdon  	15

      Experience in Exercise Evaluations, by George E. Bickerton	19

      Existing Ingestion Guidance: Problems and Recommendations,
      by Robert Mooney, Gordon L. Ziegler, and Donald S. Peterson  	27

      Concerns for the Human Element in Implementing Protective
      Action Guides,  by Aby Mohseni, Aileen Jeffries, and Paul Fedorchak   	35

      Problems Related to Public Perceptions of Radiological Emergency
      Planning and Response, by Margaret A. Reilly	43

      International Commerce and the Chernobyl Experience, by Ronald (Skip)
      Engel, Victor Randecker, and Wesley Johnson  	47

      International Guidance Activities, by Allan C.B. Richardson	55

      Economic Criteria for Implementing PAGs for Food, by Byron M.  Bunger  .... 61

Submitted Papers	69

      Issues Regarding the U.S. F.DA. Protective Action Guidelines and Derived
      Response Levels for Human Food and Animal Feed, by Bruce Denney	71

      Concerns in Assessing Radiological Releases to a Major Estuary,
      by Leslie P.  Foldesi  	73

       The Ingestion Pathway Comments and Issues, by Lawrence J. McDonnell  .... 75

       Implications of the Chernobyl Accident for Protective Action  Guidance,
       by Charles W. Miller, Andrea J. Pepper	77

       PAGS - Public Perception and Acceptance, by Robert M. Quillin  	81

       New Jersey's Experience with Implementing Protective Action  Guides
       During the 1988 Salem Ingestion Pathway Exercise,  by Duncan White 	83

Working Group Summaries	87

       Working Group One
       For what Protective Actions and Situations are Ingestion PAGs Needed?	89

       Working Group Two
       What Considerations should be Evaluated in the Process of Selecting
       PAG Values for Ingestion Pathways?	93

       Working Group Three
       What Considerations are Important for the Development of Guidance
       for Protection from Contaminated Water?	99

       Working Group Four
       What Guidance is Needed to Support Implementation of PAGs for
       Ingestion Exposure Pathways?	103

Appendices	109

       A Proposed FAO/WHO Levels for Radionuclide Contamination of Food
          in International Trade Following an Accidental Nuclear Release	Ill

       B.  Accident in the Southern Urals on 29 September, 1957,
          by B.V. Nikipelov, G.N. Romanov, L.A. Buldakov, N.S. Babaev,
          Yu.B. Kholina and E.I. Mikerin  	119


       The Workshop on Protective Action Guides for Accidentally Contaminated Water and Food
was designed for those who have experience in planning for and responding to ingestion exposure
scenarios.   The  objective  was  to  identify  and discuss all  of the issues,  problems,  relevant
experiences, and  research that  should be  considered in the  development of Protective Action
Guides  (PAGs) for water and  food.  The  workshop was not designed to produce consensus
conclusions or recommendations, but rather provide a forum for discussion of problems, debate of
solutions, and exchange of ideas.

       The workshop consisted  of two plenary sessions  and one working group session.  This first
plenary session consisted of a variety of speakers with State and Federal perspectives on the issues
and  it provided background information for the working group sessions.   The second plenary
session consisted of presentations and discussions from the working groups, which met in sessions
to address four different issues.

       The workshop proved to be very helpful for those responsible for developing PAGs for the
ingestion exposure pathways.  The Environmental Protection Agency (EPA), the Department of
Agriculture (USDA) and the Conference of Radiation Control Program Directors (CRCPD) were
cosponsors of this event.  The planning committee for the workshop consisted of Aubrey Godwin
from the CRCPD, George Bickerton and Ronald (Skip) Engel from USDA, and Allan Richardson
and Joe Logsdon from EPA.  They were responsible for the organization of the workshop and the
selection of key participants, speakers, and session leaders.  Cheryl Malina from EPA had primary
responsibility for  executing the  plans  of the workshop.  In addition to participants  from the
sponsoring organizations, representatives from  the Health Physics Society, the  Food and  Drug
Administration (FDA), the Department of Energy (DOE), the Nuclear Regulatory Commission
(NRC), and the Federal Emergency Management Agency (FEMA) were in attendance.

       This workshop addressed the roles and responsibilities for the development of PAGs.  EPA
has the responsibility for  development  of PAGs, except in the case of PAGs for food for which
the  responsibility  is  shared with  FDA.   EPA  participated  in  the  development  of the
recommendations on PAGs for food and animal feed that FDA published in 1982, which are under
revision.  In the absence of PAGs specifically  for water, past practice has been for EPA to provide
ad. hoc. guidance  when needed.  EPA will be developing guidance for drinking water during the
next  fiscal year and, therefore,  one of the  working groups  at the workshop  was  devoted to
considering issues  related  to PAGs for  water.  It has not yet been determined whether PAGs for
drinking water should be  separate or included with those for food.  These issues were discussed
at the workshop and the recommendations included in this proceedings document will be used a
resource in the development of  PAGs  for the ingestion pathway.

       For more information or  additional copies of this document contact Joe E. Logsdon, at the
Guides and Criteria Branch, Office of Radiation  Programs, EPA, 401 M Street, S.W. (ANR-460),
Washington, D.C.   20460, (202)  475-9620.

Mr. William Belanger
Radiation Representative
U.S. Environmental Protection Agency ~ Region
841 Chestnut Street (3AH14)
Philadelphia, PA 19107
(215) 597-4084
Mr. George Bickerton
Director, Office of Emergency Planning
Food Safety and Inspection Service
U.S. Department of Agriculture, Room 2940-S
14th and Independence Streets, S.W.
Washington, D.C.  20250
(202) 475-3683
Mr. Byron Bunger
Economics and Control Engineering Branch
Office of Radiation Programs
U.S. Environmental Protection Agency
401 M Street, S.W. (ANR-461)
Washington, D.C.  20460
(202) 475-9644
Mr. Bruce Burnett (Observer)
Senior Engineer
Food  and Drug Administration (HFZ-60)
5600 Fishers Lane
Rockville, MD  20857
(301)  443-2850
Mr. Robert Conley
Emergency Programs Specialist
Office of Emergency Planning
Food Safety and Inspection Service
U.S. Department of Agriculture
14th and Independence Streets, S.W.
Washington, D.C. 20250
(202) 475-3683
Mr. William C. Cunningham (Observer)
Research Chemist
Food and Drug Administration (HFF-426)
5600 Fishers Lane
Rockville, MD  20857
(301) 975-6271
Mr. Lawrence B. Czech
Assistant Director for Technical Services
New York State Emergency Management Office
State Campus Building, No. 22
Albany, NY  12226-5000
(518) 457-8909
Mr. Bruce Denney
Health Physicist
Minnesota Department of Health
717 S.E. Delaware Street
P.O. Box 9441
Minneapolis, MN 55440
(612) 623-5350
Mr. Doug Collins
Chief, Emergency Preparedness
  and Radiation Protection Branch
Nuclear Regulatory Commission
101 Marietta Street
Atlanta, GA 30323
(404) 331-5584 FTS 242-5584
Dr. Ronald E. (Skip) Engel
Assistant to the Administrator
International  Scientific Liaison
Food Safety and Inspection Service
U.S. Department of Agriculture
14th and Independence Streets, S.W. - Room 3165
Washington, D.C. 20250
(202) 447-2326

Mr. Leslie Foldesi
Director, Bureau of Radiological Health
Virginia Department of Health
109 Governor Street
Richmond, VA  23219
(804) 786-5932
 Mr. S.W. Felix Fong
 Chief, Nuclear Facility and Environmental
   Radiation Surveillance Section
 North Carolina Division of Radiation Protection
 Department of Human Resources
.701 Barbour Drive
 Raleigh, NC  27603
 (919) 733-4283
 Mr. Aubrey Godwin
 Director, Radiological Health Branch
 Alabama Department of Public Health
 State Office Building - Room 510
 434 Monroe Street
 Montgomery, AL  36130-1701
 (205) 261-5315
Mr. Charles W. High
Emergency Planning Coordinator
Bureau of Radiation Protection
Pennsylvania Department of Environmental Resourc
P.O. Box 2063
Harrisburg, PA 17120
(717) 787-3479
Mr. Joe Keller
Fellow Scientist
Idaho National Engineering Lab
P.O. Box 4000
Idaho Falls, ID  83403
(208) 526-2123
Mr. Joe Logsdon
Certified Health Physicist
Guides and Criteria Branch
Office of Radiation Programs
U.S. Environmental Protection Agency
401 M Street, S.W. (ANR-460)
Washington, D.C.  20460
(202) 475-9620
Mr. Bernis O. Hannah
Director, Emergency Planning and Environmental
   Monitoring Section
Radiological Health Branch
Alabama Department of Public Health
State Office Building ~ Room 510
434 Monroe Street
Montgomery, AL  36130-1701
(205) 242-5315
Mr. Thomas Heim
(Conference Management Support)
ICF Incorporated
9300 Lee Highway, #446
Fairfax, VA  22031
(703)  934-3791
Ms. Cheryl Malina
Emergency Programs Specialist
Guides and Criteria  Branch
Office of Radiation Programs
U.S. Environmental Protection Agency
401 M Street, S.W. (ANR-460)
Washington, D.C. 20460
(202) 475-9620
Mr. Dave McCormack
P.O. Box 999
Mail Stop K3-54
Richland, WA 99352
(509) 375-2429

Mr. Lawrence McDonnell
Staff Scientist
State of Wisconsin Radiation Protection Council
5708 Odana Road
Madison, WI  53719
(608) 273-6437
Mr. Robert Mooney
Head, Environmental Radiation Section
Division of Radiation Protection
Department of Health (MS LE-13)
Olympia, WA 98504
(206) 586-3303
Mr. Thomas McKenna
Incident Response Branch
Nuclear Regulatory Commission
Washington, D.C 20555
(301) 492-4184
Mr. Gary W. McNutt
Radiological Health Analyst
Missouri Department of Health
P.O. Box 570
1730 E. Elm Street
Jefferson City, MO 65109
(314) 751-6083
Mr. Charles W. Miller
Chief, Division of Planning and Analysis
Illinois Department of Nuclear Safety
1035  Outer Park Drive
Springfield, IL 62704
(217) 785-9889
Mr. Michael H. Mobley
Director, Division of Radiological Health
150 9th Avenue, North
Nashville, TN  37219-5404
(615) 741-7812
Mr. Aby Mohseni
Division of Radiation Protection
Department of Health (MS LE-13)
217 Pine Street, Suite 220
Seattle,  WA  98101-1549
(206) 464-7274
Mr. T. Pearce O'Kelly
Director, Division of Electronic Products
Bureau of Radiological Health
South Carolina Department of Health and
   Environmental Control
2600 Bull Street
Columbia, S.C.  29201
(803) 734-4700
Ms. Andrea J. Pepper
Emergency Planning Section Head
Illinois Department of Nuclear Safety
1035 Outer Park Drive
Springfield, IL 62704
(217)  785-9890
Mr. Robert M. Quillin
Director, Radiation Control Division
Colorado Department of Health
4210 East llth Avenue
Denver, CO 80220
(303) 331-8480
Mr. Victor Randecker
Environmental Engineer
Food Safety and Inspection Service
U.S. Department of Agriculture
300 12th Street, S.W.   Room 402
Washington, D.C.  20250
(202) 447-2428

Mr. Thomas Reavey
Environmental Scientist
Guides and Criteria Branch
Office of Radiation Programs
U.S. Environmental Protection Agency
401 M Street, S.W. (ANR-460)
Washington, D.C.  20460
(202) 475-9620
Ms. Margaret A. Reilly
Chief, Division of Environmental Radiation
Bureau of Radiation Protection
Pennsylvania Department of Environmental Resources
P.O. Box 2063
Harrisburg, PA  17120
(717) 787-3479
Mr. Allan Richardson
Chief, Guides and Criteria Branch
Office of Radiation Programs
U.S. Environmental Protection Agency
401 M Street, S.W. (ANR-460)
Washington, D.C. 20460
(202) 475-9620
Dr. Karim Rimawi
Bureau of Environmental Radiation Protection
New York State Department of Health
Two University Place
Albany, NY  12203
(518) 458-6461
Mr. Dave Rohrer
Health Physicist
Office of Safety,  Policy and Standards
U.S. Department of Energy (EH352)
Washington, D.C. 20545
(301) 353-5609
 Mr. Robert J. Schell
 Nuclear Engineer Specialist
 State of Maine Radiation Control Program
 State House Station 10
 Augusta, ME  04333
 (207) 289-5676
Mr. Gail Schmidt (Observer)
Certified Health Physicist
Food and Drug Administration
10025 Lloyd Road
Potomac, MD 20854
(301) 424-3151
Dr. Bernard Shleien
Representative, Health Physics Society
Scinta Inc.
2421 Homestead Drive
Silver Spring, MD  20902
(301) 593-9478
Mr. Peter Stang
Health Physicist
Office of Emergency Planning
Food and Safety Inspection Service
U.S. Department of Agriculture
Washington, D.C.  20250
Mr. Marlow Stangler
Emergency Management Specialist
Federal Emergency Management Agency
500 C Street, S.W.
Washington, D.C. 20472
(202) 646-2856
Mr. Stephen Stasolla
Section Supervisor
New Jersey Department of Environmental Protection
Bureau of Nuclear Engineering (CN-415)
Trenton, NJ 08625
(609) 987-2032

Mr. Allan C. Tapert
Bureau of Environmental Health
Office of Radiation Control
Cooper Building, Capitol Square
P.O. Box 637
Dover, DE 19903
(302) 736-4731
Ms. E. Archer Taylor
(Conference Management Support)
ICF Incorporated
9300 Lee Highway
Fairfax, VA 22031
(703)  934-3168
Mr. Kenneth L. Travis
State and Federal Legislation Committee
Health Physics Society
8123 Truro Court
Springfield, VA  22152
(703) 644-5655
Mr. Duncan White
Health Physicist
Bureau of Nuclear Engineering (CN-415)
New Jersey Department of Environmental Protection
Trenton, NJ  08625
(609) 987-2032
Mr. Vern Wingert
Emergency Management Specialist
Federal Emergency Management Agency
500 C Street, S.W.
Washington, D.C.  20472
(202) 646-2872


                        WORKING GROUP ASSIGNMENTS

  Bruce Denney: Chairman

  George Bickerton
  Bruce Burnett
  Douglas Collins
  Lawrence Czech
  Skip Engel
  Lawrence McDonnell
  Pearce O'Kelly
  Allan Richardson
  Dave Rohrer

Charles Miller: Chairman

Byron Bunger
Joe Logsdon
Gary McNutt
Robert Quillin
Karim Rimawi
Bernard Schleien
Gail Schmidt
Peter Stang
Kenneth Travis

  Michael Mobley: Chairman

  George Brown
  Leslie Foldesi
  Aubrey Godwin
  Charles High
  Dave McCormack
  Thomas McKenna
  Aby Mohseni
  Thomas Reavey
  Margaret Reilly
  Allan Tapert

Duncan White: Chairman

William Belanger
William Cunningham
Felix Fong
Robert Mooney
Andrea Pepper
Robert Schell
Marlow Stangler
Stephen Stasolla
Vern Wingert


                            Pan American Health Organization
                              525 Twenty-Third Street N.W.
                                    Washington, DC

                                 September 13-14, 1989


  Workshop Objective

  The  principal objective  was  to identify and discuss  issues that require consideration in  the
  development of recommendations to protect the public from accidentally contaminated water  and
  food.  It was not expected at this workshop that issues would be resolved or guidance developed.

  September 13, 1989

                     Plenary Session

  8:30 to 8:45         Registration (ICF)

  8:45 to 9:00         Welcome and Introduction ~ Aubrey Godwin, CRCPD

  9:00 to 9:20         Overview of Workshop Objectives ~ Joe E. Logsdon

  9:20 to 9:40         Experience in Exercise Evaluations - George E. Bickerton, USDA

  9:40 to 10:00        Existing Ingestion Guidance: Problems and Recommendations - Robert
                     Mooney, State of Washington

  10:00 to 10:20       Concerns for the Human Element in Implementing Protective Action
                     Guides ~ Aby Mohseni, State of Washington

  10:20 to 10:40       Break

  10:40 to 11:00       Problems Related to Public Perceptions of Radiological Emergency
                     Planning and Response - Margaret A. Reilly, State of Pennsylvania

  11:00 to 11:20       International Commerce and the Chernobyl Experience ~ Ronald (Skip)
                     Engel, USDA

AGENDA (continued)

11:20 to 11:40       International Guidance Activities -- Allan C.B. Richardson, EPA

11:40 to 12:00       International Activities on Criteria for Food -- William Cunningham,

12:00 to 1:10        Lunch

1:10 to 1:30          Cost of Implementing PAGs for Food - Byron M. Hunger, EPA

1:30 to 1:45          Review of Issues Raised in Presentations -- George E. Bickerton, USDA

                    Working Group Session

1:45 to 2:00          Organization of Working Groups - Joe E. Logsdon, EPA

2:00 to 5:00          Working Group Discussions and Preparation of Summary Reports

September 14, 1989

9:00 to 9:30          Working Groups Meet to Organize Presentations

                    Plenary Session

9:30 to 10:30        Working Groups One and Three Presentations and Audience Participation;
                    Moderator - Joe E. Logsdon, EPA

10:30 to 11:00       Break

11:00 to 12:00       Working Groups Two and Four Presentations and Audience  Participation;
                    Moderator -  George E. Bickerton, USDA

12:00 to 1:30        Lunch

1:30 to 3:00          Audience Discussion and Review of the Most Important Issues
                    - Aubrey  Godwin, CRCPD

3:00 to 3:30          Closing Remarks and Adjournment -- Allan C.B. Richardson, EPA


                         Overview  of the Workshop
                                     Joe E. Logsdon

                              Office of Radiation Programs
                           US Environmental Protection Agency
                                     Washington, DC

       Welcome to the Workshop on Protective Action Guides for Accidentally Contaminated
Water and Food.  The organizers  have put forth considerable effort to bring it all together, and
I believe it will prove invaluable to the  Federal agencies responsible for developing Protective
Action Guides (PAG) for the ingestion exposure pathways. I hope the other participants will also
benefit from the discussions.  This will be a presentation of the reasons for and the objectives of
the workshop and our plans for its operation and the use of its product.

Participants and Roles:

       The Environmental Protection Agency (EPA), the Department of Agriculture (USDA) and
the Conference of Radiation Control Program Directors (CRCPD) are cosponsors of this workshop.
Our planning committee for the workshop consisted of Aubrey Godwin from the CRCPD, George
Bickerton and Ronald (Skip) Engel from USDA and Allan Richardson and myself from EPA. We
were  responsible for the organization of the  workshop and the selection of key participants,
speakers, and session leaders. Cheryl Malina from EPA has been primarily responsible for  making
everything happen as planned. In addition to participants from the sponsoring organizations, we -
have representatives from the Health Physics Society,  the Food  and Drug Administration (FDA),
the Department of Energy (DOE), the Nuclear Regulatory Commission (NRC), and the Federal
Emergency Management Agency (FEMA).  We attempted to hold the number of participants to
a level that could function effectively as a workshop and, therefore, had to reject many requests
for attendance.

       EPA has the responsibility for development of PAGs except in the case of PAGs for food,
the responsibility  is  shared  with  FDA.    EPA  participated  in  the development  of  the
recommendations on  PAGs for food and  animal feed that FDA published in 1982.   However, we
had some remaining  problems with  them and were  never able to  get internal concurrence to
publish them in the  Manual of Protective Action Guides and Protective Actions for Nuclear
Incidents (PAG manual) as requested by FDA. FDA is now in  the process of revising their 1982
recommendations and we  want  to make every  effort to assure that  when their  revisions are
complete, we can concur and publish them in the PAG manual  as EPA recommendations. Since
USDA and States have the major role in the implementation of PAGs for water and food, we plan
to closely coordinate  the development process with them.


       In the absence of PAGs specifically for water, past practice has been for EPA to provide
ad. hoc.  guidance when  needed.  We recognize that this is not satisfactory guidance for use in
developing radiological emergency response plans.  EPA will be developing guidance for drinking
water during the next fiscal year and, therefore, we have devoted one of the working groups at this
workshop to consider issues related to PAGs for water.  It has not yet been determined whether
PAGs for drinking  water should  be separate or included with those  for food.  This is an  issue
appropriate for discussion at this  workshop.

Workshop Objectives:

       This Workshop is designed as a forum for those who have experience in planning for and
responding to ingestion  exposure scenarios.  The  objective  is to identify and discuss all of the
issues, problems, relevant experiences, and needed or ongoing research that should be considered
in the development of PAGs for water and food.   We do not expect the workshop to produce
consensus conclusions or recommendations.  However,  this does not preclude  individuals  from
expressing opinions or  making  recommendations  for  consideration  by  the Federal  agencies
responsible  for establishing guidance.  It also does not  prevent the presentation of consensus
opinions if they develop, but we  are not asking participants to spend their  time trying  to -each

       Although the Federal agencies will not be able to resolve all of the identified issues and
problems to everyone's satisfaction,  I expect that they will have at least considered them  carefully
and will  be prepared to  explain why they chose  a particular approach or solution.  This process
should significantly  reduce the need for changes to drafts  of the  guidance based on  reviewer

Format for the Workshop:

       As  you can  see by the  Agenda, the workshop consists of two plenary sessions  and one
working  group session.   This first plenary session will provide background information that may
stimulate you to identify  issues  or problems that  require discussion by the working groups.  Each
presentation in this  session is scheduled for 15 minutes with an additional 5 minutes for questions.
Although there is an overall constraint on time, I plan  to be somewhat flexible with regard to
individual presentations.  In other words, we don't want to miss important information because of
a time constraint, but on  the other hand please don't feel obligated to use up the allotted time for
presentations.  If questions and  discussions  tend  to be lengthy, they will  be deferred to  the
appropriate working group in the  next session.

Working Groups:

       Each person has  been assigned to one of the four working groups that will convene this
afternoon.   Each group  will be addressing a different subject.  Many of the participants have
prepared papers for use by the  working groups.  We have reviewed them  and attempted to  sort
them with regard to  the appropriate  group. Each working group will have set of the most  relevant
papers for their group and the Chairman will have a complete set. Some papers were relevant to
more  than one  group and duplicates  of these  have been included for the additional group
participants.   This  process should  reduce  the  need for  working group members to  review
nonrelevant papers.   In most cases,  authors papers have been assigned to  the group that should


have the most interest in his/her paper.  I will provide additional information on the operation of
the working groups at the time of their formation.

Use of Workshop  Results:

       The proceedings of the workshop will include an introduction followed by the papers that
were presented in the plenary session and those that were prepared for use by the working groups.
It will also include  summaries prepared by the four working groups based on their discussions.  The
document will then be  distributed to all of the attendees  plus other interested parties.   Most
importantly, we plan to use it as a resource in the development of PAGs for the ingestion pathway.

       Thank you  for coming.  If you have any questions about the workshop, either now or later,
please let me know.

                   Experience in Exercise  Evaluations

                                   George E. Bickerton

                               Office of Emergency Planning
                             Food Safety and Inspection Service
                          United States Department of Agriculture
       Good morning.  It's a real pleasure being here today.  I have been asked to discuss our
experience in exercise evaluations.

       USDA is unique among Federal agencies in the way we are organized to carry out our
Radiological Emergency Response Program.

       All Radiological  Assistance Committee functions  have been centralized at Headquarters in
the Food Safety and Inspection Service, Office of Emergency Planning, the staff which I head up.
This means that all State and local radiological emergency response plans are reviewed by my staff,
and all exercises that require USDA evaluators are provided evaluators from my office.

       This has resulted in a continuity and consistency in plan reviews and exercise evaluations
that could not be achieved  in a decentralized approach.  It  has also proved to be quite cost

       The State and local governments in our opinion have  come a long way in planning and
exercising  the  plume exposure pathway.   Most  problems related  to Alert and  Notification,
Sheltering and Evacuation have been resolved.

       As we begin the  6 year Ingestion Exposure Pathway exercise cycle, it appears  we still have
work to do. Let's begin by looking at some general areas of concern:
Ingestion Exposure Pathway Plans

       Some States have not completed or even begun to make the ingestion related revisions to
       the State and local Radiological Emergency Preparedness Plans.  The concern appears to
       center around cost, questions of format and questions  of content.  Basic guidance is
       provided in NUREG-0654 FEMA REP-1 and FEMA Guidance Memorandum GM IN-1.
       Without the plan we have a problem.  A well defined plan is necessary for an effective
       emergency response and exercises are evaluated based on the plans.

   -   Another problem relates to the Agricultural Brochure which has not yet been published.
       Since States will be required to provide site specific information and distribute the brochure
       within 120 days after it is on the street, this has posed another concern to the States.

Ingestion Exposure  Pathway Exercises

   -   The  plan must be  exercised out to 50 miles instead of the 10 miles required for plume
       pathway exercises.   This requires increased funding and often involves additional towns,
       cities, counties and adjacent States.

   -   An unclear perspective of the role Federal Agencies could play in providing guidance and
       assistance during the postemergency phase, particularly FEMA, EPA, USDA, and HHS.
       Closely related is the failure to recognize that regulatory functions  are being performed
       simultaneously with the emergency  functions and good communications between these
       groups of officials is essential.

   -   The ingestion response requires the involvement of additional response personnel who may
       need training in emergency response.  For example, some  agriculture and public health
       officials whose expertise is required, may not be familiar with the emergency response roles
       and interfaces among the various participants.

       The overlap  and interrelationship among recovery and reentry issues that may arise during
       an ingestion exercise.  For example, will farmers be treated as emergency  workers for
       reentry purposes or how will this be handled?

       The  preparation of consistent  and  appropriate  public information.   This includes the
       agriculture brochure issue mentioned earlier.  How will information be disseminated during
       the postemergency phase?  Has use of the  Cooperative Extension System been considered?

   -   The  issue of the FEMA Exercise Evaluation Methodology  (EEM).   Some planners and
       evaluators have complained that the questions are vague and not all  inclusive.

