40 CFR 190
ENVIRONMENTAL RADIATION PROTECTION
REQUIREMENTS FOR NORMAL OPERATIONS
OF ACTIVITIES IN THE
URANIUM FUEL CYCLE
FINAL ENVIRONMENTAL STATEMENT
VOLUME I
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Radiation Programs
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BiBUOGRAPHSC DATA 5. Report No. 2.
SHEET EPA 520/4-76-016- O- /
4;-.;T»tle and Subtitle IJ.Q QJTR 1_C)Q
Environmental Radiation Protection Requirements For Normal
Operations Of Activities In The Uranium Fuel Cycle
.Final Ifnvirozmjental jSt^tipment, Volume T- -
7. Author(s)
9, Performing Organization Name and Addii-.«,s
U.S. Environmental Protection Agency .
Office of Radiation Programs (lSR-if-58)
Washington, B.C. 20^60
12, Sponsoring Organization Name and Address
Same as above
5. Report Date
November 1, 1976
6.
8. Performing Organization Rept.
No.
10. Project/Task/Work Unit No.
11. Contract/Grant No,
13. Type of Report & Period
Covered
Technical Report
14.
15. Supplementary Notes
16, Abstracts Yolume I describes and evaluates ne« standards to limit radiation doses to the
general public and quantities of long-lived radioactive materials in the general
environment, attributable to planned releases from operations contributing to the
generation of electri'cal power through the uranium fuel cycle. These standards apply
to milling,- chemical conversion, isotopic enrichment, fuel fabrication, light-water-
-cooled reactors, and fuel reprocessing, but exclude mining, the transportation of
radioactive materials in connection, with any of these operations, and waste management
operations. The standards specifically limit irreversible contamination due to release*
of radioactive krypton, iodine 129} and alpha-emitting transuranics. The total reducti
in potential health -impact attributable to operations through the year 2000 is estimate
to be in excess of 1000 cases of cancer, leukemia, and serious genetic effects in
human populations. In addition maximum annual radiation doses are limited to 25 -
millirems to the whole bodyvand all other organs except the thyroid, -which would be
17. Key Words and Document Analysis,, 17a. Descriptors
?k. Ideatifiers/Open-Endcd Terms
Radiation Protection
Radiation Dose
Uranium Fuel Cycle
Nuclear Reactors
General Environment
Alpha-emitting Transuranics
i/«. COSATl
Iodine - 129
Krypton - 85
Plutonium - 239
S, AvaiUbiiuy Sz»»eracnt
Unlimited
19. Security Class (This
Re port )
UNCLASSIFIED, , .,
20. Security t lass ( I his
I'Nri.AS>!F!Fn
21. No. of Page*
fcftiffioi
' Q«M NTis-»s («KV. so-7*i ENDORSED HY ANSI AND UNESCO.
THIS FORM MAY BE XKPKOIHKIED
OSCOMM-OC
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FINAL ENVIRONMENTAL STATEMENT
ENVIRONMENTAL RADIATION PROTECTION REQUIREMENTS FOR
NORMAL OPERATIONS OF ACTIVITIES IN THE URANIUM FUEL CYCLE
Prepared by the
OFFICE OF RADIATION PROGRAMS
Approved by
Deputy Assistant Administrator for Radiation Programs
November 1, 1976
I!1
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SUMMARY
) Draft
X) Final Environmental Statement
Environmental Protection Agency
Offa.ee of Radiation Programs
i. This action is administrative.
:. The Environmental Protection Agency is promulgating standards to
limit radiation doses to the general public and quantities of long-
lived radioactive materials in the general environment attributable
to planned releases from operations contributing to the generation
of electrical power through the uranium fuel cycle. These
standards apply to most operations within the fuel cycle, including
the operations of milling, conversion, enrichment, fuel
fabrication, light-water-cooled reactors, and fuel reprocessing,
but exclude mining,, the transportation of radioactive materials in
connection with any of these operations, and waste management
operations. Covered operations may occur in any State, although
milling operations are expected to occur primarily in Wyoming, New
Mexico, Texas, Colorado, Utah, and Washington.
Summary of environmental impact and adverse effects;
a. The standards limit irreversible contamination of the local,
national and global environment due to releases of radioactive
krypton-85 (half-life 10,7 years), iodine-129 (half-life 17
million years)„ and alpha-emitting transuranics (half-lives 18
years to 2 million years). The total reduction in potential
health impact attributable to operations through the year 2000
is estimated to be in excess of 1000 cases of cancer, leukemia,
and serious genetic effects in human populations, based upon
the assumed achievement of an annual nuclear production of 1000
GW(e)-yr of electrical power by that year.
b. Maximum annual radiation doses to individual members of the
public resulting from fuel cycle operations are limited to 25
millirems to the whole body and all other organs except
thyroid, which would be limited to 75 millirems. Previously
applicable Federal Radiation Protection Guides for maximum
annual dose to individual members of the public are 500
millirems to the whole body and 1500 millirems to the thyroid
from all sources of exposure except those due to medical use
Preceding page tiank
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and natural background. However, most fuel cycle operations
are now conducted well within these guides, and the principal
impact of the new individual dose limits will be limited to the
relatively small populations in the vicinity of mills,
conversion, and fabrication facilities.
c. There are no anticipated adverse environmental effects of these
standards.
4. The following alternatives were considered;
a. No standards.
b. Modification of the Federal Radiation Protection Guides for
maximum annual exposure of members of the public.
c. standards for fuel reprocessing operations only.
d. Standards without a variance for unusual operating situations,
and incorporating standards for annual population dose to limit
environmental burdens of long-lived radionuclides, instead of
limits on the quantities entering the environment.
e. The proposed standards.
f. Standards based on a lower level of cost-effectiveness than
those proposed.
g. standards based on use of "best available" effluent controls.
5. The following Federal agencies have commented on the Draft
Environmental Statement;
Department of Commerce
Department of Interior
Energy Research and Development Administration
Federal Energy Administration
Nuclear Eegulatory Commission
Tennessee Valley Authority
6. This Final Environmental Statement was made available to the public
and the council on Environmental Quality in November 1976; single
copies are available from the Director, Criteria and Standards
Division (AW-460), Office of Radiation Programs, U.S. Environmental
Protection Agency, 401 M Street, S.W., Washington, D.C. 20460.
VI
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CONSENTS
VOLUME ONE
SUMMARY V
I. INTRODUCTION 1
II. THE PROPOSED ACTION 8
III. THE STATUTORY BASIS FOR ENVIRONMENTAL RADIATION
STANDARDS ................."..... 18
IV. RATIONALE FOR THE DERIVATION OF ENVIRONMENTAL
RADIATION STANDARDS 21
V. TECHNICAL CONSIDERATIONS FOR THE PROPOSED STANDARDS 29
A. Model Projections of Fuel Cycle Environmental
Impacts « 37
B. Results from Environmental Assessments under NEPA ........ 52
C. Field Measurements of Environmental Impact ............... 61
D. The Proposed Standards 68
VI. ANTICIPATED IMPACT OF THE PROPOSED STANDARDS 78
A. Environmental Impact 79
B. Health Impact 87
C. Economic Impact ««** ...**.....«* 93
D. Administrative Impact .................................... 96
E. Intermedia Effects 100
F. Impact on Facility Distribution and Reactor
Mix 102
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VII. ALTERNATIVES TO THE PROPOSED ACTION 125
VIII. MAJOR ISSUES RAISED DURING REVIEW , 140
A. Implementation of the Standards 140
B. Control of Krypton-85 166
C. Health Effects Estimates 177
REFERENCES . 189
APPENDIX A: The Proposed Rule
APPENDIX B: Policy Statement - Relationship
Between Radiation Dose and Effect
VOLUME TOO
IX. RESPONSE TO COMMENTS
APPENDIX: Comments on the Draft Statement
Vlll
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TABLES
•?able 1. characteristics of Model Fuel Cycle Facilities 32
?able 2, Principal Radioactive Effluents from the Uranium
Fuel Cycle and their Associated Critical Target
Organs 36
"able 3 Dose and Quantity Levels Implied by Model
Projections ...*..*..*.* 41
"able 4. Environmental Impacts of Normal Releases from
Pressurized Water Reactors 54
"able 5. Environmental Impacts of Normal Releases from
Boiling Water Reactors 56
"able 6. Environmental Impacts of Normal Releases from
Other Fuel Cycle Facilities 58
"able 7. Calculated Doses from Noble Gas Releases at
Operating Plants (1972-1974) 63
"able 8. The Proposed Standards 70
"able 9. Potential incremental Whole Body Doses Due to
Overlap of Exposures from Airborne Effluents at
Closest Presently Projected Nuclear Facility
Sites 76
"able 10. Potential Health Effects" Attributable to Operation
of the Nuclear Fuel Cycle Through the Year 2000 at
Various Environmental Radiation Protection Levels ....... 88
"able 11. Environmental Impacts of Three- and Four-Unit Sites ..... 107
''able 12. comparison of the Proposed standards and Alterna-
tive Levels of Control for Environmental Releases 138
"able 13. Cost-Effectiveness of Krypton Control at Fuel
Reprocessing Plants 171
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FIGURES
Figure 1. Uranium Fuel Cycle Facility Relationships ............... 30
Figure 2. Projected Nuclear Fuel Cycle Facility Needs ............. 33
Figure 3. Risk Reduction vs Cost for the Uranium Fuel Cycle 39
Figure 4. Cost-effectiveness of Risk Reduction for the
Uranium Fuel Cycle 49
Figure 5. Distribution of Noble Gas Releases from
Boiling water Reactors in 1961-1973 65
Figure 6. Projected Environmental Burden of Tritium from
the U.S. Nuclear Power Industry 81
Figure 7. Projected Environmental Burden of Carbon-14
from the U.S. Nuclear Power Industry 82
Figure 8. Projected Environmental Burden of Krypton-85
from the U.S. Nuclear Power Industry for
controls Initiated in Various Years 83
Figure 9. Projected Environmental Burden of Iodine-129
from the U.S. Nuclear Power Industry at
Various Levels of Control 84
Figure 10. Projected Environmental Burdens of Alpha-emitting
Transuranics with Half-lives Greater than One
Year from the U.S. Nuclear Power Industry 85
Figure 11. Cumulative Potential Health Effects Attributable
to Environmental Burdens of Long-lived Radio-
nuclides from the U.S. Nuclear Power Industry 92
Figure 12. Risk Reduction vs cost for Alternatives to the
Proposed Standards 139
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I. INTRODUCTION
Within the last few years it has become clear that the national
jffort to develop the technology required to generate electricity using
mclear energy has been successful, and that the generation of
Jlectrical power by this means is likely to play an essential role in
neeting national electrical power needs during the next several decades
(1). However, the projected extensive use of nuclear power has led to
widespread public concern over the hazards to health posed by the
radioactive materials associated with nuclear power generation. Unlike
iossil-fueled power generation, which uses fuels known to man from
prehistoric times, the fissioning of nuclear fuel is a very recently
liscovered phenomenon and man is just beginning to learn how to assess
-he full implications of its exploitation. Paradoxically it is also
^rue, however, that we .know more about the implications for health of
radioactive materials than of the pollutants released by the burning of
traditional fossil fuels. This knowledge facilitates the process of
assessing the implications of using nuclear energy for the generation of
lilectrical power. This is particularly true for planned releases of
radioactive materials; the assessment of accidental releases is a much
iore difficult task which is heavily dependent upon our limited
capability to predict the probabilities of accidents. In the process of
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developing these proposed standards a comprehensive assessment has been
made of planned releases of radioactive materials associated with
nuclear power generation so as to assure an adequate basis for informed
judgments of what the potential effects on public health and the
environment are, what can be done to minimize these effects through the
promulgation of environmental radiation standards, and the costs
involved.
The Environmental Protection Agency was vested with the
responsibility for establishing environmental radiation standards
through the transfer of authorities from the Atomic Energy Commission
(AEC) and the former Federal Eadiation Council by the President's
Reorganization Plan No, 3 of 1970 (2). The Agency's role is
complementary to the responsibilities transferred from the AEC to the
Nuclear Regulatory Commission (NEC) in 1975 (3), which are focused on
the detailed regulation of individual facilities within the standards
established by EPA, whereas EPA must address public health and
environmental concerns associated with the fuel cycle taken as a whole.
This statement summarizes the data base and judgments upon which
these proposed environmental radiation standards for planned radioactive
effluents from the uranium fuel cycle are based. It also provides an
assessment of the anticipated impact of the proposed standards and of
alternative courses of action on public health, the environment, the
industry and upon government. In reviewing the information presented in
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tiiis statement it should be recognized that past growth of the nuclear
power industry has been conducted so that radioactive environmental
contamination is minimal at the present time. Because of this
situation, an unusual opportunity as well as a challenge exists to
manage future growth in the use of nuclear energy in a preventive rather
than in a remedial context, a situation that is the ultimate aim of all
environmental protection. Within such a context, the tradeoffs between
potential health risks or environmental quality and the costs of
environmental controls can be made most easily and with the greatest
effectiveness.
In the United States the early development of technology for the
nuclear generation of electric power has focused around the light-water-
cooled nuclear reactor. For this reason the proposed standards and this
statement will consider only the use of enriched uranium-235 as fuel for
the generation of electricity. There are, in all, three fuels available
to commercial nuclear power. These are uranium-235, uranium-233, and
Plutonium-239. The first of these materials occurs naturally and the
last two are produced as by-products in uranium-fueled reactors from the
naturally-occurring isotopes thorium-232 and uranium-238, respectively.
Although substantial quantities of plutonium-239 are produced from
uranium-238 present in the fuel of conventional light-water-cooled
reactors, large-scale production requires the development of a
commercial breeder reactor. The liquid metal fast breeder, which would
make possible the extensive production and utilization of plutonium
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fuel, is now under intensive development, fcut is not expected to be
commercially available before the late 1980.*s, at the earliest (4).
However, limited commercial use of recycled plutonium produced in light-
water-cooled reactors is under consideration for the near future {5).
The third fuel, uranium-233 derived from naturally-occurring thorium^ is
used by a new reactor type also under active development, the high
temperature gas-cooled reactor, which may be available for expanded
commercial use by the end of this decade.
It has been projected that from approximately '400 to 1500 gigawatts
of nuclear electric generating capacity based on the use of uranium fuel
will exist in the United States within the next twenty-five years (6)„
This increase will require a parallel growth in a number of other
activities that must exist to support uranium-fueled nuclear reactors.
All of these activities together, including the reactor itself, comprise
the uranium fuel cycle. This fuel cycle is conveniently considered in
three parts. The first consists of the series o£ operations extending
from the time uranium ore leaves the mine face.through fabrication of
enriched uranium into fuel elements. This is followed by a part
consisting only of the power reactor itself, in.which the fuel is
fissioned to produce heat which in turn is used to generate electric
power. The final part consists of fuel reprocessing plants, where used
fuel elements are mechanically and chemically broken down to isolate the
large quantities of high-level radioactive wastes produced during
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fission for permanent, protective storage and to recover substantial
quantities of unused uranium and reactor-produced plutonium.
These three parts have fundamentally different characteristics with
respect to radioactive effluents. The first involves only naturally-
occurring radioactive materials which are, nevertheless, made available
to the biosphere as the direct result of man's activity. The control
technologies appropriate to these materials, specifically uranium and
its associated daughter products, are common to most components of this
part of the cycle. By means of fission and activation the reactor
creates large additional quantities of radioactive materials. Although
these are largely contained by fuel cladding, some small releases do
occur. However, in spite of their relatively low levels, reactor
effluents are important because these facilities are the most numerous
component of the fuel cycle and are often located close to large
population centers in order to achieve economic transmission of the
power they produce to its ultimate users. Finally, although fuel
reprocessing plants are few in number, they represent the largest single
potential source of environmental contamination in the fuel cycle, since
it is at this point that the fuel cladding is broken up and all
remaining fission and activation products become available for potential
release to the environment.
The environmental effects of planned releases of radioactive
effluents from the components of this cycle have been analyzed in detail
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by the EPA in a series of technical reports covering fuel supply
facilities, light water reactors, and fuel reprocessing (7,8,9,10).
These technical analyses provide assessments of the potential health
effects associated with each of the various types of planned releases of
radioactivity from each of the various operations of the fuel cycle and
of the effectiveness and costs of the controls available to reduce
releases of these effluents. In addition to these analyses, there is
considerable other information on planned releases from these types of
facilities available. This includes the generic findings of the NRC
concerning the practicability of effluent controls for light-water-
cooled reactors, extensive findings of the utilities, the NRC, and the
AEC as reflected by environmental statements for a variety of individual
fuel cycle facilities, and finally, the results of a number of detailed
environmental surveys conducted by EPA at typical operating facilities,
These standards deal with planned releases only, although it is
recognized that the potential hazard from accidents could be
substantial. However, since the coupling between controls for planned
effluents and the potential for accidents is minimal, it has been
concluded that these two important issues can be addressed separately.
In addition to the safety issue, there are two other interrelated
aspects of nuclear power production that are not addressed by these
standards. These are the disposal of radioactive wastes and the
decommissioning of facilities. These issues are currently under study
by EPA, ERD&, the U.S. Geological Survey, CEQ, NRC, and other government
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agencies, and EPA expects to make recommendations for criteria and
standards in these areas in the future. In any case, the implications
of the controls required by this rulemaking for radioactive wastes and
for decommissioning represent minor perturbations on already-existing
requirements for waste management for the fuel cycle.
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II. THE PROPOSED ACTION
These radiation standards for normal operations of the uranium fuel
cycle are proposed in order to achieve two principal objectives: 1) to
assure protection of members of the public against radiation doses
resulting from fuel cycle operations, and 2} to limit the environmental
burden of long-lived radioactive materials that may accumulate as a
result of the production of electrical energy, so as to limit their
long-term impact on both current and future generations. These
objectives are proposed to be achieved by standards which would limit:
1) the annual dose equivalent to the whole body or any internal organ,
except the thyroid, to 25 millirems, and the annual dose equivalent to
the thyroid to 75 millirems; and 2) the quantities of krypton-85,
iodine-129r and plutonium and other alpha-emitting transuranic elements
with half-lives greater than one year released to the environment per
gigawatt-year of electrical power produced by the entire fuel cycle to
50,000 curies, 5 millicuries, and 0.5 millicuries, respectively. The
proposed rule is contained in Appendix A.
Standards in the first category are designed primarily to address
doses due to short-lived fission-produced materials (although doses from
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long-lived fission-produced materials are included, they will generally
make a small contribution to persons receiving doses approaching these
limits for individuals). Those in the second category specifically
address long-lived radioactive materials. The standards for
environmental burdens of specific long-lived radionuclides are expressed
in terms of the quantity of electricity produced in order that society
will be assured that the risk which is associated with any long-term
environmental burden of these materials is incurred only in return for
an associated beneficial product: electrical power. The standard
permits up to the specified amounts of these radionuclides to be
released at any time or location and at any rate that will not exceed
the individual dose limitations. The standards proposed apply to almost
all operations within the fuel cycle, including milling, conversion,
enrichment, fuel fabrication, light-water-cooled reactors, and fuel
reprocessing. Mining operations are excluded, since these standards are
proposed under authority of the Atomic Energy &ct, which does not extend
to effluents from mining operations. A variance is proposed to permit
temporary operation in the presence of unusual operating conditions when
this is judged to be in the public interest by the responsible
regulatory agency. This can occur, for example, due to an emergency
need for uninterrupted delivery of power, or in the presence of a
temporary and unusual operating situation when a plan to achieve
compliance in a timely manner has been approved by the regulatory
agency.
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The significance of the nuclear power industry to future energy
supply and the future public health and environmental implications of
continued operation of this industry at currently required levels of
effluent control combine to provide a major incentive for the
establishment of these environmental radiation standards.
The nuclear power industry is projected by a wide variety ,of
studies to grow from its present proportion of approximately 8 percent
of total electric power capacity to between 40 and 60 percent by the
year 2000 (an absolute growth from about 40 gigawatts to anywhere from
400 to 1500 gigawatts) (11), It has been estimated that the annual
capital investment in current dollars associated with this growth will
increase from 6 to 600 billion dollars, and that the value of electric
power produced annually will grow from about 6 to over 200 billion
'dollars during this same period (12)„
The development of a large nuclear power industry has, however, the
potential for leading to unnecessary exposure of the public to
radioactive materials and to irreversible contamination of the
environment by persistant radionuclides (13). The implications of this
exposure and irreversible contamination are examined in detail below,
and include the potential for an unnecessary deleterious impact on
public health, both nationally and worldwide. It is important,
therefore,, to establish now the environmental radiation standards within
which this growth will take place.
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The principal potential impact of radioactive effluents on the
biosphere is the induction of deleterious health effects in man.
Comparable levels of impact undoubtedly exist in other biota, but there
is no present evidence that there is any biological species whose
sensitivity is sufficiently high to warrant a greater level of
protection than that adequate for man (14).
Health effects induced in man by radiation doses resulting from
exposure to radiation fall into two broad categories - somatic and
genetic. The principal somatic effects include leukemias; thyroid,
lung, breast, bone, and a variety of other cancers; and, possibly, the
impairment of growth and development. It appears clear that sensitivity
varies with age, the embryo and young children being particularly
sensitive. The range of possible genetic effects encompasses virtually
every aspect of man's physical and mental well-being. The major
exceptions are infectious diseases and accidents, but even here
inherited susceptibilities also play a role (1<4) .
The potential impact of radioactive effluents can be considered
from three different perspectives. The first of these is the maximum
radiation dose to individuals. This measure has been the one
traditionally used for limiting the potential impact of radiation, and
existing radiation standards are all related to limits on radiation
doses to individuals (15). It is of interest to note that the origin of
existing radiation limits for the general population, at least for
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somatic consequences, has been through taking a somewhat arbitrary
fraction (usually 1/10) of the dose limits established for radiation
workers exposed under controlled occupational conditions (16). The
current Federal Radiation Protection Guides for limiting radiation dose
to members of the general public are 500 mrem/yr to the whole body of
individuals and 5 reins in 30 years to the gonads for all radiation
except that due to medical practice and natural background radiation.
Additional Guides exist for some other organs. As an operational
procedure, it is recommended that a limit of 170 mrem/yr to the whole
body be applied to suitable samples of the population to assure that the
first of these limits is satisfied for any individual. This procedure
automatically assures that the second limit will also be satisfied (17).
A second perspective is provided by summing the individual annual
radiation doses to each of the members of a population to obtain a
measure of the total potential annual population impact. This summation
may be made directly on doses, rather than on potential health effects,
because it is the consensus of current scientific opinion that it is
prudent to assume a proportional relationship between radiation doses
due to environmental levels of radiation and their effects on health for
the purpose of establishing standards to protect public health.
Although this sum is usually expressed on an annual basis, it may also
be assessed for longer periods, which leads to consideration of a third
aspect of the complete assessment of the potential impact of radioactive
effluents - the buildup and persistence of long-lived radionuclides.
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Much of the radioactivity released from nuclear facilities is
short-lived and is essentially removed from the environment by
radioactive decay in less than one year. However, a few radioactive
materials have greater persistence and decay with half-lives ranging
from decades to millions of years, ihese materials may deliver doses to
populations throughout this period as they migrate through the
biosphere. The Agency has characterized the sum of these doses as the
"environmental dose commitment" (13). It is calculated for a specific
release at a specific time and is obtained by summing the doses to
populations delivered by that release in each of the years following
release to the environment until the material has either decayed to
levels at which significant contributions to the sum of doses no longer
occur, been permanently removed from the biosphere, or for a more
limited period of time, in which case it is necessary to specify that
only a partial environmental dose commitment has been calculated. For
the purpose of the analyses made for these standards, environmental dose
commitments were calculated for a maximum period of 100 years.
There are two other dose commitment concepts in common use. The
first is the dose committed to an individual by intake of internal
emitters. This dose conrmitment is directly incorporated into the sum of
doses to individuals comprising the environmental dose commitment. The
second is the dose coirmitment used in publications of the United Nations
Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) (18),
which is defined as the infinite time integral of the average dose in a
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population due to a specific source of exposure. Tliis concept is not,
in general, sinnply relatable to the environmental dose commitment, but
in the special case of a population of constant size is equal to the
environmental dose coirmitment divided fcy the (constant} number of
individuals in the population.
In recent years, it has become increasingly clear that the current
Federal Radiation Protection Guide {500 mrem/yr to individuals, usually
interpreted as an average of 170 mrem/yr to members of critical
populations) for limiting radiation doses to the public is unnecessarily
high. The National Academy of Sciences, in its recent report to the
Agency on the effects of environmental levels of radiation exposure
(14), expressed what may be regarded as a consensus of informed
scientific opinion when it said:
There is reason to expect that over the next few decades
the dose commitment for all man-made sources of radiation
except medical should not exceed more than a few millirems
average annual dose. [And further,] ...it appears that
[societal] needs can be met with far lower. ..risk than
permitted by the current Radiation Protection Guide. To
that extent, the current Guide is unnecessarily high.
The potential impact on health caused by effluents from an
expanding nuclear power industry, if it were to operate at the levels
permitted by the current Federal Radiation Protection Guides, would be
large (1*4) . Current Guides do not, in addition, directly address either
the second or the third perspective of radiation exposure described
above. However, the Guides are accompanied by the advice that exposures
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should be kept as far below the Guides for exposure of individuals as
"practicable," and major portions of the industry operate at
approximately one-tenth of the level permitted by the current Guides.
This was accomplished in large part through the implementation of this
concept by the former AEC in its licensing of individual facilities.
However, attention to individual exposure alone leads to inadequate
control of releases of long-lived radioactive materials, which may give
rise to substantial long-term impacts on populations while contributing
only small increases to annual individual exposures. In addition, the
reduction of individual dose alone, if pursued without consideration of
the associated population dose and the economic factors associated with
the controls that reduce it, can also lead to the use of unreasonably
restrictive control of short-lived radioactive materials that achieves
negligible improvement in public health protection for unreasonably
large investments in control technology. Reduction of the exposure of
individuals to as low as "practicable" levels is therefore not, by
itself, an adequate basis for radiation standards.
Most present regulation of the nuclear industry is applied in the
form of individual licensing conditions for specific facilities. The
AEC has based these regulations on standards derived from the
recommendations of a variety of external advisory groups, such as the
International Commission of Radiation Protection (ICRP) and the National
Council on Radiation Protection and Measurements (NCBP) and, in recent
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years, on the Federal guidance provided by the former Federal Radiation
Council (FRC). These groups have traditionally focused primarily upon
the objective of limiting risk to the individual, although consideration
of genetic consequences to entire populations has provided the basis for
some general guidance on upper limits for exposure of entire
populations. There has, however, been no external source of standards
or guidance for radioactive materials from a specifically environmental
point of view, such as, for example, from the point of view of limiting
the long-term environmental buildup of radionuclides, until the
President's Reorganization Plan No. 3 created EPA and charged it with
that responsibility.
In summary, present'radiation protection guidance, as it applies to
the nuclear power industry, requires expansion to satisfy the needs of
the times. Specifically:
a. The consideration of dose to man on an annual basis should be
expanded to include the long-term impact of the release of
long-lived radionuclides to the environment.
b. The Radiation Protection Guides for annual dose to individuals
are unnecessarily high for use by the industry.
c. Application of the Radiation Protection Guidance that
individual doses should be maintained as far below the
Radiation Protection Guides as "practicable" should include
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explicit consideration of both the total population exposure
and the costs of effluent controls.
The proposed action reflects these three considerations in order to
insure that the anticipated major expansion of nuclear power takes place
with public assurance of an acceptable level of radiation protection of
public health and the environment.
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III. THE STATUTORY BASIS FOR ENVIRONMENTAL RADIATION STANDARDS
These standards are proposed under authority of the Atomic Energy
Act of 1954, as amended, transferred to the Environmental Protection
Agency from the Atomic Energy Commission by the President's
Reorganization Plan No. 3 (October, 1970) (2). That plan provided for
the transfer of environmental standards functions from AEC to EPA;
...to the extent that such functions of the Commission
consist of establishing generally applicable environmental
standards for the protection of the general environment
from radioactive material. As used herein, standards mean
limits on radiation exposures or levels, or concentrations
or quantities of radioactive material, in the general
environment outside the boundaries of locations under the
control of persons possessing or using radioactive
material.
This authority is distinct from and in addition to the authority to
"...advise the President with respect to radiation matters, directly or
indirectly affecting health, including guidance to Federal agencies in
the formulation of radiation standards..." which was also transferred to
EPA from the former Federal Radiation Council by the same reorganization
plan. That authority, while it is broad in scope, is most appropriately
applied to the issuance of general radiation guidance to Federal
agencies and for the use of the States, however, and not to the setting
18
-------
• >f specific environmental radiation standards. These proposed
mvironmental radiation standards are consistent with and would
:supplement the protection provided by existing Federal Radiation
Protection Guides and Guidance.
Two points are relevant to EPA's authority to set environmental
radiation standards. First, although EPA is not limited to specific
criteria for setting such standards (e.g., requirements for "best
practicable" or "best available" technology, or for effluent levels
laving Mno health effects"}, the standards can apply only outside the
ooundaries of facilities producing radioactive effluents. The required
snvironmental protection can be provided within this constraint. By the
same token, this authority may not be used to set limits on the amount
af radiation exposure inside these boundaries, consequently regulation
of occupational exposures of workers inside the boundary is carried out
by the AEC (now the NRC) operating under existing Federal Radiation
Protection Guides for occupational exposure.
Secondly, EPA can only set standards; the authority to regulate
specific facilities was not transferred by Reorganization Plan No. 3
(2). Application and enforcement of these standards against specific
facilities is the responsibility of the NRC. The division of
responsibilities between EPA and AEC (whose regulatory responsibilities
are now carried out by NRC) for carrying out these objectives was
19
-------
addressed specifically by the President's message transmitting
Reorganization Plan No. 3 to the Congress as follows:
Environmenta1 radiation standards programs. The Atomic
Energy Commission is now responsible for establishing
environmental radiation standards and emission limits for
radioactivity. These standards have been based largely on
broad guidelines recommended by the Federal Radiation
Council. The Atomic Energy Commission's authority to set
standards for the protection of the general environment
from radioactive material would be transferred to the
Environmental Protection Agency, The functions of the
Federal Radiation Council would also be transferred. A.EC
would retain responsibility for the implementation and
enforcement of radiation standards through its licensing
authority.
This division of responsibility is not expected to interfere with
effective administration and achievement of these proposed environmental
standards (see, also, Chapter VIe Section D)«
20
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IV. RATIONALE FOR THE DERIVATION OF ENVIRONMENTAL RADIATION STANDARDS
Two objectives are of prime importance in deriving environmental
radiation standards for a major activity such as the uranium fuel cycle.
'.he first is that as complete an assessment of the potential impact on
public health be made as possible. The second is that the cost and
effectiveness of measures available to reduce or eliminate radioactive
-ifffluents to the environment be carefully considered. It would be
. .rresponsible to set standards that impose unnecessary health risks on
.he public (unnecessary in the sense that exposures permitted by the
standards can be avoided at a small or reasonable cost to the industry),
and it would be equally irresponsible to set standards that impose
unreasonable costs on the industry (unreasonable in the sense that
:ontrol costs imposed by the standards provide little or no health
.benefit to the public) .
Projections of health effects made in the technical analyses for
:his rulemaking have been based in large part on recommendations
resulting from the recently completed study of the effects of low levels
3f ionizing radiation by the National Academy of Sciences-National
research council's Advisory Committee on the Biological Effects of
21
-------
Ionizing Radiation (BEIjR Committee) (14) . This committee, which
consisted of a broad cross-section of prominent members of the U.S.
scientific community knowledgeable in the various disciplines
appropriate to a review of existing scientific knowledge in this area,
has provided EPA with the most exhaustive analysis of risk estimates
that has been made to date. Their conclusions include, among others,
the recommendations that it is prudent to use a linear, nonthreshold,
dose-rate-independent model for establishing standards to limit health
effects from environmental levels of radiation, and that numerical
standards for the nuclear power industry should be established on the
basis of an analysis of the cost-effectiveness of reducing these
effects.
Other authorities have suggested, usually on the basis of the same
data, that estimates of health effects based on the first of the above
recommendations may be either too high or too low. Those supporting the
first view argue that (a) risk coefficients have been derived from data
obtained at much higher doses and may, therefore, not properly reflect
any nonlinearity that may be present at low doses or dose rates and (b)
that repair mechanisms may operate at low doses or dose rates to reduce
the impact of such exposures. Those supporting the second view argue
that: (a) some data indicate that low doses may be more efficient in
producing health effects than higher doses,
-------
radiation-induced cancer and are, therefore, at greater risk than most
studies have indicated.
The NAS committee examined all of these views in some detail and
concluded that while each of these arguments may have validity under
various assumptions or for various specific situations, the weight of
currently available scientific evidence strongly supports the continued
use of a linear nonthreshold model for standards-setting. EPA agrees
that this conclusion is the prudent one for use in deriving radiation
standards to protect public health (19). It is also recognized that
rather large uncertainties remain for describing the actual situation,
an uncertainty which is presently beyond scientific resolution.
The health assessments made for deriving these standards depart in
two significant respects from practice common in the past for assessing
the significance of radiation exposures. The first of these is the use
of the concept of environmental dose commitment described earlier to
assess the impact of environmental releases. Previous assessments have
usually been limited to the calculation of radiation doses to
individuals in local populations incurred immediately following the
release of an effluent,. For short-lived radionuclides this will usually
suffice, but when long-lived materials are involved this practice can
lead to large underestimates of the total potential impact of an
environmental release. The underlying assumption justifying such a
practice has been that individual doses to other than local populations
23
-------
and at times after the "first pass" of an effluent are so small as to be
indistinguishable from those due to natural background radiation and are
therefore ignorable. This point of view is not considered acceptable
because it not only neglects the implications of the nonthreshold linear
hypothesis for radiation effects, but also the point that the radiation
doses involved are avoidable man-made doses, not doses due to natural
radioactivity.
The second departure from practice usual in the past has been the
use of explicit estimates of potential health effects rather than
radiation dose as the endpoint to be minimized. In carrying out these
assessments the results of the exhaustive review and analysis of
available scientific observations on the relationship between radiation
dose at low levels and health effects completed recently for the Agency
by the BEIR committee were extremely useful, it is perhaps obvious, in
retrospect, that the proper focus for determination of the appropriate
level for a standard should be its estimated impact on public health,
but in the past minimization of dose has served as a useful surrogate
for this impact because of uncertainties about the functional form and
magnitude of the relationship between dose and effect. Assessments
similar to those made for this statement have also appeared in some
recent environmental statements for generic programs, such as those for
the proposed liquid-metal fast breeder reactor program |4)
plutonium recycle in light-water-cooled reactors (5).
-------
The health impact analysis thus considers the total impact of
releases of radioactive materials to the environment by including
radiation doses committed to local, regional, national, and worldwide
populations, as well as doses committed due to the long-term persistence
)£ some of these materials in the environment following their release.
''he analysis served to identify which processes and effluents from the
;:uel cycle represent the major components of risk to populations, and
, ,eads to a clearer view of the need to control long-lived materials, as
veil as of the futility of excessive control measures for very short-
lived radioactive materials.
In order to assist the determination of the degree of effluent
control that can reasonably be required by standards, an analysis of the
cost-effectiveness of risk reduction was carried out. The consideration
cf the cost-effectiveness of all (or, in some instances, a
aepresentative sampling) of the alternative procedures available for
i isk reduction within the fuel cycle reveals where and at what level
effluent controls can achieve the most return for the effort and expense
involved. Such an assessment of the costs and efficiencies of various
forms and levels of effluent control requires that judgments be made of
t iie availability, efficiency, and dependability of a wide variety of
technological systems, and that for each of these capital and operating
c osts be determined over the expected life of the system. These cost
d ata were reduced to present worth values for use in the consideration
c f cost-effectiveness.
25
-------
Finally, although the primary consideration involved in developing
these standards was reduction of the total potential health impact of
radioactive effluents on large populations, doses to individuals must
also be examined, since even though the total potential health impact
may be at an acceptable level, extreme maldistribution of that impact
may result in a few individuals receiving unreasonably high doses. A
few such situations exist, for example, radioiodines from reactors and
particulates from mills, where inequitably high dose levels may occur
even after cost-effective control of total population impact has been
achieved. Although the absolute risk to any given individual is quite
small for these doses, which are generally below a few hundred
millirems, EPA believes that such doses should also be minimized,
especially when the individual at risK is not the direct recipient of
the benefits of the activity producing them. In these cases, the
approach to setting standards for maximum individual dose was to weigh
the cost-effectiveness of individual dose reduction and the cost of
control relative to total capital cost, in order to arrive at a judgment
whether or not it was possible, at reasonable cost, to reduce these few
individual exposures to the same general levels that are achievable for
large populations for other sources of environmental radiation exposure
••%
from the uranium fuel cycle.
Within the context of the methodology outlined above, radioactive
effluents to the environment from the nuclear power industry can be
considered from three points of view:
26
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1. the potential public health impact attributable to each
effluent stream of radioactive materials from each type of
facility in the fuel cycle;
2. the combined potential 'public health impact of the various
components of the fuel cycle required to support the production
of a given quantity of electrical power; and
3. the integrated potential public health impact of the entire
fuel cycle due to the projected future growth of the industry
over some period of time, such as through the year 2000.
The first of these is useful for assessing the effectiveness of the
control of particular effluent streams from specific types of
facilities. It provides the basic data from which judgments concerning
the latter two perspectives flow. The second viewpoint, which provides
en assessment of the total impact of the industry for each unit of the
ieneficial end-product (electrical power) as a function of the level of
effluent control, provides the information required for assessing the
I otential public health impact of standards for the fuel cycle taken as
3. whole. Finally, although each of these perspectives assists in
farming judgments as to the appropriate level of control and the public
Iealth impact associated with a unit of output from the fuel cycle, only
the third provides an assessment of the potential public health impact
cf the entire industry. The magnitude of this future impact, which
could be either considerable or relatively small, depending upon the
size of this industry as well as the level of effluent control implied
27
-------
by the proposed standards, provides an important part of the basis for
EPA1s conclusion that environmental standards defining acceptable limits
on the radiological impact of the industry are clearly required,
The standards-setting method described in the preceding paragraphs
may perhaps be best characterized as a process of cost-effective health
risk minimization which is here applied to the broad class of related
activities constituting the uranium fuel cycle. This method offers, it
is believed, the most rational approach to choosing standards to limit
the impact of nonthreshold pollutants from an industry encompassing a
wide variety of operations which combine to produce a single output.
There are, of course, a variety of alternatives to this approach to
setting environmental radiation standards. These encompass the use of
health considerations alone instead of considering both health risk and
costs, selective instead of comprehensive coverage of the industry, use
of best available technology, and, finally, the option of substituting
the use of EPA influence on NEC regulatory practice for the setting of
standards. Each of these alternative approaches were considered by the
Agency and are discussed in Chapter VII along with some quantitative
alternatives to the proposed standards that also consider both health
risk and control costs.