       Sensitivity  to potential lawsuits  if ingestion  pathway issues are not handled timely and
       responsibly.  (Consumers, farmers, food processors, and distributors).

       We have also observed the following issues being raised as major concerns during Ingestion
Exposure Pathway exercises and in many cases  appropriate answers and/or  responses  are not

   -   Proper sampling team composition, equipment, and sampling protocol.

       Damage assessment of the  agricultural  community in both the intermediate and long term
       and the overall impact on the State.

   -   Public perception within the State and adjoining States regarding tourism, agriculture, food,
       and restaurants, and the resulting economic impact.

       Reimbursement  and indemnification issues.  Who pays  for what?  How does the Price
       Anderson Act work and what  is  covered by the American Nuclear Insurers?


       Embargoes - What State agencies are responsible for initiating embargoes and who enforces
       them? What role do Federal agencies play?

       Disposal of waste - Who has the regulatory authority and responsibility for clean up and
       reclamation?  (This is not usually addressed.)

       Rumor control for ingestion pathway concerns, specifically with regard to drinking milk and
       water and eating food.

       The process for  determining if food products are safe.  The FDA guidance dated October
       22, 1982, gives response levels  for only the milk pathway while setting Protective Action
       Guides for food  in general.  The draft FEMA document REP-13 gives  guidance for water
       and non-dairy foods.

       The importance  of harmonization in the PAGs developed for food by EPA, FDA, and FSIS
       cannot be overemphasized.

       It is  also important that  the States concur with  the levels established  by  the Federal
       guidance.  Without agreement on action levels, interstate commerce of food and milk would
       be  seriously disrupted.  This occurred  in  Europe  following the accident at Chernobyl.
       Lacking harmonization, each country established  their own "safe" levels.  As  a  result,
       movement of foods across borders in much of Eastern and Western Europe was virtually

       Scenario development that provides for realistic tasking of response personnel out  to 50

       Establishing a clear time  advance from the plume phase to the ingestion phase of the
       exercise with sufficient time, specifically one full day, for ingestion pathway exercise play.

       The need for continuity, particularly during Ingestion exercises. To the extent possible, both
       players and evaluators should be trained and experienced.

       We believe that an effective approach to assisting States in planning and executing ingestion
pathway exercises should include:

       Meetings among Federal, State, county, and utility officials 6 months to  a year prior to the
       exercise to discuss issues to  be  included in  ingestion exercises.  This has occurred in New
       Jersey (Artificial Island), Pennsylvania (TMI),  and Virginia (Surry and North  Anna).

       More Federal player participation at the regional  level in required exercises.  Plans are
       being  formulated for this type of participation  at the Byron NPS exercise in Illinois during
       December 1989.

       Continue with the jointly  sponsored USDA-FEMA  Workshops which  address Federal
       response with an emphasis on agriculture and  public health issues.

       In summary, the ingestion exercises should not be viewed as being for the benefit of USD A,
FEMA, or other Federal evaluators, but rather an opportunity to provide experience and training
for State and local responders.  Solving intermediate and long range ingestion issues for the local
area should be the primary goal.  Until  those problems are solved, the implementation of PAGs
will be extremely difficult.

                            OBSERVATIONS CONCERNING

IN-1 provides overall Ingestion Exposure Pathway guidance for:
   — plans and
   ~ exercises
   emphasis is on three pathways:
       ~ milk
       -- other foods
       — water

Key  Issues in IN-1 are:
   ~ Public Information
   ~ Protective  Response
   -- Exercise & Drills

Three key things must be demonstrated  in an effective Ingestion Exposure Pathway exercise:
   -- The formulation of:
       -  Preventive PARs -  Actions  to  prevent or reduce contamination  of  milk  and food
          products (continue stored feed)
       —  Emergency PARs   Actions  taken by public officials to isolate food to prevent its
          introduction into commerce and to determine whether condemnation or other disposition
          is appropriate   Embargo
   -  How decisions are made based on known releases, dose projections, laboratory analysis, and
       verification.  This could be accomplished through establishing:
       --  Sampling priorities (milk, soil, vegetation, feed,  and water)
       --  Mobilizing and  deploying sampling teams.  (Agriculture, Health and  Environmental
          - Develop sampling plans that at a minimum describe:
             - How sample is received, processed, and results  are forwarded to  decision maker
                 - Timeliness
                 - System is according  to State plan
       -- Appropriate Laboratory Support
          -- Labs must be active players during exercise
          - Operations and procedures for measuring and analyzing samples must be demonstrated
          - Must have good data to make decisions
       --  Monitoring teams must be alerted, mobilized, activated and deployed out to 50 miles
          (check for "hot" spots)
       --  Demonstrate implementation  of decisions

 USDA  has  participated  in  numerous  Ingestion  Exposure  Pathway exercises.   The  key
 recommendation my staff asked me to make was:
    --   Exercises are not for the benefit  of USDA, FEMA or other Federal evaluators, but are to
        provide experience and training for State and local responders.
    -   What issues should you be discussing  to get the most out of the exercise?  What would be
        useful to you?   Big investment.   Get the maximum out of it.
        —  Responders need to think in terms of intermediate and long-term solution to  various
           and complex problems and
        ~  Consider what is  important in local area
        -  Hash out all the "what if issues as time permits
        --  Get key officials involved in the exercise play in EOC
        --  Keep in mind  that the recovery and  reentry phase will overlap the ingestion phase

 Based on  our observations  from State  exercises, we believe the  following  issues may  warrant
 consideration in Ingestion Exposure Pathway exercises:

    -   Remove lactating animals from pasture and provide  them with protective feed and water
        (everyone does this). The following are also important and sometimes overlooked.
    --   Interdiction of milk shipments to keep trucks out  What if milk  has already been picked
        up? What do you do with the truck?
    —   Diversion of fluid milk  (if this is  considered a viable option).
    --   Storage of dairy products.
    —   If you make the decision it is safe to use, what provisions  have  you  made  to assure the
        public will use  it?

 Regulatory and Enforcement Actions
    ~   Quarantine  eliminate agriculture products.
    ~   Embargo   prevent the  movement of  products (Decisions based on facts).
    -  Access Control Points - For agriculture products, need instructions for police as to what
        is expected of them.

 Agriculture Worker Exposure Control
    --  Provide dosimetry/TLDs.
    --  Advise farmers  to wear  outer clothing that covers all portions of the body, similar to what
       would be  worn when applying pesticides.  For example, gloves, boots  or  shoe  covers and
       coveralls or long sleeved shirts and long pants.
    -  Wear a protective mask or place a folded (preferably dampened) cloth over your mouth and
       nose when working outside to prevent inhalation of radioactive materials.
    --  Allow controlled re-entry into evacuated area to perform vital tasks such as milking cows
       or feeding livestock.
    -  Restrict farming activities that are dust producing to prevent  of  contamination. Do not
       plant, cultivate  land,  or  harvest.  Do not move animals within  close distance of house.

Emergency Instructions and  Public Information
    --  Instruct the agricultural community on exposure prevention, control and decontamination.
    --  Issue   recommendations  to  restaurant  operators,  food  transporters,  distributors  and


   --  Advise consumers on safe products.
   -  Public Information/News releases  that are timely,  coordinated, consistent, credible  and
       reliable.  Brief media in an accurate, coordinated and timely manner regarding control of
       contaminated food products.
   --  The  transportation  of  agricultural products may be disrupted  and/or  rerouted  -- Public
       perception of State and  county areas and local products may be altered: GA  - Vidalia
       Onions, WI - Dairy State, NJ- Garden State.
   -  Key  Information officials must be  involved to be sure information released is timely  and
   --  Use  of Cooperative Extension System.

Operational Considerations
   --  Coordinate decisions with adjacent States (especially in regard to evacuation and traffic
   --  Decision making should be consistent among state(s)/counties.  (Key point, particularly if
       several jurisdictions are involved.)
   --  Federal Support to  State/local governments -  When will it be requested?
   -  Response levels - What are you using  how were they derived?
   --  HOC staff, field & lab  teams involved in  ingestion measures (ability to communicate with
       all locations).

Food and Feed Considerations
   —  Food for schools/congregate  care centers/special faculties  may need to be  located  and
   —  Provide for the transport and availability  of safe drinking water, food or feed.

Fish and Marine Life                            Migratory Birds &  Wild Game
Fish Farms                                      Hunting & other considerations
Fresh Water
Salt  Water

Domestic Animals & Their Products               Honey  Bees

   --  Washing animals
   --  Equipment, houses, buildings and food processing establishments (Don't forget the  plow  and
       tractor in the field) How? (Firemen have been used to wash food processing plants)
   --  Land - options and  appropriate option for the specific situation
   --  Don't forget to wash food and hands before eating

   —  Exposed livestock and poultry - when and how
   -  Other  contaminated  product  -  criteria  (example  -   truckloads  of  produce-lettuce,
       watermelons, etc. that have been interdicted)

General Consequences Considerations
   -- Health & Social Impact
       --  Return - resettlement - relocation
       --  Psychological distress from accident (this could occur early)


       --   Demand  for  Social Services,  such  as food stamps, counseling,  follow-up medical
           treatment, extended temporary lodging
    -- Environmental Impact
       --   Long range impact of contaminants on agriculture (may need to alternate food crops,
           plant fiber crops such as trees or cotton, or idle the soil) - Impact on water	ponds,
           lakes and rivers, streams, reservoirs, (drinking water supplies and irrigation)
    ~ Economic Impact - Long and Short Term
       --   Damage Assessment to Agricultural Community
           — Cost of lost business - restaurants, food stores & markets
           ~ Cost of clean-up and recovery to agriculture
       -   Indemnification Programs
           -- Federal
           - Price Anderson Act - American Nuclear Insurers
           — Lawsuits
       -   Key thing is to size up cost  of recovery to agriculture - immediate & long  term and
           together develop a solution.
       -   Political Impact
           -- Constraints
           — Pressures

Verification of  measured levels  for  both preventive &  emergency  protective  actions and  a
consideration of the health, economic & social impacts of such actions.

Don't create a bigger problem with solutions.

Scheduling Exercises
    -  Separate day for Ingestion Exposure Pathway exercise ~ season variation (for different
       growing seasons)
        Don't schedule when adverse weather conditions (simulate)
    -  Consider holding with adjacent State(s) when feasible - Consider feasibility of Statewide
       exercise  when  multiple plants  are  involved  (Labor intensive  for State  and Federal

Can  be separate plan, part of existing plan or a separate annex (Opinion).  If not integrated in
plume  plan, is easier to find - Be sure it is workable and doable
Plan should contain as a minimum
    - Statement of Intent
    - Concept of Operation
    - Protective Responses
       — State PAGs
       — Preventive and Emergency PAR Is for milk, food, water and animal feed.
       — Sampling plan
       — Monitoring data and analysis
    - Public Information


       — Rumor control
       — Brochures
       — Radio and TV prescripted messages
    -- Federal Resources Availability
    - Food Chain Information Annex
       — Food establishments
       — Milk Processors
       — Retail foods listings
       — Land use data

More specific guidance in IN-1

                        Existing Ingestion Guidance:
                     Problems and Recommendations
                                    Robert R. Mooney
                                    Gordon L. Ziegler
                                    Donald S.  Peterson

                              Environmental Radiation Section
                              Division of Radiation Protection
                                   State of Washington
I. Introduction

       Washington State has been  developing plans  and procedures for responding to nuclear
accidents since the early 1970s.  A  key part of this process has been formulating a method for
calculating ingestion pathway concentration guides (CGs).  Such a method must be both technically
sound and easy to use.  This process has been slow  and frustrating.  However, much technical
headway has been made in recent years, and hopefully the experience of the State of Washington
will provide useful insight to problems with the existing guidance.  Several recommendations are
offered on ways to deal with these problems.

       In January 1986,  the  state  held an ingestion  pathway  exercise which required  the
determination of allowed concentrations of isotopes for various foods, based upon reactor source
term  and field data. Objectives  of the exercise were not met because of the complexity of the
necessary calculations.  A major problem was that  the allowed concentrations had to be computed
for each isotope and each food group, given assumptions  on the average diet.

       To solve problems identified  during that exercise,  Washington developed, by March 1986,
partitioned CGs.   These CGs  apportioned doses  from each food  group for an assumed mix of
radionuclides expected  to result from a reactor accident.   This effort was therefore in place just
in time for  actual use  during the Chernobyl fallout episode in  May 1986.  This technique was
refined and  described in a later report (Ref. 1) and presented at the 1987 annual meeting of the
Health Physics Society.

       Realizing the technical weaknesses which still existed and a need to simplify the numbers
for decision makers, Washington State has been developing computer methods to quickly calculate,
from  an accident specific  relative  mix of isotopes,  CGs  which  allow a single radionuclide
concentration for all food groups. This latest approach allows constant CGs for different periods
of time following the accident, instead of peak CGs, which are good only for a short time after the
accident. Washington's new computer model is consistent with informal guidance received in 1988
from FDA (Ref. 2). An important change  of philosophy made in this process was to establish CGs
which  define foods that may be marketed, whereas  current CGs define food which must  be


interdicted.  The concept of food (contaminated with radioactivity) being consumed by the public
creates a totally different mindset from the concept of contaminated food being embargoed.

       This experience has led us to identify a number of problems with existing federal ingestion
guidance, as well as some recommendations for resolving these problems.  The lead federal agencies
responsible for radiation protection guidance are to be commended for convening this workshop
and addressing these issues.
n.  Problems In Using Existing Ingestion Guidance

       1.  The occurrence of this workshop highlights the worst problem with  existing federal
protective action guides  (PAGs):  the guidance  is  still not  official.   For over  14 years  the
Environmental Protection Agency (EPA)  has been developing  PAGs for nuclear incidents (Ref.
3).  The PAG manual is still in draft form. Still existing are such basic issues as:
       *  how many PAGs there should be for ingestion,
       *  whether or not  there should be  a separate thyroid PAG,
       *  whether PAGs should be two-tiered or one-tiered,
       *  what time period the PAGs should cover,
       *  what technical data is needed for implementation,
       *  what computer models should be used, etc.

       2.  The guidance  which exists in draft form is missing key sections.

       3.  Three federal  agencies, EPA, FDA, and FEMA, do not agree on one set of guidance.
Each agency uses different approaches and terminology, leading to conflicts for the States in trying
to follow federal guidance.

       4.  There is no agreement on dose conversion factors (especially for  the limiting infant).
Those  used now (Ref.  4)  are outdated and do not follow ICRP 26/30  methodology (Ref. 5, 6).
No lead  federal  agency  has  published dose conversion  factors according  to the ICRP 26/30
methodology for any isotope for the critical age group of infant. States are  therefore forced to
use estimates of dose conversion factors from other countries which have generated DCFs for all
age groups using the ICRP methodology (Ref. 7).  As an example of how serious this problem is,
in units of nanoSieverts per Bequerel, the infant whole body dose conversion factors for Strontium-
90 vary from  15 (Ref. 7)  to 1,270  (Ref. 4).

       5.  There is no agreement  on diet factors for the different age groups nor agreement on
the definitions of the different age groups.  The NRC uses four  age groups: adult,  teen, child, and
infant (Ref. 4).  Informal  FDA guidance (Ref. 2) and international guidance (Ref. 7, 8) uses three
age groups: adult, child, and infant.  Total diet estimates for each age group vary considerably (Ref.
4, 8-13).  For example,  the total average diet for an adult varies from 325 (Ref.  10) to 1689 (Ref.
13) kilograms per year, depending upon the reference.
       6.  No federal guidance provides for a rapid computer methodology for calculating CGs.
Any set of CGs are source term dependant.   Precalculated CGs tend to be overly conservative.


Ideally CGs would be calculated soon after the accident using the actual mix of isotopes found in
the environment.

       7.  Disagreement on thyroid  doses versus whole body  doses  provides  an unnecessary
complication. The EPA draft guidance provides for a thyroid PAG 3 times higher than the whole
body PAG.  International guidance and informal FDA guidance provides for a thyroid  PAG 10
times higher than the whole body PAG.  Washington State  has  found that  having a  separate
thyroid PAG severely complicates the calculation  of Concentration Guides.

       8.  Existing federal guidance on CGs uses the  peak dose model for interdictions.  There
are several serious problems with this interdiction model.  Two of the biggest ones are:

       a.  Peak CGs are good for only  the very short term,  say the  first day  of the accident
           After the first day, decay curves must  be used for each isotope, or the public will be
           overexposed if the same CGs are used for successive days and weeks after the accident.
           Peak CGs raise questions as how to market interdicted foodstuffs as  the radioactivity
           decays. There are serious difficulties  in establishing relaxation levels.  Because of the
           decay and weathering assumptions inherent in a peak CG, the appropriate relaxation
           levels would decrease with time. This results in serious inequities between producers
           inside the restricted area versus those outside the restricted  area.

       b.  Existing peak CGs are made unnecessarily complicated and inconsistent by the use
           of weathering terms. Both decay and weathering are considered to find the very peak
           that could be allowed at the time of the accident, which, if decayed and weathered down
           with  time, will give the person the applicable PAG.   Produce is  not  corrected for
           weathering, whereas  leafy  vegetables  are.   Therefore leafy  vegetables are allowed a
           higher peak  CG than produce.  How can the difference be explained  to a reporter or
           the general public?

       9.  Federal ingestion guidance  has yet  to incorporate the lessons learned from the
Chernobyl experience (Ref.  2).

       10. The two-tiered PAG system (preventive and emergency) is confusing, inconvenient, and
unnecessarily complex.

       The above points are just some of the  problems Washington has experienced in trying to
implement existing federal guidance.  Below we offer several recommendations for resolving these
III.  Recommendations

       The following recommendations are based on the underlying precept that implementation
of the PAGs should be as simple  as possible.  This is particularly important  since the decision-
making process must be understandable and  usable to those from various  responding state and
federal  agencies  as well as the  general  public.   These  groups  will seldom have  technical


       1.  Establish a maximum allowable dose (PAG) for the ingestion pathway.

       2.  State the ingestion PAG  as  a single value, not as a  range of values.  For political
reasons, the States are forced to use the lowest number in the range anyway.

       3.  Discontinue the thyroid PAG and go solely with a committed effective dose equivalent
PAG. Considering the uncertainties between health effects and the dose associated with these low
levels of radiation exposure, the thyroid dose savings from a separate thyroid PAG does not merit
the added complexity in computations and decision making.  With little added health risk,  the
calculations  and decision making are made much simpler.

       4.  For simplicity of computation and administration, it would be prudent to have first year
PAGs only.  Planning should only occur for the first year.

       5.  Develop only one PAG for ingestion (both food and water), not a  separate PAG for
drinking water.

       6.  Have the same  PAG apply to home grown produce as well as commercially marketed

       7.  Special categories of food, such as herbs and spices, should be allowed  10 times the
concentration of food and water.

       8.  Special populations, such as  hospitals, prisons, schools,  etc., should have the same
(and not higher) ingestion PAGs as  the general public.

       9.  Aim for maximum cooperation with international agencies to have  uniform guidance
with all countries.  Since the Chernobyl accident, the State of Washington has issued 47 certificates
required to  export  state food  products out of the U.S.  If the U.S.  federal guidance is  not in
harmony with international guidance, U.S. food exports may suffer.

       10.  The lead federal agencies should leave this workshop with a commitment to establish
common dose conversion factors by September 1990.  These dose conversion factors  must include
the infant since that age group becomes a limiting factor.

       11.  The lead federal agencies should establish common total average diet mass per year
per individual (at  least for the limiting infant) by September 1990.  This includes water as well
as food. The average meat, cereal, fruit, and produce diets for a one year old infant are not zero
(Ref. 13).  Several  early diet estimates of infants  listed only milk and water (Ref. 4).  The lead
federal agencies should not make this same mistake in arriving at new unified diet  factors. If a
separate PAG is adopted for water or for any other diet fraction,  then the diets must be broken
down by pathway.

       12.   To avoid problems with weathering terms, and to obtain  CGs that are good for a
specific period of time following an accident,  constant (straight-line)  CGs should be calculated
instead of peak CGs. When the constant CGs are partitioned according to isotope, the weathering


terms disappear as variables in the calculations.  Only physical decay matters in the relative mix of
isotopes (assuming all isotopes weather equally).

       13.  EPA, FDA, FEMA, and USDA should go beyond PAG guidance.  They should propose
uniform Concentration Guides. Or, they should develop a single computer code to calculate CGs
from the actual mixes of isotopes found in the environment following the accident

       14.  Uniform Concentration Guides and/or the computer code should incorporate the post-
Chernobyl  international guidance (see Ref. 2).

       15.   States with experience in ingestion CG  modeling should have input to the federal
formulation of the PAGs and associated computer codes.

       16.   The PAGs and associated  computer code(s) should be officially proposed  in the
Federal Register by September 1990.

       17.  The PAGs and associated computer code(s) should  be finally adopted by September
       The State of Washington hopes these recommendations are useful and will be considered
and adopted.  They are offered to correct and simplify existing technical problems with federal
guidance which is neither definitive nor official.  Any guidance for the ingestion pathway should
adhere to the following principles:

       *  it  should be technically sound  but as simple as possible so decision-makers and  the
          public understand the process.

       *  it should not be stymied by technical differences which, in the larger picture are quite
          minor (e.g.  what should the thyroid to whole  body ratio be?) compared with large
          uncertainties which already exist  (e.g. uncertainties in dose/response, dose projection

       *  there needs to be a commitment by the lead federal agencies to generate, with state
          input, a comprehensive, consistent and coherent set of guidelines which has been lacking
          for so long.

       *  this commitment must be given high priority so that the aggressive schedule proposed
          above is met.


      recommendations for ingestion pathway response levels for radiation accidents. Department
      of Social and Health Services.  Office of Radiation Protection.  November 14,  1986.
      Olympia, Washington.

2.     SCHMIDT, G. Impact of Chernobyl on ingestion pathway guidance.  Center for Devices
      and Radiological Health. Food and Drug Administration.  May 1988.  Washington, D.C.

3.     ENVIRONMENTAL  PROTECTION  AGENCY.   Office of  Radiation  Programs.
      Environmental Analysis Division. Manual of protective action guides and protective actions
      for nuclear incidents.  EPA-520/1 -75-001. September 1975.  Washington, D.C.

4.     U.S.  NUCLEAR REGULATORY COMMISSION. Calculation of annual doses to man
      from routine releases of reactor effluents for the purpose of evaluating compliance with 10
      CFR part 50,  Appendix I.  Regulatory Guide 1.109, Revision 1.1977.   Washington,  D.C.:
      U.S.  Government Printing Office.

      of the international commission on radiological protection.  ICRP Publication 26.  Annals
      of the ICRP. Volume I, No. 3.  1977. Oxford: Pergamon Press.

      of radionuclides by workers. ICRP Publication 30. Annals of ICRP. Volumes 2-8,  1979-
      1982.  Oxford: Pergamon Press.

7.     NATIONAL RADIOLOGICAL PROTECTION BOARD. Committed doses to selected
      organs and committed effective doses from intakes of radionuclides. NRPB-GS7.  August
      1987.  Chilton, Didcot, Oxfordshire, England.

8.     INTERNATIONAL ATOMIC  ENERGY AGENCY.  Derived intervention  levels for
      application in  controlling radiation doses to the public in the event of a nuclear accident
      or radiological emergency.  Safety  Series No. 81.  1986. p. 63.  Vienna:  IAEA

9.     WORLD HEALTH ORGANIZATION-GENEVA.   Derived intervention levels for
      radionuclides in food. Guidelines for application after widespread radioactive contamination
      resulting from  a major radiation accident.  1988. Albany, NY: WHO Publications Center.

      Survey-Continuing Survey of Food Intakes by Individuals. Low-income women 19-50 years
      and their children 1-5 years, 1 day. NFCS CSFTI Report No. 85-2. 1985.

      Service.  Radiological Health Handbook.  Revised Edition.  January 1970.  p.216-217.
      Washington, D.C. Government Printing Office.


12.    NUCLEON LECTERN ASSOCIATES.   The Health Physics  and  Radiological Health
      Handbook.  1984.  p. 208.  Olney, MD.
      Bureau of Radiological  Health.  Background for protective action recommendations:
      Accidental radioactive contamination of food and animal feeds. HHS Publication FDA 82-
      81%. August 1982.  Rockville, MD:  U.S. Government Printing Office.

                    Concerns for the Human Element
                               in Implementing
                 Protective Action  Guidelines (PAGs)
                                     Aby Mohseni
                                     Aileen Jeffries
                                    Paul Fedorchak

                                 Department of Health
                                 Reactor Safety Section
                                  State of Washington

       Washington State has tested implementation of current ingestion PAGs at several drills and
exercises.  This testing has shown that protective action decisions cannot be based on computed
projected doses (due to many assumptions involved).  And so we recommend an alternative, simpler
methodology based on the concentration of radionuclides in foods. Simplifying the process helps
us to avoid confusing the public and to avoid problems that foster unintended public  response.
The purpose of the present paper is to describe three such problems, propose tentative  solutions,
and request federal assistance in arriving at a final resolution.  The problems are as follows:

       Following a known release of radioactive material from a nuclear plant...

       1)  Should we prevent food  from reaching the market until  its safety can be determined
or allow food into the market until its danger is verified?

       2)  Should a decision to prevent food from reaching the market be based on plant status
(coupled with limited environmental  measurements) alone or should it await laboratory analysis of
samples taken after the  release?

       3)  Should we continue using the current two-tier (Preventive - Emergency) PAG structure
or abandon it in favor of a system  which  replaces  the PAG concept with a simpler Allowable
Concentration Level (ACL)  system?

       The first problem is the main issue of the present paper, with the other two being more
accurately  characterized as subsets of that problem.  A background summary is presented below,
along with our solutions.



       Following Chernobyl, there was widespread loss  of control over  food management in
Europe.   This  situation, characterized as chaotic  (1), focused world attention on the need to
develop better guidance, and resulted in more resources being made available to the  responsible
federal agencies.