28
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V. TECHNICAL CONSIDERATIONS FOE THE PROPOSED STANDARDS
The sequence of operations occurring before and after the
f issioning of fuel at the power reactor is shown schematically in Figure
1, Natural uranium ore (which usually contains approximately 0.2
percent natural uranium), is first mined and then milled to produce a
concentrate called "yellowcake" containing about 85 percent uranium
o*ide. A conversion step then purifies and converts this uranium oxide
t > uranium hexafloride, the chemical form in which uranium is supplied
t 3 enrichment plants. At the enrichment plant the isotopic
cincentration cf uranium-235 is increased from its natural abundance of
aaout 0.7 percent uranium to the design specification of the power
r aactor (usually 2 to 4 percent) by a differential gaseous diffusion
process. The greatest portion of the feed uranium hexaflouride becomes
a plant tail depleted in uranium-235 content and is stored in gas
c/linders. At the fuel fabrication plant the enriched uranium
haxaflouride is converted into uranium oxide pellets, which are then
iDaded into thin zircalloy or stainless-steel tubing and finally
fabricated into individual fuel element bundles. These bundles are used
t3 fuel the reactor. After burnup in the reactor, the spent fuel is
ir echanically sheared and chemically processed in order to remove
29
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to
o
(O
c
73
i
o
A
>
n
m
§
O
Z
to
I
ISOTOPIC
ENRICHMENT
LOW LEVEL
WASTE
MANAGEMENT
.FUEL
REPROCESSING
FUEL
FABRICATION
LIGHT WATER
POWER REACTOR
HIGH LEVEL
WASTE
MANAGEMENT
-------
radioactive waste products and to reclaim fissile material (mainly
Plutonium and unused uranium) for reuse. Each of these operations
depend upon the transportation of a variety of radioactive materials.
Table 1 shows basic parameters that are representative of typical
facilities for each of these fuel cycle operations (20). The values
wl ich relate these operations to the number of gigawatts of power
pa eduction supported can be used as the basis for an assessment of the
environmental impact of the fuel cycle as a whole. A projection of the
magnitude of fuel cycle operations required to support reactors through
tie year 2000 is shown in Figure 2 (7). Currently existing capacity is
expected to be sufficient to accommodate the requirements of the fuel
cycle up to about the year 1980, with the exception of fuel reprocessing
operations. In this case, a single facility is expected to become
operational within a few years, with additional capacity becoming
operational in the 1980's.
The environmental impacts due to radioactive materials associated
with the various operations comprising the uranium fuel cycle fall into
fcur major categories. These are: 1) doses to populations and to
individuals due to naturally-occurring radioactive materials from
operations prior to fission in the reactor; 2) doses to populations and
individuals from short-lived fission and activation products; 3) doses
tc populations from long-lived fission products and transuranic
elements; and 4} gamma and neutron radiation from fuel cycle sites and
31
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TABLE 1
CHARACTERISTICS OFMODEL
FUEL CYCLE FACILITIES
Operation1
Uranium Mill
(MT U308)
UFg Production
(MT U)
Iso topic Enrichment
(swu)
UC>2 Fuel Fabrication
(MT U)
Light-Water-Cooled Reactor
(GW(e) capacity)
Spent Fuel Reprocessing
(MT U)
Fuel Cycle Plant
Annual Capacity
Range
500-1100*
5000-10,000
6000-17,000
300-1000
0.04-1.3
400-2100
Model
1140
5000
10-, 500**
900
1
1500
Number of Model
LWR's Supported
by Facility
5.3
28
90
26
1
43
lrThe units which characterize each type of operation are abbreviated
as follows; Metric Tons = MT; separative work units = swu; and
gigawatts(electric) = GW(e).
*
Characteristic of about 70% of current facilities.
sit
Current operating level of industry and assumed model plant capacity.
32
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900
800
1135
700
600
LJ
500
400
j
Si
300
200
100
1970
ELECTRICAL ENERGY SUPPLIED
-120
1980
1990
2000
YEAR
Figure 2. PROJECTED NUCLEAR FUEL CYCLE FACILITY NEEDS
33
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transported radioactive materials, which may produce doses to a few
individuals close to facilities, and to large numbers of people at low
levels of exposure along shipping routes.
Standards to limit the above four categories of individual and
population dose can be expressed using three major kinds of units of
measure: 1} limits on annual doses or individual dose commitments to
the whole body or to specific organs of individuals (millirems/year); 2}
limits on annual population dose or environmental dose commitment (man-
rems/year or man-rems, respectively); and 3) limits on the total
discharge of long-lived materials to the environment per unit of output
from the fuel cycle (curies/gigawatt-year). Limits on the impact on
individuals through each of the above categories of exposure are most
easily expressed directly as limits on annual individual dose commitment
(millirems/year). Control of population impacts, both from long- and
short-lived materials, can be achieved directly through application of
either of the latter two kinds of units of measure. However, although
the best measure of the population impact of long-lived materials is the
environmental dose coirmitment (man-rems) r standards expressed in nian-
rems would be extremely difficult to enforce because of the many
pathways and wide choice of models for transport through the biosphere
that are available. A more reasonable approach for long-lived materials
is to limit the total quantity of such materials introduced into the
environment by first calculating environmental dose commitment and
health effects and then deciding what limit on the directly measurable
-------
quantity (the quantity released to the environment measured in curies)
best achieves the level of protection indicated. Furthermore, analysis
of dose distributions indicates that the population impact of short-
lived materials is quite adequately limited by a limit on individual
exposure, and that a separate limit for the impact of these materials on
populations eKpressed in man-rems/year is an unnecessary redundancy,
Thus, standards for the fuel cycle expressed in just two kinds of units
Df measure {millirems/year and curies/gigawatt-year) are adequate to
Limit both the total population impact of fuel cycle operations and, at
the same time, maximum individual risk.
Table 2 summarizes the principal types of radioactive effluents
from the fuel cycle and the associated target organs which are of
greatest concern. The degree of environmental protection appropriate to
minimize the public health impact of these (as well as other less
important effluents) may be assessed using three complementary sources
af information: 1) projections based upon modeling of source terms, the
capabilities of effluent control, and environmental pathways, 2)
measurements of the actual performance of existing facilities, and
projections based upon these measurements for improved levels of
affluent control, and 3) the performance anticipated by the industry,
the Atomic Energy Commission, and the Nuclear Regulatory commission as
reflected by recently filed environmental statements for a variety of
Euel cycle facilities.
35
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TABLE 2
PRINCIPAL RADIOACTIVE EFFLUENTS FROM THE URANIUM
FUEL CYCLE AND THE ASSOCIATED CRITICAL ORGANS
Effluent
Noble gases
Radloiodine
Tritium
Carbon-14
Cesium and other metals in liquids
Plutonium and other transuranics
Uranium and daughter products
Gamma and neutron radiation
Principal Critical J)rgan(s)
Whole body
Thyroid
Whole body
Whole body
Whole body, G.I. tract
Lung
Lung, bone
Whole body
36
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The most complete set of information available is that derived from
model-based projections. For this reason, the principal inputs for
judgments about acceptably low levels of environmental impact are based
upon this data base. The rationale for these judgments is described in
Section A below, which also summarizes the results of these projections,
Sections B and.C present data from environmental statements and field
measurements for specific facilities, respectively. These data in some
instances confirm the conclusions drawn from models, and in others point
out areas where modifying judgments are appropriate. The final section
describes the conclusions reached,by the Agency for the proposed
standards.
A. MODEL PROJECTIONS OF FOEL CYCLE ENVIRONMENTAL IMPACTS
There are several elements to the development of a projection of
the potential health impact of radioactive effluents. The first is a
determination of effluent source terms as a function of the level of
effluent control. Next, the assumed radionuclide effluents must be
followed using semiempirical models over as wide an area and for as long
a period as they may expose human populations. Human doses are then
calculated from the radionuclide concentrations projected by these
models for air, water, and foodstuffs. For each radionuclide this
involves modeling of the penetration of the radiation through body
tissues, rates of ingestion and excretion, and partition among and
37
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metabolism in the various organs of the body. Finally, after doses to
various critical organs have been, determined, the probabilities of
incurring somatic and genetic health effects attributable to these doses
are estimated.
These projections have been carried out and are described in detail
for each of the major effluent streams from the various activities
comprising the fuel cycle in the EPA reports entitled "Environmental
Analysis of the Uranium fuel Cycle" (7,8,,9,1Q}. The results of these
analyses include both the reduction in potential health impact and the
costs of a large variety of measures that can be instituted within the
fuel cycle to reduce its environmental impact. These have been
summarized in Figures 3a and 3b for the entire fuel cycle by using the
normalizing factors sho»n in Table 1 for the typical model facilities
described in detail in references 7-10. Figure 3a displays the
reduction in potential health effects achieved as a function of
cumulative incremental control system costs to the entire fuel cycle for
the case of a typical pressurized water reactor, for a representative
variety of control options on each component of the cycle. The costs of
control have been normalized to one gigawatt of electric power output
and were applied in the order of decreasing cost-effectiveness of health
effects reduction for the-fuel cycle, taken as a whole. A similar curve
can be constructed for the fuel cycle for the case of a typical boiling
water reactor, and is shown in Figure 3t. It should be noted that many,
if not most, of the types of controls shown are representative of
38
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[PWR CASE!
O 200
CfcSf BGlf-3 #W|
CHE** TREATMENT (CWN-WSI
r— CHEM TREATMENT (CWN-WSI '"" W B*S W
\ i— PSffiiftS * Ft.OC*N (FUSS. fMti / /
\ \ / / . - CHEW IHf^
S \ // / /-3wl HCPA JFU
/f
0 1 2
3 4 5 6 7 8 9 10 fl 12 T3 14 15 16 17 18 IS 20
PRESENT WORTH CUMULATIVE COST fMiiUONS OF DOUARS)
' — ' — i - "™~~ - 1 - ' - 1 - 1 -
30.05 30.10 30 15 30.20 3
COST OF ELECTRICITY TO CONSUMER iMiLLS/KILQWATT HOUR)
?8WR CASE)
250
23 4 5 $ 7 8 9 10 11 12 13 14 15 16 17 18 19 20
PRESENT WORTH CUMULATIVE COST (MILLIONS OP DOLLARS;
T
30.OS 30,10 30.15 30.20
COST Of ELECTRICITY TO CONSUMfH JMILLS/KttOWATT HOUR)
FIGURE 3. RISK REDUCTION VS. COST FOR THE URANIUM FUEL CYCLE
39
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current practice. "A detailed discussion of the various control options
displayed on these figures, as well as of alternatives not shown, will
be- found in references 7-10. The examples shown are typical, however,
and provide a good representation of the options available for effluent
reduction,
The rationale for deriving an acceptable choice of values for
standards described in Section IV was applied to the data exemplified by
Figure 3 to determine the levels of performance achievable, based on
model projections. Table 3 shows,' for the major categories of
radiological impact, the projected maximum doses to exposed individuals
and the quantities of long-lived radionuclides released to the
environment achievable at the levels of effluent control judged to be
consistent with such considerations ass a) an acceptable level of cost-
effectiveness of risk reduction, b) an equitable distribution of
radiological impact,, or c) the existing use of technology by industry as
the result of non-radiological considerations. The numerical criteria
used for judging the acceptability of the level of cost-effectiveness of
risk reduction are discussed later in this section. The second, and
third columns indicate the type of facility at which each major impact
occurs and the level of control which has been judged environmentally
acceptable, respectively. The final column indicates which of the above
considerations was controlling for each category of exposure.
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TABLE 3
DOSE ASP QUANTITY LEVELS IMPLIED BY PROJECTIONS
Level* Source Control^ Limiting Factor
A, Maximum Annual Individual Doses (mrem/yr)
1. Whole Body
a. Noble Gases <1
b. Tritium
o. Carbon-14
d. Cesium, etc.
2. Lung
a. Plutonium, etc.
b. Uranium, etc.
3. Thyroid-Radioiodine
4« Bone ~ Uranium, etc.
1-5
PWS
ws.
n
FR
FR
Bit
BWR
IB
18-13
2-20
Not* 1
None
Not* 1
PUR-3
BWR- 3
Not* 2
C/E
C/E
C/B
Not Available
C/B
C/I
C/E
C/B
Ft
HEPA
11
10
2-9
1-8
15
tan
Fab
PWR
mm
FR
Filter
HEPA
PGIl-3,0-5
BGIE-2,0-5
Note 3
13 Hill Clay Core
C/B
C/E
Recovery of Uranium
Maximum Individual
Maximum Individual
C/E
C/E
B. Maximum Quantities Released to the Environment, Per Gigawatt-Year of
Electric Power (Curies)
1. Tritium
2. Carbon-14
3. Krypton-SS
4. Iodine-129
**
5. Plutonium, etc.
30,000
A.ZO
4000
<0.002
<0.0003
FR
LWR
FR
FR
FR
None
Note 1
Note 1
Note 3
HEPA
Not Available
C/I
C/E
C/E
C/E
doseii are rounded to the nearest number of millirems/year at the
location of maximum dose outside the facility boundary.
""System designations are theye used in Ref, 48; the levels at LBR's
are for 2 units,
*At the nearest farm in the CM* of elemental release of iodine, and
at the nearest residence in the case of organic releases; dose ranges
shown encompass that for 100Z release of either form,
**Defiaed ns alpha-emitting transuranics of half-life greater than 1 year.
Note 1 Assumes krypton retention via any of several alternative methods of
equivalent cost. Such control is assumed to permit the retention of
the approximately 60Z of carbon-14 produced by the fuel cycle that
is released by fuel reprocessing at negligible additional cost. The
balance shown is released at the reactor.
Mote 2 In addition to tritium whole body exposures at fuel reprocessing,
cesiua-137, ruthenium-106, and iodine-129 may combine to yield com-
parable whole body doses. The do»e shown is that remaining in the
presence of cost-effective levels for control of other major
effluents (particularly transuranics and iodine).
Note 3 Assumes Iodine control is available with a removal efficiency of
99,9Z for both lodin*-131 and iodine-129. Although some uncertainty
exists concerning the performance of immediately available systems,
systems presently under active development should achieve such
efficiencies and become available prior to expansion of the fuel
reprocessing industry to more than one or two facilities following
the year 1980.
-------
The results shown in Table 3 indicate that at these levels of
control of environmental releases the attainable range of maximum annual
whole body dose to an individual at the boundaries of representative
reactor sites (for the unlikely case of simultaneous exposure to air and
water pathways) is 0-2 mrem/yr for pressurized water reactors and 1-6
mrem/yr for boiling water reactors. All of the three major types of
sites (river, lake, and seacoast) are included in the projections which
yielded these dose ranges. At a few atypical boiling water reactors on
small sites, gamma radiation doses from skyshine due to nitrogen-16 in
turbine building components may be significant compared to these values.
However, in such cases, additional concrete shielding will reduce these
doses to a few mrem/yr (10). A large (1500 metric tons per year) fuel
reprocessing facility is expected to exhibit maximum doses of 6-8
mrem/yr to the whole body. The only other source of exposure in the
fuel cycle which has the potential to produce whole body doses of
significance in comparison to these types of facilities is tailings at
milling operations, which may produce gamma doses to the whole body if
not properly stabilized against wind and aqueous erosion. However, if
these tailings are stabilized to the degree required to adequately
control lung doses, the residual gamma doses to the whole body are
small.
It should be noted that the cases considered in this analysis
assume two one gigawatt (electric) power reactors on each site. Larger
numbers of reactors would require larger sites in order to achieve these
-------
doses at the boundary, or, alternatively, a greater degree of effluent
control. It is anticipated, based on experience, as well as
environmental and other considerations not related to radioactive
effluents, that sites used for multiple reactor installations will, in
practice, be significantly larger than those for single or twin reactor
installations, and that in those instances where this is not the case
the economies associated with the use of smaller sites and multiple
installation of reactors will readily accommodate the slightly higher
costs of improved effluent control required to maintain the above dose
levels. An additional factor influencing the maximum doses at sites
with large numbers of reactors is the small likelihood that all of the
limiting fuel failure and leakage parameters assumed in order to model
the effluent source terms will be realized by all of the reactors on a
site simultaneously. The matter of doses anticipated from sites with
more than two reactor units is elaborated upon at length in
Section Vl-F.
Maximum potential annual doses to the lung and to bone from the
fuel cycle occur at mills and at fuel fabrication facilities. These
doses result from the release of dust containing natural or enriched
uranium. At fuel fabrication facilities current releases are restricted
to levels corresponding to maximum lung doses of approximately 5
mrem/yr, due to the incentive provided ty the recovery of valuable
enriched uranium. Readily achieved levels of effluent control at mills
and other facilities associated with the supply of uranium fuel to
-------
reactors lead to comparable or lower doses to the lung, as well as to
bone. In the case of some mills achievement of this level will involve
use of dust control measures at tailings piles, as well as additional
effluent controls on mill operations themselves. For a detailed
discussion of effluent controls at mills see reference 10,
"Supplementary Analysis - 1976."
Thyroid doses due to environmental releases of short-lived
radioiodines from the fuel cycle are particularly difficult to model
realistically due to uncertainties in the magnitudes and effective
release heights of source terms and the chemical form in which iodine is
released, as well as complicated environmental pathways, which, in
addition to direct inhalation, typically involve airborne transport of
iodine to vegetation (the extent of which is extremely sensitive to
rainfall), immediate or delayed uptake fcy cows, and, following an
indefinite additional period of delay, final ingestion by humans in
milk. Doses calculated from milk ingestion are subject to uncertainties
due to dilution resulting from milk pooling in addition to those
resulting from the relatively rapid decay of radloiodine (half-life of
iodine-131 = 8.1 days). Because of all of these uncertainties, model
calculations of thyroid dose are generally anticipated to be markedly
more conservative than those for most other effluents - i.e., actual
doses are expected to be considerably lower than calculated doses. The
model calculations project maximum individual thyroid doses of 1-9
-------
mrem/yr from typical reactor sites at the locations of either .permanent
residents or at nearest farms.
The radioiodine situation at fuel reprocessing plants is even more
uncertain than that at reactors, because of a lack of experience with
many of the control methods for iodine appropriate to these plants and
the paucity of knowledge concerning the chemical form of radioiodine
effluents. In addition to the variety of control methods currently
available, a number of more advanced methods are now in final stages of
development. Currently available systems provide cost-effective control
of iodine emissions with anticipated effluent stream decontamination
factors of 100 (10). Since no fuel reprocessing facility is expected to
become operational before 1980, and only one or two more during the
following decade, it is important to also consider more advanced systems
that are expected to become available during that time period. These
include iodine evolution at the dissolution stage of reprocessing, and
the iodox process (10,21). These systems should permit the achievement
of decontamination factors approaching 1000, and are not anticipated to
represent a major increase in the cost of fuel reprocessing.
Development programs for these systems have been underway for a number
of years at Oak Ridge National Laboratory, and most are in final stages
of pilot scale demonstration, having completed laboratory scale testing.
A further consideration is that it is highly unlikely (and unnecessary)
that fuel will be processed at 150 days after removal from the reactor,
as previously proposed. For a number of years in the foreseeable future
-------
most reprocessed fuel will be more than a year old and therefore have
negligible content of short-lived radioiodines. It thus appears
reasonable to assume that within the next few years overall plant
decontamination factors of at least 300 can be readily achieved. On
this basis, the calculated maximum thyroid dose from a fuel reprocessing
facility would not exceed 15 mrem/yr.