       Recently,  numerous drills at nuclear power plants, in addition to the Chernobyl disaster
have raised concerns about the "human element" involved in the implementation of ingestion PAGs.
During an emergency, people need to believe they  can control their exposure to potential danger.
Fostering this sense of control is the single most important issue in preventing panic and ensuring
cooperation of the  general public.  To this  end, the importance  of consistency amongst various
state, local and federal officials  cannot be overemphasized.

       If the decision makers  from  various jurisdictions are not clear, decisive and responsive
enough, in terms of telling people what they need to do to ensure safety, public confidence in their
ability to handle the crisis may be severely hampered.  Faced with  mixed messages, the public will
be likely to act in the most conservative way, and this could cause large unnecessary economic
losses.  For this reason, compromises and reasonable simplifications in the developrnen  of  the
PAGs and other guidance should be  made in order to achieve consistency.  The guidance should
be technically sound, simple to  follow, and leave little room for on-the-spot interpretations that
could undermine consistency. Yet at the same time, it cannot be so specific as  to be impossible
to implement

       It has been observed that when faced with confusing and unimplementable guidance, there
is  a  tendency for public officials  to overreact.  This would be especially true when it comes  to
radiation.  Unfortunately, during crises, leaders often emerge into the spotlight by  proving their
commitment to their citizenry's  welfare  through concerned  (over)reaction.
                              Statement of the Main Problem

       Last fall, during extensive two-day exercises, we identified the following conflicting "human"
elements that must be addressed when formulating PAGs:

         maintaining public confidence that the market place has uncontaminated food

       -  maintaining the confidence of the agricultural sector that the state will act to minimize
       their economic losses.

       The conflicting nature of the above elements came to light during a drill at WNP-2.  Below
is a description of the issue, and our preferred solution to it.  There are no precedents for this
situation; however, two incidents in the Northwest last year - The Alar Scare and Exxon Oil Spill
 provide  some insight into the  implications of the alternative solutions presented below.

                           Policy Issue following Reactor Accidents

       The scenario  for a drill at  WNP-2 involved a severe accident at a nuclear reactor that
released a large quantity of radioactive material to the environment through an airborne plume.
This material was deposited on the ground as the plume passed over and caused agricultural areas
below the path of the plume to be contaminated.  The area of contamination was determined from
computer models which estimated the path of  the  plume  and  from ground measurements of
radioactive contamination made by  field teams.

       The State policy maintains that to  assure public health  is protected,  it  is necessary to
embargo crops from all areas  suspected of contamination until laboratory results of crop samples
are available  to  demonstrate  that  the crops are not contaminated,  or contamination is below
allowable limits.

       An alternative policy  advocated by a federal agency is to  not  embargo any  crops until
laboratory results  are available to prove that the crops are  contaminated beyond the allowable
limits.  The reason for this action  is argued to be that a State  embargo of crops from a large
suspected area may cause large unnecessary economic losses.  The  embargoed crops are delayed
in their access to market and thus lose all or part of their value.  The State may be held liable for
these losses.  The argument continues that the intervention levels are ultra-conservative, and that
the levels of radioactive contamination at which the crops are excluded from commerce would
represent only a small health hazard if consumed for several days following an accident.  Thus, if
an individual were to consume a few contaminated items for the short period of time following the
accident before laboratory  results were available,  the health effect would be insignificant.

       The Washington State  policy maintains that we cannot, even for short duration, allow foods
contaminated  above federal guideline levels into the marketplace for the following reasons.  First,
public health and safety must  have the highest priority above considerations of economic liability.
Second, economic losses from  a limited, temporary embargo would not be excessive.   Third and
finally, the economic consequences of not enforcing a precautionary embargo would be much graver
and more far reaching than the alternative, as the appearance of  a  few contaminated agricultural
products in the market could  cause consumers to panic and refuse  to buy any Washington State
products.  The basis for these three arguments is developed below.

       1. Public health is  the priority.

       The protection of the  public health and safety is the  prime  mandate of the public health
       officials.   No policy  which  places public health  and safety  as a secondary  factor is
       acceptable. If untested and  contaminated  food goes to the market it might have any level
       of contamination. Hot  spots within a deposition area may have contamination tens of times
       higher  than the allowed levels. Were the State to release foods potentially contaminated
       beyond the intervention level, not only would the health effects have to be accounted for,
       but it could also result in a severe loss of public confidence and trust.

       2. Immediate embargo costs are not excessive.

       The alternative policy argues that costs of embargo could amount to billions of dollars.  In
       fact, the  costs  for holding  crops  48 hours  in an  agriculturally rich area  as  Eastern
       Washington are probably less than $100,000. An upper limit for the losses resulting  from
       holding the agricultural products indicated in the drill scenario would be $260,000.  In the
       context of a multibillion dollar reactor accident, these costs are not excessive. (These  costs
       are derived from data provide by the Yakima and Grant County extension agents, and staff
       from the Washington State Department of Agriculture).

       3.  Public values safe agricultural products.

       The public is  extremely sensitive to contamination by radioactive material.  If the public
       suspected that Washington food was contaminated, all Washington products would suffer.
       It would take years to re-establish credibility in the State's agriculture. The situation could
       cause a market panic that would cost far more than the proposed embargo.

       Where the public is concerned, the perception of  safety is just as important as the actual
       safety.  That is, not only must we ensure safety, we must also ensure the public's belief in
       it.  Any waivering by  the state will cause the public and agricultural sector  to doubt  their
       authority.  As  public officials, we may find ourselves in the very difficult position of trying
       to make reasonable judgements that are not overly conservative, in the face of heightened
       public sensitivity.
                             Public Reaction to Alar in Apples

       For an excellent precedent of what can happen when the public is given a reason to suspect
the safety of food in the marketplace we have only to recall the recent "Alar scare."   In the Alar
case, the public was "informed" by the popular television show 60 Minutes that apple growers were
still using a chemical  Alar - on their apples even though it was known to cause cancer in children.

       Within days we  learned that the "evidence" for the alleged cancer link was provided by a
study that had already been identified by the  scientific community as being seriously flawed. And
in the weeks to follow, hundreds of scientists  came out supporting Alar's safety, and criticizing the
way the danger had been misrepresented by the media.

       But all this was lost on the public.  Equating Alar with cancer, they stopped buying apple
products.  Apple growers, unable to  wait for  the scientific  message to trickle through the  buying
public, acted to cut  their losses by announcing that they would no longer use Alar. Although this
action was a marketing strategy,  the  public took it as an admission of guilt; an acknowledgement
that Alar was indeed dangerous.  And who could blame them.  Faced with conflicting information,
it was better to err  on the side of safety.

       Err on the side of safety is what the  public will do if contaminated food is discovered in
Washington's markets.  With Alar, even as the danger itself was being scientifically refuted, the
public still pulled away.  With radioactive contamination, we won't even  have that luxury. The
economic impact of a "few contaminated food items" could quickly snowball. Besides the direct
costs of a turn away from Washington food products, there would be the costs of mass testing for


 contamination, the legal liability to individuals and fanners, and ambiguous health effects.  The
 phrase "Grown in Washington" would take on a whole new meaning.

        The main difference between the two above-stated positions  can be summed  up in  the
 following way.  The federal agency  is worried  about immediate, direct economic losses from  a
 "precautionary" food embargo, while the State's concerns focus on the more long-term consequences
 associated with  the  loss  of trust  in  Washington's food  products  and  its public officials, if
 contaminated food was discovered  in the marketplace.

        Alaska, wrestling with similar immediate versus long-term consequences in the wake of the
 Exxon oil spill, adopted a "zero tolerance" policy to keep fish contaminated or even suspected of
 contamination from reaching the market.  Although one would expect this decision to  anger the
 fishermen, it appears that they are generally supportive of it.  The (zero tolerance) policy has the
 support of most fishermen, who believe it would be better to lose an  entire season than to have
 the market crash and cost them their livelihoods for several years." (2).
                                       Satellite Issues

       At the present time a two-tiered system is used for ingestion Protective Actions: Preventive
PAGs and Emergency PAGs.  This structure requires a fairly complicated decision process.  The
concept of PAG, namely projecting the dose to the public from the ingestion of contaminated food
and using  this  as the criterion to intervene, has not proven to be practical.  Variability of such
parameters as the public diet, dose conversion factors and source terms, does not allow consistency
and uniformity of decisions during accidents.

       The decision process could be made simpler.  The triggering event could be better defined;
and the contamination levels could be made more acceptable to the public.  A one-tiered allowable
concentration  level  structure  should  be  adopted  instead of  the current  PAG concept.
Contamination levels, sanctioned by the FDA, should be set as with other food contaminants, such
as pesticides or other chemicals, at allowed concentration levels (ACL's). These levels should apply
to any radioactive contamination, at any time, resulting from any accidental occurrence.  They
should be conservatively calculated to eliminate the need  for additivity due to contamination by
more than one radionuclide.
                          Accident Scenario and Recommendations

       The immediate state and local  response to a severe reactor accident will set the tone for
public confidence in what follows.  If one postulates a severe reactor accident,  the immediate
response would focus  on protecting the public  from exposure to  the plume.  The regulatory
position for this phase has been shifting towards making protective actions based primarily on plant
status; partly because of the urgency present in the  plume phase and partly due to uncertainties
associated with dose projection techniques.  Parameters such  as the reactor vessel water  level,
reactor coolant  system  pressure  and temperature, radiation levels  inside  containment  and
containment status will drive the offsite protective actions.   The field measurements will be used

to confirm  or deny  the presence of  radionuclides,  and help  characterize  their  release  and
atmospheric dispersion.

       During the plume  phase,  plant  parameters coupled with offsite  measurements  should
determine the magnitude of noble gases in the release and detect the presence of the radio-iodines
and  the radio-cesiums.  Even in the  absence  of the urgency inherent in the  plume phase,  this
information  could and should be used  as soon as  it  becomes  available, to determine ingestion
protective actions intended  to prevent  or reduce the contamination of foodstuff,  e.g.,  placing cattle
on  stored  feed.    This action should  not  await laboratory analysis  results confirming  the
contamination of pasture beyond  the preventive PAGs.  In fact there  may  be  no need for  a
preventive PAG at this phase; a two-tiered PAG system is  too complicated and unnecessary.  The
fact  that a nuclear plant has experienced an accident  of  sufficient severity to be  classified as  a
General Emergency coupled with valid  plant information  that the release is either unfiltered or
unmonitored should be enough to warrant protective measures intended to reduce or prevent the
contamination of foodstuff.

       Computerized atmospheric  dispersion  models can  be used  to  project  deposition of
radionuclides. Harvestable crops in areas where projected deposition levels equal  or exceed the
allowable limits should be embargoed. In other words, when a General Emergency is dec'..red at
a plant and there is reason to suspect that radio-iodines  and other  particulates may have been
released into the environment, agricultural products potentially contaminated should not be allowed
into  the market  place  until an adequate sampling system  and  laboratory analysis  sufficiently
characterize the deposition and radio-nuclide concentrations in those  products.   As noted earlier,
an "allowable concentration level" (ACL), rather than an emergency PAG, should  become  the
criterion for retaining or lifting the protective embargo.

       The  embargo  can be  lifted, modified or continued when  an  adequate  sampling program
sufficiently characterizes the  radionuclide concentrations in the embargoed crops;  this leads to
another issue, namely the statistical significance and the adequacy of the sampling program.  There
are currently no federal  guidelines on  the statistical requirements and sampling  program adequacy
for the States to follow.  As a result, major decisions have sometimes been made by public officials
during federal evaluated drills  without  the  use of  sound and  comprehensive  sampling criteria.
Federal guidance  is needed in this  area so that the sampling criteria used by different States and
jurisdictions to impose or relax ingestion protective  actions are  compatible.  Federal guidance to
the  State  and local governments should  include  statistical  analysis requirements, sampling
methodologies and strategies, sample counting  and levels of precision.

       Based on the above the following specific recommendations are made for severe reactor

       1.  To eliminate the confusing Preventive PAG in a two-tier system the following Protective
          Actions should be  taken based on plant conditions. These actions will ensure that no
          contaminated food products reach the market.

           Embargo harvestable crops  in a potentially contaminated area until an adequate and
           statistically sound sampling  program characterizes the radionuclide concentrations  in
           those crops.  This action could be tied to the declaration of a General Emergency and
           confirmation of an unmonitored or unfiltered release.

           Place cattle  on stored  feed at  General Emergency outside  the  10 mile Emergency
           Planning Zone  in  areas  expected  to be  contaminated.    No such  actions are
           recommended  within the 10 mile  zone until the threat  to the  pubb'c from plume
           exposure is removed.

       2.  To move away from the PAG concept to a more practical decision-making tool that can
           be used in any radioactively contaminated food (regardless of source), and  to ensure
           consistency among all jurisdictions, we should adopt a one-tier allowable concentration
           level (ACL)  system.  These ACLs should be developed for food  and  water by radio-
           nuclide based on  the acceptable risk concept.  The  presence of radio-nuclides below
           these levels in food products would constitute an acceptable public dose.  This would
           be a set of fixed (non-peak) regulatory  levels which would permit  marketing.

           The contamination of food products by  radioactive material should not be treated any
           differently from chemical contaminants such as pesticides. The selection of these ACLs
           should  no longer  be based on the assumption that a severe reactor accident will not
           occur more than once in a lifetime (3).

           Once a set of ACLs are developed, public officials should move away from expressing
           PAGs or projected doses, and instead focus  on allowed concentration  limits.

       3.  Assumptions used in the calculation of these ACLs should be conservative enough to
           avoid the need for additivity due to contamination by more than one radionuclide.  (A
           reasonable number would be to  calculate the ACLs to correspond to 1 mSv (0.1 rem)
           per critical isotope.)

       4.  Expand  the  list of isotopes of concern (currently light-water-reactor  source term
           dependent) to  include weapons accident source terms, i.e., Pu isotopes.

       5.  Federal guidance to the State and  local  governments should include statistical  analysis
           requirements, sampling  methodologies  and strategies, sample counting and levels of

1.      SCHMIDT,  G.D. Impact of Chernobyl on Ingestion Pathway Guidance, Aug 1988.

2.      BORRELLI, Troubled Waters, The Amicus Journal,  11(3), pg 14, Summer 1989.

3.      47FR47073,  Oct 1982.

                Problems Related to Public Perceptions
                         of Radiological Emergency
                           Planning and Response

                                    Margaret A. Reilly
                     Pennsylvania DER/Bureau of Radiation Protection
       To the best of my knowledge, no organized scientific study has been made of the basis for
public fears surrounding radiation accidents or of radiation in general.  This presentation makes
no pretence of being such.  What is offered here should be construed as food for thought or
perhaps a light snack.  Over the last  15   years a few opportunities for observation of public
reaction to  radiation crises have presented themselves in Pennsylvania.  These events were the
fallout of Chinese weapon test debris in the fall of 1976, the accident at Three Mile Island in
March of 1979, and the accident at Chernobyl in April of 1986.  The whole problem really began
in 1945.

       In early August of 1945,  the atomic age was born into public perception, literally in a blaze
of glory, with the detonation of a nuclear weapon at Hiroshima. That spectacular start, followed
by a decade of veiled secrecy surrounding weapons technology and surrounding the infancy of the
peaceful uses of atomic energy, worked wonders to instill a sense of fear and suspicion in the mind
of the public.  Although historically warfare has  been largely  responsible for driving technology,
the nuclear branch on the tree of technology probably took a different twist.

       It would be handy if radiation smelled bad. Then we would not have the public perception
problem.   Of course we  would all  be doing something else for  a living  anyway.   A  really
fundamental problem here is  the  matter that  the average  individual cannot gather his  own
information with which to make  a decision, radiation being undetectable by the human senses. He
must  generally depend on a  faceless bureaucrat to tell him  what  to do.   He has, in  effect,
surrendered  control to somebody he doesn't  know.  Control is right up there after air, water,  food
and shelter in  human priorities.

       This  would seem to suggest that if the bureaucrat were endowed with a face, that some
element of trust would ensue.  This appears  to be the case, witness the success  of Harold Denton
of USNRC as the single  spokesman during the  accident at Three Mile Island.  The  case  may,
however,  not be universally true. There is reason to suspect that the spokesman must be someone
that the individual  doesn't know personally, a prophet from another village.  That side of the coin
goes something like this: I, as an ordinary person, don't know anything about radiation.  You are
my friend or relative  or  neighbor  or coworker, and you  are  a lot  like me.  You don't  know


anything about radiation, either.  Nobody knows. But if you do  know, it must be because you are
in league with the industry.  Come to think of it, you do talk a lot like THEM.

       This knowledge aspect of the problem has a few corollaries.  One is the notion that, after
all, this judgement is being made by a government worker, and we all  know that those  folks are
ignorant.    No one  in  his right mind  would cede control to a government worker.    (This is
especially true in government towns where many people are government workers, who know how
government workers  are.)

       Another knowledge corollary is found among technical professionals who are not  radiation
specialists.  If the average radiation specialist were to think back to their high school and college
science courses which were not specifically radiation oriented courses, in few, if any instances, did
the course work ever get around to the radiation and radioactivity chapter in the back of the book.
So one frequently encounters technical  professionals who feel compelled  to express  views on
radiation issues in a  convincing way in the eyes of the  non-technocrat, while never having made
it  to the back of the  book.  After all, if someone is a chemist, physicist, engineer, or physician, he
should know about this.

       In  the  specific  case of  foodborne  radioactive  contamination two public per,,sption
phenomena have been  observed to date.   The first is the perceived relative radiotoxicity of
domestic versus imported contamination.  The ratio appears to approximate ten to one,  domestic
to imported. The value could be higher than  that.  Far more concern was expressed  over an
intermittent 20 or so  pCi/liter 1-131 in milk from a few close farms after the accident at TMI, than
concern over widespread contamination to 1000 pCi/liter throughout the northeast United States
after the Chinese episode in 1976. The same comparison holds for public response to the  accident
at Chernobyl in 1986.  This resulted in widespread milk contamination up to 50 pCi/liter over a
two week period, at   least in Pennsylvania.   Two possible reasons for this perception have been
identified.  One reason could be the ease of avoidance of a local  problem such as was encountered
at TMI.  As the sign in the Safeway in Bethesda  said:  "We don't sell Pennsylvania milk".  It would
be a bit  much to  believe such  a  sign for  the weeks following  the Chinese episode  or Chernobyl,
which would then have to read:  "We don't sell  northern hemisphere milk".

       The other possible reason for this relative toxicity ratio  is  something akin to the old control
problem.  If the problem is from "over there", there is not much that  the government could do
about it. On the other hand, if the problem  is from "over here", somebody allowed it to  happen;
the utility and government being the somebodies.  In this case it is a lot easier to get the ear of
the somebodies.

       The  second public perception  phenomenon relating to  foodborne contamination is the
relative toxicity ratio between uptake resulting from ingestion  versus  uptake  resulting  from
inhalation.   It appears that ingestion is  the greater concern. This may have something to do with
control, again, in that it  regardless of one's confidence in the faceless  bureaucrat, one can choose
not to  consume suspect  commodities.  Choosing not to  breathe  is less an option.

       In the course  of the accident at Three Mile Island a major fraction of  the population from
the surrounding area engaged in a voluntary spontaneous evacuation.  This was in  spite of the fact
that an evacuation of the general  public was never recommended or ordered.  People did not seem


to care whether they lived downwind or not; they just left.  This observation coupled with actual
wind  conditions  on  the first day  gave  rise to  a  revised  philosophy of   protective  action
implementation in Pennsylvania.  During the first day of the accident the wind direction changed
from 30 degrees to 270 degrees. Since downwind could, in effect, be everywhere, and people were
very likely to leave regardless of where the affected area was, the policy of a 360 degree protective
action area  was established, extending out to  10 miles.  (If everyone is going to leave anyway, it
is  best we plan around that.)  The policy remains  in effect.

        The basis  for the spontaneous evacuation probably include a large dose of control, i.e. since
I can't  independently assess the problem for myself, I can  at least control my risk by getting out
of the area.  The situation was exacerbated by the dearth of information from sources  perceived
to be reliable.  In this case no news was bad  news. In addition  many people evacuated because
they expected that a forced evacuation would be ordered and they  wanted to beat the rush.

        Another public perception which prevails in times of normal operations as well  as during
radiation crises is that of unlimited government resources to meet their  individual demands.  One
area perceived to be inexhaustible is  that of field monitoring capability combined with radioanalytic
capacity.  This notion is  frequently shared by people in high places in government especially from
agencies which are not charged with doing the monitoring.  It is also shared by the  news media.
People will  demand that specific  data be available for their county or town or neighborhood, yea
verily  for their house;  even if  their  house  is at the  other end  of  the  state.  After  all,  if
measurements were not taken there, "nobody knows if the plume didn't sneak over there".  People
will want the  contents of their swimming pool analyzed.  High ranking government officials will
have beef livers, broilers, eggs and other non-traditional things sent to the lab for analysis. Federal
agencies will  call at two  in  the morning looking for  updated milk  data,  evidently  with the
expectation  that cows should be milked  every four hours, or perhaps that a catheter be installed
with a line running from utter to analyzer.

        This perception of inexhaustible sampling and analytic capacity can be addressed up front
by stipulating in the plan the agency which will control this  function. Another enormous help can
be the data  from an extensive inplace environmental monitoring  program, especially with  respect
to TLDs. Some  of the public and news media demand can probably be  eliminated by  early and
frequent  news releases covering the extent  of monitoring and the results.  It  is important to
include a representative sampling from areas known not to  have been visited by  the  plume.
Negative data is at least  as valuable  as positive data.  The important thing here is to portray that
"somebody knows".

        To  be forewarned  is to be forearmed.  Some of the observations presented here are
probably right and some are probably wrong.  Radiation crises being the rare occurrences they are,
we  do not have  the  data  base for generating scholarly quantitative reports.  Suffice it  to say,
however, that one should be prepared for people to behave in what they believe to be their own
best interests; to keep control of their lives. The more information they have upon which to base
their decision, the better.   The  information  must be accurate  and, above  all,  timely.   The
information  should be delivered by a single spokesman of high perceived credibility.  To do this


requires a high degree of organization  in the responsible agency in the  planning, operating and
control of the response effort.

                      The Role of the  United States
                   Food Safety and Inspection  Service
                       After the Chernobyl Accident
                                    Ronald E. Engel
                                    Victor Randecker
                                     Wesley Johnson

                            Food Safety and Inspection Service
                          United States Department of Agriculture
       The  Food  Safety and Inspection  Service (FSIS) of the United States Department of
Agriculture (USDA) inspects domestic and imported meat and poultry food products to assure the
public  that they are safe, wholesome,  not economically adulterated and  properly labeled.  The
Service also monitors the activities  of meat and poultry plants  and  related activities  in allied
industries, and establishes standards and approves labels for meat and  poultry products.  As part
of its responsibility, shortly after the Chernobyl accident occurred, FSIS developed a plan  to assess
this accident's impact on domestically produced and imported meat and poultry.

       The events leading to the  accident at the Chernobyl plant began on Friday morning, April
25, 1986, entered a stage of crisis with an  explosion at 1:23 a.m.  on April 26, and over the
subsequent week to 10 days  released the largest quantity of radioactive material ever freed in one
technological accident  [1].  The distribution  of radioactive materials from Chernobyl occurred in
the following manner [2]:

       After 2 days the lower-level particles (surface  to 1.5  km) moved towards  Scandinavia.

       After 4 days the lower-level cloud was still over Scandinavia with parts moving into Western
       Europe. Mid-level (1.5   4.5  km) was moving  toward the Mid-East and upper level (4.5 -
       8 km) was moving toward  Siberia.

       After 6 days the upper-level cloud was approaching Japan.

       After 10 days part of the upper-level cloud was over the U.S.

       The Chernobyl fallout was transmitted through the troposphere, and fell out in a relatively
short period. In contrast, the bulk of weapons testing fallout came down through the stratosphere,
where aerosols have residence times  of 1 to  5 years [1].


       The accident at Chernobyl demonstrated that accidental releases of radioactive substances
into the  environment  can contaminate large geographical areas.    The  possibility,  although
improbable, of future  accidental releases cannot be ruled out;  therefore it  is incumbent on the
international community to be prepared to measure environmental radioactivity in the event of an

       One aspect of being prepared after any nuclear accident where radioactivity is released into
the environment, public health authorities must introduce measures to restrict the radiation doses
received by members of the public to minimize the risks of adverse effects.  Measures must  be
taken to minimize the incorporation of radionuclides into food  produced in  areas where there is
ground  contamination.  Control measures over food could exist for months or even years.

       In  addition to  the predicted physical  health  consequences of irradiation, considerable
psychological effects may constitute a significant public health and political problem. The level .of
anxiety  generated by the possible contamination of food or the environment may not be  related
to the level of exposure.  Psychological stress or even hysteria may be exhibited where  radiation
is low or insignificant.  These effects can be attributed to: 1.  The association of nuclear accidents
with the explosion of  a nuclear bomb;  2.  The inability of the human senses to detect  ionizing
radiation; and 3.  Inadequate and often conflicting information concerning the accident. A^equate
planning for dealing with the  potential emotional and  psychological problems  is an  essential
component of emergency preparedness  [3].

       Most authorities agree that the single most important aspect of emergency response is the
communication system.  Experience has shown that when any major accident occurs - not just those
involving radioactivity - the normal communication  system is usually not adequate, and therefore
a reliable,  alternative  system  of communication for emergencies  will be needed and  must  be
available.   [3]  An  advisory group of multidisciplinary technical experts, which is organized  in
advance can  make decisions and communicate with local professionals to substantially minimize
radiation contamination of populations and  their food, feed, and water supplies.  Pre-planned
communications will enhance evaluations of  the exposure pathways during all three phases of a
nuclear accident to more adequately apply the  proper protective measures.

       In  evaluating any disaster situation,  including those involving  radiation and radioactive
materials, it is important to place the specific situation in perspective to other  risks.  Actions taken
to control  radioactively contaminated foods should be appropriate to the likely risk.  Special care
must be taken to assure that counter-measures do not result in  new and greater risks. If certain
food products are to be removed from the market because of low level radioactive contamination
e.g., well within the safe standards established by the international community, it is important that
the nutritional status of the population is not thereby compromised.