The second part of Table 3 reflects the capabilities of cost-
effective control techniques for long-lived radiomiclides, where they
are available, it should be noted that although tritium control is not
yet available, the voloxidation process now under active development for
fuel reprocessing for the LMFBR program would make possible effective
control of the largest source of tritium from the uranium fuel cycle.
This development program is not expected to be completed for more than a
decade, however (22), and its cost is anticipated to be high.
Garbon-14 has only recently been recognized as a fuel cycle
effluent of potentially large impact (23), and control methods have not
yet been extensively investigated. However, retention of krypton-85 by
either cryogenic distillation on selective absorption at fuel
reprocessing (two of the principle control options for this
radionuclide) would permit, at small additional cost, the simultaneous
removal of carbon-It as carbon dioxide.
-------
Specific control options for krypton-85, iodine-129, and plutonium
and other long-lived transuranics are discussed in references 9 and 10.
In addition, a detailed review of krypton-85 control is presented in
Section V1JI-B of this Statement. The comments above concerning control
systems for retention of short-lived iodine-131 at fuel reprocessing
also apply to iodine-129. Controls for plutonium and other transuranics
are well established technology; those for krypton-85 and iodine-129 are
either developed and currently becoming available for commercial use or
demonstrated in the laboratory and in the final stages of development
for commercial use.
We return now to a discussion of the choice of criteria for
acceptable levels of risk reduction. The display of the options
available for reducing the environmental impact of the fuel cycle shown
in figure 3 can be examined from several points of view. If a certain
number of health effects were presumed justified in order to obtain the
generation of a given quantity of electricity, then this curve would
allow a judgment to be made as to which controls should be used in order
to meet that criterion at the lowest cost. If, on the other hand, a
determination had been made that the total cost of control should not
exceed a fixed amount, the curve can be used to make a determination of
the maximum amount of health effects reduction possible. However, such
judgments are not available for either of these simple constraints with
regard to the generation of electricity. A judgment of the appropriate
level of environmental control must instead consider a variety of
-------
issues. These include such matters as: a) the limiting rate up to
which society is willing to incur costs to prevent deleterious effects
on health, b) the availability of improved control technology not yet in
use, as well as present patterns of use of control technology, installed
for the reduction of radioactive effluents, in order to recover valuable
materials, or for other reasons, and c) the distribution of potential
health effects, i.e., should a few individuals incur relatively larger
risks so that others may receive the benefit of an industry's operation.
If the data in the cost versus health effect curves in Figure 3 are
plotted as differential curves, as shown in Figure 4, a display of the
rate of aversion of health effects per unit cost versus cumulative cost
is obtained. An examination of these curves in conjunction with Figure
3 shows that near a cumulative present worth cost of about three million
dollars per gigawatt of power capacity for the entire fuel cycle for the
PWR case {about eight million dollars for the BWR case), a breakpoint
occurs between efficient and inefficient control options. At this point
the rate of reducing potential health effects is roughly one per half-
million dollars. In the region beyond this point, the differential
curve continues to descend rapidly to very low rates of cost-
effectiveness (note that the vertical scale is logarithmic, not linear),
and an insignificant further reduction in health effects is obtainable
even for large additional control expenditures.
-------
FIGURE 4A PWR CASE
FIGURE 4B BWR CASE
*r
VD
-MEPA (FUEL F
-HEPA'SfREPRC
-•BAG FILTER ICO
_IQDIr\E SCRUBBE
FILTER ICONV MFI
IITE IREPRO)
(OflVINGI FILTER IMILLI
-SETTLING PONDS ICONV *S>
HOLDING POND ICONV HFI
|^/TBITHJM, CONTROL IREPHOI
. LIQUID CASE PWR 3!
v CORE DAM
il SAG FILTER ICONV WS1
^SETTLING TANKS IFUEL FAB)
AY PWR CAS HOLDUI
IODINE CASE PGIE-B IPWRI
° 2 4 6 8 10 12 14 16 18 20
PRESENT WORTH CUMULATIVE COST PER GWe (MILLIONS OF DOLLARS)
I I I I I I
30 0 30 05 30 10 30 16 30 20 30 25
COST OF ELECTRICITY TO CONSUMER (MILLS/KILOWATT HOUR)
v
«>
I HEPA'S (REPRO)
1 BAG FILTER (CONV WSI
1 J^--- IODINE SCRUBBER (REPROI
1^ . ^^s*' SETTLING PONDS (ENRICH,
100. \*^/^
\^>^ ^_^- LIQUID CASE BWR 2
ir ^+ KRYPTON REMOVAL 1REPROJ
T ^^--'OBAG FILTER ICONV HFJ
IgJP-*^- ZEOLITE (BEPRO)
B?-±--— BAG (ORVINGI FH.TER IMILII
prT^-SETTLING PONDS ICONV WS>^ „ QAy x£ CHAflcoAL D£Lflv |£)WR]
10.0 — | ^ f HOLDING POND (CONV HFI
L^*^^"^"^?™! BAG FILTER 1C
^ BAG (CRUSHING! F
r^^**^***'>1 LIOUID CASE BWR
^O^\X\,?0 COVER (MILL)
Q . ^^&^ LIQUID CASE BWR
\ ^2
0.01 -
0.001 -
0001 111 111
024 6 8 10 12 14
PRESENT WORTH CUMULATIVE COST
3NV IVS)
UEL FAP1
LTER IMILl)
3
B)
OOINE C'ASE BGIE 2 IBWRI
CHEM TREATMENT (CONV WSI
-60 DAV XI CHARCOAL DELAY I8WR>
^ ^ PRFCIP'N ft FLOC'N (FUli FAR!
1 ^_^7iK( BAG (CRUSHING) FILItB IMtLLi
Lj-^L.-^ CHEM TREATMENT ICONV HFl
i , 1 1 I 1 1
16 18 20 22 24 26 28
(MILLIONS OF DOLLARS)
30 0 30 05 30 10 30 15 30 20 30 25 30 30
COST OF ELECTRICITY TO CONSUMER (MILLS/KILOWATT HOUR)
FIGURE 4. COST EFFECTIVENESS OF RISK REDUCTION FOR THE URANIUM FUEL CYCLE
-------
If the sole criterion for choosing an acceptable level of potential
health impact was that expenditures to achieve health effects reduction
stop at such a point, then no more cost should be incurred beyond about
three or eight million dollars per gigawatt of fuel cycle power
generating capacity (depending upon whether the power reactor is a PWR
or BHR, respectively), no matter how many potential effects were
remaining at that level. At this point resources are being committed at
the rate of about one half million dollars for each health effect
averted. Since the majority of these potential health effects are
serious in nature, involving loss of life or severe disability, this
could be.taken as implying acceptance of that rate as limiting for
preventing the loss of human life due to the impact of effluents from
uranium fuel cycle operations.
It is extremely difficult to estimate what limiting value society
actually places on expenditures to prevent loss of human life, because
so many intangible factors must be evaluated (24). This task becomes
especially difficult when one is faced with the question of preventing
the loss of life; the task is less difficult, but no more exact, when
considering the choice of appropriate compensation for a specific loss
that has already occurred. Leaving aside the moral implications of
assigning a monetary value to compensation for such a specific loss, and
considering only the experience we can draw upon for what society has
been willing to spend to prevent future losses, one can distinguish
several characteristics. The amount depends upon whether the risk of
50
-------
incurring the effect is imposed voluntarily or involuntarily (the latter
case carrying a much greater willingness to spend) and how far into the
future it is anticipated to occur. The amount also defends upon who is
supplying it and upon how the burden of payment is distributed. In
addition, the historical trend is for steadily increasing amounts.
Most current estimates of the acceptable limiting rate of
investment for the prevention of future loss of life appear to fall at
or below an upper limit of one-quarter to one-half million dollars (25) ,
just below the value, noted above, at which the cost-effectiveness of
health effects reduction for the fuel cycle reaches a point of rapidly
diminishing return. This range of estimates of the acceptable limiting
value for prevention of future loss of life corresponds to a minimum
cost-effectiveness of risk reduction of two to four effects per million
iollars. Returning to the curves in Figure 4 displaying cost-
sffectiveness of risk reduction, it can be seen that most of the systems
»?hich lie above or within this range of cost-effectiveness (with the
important exceptions of krypton and tritium control) have already been
developed and are either available for immediate application or are
already being applied by the industry in response to a variety of
factors that are not as well defined, perhaps, as the explicit health
effect and cost considerations developed here, but are present
lonetheless. it seems reasonable, therefore, that levels of
anvironmental protection achievable by systems of cost-effectiveness
ireater than this range of values should be required, and that levels of
51
-------
protection that can only te achieved using systems of lower cost-
effectiveness should not be required unless other extenuating
circumstances exist. Such circumstances may be that they are currently
already included in facility designs for a purpose not related to
radiation control, or that their use may be indicated in some instances
to bring about the reduction of excessive doses to specific individuals
in the general environment, that is, to ameliorate extreme
maldistribution of impact within the population. The levels of control
shown above in Table 3 were chosen to satisfy these criteria.
B. RESULTS IROM ENVIRONMENTAL ASSESSMENTS UNDER NEPA
For the past four years, an extensive program has been carried out
by the utilities, manufacturers, and the AEC (and its successor, the
NRC) in order to assess the expected performance characteristics of
nuclear power facilities, for each of which the AEC (now the NRC) is
required to file an environmental statement under the provisions of the
National Environmental Policy Act of 1969 {26}. By the end of 1974,
environmental statements had been submitted for 152 reactors at 82
different sites. These analyses provide unusually detailed descriptions
of the impact cf facilities at specific sites. For each site such
details as the local meteorology, topography, population distribution,
water usage patterns, and land usage patterns (including the locations
of nearby permanent residences, vegetable and dairy farms, and
52
-------
recreational facilities) are considered with respect to each pollutant
released to the environment. The sample of statements available
ancompasses every important power consuming region of the United States
ind every significant geographical situation, individually and
2Ollectively, these assessments represent the most comprehensive
analysis ever performed of the potential impact of an industry upon the
snvironment.
Tables 4, 5, and 6 summarize the results of these analyses for
radioactive releases from pressurized water reactors, boiling water
reactors, and other fuel cycle facilities, respectively. 'The results
:or reactors are listed in order of the most recently filed
environmental statement for each site. In cases where more than one
statement has teen filed the most recent has been used. The statements
ire all final unless otherwise indicated. For each reactor site the
Miaximum whole body doses due to gaseous releases, liquid releases, and
fanuna radiation from the site, as well as the maximum thyroid dose to a
child's thyroid (calculated at the nearest pasture) are shown. In the
::ase of other fuel cycle facilities, the maximum whole body, thyroid,
,ung, and/or bone doses are shown, as is appropriate for the particular
•!:ype of facility considered.
Table 4 demonstrates that for over 90 percent of the 52 sites
Containing PWR's, maximum whole body doses from gaseous releases no
greater than 1 mrem/yr are anticipated. For three, maximum doses of 2
53
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TABLE 4<> Environmental Impacts of Pressurized Hater Reactors
Exposure Mode
facility
(No. of Units)
Byron (1)
Pilgrim (3)a)
Conmanche Peak (2)
Bellefonte (2)
Fulton (2)f)
St. Lucie (2)
Surry 3 & 4 (2)
Braidwood (2)
Seabrook (2)
Vogtle (4)
S0 Harris (4)
Millstone (3)a)
Sequoyah (2)
R. E8 Ginna (1)
Catawba (2)
Indian Point (3)
Haddam Neck (1)
Trojan (1)
D. C» Cook (2)
Beaver Valley (2)
Diablo Canyon (2)
Crystal River (1)
Prairie Island (2)
H. B. Robinson (1)
North Anna (4)
Calvert Cliffs (2)
Salem (2)
Waterford (1)
San Onofre (3)
Davis-Bess e (1)
filS
(Date)
7/74
6/74 (draft)
6/74
6/74
5/74 (draft)
5/74
5/74
4/74 (draft)
4/74 (draft)
3/74
3/74
2/74
2/74
12/73 (draft)
12/73
10/73 (draft)
10/73
8/73
8/73
7/73
5/73
5/73
5/73
4/73 (draft/
4/73
4/73
4/73
3/73
3/73
3/73
Gaseous Liquid Site Gamma*
(Whole-body)
<1 2
-------
TABLE 4, Environmental Impacts of Pressurized Water Reactors (coot.)
Exposure Mode
* j.a
(Date)
3/73
2/73
2/73
1/73
12/72
12/72
12/72
11/72
10/72
8/72
7/72
7/72
6/72
6/72
6/72
5/72
3/72
3/72
Gaseous Liquid Site Ganma*
(Whole-body)
<1 3 N.R.
<1 <1 N.R,
3
4
3
<10
10
<1
<1
48e)
12 "
1
5
<1
5
N.R.
Not Reported.
500 hours unshielded occupancy of boundary per year.
a).
b)
c)
d)
One BWR and two PWR units,.
Assumes public access to cooling water discharge canal and consumption of
18 kg of fish and molluski) raised in discharge per year.
Monitoring and appropriate operational practices will be required by the AEC
to maintain this dose level, however, the AEC considers the dose calculated
without use of such measures (28 mrem/yr) very-conservative (i.e., the actual
dose will be lower).
The dose calculated in the EIS (18.5 mrem/yr) will be reduced to this level
by changes in control capability required of the applicant by the AEC.
98Z of the release is froii the condenser air ejector and steam generator
blowdown, and can be eliminated through simple modifications of existing
control equipment.
f)
Two HTGR units.
55
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TABLE 5. Environmental Impacts of Boiling Water Reactors
Exposure Mode
racj.jLj.t.y
(No. of Units)
Siver Bend (2)
Allen's Creek (1)
Clinton (1)
Pilgrim (3)c)
Douglas Point (2)
Perry (2)
Hope Creek (2)
Millstone (3)c)
Bine Mile Point (2)d)
Brunswick (2)
Limerick (2)
Dresden (3)
Grand Gulf (2)
Oyster Creek (1)
Susquehanna (2)
K)
Peach Bottom (2)*'
Pitzpatrick (2)
Duane Arnold (1)
LaSalle (2)
Bailly (1)
Cooper (1)
Hanford No. Two (1)
Monticello (1)
Hatch (2)
Zimmer (1)
Shoreham (1)
Brown's Ferry (3)
Quad Cities (2)
Vermont Yankee (1)
Fermi Unit Iwo (1)
fipj.3
(Date)
9/74
7/74 (draft)
6/74 (draft)
6/74 (draft)
5/74 (draft)
4/74
2/74
2/74
1/74
1/74
11/73
11/73
8/73
7/73 (draft)
6/73
4/73
3/73
3/73
2/73
2/73
2/73
12/72
11/72
10/72
9/72
9/72
9/72
9/72
7/72 (draft)
7/72
Gaseous Liquid Site Gamma
(Whole-body)
<1 <1 <1 <1
2 4 <1
<1 <1 <1
4 <1 <1
8 <1 <1
3 <1 3
1 <1 <1
1 4 25
5 4 N.R.
3 <1 <1
1 <1 N.R.
1 <1 <1
<1 <1 <1
2
-------
TABLE 5, Environmental Impacts of Boiling Water Reactors (cont»)
FOOTNOTES
H.R. = Not Reported.
500 hours unshielded occupancy of boundary per year,
a)
The AEC has required installation of additional equipment to maintain
doses to less than 15 mrem/yr in its comments on the EIS,
At least three-fourths of the projected dose is due to turbine building
exhaust, which is untreated.
c)
'One BWR and two PW1 units.
Includes the contribution from Fitzpatrick, The site gamma dose assumes
100 hours in a boat at point of nearest approach per year. The figures
shown are after scheduled 1975 augment of unit one gaseous effluent
control.
The AEC also calculates a dose of 43 arem/yr through the goat-milk
pathway| more than half of the dose is due to turbine building effluent,
applicant is evaluating improved systems.
The dose of 22 mrem/yr in Table 5.3 of the EIS for unit one will be
reduced by a factor of 100 by a scheduled augment committed by the
applicant (see p.11-40 of the EIS).
8>Plus one 40 MW(e) HTGR,
h'Applicant calculates a maximum dose of 0.45 mrem/yr= AEC will require
applicant to reduce iodine dose to "as low as practicable" levels (see
summary comments on EIS).
EIS lists calculated doses of up to 10 mre»/yr (whole-body) and of
95 mrem/yr (infant thyroid), but applicant has committed to install
additional control equipment to insure no greater than 5 mrem/yr for
both pathways.
•^Assumes a hypothetical cow grazing at the site boundary. Distance to
the nearest pasture was not determined in this early EIS5
57
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TABLE 6
ENVIRONMENTAL IMPACTS OF OTHER FUEL CYCLE FACILITIES
Facility
(Type)
Humeca
(mill)
Highland
(mill)
Shirley Basin
(mill)
Sherwood
(mill)
Sequoyah
(conversion)
Barnwell
(conversion)
Exxon Nuclear
(fabrication)
Midwest2
(reprocessing)
Barnwell
(reprocessing)
EIS
(Date)
12/72 (draft)
3/73
12/74
4/76 (draft)
5/75
4/75 (draft)
6/74
12/72
4/74 (draft)
Exposure (mrem/yr)
Whole Body
—
—
—
—
—
—
—
1
4
Thyroid
—
—
—
—
—
—
1
6
Lung
11
<1
1
<1
3
<1
<1
N.R.
4
Bone
421
3-12
<1
<1
<1
1
N.R.
2
7
N.R. - Not Reported.
1This early draft EIS contains insufficient information to assess this
dose in detail, but it is at least an order of magnitude greater than
that from other comparable facilities,
2This facility is not now expected to become operational in the fore-
seeable future. A cow is occasionally pastured 1,5 mi. north of the
site; the maximum estimated annual dose to a child's thyroid from milk
supplied by such a cow is 7.4 mrem.
Doses are to nearest individual.
58
-------
ir rem/yr, and for one, 4 mrem/yr are expected. Maximum doses due to
liquid effluents display a similar pattern; the handful of doses shown
t lat are significantly greater than 1 mrem/yr are calculated for the
hLghly unlikely situation of individuals postulated to derive a major
p Drtion of their annual animal protein diet from fish grown directly in
tae undiluted effluent from the site. (Such situations, although
p arhaps theoretically possible, have not been observed, are not
anticipated to actually occur, and could be avoided, if necessary, by
restricting fishing at effluent discharge outlets.) Similarly, no
individual is estimated to receive a dose as great as 1 mrem/yr due to
g-unma radiation from the combined impact of all facilities at any site.
F.inally, 90 percent of sites anticipate doses to a child's thyroid due
t > ingestion of milk at the nearest farm no greater than 10 mrem/yr.
The single facility exceeding 15 mrem/yr could control 98 percent of its
p rejected releases through simple modifications of the handling of
untreated air ejector and steam generator blowdown effluents (27).
fable 5 demonstrates that 80 percent of the 31 sites containing
BlifR's anticipate maximum whole body doses from gaseous releases no
greater than 2 mrem/yr, and that all but one will not exceed 5 mrem/yr.
That site (Peach Bottom) predicts 8 mrem/yr at its nearest boundary for
fulltime year-round unsheltered occupancy. The actual dose at the
nearest residence would be significantly lower. Doses from liquid
effluents are smaller, with 90 percent estimating 1 mrem/yr or less and
no site exceeding 4 mrem/yr.
59
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Doses due to gamma radiation originating onsite can be significant
at BWR sites because of the circulation of activation-produced nitrogen-
16 through the turbines in this reactor design. Careful design of
shielding and turbine location relative to the site boundary and
topographical features is required. In spite of this, only two BWR
sites project boundary doses significantly greater than 5 mrem/yr to
individuals. In one of these cases (Nine Mile Point) the dose can be
reduced by restricting boating near the discharge canal; in the other
(Bailly) the dose is to steel workers, not permanent residents, on an
adjacent site, and appears to be unnecessarily high.