       Although  preliminary monitoring results will become  available soon after an accident, they
will be difficult to evaluate fully.  Initially, monitoring will be directed towards identifying higher
levels of contamination in order to specify areas in which further countermeasures  will need to  be
considered. It is  important for monitoring to be undertaken well outside the areas of concern  to
provide  data to the responsible authorities to take the appropriate  actions.

       Three phases of a nuclear accident have been identified. The early, intermediate, and late
or recovery phases  are  generally accepted as being common to all nuclear accident  scenarios.
Although these phases cannot be represented by precise periods, and may overlap, they provide
a useful  framework within which one can intervene with countermeasures.

       The actual countermeasures used in a  specific situation depend on the level of radioactive
contamination, the availability of radionuclides in the contamination, and intervention levels used
for the different food products.  Derived intervention levels can be determined (once intervention
levels of dose have been set) from knowledge of physiological and metabolic processes  in human
beings, of the distribution of radionuclides in  the body after intake, and of the resulting radiation
doses to various body  organs  [4].

       After the Chernobyl accident FSIS and the Food and Drug Administration (FDA) met to
establish intervention levels for food, because derived intervention levels for meat and poultry in
the United States had never been officially adopted. The FSIS derived intervention levels for meat
and poultry were established by using the FDA's "Accidental Radioactive Contamination of Human
Food and Animal Feeds; Recommendations for State  and Local Agencies" [5]. At that time, FSIS
and FDA agreed that meat and poultry could be separated from food items under FDA's regulatory
control with respect to potential food contamination from the radioactive fallout. Meat and poultry
composed a readily discernible and easily segregated subset of all food items. The radionuclide
intervention levels that were established were based on a 5 mSv projected dose commitment to the
whole  body, bone marrow, or any organ other than the thyroid.

       This intervention level was based, in  part, upon the expectation that the major contributors
of radiation to imported meat and poultry will be cesium-134 (half-life of 2.1 years) and cesium-137
(half-life of 30 years).  In addition, it was not  expected that iodine-131 (half-life of 8 days) would
contribute radioactive levels of any practical concern.  The calculation of the intervention level took
into consideration the total intake of activity from radionuclides and the average daily consumption
of meat and poultry.   In  calculating this response level,  FSIS used data for U.S. consumption of
meat and poultry which represented 13 percent of total  food  intake.  Other derived intervention
levels,  such as the one developed by WHO, use the total average daily consumption of all foods
[4].  This information was not available to FSIS at the time of the accident.

       On May  16,   1986,  FSIS  officially set  a  total cesium (cesium-134 plus cesium-137)
intervention level of 2,775 Becquerels  per kilogram (Bq/kg) and 56 Bq/kg of iodine-131 for meat
and poultry.   On  May 28,  1986,  FSIS began collecting samples of  meat and poultry products
imported into the  U.S. from 14 European countries.  The criteria for selecting samples included
the best  available information  concerning  the geographic distribution of the fallout, types of
products  being  imported and the level  of contamination of the  products as  determined  by
scintillation survey instruments used by FSIS inspectors at the seven ports of entry. The samples
were collected in response to significant readings on the instruments and subsequently sent to the
laboratory.  Initially, the following five radionuclides were measured in the laboratory. Cesium-134,
Cesium-137, Strontium-89, Strontium-90, and Iodine-131.

       By October of 1986, 366 of 815  samples exceeded background levels for total  cesium.
Iodine and strontium results were not practically distinguishable from background radiation levels.
However, only, five countries had any samples with results greater than 37 Bq/kg for total cesium:


Belgium, Hungary, Poland, Romania, and Sweden.  Only Romania had values  greater than 185
Bq/kg, with the highest  reading of 794  Bq/kg.  The sample  data  collected and information on
agricultural practices in the exporting countries indicated that the occurrence of  these two cesium
radionuclides in meat and poultry may continue for an extended period. Six months following the
release of radioactivity, FSIS determined that  the intervention level of 2,775 Bq/kg needed to be

       The FDA  1982 guidelines are for short-term protective actions in an accident resulting in
radioactive  contamination of human food or animal feeds, and not for  long-term, continuous
exposure applications  [5].  They state that the duration of the recommended protective actions
should not exceed 1 or 2 months.  However,  evaluating the public health  consequences of food
contamination, even on a preliminary basis, requires a period of some length following the accident
to assess or reassess all the available pertinent information. These protective action guides consider
the  types of contamination  which  might occur after such  an event, the  half-lives of resulting
radioactive substances, and the biological pathways for human exposure.

       The FSIS  initial  intervention level of 2,775 Bq/kg for total cesium was established at
one-tenth of the emergency Protective Action Guides (PAGs) [5].  in specific situations, and where
justified,  lower projected doses  than  the   PAGs can be  established.    Another  \nportant
consideration  in establishing the FSIS intervention  level was that the FDA guidelines did not
consider perceived risks  in  developing the PAG  values.  Such  risks involve a high degree of
subjectivity  and could  cast doubt on the validity of  the scientific evaluations. In the opinion of
FSIS, protective actions had to address the nature of the  situation, the availability  of resources, and
the impact of these actions.

       The FDA guidelines provided FSIS, by virtue of its immediate knowledge  of its operations,
the basis for developing intervention levels to meet the particular needs of the Agency.  Therefore
FSIS determined that  the initial intervention level of 2775 Bq/kg needed to be  lowered to meet
the criteria of good public health practices.

       Since the  2775 Bq/kg intervention level was established using the  emergency PAG, it
therefore  seemed  appropriate to employ a more conservative margin of safety  of two orders of
magnitude, i.e., 100, relative  to the emergency PAGs.  This yielded a new intervention level for
total cesium of 277 Bq/kg.   However, the  Agency obtained some preliminary data from a  1986
study that indicated a lower rate of meat consumption in the United States [6].  Consequently, a
lower consumption rate resulted in a higher intervention level.  In October 1986 FSIS adopted a
370  Bq/kg response level for  total cesium to harmonize U.S.  intervention levels for all food items.

       The highest total  cesium levels had  occurred by  April 1987, for each of the 14 European
countries [7].   However,  on June 3, 1987 a sample  of beef extract from Brazil  was taken by an
FSIS inspector who noticed,  on routine inspection, that  a large container of beef extract caused
an unusually high reading on  his scintillation survey instrument. An adequate sample for analysis
was sent to the laboratory. The sample contained 481 Bq/kg and 168 Bq/kg of cesium 137 and  134,
respectively. The total cesium of 649 Bq/kg, exceeded the FSIS response level of 370 Bq/kg.   The
cesium 137/134 ratio of 2.86,  indicated a  strong probability that the beef used in the product was
from Chernobyl contaminated animals [7].  The Brazilian plant that produced the beef extract,

stated that the meat used  to produce the extract may have been imported from three European
countries: Poland, Ireland, or Denmark.

        Based on  the  result  of  this sample,  FSIS started a sampling program  to determine  the
cesium levels in: 1) all non-distributed Brazilian beef extract products in the U.S., 2) all Brazilian
beef extract  entering  the U.S.,  and 3) all products  exported to the U.S. by the Brazilian plant
Two out of the  60  beef extract  samples  exceeded the  FSIS 370 Bq/kg intervention  level.
Subsequently, the contaminated  product was  prevented from entering U.S. commerce. A total of
122 samples  of Brazilian beef products were  taken during a four month period. In  August 1987,
FSIS stopped routine sampling of Brazilian product  Thereafter, samples were collected only when
the inspector obtained a significant response on the scintillation survey instrument  Since all of
these samples contained relatively  low levels of cesium 134 and  137, a definite response of  the
instrument was in all probability due to the presence potassium 40, which is concentrated in beef

        By October 1988, most of the samples contained cesium levels that were indistinguishable
from background.   Therefore,  FSIS discontinued  taking samples  of product from European
countries exporting meat and poultry products to the U.S.  The Agency determined that any public
health benefit of continuing the  program was offset by cost consideration and resources that could
be  reprogrammed to other high  priority areas.

        In  total,  FSIS analyzed 6195 samples  of imported  meat products  from  14 European
countries.  3701 samples of the 6195 were above background [Table I]. The highest values found
were not necessarily from those  countries with the largest number of samples above background.

        In summary, the following actions were taken by FSIS  after the Chernobyl accident:

        Set a  realistic  intervention  level using United States interim protective  action guidelines
        Calculated the intervention levels by using both the maximum intake of radionuclide activity
        allowed and food consumption data.
        Monitored, sampled, and tested imported meat and poultry products for five radionuclides.
        Periodically assessed  and revised the intervention levels based  on good  public  health
        Continued to evaluate and assess the  ongoing regulatory activities.

        Subsequent to these actions, "Derived Intervention Levels for Radionuclides in Food" was
published by  the World Health Organization [4]. Also a joint FAO/WHO recommendation to the
Codex Alimentarius Commission  to control foods in international trade that have been accidentally
contaminated with radionuclides  may soon help harmonization of intervention levels.  The goal is
to provide a  system that can be  uniformly  and simply applied  by government authorities and  yet
one that achieves a level of public health protection to the individual that is more than adequate
in the event of a nuclear accident".  [8] Codex represents a worldwide search for compromise and
consensus based on science. Food Safety Officials have been instrumental in setting many of these
guidelines; they supervise radiological monitoring of  much of the food in international trade and
food consumed in each nation; and they will continue to be more important in orchestrating new
activities for  the benefit of all nations.



      NAME          SAMPLES    BACKGROUND    CESIUM Bq/kg*

      BELGIUM             224               177    51 (9/86)
      CZECHOSLOVAKIA     63                59    42(1/87)
      DENMARK           1820               348    26 (3/*87)
      FINLAND             274               241    71 (1/87)
      FRANCE              239                15    <1 (1/87)
      GERMANY             57                20    7(3/87)
      HUNGARY            307               269    3 (4/87)
      NETHERLANDS         99                20    5 (11/86)
      POLAND              849               749    115 (8/86)
      ROMANIA            1425               1376    1043 (10/86)
      SWEDEN              571               229    83 (10/86)
      SWITZERLAND         68                36    165 (12/86)
      YUGOSLAVIA         188               157    86(3/87)
      TOTAL               6195              3701

      Note:  Numbers may change slightly pending final audit of data.

      * Total cesium is the sum of cesium -134 and cesium -137.


      We thank Edith E. Kennard, Office of the Administrator and Kathryn L. Kimble-Day,
Office of the Deputy Administrator for Science for their technical assistance in the preparation
and editing of this paper.


      RECKNAGEL, E., Environment, Vol. 28 (1986) (5) :6

[2]    EDWARDS, M., Chernobyl-one year after; National Geographic Magazine, Vol. 171 (1987)

[3]    Nuclear Power -Accidental releases-practical guidance for public health action, WORLD
      HEALTH ORGANIZATION Regional Publications, European series No. 21:12,33 (1987).

[4]    Derived  .Intervention  Levels  for   Radionuclides in  Food,  WORLD HEALTH
      ORGANIZATION (1988) p. 13.


[5]    FDA,  Accidental  Radioactive Contamination of Human  Food  and Animal  Feeds;
      Recommendations  for State and Local Agencies. Fed. Reg. 47:47073.  (1982)

[6]    BREIDENSTEIN, B., WILLIAMS, J., Contribution of Red Meat to the U.S. Diet, National
      Livestock and Meat Board.  Chicago, IL.(1987).

[7]    ENGEL, R, RANDECKER, V., FRANKS, W., Lessons Learned From  Chernobyl: Public
      Health Aspects; Journal of the Association of Food  and Drug Officials, Vol  52  (1988)

      Session, The Hague,  Netherlands)  ,  Proposed  FAO/WHO  levels for  Radionuclide
      contamination of Food in International Trade (1989).

                     International Guidance Activities
                                  Allan C.B. Richardson

                               Office of Radiation Programs
                            US Environmental Protection Agency
                                     Washington, DC
       My charge today is to review international guidance activities on principles for setting
Protective Action  Guides (PAGs).   It's really quite  a simple  task.   There is  only  one  set of
guidance in existence now; that guidance is currently under revision; and we don't have the results
yet.  The principal group involved in generating this guidance is the International Commission on
Radiation Protection (ICRP).  Contributing groups include the International Atomic Energy Agency
(IAEA) and the Nuclear Energy Agency (NEA) - which represents the European  Community,
primarily, and  is part of the Organization for Economic Cooperation and Development (OECD).
In the case of PAGs for food,  there are some complicating factors; other agencies  enter the picture
- the World Health Organization (WHO), the Food and Agriculture Organization (FAO), and the
Codex Alimentarius have been mentioned  several times today.  Skip Engel discussed that  subset
of considerations in an earlier paper.  Here, instead of those more complex issues, we will  focus
on the basic principles upon which all PAGs are based.

       We need a common set of basic principles because we need  to get to  the  bottom line
(PAGs) in an unequivocal way that everybody understands. Let me give you an example of how
equivocal some international organizations have been, on this question of PAGs, in the recent past.
An unnamed international health agency, just a very few years ago, right after Chernobyl, set out
to produce PAGs.  They stated their intentions as two objectives.  The first was: "...  to set
[Protective Action  Guides], below which the introduction of control measures cannot be justified
on the grounds of protecting health."  But,  they went on to recognize, control measures could still
be introduced  for other reasons, as health  is not the sole criterion for decisionmaking.  This first
part of their objectives can be paraphrased as,  "We will set a level below which you don't need to
do anything, but you might do something anyway."  The second objective was, "The  [PAGs) will
represent  levels above which  control  measures should  be considered,  but  not  necessarily
introduced."   I would  paraphrase this as saying: "We will set  a level above which you should
consider doing something,  but you might do nothing anyway." I don't know how anybody  could
derive decisive action based on that set of  objectives.

       International principles for setting PAGs are contained in two key documents  that contain
identical statements.  One is Publication Number 40 of the ICRP, which was issued in 1985.  The
title  is "Protection of the  Public in the  Event  of Major Radiation Accidents,  Principles  for

Planning."  The other  is the IAEA's Safety Series Publication Number 72,  also issued in  1985,
written by many of the same authors and titled, "Principles for Establishing Intervention Levels."

       The  principles that were set forth in these  documents were identical, were  incomplete,
and they are, unfortunately, the only principles that  are now in effect, while proposed revisions
go through one draft after another.  There are several such draft revisions that are of significance.
The  most important is that of the ICRP.   The basic guidance that applies to most planned
exposure to radiation is ICRP  Publication 26.  That document has been under revision by the
Commission for  a number of  years,  and  the new version will,  for the  first time,  include
recommendations for emergency response.  They are now  getting close to closure, and I think it
should be a very much improved and useful document.  But it isn't finished yet.

       Such guidance doesn't get developed in a vacuum, and there have been a couple of parallel
efforts which have provided significant input to the ICRP, which is essentially a behind-closed-doors
effort. These other efforts are more open.  One of  these is being carried out within the IAEA,
which has convened annual meetings of national experts  for  a number of  years in  Vienna, to
generate a replacement for Safety Series No. 72, mentioned earlier. There is  a meeting scheduled
this December to complete this effort; and, hopefully, we will reach closure at that meeting on at
least the basic principles.

       The Nuclear Energy Agency (NEA) has also  been  at work.  It has convened a group of
experts from member nations that have been developing recommendations.  There is an overlap
between the ICRP, the IAEA, and the NEA groups, and they are all headed in the same direction.
By this time next year, with luck we  will have international  agreement on the  basic principles, and
both the ICRP  and the IAEA will have published their new reports.

       With that as a preamble, we can move to the principles themselves.  These are shown in
Figure 1, which lists the basic considerations  for selecting PAGs. What should we expect the set
of principles to say?  It is fairly obvious,  I think.  First,  avoid unreasonable risks of acute  and
long-term health effects.  Next,  avoid additional  health risk when it is cost effective to do so;  and
finally, the risk from the  protective action must be  less than the radiation  risk avoided.  You
certainly do not want to do anything which causes more harm than good.

                                        Figure 1

                                 Basis for Selecting PAGs

          •  Avoid unreasonable risks of:

                    Acute health effects
                    Long-term health effects,  and

          •  Avoid additional  health risks when it is cost-effective to do so; but,

          •  The risk from the protective  action must be less than the radiation risk

       In  a little more sophisticated formulation, the NEA,  in  its review of the principles  for
deriving  PAGs, has put together a chart showing  their basic objectives.  This is given in Figure
2, and shows how the ICRP 26 principles for normal situations translate into the accident situation.
This transition from principles for normal situations is something, by the way, that has been resisted
for a long time; the tendency has been to treat accidents as unique.  Under ICRP 26 - that is,  for
normal radiation protection when you  have a source that is  under control  and you are really
deciding how much control  you want to exercise -- there  are  three principles.  They are called
justification, optimization,  and  limitation  (or  constraints  on  individual risk).   Justification  is
something  which has usually already taken place before radiation protection people get  involved
- like the  decision to have nuclear power  or not.  Optimization is, basically, making the choice of
the best  buy for the money in control. It's  what we call ALARA  The optimization process results
in regulations like 40 CFR 190,  the 25-millirem EPA standard  that the nuclear industry  operates
under for normal releases.  We all know the dose limits for limitation of individual risk.  They are
well established.  The dose limits referred to here are the overall limits; for example, in the United
States it is our 500  millirem Federal Radiation  Protection Guide.

                                           Figure 2

                                        (April, 1989)
       Constraints on
       total individual
   Normal case
Source under control

   of a practice

   Choice of the
   "best" option
   for control

   Dose  limits for
   workers and for
   the public
Source out of control

Justification of
a protective measure

Choice of the "right"
intervention level
Radiological risk and
risk from protective
measures kept below
unacceptable levels
       Now, when  you consider the  accident situation, some interesting changes  take  place.
You're no longer justifying the practice ~ the existence of the source ~ what you are justifying
is  the imposition  of a protective measure.   The source is  already there.  So the  justification
requirement becomes  much  more real.  It's the determination that taking the protective  action
will do you some good.  Optimization really remains the same - it's a question of where you get
the greatest protection for the effort, including the cost.  But there is a subtle difference.  In the
case of a  source  that  is being controlled,  you are  usually looking at  a discrete set of control
options, e.g. what type of control of iodine  releases do you install, or how much holdup of noble
gases.  Whereas, in the case of protective action you are really looking at the choice of the level

of radiation exposure at which you introduce the protective action. This is a continuous range, not
a set of discrete options.

       Finally, we must consider constraints on total individual risk.  In the normal case, specified
dose limits exist, e.g. the ICRP's current dose limits are 100 millirems  for chronic exposure,  and
500  millirems for  non-recurring planned  exposures.  In  the  case  of an accident, there are no
numbers.  In the international guidance under development, that will remain the case.  What will
emerge is a recognition that individual countries will have to make decisions about what level of
protection they want to provide people, as an upper bound to  risk under accident situations.  But,
it is  not something on  which numerical international guidance will be offered.

       Figure 3 shows  the existing international principles, as they have been set down in ICRP-40.
It is  kind  of a mess, really.  The first principle is an example  of limitation; it corresponds to the
third principle on Figure 2.  It is an upper limit on risk, but it only applies to nonstochastic effects.
That is, there is no  recognition of the need to provide an upper bound on health effects from
stochastic effects in the existing international guidance.  That is one of the things that needs to be

                                          Figure  3


              Principles for planning intervention in the event of an accident:

       (a)  Serious nonstochastic effects should be avoided  by the introduction of
       countermeasures to  limit individual dose to levels below the thresholds for  these

       (b)   The  risk from stochastic effects  should be  limited by  introducing
       countermeasures which achieve a positive net benefit to the individuals exposed.

              This can be  accomplished by comparing the reduction in individual  dose,
       and  therefore   individual  risk,  that   would  follow  the  introduction  of  a
       counter-measure with the increase in individual risk resulting from the introduction
       that countermeasure.

       (c)  The  overall incidence of  stochastic effects  should be limited,  as far as
       reasonably practicable, by reducing the collective  dose equivalent

              This source-related assessment may be carried out by cost benefit  analysis
       techniques  and  would be similar to a process of optimization in that the cost of a
       decrease in the  health detriment in the affected  population is balanced against the
       cost of further countermeasures.

       The second principle  in ICRP-40 is the most difficult one to analyze.  It actually  is a
requirement for justification of a protective action.  What it really says is, "Don't do it if it isn't
going to do more good than harm."  The word  "stochastic" is misleading here,  because it implies
that stochastic effects have  been limited.  They  have not.  This is  a justification requirement, but
not well expressed because  it leaves out the costs implied by the  protective  action. And finally,
the last principle is expressed correctly.  It is a requirement for optimization, or ALARA.  It is the
only one that is expressed clearly and completely in the  existing guidance.

       Figure 4  shows last year's draft of new principles prepared by an expert group for  the
IAEA.  It is much clearer.  There are  three principles:  justification, optimization, and limitation
of the risk to individuals.   The third principle adds to the old ICRP-40 statement the phrase "
the  level of total radiation exposure of individuals should  be  maintained below  that which is
regarded as unacceptable for stochastic effects .  .." This level is not defined, and it's left to each
country to decide what it's  going to do.

                                          Figure 4

                  IAEA DRAFT REVISION OF PUBLICATION 72 (11/88)
       Intervention  should be justified (i.e. the particular action should do  more good
       than harm for the group of people it will affect).

       The protection of  the population should be optimized (i.e.  the  particular action
       should be implemented at the level which will produce the most good).

       The risks to  individuals should be constrained below unacceptable levels (i.e.  the
       level of  total radiation exposure to individuals  should be maintained  below that
       which  is regarded  as  unacceptable  for stochastic effects, and below  that which
       serious non-stochastic health effects  could occur).
       Figure 5 shows what EPA has done in its revised draft revision of the PAG manual; it is
essentially identical to the principles in Figure  4. We have tried to choose words that would be
clearer.  The  first two principles  here  deal with the limitation  of risk to individuals; they deal
separately with  nonstochastic and stochastic effects.   They  should  be considered  together  as
limitation of individual risk.  The third principle is  a  requirement for ALARA, and the fourth
one is  a requirement that the protective action be justified, i.e.,  that it do more  good than  harm.

       1.  Acute effects on health (those that would be observable within a short period
       of time and which have  a dose threshold below which such effects are  not  likely
       to occur) should be avoided.

       2.  The risk of delayed effects on health (primarily cancer and genetic effects for
       which  linear  nonthreshold relationships to dose are assumed) should not exceed
       upper  bounds that are judged to be adequately protective of public health under
       emergency conditions, and are reasonably achievable.

       3.  PAGs should not be  higher than justified on  the basis of  optimization of cost
       and the collective risk of effects on health.  That is, any reduction of risk to public
       health avoidable at acceptable cost should be carried out.

       4.  Regardless of the above principles, the risk to health from a protective action
       should not itself exceed the risk to health from the dose that  would be avoided.
       This summarizes the current state of advice on how to set PAGs.  I would like to make
two additional; points.  One minor and one  major.  The minor one is that none of these sets of
principles requires  that the PAGs be expressed in terms of  rems, or  sieverts.  They may be
expressed in terms of any  kind  of indicator  of exposure that is  useful for deciding when to
introduce a protective action. The second, and major point, is that I think we really need a fourth
principle to be added to the three we have  been discussing.  That is to keep PAGs as simple as
possible.  This is essential so that political  decision makers can go about  the vital  business of
providing protection  of the public without  having  to make complicated radiological  health
judgements that it is unreasonable to assume they are trained to carry out.

                             Economic  Criteria for
                        Implementing  PAGs for Food
                                       Byron Bunger

                                Office of Radiation Programs
                            U.S. Environmental Protection Agency
       In the case of an airborne release from a nuclear power reactor, agricultural land in the
fallout zone  may be  contaminated with radioactivity.  If the foods  produced from this land are
sufficiently contaminated that they pose a risk to consumers, public authorities can intervene on
the basis of Protective Action Guides (PAGs) to prevent their entry  into commerce.

       The limiting factor for  selecting the PAG is the protection of public health.  Once an
acceptable level of risk has been determined,  economic  considerations can be introduced  to
determine whether the benefits of a lower PAG justify the additional costs. This is an investigation
into the costs and benefits of the interdiction of specific foods representative of the broad spectrum
of those produced  in  the U.S.

       The Costs of Intervention

       The types of food and the amounts of production  interdicted determine the social costs of
intervention.  The  amounts of production  evaluated here  range from minimums of a few units of
production to maximums equaling  the production of the  largest  producing States for each food.
The Table shows the eleven foods evaluated, the State with the largest production of each, and
the proportion of national production produced by that State (JF-89) .

       The social  cost of interdiction is measured  as deadweight loss.  This is  the  loss to  the
consumers  of the food that is not recaptured by its  producers.  The  loss to consumers is reduced
food availability  and  increased  price  for  that portion of the  food  still available.   The loss  to
consumers  due to increased  price for the food still  available is returned to its producers with no
net loss to society.  Deadweight loss  is the additional loss experienced  by consumers which is  not
returned to producers.


                    CROP              100% INTERDICTION
                                        STATE  PERCENT
      The crosshatched  area ABCD  in  Figure  1 demonstrates  the  deadweight loss  for  a
representative situation.  It  is assumed that  only one year's production  is lost because of the
intervention Caused by the reactor accident and, therefore, that farmers whose production is not
affected  by the accident are not able  to  respond  to the accident by increasing their  output.
Therefore, the supply functions for the before  and after accident situations are vertical and labeled.
SI and S2 respectively.  The loss  in production is represented by the horizontal distance between
SI and S2 (i.e.  AB).

                                       Figure 1
                                        DEADWEIGHT LOSS
                                 QUANTITY (MILLIONS OF POUNDS)

       The height of the line AD represents the price that would have been paid for the food had
there been no intervention, but, more importantly for this analysis, it represents the loss to society
due to the first few units of food production withdrawn because of the intervention.  This loss to
society is measured  as marginal cost or the cost on a per unit basis.  Similarly, BC represents  the
price  paid for the food after the intervention and also represents the marginal cost to society for the
last few units of production withdrawn.

       Some social  costs of intervention, such  as the destruction of foods and the  value of health
effects associated with the interdiction itself, are ignored here.  They would be small in comparison
to the other costs of interdiction and would have no appreciable impact on this analysis.