Of all the effluents from power reactors, iodine releases from
BWR's represent the greatest potential source of maximum exposure to
individuals. Although 70 percent of sites have projected maximum
thyroid doses at the nearest farm of less than 10 mrem/yr, five estimate
doses between 20 and 30 mrem/yr, and one projects doses significantly
greater. The principal potential source contributing to all potential
doses that are greater than 10 mrem/yr is iodine released from the
turbine building vent (28). Treatment of this source term is possible,
but is made more difficult by the large volume of air released from the
turbine building. Selective treatment of the largest sources in the
turbine building is possible, however, at reasonable cost, and is
incorporated in a number of recent designs (29). The need for such
treatment must be weighed, nonetheless, in the light of the results of
60
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field measurements of potential doses to the thyroid discussed below in
£ action C.
Table 6 summarizes conclusions on anticipated doses to the public
dae to operation of fuel cycle facilities other than reactors from
environmental impact statements. It is far less extensive than that
available for reactors, but represents the projected impact of
facilities typical of modern practice. Significant, but relatively
snail doses are projected to the lung and bone at mills and fuel
r^processing, as well as to the thyroid at fuel reprocessing. The
single instance of a projected dose significantly exceeding 10 mrem/yr
is for a facility not projecting use of cost-effective levels of
p irticulate control (30).
C, FIELD MEASUREMENTS OF ENVIRONMENTAL IMPACT
The oldest commercial power reactor, Dresden 1, commenced operation
orer fifteen years ago, in October 1959. By the end of 1972, there were
2 i commercial power reactors in operation at 22 different sites, and in
1)73, ten more reactors commenced operation. These utilities submit to
the AEC (now the NRC) reports of actual releases on at least a semi-
annual basis. These are reviewed for accuracy and published annually.
I i addition, EPA and its predecessor organizations have conducted
detailed surveillance programs at selected facilities. These studies
61
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have consistently confirmed the accuracy of reported effluents of noble
gases and liquids and the potential doses associated with these, but
appear to reveal significantly lower potential thyroid doses than would
be expected from reported releases using commonly employed modeling
techniques and parameters for environmental pathways.
Table 7 shows calculated maximum doses at the site boundary for the
reported releases of noble gases from operating reactor facilities for
the years 1972, 1973, and 1974 (31). In almost all cases, actual
releases were less than those assumed for the model-based calculations
discussed in Sections A and B above. Figure 5, which is taken from a
recent EPA, report (32), shows the distribution of these releases for ail
BWR«s commencing operation within the past decade as well as that
assumed for the model calculations of the preceding sections. A similar
figure is not available for PWR's due to their extremely low levels of
reported releases. Jt can be seen from the figure that the average
facility experienced releases a factor of 3 lower than the model
assumptions, and that all facilities were at least 35 percent lower.
The doses shown in Table 7 are expected, on the basis of field
experience, to fairly accurately represent actual doses that would be
received by a hypothetical individual located at a reactor site boundary
in the prevailing wind direction, year-round, and unshielded by any
structure. Actual maximum doses to real individuals would, of course,
be substantially lower. These doses have also been calculated for an
62
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TABLE 7
CALCULATED DOSES FROM NOBLE GAS RELEASES AT OPERATING PLANTS (1972-74)
Facility
(Site)
PWR's
Yankee Rowe
Indian Point 1 & 2
San Onof re 1
Haddam Neck
R. E. Ginna
Point Beach 1(2
H . B . Robinson
Palisades
Surry 1 & 2
Turkey Point 3 & 4
Maine Yankee
Oconee 1, 2, & 3
Zion 1 & 2
Ft. Calhoun
Start Up
8/60
8/62,5/73
6/67
7/67
11/69
11/70,5/72
9/70
5/71
7/72,3/73
10/72,6/73
10/72
4/73,11/73,9/74
6/73,12/73
8/73
Net Site
Capacity
IGH(e)]
0.18
1.14
0.43
0.58
0.47
0.99
0.70
0.70
1.58
1.39
0.79
0.88
1.05
0.46
Annual Output
(Z of Capacity)
1972 1973 1974
40 68 60
16 24 50
74 60 84
85 46 89
57 87 52
70 67 77
72 82 87
32 41 1
6 65 45
— 62 66
7 58 52
— 47 52
— 22 39
42 60
Site Boundary Dose
(mrem/yr)
1972 1973 1974
<1 <1 <1
<1 <1 1
3 2 <1
<1 <1 <1
2 <1 <1
<1 <1 2
<1 <1 <1
<1 <1 <1
<1 <1 8?
— <1 <1
<1 <1 <1
— <1 3
— <1 UA
— <1 <1
Site Boundary Dose
80Z Cap.
(mrem/yr)
1972 1973 1974
<1 <1 <1
r • M_ ii ___
___ ti ___
D.F.I'
N.A.
n
ii
ii
it
ii
»
ii
ii
n
ii
ii
ii
ii
CO
N.A. - Not Applicable. UA - Unavailable.
^Decontamination factor of system augment committed by facility. No D.F.'s are listed since all existing facilities project
releases of <1 mrem/yr.
ftlot projected, due to the low fraction of capacity utilized.
^Unusual high dose due to operating problems with recombiner which resulted in shorter holdup times and higher than normal releases.
-------
TABLE 7
CALCULATED DOSES FROM NOBLE GAS RELEASES AT OPERATING PLANTS (1972-74)
(continued)
Facility
(Site)
BWR's
Dresden 1
Big Rock Point
Humbolt Bay
LaCrosse
Oyster Creek
Nine Mile Point
Dresden 2 & 3
Millstone 1
Montlcello
Quad Cities 1 & 2
Vermont Yankee
Pilgrim 1
Start Up
10/59
9/62
2/63
7/67
5/69
9/69
1/70,1/71
10/70
12/70
10/71,4/72
3/72
6/72
Net Site
Capacity
[GW(e)J
0.20
0.07
0.07
0.05
0.64
0.63
1.62
0.65
0.55
1.60
0.51
0.66
Annual Output
(Z of Capacity)
1972 1973 1974
65 33 21
57 68 54
62 77 67
60 46 79
78 64 67
59 68 62
57 64 48
55 34 63
75 68 62
28 73 57
10 44 56
15 71 34
Site Boundary Dose
(nrem/yr)
1972 1973 1974
13 12 <1
543
67 47 77
<1 3 2
37 32 11
11 22 16
254
8 2 23
30 31 67
<1 4 5
341
<1 2 5
Site Boundary Dose
80Z Cap.
(mrem/yr)
1972 1973 1974
16 29 5
855
87 49 92
<1 5 <1
47 40 13
15 26 20
366
12 5 29
32 36 86
347
25 7 2
<1 2 11
Site Boundary Dose
w/Retrofit
(mrem/yr)
1972 1973 1974
<1 <1 <1
<1 <1 <1
2 <1 2
<1 <1 <1
1 1 <1
<1 <1 <1
<1 <1 <1
2 <1 4
<1 1 2
<1 <1 <1
1 <1 —
<1 <1 <1
o.F.y
180
40?
40?
100
40
75
40
8
40
16
>20
>40
^Decontamination factor of system augment committed by facility.
ffoo commitment for retrofit made. A minimum augment has been assumed (recombiner plus 1-day holdup) beyond 20-minute holdup
and release via the existing stack.
-------
5.0 r-
Cn
30-MINUTE
HOLDUP
BASELINE
0.1
0.010.050.10.2
2 5 10 20 30 40 50 60 70 80 90 95
PERCENT OF SAMPLE NOT EXCEEDING PRODUCTION RATE
98 99
99.8 99.9
Figure 5. Distribution of noble gas releases in 1971-73 for boiling water reactors that commenced operation after
1968. The solid line is a fitted log normal distribution.
-------
assumed year of full operation (taken to be 80 percent of rated
capacity, on the average, on an annual basis) at the level of effluent
control in effect during 1972 through 1974. Finally, on the basis of
the retrofits of these facilities presently committed (all are scheduled
to be completed within the next year, except for the two small old BWR's
indicated as not yet committed), the doses that would have been observed
in these years if the retrofits had been in place are shown. The data
indicate that all but one PWR currently produces a maximum potential
fence post dose 5 mrem/yr or less and that all BWR's with currently
committed (or assumed minimum) retrofits would deliver fence post doses
of 4 airem/yr or less. The single anomolous case (Surry in 1974) was due
to a breakdown in control equipment. These results appear to confirm
\
the conservative nature of the model projections of the two preceding
sections.
Liquid pathway releases from these facilities result in much
smaller potential doses than do noble gas releases. Detailed studies of
several operating facilities have revealed no actual dose to any
individual from this pathway as great as 1 mrem/yr (33).
Studies of iodine pathways and potential thyroid doses have been
conducted jointly by EPA and AJBC (now ERBA and NRC) over the past
several years at the Dresden, Monticello, Oyster Creek, and Quad Cities
sites (34). Although atmospheric fallout from bomb testing has
prevented the accumulation of definitive long-term measurements, the
66
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available results present a consistent picture of iodine concentrations
in milk significantly less than those projected by models for the milk
pathway used for most of the environmental analyses reported above. The
difficulty appears to arise from inadequate assumptions regarding the
input parameters of the model for airborne transport of iodine, although
this is by no means definitively established and such other factors as
the influence of wash-out, chemical form of the iodine, and pasture
retention factors are also in question. Regardless of the exact cause
of the discrepancy, the measurements at these facilities are consistent,
and there is no known data in contradiction. The data for Monticello,
Dresden, and Quad Cities are the most complete, and at pastures near
each of these sites the concentrations of radioiodine in milk that were
observed would lead to maximum thyroid doses to infants of a few tenths
of a mrem/yr per curie of iodine-131 released annually to the
environment from the site.
The results of these studies were used to project the expected
maximum doses to a child's thyroid at the nearest pasture at all but 2
of the 12 BWR sites reporting releases in 1972 and 1973. (The locations
of pastures and meteorological characteristics for two small, atypical
BWR's, Humbolt Bay and Big Bock Point, were not available.) These
projections were obtained by normalizing the meteorological
characteristics for the nearest pasture and the actual releases of each
facility to the same quantities for Monticello and Quad Cities, and
projecting the resulting doses for operation of each facility at 80
6?
-------
percent of full capacity. The results indicate that, based on actual
releases reported in 1972 and 1973 by these operating facilities and the
field measurements conducted in these years at the two facilities
studied in detail, no facility had projected maximum potential thyroid
doses to an infant as great as 1 jnrem/yr, in either year, for assumed
average annual operation at 80 percent of full rated capacity.
Field measurements at other fuel cycle facilities are very sparse.
In 1968 DHEW completed a study at a fuel reprocessing facility {35};
this facility is not now in operation and is not representative of the
performance of current technology. The study indicated that maximum
potential individual whole body doses of up to several hundred mrem/yr
and comparable maximum organ doses to the bone were possible at that
time due to ingestion of deer (which had access to the site) and fish
raised in the plant effluent. Access to such sources of intake would
not be possible at a modern facility of this type.
D. THE PROPOSED STANDARDS
Numerical values to limit public exposure and environmental
contamination by long-lived radioactive materials were selected by first
determining the dose levels achievable using cost-effective levels of
effluent control for the reduction of total population impact, and then
by further considering the acceptability of the resulting maximum
68
-------
individual doses and, finally, in addition, the potential for long-term
environmental contamination. The methodology has been described in
Chapter IV in general terms, and specifics are as developed above in
Section V-A. The resulting levels are shown in Table 3, and are
confirmed as representative of levels achievable by real sites and by
actual operations by the data developed in Sections V-B and V-C above.
To these levels was added a margin to provide for operating flexibility
to accommodate minor deviations from anticipated performance levels,
differences in specific parameters of actual sites, and the possibly
somewhat greater impact of larger numbers of facilities on larger sites.
The standards were chosen so as to limit the quantity discharged or the
maximum individual annual dose rate depending upon whether the
radioactive materials concerned were long-lived or short-lived,
respectively. Table 8 summarizes the numerical values of the standards
proposed on these bases.
The proposed standard for maximum annual whole body dose to any
Individual limits the combined external and internal dose due to short-
lived gaseous and liquid effluents as well as to exposure to gamma
radiation originating from all operations of the fuel cycle to 25
nrem/yr. As shown in the preceding sections, such a value is easily
satisfied by levels of control that are cost-effective for the risk
reduction achieved; is achievable at all sites for which environmental
statements have been filed; and, on the basis of operating experience at
axisting sites, can be readily achieved in practice. This value has
69
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TABLE 8
THE PROPOSED STANDARDS TOR
NORMAL OPERATIONS OF THE URANIUM FUEL_CYCLE
A. Individual Dose Limits
1. Whole body 25 millirems/year
2. Thyroid 75 millirems/year
3. Other organs 25 millirems/year
B. Limits for Long-Lived Radionuclides
1. Krypton-85 50,000 euries/gigawatt-year
2. Iodine-129 5 millicuries/gigawatt-year
**
3. Transuranics 0.5 millieuries/gigawatt-year
C. Variances
At the discretion of the regulatory agency (licensor) for
temporary and unusual operating circumstances to insure orderly
delivery of electrical power.
D. Effective Dates
1. Two years, except
2. 1983 for krypton-85 and iodine-129.
Any human organ except the dermis, epidermis, or cornea.
**
Limited to alpha-emitters with half-lives greater than one year.
70
-------
iieen chosen to provide a reasonable margin of operating flexibility
Jseyond the 1-5 mrem/yr projected for most sites operating with levels of
,'ontrol that are cost-effective. It will also provide an ample margin
"or sites with larger numbers of reactors than two {see Section VI-F).
. "inally, the combined impact of a fuel reprocessing facility, if added
:o that at any reactor site, is judged to be such that the standard
iiould continue to be met by levels of control that are cost-effective.
•;?his case of mixed types of facilities on a single site is judged to
represent the worst case reasonably anticipatable.
The appropriate level for a standard limiting the maximum annual
thyroid dose of individuals is not as easy to select. On the basis of
existing field measurements a value much less than that proposed would
ippear to be appropriate. In addition, the level of control assumed
jecessary by the NEC in recent licensing actions on the basis of model
projections appears to be somewhat greater than that justified on the
basis of cost-effectiveness of risjc reduction to the entire population
ilone. This is because only a small number of individuals are
potentially subject to relatively high doses, if actual doses are,
indeed, as low as those indicated by the limited existing number of
field measurements, the degree of control assumed necessary may be
mwarranted. However, the proposed standard has not been based upon the
evidence of field measurements, except to the degree that they indicate
;hat the very high doses projected in a few instances are unrealistic.
the standard has been chosen, instead, so as to reflect a level of
71
-------
biological risk comparable, to the extent that current capability for
risk estimation permits, with that represented by the standard for whole
body dose. This level (75 mrem/yr) should be readily achievable by all
sites using no more control equipment than is now required by normal
licensing procedures.
Doses to other organs may be maintained within 25 mrem/yr using
economical and readily available controls for limiting environmental
releases. These doses arise principally from exposure of lung and bone
as a result of airborne effluents from fuel supply facilities. The
controls required to achieve the necessary reduction of effluents are in
common use in other industries, and include such methods as wet and
venturi scrubbers and HEPA filters for the removal of particulates, and
on-site dust control through the use of chemicals and other materials to
prevent wind erosion. In some cases the achievement of doses within 25
mrem/yr may not be cost-effective, because of the small populations
involved near many fuel supply facilities. However, because of the low
cost of these control measures, individual doses of higher magnitude
than those permitted by the proposed standards are not judged to be
necessary or reasonable.
The proposed standards for long-lived materials fall into two
categories: those which can be achieved using currently available
methods for control of environmental releases, and those that require
use of methods that have been demonstrated on a laboratory or larger
72
-------
scale, but have not yet achieved routine use. In the former case,
exemplified by the standard for plutonium and other transuranics, the
standard limits the environmental burden to a level consistent with that
reasonably achievable using the best available control methods. This
level of control also satisfies the criteria for cost-effectiveness
developed in section V-A. In the latter case, that of the proposed
standards for krypton-85 and iodine-129, the limiting levels of
environmental burdens specified are not those achievable by best
available performance, tut instead by minimum performance reasonably
anticipated from these new systems. Again, the costs of these systems
are judged to be justified by the reduction of potential health impact
achieved at these levels of performance. (See also, in this regard, the
expanded discussion of the costs and benefits of krypton-85 control in
Section VIII-B). As experience is gained concerning the ability of the
industry to limit fuel cycle releases of these materials to the
environment the Agency will consider the need for revised levels for
maximum environmental burdens of these persistent radionuclides.
Similarly, as knowledge becomes available concerning the capability
of technology to limit environmental releases of tritium and carbon-14,
the appropriate levels of environmental burdens of these radionuclides
will be carefully considered by the Agency. However, the knowledge base
now available is considered inadequate for such a determination, and no
standards are presently proposed for these radionuclides.
73
-------
The proposed standards are designed to govern regulation of the
industry under normal operation, and therefore a variance is provided,
to be exercised by the regulatory agency, to accommodate unusual and
temporary conditions of facility operations which deviate significantly
from such planned normal operation. This provision is important because
the standards, although they should be readily satisfied with an
adequate margin of flexibility under normal conditions, are not intended
to provide for the operational flexibility required under unusual
operating situations. Unusual conditions have not been addressed by
these standards, which are intended to define environmentally acceptable
levels of normal operation only, and not acceptable levels of unusual
operation. It is anticipated, however, that although such unusual
operation may occur, at some facilities more often than at others, every
effort will be made to minimize such operation by the regulatory agency.
The proposed standards for maximum doses to individuals were
derived through consideration of the doses arising from effluents
released from single sites. However, since large numbers of sites are
projected for single geographical regions in several parts of the
country, the possibility of additive doses exceeding the maximum limits
for individuals due to the combined effect of effluents from many sites
must also be considered. This problem may be conceptualized as having
two components. The first is the possibility that two sites may be
sufficiently close to each other that the maximum dose to an individual
from one is appreciably increased by the other. The second is the
-------
possibility that the combined effect of all of a large number of sites
in a particular geographical region may give rise to a general increase
in dose levels of significance compared to the maximum dose from any
single site.
Because of the importance of specific meteorological and
geographical parameters, the first possibility is best considered on the
basis of real cases. The largest potential contribution to individual
dose is via airborne releases. Since doses due to such releases
generally fall off to less than 10 percent of their maximum values
within 10 to 20 kilometers, only sites separated by less than 20 km were
considered. There are presently only 3 pairs of such sites projected
through the year 1985. These were each examined using the specific
meteorological parameters characteristic of these sites. The maximum
increases in maximum doses are shown in Table 9. In no case is the
increase as great as 20 percent. Given the margin of flexibility
available in the capability of effluent control systems, this modest
overlap of doses xs not judged to pose any difficulty with respect to
compliance with the proposed standard.