       The marginal costs of intervention,  based  on  data  for 1983 through 1985, are shown in
Figure 2 (JF-89).  The costs  for three cases are shown: a small intervention (representative of AD
in Figure 1), a  large intervention equaling the production of largest producing state (representative
of BC in Figure 1) and an intermediate intervention  representing  10% of the production of the
largest producing state.  These are labeled as: minimum interdiction,  100% interdiction, and 10%
interdiction respectively.

                                           Figure 2
                                COSTS & BENEFITS OF INTERDICTION
                                                                     1008 INTERDICTION
                                                                     10* INTERDICTION
                                                                    MIN INTERDICTION

       The Benefits of Intervention

       In  the  following discussion of exposures experienced by  consumers of  the  radioactively
contaminated agricultural production, dose values are understood to represent the 50 year committed
effective dose equivalent to the consumers.  Since consumption takes place after all  processing is
completed and the foods have been  marketed  and delivered to the consumers,  some radioactive
decay will  have taken place.  This decay is assumed to be taken into account.

       The World Health Organization estimate of the average  yearly intake of  food is 600kg,
which is equivalent to 1320 pounds (WH-88).  If the PAG is  expressed as a  uniform dose from
each unit  weight of food intake, regardless of the type of food, a one rem  per  year dose (for
example) is equivalent to a 1/1320 (=0.00076) rem dose from each pound of food consumed.

       EPA has published  a guideline establishing the  value of a  statistical  life.   The  value is
expressed  as a range, from a  low of  $400,000 to a high  of $7,000,000 per life, expressed in 1982
dollars  (EP-82).   This  is equivalent  to a range from $490,000 to  $8,580,000 per statistical life
expressed in 1988 dollars, when adjusted by the  consumer price index (CE-89).  This range for the
value of life is intended  to be used only as  a  guide.

       The preferred  method for  using this guide is in terms of an implied value of life.  In
evaluating  the implied value of life the net cost of a regulatory alternative is divided  by the number
of statistical lives saved and the result compared  to this range.  An alternative with an implied  value
of life falling within this  range is judged to be reasonable. An alternative with an implied value of
life exceeding the upper  end of this range may be unreasonably stringent (and costly) and, perhaps,
should be  removed from consideration.  An alternative with an implied value of  life falling below
the lower end of this range may not be stringent  enough and, perhaps, also should be removed from

       Since this investigation addresses situations believed to be representative of those that may
occur in the future rather than actual events, specific alternative  interdictions  are  not evaluated.
Therefore, the actual costs of interdictions are not compared to the value of life.

       Instead, representative interdictions  are  used to  determine the exposure  levels needed to
justify their costs in terms of avoided risk.   This is done  in a  cost-benefit framework.  To do this,
"rem equivalent costs" are determined.  They  are derived from the value of life and are expressed
in units of dollars per pound-rem.  The following calculations are to determine the range of "rem
equivalent  cost".

       It is assumed that the  dose to risk conversion factor is 0.0004 deaths per rem in all  cases
(EP-89). Based on the lower  end of the range  of values of a statistical life, the value of a rem is
(0.0004  deaths/rem) ($490,000/death)  = $196/rem.  Assuming the average annual  intake of food is
1320 pounds, (1/1320) (196) = $0.148/pound-rem is the "rem equivalent cost".  This means that, for
a value of statistical life assumed to equal $490,000 and a risk of death per rem of  0.0004, the value
of one rem is $196. This value, when translated to an annual diet, is equivalent to $0.148 per pound
of food  ingested.

       A similar calculation for the upper end of the range of values of a statistical  life gives a
"rem equivalent cost" of (1/1320) (0.0004)  (8,580,000)  = $160/pound-rem.

       These calculations establish the range for the "rem equivalent cost".  The two extremes of
this range are the bases for the two axes on the right side the Figure 2.  These axes are scaled in
dollars per  pound, but are delineated in  rems.  They represent the marginal cost of consuming
contaminated foods and are directly comparable to the marginal costs of interdiction shown on the
left axis in the figure.

Costs and Benefits Compared

       The two costs, the cost to potential consumers of the foods in terms of risk from exposure
to radiation and the cost of interdiction, are tradeoffs, either one or the other is incurred for any
unit of contaminated food.  The  objective of the cost benefit analysis  is to  identify the level of
contamination (the PAG) that minimizes total cost to society. This is the level where the marginal
cost and marginal benefit of interdiction are equal.  (In this case the benefit is the risk avoided by
not consuming the contaminated food.) Food contaminated above the PAG is interdicted because
the marginal cost of withdrawal  from the market  is less than the monetary  value placed on the
incremental risk from its consumption, and food contaminated below the PAG is  allowed to enter
commerce because the marginal  cost  of withdrawal from the market exceeds the monetary value
placed on the incremental risk from its consumption.

       The methodology used here makes  it possible to identify the dose level  where marginal costs
equal marginal benefits although the total benefits of interdiction are not known, because the  actual
level of contamination is not knowable in  the absence of an actual release.

       Note that consumers' payments for the foods if they were to enter commerce would not be
social costs because they exactly balance the receipts of sellers, the net cost to society would be zero.

       In the discussion that follows it will be shown that  value of life criteria can be helpful in
establishing the PAG for interdicting  foods.

       Figure 2 is used to  determine the range of  dose levels implied by the costs of intervention.
For example, consider beef. Interdicting even a small portion of the beef producing industry would
incur a marginal cost of $0.73 per pound of beef removed from the market.   This is the minimum
cost of intervention.   The  exposure  levels equivalent to this  cost range from  0.28  to 4.9 rem,
depending on the value of a statistical  life.  For example: 0.73/(( 1/1320) (0.0004) (8,580,000)) = 0.28.

       Based on the  upper end of this range (with a value of life equal  $490,000), interdiction of
beef is required if the exposure level  exceeds 4.9 rems because to not interdict is to imply a value
of life lower than $490,000.  Based on the  lower end of this range, interdiction is not to be carried
out at levels below 0.28 rems because to do so implies a value of life greater  than $8,580,000.

       In summary, when  applying the value of life criteria  to  the interdiction of beef, where
interdiction  costs $0.73 per  pound: interdiction should not  take place where  contamination  levels
are below 0.28 rem and  should  take place  where contamination  levels   are  above  4.9  rem.

Interdiction may, or may not,  take place when the contamination level is between 0.28 and 4.9
rems, depending on factors other than cost that may affect the decision.

       The proceeding  discussion addresses the  question  whether  any interdiction should be
undertaken.  In cases where it is undertaken, the size Of the interdiction must be determined. The
10% and 100% interdiction costs provide some insight into the relationship between the size of the
interdiction and its cost.  The upper end of the range of cost, 100% of the largest state's production,
is  chosen as  a reasonable upper limit to the production interdicted because  it is unlikely that an
airborne release from a nuclear reactor would contaminate a larger area.

       The marginal  cost of interdicting as much beef as produced in Texas  is $1.04 per pound.
The rem equivalents  range  from 0.40 to  7.0 rem.  This means that  an expenditure of $1.04 per
pound to interdict beef can  be justified, on value of life criteria, for exposure levels as low as 0.40
rem.  A decision to interdict production equal that of Texas, if the marginal exposure level were
below 0.4 rem, would imply  a value of life greater  than $8,580,000.  On the other hand, a decision
to not interdict production equal that of the State of Texas, if the marginal exposure level were
above 7.0 rems, would imply a  value of life less than $490,000.

       Establishing PAGs

       Reasoning similar to that employed above  can be used in evaluating possible PAGs.  The
difference in reasoning is that the rem level  is selected; then  the range of costs  that would justify
that rem level, based on the value of life, is determined.  Continuing with the example of beef,
consider a 0.5 rem PAG. Any costs falling within the range $0.074 to $1.30 per pound can justifiably
be spent interdicting beef contaminated at 0.5 rem.  For example: (1/1320)  (.0004) (490,000) (0.5)
=  0.074.   The interpretation  is similar to that developed above for rem  equivalent cost:  to be
unwilling to spend as much  as  $0.074 per pound to interdict  foods contaminated at 0.5 rem is to
undervalue life and to spend more than $1.30  per  pound is to overvalue life.  Lines representing
these two costs are shown on Figure 2.  Since the costs of intervention start  at $0.73 per pound for
the first few pounds of beef removed  from commerce, beef could be interdicted if contaminated at
or above 0.5 rem. The upper end of this range exceeds the cost of interdicting production  equal
that of Texas. Therefore, economic considerations  do not impose limitations on a 0.5 rem PAG for

       The objective in  establishing the ingestion  PAG for food is to set a single value which is
applicable to all categories of food, rather than for just one category such as beef.

       The reasoning in evaluating a  PAG for all  food is the same as that  used for beef. Again,
consider a 0.5 rem PAG. As determined above, costs ranging from $0.074 to $1.30 per pound can
justifiably be expended interdicting foods contaminated at this level.  Inspection of Figure 2 shows
that $1.30 per pound exceeds the costs of interdicting the maximum state's production for all  foods
investigated.  Therefore, production exceeding that of the maximum producing state for each food
can justifiably be interdicted if contaminated at 0.5  rem or  above.   The  full range of costs of
intervening most of the foods shown  fall within this range.  The reasoning for these  foods is  the
same  as that for beef.

       The marginal costs of interdicting small portions of wheat production falls below $0.074 and
the marginal cost of interdicting production as large as that for Kansas is only slightly above $0.074.
This is interpreted  to  mean that very large quantities of wheat can justifiably  be interdicted  if
contaminated at 0.5 rem or above.  This should not cause a problem because it is unlikely that the
areas of  contamination would be this large.   It also  means  that the PAG  for wheat  could be
established at a level below 0.5 rem.  The highest possible PAG with a range of justifiable costs
encompassing the cost of interdicting a small portion of wheat production is 0.378 rem.  Justifiable
costs for  this exposure level range from $0.056 to $0.984.  Note that this range does not extend high
enough to cover the cost of interdicting as much beef as produced in  Texas.

       Clearly  there is no PAG with a range  of justifiable costs encompassing the full range of
expenditures required to perform all the interdictions shown in Figure 2.  Therefore no single PAG
has all the properties judged to be desirable under  the value of Ufe criteria.

       A PAG equal to  or below 0.5 rem is attractive from  a public health perspective.  Such  a
PAG could be  selected for reasons unrelated to economics, or the consideration  of the value of
life. However,  this  discussion has shown that a PAG equal 0.5 rem has many desirable properties
from an economics perspective.  The costs of interdiction can be expected to rise dramatically as the
PAG is lowered. Therefore, very low PAGs may be unreasonably costly and  not justifiable based
on  the value of Ufe.

       This is an investigation of the costs of interdicting eleven foods believed  to represent the
broad range of those produced in the United States.   The only changes that could  result from
investigating a  broader range of foods would  be to increase the range of costs of interdiction.
Unless some foods not investigated have costs of interdiction  much higher or lower than  the costs
investigated here, no change in  these conclusions is expected.

CE-89 COUNCIL OF ECONOMIC ADVISORS.  Economic Report of the President, January
       1989, Table B-58.

EP-82 U.S. ENVIRONMENTAL PROTECTION AGENCY. Guidelines for Performing Regulatory
       Impact Analysis,  EPA-230-01-84-003, December 1983.

EP-89 U.S. ENVIRONMENTAL  PROTECTION AGENCY.   Draft  Environmental  Impact
       Statement for Proposed NESHAPS for Radionuclides, Volume 1, EPA-520/1-89-005, February
       1989, Table 6-27.

JF-89  JACK FAUCETT ASSOCIATES, Cost of Implementing Ingestion PAGs, Draft Final Report,
       August 1989.

WH-88 WORLD HEALTH ORGANIZATION, Derived  Intervention  Levels for Food, 1988.


                             Issues Regarding the
                        U.S.  F.D.A. Protective Action
                Guidelines and Derived Response  Levels
                   for Human Food  and Animal Feed
                                      Bruce Denney

                   Environmental Monitoring and Emergency Planning Unit
                                Radiation Control Section
                             Minnesota Department of Health
       A review of the Food and  Drug Administration's  (FDA)  rationale  and methods  for
determining protective  action guidelines  (PAGs) and derived response levels (DRLs) (FDAa82,
FDAb82) for human food and animal feed reveals the presence of ambiguous and contradictory
information that should be clarified in order to improve the usefulness of the guidance.

       The differences in the criteria used to determine the Preventative and  Emergency PAGs
and DRLs, for example, are striking.  The Preventative PAGs (and DRLs) are based on  accepted
health physics principles, e.g. risk factors,  avoidance of fetal health effects, agricultural models, etc.
The Emergency PAGs (and DRLs), however,  are based solely on a traditional safety factor of ten.
This difference in rationale becomes more conspicuous when the protective actions for these PAGs
are compared:  preventative protective actions involve low impact actions, e.g. removal of cattle from
pasture, storage to allow for radioactive decay, etc., while emergency protective actions involve high
impact  actions  e.g. isolating  and condemning food products.   These differences result  in a
contradiction: high impact actions,  which  may cause considerable problems and loss of income for
farmers and food processors, are based on non-technical premises ("tradition"), while the low impact
actions, which may only  result in minor inconveniences to farmers and food processors, are based
on solid scientific principles.  Justifying or explaining these differences to farmers or to the media
may be very difficult. Clearly there exists a need to review the basis and rationale upon which the
Emergency PAGs and DRLs were derived in order to provide a more scientific explanation for their
choice and use.

       In the FDA guidance (FDAa82),  references are also made to ALARA  and to the use of
low-impact actions at doses  lower than the PAGs.  Although the  FDA accepts and endorses the
concept of keeping doses as low as reasonably achievable, the FDA does not support its use "under
emergency conditions".    In  another  part of the  guidance, however, the FDA  describes  the
concentrations  at  which  the cost of implementing a protective  action equals the risk avoided by
(i.e., benefit of) the action.   These concentrations are fractions of the DRLs, which suggests, as


the guidance itself states, that it  may be "appropriate to implement low-impact protective actions
at projected radiation doses less  than those specified  in the guides".  The resulting implication is
that ALARA principles may indeed play an important  role in ingestion pathway planning.  The
FDA should, therefore, re-evaluate its position on ALARA and should estimate the concentrations
of radionuclides in human food and animal feed below which protective actions are unnecessary
based on ALARA principles and  cost/benefit evaluations.

       Finally, to determine if the PAGs for milk are being exceeded when mixtures of radionuclides
are present, DRLs must be derived for radionuclides other than those currently in the guidance (i.e.,
1-131, Cs-134, Cs-137, Sr-89, Sr-90). Such data already exists for more than thirty other radionuclides
for water, produce, and leafy foodstuffs in the Federal Emergency Management Agency document
entitled "Guidance on Offsite Emergency Radiation Measurement Systems,  Phase 3,  Water and
Non-Dairy Food Pathway"  (FEMA88).

       In conclusion, the basis and principles upon which the  protective action guides and derived
response levels for the ingestion pathway were created need to be re-evaluated to ensure that the
guidance is technically valid and  practical to implement.  In  addition, efforts should be  made to
improve the applicability of the guidance by  including DRLs for other radionuclides which may be
present in milk.
FDAa82   Food and Drug Administration, "Accidental Radioactive. Contamination of Human Food
          and Animal Feeds; Recommendations for State and Local Agencies", Federal Register.
          VoL 47, No. 205, Friday,  October 22, 1982, p. 47043.

FDAb82   Food and Drug Administration,  "Background for Protective Action Recommendations:
          Accidental Radioactive Contamination of Food and Animal  Feeds", August 1982, FDA

FEMA88  Federal Emergency Management Agency, "Guidance on  Offsite Emergency Radiation
          Measurement Systems, Phase 3  Water and Non-Dairy Food Pathway" (Draft), October
          1988, FEMA-REP-13.

              Concerns in Assessing Radiological Releases
                                to a Major Estuary
                                      Leslie P. Foldesi

                                Virginia Department of Health
                                Bureau of Radiological Health
       In the State of Virginia, the James  River flows  into the Chesapeake Bay and from  the
 mouth of the James River to the fall line the river is under the influence of tidal forces.

       There are several centers of commerce along the  river  including an international port of
 call at the mouth of the James.  Associated with the centers of commerce are  potential sources of
 radioactive materials for being released to the river.

       Two hundred miles inland, the Babcock & Wilcox nuclear fuels processing plants are situated
 along-side the James River, which has  been known to flood its  banks  quickly  in the mountainous
 regions of Virginia. Storage  tanks have been  swept downstream from this facility in a previous flood.
 Fortunately, the tanks were  not destroyed.

       Another source  of a possible release is the Surry Nuclear Power Station  located on  the
 James River about fifty miles from the  Chesapeake Bay.

       In the cities of Norfolk and Newport News, shipyards are fueling and defueling the Navy's
 nuclear powered fleet.   In addition, many of the Navy's ships are carrying nuclear weapons.  These
 activities may also result in an inadvertent release.

       In assessing the  radiological release from any one of the previously mentioned activities, it
 is obvious that dilution of the material released into the river is  a major factor in dose assessment,
 as well as the fact that  the water is  brackish  and not suitable as a source of potable water.
 However, dilution in this case may not be the simple solution.  We also have to remember that this
 estuary is under tidal effects, which means that the materials  may not be going out to  sea to be
 further diluted  as quickly as we would  like to think.  It may be possible that  the material will be
 carried up river as far as the fall line and deposited, or deposited along the river's banks.  From
 Virginia's experience with the pesticide, Kepone,  materials may be deposited along the estuary and
 enter the food  chain  thereby necessitating the limitation of  taking  shellfish and commercial,
 recreational  fishing.  A  major problem  in assessing the environmental  impact  is determining what
 isotopes and in what forms will be taken up in species of commercial interest or those species that
would otherwise contribute to man's exposure.


       Even though water in the lower James River is brackish, there may be uses for the water
that have not been considered before, such as use by desalinization plants.  Currently, the City of
Virginia  Beach has difficulty maintaining an adequate supply  of water  and there has been some
discussion of building desalinization plants.  If such a plant were in operation, the health  physicist
would  have to consider the consequences of the  material being concentrated and the problems
associated with disposal of resins or contamination of the equipment.

       Most ships distill water while at sea and probably the still would not be operating  while in
port;   however, the brackish water  is  used  for fire  fighting and many prove  to  be a source of
contamination on the piers, unless an advisory was issued.

       At  the mouth of the James River is located  a major beach resort and in the event of a
major  release its  business would suffer if the  radiological  conditions were not  assessed  and
communicated effectively to the public promptly.

       I would like to  conclude this discussion by stating  that citizens  in states surrounding the
Chesapeake Bay have become very sensitive to the environment of the Bay and that they no longer
tolerate rivers being used as sewers. As health physicists we  also need to be sensitive to these issues
and be mindful that estuaries are more complicated than a  direct sewer drain to the ocean for wastes
even though the discharges may be accidental.

             The Ingestion Pathway  Comments and Issues

                                   Lawrence J. McDonnell
                                Radiation Protection Council
                                     State of Wisconsin
       The  Ingestion  Pathway and its recent emphasis  on planning for nuclear power  plant
emergencies has created activity  at all  levels  of government.   Federal Emergency Management
Agency (FEMA) guidelines  have been developed and there  has  been  an  urgency placed on
implementing these guides and planning standards at all levels of government. This global approach
has led to confusion and in some cases rapid development of public brochures at the state  level.
These brochures are  meant to educate the public in the need for protective action in the ingestion
pathway.  Some forethought on the planning process and  the integration of the protective action
guidelines seems in order.  Some  issues that should be addressed are listed below:

       Suggested consideration of issues to facilitate the planning process:

*      Review existing technical  specifications of  nuclear  power  plants requiring  environmental
       monitoring.  This should provide at  least the baseline sampling of food products  for site
       specific plants.

*      Review state monitoring/analysis of sampling programs  and  NRC  contracts to states for
       radiological monitoring of  nuclear power facilities.

*      Encourage each state to involve food producers at an early date in the planning development
       Such producer associations as the Dairy Associations, Marketing Boards, and Cooperatives
       are valuable resources in implementing  plans because they represent the affected economic
       impacted parties.

*      Involve and educate the agricultural extension agencies in the planning process so they can
       inform the public through  their usual points of contact.

*      Set up principle agency responsibilities in existing state specific framework.  For example,
       the farm or food producers normally are  familiar  with  their extension agents. Use this
       relationship to help the affected producers understand  the protective  actions that will be
       implemented in case of severe nuclear power plant accidents.

*      Recognize that the disaster services agencies are lead agencies for implementing evacuation
       procedures but may have no experience in relating to food  production  or farming practices

in the area.  Agriculture extension agents and their communication networks may be the
primary notification and implementation method used in protecting the food pathways.

Integrate planning activities so that conflicts  and confusion can be avoided.  For instance,
the requirements for monitoring  the population in  the EPZ require  that  20% of the
evacuated population require monitoring for contamination at reception centers  located
about 15 miles from the plant.  Existing  Food and Drug Administration  (FDA) guides for
protection of dairy products to 50 miles would indicate contamination of microcurie amounts
of iodine and cesium at a reception center located 15 miles from the plant. This dilemma
has been  ignored in the planning process and makes one question  the approach of the
issuance of stand alone guides by the federal agencies.

Emergency workers should be considered the same as the general public.  If samples are
gathered by emergency workers  at locations (50-100 miles) from the affected  area, it does
not seem  sensible to imply by protective dress that the population in those areas may be
contaminated. The protective measures for these workers should be comparable to the risk
that is involved.

Standard Procedures and  Analysis: One of the  most difficult  problems in assessing the
radiological impacts for real  events such as Three Mile Island has been interpreting the
data.  Often,  the data is either incorrect or the errors are unknown. This leads to difficulty
in taking correct protective action and loss of confidence in the entire emergency response

The total  emergency response program must include  the federal  resources at the outset.
It is unreasonable to assume that the state should duplicate the federal resources in meeting
the federal guidelines.

                Implications of the  Chernobyl Accident
                      for Protective Action  Guidance
                                     Charles W. Miller
                                     Andrea J. Pepper

                             Division of Planning and Analysis
                              Office of Nuclear Facility Safety
                            Illinois Department of Nuclear Safety
       The accident that occurred at Unit 4 of the nuclear power station at Chernobyl in the Union
of Soviet Socialist Republics on April 26, 1986, was the worst accident in the history  of nuclear
power. Thirty-one workers and emergency personnel died  and more than  200 site personnel were
hospitalized  as a result of this event  Approximately  135,000 persons within 30 km around  the
reactor were evacuated, and radioactive debris  was  spread throughout the Northern Hemisphere.
There was much public concern generated around the world, and an increased risk of fatal cancer
in the world's population is possible as a  result of exposure to Chernobyl fallout (USNRC, 1987a).

       Since the time the Chernobyl accident occurred,  many  authoritative studies  have been
published, e.g. USNRC, 1987a.  In these studies, differences in design between commercial U.S.
reactors and the RBMK pressure-tube reactor at Chernobyl  have been emphasized, e.g. USNRC,
1987b. While significant differences in design  do exist between  these reactors, we believe there
are still significant lessons to be learned from the Chernobyl accident  for U.S. reactors. The purpose
of this paper is to summarize some of the major lessons to be learned related to protective action

       The  Illinois  Department of Nuclear Safety  (DDNS)  has identified three areas  related to
protective action guidance  for food and water where implications can be drawn from Chernobyl for
the U.S.:  (1) uniformity of Protective Action  Guides  (PAGs),  (2) incompleteness of U.S. PAGs,  and
(3) international communications. Following the Chernobyl accident, a variety of protective actions
were  undertaken by various nations.  Furthermore, these actions were  initiated, modified,  and
terminated at different times in different places and, in some instances, were applied on a local or
regional basis  rather than a national basis  (Goldman et al, 1987).  One result of this differing
application of PAGs was the generation of considerable confusion among  decision-makers and the
public, between and within countries, regarding appropriate levels of response.  For example,  one
country may have considered a  product acceptable for consumption while another country reported
that  the  same level of contamination in the same product  was too high for  consumption.  An
accident in the U.S. could lead to similar discrepancies between States, and between the U.S.  and
other nations.   Therefore, more emphasis  must be given  to both interstate  and international


cooperation in the development of PAGs.   These  guides  should be  developed using similar
contamination action levels and applying consistent dose assessment methodologies. We recognize,
however, that in the U.S. each State is responsible for protecting the health and safety of its citizens.
Therefore, some differences between PAGs for different States may exist.  Through workshops such
as this one, though, the federal government can supply leadership to minimize differences  in PAGs
both within the U.S. and between the U.S. and other nations.

       PAGs have been developed in the U.S. for both the  plume pathway (USEPA 1989) and
for the food pathway  (USDA 1982).   However,  the  PAGs  for the food  pathway,  which  were
developed by the  Food and Drug Administration, specifically do not cover drinking water because
drinking  water standards  fall  within the Environmental  Protection  Agency's  (EPA)  area of
responsibility.  The  EPA has not  issued PAGs for  drinking water, but it  did issue response  levels
for radioactivity in finished drinking water during the Three Mile Island accident (USFDA 1983).
During the aftermath of the Chernobyl accident, PAGs for drinking water sources were applied,
e.g. in the Soviet  Union (USSR, 1986).  The EPA  should move quickly to provide the States with
practical  guidance for drinking  water. This workshop is designed to be a step in that direction, but
it is only the first step.  When this workshop is finished,  EPA must use the information gained from
this meeting to move forward with this guidance.

       As mentioned earlier, radioactive debris from the Chernobyl accident was spread throughout
the Northern Hemisphere.  Small, but measurable, quantities of fallout were even found in Illinois.
Measurements of environmental concentrations and estimates of dose were made by many  different
organizations in many different places. One very noticeable difference in these values was the units
used  to report them.   The U.S. continues to  use  traditional  units of measurement for radiation
quantities, e.g. 7 curies for amount of radioactivity and rems for dose, while most of the rest of the
world  appears to be adopting  the new  SI units of measurement,  e.g. becquerels for amount of
radioactivity and sieverts for dose. This difference has the potential for  creating great confusion
when radiological  information is exchanged across international borders.  We, like many U.S. health
physicists, do not like some aspects of the SI system. It appears, however, that our objections have
not been heard in the  international community, and that SI units are  here to stay.  If that is the
case, EPA should  take the lead to help the U.S. move to SI units.  All future PAG values, including
those that result from this workshop  and its subsequent proceedings, should be published in both
traditional and SI  units.  All States and other federal agencies should also begin moving to  SI  units.
One  outcome  of the   Chernobyl accident has been  a renewed commitment to international
cooperation  in  the   area  of  reactor  safety  and   accident  notification.    Adoption   of  a
universally-accepted set of radiation measuring units will enhance this process.

       There is one other area where the Chernobyl accident can be of assistance in utilizing PAGs.
Mathematical  models  are an integral part of the PAG implementation process.   For example,
intervention levels for radionuclide concentrations in food and water are  derived from PAG dose
limits using environmental transport and dosimetry models. The process of  testing model predictions
with suitable data is known as  model validation.  The  extensive amount  of data  developed  from
monitoring Chernobyl fallout provides an independent data set that can be used to test, or  validate,
the models used  in dose assessment, including those  used with PAGs (Richmond et al, 1988).
International programs  are being developed to test models using Chernobyl data, e.g., Hoffman and
Doming,  1988.  U.S. participation and support for these efforts, however, has been minimal.  EPA
and  possibly  other  agencies of the federal government, should take the lead to  increase U.S.


participation in these model validation efforts.  The information gained from this effort should be
reflected in federal guidance and shared with the States in a timely fashion.

       Although significantly different in design from the Soviet RBMK, release rates similar to
the Chernobyl accident have been postulated for U.S. reactors (USAEC, 1975).  As a result,  it is
important  that persons and organizations responsible for protecting  the public in the event of a
severe  reactor accident learn as much as possible from the Chernobyl experience. The preceding
paragraphs summarize some of the lessons related to water and food chain contamination that we
believe can be learned from Chernobyl.  Through participation in this workshop, as well as other
activities, IDNS is  actively seeking  to apply all the knowledge we  can gain from Chernobyl to
protecting the health and safety of the citizens of Illinois.

   WARMAN, E.  1987.  "Health and Environmental Consequences of the Chernobyl Nuclear
   Power Plant Accident." DOE/ER-0332.

2.  HOFFMAN,  P.O., AND DEMING, E.J.   1988.  The  Use of Chernobyl Data for Model
   Validation" in "Proceedings of the ANS Topical Meeting on Emergency Response -  Planning,
   Technologies,   and  Implementation,"   Charleston,   South  Carolina,   September  26-28.

   P.A.,  MILLER, C.W., NG, Y.C., AND TILL, I.E.  1988.   "The Potential Use of Chernobyl
   Fallout Data  to Test and Evaluate the Predictions of Environmental Radiological Assessment
   Models." ORNL-6466.

4.  U.S. ENVIRONMENTAL PROTECTION AGENCY.  1989.   "Manual of Protective Action
   Guides and Protective Actions for Nuclear Incidents." EPA/520/1-75-001 (Draft).

5.  U.S. FOOD AND DRUG ADMINISTRATION.  1982. "Accidental Radioactive Contamination
   of Human Foods and Animal Feeds." Federal Register, Vol.  47, No.  205, pp. 47073-47083.

6.  U.S. FOOD  AND  DRUG ADMINISTRATION.   1983.   "Preparedness and  Response  in
   Radiation Accidents."  FDA 83-8211.

7.  U.S. NUCLEAR REGULATORY COMMISSION.  1987a.  "Report on the Accident at the
   Chernobyl Nuclear Power Station." NUREG1250, Rev. 1.

8.  U.S. NUCLEAR REGULATORY COMMISSION.  1987b.  "Implications of the Accident at
   Chernobyl for Safety Regulation  at Commercial Nuclear Power Plants in the United States."
   NUREG-1251 (Draft for Comment).

   "The Accident at the Chernobyl Nuclear Power Plant and Its Consequences."  International
   Atomic Energy Agency.

10. U.S. ATOMIC ENERGY COMMISSION. 1975.  "Reactor Safety Study: An Assessment of
   Risks in U.S. Commercial Nuclear Power Plants." WASH-1400.

              PAGS  - Public Perception  and Acceptance

                                     Robert M. Quillin

                                 Radiation Control Division
                               Colorado Department of Health
       While Protective Action Guides or PAGs have been a part of the lexicon of the radiation
protection field for several decades, the  concept of accepting higher levels of risk under certain
situations has not received adequate scrutiny by the general public, the media  or elected officials.

       Consequently there is a question  as to how implementation of PAGs  would be perceived
by the above groups in the event that such implementation became necessary.  A personal case in
point involves the response of an executive in the food industry. When the concept of selling a food
product meeting the PAGs was explained his response was, "we won't sell a contaminated product,
we would dump the unprocessed  raw food.  Our industry image is that of a natural unadulterated
food".  While this may be an isolated view, there is  a need to determine what is the perception and
consequently what would be the response if PAGs were implemented today.  If the response was
negative by anyone of the three groups  listed previously, then  there is an  obvious  need for  a
program to assure receptiveness by those  concerned. However, this may  face formidable obstacles.
This is because the terms radiation and radioactive have gained generally negative word associations,
e.g. "deadly"  radiation and  radioactive "desert".  The former term was recently heard in a taped
presentation at a Museum of Natural History on a completely unrelated subject. The latter term
was part of a recent article heading in the Wall Street Journal.  Incidentally the article was discussing

       Thus  beyond the scientific issues of setting PAGs  and  the  administrative and  procedural
issues of implementing PAGs there  is the issue of society's understanding and acceptance of PAGs.
Particularly, how  can such  understanding and acceptance  be  achieved in  a situation which  is
associated with an actual or perceived radiation emergency?

       These are  not questions that radiation or agricultural scientists can answer alone.  These
are questions requiring the additional input of social scientists.  These are questions that also require
the sponsorship of more  than one particular discipline, agency or organization.  This is to achieve
a broader perspective and understanding of the issue and to stimulate creative ways of making PAGs
work effectively if the need ever arises for their  actual use.   While PAGs  may have  a sound
technical base, this is not sufficient alone to  assure that they will work in today's sociopolitical

                      New Jersey's Experience  with

                Implementing Protective Action  Guides

        During the 1988 Salem Ingestion  Pathway Exercise

                                    Duncan White

                   New Jersey Department of Environmental Protection


       On November 30 and December 1, 1988, the New Jersey Department of Environmental
Protection (DEP) and three other State agencies (Health, Agriculture and State Police) participated
in the ingestion pathway portion of the 1988 Salem Nuclear Generating Station Emergency Exercise.
The purpose of this phase of the exercise was to demonstrate the ingestion pathway components of
the State's Radiological Emergency Response Plan (RERP) to the Federal Emergency Management
Agency (FEMA).  The intent of this paper is to provide a summary of difficulties and some lessons
learned in implementing the DEP's ingestion pathway Protective Action Guides (PAGs) during the
exercise as well as during the preparation of a total population dose estimate (TPDE).

Summary of 1988 Ingestion Pathway Exercise

       The first day of the ingestion pathway exercise was concerned with evaluation of deposition
measurements, selection and prioritization of sampling locations for foodstuffs, and the demonstration
of sampling procedures.  A  majority  of these activities were conducted at the DEP's Forward
Command Post (FCP) located 11 miles  east of the reactor site.  Second day activities were conducted
at the Department's decision-making location, the Technical Assessment  Center (TAG) ,  located at
DEP offices in West Trenton.  The TAC's functions included:

a.     Screening  analyzed samples based on either Environmental Protection Agency's  (EPA) or
       Food and Drug Administration (FDA) preventive and emergency PAGs (response levels).
b.     Isolating and/or  condemning  foodstuffs  on  a  municipal  level  using  the   attached
       decision-making criteria.
c.     Determining the fraction of PAGs using radionuclide concentrations.
d.     Making recommendations to  the State Police on areas to be isolated and/or condemned for
e.     Placing farm animals in the contaminated area on stored feed.

       In addition to the decision-making activities during the exercise, DEP submitted to FEMA
a report that demonstrated  the DEP's ability to estimate the total population dose for the scenario
developed for the exercise.

Problems Encountered Implementing PAGs

       The implementation of PAGs during the ingestion pathway exercise and their subsequent
re-evaluation during the preparation  of  the TPDE raised a number of issues where additional
guidance in the RERP would have  made decision-making at the FCP  and the TAG easier.  A
summary of these issues is presented below.

1. Sampling of Contaminated Foodstuffs

       a.   What is  a representative sample?
       b.   How many samples are needed to adequately evaluate a property?  A municipality?
       c.   To make a protective action decision, should each type of crop be sampled? Each group
           of crops (i.e. leafy vegetables and produce)?  A representative crop from each group?
       d.   How should non-agricultural foodstuffs such as hunting and migratory  birds be  handled?

                                     Lessons  Learned

       For ease of implementing PAGs,  DEP used one sample from each crop group  to either
isolate or impound all foodstuffs for a municipality. The sample used in the decision-making process
was usually taken in the area of highest deposition concentration and consequently represented a
conservative sample.

       Although hunting (especially  deer) can be controlled at weigh-in stations,  the control of
migratory birds is more complicated due to the large migratory range (entire Eastern Coast).

2. Application of Individual Radionuclide Response Levels

       a.  What de-minimis level  should be used?
       b.  Should the thyroid continue to be treated as a critical organ or integrated into a whole
          body dose?
       c.  Only during the  TPDE evaluation was DEP able to better quantify radionuclide intake
          by age groups. Should the most sensitive portion of the population be used to evaluate
          ingestion or should all  age  groups be considered?

                                     Lessons  Learned

       The DEP accepted EPA/FDA  Position on these issues, but feels that future  guidance must
address these.

3. Implementation of PAGs

       a.  What is the appropriate target population for contaminated foodstuffs?
       b.  What and how much data is needed from the field sampling teams?


       c.  Should  doses  from other phases of the exercise (plume and deposition) be included
          during decision-making for ingestion PAGs?

                                      Lessons Learned

       The  target  population was  assumed to be the municipality where the crop was grown or
harvested.  There was no easy means to determine the distribution of these crops to market due
to the proximity of large population centers (i.e. Philadelphia and New York).  In addition, there
are a large number of truck farms with multiple crops which influences the effective implementation
of the PAGs.

       There  was  a tendency to  use one short-lived radionuclide (i.e. 1-131)  and one of two
long-lived radionuclide (either Co-60 or Sr-90) in determining PAGs for foodstuffs.  Due to the
time constraints during  the exercise,  it was later discovered during the TPDE  that some  initial
decisions were erroneous because other radionuclides were not included  or were more restrictive.

                           Decision  Criteria For Recommended
                          Ingestion Pathway Protective  Actions
                                            Contaminated  Food,
                                                Milk, Water
                             > 1-131
                          Emergency Response
 OX for
NorMl Use
            < 1-131
                           > 1-131 Preventive
                           <1-131 Emergency
                           Response Levels
 Long-Li ved
                   Isolate Food fron
                   Market, Store for
                   frantitative and
                  Qualitative Analysis
                     Divert for Use
                    in Manufactured
   Concentration of  Muclide ft
   Preventive Response Level A
                       Concentration of Muclide B
                      Preventive  Response Level B
 Concentration of Muclide C
 Preventive Response Level C



                            Chairman:  Bruce  Denney, Minnesota

ISSUE:   For what protective actions and situations are ingestion PAGs needed?

1.   What are  the  problems  and  benefits of  having  different  PAGs  for emergency  and
     non-emergency accident conditions?  Likewise for near-field and  far-field conditions  with
     respect to time and distance from the accident location.

     After much discussion regarding what this question really asked, it was determined that the
     words "need for food" should have been added after the  "non-emergency".  So the question
     really referred whether or not there is a need to have different  PAGs for accidents in which
     there is a normal uncontaminated supply of food and for accidents in which there is a shortage
     of these foodstuffs.

     The  group concluded  that PAGs  (protective  action  guidelines)  should  address  "normal"
     accidents, i.e. those  in which there are foodstuffs available.  Modifiers or multipliers of some
     sort should be applied to other  specific situations.

     In terms of defining what the PAGs should be, many group members believed that a single
     numbered approach  would be easier to use than the present two-tiered Preventative-Emergency
     approach and that  such a system would be  more in line  with what is happening on  the
     international level.  In addition, mention was made of using a system of derived intervention
     levels, e.g. that are present in the CODEX  document, instead of dose levels.

     With  regard to far- and near-field situations,  many opinions were expressed regarding what
     they  really are. Is near-field for the ingestion pathway the 50 mile EPZ or the country from
     which the contamination originates from? Is far-field anything greater than 750 miles away or
     is it a neighboring country affected by the fallout?  In any case, the group decided that the
     same PAGs or derived intervention levels should apply to  either situation -  near- or far-field.

     Lastly, in terms of the time factor, it was determined that one year was the appropriate amount
     of time that the PAGs should be applicable.  After one year,  long  term guidance involving
     lower PAGs or models incorporating planned exposures should be incorporated.

2.   Which types of conservatisms are appropriate and which are not appropriate for consideration
     in the development of PAGs? Which conservatisms may be best relegated to derived response
     levels or other guidance?

     The workshop group decided that the conservatisms used in the development of the PAGs
     and DILs (derived intervention  levels) should be the same.  Factors such as age dependent
     DCFs (dose conversion factors), diet, pertinent radionuclides and pathways were discussed.  It
     was agreed that agreeing  on  the proper conservatisms was a very  difficult task - but  that


     somewhere along the line, it must be done.  Many of the group members felt that the PAGs
     should be based on doses to standard man and that there are enough conservative assumptions
     built into  standard  man DCFs,  that  use  of the DCFs would also protect more  sensitive
     population segments, e.g. infants.  Use of such a PAG would only involve calculating the dose
     for adults and eliminate the need to also calculate doses for infants.

     Other discussions also demonstrated that many people have differing ideas as to what PAGs
     really are.   Are they doses?  concentrations?  guides? or guidelines?  Are PAGs and PARs
     (protective action recommendations) separate entities or  are they part and parcel of the same
     thing?  Some members  expressed a concern that the definition and use of this term should be
     clarified in  the guidance and that some other  term, e.g. intervention  level,  etc., might be a
     better term to use.

     Lastly, it was expressed that PAGs and DILs may be of little practical use, since State governors
     are often the ultimate decision makers in the States, and are free to change  PARs based on
     political, economic or other considerations.  Perhaps there is a need for adjacent States  and
     countries to have memorandums of understanding to agree upon the PAGs and PARs that they
     will  use in case of an accident.
3.   What type of guidance is  needed regarding cumulative dose?  What are the problems and
     benefits of this type of guidance?

     After some discussion it was decided that the term cumulative dose referred to the  sum of
     the plume dose, re-entry-relocation dose, and ingestion-dose - not the collective or population

     It as  the view of most of the group that there is no need to sum these doses and that each
     one should be treated independently of the others. This is further addressed in a later question.
4.   Which protective actions for the ingestion pathway need specific PAGs?

    Discussions within the work group indicated that there are three groups of protective actions
    that may or may not need PAGs:

    1)   High  impact  protective  actions, e.g.  embargoing, in  which concentrations or doses are
         greater  than  the interdiction  levels  or PAGs (e.g. DILs = CODEX  criteria),  need
         protection actions.

    2)   Long  term protective actions, e.g. seedling, liming soil, etc., need protection actions.

    3)   Low-impact preemptive or precautionary protective actions, e.g. puting animals on stored
         feed, may not need PAGs because they're done for ALARA purposes.

5.   What are the problems and benefits of having a specific PAG for each protective action?

     There are a wide variety of radiological situations that may justify the development of PA
     specific PAGs.  The use of such multiple  PAGs,  however, may actually  hinder PA decision
     making processes  due to the  increased complexities and time involved in manipulating and
     assessing the PAGs.

     To minimize these potential problems, it may be best to establish a smaller  number of PA/PAG
     combinations that would be applicable to many different accident scenarios.
6.   What problems should be addressed in developing separate PAGs for water and food?

     A  major problem  in  developing  PAGs is  that guidance  appropriate for specific  accident
     scenarios,  e.g. nuclear power plant accidents, may  not be appropriate  for other  types of
     nuclear-related  accidents.   This  process  is further  complicated  by  the  existence of many
     jurisdictional divisions  within the federal government, each of which has its own  authorities
     and methods  of doing business,  etc. Although it may be "cleaner" to keep agency guidance
     separate, the  development of uniform  PAGs applicable  to all radiological accident situations
     may be more  effective.

     With respect to PAGs for water and food, for example, the working group decided that there
     is a need to develop a PAG for water  for emergency conditions and that this PAG should be
     similar to the PAG for food under similar conditions.

     Another consideration brought  up in  the group is  that if all water treatments  can lower
     concentrations to levels less than the 4 millirem per year limit, why bother with an  emergency
     water PAG?
7.    What environmental conditions differentiate between emergency and non-emergency accident
     conditions for ingestion exposure pathways?

     This question was not discussed by the working group.
8.   What problems should be addressed in the development of separate PAGs for home produced
    or collected food and drinking water as compared to food and drinking water in commerce?

    The working group decided that the PAGs for both situations should be the same,  but that
    the protective actions for these groups may be different.   For example, commercial apple
    growers may need to clean their apples in  a manner different than the homeowner with a few
    apple trees should take.

    It was also  decided that it may be necessary to identify  special population groups that may
    require special PARs. The best means of identifying these groups is by using local agricultural


9.    What problems should be addressed regarding the relationship of ingestion PAGs to other
     categories of PAGs?

     The question refers to summing plume, recovery and ingestion doses  together.  The working
     group decided that this is not appropriate during the emergency phase or first year, but  that
     there may be a benefit for establishing such a dose limit for long term exposure.  This  should
     be addressed in future recovery guidance.

     In addition,  concern was expressed regarding the confusion or dilemmas that conflicting or
     incompatible federal guidance may  create.  An example of this is the  FEMA requirement for
     decontaminating  20% of the 10 mile EPZ  population at relocation centers which may be
     located only 15 to 20 miles from the affected plant.  If these centers are in areas which are
     considered to be  contaminated  because of ingestion pathway concerns,  the surrounding
     groundshine may inhibit decontamination efforts by masking the contamination on the evacuees
     themselves.  In addition, there may  be little merit in decontaminating evacuees when they  may
     become recontaminated as they exit the decontamination facility.

     Clearly there is a need for federal agencies, States, etc., to confer and  consult with each other
     so that consistent and coordinated  guidance will be produced.  To make this guidr^ce work,
     of course, concurrence must be reached by all of the agencies involved.
10.  When should ingestion PAGs be replaced by limits for population exposure under normal
     conditions?  What problems should be addressed regarding this topic?

     The working group obtained clarification  on this question and determined that the question
     was not one of using the population  doses  as  a basis for initiating PARs, but rather   by
     deleting the word  "population" from the sentence - was a question regarding how long  PAGs
     should be applicable. This was determined to be one year, after which the limits of exposure
     should become more in line with the limits for normal  operations.
11.  What problems should be addressed with regard to special categories of foods and  special
     population groups?

     The working group  decided  that special foods and population groups  should be  treated as
     exceptions to the general PAG guidance and  that such cases  may  merit  individual  PAs.
     Questions were raised regarding the point at which these  PAs should be applied -  i.e. during
     processing; at end point of consumption; etc.  This needs  further evaluation.

                             Chairman:  Charles W. Miller, Illinois

ISSUE:  What considerations should be evaluated in the process of selecting PAG values for
         ingestion pathways?

     This  Working  Group addressed the issue "What considerations should be evaluated in the
process of selecting PAG values for  ingestion pathways?".  During its deliberations, the Working
Group considered nine questions, eight developed by EPA staff prior to the meeting and one based
on discussions during the  first half-day of the Workshop.  Each of these questions is listed below,
followed by  a summary of the Working Group's conclusions about that topic.

1.  The basic principles for selecting all PAG values can be summarized as:

     Avoid unreasonable risk of radiation induced health effects, and

     avoid additional health risk when it is cost effective to do so; but

     the risk from the protective action itself must be less than the radiation risk avoided.

     What problems  may be encountered in applying these principles to ingestion  PAGs? Are
     additional principles needed?

     The first principle listed involves the idea of setting a PAG on the basis of health risk.  This
     principle is the chief driving mechanism in the process.  Health professionals often state that
     this principle should  be the only principle  for setting health related standards. Standards are
     actually based on "acceptable risk", however, rather than just pure health risL

     The second principle listed is difficult to implement and a source of great controversy.  It may
     be implicitly involved in the "acceptable risk"  decision, however, even when its explicit inclusion
     is vehemently avoided, i.e., there are limits to what society will pay to lower the risk.

     The third  principle  is  more of an  implementation problem  than a PAG-setting problem.
     Basically,  it says  there are exceptions to every rule.  Often, this principle is not quantifiable,
     and it  is subjective rather than  objective.   For example, following the Chernobyl accident,
     Sweden raised the allowed limit for radioactivity in reindeer because their original PAG would
     have  caused unacceptable societal costs  to Laplanders.

     The Working Group also suggests that a fourth principle be added to the list:

                 The PAG system developed  should be as simple as possible.

     For example, one  should not  develop different PAG guidance for different phases of the
     accident. An overly complicated PAG system will only lead to confusion for both those officials

    who must apply  the  PAG and those members of the general public who must ultimately
    implement any protective action recommendation.

2.   What  problems are introduced or avoided  by the use of fixed value PAGs as opposed to
    ranges of values?

    Where ranges  of PAGs  are used, confusion, indecision, and disagreement may result when
    deciding which PAG to use.  There is, in many cases,  a tendency to accept the lower, more
    conservative number as the predominant PAG.  There may be justification for ranges of PAGs,
    such as socio-economic reasons; but if ranges are used,  plans should stress when and how the
    ranges are to be  used.

    Single PAG values are much easier to implement and, in most cases, will result in  fewer
    problems than  a  range of PAGs.  Even when  single values are used, they may be adjusted
    according to circumstances which may warrant changes.

    In summary, we recommend that PAGs be based on dose and be single fixed values.
3.    What problems should be addressed regarding harmonization of PAG values between States
     and between countries in the selection of PAG values?  Are the problems different where
     commerce is the issue?  Units?

     The only way of  achieving protection without falling into  the  "zero  risk"  trap is to have
     credibility.   Therefore, it is essential that everything reasonable be done to give  any PAG
     credibility.  Some of the  things needed  to achieve credibility are:

         Scientifically supportable.

         Accepted by the States.

         Accepted by all other relevant governmental jurisdictions.

         Preferably accepted  by other countries.

         A single value (rather than a range).

         Costs must be considered, and the costs expended must be  reasonable (neither too high
         nor too low).

     EPA can play an important role in helping to achieve credibility.  It speaks with a single voice,
     is authoritative, and speaks for the whole nation.  Nevertheless, in order  to establish  a credible
     PAG, the EPA must:

         Work  with the States  in  establishing  the PAG (or,  perhaps,  with  CRCPD  or  a
         subcommittee of CRCPD).

         Demonstrate a good faith effort in dealing with the concerns of the States and with other
         public interest groups (although generally it will not be possible to completely satisfy each
         State or public interest group).

     Credibility and harmonization between States is the best way of impeding political interference
     by State governors.

     EPA is probably the best agency to work towards harmonization between countries.  It must
     be recognized that harmonization  between countries  will be much more  difficult  to achieve
     than harmonization between States because  of variation  in level  of economic development,
     cultural values, and perception of risk.  There is no agency or  body that speaks for the whole
     world in a way similar to the role played by EPA for  the nation.

     PAG values should probably be  expressed in international units.  This is especially important
     in achieving harmony between countries.
4.    What social/political  problems  should be  addressed in the selection  of  PAG values for
     ingestion pathways?

     The social/political problems which  are faced in the use of PAGs are related to the need to
     communicate with the public  and decision  makers in simple, direct language which  will be
     accepted by those groups.  This presents the difficulty of the use of terms which are understood
     by the public and decision makers (e.g., safe  levels) versus terms which are used in radiological
     health (e.g., comparative  risks).   In addition  to communication issues, there is a  need for
     consistency with  other similar guides or standards.  The terminology used  should be the same.
     In the  international  community the  terminology used  is  Becquerel and  Sievert.    It is
     recommended that PAGs should be stated in the same  terms for consistency  and ease of
     comparison.  Compatibility of standards is a key to acceptance, as is simplicity and consistency.
5.    What problems need consideration in selecting PAGs for particular exposure pathways and
     population groups?

     The iodine-milk-infant pathway is considered a critical exposure pathway. Differences between
     the diets of the general population and infants may also need to be considered, as an infant's
     diet is predominantly milk.

     A standard U.S. diet should be established.   This will allow all to know the basis for PAGs,
     and everyone will have the same guidance.

     The guidance needs to thoroughly explain the assumptions and data supporting derivation of
     PAGs.  In going from dose to Derived Intervention Levels (DILs), the rationale/reasoning for
     this conversion must be carefully explained.

     The group suggests using a single dose PAG for all  ages of the general population; do not
     establish an infant-only PAG.  Also, during an emergency, the same number should be used
     for milk and water.

     EPA should emphasize that the PAG is a generic calculation  for decision making only, not
     an indicator of actual dose to a person. It is the responsibility of States and local governments
     to apply PAGs to special population groups under their jurisdictions.

6.    What problems require evaluation with respect to selection of PAG values to apply to different
     types of accidents (e.g., accidents involving primarily beta-gamma  emitting nuclides versus
     those involving primarily alpha emitting nuclides)?

     In applying these PAGs  to DILs,  if the peak concentration value is used, more information
     needs to be developed on weathering, root uptake, and other factors that affect the projected
     human intake. If a constant concentration is used,  this problem should not be there.

7.    What problems should be evaluated regarding a change in the dose quantity from c' jmiited
     dose equivalent (CDE) to committed effective dose equivalent (CEDE) with special limitations
     to the thyroid in terms of committed dose equivalent?