The second possibility, that of a general increase due to the
impact of large numbers of facilities in a region, has been extensively
examined in a recent AEC study of the implications of projected future
nuclear facilities in the upper Mississippi river basin (36), This
study, which was carried out, among other objectives, to assist EPA in
75
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TABLE 9
POTENTIAL INCREMENTAL DOSES DUE TO OVERLAP OF
EXPOSURES TO AIRBORNE EFFLUENTS AT CLOSEST
PRESENTLY PROJECTED NUCLEAR FACILITY SITES
„.., „ , ... Distance Between „ _ t
Site Designations „_ ,. H Maximum Dose
Sites (km)
Peach Bottom - • 2.4 1.20
Fulton
Point Beach - 7.0 1.06
Kewaunee
Hope Creek, Salem*"1" - • 14.5
-------
evaluating the environmental aspects of expanded use of nuclear power,
analyzes the potential combined impact of approximately 350 reactor
facilities and 9 fuel reprocessing facilities projected for this river
basin by the year 2000. The study divided the region into 300 areas,
almost as many areas as there are individual reactors projected for the
region. The analysis shows that in none of these areas does the
projected average dose to individuals exceed 1,2 mrem/yr. The average
for the entire region is less than 0.2 mrem/yr. It should be noted that
these are average, rather than maximum, doses, so that these results do
not specify the maximum doses projected in each subarea, but rather the
sum of the general impact of the many sites outside each area plus the
average local impact of any single sites within the area. A substantial
portion of even these small doses must necessarily arise from local
contributions from within each area. The analysis included a detailed
treatment of all pathways, including air, water, and foodstuffs. Well
over 90 percent of all doses was found to result from pathways involving
airborne transport of effluents, justifying, therefore, the above
assumption that airborne effluents are the primary source of doses. It
is concluded that any general increase in radiation doses from regional
contributions will be small compared to the maximum individual doses to
which the proposed standard applies.
77
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VI. ANTICIPATED IMPACT OF 1HE PROPOSED ACTION
The proposed environmental radiation standards for the uranium fuel
cycle are anticipated to have impacts on long-term contamination of the
environment, on public health, and on the economic cost of producing
electrical energy. The impact of the proposed standards has been
assessed relative to that associated with current standards under wiiich
the nuclear industry has evolved up to the present time. Since the
proposed standards are more restrictive than current standards their
environmental and public health impacts will logically be positive and
not adverse in nature, on the other hand, achievement of improved
levels of protection of public health and the environment will require
controls that will result in increased costs which must be reflected in
energy prices. Standards could also have implications for Federal and
State agencies charged with the responsibility of regulating the
industry (or operating facilities that are part of the fuel cycle), on
the distribution of pollutants between the various environmental media,
for the number of uranium fuel cycle facilities that can be operated at
single or contiguous sites, and even on the mix of nuclear and non-
nuclear fuels used for the production of electricity. These real and
potential impacts are considered in turn in the following sections.
78
-------
The projection of total impact is, of course, dependent upon
forcasts of the growth of the industry. For the purpose of these
analyses it has been assumed that the industry will grow at a rate
consistent with the annual production of 1000 gigawatt-years of power in
25 years, or approximately by the year 2000. This level of output is
consistent with the goal set in 1975 by the President's program for
energy independence (HI) and the midrange projections of the Atomic
Energy Commission (11) when this statement was prepared. However, more
recent assessments indicate that this level of output may not be •
achieved by the year 2000 (6). The projections of impact made below
would hold, approximately, for achievement of this level of output by a
later (or earlier) year, or can be scaled proportionately to obtain an
assessment of impact for other assumed levels of power production by the
year 2000.
A. ENVIRONMENTAL IMPACT
The environmental impact of fuel cycle operations has been
considered from the point of view of long-term irreversible commitments
of radioactive pollutants to the planet's terrestrial, atmospheric, and
aquatic environments. in the next section, the public health
implication of these commitments, as well as that of short-lived
materials, is considered. That consideration of public health impact is
limited, however, to potential health effects initiated by exposure to
79
-------
these materials during the first 100 years following their introduction
to the environment only, and cannot, because of our inadequate
understanding of their long-term behavior, comprehend their full
potential impact. Effects on other life forms have not been assessed in
this statement, since tfcey are not,expected to be significant at levels
adequate for protection of human populations (37) .
Environmental burdens of tritium, carbon-14, krypton-85, iodine-
129, and plutonium and other transuranics were examined for projected
normal releases over the next 50 years from the U.S. nuclear power
industry operating under existing standards and regulations (13). The
results of these analyses are shown in Figures 6-10. For those
radionuclides now released without any restriction, the levels that
could be achieved with and without the proposed standards are shown. In
cases where releases of these materials are currently limited,
projections for each of several levels of control are shown.
These projections demonstrate several significant characteristics.
In all cases, existing environmental burdens due to nuclear power
operations are small, and in all cases rapid increases are anticipated
in the near future at current levels of control. The public health
significance of these increased burdens, as assessed in the next section
of this statement for the first 100 years following release, is
significant for all of these radionuclides and is particularly large for
tritium, carbon-It, and Jcrypton-85, The total significance of
80
-------
700
600
500
J 400
w
D
U
O
0>
0)
300
200
100
1970
1980
1990
2000
tOIO
2020
Figure 6. Profected Environmental Burden of Trifriom.'ftprti'tiKe llnfted States
Nuclear Power Industry.
81
-------
600
1975
1980
1985 1990
YEAR
1995
2000
Figure 7. Projected environmental burden of carbon-14 from the United
States nuclear power industry,
82
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EQUILIBRIUM VALUE
WITHOUT CONTROLS
<1.33x10'°Ci)
.EQUILIBRIUM VALUE
WITH CONTROLS
1970
2020
FIGURE 8.
95 2000 OS
YEAR A,D.
PROJECTED ENVIRONMENTAL BURDENS OF KRYPTON-85 FROM THE UNITED STATES
NUCLEAR POWER INDUSTRY FOR CONTROL INITIATED IN VARIOUS YEARS, THE
EQUILIBRIUM VALUES ARE THOSE FOR MAXIMUM POWER PRODUCTION EQUAL TO
THAT PROJECTED FOR THE YEAR 2020.
83
-------
U
O
4
1970
1980
2010
2020
1990 2000
Year
Figure 9. Projected Environmental Burdens of Iodine-129 from the United
States Nuclear Power Industry at various levels of control
-------
0
1970
1980
1990
2000
2010
2020
YEAR
Figure 10. Projected environmental burden of alpha-emitting transuranics
with half-lives greater than one year, from the United States nuclear power
industry/ assuming release of 10-° of inventory and operation with
uranium fuel only.
85
-------
environmental burdens of carbon-14, iodine-129, and the long-lived
transuranics, which have half-lives of 5700 years, 17 million years and
from 18 years to 2 million years, respectively, cannot be quantitatively
assessed, but must be assumed to be considerably greater than that
anticipated during the first 100 years alone. The potential future
impact of the release of krypton-85, especially if other releases around
the world are added to these estimates, is strongly dependent not only
upon the level of nuclear power production, but also upon the year in
which controls to limit releases of this radionuclide are implemented
(38). As Figure 8 demonstrates, implementation of controls with an
attained decontamination factor (D.F.) of 100 in the early 1980's would
insure that the environmental burden never exceeds the equilibrium
burden, with such controls, associated with any power production level
projected over the next 50 years. Although the proposed standard
requires a D.F. of only approximately 10, it is expected that
installation and use of the controls needed to satisfy this requirement
will result in an actual performance level approaching that shown in
Figure 8. The proposed standards would limit projected environmental
burdens of iodine-129 to 1 percent of that currently projected (39) , and
would also require continuation of presently used best practicable
control of releases of transuranics.
The admonition of the National Environmental Policy Act (26) that
"...it is the continuing responsibility of the Federal Government to use
all practicable means.,to the end that the Nation may...fulfill the
86
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responsibilities of each generation as trustee of the environment for
succeeding generations..." is particularly germane to consideration of
chese long-term environmental pollutants. At currently projected levels
of fuel cycle operations it is clear that the potential for future
radiation effects is substantial in the absence of standards to limit
environmental burdens of these materials. This goal is not satisfied by
;hese standards for releases of tritium and carbon-14 only because
control technologies for these materials are not yet commercially
.•tvailable.
L. HEALTH IMPACT
The anticipated impact of these standards on the potential for
effects on public health is shown in Table 10. These estimates of
potential health effects are limited to cancers (including leukemia),
and serious genetic effects (these include congenital abnormalities
leading to serious disability, and increases in diseases that are
specifically genetic, such as certain forms of mental defects, dwarfism,
ciabetes, schizophrenia, epilepsy, and anemia). The genetically-related
component of diseases such as heart diseases, ulcers, and cancer as well
as more general increases in the level of ill-health are omitted from
estimates of genetic effects, as are effects on growth and development,
b =cause of the wide range of uncertainty in existing estimates of their
i nportance, coupled with a judgment that their total impact is probably
67
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TABLE 10
POTENTIAL HEALTH EFFECTS ATTRIBUTABLE TO OPERATION
OF_THEJffl_CL_EAR JFUEL . CYCLJE THROPGH THE YEAR 2000 AT
VARIOUS ENVIRONMENTAL RADIATION PROTECTION LEVELS^
Type of
Radioactive Material
Federal
Radiation
Guides
Current
AEG
Practice """T
EPA Generally
Applicable
Standards'^
1. Short-lived materials
2. Long-lived materials'''
a. Controllable
(85Kr,129I,239Pu,etc.)
b. Tritium
c. Carbon-14
34,000
1,040
440
12,000
170
160
1,040
440
12,000
20
440*
12,000*
"'"These projections are based upon the linear nonthreshold assumption,
which, at the current level of understanding of radiation effects in
man, warrants use for determining public policy on radiation protec-
tion. It should be recognized, however, that these projections are
not scientific estimates, but judgments based upon scientific data
obtained under different conditions of exposure than those associated
with nuclear fuel cycle operations. Health effects shown are limited
to total cancers, including leukemias, and serious genetic diseases
(see text). The entries are the predicted number of health effects
attributable to releases from the U.S. nuclear industry by the year
2000. The projections assume that approximately 8300 GW(e)~yr of
electric power will be produced by nuclear reactors in this period,
based on AEC Case B projections (WASH-1139(74)). It is also assumed
that all nuclear fuel cycles will operate at the same level of impact
as the uranium fuel cycle.
''Assumes implementation of Appendix I as proposed in the Concluding
Statement of the Regulatory Staff (February 20, 1974).
"""'"Effects are projected for the first 100 years following release only.
&
The majority of this impact can be eliminated through implementation
of the voloxidation process at fuel reprocessing, if current develop-
ment efforts continue and are successful.
**About 60% of this impact may be eliminated as a by-product of the
retention of krypton-85 at fuel reprocessing, however, knowledge con-
cerning control of this source of health impact is currently limited.
88
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ro greater than that of those health effects that have been
quantitatively considered. To the extent that other somatic and genetic
effects are important, the present estimates of the impact of
i adioactive effluents on health are not conservative, although such
e £f ects are expected to be reduced by improved levels of effluent
cantrol in the same proportion as are those that have been quantified.
I.i most instances, the numerical estimates of health effects were
derived using the results of EPA's model projections of effluents and
d >se pathways for fuel cycle operations and health risk estimates from
trie recent National Academy of Sciences' report on this subject
The Table 10 entries in the column labeled "Federal Radiation
Guides" were derived assuming use of the minimum level of effluent con-
trol required to assure a dose no greater than 170 mrem/yr to indi-
v; duals permanently residing at site boundaries. They do not represent
tl.e physically unrealizable assumption of 170 mrem/yr/lndividual to
ei tire local, regional, or national populations. While these entries
axe representative of the levels of operation that are permitted by the
current Federal Radiation Guides and reflected by the NEC's effluent
standards in 10CFR20, it shculd be recognized that most current
operations are conducted so as to maintain maximum doses well below
th 2se permitted levels. The proposed standards would, however, remove
th 5 possibility that these unnecessarily high levels of dose could
co itinue to be sanctioned by license conditions for normal operations of
an f fuel cycle operations, as is now the case for all facilities except
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those reactors whose license conditions have been updated to reflect the
guidance of Appendix I to 10CFR50.
The second column shows the reduction in potential effects that was
achieved through application by the AEC of the Federal Radiation
Guidance that annual doses to individuals be kept as far below the
Radiation Protection Guides "as practicable." These entries also reflect
the levels of potential impact that would have resulted from the
guidance for design and operation of light-water-cooled reactors
proposed by the AEC as Appendix I to 10CFR5Q, if it had been promulgated
by HEC as proposed (iiO) . An assessment of Appendix I as actually
promulgated is more difficult because of the deletion of curie limits
tor radioiodines in airborne effluents and for radioactive materials in
liquid effluents. However, it is anticipated, if Appendix I is
implemented so as to maintain effluents sufficiently low as to insure
that the design objectives are met in actual operating situations for
all but temporary and unusual circumstances, that the level of potential
impact should be essentially that projected for "proposed" Appendix I.
The final column shows the estimated levels of effects attributable
to the industry operating under the proposed standards. The small
reduction shown in the final column for short-lived materials occurs as
a result of reductions in dose from components of the cycle other than
reactors only, since it is assumed that the proposed standards would be
90
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satisfactorily implemented,at reactors by the guidance contained in
Appendix I.
The proposed standards would result in a reduction of approximately
1000 potential health effects due to releases of long-lived materials to
the environment through the year 2000, The principal residual impact of
the fuel cycle would then be that attrifcutable to carbon-14 and tritium,
and control of a substantial fraction of this impact may be achievable
in the near future through inexpensive modification of systems that are
installed to meet the requirements of the proposed standard for krypton.
In any case, the Agency will closely follow the development of knowledge
concerning control of these materials.
Figure 11 shows the projected growth of the potential health impact
of these materials through the year 2000. The projections are for
assumed operation of the industry using uranium fuel only, and also
assume the achievement of an annual production of 1000 GW
-------
VD
103
S 102
* 10
D
4)
(U
03
1970
10"
10'
10'
10
1975 1980 1985 1990 1995 2000 1970 1975 1980 1985 1990 1995 2000
Figure 11. Projected health effects attributable to releases of long-lived radionuclides. Health effects are projected for 100 years
following release only,and the exclusive use of uranium fuel is assumed.
-------
C ECONOMIC IMPACT . ' .
The economic impact of the costs imposed by these standards has
b :en be considered from two viewpoints; first, is the cost reasonable
for the protection received, and second, will the costs have any impact
Uj.ion the ability of industry to supply needed power. The cost-
elf ectiveness of the risk reduction achieved by the proposed standards
w;:,s given careful consideration, as has been described in preceding
sections of this statement. Most of the reduction in potential health
elfects required by these standards comes as a result of the reduction
oJ: environmental releases of long-lived materials. This reduction is
achieved at a cost of no more than a few hundred thousand dollars per
pctential health effect averted (42), a rate of spending for public
hf. alth protection less than that already in effect in the industry for
other types of radioactive effluent control (50), This is because the
pioposed standards impose increased control requirements principally on
effluents that can deliver doses to very large populations over long
periods of time, instead of in areas where short-term doses to only a
relatively few individuals near facilities can occur.
In November 1975, there were approximately 55 reactor units in
operation, 86 under construction, 55 under construction permit review
but not authorized for site work, 23 ordered, and 19 more planned for
cc cistruction during the next 10 years, for a total of 238 units. The
capital cost of a newly ordered one GW(eJ reactor was estimated in 1972
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to be on the order of 450 million dollars. Current estimates are
considerably higher,, and values of over 700 million dollars are now
projected (43) . The additional capital costs, beyond those incurred by
practice employed in industrial operations prior to the proposal of
Appendix I by the AEC, for control equipment required to meet the
standards are estimated to be approximately 1.5 to 2.8 million dollars
(1972 base) at a PWR and 6.2 to 7.6 million dollars at a BWR, for a 1
GW(e) facility. The range of values reflects the range of iodine
control required at different sites. If it is assumed that the costs of
effluent controls exhibits the same behavior as has the cost of reactors
as a whole, it is clear that the capital cost of controls to meet the
proposed standards is less than one percent of the capitol cost of
pressurized water reactor and one to one and one-half percent of the
capitol cost of a boiling water water reactor. The increased annual
operating cost associated with these additional controls would be less
than 1 percent for a PWR and perhaps as much as 5 percent for a BWR.
The higher costs for EWR's are a reflection of a simpler basic design
which produces, however, a considerably larger volume of effluents that
must be treated. It should be particularly noted that these increased
costs, for reactors are required, independently of these EPA standards,
by Appendix I as issued by the NEC in May 1975. Since this increase has
already been anticipated by industry in its current designs and the NRC
is currently implementing Appendix I in its license specifications, the
proposed EPA standards %»ould not, in any real sense, cause any increased
expenditures at reactors, it should be noted that monitoring and
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reporting requirements would be essentially unchaged at reactors. The
;; ew minor additional costs are described in Section VIII-A.
The principal economic impact of the proposed standards is that
they would require an approximately 10 percent increase in the capital
costs of a fuel reprocessing plant, principally to remove krypton-85.
•She impact on the balance of other components of the fuel cycle is
einticipated to be smaller. The present worth of new controls to meet
the proposed standards at a fuel reprocessing facility is estimated as
approximately 30 million dollars, or 0.7 million dollars per
cigawatt(electric) of fuel cycle capacity served. The combined cost of
controls at all other fuel supply and handling facilities is estimated
to be no more than 0.3 trillion dollars per gigawatt (electric) of fuel
cycle capacity served. Since fuel cycle costs not directly associated
vi'Lth the power reactor represent less that 20 percent of the total cost
cf power (44) , the impact of these increased fuel supply and
reprocessing costs on the cost of power is anticipated to be
c snsiderably less than 1 percent. This cost, even when added to
increases in capital and operating costs for controls on the reactor
required by Appendix I, is calculated to result in an overall impact of
tiese standards on the cost of power that is still less than one percent
o: its total cost at the busbar from a PWR, and less than two percent
f rom a BWE. Incremental costs to consumers will be a factor of two to
four less than even these small amounts, due to the presence of large
unaffected fixed costs for power transmission and distribution. It is
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concluded that the combined economic impact of these proposed standards
and Appendix I will be small, and cannot realistically be anticipated to
have any impact on the ability of the industry to supply electrical
power.
D. ADMINISTRATIVE IMPACT
The Federal agency principally affected by these standards will be
the Nuclear Regulatory Commission (NRC), which has the responsibility to
insure adherence to EPAfs environmental standards in its regulation of
the individual facilities comprising the commercial nuclear power
industry. The Energy Research and Development Administration (ERDA)
will be affected to the extent that the uranium enrichment facilities
operated by ERDA supply the commercial nuclear power industry and
additional development and/or research associated with of effluent
controls for krypton-85 and iodine-129 is carried out by ERDA
laboratories. The Department of Transportation would also be affected
to the extent that its regulations concern minimization of public doses
due to shipments of spent fuel assemblies and high-level radioactive
wastes.
It is unlikely that issuance of these environmental standards will
cause any substantial impact due to the need for changes in licensing
regulations for power reactors. In the case of reactors, the NRC
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recently issued new design and operating guidance (Appendix I to
10CFR50) which can, with certain minor modifications, be used
immediately as regulatory implementation of these standards for reactors
by NRG. These are discussed in Section VIII-A. The NRC announced, when
it issued Appendix I to 10CFR50, that it would make any changes in that
proposed guidance that would be required to conform to EPA standards,
Since the standards proposed here for reactors do not require
substantial modification of Appendix I, there should be no impact on
NRCfs regulatory process for power reactors that differs materially from
that already required for implementation of Appendix I.