     There will be public perception that government is pushing  the limit up if we do not have a
     separate limit for the thyroid.

     International recommendations have separate limits for organs.  To  ignore them will require

     Mixing CEDE with CDE is contrary to the proposed principle of simplification.

     The factor of 3 difference between the .03 weighting  factor for thyroid and the international
     limitation of 10 times the CEDE value for organs may not be significant if other uncertainties
     are considered.
8.   What problems are created or solved by considering the cost of specific protective actions?

     Cost is usually implicitly considered in most health or protective actions.  The difficulty is the
     explicit consideration of cost because it has numerous (and almost inherent) uncertainties in the
     calculations. Those factors used (and  assumed) can be calculated by many individuals or groups,
     resulting  in continuing controversy.  Cost should be  analyzed as part of the evaluation on
     whether achieving the proposed level is  reasonable.

     If cost is  used explicitly in developing dose or derived levels for specific foods or food actions,
     this will likely result in different levels and destroy the simplicity of the guidance. It will then
     be difficult to explain  why higher levels  are allowed in certain cases.

     In conclusion, a basic cost analysis should show the acceptability of the levels selected or other
     factors (i.e., acceptable risk).  That is, such selected values should be  used  unless the cost
     analysis shows that the cost of achieving such levels  is unreasonable.

9.   Should there be separate PAGs for food and water?

     The group suggests one  number  for water and milk. (This will help with  public perception.)
     Water and milk should be generally considered as food.  EPA should take into consideration
     how this one PAG number impacts both the adult and child.

                           Chairman:  Michael Mobley, Tennessee

ISSUE:  What considerations are important for the development of guidance for protection from
         contaminated water?

Herein is provided a narrative of the conclusions reached by Work Group 3, which was tasked with
the problem: What considerations are important for the development of guidance for protection from
contaminated water?  The Group was chaired by Michael Mobley (TN) with Charles High (PA) as
the scribe.

The narrative is driven to some extent, by the example topics provided in the guidance to the Work
1.    What problems should be evaluated regarding the allotment of a portion of the ingestion
     PAG to drinking water as opposed to having separate PAGs?

     The group response to the question went beyond the scope of the question and addressed a
     proposed fundamental  philosophy for the entire ingestion PAG issue.  Several  axioms  or
     boundary conditions apply to the philosophy.

     a.   The PAG is an effective whole body equivalent dose commitment.

     b.   The PAG for ingestion  should be considered separately  from those for plume exposure
         and for reentry and relocation.

     c.   The PAG for ingestion should include anything  that is put into the mouth and swallowed;
         i.e. food and water considerations are combined rather than assigned separate and distinct

     d.   The practical expression  of the PAG should be in terms of concentration (pCi/1 or pCi/kg)
         of each specific radionuclide likely to be encountered. This concentration should be called
         the Interdiction Level.

     e.   The Interdiction  Level  is  applicable at any  stage  in  the food/water processing for
         consumption; from raw to packaged.

     f.   The term "interdiction"  means that reaching or exceeding that concentration  requires a
         conscious decision.  It does not mean condemnation.

     g.   Where a mix of isotopes is observed in a sample, the sum of the fractional Interdiction
         Levels shall not exceed unity.

     h.   Compliance should be determined by  radioassay.  Protective Actions, however, are not
         necessarily contingent on radioassay.

     i.   Consideration could be given to parceling the PAG into three compartments; for example,
         water, solid food, and milk based on model diets according to relative consumption rates
         (liters per day or kilograms per day), and using the most sensitive group for each vector.

     j.   If only one vector is contaminated, say milk, the entire PAG may be used for that vector.
2.   What exposure pathways from contaminated water other than drinking water are likely to
     be a problem?

     a.    Given the system described above,  problems should be minimized, since water is water.
          See also items 6, 7, and 8.

3.   What problems may be  caused by  surface runoff? What types  of  guidance  would be

     a.    Occurrence of runoff should require additional monitoring to assess consequential changes
          in water concentrations and isotopic mix.  Then apply principles  in topic 1, above.

4.   What situations or special population  groups may cause specific exposure problems  that
     require guidance?

     a.    The combined PAG is driven by the most sensitive group for each  vector.  Also since
          the  Interdiction Level applies  to any level in  the process, most food fetishes will be
          indirectly addressed.  No guidance is needed for the short term,  say,  the first year.
5.   What monitoring problems need evaluation and resolution?

     a.   Calibration sources shall be NBS traceable.

     b.   The chain of custody for samples should be established.

     c.   The Lower Limit of  Detection (LLD)  for  each  analytic  method  should be defined

     d.   The required value of the LLD should be established for each nuclide, and perhaps each
         vector if the PAG is to be allocated among water, food and milk.  For example, should
         the LLD be 0.1  of the Interdiction Level,  or  should it be 0.05?
     e.   A  protocol for sampling priorities should be developed; i.e. what do you grab first.

     f.   A protocol for analytic considerations should be developed, a sort of triage.  This is due
         to the fact that the lab capacity for through put will be the constrictor in the process.
6.   What problems, solvable by guidance, are related to contaminated water (non-drinking water)
     under accident conditions?

     a.    Consideration of drinking water for  livestock and water for irrigation are beyond the
          scope of this discussion.
7.   What problems or benefits should be evaluated regarding water treatment facilities?

     a.    Two problems are the disposal of flock and other water treatment wastes, and the disposal
          of sewage sludge.  The resolution of the problem will require some method of determining
          the point at which these wastes will require special treatment, and by whom.

     b.    Some thought should be given to the limiting concentration, if any, for the use of water
          for sanitary purposes and for fire protection.
8.   What problems are related to the weathering of water systems?  How do they relate to the
     type of system?

     a.    Turnover rate must be considered along with the body of water in  question with rivers
          of concern for shorter periods, and reservoirs for longer time frames.

     b.    Guidance is needed for the selection of a removal coefficient or its  derivation based on
          decay, weathering, and turnover.
9.   What problems can legally be solved by dilution?

     a.    It is customary to blend water to achieve desirable water quality.

     b.    Deliberate dilution of food for the purpose of lowering a contaminant concentration is
          not an acceptable practice, according to FDA rules.

                           Chairman:  Duncan White, New Jersey

ISSUE:   What guidance is needed to support implementation  of  PAGs for  ingestion exposure


     This report summarizes the discussions of Working Group 4 at the "Workshop on Protective
Action Guides for Accidentally Contaminated Water and  Food". The Working Group discussed
the guidance needed  to support  implementation of Protective  Action Guides (PAGs)  for the
ingestion exposure pathway.  The group expressed concerned  that any derived response levels
(DRLs) that were developed  for contaminated  foodstuffs should be  as simple as  possible and
uniformly implementable. This concern resulted in the group recommending guidance which would
serve as the basis for developing DRLs per radionuclide per given  food group. The Working Group
envisioned  the  PAGs implemented as a  single set of  DRLs  based  on  the entire  diet being
contaminated for the maximum exposed group in the population. It was felt that PAGs based on
DRLs derived in this manner  would provide sufficient protection to the entire population. Since
the DRLs were derived for the most critical group in the population, there should be no need for
different DRLs for special population groups.

     The remainder of the paper  summarizes the Working Group's discussions and/or consensus
on the 11  topic areas identified for this issue.

     Discussion of Topic Areas

1.    What problems or  benefits are  associated with the  categorization of DCFs  and DRLs for
     nuclides into two or three values for the purpose of simplification?  How do these problems
     relate to special population groups?

     The Working Group felt  that dose conversion factors (DCF) and particularly DRLs used for
     the implementation of ingestion PAGs should be as simple as possible.  In the course of the
     group's discussion of this  topic, a  number of issues were identified  and discussed.

     a.   PAGs should apply to all nuclear accidents, although it was recognized that the greatest
         application of the PAGs would be nuclear power plant accidents due to the radionuclides
         involved and area impacted.

     b.   The methodology for implementing PAGs should be provided to the States so that their
         implementation would be uniform  and consistent.  Specific examples  would  include
        sampling protocols, analytical procedures, DCFs and food intake factors.

     c.   Under current guidance, direct measurements of the foodstuffs in question are  needed
         in order for the authorities to interdict and remove the  contaminated foodstuffs from the
        market.   The group  agreed  that the authorities should be able  to interdict foodstuffs


         without any measurements because it would provide more time to evaluate the impact of
         the accident Likewise, there should be no geographic limitation on interdiction. Decision-
         makers need the flexibility to look at the overall seriousness of the situation and balance
         potential losses.

     d.   International guidance should be considered during the development of guidance for the

     e.   PAGs should be expressed as whole body dose equivalent.

     f.   The discussion  of applying PAGs to special population groups lead to the consensus that
         the DRLs should be structured around the most critical group in the population. If this
         is done, there would  be an added level of safety for the rest of the  population  and no
         other special group needs consideration.  The group identified as the critical group for
         nuclear accidents impacting the ingestion pathway were  farmers because they  had the
         highest potential  of any group in the  general population  for  consuming home-grown
2.   What problems or benefits are associated with assuming that the entire diet is contaminated
     for purposes of conservatism and simplification?

     This  issue is a continuation of the critical group approach discussed in  the previous section.
     Since the local fanners would probably have the largest portion of their diet from  food and
     water taken directly from contaminated areas, assuming that their entire diet is contaminated,
     would provide sufficient protection to the remainder of the population. Assuming that the
     critical population's entire diet is contaminated does raise a number of important issues.

     a.    Assuming that  the entire diet is contaminated makes the  calculation of DRLs simpler.
          A single  DRL per radionuclide per foodstuff could be determined.  If multiple nuclides
          are involved for a single foodstuff, their sum should not be greater than unity.

     b.    The risk of assuming that the entire diet is contaminated is a DRL that is too conservative
          because of the  assumptions introduced.   Examples  of conservatisms introduced would
          include:  assuming that  the entire  diet  is  contaminated, use of peak radionuclide
          concentrations  instead  of average  concentrations and protection from stochastic effects
          based on the population versus an individual. The best way to limit the overly conservative
          nature of the DRLs  would be the  evaluation of several scenarios with the range of diets
          expected in the population.  This would provide an assessment of what is likely to really
          happen instead of the worst case.  This type of evaluation is analogous to Reactor Safety
          Study (WASH-1400).

     c.    Not everyone has the same diet. The single DRL determined for a particular food stuff
          may not offer the level of protection intended because it may have been derived based on
          a particular mix of foods. In these cases, the DRL could be  used as a screening level until
          a site-specific dose assessment is performed.

3.    What implementation problems are associated with having different PAG values for emergency
     response and for food in commerce under accident conditions ?

     The Working Group recommended that only one set of PAGs be used for all foodstuffs. The
     system with two tiers of PAGs, one for emergency conditions and a second one for commerce
     or preventive situations could not be implemented.  The lower or preventive PAGs  would
     become  the only guidance utilized. The food with radionuclide concentrations between the two
     tier levels would not be utilized because of its acquired label.  With the one tier system, there
     is sufficient protection to the population because if the maximally exposed individual meets the
     DRL, then the  rest of the population should meet the PAG.
4.   What should be done to increase public comprehension and improve communication with
     the public regarding radiological emergency response planning and guidelines?

     In order to improve the public's comprehension of radiological emergency response planning
     and guidelines, the group identified two courses of action.  The first would be the creation of
     a document that is prepared for non-technical people such as reporters and  political officials.
     Secondly, intervenor groups and the public  should be briefed on  the basic concepts and how
     the DRLs were derived.
5.   What problems can be solved by evaluating the effectiveness of specific protective actions?

     The best place to evaluate the effectiveness of the PAGs would be in the marketplace at the
     wholesale level.  At this point,  if there  are still radionuclide concentrations in excess of the
     DRL, then interdiction would be more effective than at  the retail  level.

     The group felt that a de-minimis criterion is needed to stop testing foodstuffs on an emergency
     basis.  It would serve as a benchmark for the transition from emergency to routine monitoring.
     In the laboratory, this  would have practical implications since the level of analytical sensitivity
     is different for emergency samples compared to the routine samples. With regard to estimating
     the total population dose, the existence of a de-minimis level  would limit the extent of the
6.    What  implementation problems have  been experienced  with regard to specific protective
     actions?  What evaluations or guidance is needed regarding these problems?

     As discussed above, the use of two tier system is not practical and should not be recommended
     in federal guidance.  For example, there is little chance food processors would accept milk with
     radionuclide concentrations between the preventive and emergency PAG to make cheese or ice
     cream. This highly unworkable scenario and ones like it should not be endorsed or suggested
     in the guidance.  The use  of a single tier system eliminates these types of problems.

     The development of  PAG guidance should look at reasonable scenarios such as power plants
     and transportation accidents.  The nuclear war/general disaster scenario is not appropriate.


     The final implementation problem discussed  by the group was the lack of federal consensus
     in this  area.  Without such consensus, conflicting guidance from  two different agencies will
     result in implementation problems for those affected, namely the States. Conflicting guidance
     also contributes to a credibility problem for public officials during  the emergency.
7.   What  problems have been experienced in the application of DCFs or DRLs  that require
     special evaluation or guidance?

     The discussion of current federal guidance (such as FEMA REP-13) lead the group to conclude
     that although the PAGs for foodstuffs in this document are workable, the evaluation process
     is cumbersome and requires a good deal of training to be used effectively.  A better approach
     to implementing the PAGs for contaminated foodstuffs would be a system of pass or fail. The
     use  of individual nuclide specific limits for each foodstuff eliminates much of the need for
     special guidance.

     The implementation of the PAG guidance  endorsed  by the group would require a significant
     amount of evaluation and assessment before  the DRLs are  determined.   If  this .vork is
     performed prior to any accident and incorporated into the appropriate emergency plans, then
     the implementation should not  be too difficult.
8.   What problems regarding disposal of contaminated water or food require special evaluation
     or guidance?

     The group did not see any particular problems for disposing of contaminated foodstuffs.  The
     contaminated  foodstuffs should be put back on the ground where they originally came from.
     This is no different than the current protocol  used for wash water from  decontamination

     The long term disposal issue becomes the contaminated soil.  This soil could be allowed to
     decay, plowed under or treated as low level radioactive waste where it would be dug up and
     disposed of in a licensed facility.

9.   What problems have been experienced in the implementation of ingestion PAGs for special
     population groups?

     The issue of special population groups was discussed in the first sections. If the single nuclide
     specific limits  for each foodstuff is implemented  as discussed, there would be no concern for
     special population groups  because the DRL would provide sufficient protection.

     If the special  population group's  food source became contaminated, then an alternative food
     source could be substituted to prevent a  food shortage. If the diet of the special population
     group deviates far from the basis of the  DRLs,  (Eskimos instead of the farmer) then a diet


    specific assessment would be needed to determine acceptable DRLs to meet the PAG.  As
    indicated  above, until this assessment is  performed,  the  original  DRLs could be  used  for
10.  What problems arise from implementation of relocation and food restrictions simultaneously
    under separate PAGs?

    The implementation of relocation and ingestion PAGs simultaneously would not present any
    problems for most of the population because they will be well below the single set of DRLs
    proposed for contaminated foodstuffs.  The portion of the population not relocated would be
    potentially exposed to the contaminated foodstuffs and would be subject to the ingestion PAGs.
    There could be special restrictions on certain members (assume most sensitive) of the relocated
    population if no locally grown food is  available.  In this case, the change in diet may require
    reassessment of the  DRLs,  not  the  PAG.  As long as  the ingestion DRLs  are met, the
    population should have sufficient protection.
11.  What  problems  are associated  with the long-term management of food  production  on
    contaminated land? What evaluations or guides are needed to resolve these  problems?

    The long  term  management of  contaminated foodstuff  would consist  of  the continued
    measurement of  foods and comparison of those results  to  the single tier DRLs.  Return to
    routine monitoring of  food when de-minimis levels are  reached.  Depending  on the time of
    year of the accident and the type of crops grown in the contaminated areas, monitoring of
    foodstuffs could continue for a few years.

    There  may be a need  for special studies  and sampling of the soil to determine suitability for
    agriculture.   Surface water  sources  may also require further  evaluation  to determine their
    suitability for irrigation, recreation or drinking.  Long term studies of radionuclides trapped in
    river, lake or estuary sediments may also be needed.  Any of these studies would provide
    information needed to make decision on  the use,  access or need  for  additional  remedial


Appendix A
           Proposed FAO/WHO Levels for Radionuclide Contamination
                      of Food in International Trade Following
                            an Accidental Nuclear Release

I.  Purpose

1.  The aim of this document is to provide to the Codex Alimentarius Commission joint FAO/WHO
recommendations to control foods in international trade that have been accidentally contaminated
with radionuclides.  The goal is  to provide a system that can be uniformly and simply applied by
government authorities and yet one that achieves a level of public health protection to the individual
that is more than adequate in the event of a nuclear accident

2.   The levels proposed are based on very conservative assumptions and are intended  to be used
as values below which no food  control  restrictions  need to be applied.   Measured values above
these levels are not necessarily of public health concern but should alert the competent food control
authorities for the need to assess the potential health detriment

II.  Background

3.    Following  the April 1986  Chernobyl, USSR  nuclear reactor  accident,  large amounts of
radionuclides were released into  the atmosphere and carried by weather patterns prevailing at that
time for many thousands of kilometers through Europe and the Northern Hemisphere.  At the time
of the Chernobyl accident there was  a  definite lack of comprehensive international guidance on
radionuclide contamination and authorities responsible for agriculture, environment, health and trade
were unable to take uniform  action to control radionuclide contaminated food and feed.  Differences
between countries on acceptable  levels of contamination of food led to confusion and disruption of

4.   Compared with background radiation from natural and  man-made sources that existed before
the Chernobyl  accident,  exposure to  X-rays for  medical purposes  and  other  types of radiation
exposure, radiation  protection experts  pointed out that exposure to Chernobyl-related radionuclide
contamination would add only a small increment to pre-Chernobyl levels of exposure.  Due to the
known carcinogenic and mutagenic effects of radiation and  varying estimates of increased rates of
cancer from  Chernobyl-related  contamination, many  consumers were  not reassured by these

5.   For about four  to six weeks  after  the Chernobyl accident confusion existed about whether or
not to let children play outside, whether or not  to plough under leafy green vegetables exposed to
heavy fallout and whether or not  interdiction of local and international  shipments of foods and
other agricultural products was warranted.  Most countries that were directly affected by radioactive
fallout from Chernobyl took significantly different  and usually less restrictive approaches to control
the levels of radionuclide contamination in food than those countries that were not directly affected.

6. Following the widespread confusion and concern that existed after the Chernobyl accident, FAO,
WHO and IAEA took action to provide additional guidance to member countries on appropriate
responses to nuclear accidents.  Other bodies such as the Organization for Economic Cooperation
and Development (OECD) and the Commission of European Communities (CEC) also took action
to provide  guidance  to  their member countries.  The  International  Commission on  Radiation
Protection (ICRP) also undertook to review  its previous guidance on nuclear accident responses.

7.  Shortly  after the Chernobyl accident,  the  Director-General of FAO  called on  the  FAO
Secretariat, working in close collaboration with WHO and IAEA, to develop limits for radionuclide
contamination for foods in trade which could be accepted by the FAO/WHO Codex Alimentarius
Commission and utilized  by FAO and WHO  member countries to assure orderly trade in foods in
the event of accidental  contamination with radionuclides.   The FAO  Secretariat commenced this
work through preparation of papers examining various aspects of the problem, which were reviewed
by the December 1986  FAO  Expert  Consultation on Recommended Limits  for  Radionuclide
Contamination of Foods.  This Consultation included food control, radiation protection, and safety
experts from  several countries.  The recommendations  of the FAO  Expert Consultation were
transmitted by the FAO Director-General in January 1987 to all FAO member countries, all United
Nations agencies and to all other known interested parties so that the FAO recommendations could
be used as interim guidance in controlling foods in international commerce until all consult? ^ons and
final recommendations were available from FAO, WHO and IAEA.

8. The FAO Expert Consultation Report  and recommendations were introduced into the  Codex
Alimentarius Commission approval and recommendation process by requesting the Codex Committee
on Food Additives and  Contaminants  (CCFA) to consider the FAO report in its March 1987
meeting,  prior to the June-July  1987 Session  of the Codex Alimentarius Commission  (CAC).  The
CCFA reviewed and generally endorsed the FAO Expert Consultation report, commended FAO on
its rapid  action, and requested FAO  and WHO to convene a Codex Working Group prior  to or
during the  June-July CAC Session  so that  Codex member  countries  could include appropriate
expertise in their delegations  to consider the  FAO Report in depth before any action by the CAC.
A Working Group was scheduled as requested by CCFA to meet during the CAC session but was
subsequently cancelled at the request of WHO which suggested postponing the CAC review until
after WHO had completed its work on developing guideline values. The June-July 17th Session of
the CAC took  note of  the  CCFA recommendations, commended FAO for providing the only
available  international recommendations for radionuclide contamination in foods in trade and urged
speedy completion of the WHO work so that a joint FAO/WHO  approach could be reviewed for
approval  by the CAC Executive Committee in its July 1988 session.

9. The FAO December 1986  Expert  Consultation  utilized food control principles  to  uniformly
allocate the total amount  of radioactivity from a dose of 5 millisieverts (5 mSv) over 100%  of the
food consumed.  The FAO Expert Group assumed that all foods would be contaminated and utilized
the most  sensitive population  group and body tissue in making its recommendations.  On this  basis,
the group  recommended interim international  radioactivity  action levels in foods which  were
considerably lower than  those recommended  by other groups.  The FAO interim values were not
signiflcantly different from some national levels and those adopted by the Commission of European
Communities (CEC) soon after the Chernobyl accident.

10.  In assessments of acceptable  contamination  levels  made  by WHO,  IAEA,  OECD and  the
European Community Article 31 group in 1986-1987, approaches tended to concentrate on radiation
protection  and safety principles rather than food control  and food law procedures.  The  dose level
of 5  mSv  was  accepted  by most  groups as a basis for calculation.  However, differences of
assumptions about the  percentage of food supply that might be contaminated and about which dose
conversion factor should  be used usually resulted in higher contamination levels than  the FAO
interim levels.

11. During late 1986 and 1987 WHO engaged several consultants and held a preliminary meeting
in April  1987  to  prepare  the  WHO  recommended  health-related approach  to  radionuclide
contamination in foods. In September 1987, WHO held an expert consultation in Geneva and also
invited  participation of  FAO,  OECD,  IAEA, ICRP  and  the  Commission  of the  European
Communities (CEC).  The WHO Expert Consultation provided a methodology and guideline values
which could be used by national authorities as a basic for setting their own levels. The reference
level of dose was accepted as 5 mSv and food consumption was  normalized to a hypothetical intake
of 550 kg/y.  The potentially contaminating radionuch'des were divided into two main classes,  the
actinides such as Plutonium 239 and all others such as Caesium 137.  Only food groups  that were
consumed in quantities greater than 20 kg/y were used in the calculation of the guideline values, and
special values for infants  were developed.  Additivity of radionuclides contaminating  one or more
food groups was accommodated.  These values, while assisting member states to develop  their own
levels, were considered too complex and  unsuitable for application to  international trade in food.

12.  In January 1988, the  WHO  Executive Board urged the Director-General  to continue to
cooperate  with FAO  in developing  uniform recommendations on maximum  levels  regarding
radionuclides in food moving in international trade for consideration and adoption by the Codex
Alimentarius Commission.

13. The principles  applied to the control of contamination of foods moving in  international trade
are similar  to those used in national food control legislation. These have been successfully applied
by  the  Codex  Alimentarius Commission in  making  recommendations  about environmental
contaminants such as lead, cadmium and mercury  in food, and are the basis for current work on
the establishment of guideline levels for aflatoxins.  These food protection principles  are based on
the utilization of safety factors which assure the consumer of wide margins of safety beyond the basic
levels derived from known health and toxicology  research data.  At  the same time  they  provide
national food control authorities with simple and uniform levels which can  be applied to all foods
moving in trade, whatever their origin, and whatever their destination in the distribution chain after
clearance by control officials.

14.  In most countries, national food law prohibits sale or shipment of food  contaminated with
poisonous  or deleterious substances.   However, it  is  recognized  that  certain low  levels of
contaminants are unavoidably present in food and  maximum levels for their occurrence have to be
set to  protect the safety  of food supplies to all consumers.   In arriving  at a  contaminant level,
toxicological data on test animals are reviewed, and a series of conservative assumptions and safety
factors are applied in setting the contamination level to be used for regulatory food control purposes.
If a  no-effect level  has been demonstrated  in controlled animal feeding  tests, that level is  the
departure point for applying conservative assumptions and safety factors to  arrive at a much lower
contamination level for foods for human  consumption. For contaminants such as radionuclides or


mycotoxins where a no-effect level cannot be established, additional considerations are applied in
setting  contaminant  levels which acknowledge  the impossibility of  avoiding  all  inadvertent
contamination of foods with these substances.

15. The FAO Expert Consultation in December 1986 recommended interim limits for radionuclides
in food. At that time, these were regarded as interim levels which would probably need revision at
a later date as a result of the experience gained from the Chernobyl accident.  It is recognized that
both the FAO and WHO guideline values require specific knowledge of the profile of contamination
and are not necessarily applicable to the control of future unknown accidental contamination through
existing food control legislation.

16. It is therefore necessary to develop values that can be readily applied to future accidents under
existing food control legislation.

HI.  Derivation of Values

17.  On examination, the approaches of WHO  and FAO, and indeed of other organizations, are
basically similar.  They all  assume a reference level of dose (usually 5 mSv) a total average food
consumption rate, a dose per unit intake factor for various radionuclides and a patterr of food
consumption, and calculate the levels by the following  formula:

       Level = m x d

       where RLD  = Reference Level of Dose (Sv)
              m =  mass of food consumed (kg)
              d = dose per unit intake factor (Sv/Bq)

18. Controlling radionuclide contamination of foods moving in international trade requires simple,
uniform and easily applied values.  This  approach  is  one  that can be uniformly  applied by
government authorities and yet one that achieves a level of public health protection to individuals
that is considered more that adequate in  the event of a nuclear accident.

19. In making these joint FAO/WHO recommendations  the following  assumptions
have been  made in calculating the levels:

       1.      5 mSv  has been adopted as the reference level of dose for an accident.  This value,
              for most  radionuclides, is the committed effective dose equivalent  resulting from
              ingestion  in the first year after an accident.  Owing to the extremely  conservative
              assumptions adopted, it is  most unlikely that the application of the following levels
              will result  in a dose to an  individual greater than a small fraction of 1 mSv.

       2.      550 kg of food is  consumed in a year, all of which is contaminated.

       3.     Dose per unit intake factors for the radionuclides of concern (1311, 137Cs, 134Cs,
              90Sr, and 239Pu) can be conveniently divided into three classes and applied to the
              general population:

              (a) those with a dose per unit intake of 10~6 Sv/Bq such as 239Pu and other actinides;

              (b) those with a dose per unit intake factor of  10~7 Sv/Bq such as 90Sr and other
              beta emmitters; and

              (c) those with a dose per unit intake factor of Itt8 Sv/Bq such as 134Q, 137Cs, and

20. Applying these assumptions to the above formula, the level for the general population for the
radionuclides in the 10"5 Sv/Bq group would be:

                     5 x IP'3          = 909 Bq/kg
                     550 X
which can then be rounded to 1000 Bq/kg.  For the actinides this value would be 10 Bq/kg, as the
dose per unit intake factor is 100 times larger, and for the radionuclides in  the 10"7 Sv/Bq class (such
as 90Sr), it would be 100 Bq/kg.

21. It is recognized that the sensitivity of infants may pose a problem if the dose conversion factor
for the  general population were applied to  them indiscriminately. WHO, in its document Derived
Intervention Levels for Radionuclides in Food7, proposed separate guidelines for infants. The values
were based on  an infant consumption of milk of 275 L/y and the specific dose conversion factors for
infants for 90Sr,  1311, and 137Cs.

       The  resulting WHO Guidelines  values were:

               90Sr          160 Bq/L
               1311*          1600 Bq/L
               137Cs         1800 Bq/L

       * The value for  1311 was based on a dose of 50 mSv to the  thyroid and a mean life of
       ingested 1311 of 11.5 days.
      ^-Derived Intervention Levels for Radionuclides in Food.  Guidelines for application after
widespread radioactive contamination resulting from a major radiation accident.  WHO, Geneva,

22.  However, the dose per unit intake factors for infants ingesting alpha-emitting actinides  have
recently been revised upward and as a prudent measure, a dose per unit intake factor of 10~5 Sv/Bq
for these radionuclides has been applied to infants consuming milk and infant foods.

23.  To reflect the infant's sensitivity, 1311 has been assigned a dose per unit intake factor of 10"7
Sv/Bq, putting it in the same class as 90Sr.

24.  For infant foods and milk the application of these dose per unit intake factors results in  a
level of 1 Bq/kg for the alpha emitters of the actinide series and any other radionuclide with a  dose
per unit intake factor of 10'5 Sv/Bq, and  100 Bq/kg for 90Sr and 1311 or any other radionuclides
assigned a dose per unit intake of 10"7 Sv/Bq.

25.  By infant foods  is meant a food prepared specifically for consumption by infants  in the first
year of life.  Such foods are packaged and identified as being for this purpose.

26.  The proposed levels are tabulated below:

241Am, 239Pu
1311, 134Cs, 137CS
27. For  infant foods and milk a dose per unit intake factor of 10~5 Sv/Bq is used instead of the
W6 Sv/Bq value and 1311 is assigned to the 10~7 Sv/Bq class of radionuclides.

                             MILK AND INFANT FOODS

       INTAKE FACTOR     RADIONUCLIDES       (Bq/kg)

         1(T5                241Am, 239Pu              1

         Iff7                1311, 90Sr                 100

         10'8                134Cs, 137Cs             1000

NOTES:  As the proposed levels have extensive conservative assumptions built in, there is no need
to add contributions between dose per unit intake groups, and each of the three groups should be


treated independently. However, the activity of the accidentally contaminating radionuclides within
a dose per unit intake group should be added together if more  than one radionuclide is present
Thus, the 1000 Bq/kg level for the IGr8 Sv/Bq dose per unit intake group is the total activity of all
contaminants assigned to that group. For example, following a power reactor accident, 134Cs and
137Cs could  be contaminants of food,  and  the  1000 Bq/kg refers to the summed activity of both
these radionuch'des.

28.  The levels suggested are designed to be  applied only to radionuclides contaminating food
moving in international trade following an accident and not to the naturally occurring radionuclides
which have always been present in the  diet.

29.   Both FAO and WHO have  called  attention in their  expert meeting reports to special
consideration which might apply to certain classes of food which  are consumed in small quantities,
such as spices.  Some of these foods grown in areas affected by the Chernobyl  accident fall-out
contained high levels  of radionuclides following  the accident.  Because they represent  a very small
percentage of total diets and hence would be very small additions to the total dose, application of
the suggested levels to products of this type may be unnecessarily restrictive.  FAO and WHO  are
aware that policies vary at present in different countries regarding such classes of food and suggest
that further  Codex Alimentarius  Commission consideration should  be  given to a  more uniform
approach to harmonize international trade practices for minor dietary components, no  matter what
the contamination may be.

30.  These levels are intended to be applied to food prepared for consumption.  They would be
unnecessarily restrictive if applied to dried or concentrated foods prior to dilution or  reconstitution.
Further Codex Alimentarius Commission consideration should be  given to the policy to be adopted
when dealing with any contaminant of such foods.

31.  By  an accident is meant a situation where the uncontrolled release of radionuclides  to  the
environment  results in contamination of food offered in international trade.

Appendix B

Official translation from Russian

               Accident in the Southern Urals  on 29 September 1957


                        B.V. Nikipelov, G.N. Romanov, L.A. Buldakov,
                         N.S. Babaev, Yu.B. Kholina and E.I. Mikerin

       To a very great extent,  the negative attitude towards nuclear power which  has  arisen in
certain sectors of our population can be explained by the inadequate information that  has been
provided concerning the activities of nuclear fuel cycle facilities.  This involves  questions relating
to the construction of  new nuclear power plants, and also a comparison  of their effects on  the
environment with those of more traditional industrial undertakings such as  thermal power stations,
chemical enterprises and metallurgical plants.  We  are concerned here, furthermore, with information
on accidents that have occurred in plants belonging to  the nuclear industry and  the  consequences
of those accidents.

       In the years immediately following the Second World War a military installation was set up
in the southern Urals to produce a completely new type of weapon, nuclear weapons  in fact, which
were  needed to strengthen the defensive  capacity of our country.   With  a  truly heroic and
superhuman effort on the part of the Soviet  people, under extremely difficult conditions  including
conditions which had a deleterious effect on the health of the staff — this nuclear shield was created.
During the first few years of operation no experience was available with facilities of  this kind, and
problems affecting  the  environment and  the  health of personnel had not yet been studied  in  a
scientific manner. As a consequence, certain parts of the territory surrounding the facility were
contaminated during the 1950s.

       Very serious  radioactive contamination  resulted from an  accident which  occurred  on
29 September 1957.  Owing to a fault in the  cooling system used for the concrete tanks containing
highly active nitrate-acetate wastes, a chemical explosion occurred in these materials and radioactive
fission products were released into the atmosphere and subsequently scattered and deposited in parts
of the Chelyabinsk, Sverdlovsk and Tyumensk provinces.

       The radioactivity released amounted altogether to about 2 million Curies (1 Ci = 3.7 x W10
Bq; the Chernobyl accident released  50 million Ci).   The composition of the  material released is
indicated in  Table 1.

       For the area with a 90Sr contamination density of 0.1  Ci/km2 (double the level  of global
fallout), the maximum length of the deposition track under the  radioactive plume formed reached
300 km;  for 90Sr contamination density of 2  Ci/km2 it reached 105 km, with a width of 8-9 km.
The area density distribution is shown in Table 2.

       The  presence of gamma emitters among the contaminating nuclides  was responsible for the
external irradiation of the population  and the environment. During the initial period the  dose rate


was about 150 /iR/h (1 R = 2.58 x 10   coulomb/kg) in the area with a 90Sr contamination density
of 1 Ci/km2

       Owing to radioactive decay of the short-lived nuclides, contamination levels and gamma dose
rates in the area of the accident fell off fairly rapidly during the first few years after formation of
the cloud track (see Table 3), and subsequently the radiation situation was governed entirely by the
presence of strontium-90 and its rate of radioactive decay.  The exposure of the population in the
contaminated territory was due in the  first instance to external irradiation from the soil and from
objects in their dwellings including their own clothing  and also to internal irradiation due to the
consumption of contaminated food and drinking water and inhalation of activity at the time when
the cloud was  being formed.  Subsequently (after half a year to  a year) internal exposure from
contaminated food was predominant.

       The radiation protection measures adopted for the population were as follows:

              Evacuation of the population;

              Decontamination of some portions of the  agricultural land;

              Monitoring of contaminated levels in agricultural products and rejection of produce
              with activity levels exceeding the accepted norms;

              Limitations imposed on  the utilization of contaminated land; and

              Reorganization of agriculture and forestry, with the creation  of  specialized state
              farms  and   forestry enterprises operating   in   accordance   with the  special
              recommendations worked out in the light of the accident.

       The dynamics  of the  evacuation exercise  for  persons living  in  regions  with a 90Sr
contamination density above 2 Ci/km2 are shown in Table 4.

       In the immediate  aftermath  of the accident - that is, within 7 to 10 days   six  hundred
persons were evacuated from the settlements in the most severely  affected area;  and about ten
thousand persons were evacuated in the  18 months following  the  accident.   Altogether  10,180
persons were evacuated.  Maximum average exposure doses preceding evacuation reached 17 rem
in external exposure and 52 rem in effective dose equivalent (150 rem to the gastrointestinal tract).

       Decontamination consisted mainly in ploughing under the surface layers of agricultural land.
In 1958 and 1959 about 20,000 hectares of land at the head end of the cloud track were ploughed
under in the usual way and in  1960-1961 deep ploughing was carried out on 6200  hectares of land,
in the course of which the contaminated surface layers were turned under  to a depth of more than

       A regime for limiting the use of contaminated areas and the access of the population to
such areas was introduced immediately after the accident at the head end of the cloud track, and
after completion of the evacuation in  1959 this regime was extended to the entire region with a
90Sr contamination density in excess of 2 Ci/km2; this region was then subjected to special sanitary


protection regulations.  Subsequently, in 1962, this zone was reduced to 220 km2, with a maximum
90Sr contamination density of 100 Ci/km2 at the far end.  The rest of the territory was returned to
agricultural use.

       In 1958, 59,000 ha were removed from agricultural use in Chelyabinsk province and 47,000
ha in Sverdlovsk province. Beginning in  1961, these lands were gradually returned to  agriculture.

       In Chelyabinsk six special state farms were set  up, and in the Sverdlovsk region three such
farms; in the latter region, agricultural production was restored  in 1961.  In  Chelyabinsk province
the restoration of lands to agricultural use was virtually completed by 1978, and by now 40,000 ha
out of a total of 59,000 have been returned to agriculture.

       The work of the specialized state farms is carried out in accordance  with special scientific
and political regulations developed for the purpose7 and is concentrated primarily on the production
of meat as a product with minimum 90Sr levels by comparison with other foodstuffs.  For economic
reasons the specialized state farms do yield other products  as well, but where contaminated lands
amount to 10-15% of the total agricultural land available to the farms, this land is used exclusively
for the production of cattle and pig fodder.   Levels  of contamination of meat and milk  on the
specialized state farms  of Chelyabinsk province are shown in Table 5.  The effectiveness of this
agricultural system, evaluated on the  basis of the reduction in 90Sr levels brought about in the
produce of the specialized state farms by comparison  with  the levels in "unregulated" agricultural
produce, amounts to factors of 2-7 for meat production and 3-4 for milk.  However, these figures
cannot be applied to the produce of individual farms.

       Non-evacuated  population  continued to live  in  areas  with an  average  maximum  90Sr
contamination density of around 1 Ci/km2.  The main exposure pathway for these people after the
initial period following the accident was  ingestion of strontium-90 with food,  in particular milk  (as
much as 60-80%); strontium-90 is deposited in the skeleton, with consequent irradiation of bone and
red bone marrow. After thirty years, the daily intake of strontium-90 with food by  these members
of the population had dropped by a factor of 1300 in comparison  with  the  initial period of the
accident, and by a factor of 200 compared with 1958.   This was due to the fact that strontium-90
concentrations in milk and other products fell  off more quickly than would be expected from the
isotope's decay rate (by factors of  as much as 110 over thirty years)  owing to physico-chemical
processes which transformed the strontium in the soil, as well as other natural processes.  The annual
limit on intake  of strontium-90  for a limited sector  of  the public, namely  0.32 /xCi/year under
NRB-76/87 [the 1987 radiation safety standards] was exceeded at a contamination density of 1 Ci/km2
over the first four years following the accident.  At  present the annual strontium-90 intake  for
members of the population living in areas with a contamination density of 1 Ci/km2 averages 3% of
the permissible annual intake, the largest value being 12% in one settlement.
      1The relevant recommendations were formulated by experts of the Experimental Station set
up by the USSR Ministry of Medium Mechanical Engineering in 1958 to study the consequences
of the accident. This work was carried out in co-operation with the local branch of the Institute
of Biophysics of the USSR Ministry of Health.

       After thirty years in areas with a maximum average 90Sr contamination density of 1 Ci/km2,
the effective dose equivalent was 1.2 rem, of which about 2.5 rem affected the red bone marrow and
about 8 rem  the bone.  If we take a dose limit of 0.5 rem per year for exposure of the red bone
marrow, the aggregate exposure over thirty years was 2.5: (0.5 x 30) = 0.17 of the permissible limit
under NRB-76/87. This evaluation could well be  increased by a factor of two, however, in view of
the uncertainties in the  formation of irradiation pathways.

       In addition to studying matters of health  and safety and the ecological situation  that had
arisen in the areas affected by the radioactive cloud, special medical brigades performed therapeutic
and diagnostic tasks among the local population and carried out a public information campaign aimed
at ensuring the best possible approach to radiation hygiene. This latter campaign consisted largely
of propaganda for personal hygiene aimed  at preventing  the  uptake of radionuclides in human
beings, confiscation of foodstuffs contaminated beyond acceptable levels and in the replacement of
those foodstuffs by pure uncontaminated products.  In the first stage of the accident an effort was
made to interrupt the food chain at the fodder-growing and stock-raising  level: this was  during the
autumn and winter. Interruption of the food chain at the soil-fodder-crop-growing level was carried
out in a second stage, during the spring and summer of the following year when radionuclides were
reaching living organisms with the new harvest.   The main steps taken at this stage were  deep
ploughing of the radionuclides and careful monitoring of fodder and of food for human conr ^mption.
Deep ploughing-under of the soil was started in the late autumn of 1957, but was carried out to a
large extent in the summer of 1958. This was a measure which reduced the gamma dose by a factor
of ten.

       These should  not  be  considered as radical measures.  Although  they  made  it possible to
reduce the uptake of radioactive  materials  by human beings by a factor  of  more than  ten, the
radiation burden  to internal organs was reduced by no more than a factor of two.   This  was due
to the composition of the radionuclide mixture in the fallout from the accident.

       Other clean-up  measures  also  proved  to  be  inadequately  effective,  especially  as
decontamination,  owing  to  the  special  geographical characteristics of  the region,  produced
comparatively poor results.

       Medical surveillance of the population was carried out in the following manner.  The zone
affected by radioactive contamination was mapped out and the population  living in that zone was
transferred, stage by stage, to  localities free of radioactive contamination  (see Table 4).  In all the
inhabitants of the region - those who were resettled and also those who  lived on the boundary of
the resettlement zone, i.e. the region with contamination  levels lower than 1 Ci/km2 (90Sr), and
persons living further  from the boundary of the contaminated zone   a number of health indicators
were studied:  these included  general physical state, blood  formation (haemopoiesis), neurological
status,   the  development of children,  the  condition of  new-born infants  and  their  physical
development, the  development of allergies, the condition of the gastrointestinal tract, the incidence
of infectious  illnesses, and infant mortality.  During the first three years after the  accident these
studies were  carried out once a year and in the  subsequent  period once every ten years.  The
investigations are  continuing at the present time with a view to finding any malignant tumours that
have developed as well  as other similar afflictions, and to establishing the causes of death among
persons who spent a short time in either the  contaminated  region or in control areas.

       These dynamic population studies have revealed the following.  During the first three years
the resettled population and groups living in the area with 90Sr contamination levels above 2 Ci/km2
(see Table 6) exhibited no excess over control groups of specific symptoms such as radiation sickness
in any of its forms,  nor were there  any instances  of  bone marrow depression  or any organic
neurological changes or cases of allergy development.  There was, further,  no manifestation of any
increased frequency of vegetative-vascular disorders, myocardial infarction,  hypertonic states or any
similar disorders.  Furthermore, although in 21% of the persons investigated - out of a total of more
than 5000 individuals at certain times - a reduction in the leukocyte count in the peripheral blood
was found on one occasion,  there was rarely  any reduction in the thrombocyte count and equally
rarely any functional neurological disorders.  The external gamma dose among this  group of people
amounted to anywhere from 0.7 to 17 rem, and the effective  dose equivalent to 2.3-52 rem.   The
main dose,  for example, was three to four  times  greater than  the permissible effective  dose
equivalent to the gastrointestinal tract during the first year owing to the presence of "non-absorbable"
radionuclides in the fallout mixture.

       Special  attention has been given to what is the most strongly indicative  and most sensitive
criterion of both the health and safety situation and the ecological state of the  environment, a
criterion which reacts rapidly to radiation - namely infant mortality, i.e. deaths among children aged
less than one year.  The investigations were conducted among the inhabitants of areas affected by
the cloud, among persons living in areas with a 90Sr soil contamination density of less than 1 Ci/km2
(control group  number 1) and among persons living in regions remote from the boundaries of the
cloud track (control group number 2).

       As can  be seen from Table 7, even against the background of very high infant mortality in
those years,  it  was  not possible to detect any  aggravating influence of enhanced radiation levels on
this indicator.  A certain excess of infant mortality in the second control group was due to  high
frequencies of pneumonia and disease of the newborn.

       As we know, the theoretical assumption that anomalies may often occur in the offspring of
irradiated parents has given rise to  a great deal of apprehension.   Investigations aimed at clarifying
this effect were carried out in the period 1980-1987, i.e. at a time when the radiation doses received
as a result of the accident were  bound to have had their full effect not only on the first but on the
second generation of persons subject to  the action of radiation.  The resultant data are presented
in Table 8.

       This information, based as  it is  on a large volume of data, appears to confirm that the
radiation levels we  have been discussing have no effect on the appearance of  congenital defects,
or on  mortality from  such  defects, in  individuals  irradiated  in the  first  and  second generations
following  an  accidental release of radioactive fission products.

       Investigators all over the world  have  been  particularly interested in the  development  of
malignant tumours as a result of exposure to ionizing radiation at any and all doses. The idea that
such tumour formation is possible  relies on the  hypothesis of a linear development of cancerous
growths which has no threshold.  However, an analysis of the incidence of such disease, and of the
causes and levels of mortality from malignant neoplasms,  carried out over decades,  has indicated no
significant difference between irradiated and unirradiated populations as far as the incidence of such
illness and the  structure and level of mortality are concerned  (see Table 9).


       Table 9 encompasses mortality levels from all types of cancer.  It will be seen, in the first
place, that there are no differences in mortality depending on the place of residence of the persons
concerned.  Secondly, with time, in the USSR as  in the world as a whole, and also in areas affected
by the radioactive cloud, mortality from malignant tumours is increasing   the consequence of a
general worsening of the ecological situation in the world. The  role of radioactive contamination
and doses of ionizing radiation against the generally unfavourable background is so small as to  be
scarcely detectable.  The radiation levels built  up following the events of 1957 are well below the
limit which, in the light of all the realistic factual evidence available to us, could be considered as
significant - in other words below a dose of 50  rem.  Even  this level, in terms of effective dose
equivalent, was received by only a limited number of people  (see Table 4), and in this population
no meaningful deviations in the structure of illness have been detected  up until now.

       The scientific investigations which have  been carried out since 1957 on the territory affected
by the radioactive cloud  in the Urals have yielded data of fundamental theoretical and  practical

              Information  relating to  the spatial and temporal distribution of radionuclides  in
              terrestrial and aqueous ecosystems, and to the behaviour of radionuclides in the food
              chains of land and  water  animals;

              Information relating to the dynamics of formation of the  radioactive  cloud, the time
              required  for the  plume  to become  established,  the stability  of  the  plume,  its
              redistribution in space and time, and so on;

              The paths by which dose burdens  to man, natural  organisms and  communities were
              formed in  the acute period and  in the  longer term;

              Biochemical and biophysical turnover of radionuclides;

              The biological effects of radiation  observed in natural organisms  and in  members  of
              the population;

              Forecasts of root and non-root  uptake of radionuclides in crops  and livestock, and
              measures  to reduce the levels of radioactive contamination; and

              Organization of safe and  rational  methods applicable to  agriculture, forestry, water
              bodies, and fish and game culture in the areas affected by radioactive contamination.
              Possibilities  for  the  reorientation  of public  and  individual   farm  production.
              Arrangements permitting agricultural production without the necessity of any special
              agrotechnical or  zootechnical  measures in areas with  the following  degrees  of
              radioactive contamination: 5 Ci/km2 - grain, hay, natural grasses;  up to  10 Ci/km2 -
              milk, seed  grasses, silage crops; up to 25 Ci/km2  beef, root plants; up to 50 Ci/km2
              - fodder grain crops; and  up to  100 Ci/km2 - pork, potatoes, fodder  grain crops for
              processing, seed grasses, seed grains.

       The  scientific investigations carried out from  1957 onwards made it possible to establish a
reliable long-term prognosis for the development  of the radiation situation following the Chernobyl


accident, to predict the biological effects of the accident on various elements of the environment,
to develop practical recommendations for reducing the  negative consequences of the Chernobyl
accident on agriculture, forestry, and on land- and water-based wildlife in the parts of the Ukraine
affected by radiation and also in parts of the Gomel' and Mogilev provinces of the Byelorussian SSR.
The work of the radioecologists in the Urals is being continued in this direction.

       The experience obtained in managing the radioecological and radiation-hygiene consequences
of the Chelyabinsk and Chernobyl accidents has been used in the preparation of a "Guide to the
Planning and Implementation of Measures Designed to Reduce the Negative  Radiological and
Radioecological Consequences of Accidents Going Beyond the Design  Basis Accident and Involving
Releases of  Radioactivity to the Environment", which,  once it has been  approved by the state
regulatory bodies,  will be used when necessary by undertakings in the nuclear and nuclear power

Table 1

90Sr 4- 90Y
95Zr + 95Nb
106Ru + 106Rh
144Ce + 144Pr

Characteristics of the radionuclide mixture released in the
Contribution to Half-life Type of
total activity radiation
of the mixture, emitted
traces 51 d ft, T
5.4 28.6 y /3
24.9 65 d 0, T
3.7 1 y ft, 7
0.036 30 y 0, T
66 284 d 0, 7
traces 2.6 y /3, T
traces 5 y /J, T
traces - a
Table 2
Area and population of the contaminated region
Density of radioactive
contamination, Area of the
Ci/km2 (90Sr) region, km2
> 0.1
> 2
> 100
> 15,000

Nature of

Internal irradiation
External irradiation
External and

Population of the
region (x 103)
~ 270




                                               Table 3

                                  Dynamics of the radiation situation
Time after

Contamination density

Gross activity
(relative units)

Table 4
Gamma dose rate

(relative units
based on initial value)
5.6 x 10'2
8.2 x lO'3
9.8 x 10-*
3.8 x 10-*

Dynamics of population evacuation and of exposure dose
to the population before evacuation
group and
size (x 103)
I: 0.60
II: 0.28
III: 2.0
IV: 4.2
V: 3.1
Total: 10.18 [*]
Average contam-
ination density,
Ci/km2 (90Sr)

Time required
for evacuation,

Average dose received
up to evacuation, rem
External Effective
dose eq.


[*] Following the Chernobyl accident 115,000 persons were evacuated.

                                               Table 5

                           90Sr concentrations in the meat and milk of cattle
                                     during the period 1965-1988
Meat (beef)

1.  Specialized state farms

concentration, pCiykg

Normalized (permissible)
concentration, (pCi/kg)/(Ci/km2)


Observed concentration, pCi/L

Normalized concentration,

2.  Privately held cattle

Observed concentration, pCi/L

Normalized concentration,

                                              Table 6

                          Observed changes in the health of individuals living
                           in areas with a contamination density of 2 Ci/km2
                                 (by comparison with control groups)
Frequency of occurrence
(% of patients investigated)
Radiation sickness (all forms)

Bone marrow depression

Reduced leukocyte count in blood

Reduced thrombocyte count

Functional neurological disturbances

Organic neurological changes

Allergy development
    None observed

    None observed


    A few cases

    A few cases

    None observed

    None observed
                                              Table 7

                        Mortality among infants aged < 1 year per 1000 births
                                   in areas affected by the plume
Causes of mortality
All causes
Nutritional disorders
Infectious illnesses
Disease of the newborn
Plume track
Control No. 1
Control No. 2

                                               Table 8

                        Mortality of newborn infants with innate developmental
                                     defects (per 1000 live births)
In the whole of the                            In Chelyabinsk                 In Sverdlovsk
affected zone, including                        province                       province
the plume track

0.95 +/- 0.08                                  1.0 +/- 0.08                    1.1 +/- 0.07
                                               Table 9

                                 Mortality due to malignant neoplasms
                                       (per 100,000 inhabitants)
                           In the whole of
Period of                  the affected  zone,                In Chelyabinsk          In .Sverdlovsk
research                   including the                    province                province
                           plume track

1970-1980                  145.8                            146.6

1980-1987                  160.7                            167.6                   159.4