In the case of other components of the fuel cycle, the current
regulatory situation is one of uncertainty and potential change. These
Eacilities have generally operated within the numerical limits
prescribed in 10CFR20 (which contains a detailed statement of the
implications, isotope ty isotope, of the current Federal Radiation
Suides for maximum exposure of individuals) with no codification of
numerical guidance for these activities of the lowest practical effluent
Levels. In May 1974, the AEC announced that it was undertaking
culemakings to determine "as low as practicable" design and operating
conditions for several of these components of the cycle (45). To date,
:his guidance has not been issued. Issuance of these proposed standards
>y EPA should help,to expedite promulgation of this "as low as
jracticable" guidance by NRC. To the extent that any environmental
^statement is required of the NRC for such new regulations, that process
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should be considerably simplified and shortened by the existence of
these environmental standards, compared to the lengthy procedures now
followed for developing regulations governing environmental releases
from the industry. The establishment of technical specifications to
insure conformance with these standards at facilities other than
reactors will fce required. However, this process should not require
technical analyses substantially different from those already carried
out in conformance with NEP& requirements. It should be noted that
those parts of the proposed standards which Impose significant new
requirements have been phased in time so as to permit orderly regulatory
implementation with adequate lead times for their integration into plant
design and construction schedules.
In addition to the NRC regulation discussed above, certain
facilities in the uranium fuel cycle (some mills and conversion plants)
are now regulated by States under agreements with the NRC. This is also
not expected to result in any implementation difficulty, since such
"Agreement States" must, under terms of the authorizing statute for
these agreements, conform to NRC regulations, which in turn must
implement EPA standards.
ERDA is directly affected through requirements of these standards
at its uranium enrichment facilities. No substantial impact is
anticipated, however, since these facilities now operate well within the
proposed standard, according to published AEC data. In addition,
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farther investigations cf control systems for krypton-85 and iodine-129
(as well as other effluents) are being carried out by ERDA at various
national laboratories a*s a continuation -and expansion of activities
jfc.eviously underway under the auspices of AEC. The requirements set
farth by these standards underscore the need for these activities, and
t ae wisdom of their pursuit in the past.
It is anticipated that any desirable modifications of procedures
aid regulations for transport of radioactive materials associated with
c perations of the fuel cycle (especially spent fuel and high-level waste
s aipments) will be carried out jointly by MRC and DOT, which share the
r ssponsibility for insuring adherence to radiation protection guidance
in this area. Such modifications are anticipated to consist principally
c£ measures to insure that such materials do not remain for substantial
tariods of time at locations where members of the public may accumulate
substantial doses.
The standards should also facilitate the preparation and review of
environmental statements for individual facilities by providing a clear
s tatement of environmental radiation requirements from the agency
i=sponsible for determining these requirements. They are not
anticipated to incur substantial additional analysis, due to their
a pplicability to the total dose from all facilities in any particular
region, because such impacts are, in general, extremely small in
comparison to the proposed standards.
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E. INTERMEDIA EFFECTS
The proposed standards encompass pollutants discharged via both air
and water pathways. They also imply commitments of land use for the
storage of both the high and low level wastes collected by control
systems. In general, choice of the release pathway that involves the
minimum environmental impact is unambiguous; the only major exception is
for release of tritium. And in general, the waste disposal implications
of the standards are most serious for long-lived radioactive wastes.
However, the incremental amounts of these wastes are very small for the
controls required by these standards, compared to the already-existing
quantities produced by nuclear power facilities, i.e., those that do not
result from effluent control choices.
There is no presently available control mechanism for tritium; the
possibility of future control at fuel reprocessing facilities (the
principal source of tritium releases) has been discussed in a number of
investigations (46). For the present, the alternatives available for
reducing population exposure are limited to dispersal via air-versus-
water. A portion of the population dose delivered when tritium is
dispered to air occurs over the long term and on a worldwide basis.
This worldwide portion of the dose is the same when tritium is dispersed
via water. The balance of the dose is delivered promptly to the U.S.
population, and, if delivered via air,, is relatively independent of the
characteristics of the effluent site and approximately three times
100
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larger than the worldwide population dose. If delivered via water, the
population dose is extremely site dependent, ranging from negligible to
approximately ten times larger than the worldwide component of
population dose. The important variable is whether or not the receiving
waters are used for public drinking water supplies. An additional
complication is the possibility of additional contamination by other
radionuclides if water is the dispersal route. Although the proposed
standards do not address the issue of the most expeditious choice of
release pathway for tritium, it is recommended that the discharge
pathway delivering minimum dose be determined by the regulatory agency
and required on a site-by-site basis.
*
Disposal of radioactive effluents through dilution and dispersal in
air or water has, in tjae past, been a common method for satisfying
radiation protection requirements, which have been commonly expressed as
maximum permissible concentrations in air and water. The alternative is
that contemplated by these standards: collection of these materials
through the use of effluent control systems at the source followed by
storage of long-lived materials using one of several long-term waste
management schemes. The environmental question is which alternative,
over the long term, presents the least environmental hazard. The answer
in the case of materials having half-lives less than about 100 years is
unequivocally in favor of storage, since this route reduces the
probability of future human exposure to a small value. In the case of
longer-lived materials storage is also the preferred route. However,
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the possibility exists that future releases of stored materials may take
place, with attendant human exposure, and the magnitude of this
possibility is not well-defined. These waste management issues are not
addressed by this rulemaking. It is simply assumed that waste
management represents an improvement over disposal, with high
probability of success in the short term, and with reasonable prospects
for success over the long term. Although this issue is basic to the
environmental viability of nuclear power, it has been treated as
separable from the question of reasonable levels of planned effluents
because the wastes generated by effluent control systems represent only
a small addition to the total waste management problems of the industry.
The issues associated with the decommissioning of facilities are
ultimately again those of waste management. The incremental problems to
decommissioning represented by a few additional effluent control systems
are a small perturbation on the already-existing burden for
decommissioning of these facilties as a whole.
F. IMPACT ON FACILITY DISTRIBUTION AND REACTOR MIX
We discuss four related matters below. These are the potential
impact of the proposed standards on: 1) the location of a number of
reactor units on a single site, 2) the number of sites in a given
geographical area, 3) nuclear energy centers, and 4) the mix between
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nuclear and fossil fueled electrical energy production. It is concluded
that the proposed standards will have little, if any, impact on any of
these.
1. Multiple Reactor Units on Single Sites
The number of reactors at a given site could be limited, at
least in principle, by an ambient environmental radiation standard
applying to all activities in the uranium fuel cycle (^7,48). In order
to examine this possibility, conclusions developed during the AEC's (now
NRC) rulemaJcing on as low "as practicable" (ALAP) reactor effluents, AEC
and NRC dosimetric estimates for real sites in environmental statements,
the results of EPA field studies, operating data for reactors, and some
analyses of hypothetical configurations are each examined in turn below.
First, however, we digress for a brief assessment of the number and
sizes of multiple reactor sites to be expected, based on actual
commitments by utilities during the next decade.
a. Multiple reactor site projections
Originally, nuclear power reactors were constructed as
individual units, each on its own site. As nuclear power became more
attractive economically and technologically, multiple reactors were
ordered for single sit€:s. A recent listing of all reactors in
operation, under construction, or on order (49) reveals'that there are
only five sites for which as many as four reactor units are presently
committed. TVA also has plans for four more reactor units at as yet
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unspecified locations, which may or may not be built on the same site,
but since these units have not even been located yet, it will be at
least eigBt years before they can begin operation. These four-unit
sites are;
Site
Alan R. Barton
Hartsville
North Anna
Shearon Harris
Surry
Commercial Operation
Expected for Last
Location Unit
verbena, Ala.
Hartsville, Term.
Mineral, Va»
Newhill, N.C.
Gravel Neck, Va.
1987
1982
1981
1990
1984
Thus, it is likely to be at least five years before any four-unit site
could be in operation. No sites containing more than four reactor units
are presently committed. Considering the lead time of eight years
necessary (from contract award to commercial operation) for a single
reactor unit, it will apparently be at least a decade before any five-
or six-unit site could become operational.
b. Considerations from the ALAP rulemaking
One of the basic questions considered by the NEC in the
rulemaking for as low "as practicable'* discharges from light-water-
cooled nuclear power reactor effluents was whether the design objectives
of Appendix I to 10 CFR 50 should apply to each reactor or each site.
10**
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The original proposal would have applied the basic dose limits to entire
sites. However, in the words of the Commission (50):
We have chosen to express the design objectives on a
per light-water-cooled nuclear power reactor basis
rather than on a site basis, as was originally
proposed. While nc site limits are being adopted, it
is expected that the dose commitment from multi light-
water-cooled reactor sites should be less than the
product of the number of reactors proposed for a site
and the per-reactor design-objective guides because
there are economies of scale due to the use of common
radwaste systems for multi-reactor sites which are
capable of reducing exposures.
Later, in a more detailed discussion of this question (50), the
Commission expressed the view:
We are also of the opinion that it will be at least
several years before sites containing as many as five
light-water-cooled nuclear power plants are developed.
Consequently, we see no way that design-objective
guides set on a per-reactor basis can, in the near
future, result in individual exposures that are more
than 5% of present-day (10 CFR 20) radiation
standards. Indeed, we believe that, with the required
inclusion of all radwaste augments justified on a
cost-benefit basis and with the realization that
several reactors cannot physically be placed so as to
all be a minimum distance from the maximally exposed
individual, the actual doses received by individuals
will be appreciably less than this small percentage.
Thus, it was the opinion of the Commission that the radiation doses from
multi-reactor sites, containing up to five light-water-cooled nuclear
power reactors, will remain at small percentages of present-day (10 CFR
20) radiation standards, specifically, at less than 25 mrem/yr to the
whole body and 75 mrem/yr to the thyroid.
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c. Results of NEPA reviews
For the last few years, the &EC and NRC have filed
environmental statements under the provisions of the National
Environmental Policy Act; these environmental statements assess the
expected performance characteristics for projected nuclear facilities,
including nuclear power reactors. Table 11 summarizes the results of
these analyses for radioactive releases from all sites projected to
contain three or more reactors. The table shows that:
1. For the eleven such sites analyzed, in only one case is
a whole body dose by any pathway greater than 2 mrem/yr projected. The
exception, 12 mrem/yr to a hypothetical individual consuming 18
kilograms per year of shellfish collected from the reactor discharge
canal, is based upon the assumption that public access to that canal is
permitted.
2. For no site is a maximum dose of more than about 15
mrem/yr to the thyroid of an infant at the nearest farm necessary if
reasonable and readily available control measures are instituted.
It must be emphasized that the estimated doses in Table 11
have been calculated using conservative models. Even though the most
recent environmental statements employ models specified by regulatory
guides which are more realistic than those used in the past, these
models are still conservative. Again, in the opinion of the Kuclear
Regulatory Commission on Appendix I to 10CFR50 (50):
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TABLE 11
ENVIRONMENTAL IMPACTS OF THREE- AND FOUR-UNIT SITES
Site
Four-Unit Sites
Hartsville
Alan R. Barton , ,
WPPSS (Hanford)W
Surry
Shearon Harris
Vogtle
North Anna
Three-Unit Sites
Davis-Besse
Pilgrim
Millstone
Dresden
Indian Pt.
San Onofre
Browns Ferry
Oconee
EIS (Date)^
6/75
4/75
3/75
6/72,5/74
3/74
3/74
4/73
2/75
6/74
2/74
11/73
10/73
3/73
9/72
3/72
Dose Equivalent Rate (mrem/yr) *
Whole Body
Site }
Gaseous Liquid Gamma
<1 <1 <1
<1 1.3 <1
1.2 2.5 <1
<1 2.5 <1
<1 12 (g) <1
<1 <1 <1
<1 1.3 <1
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It must be understood in discussing the matters of
calculational conservatism and realism that Appendix I
means, implicitly, that any facility that conforms to
the numerical and other conditions thereof is
acceptable without further question with respect to
section 50. 3*+a.. .The numerical guidelines are, in this
sense, a conservative set of requirements and are
indeed based upon conservative evaluations.
In any event, the results presented in Table 11 indicate that for all
multi-reactor sites for which environmental assessments are available,
the maximum projected dose is less than 5 mrem to the whole body, even
under the highly unlikely presumption that the maximum whole body doses
for gaseous and liquid effluents add arithmetically. Thyroid doses
would limit the number of such reactors at a given site to no greater
extent than do whole body doses. This conclusion is, of course, in
harmony with that reached by the NRC that sites containing as many as
five light-water-cooled nuclear power reactors would result in
individual exposures that are appreciably less than 25 mrem/yr to the
whole body and 75 mrem/yr to the thyroid.
d. Results from field studies
In addition to the estimates of dosimetric impact made
using "realistically conservative" calculational models, the EPA and its
predecessor organizations have conducted detailed surveillance programs
at selected facilities (33,34,51,52). These studies have confirmed the
accuracy of reported effluents of noble gases and liquids, but appear to
reveal significantly lower iodine concentrations in milk than projected
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by models for the milk pathway currently used for environmental
analysis.
Field studies conducted by the EPA at Dresden (Unit 1),
Yankee Rowe, and Haddam Neck (formerly Connecticut Yankee) have shown
the following maximum individual doses to the various organs listed
(33,51,52):
Maximum Individual Dose (mrem/yr)
Orqan
Whole body
Thyroid
Bone
GI (LLI)
•Dresden
8.0
0.74
0.026
0,008
Yankee
3.0
0.006
0.20
0.26
Haddam Neck
3.8
6.0
3.0
o.n
It should be noted that these values are absolute maximum doses for each
organ; all pathways possibly contributing dose to a particular organ
were summed to arrive at the above totals. These doses thus presume
that an individual could be simultaneously exposed to all pathways of «
exposure and that he would receive the maximum possible dose from each
pathway. Thus, these doses are extremely unlikely to have been received
by any real individuals, as was pointed out by the authors of the
Dresden and Yankee studies (34) :
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...a farmer near Dresden may eat beef, green
vegetables, and drink milk, but he would not also eat
100 gms of fish per day that had been caught at
Starved Rock Dam, neither would he consume Peoria
drinking water, nor does he reside in the areas for
which inhalation and external whole-body exposures
were calculated. Consequently, actual radiation
exposures to existing populations in the vicinity of
both nuclear power plants are less than the total dose
rates listed....
Furthermore, most of the whole body dose listed for the pressurized
water reactors (PWRs), Yankee Rowe and Haddam Neck, result from direct
radiation originating from stored radioactive waste (gaseous and liquid
storage tanks). This exposure may be minimized by simple shielding or
careful placement of these tanks relative to the site boundary.
Virtually all of the thyroid dose and bone dose at Haddam Neck results
from the hypothetical consumption of fish (18 kilograms per year) caught
in the discharge canal. Almost all of the whole body dose listed for
Dresden results from exposure to the gaseous effluent (principally noble
gases) discharged from the stack; boiling water reactors (BWRs) such as
Dresden are presently augmenting (or have already augmented) their noble
gas treatment systems to provide additional dose reduction factors of 8
to 180 beyond those in force at the time the above studies were carried
out (48). The three reactors studied are also of early design.
Reactors going into operation today or in design and construction stages
incorporate considerably more sophisticated radwaste treatment systems
having larger processing capacities, greater cleanup efficiency, and
increased flexibility.
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Doses due to gamma radiation (directed and scattered, or
"shine") originating onsite can be significant at BWR sites because of
the circulation of activation-produced nitrogen-16 through the turbines
and associated equipment, particularly the moisture separators. The EPA
field studies discussed above considered the whole body dose from direct
gamma radiation only for the PWR field studies (Yankee Rowe and Haddam
Neck). Subsequent field measurements made by the EPA, ERDA, NEC, and
others have shown that dose rates on the order of 10 mrem/yr (whole
body) at 500 meters are possible without supplementary shielding of
turbine building components; these dose rates, however, decrease very
«.
rapidly with distance so as to produce very small population doses {53-
56). In addition, dose rates are very dependent upon the design and
layout of the turbine and its associated equipment. Appropriate design
of shielding and location of turbine components relative to the site
boundary can assure that offsite doses from "turbine shine" are
minimized. The siting of many reactor units at a single site should
also result in significantly smaller offsite doses from turbine "shine,"
as the exclusion distance increases with the number of reactor units on
& site. According to a recent study (57), the exclusion distance
averaged 460 meters for single unit BWRs and 860 meters for twin-unit
BWR sites; for PWRs, single units sites averaged 750 meters, while twin-
unit sites averaged 900 meters. Since the dose from turbine "shine"
falls off very rapidly with distance, such doses should be significantly
reduced for multi-reactor sites. For example, using the data from the
most recent study (56), the dose rate falls off by a factor of five as
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the distance increases from 460 meters to 860 meters. Therefore, it is
to be expected that dose rates from turbine "shine" at multi-reactor
sites will not be significant compared to those from the single unit
sites at which field studies have taken place.
Studies of iodine pathways and potential thyroid doses have
been conducted jointly by EPA and AEC over the past two years at the
Dresden, Monticello, Oyster Creek, and Quad Cities sites (3*»). The
available results present a consistent picture of iodine concentrations
in jnilk less than these projected by models for the milk pathway
currently used for environmental analyses.
e« Results from reactor operation
In addition to conservative environmental dose pathway
models, radionuclide source term models have also been conservative.
For example, fuel experience for PWJRs has been much better than the
0,258 fuel leakage rate now used as a design basis for calculating
environmental releases. Westinghouse, which has manufactured the great
majority of operating PWRs, reports that fuel integrity has generally
been in the neighborhood of 99.98% (i.e., a fuel leakage rate of 0,02%)
for zircaloy-clad fuel. Exceptions to this high level of fuel integrity
occurred in 1969-1970, when hydriding lowered fuel integrity to the
99.8-99.9% range, and in 1972, when fuel densification lowered fuel
integrity to the 99.S% range (58). On the other hand, BWRs which have
typically been designed for fuel leakage corresponding to the release of
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10Q,OOO^aGi/sec of noble gases from the air ejector, after a. nominal 30
minute delay, exhibit a, more variable performance. Figure 5 shows that
this design value had yet to be reached by BWRs operating through 1973;
indeed, most were very much below the design value (32). Recent data,
however, indicate a rising trend of releases from BWRs, and EPA is
maintaining a continuing surveillance of this trend, which may indicate
that the present design basis is too low to provide adequate assurance
that Appendix I design objectives will be satisfied in actual operation,
In general, however, fuel integrity at FWRs and for pre-1974 BWR
performance has been considerably better than predicted by conventional
source term models used in environmental analyses.
A second important consideration with respect to
conservatism in source term models is the fact that, especially for
PWRs, effluents are postulated for inplant pathways which require
simultaneous levels of degradation of several parameters in order to
lead to a postulated release to the environment. For example, effluents
from the PWR secondary system (e.g., steam generator blowdown vent or
condenser air-ejector exhaust) require the simultaneous existence of a
"design basis" assumed fuel leakage and a "design basis" assumed steam
generator leakage rate of primary coolant into the secondary coolant.
Since the probability of each "standard" assumption is generally
significantly less than one, the probability of both occurring at the
same time must be smaller than either of the individual probabilities.
Thus, if the annual probability of having the "design basis" number of
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fuel failures is five percent and the probability of having a "design
basis" primary to secondary leak is twenty percent, the probability of
operating a PWR with "design basis" fuel leakage and primary to
secondary leakage is of the order of one percent. In spite of this,
light-water-cooled reactors have been evaluated as if these "design
basis" conditions occur simultaneously, for periods of time comparable
to a year (59) .
f. Analysis of the additivity of doses from multiple
facilities
Similar considerations apply to the assessment of doses
from multiple facilities on a single site. A variety of site specific
factors exist, including the site size, the relative location of
individual facilities on the site, and economies available through.
utilization of design incorporating shared control measures, each of
which mitigate against arithmetic additivity of doses to a maximum
exposed individual outside the site boundary. In general, these effects
are quite significant, as is reflected fcy the low doses projected for
those sites which have been subjected to analysis, as, for example, in
the environmental statements quoted above. Indeed, these sites project
lower doses than many single unit sites. In addition, however, there is
significant operational flexibility available at a multi-unit site not
available to sites containing single or double units. For example, if a
reactor at a four-unit site is experiencing a severe rate of fuel
failure, the output of the site could be maintained at a respectable 75%
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of capacity while that reactor is serviced, by operating the remaining
units at full fuel capacity, a degree of flexibility not available to a
one- or two-unit site without calling upon another portion of the power
grid to take up the loss of capacity.
In addition to the above considerations, which in actual
situations should generally be overriding, it is, however, also
necessary to consider the question, "to what degree are doses from
identical reactors located on a site additive?" It is instructive to
consider the following hypothetical example. Assume that all units on a
site are located at exactly the same point, and that each is designed to
no more than conform exactly, using "design basis" assumptions, to the
design objective dosess specified by Appendix I (say, 5 mrem whole body
dose via the air pathway) to some common hypothetical worst case
receptor. Assume further, since under Appendix I this dose is to be
exceeded only in "temporary11 and "unusual" situations (50) , that one may
assign some reasonable probability that, on an annual basis, the design
objective dose for any single unit will not, in fact, be exceeded. For
example, the 0.25X fuel failure assumption currently used as a design
basis for PWRs is not exceeded, on the basis of current operating
history, at least 95% of the time. What then, is the dose that can be
expected to be not exceeded at the same confidence level (95%) for tt, 5,
or 6 such units? That the answer is not t, 5, or 6 times 5 mrem/yr is
obvious. The exact'result is dependent upon the variance of the
operating data, and, to a much lesser degree, the shape of the
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distribution of the data. A statistical analysis utilizing actual
operating data for PWRs and BWRs yields the following projections (60) :
Dose Levels(mrem/yr| thatwill be Satisfied 95%_o£_ the_Time*
q_Units 5 Units 6 Units
PWR It* 17 20
BWR 15 18 21
*For single units which each satisfy Appendix I at the 95% confidence
level.
Each of these values is significantly lower than that
predicted by an assumption of additivity, even for the extreme case of
colocation of all units, no exercise of operational flexibility, and
design for the maximum release permitted by Appendix 1 considered here.
On the basis of: a) results projected by the AEC and NEC for
all multi-unit sites presently committed, b) the flexibility available
through proper selection and utilization of future sites, c) the
conservative nature of design dose calculations, as opposed to the
applicability of these standards to exposures actually received, d) the
nonadditivity of design basis dose contributions from single units, and
e) the operational flexibility available to sites with multiple units,
it is concluded that the proposed standards can be readily achieved at
all presently planned and all properly designed future multi-unit sites
of up to at least six units. It is further noted that in "unusual"
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<: ircumstances during which the design objectives specified for light-
vater-cooled reactors by Appendix I may be "temporarily" exceeded (50) ,
that the variance provision of the proposed standards would permit
continued operation in times of necessity. Questions associated with
even larger configurations of units, such as nuclear energy centers, are
cddressed separately below.
2. Multiple Sites
Uranium fuel cycle facilities in a particular geographical area
could also consist of a large number of plants (of the same or mixed
types) on multiple sites in the same general area so that the potential
for overlapping doses to members of the general public exists. The
Agency has investigated the likelihood of such overlapping doses from
iraltiple sites (Section V-B) . The potential for the proposed standards
t > be exceeded (or more precisely to require significantly increased
c 3ntrol in order to be met) by overlapping doses from multiple sites was
f aund to be very small because of the very special physical siting
conditions that would have to exist. Such situations are not expected
t3 occur with any significant frequency nor with any significant impact.
3. Nuclear Energy Centers
A somewhat similar question arises in connection with the
p roposed nuclear park concept (61). The Federal Register notice
p reposing these environmental radiation standards for the uranium fuel
cycle pointed out that "...in view of the need to accumulate operating
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experience for the new large individual facilities now under
construction and the intent of the Agency to review these standards at
reasonable intervals in the future, it is considered premature and
unnecessary to predicate the standards on any siting configurations
(e.g., nuclear energy centers) postulated for the next decade and
beyond. The Agency will consider changes in these standards based on
such considerations when they are needed and justified by experience..."
(47). The proposed standard does not itself specify standards for any
specific siting configuration, nor is any siting concept excluded from
its applicability. EPA's commitment is simply to reconsider the
standard when data is available on which to base an evaluation of the
nuclear energy center (NEC) concept.
A number of commenters on the Draft Environmental Statement
addressed the NEC concept in somewhat general terms. They expressed two
types of concerns. The first was expressed by one commenter as follows:
"...however, the proposed limits may discourage plans for energy parks
for the following decades. Since the (sic) energy parks may well offer
reduced overall radiation and health effects to the general public (at
the expense of slightly higher individual exposures) along with possible
cost'savings and safeguards improvements, the long range implications of
the standards on the parks should be explicitly addressed..." (62). The
second concern seen is; "By specifically excluding nuclear parks from
the standards, EPA makes utility planning for the design, purchase and
construction of future nuclear power plants difficult" (63), None of
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the commenters provide any quantitative information to support their
concerns.
Three in-depth studies of nuclear energy centers have been
published. One, titled "Assessment of Energy Parks vs. Dispersed
Electric Power Generating Facilities," and sponsored by the National
Science Foundation (64), did not treat radioactive effluents in enough
detail to indicate whether the proposed standards would or could be met.
That study referenced "'Evaluation of Nuclear Energy Centers" (WASH-1288)
on this matter (65) .
WASH-1288 provides the most complete treatment of NEC's
available prior to the more detailed studies of the Nuclear Energy
Center Site Survey recently completed by NEC, and evaluates two real
sites in enough detail to draw some conclusions. Appendix 1 of
4ASB-1288 provides a discussion of the Hanford reservation in Richland,
Washington as a potential site, which includes an evaluation of
potential radioactive effluents. The results indicate that 25 reactors
and a reprocessing plant could be sited at Hanford with a radiological
.Blpact which should be significantly less than permitted by the proposed
i standards (66).
Appendix 2 of WASH-1288 provides a similar treatment of a site
at River Bend, Louisiana, and also estimates an impact less than that
permitted by the proposed standards (67). It should be noted that
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WASH-1288 was written in 1973, and the authors were concerned with
meeting the then proposed Appendix I. Thus, effluent controls are
assumed in the discussions that will achieve calculated doses in
accordance with proposed Appendix I.
Appendix 5 of WASH-1288, "Radiological Impact of a Nuclear
Center on the Environment" contains a generic treatment of radioactive
effluents by Soldat. Based on Ms evaluation, it appears that the
proposed standards for atmospheric releases would be met if prudent site
selection is made and reasonable levels of effluent control provided.
One potential problem indicated by Soldat that would require
special attention is liquid releases. If radionuclides are released
from a large number of reactors into a single body of water, special
radioactive waste processing systems or operating procedures may be
necessary,'Such as onsite receiving ponds. This would depend on the
specific characteristics of the water body for receiving possibly large
quantities of radionuclides (68)<
WASH-1288 does not answer all of the concerns expressed by
commenters on the proposed standards. The analyses are of a scoping
nature and do not address the advantages and disadvantages of NEC's
versus dispersed siting, nor in any detail the impact of other
considerations (thermal and potential accidents, for example)r which
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we uld certainly be appropriate to any decision on standards specifically
designed for NEC's.
The "Nuclear Energy Center Site Survey" (6) prepared by NEC was
issued in January 1976, The survey treated two radiological aspects of
reactor only Nuclear Energy Centers: 1} the effect of arrangement of
reactors on the offsite dose commitment, and 2) the radiological
erivironmental impact from an hypothetical nuclear energy center (based
or currently used effluent control technology). The results of the
NICSS analysis show that the arrangement does not greatly infuence dose
cc inmitments as long as there is some distance from the nearest reactor
(c r group) to the site boundary. With regard to dose commitments it was
coicluded that the dose commitment from a NEC would essentially meet the
Appendix I objectives for a single reactor. The exception was child
thfroid dose which was calculated to be 112 mrem/yr for the 40 unit
sice. The calculation included the milk pathway (111 mrem) with a
•'fine epos t cow" grazing the entire year. It would be expected that an
actual NEC with 10-20 reactors as recommended by the NRC, and
calculations based on more realistic pathways, would result in a childs
th 'roi<3 dose of less than the 75 mrem proposed by EPA.
For NEC's also containing other fuel cycle facilities, in
various combinations, there are situations where the calculated doses
exceed the EPA standard. However, in those cases either 1) the proposed
standard would not apply (such as Pu recycle), 2) the case is extreme
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(9000 MTHM reprocessing capability on one site), 3) the effluent control
technology assumed is not what would be expected under the EPA standard,
and 4) measures would be available, as is clearly pointed out in the
report, that could significantly reduce the doses. Thus, an examination
of the NECSS does not reveal any significant conflicts between the
proposed standards for the uranium fuel cycle and the feasibility of the
NEC concept. Such a preliminary finding does not, of course, preclude a
later finding, based on a rrore detailed study, that some specific
provisions may be required in the standards for such sites.
The task of completely assessing the potential impact of the
proposed standards on NEC's is beyond the scope of this discussion.
However, some of the unique aspects of NEC's that are involved can be
briefly mentioned.
There are some characteristics of NEC's that will make doses to
members of the pub'lic less than might be expected on the basis of
assessments for conventional sites. The exclusion distance or the
distance to the nearest boundary from such a large group of plants can
be expected to be greater than for smaller numbers of facilities on
conventional sites. A distance of one to one and one half miles may be
typical versus the typical one half or less miles for conventional
sites. The sites for NEC's are likely to be quite large (50-75 square
miles) with the plants dispersed over the site in order to minimize
effects from thermal releases to the atmosphere. NBC sites may also be
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:--'elatively remote. Economies of scale and shared systems may also majce
, iome effluent control systems available that would not be cost-effective
( t conventional sites.
The dose at the; site boundary will not be the multiple of the
i.mnber of reactors times the dose from the nearest reactor to the site
1 oundary. Soldat (69) has calculated that the increase in dose over
that due to the nearest facility (or group) would be a factor of from
two to five. A scoping calculation carried out by EPA for thyroid doses
«:rrives at a factor of three. Of course this would vary depending on
cictual site factors and could increase with the addition of other fuel
cycle facilities, such as fuel reprocessing. However, one would expect
that such other fuel cycle facilities would be placed well away from the
toundary of the large sites required for NECls and not contribute a
disproportionate part of the total dose.
Before definitive conclusions can be drawn, all pathways will
have to be considered on a consistent fcasis; the sensitivity of doses to
a variety of site factors will require evaluation; the effect of adding
fuel cycle facilities must be quantified; quantification of the
E stential population dose reduction and related benefits achieved by
aach sites in relation to any increased maximum individual dose will be
nacessary; and any benefits that could fce achieved through shared
e Efluent control systems will have to be evaluated.
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Based on the information now available, the lack of any other
quantitative input from any source to the contrary, and the expectation
of prudent and sound siting decisions, it appears likely that nuclear
energy centers will meet the proposed standards. However, should
specific proposals for nuclear energy centers be pursued in the future,
EPA will review the entire spectrum of analyses of expected impacts and
benefits provided by future more detailed assessments of proposed
specific sites, and by experience in the immediate future with existing
facilities, in order to arrive at a judgment on the appropriateness of
these environmental radiation standards for nuclear power to such
possible future siting configurations,
4. Reactor Mix
The proposed standard was also examined with respect to the
possibility that it might influence the mix between the use of nuclear
and non-nuclear fuels for the production of electrical power. The ease
with which the proposed standards can te met, both technically and
economically, leads to the ready conclusion that these standards could
not have any such influence.
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VII. ALTERNATIVES TO THE PROPOSED ACTION
In the course of developing these proposed standards, the Agency
has considered a variety of alternative courses of action. These fall
into two broad categories. The first encompasses what may be
characterized as administrative alternatives, and includes modification
o:: existing Federal Radiation Protection Guidance for Federal agencies,
issuance of generally applicable environmental standards for the fuel
cycle as a whole (the recommended course of action) or for specific
classes of activities within the fuel cycle separately, and, finally,
the alternative of no standards. The second category encompasses
different levels of generally applicable environmental standards for the
entire fuel cycle, and includes standards with and without variances for
abnormal situations and at various levels of cost-effectiveness of risk
reduction, including the extreme case of applying best available
technology, without regard to the degree of risk reduction obtained.
E< ch of these alternatives are discussed below, beginning with those
el aracteriz'ed above as administrative.
Existing Federal Badiation Protection Guides for annual radiation
exposure of members of the general public apply independently of the
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source of exposure. These general guides could have been revised
downward, or a portion of the existing guides could have been
apportioned to the nuclear power industry as representing an acceptable
level of health risk for the benefit of receiving electrical power. The
development of such revised or apportioned general guides need not
depend upon a detailed analysis of the capabilities of effluent control
technology, since only a judgment of what level of exposure will result
in either a negligible cr an acceptable level of health effects is
reguired. Such a judgment requires either a) the demonstrated existence
of a threshold for all significant radiation effects (which can be
attained by the industry) , or b) public acceptance of some level of dose
as representing a "negligible" or "acceptable11 risk. However, the
recent MAS-NEC review of somatic and genetic effects of radiation again
rejected use of a -threshold assumption for setting radiation standards,
and there is neither a publicly accepted level of negligible or
acceptable risk, nor any realistic prospect for obtaining agreement on a
value for such a general concept. Finally, when considering the risk to
public health of nuclear power in relation to its benefit, it is clearly
not acceptable to permit a health risk equal to that benefit; what is
required is to maximize the residual benefit by minimizing the
associated risk to health. However, since they cannot reflect the
detailed control capabilities of different kinds of sources, guides
based on health alone cannot minimize annual environmental radiation
exposures; they can only provide a ceiling on the permissible level of
pollution. Also, it is not clear how to modify or apportion existing
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guides so as to prevent environmental buildup of long-lived materials.
TJie Agency concluded that this alternative could not provide adequate
euvironmental protection,
The fuel reprocessing industry represents tiie largest single
potential source of radioactive effluents from the uranium fuel cycle.
The Agency could have proposed effluent standards based on cost-
effective risk reduction for this portion of the industry alone, as a
f; rst step, and issued standards for other components of the fuel cycle
si ibsequently. Such a course would provide for satisfactory protection
o: the environment, especially from long-lived radioactive effluents,
ai d it would involve a much shorter initial analysis than is required to
s< t comprehensive radiation protection standards for the entire fuel
cjcle. However, such standards a) would not be nearly as responsive to
legitimate public concerns about radiation from the industry as are
ccmprehensive standards, and b) could infringe upon the licensing
responsibilities of the NRC for individual facilities. Finally,
adoption of this alternative would represent an inefficient use of
gcvernmental resources. As many as six separate rulemakings eventually
w< uld be required to complete the establishment of comprehensive
standards for the industry. This alternative was not adopted because it
is: inefficient, is in potential conflict with a reasonable division of
El &*s responsibilities for environmental standards-setting and NRC's
regulation of specific facilities, and would not adequately respond to
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public concerns about the environmental implications of planned
radioactive releases from nuclear power.
EPA could also choose to issue no standards and instead exert its
influence to reduce environmental releases by publishing technical
analyses of the environmental impact and control capabilities of the
various components of the fuel cycle. This alternative would require
the least immediate effort and would not result in the possibility of
substantial environmental degradation during the next few years.
However, the need to establish needed precedents for control of
environmental radiation from nuclear power through issuance of formal
Federal standards for protection against environmental degradation by
long-lived radioactive materials would not be exercised, and facilities
now in the design stage would be faced with the need for costly
potential retrofits in later years, of even greater importance, the
Agency would be failing to carry out its basic responsibility under
Reorganization Plan No. 3 to set environmental radiation standards to
insure adequate protection of public health.
In summary, the environmental inadequacies of a revised Federal
guide for individual exposure, the need for definitive EPA standards to
control the environmental implications of the entire nuclear power
industry, and the efficient use of Agency resources argue conclusively
for the administrative alternative adopted. This alternative permits a
balanced consideration of the reduction of deleterious health effects
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which takes into account the costs and capabilities of controls, and
which limits the quantity of long-lived radioactive materials released
by the industry so as to minimize irreversible environmental
contamination. It thus best satisfies all environmental concerns and is
at the same time most responsive to the Nation's energy priorities.
The Agency has, in addition, considered three major quantitative
alternatives to the proposed action. The first alternative incorporates
standards with higher limits on individual dose that would apply to any
operating situation (i.e., not just to normal operations) and utilizes
annual population dose rather than quantity of long-lived radionuclides
per gigawatt-year as the unit of measure for standards to limit the
accumulation of these radionuclides in the environment. It is
substantially the alternative proposed by the AEC in their memorandum to
the President (October 19, 1973) concerning the division of
responsibilities between AEG and EPA (70)» and for which numerical
values were advanced in subsequent discussions between the two agencies.
The second alternative is similar to that proposed, but is somewhat more
restrictive. It represents the lowest levels that can be justified on
the basis of reasonable levels of cost-effectiveness of risk reduction,
and requires the implementation of restrictions on the release of long-
lived radionuclides on a shorter timetable than that proposed. The
final alternative considered is for substantially lower limits on both
individual dose and quantities of long-lived radionuclides in the
envxronment than those proposed by this rulemaking action. These limits
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represent the lowest ambient environmental levels achievable by the fuel
cycle using the most effective technology available for effluent
control, regardless of the associated costs. The types of control
technology required to achieve the levels contemplated by each of these
alternatives are limited to those either currently available and used by
NRC licensees or those in advanced stages of development, in which case
sufficient lead time is provided by the alternative standards for any
further development and safety evaluation required prior to their use by
licensees. Detailed analyses of control costs and the associated levels
of environmental and public health impacts of these various levels of
control are provided in references 7-10 and 71.
Alternative.A: Replace the entire proposed Subpart B by:
a) The annual dose equivalent to a member of the public
from radiation or radioactive materials released to the
environment from the entire uranium fuel cycle shall not
exceed 50 millirems to the whole body, 150 millirems to
the thyroid, and 150 millirems to any other organ; and b)
the total annual population whole tody dose from radiation
or radioactive materials released to the environment from
the entire uranium fuel cycle shall not exceed 1 man-rem
per megawatt of electric capacity.
The first part of this alternative provides considerably higher
upper limits of dose than those provided by the proposed action for
normal operations and, unlike the standards in the proposed action,
these are intended to be interpreted as shutdown values beyond which any
fuel cycle facility causing the standard to be exceeded would be
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required to suspend operations. For this reason no variance is
provided. Justification of this limit must therefore result not from a
determination of what constitutes an acceptable level of normal
operation with respect to environmental impact, but rather from a
determination of an unacceptable level of population risk, or an unsafe
. evel of operation. Such a determination is not possible, in general,
because knowledge of the particular conditions associated with each case
< f potential or actual operation above such a limit is required. Nor is
:i.t clear, with respect to safety, that EPA rather than NEC bears the
]rimary responsibility for such a determination.
The environmental benefit to be derived from establishment of
; tandards at these levels would be negligible, since the potential for
ictual operation of any facilities above such limits is already
^anishingly small. There appears to be no known instance of a reactor
laving ever delivered such doses to any actual individual in the general
environment, even with the relatively unsophisticated levels of effluent
control in effect over a decade ago (72).
With respect to the second part of this alternative, the current
annual population whole body dose to the world's population is
eipproximately 0.13 man-reins per megawatt of electric power produced, or
cipproximately 0.1 man-reins per megawatt of capacity, at present actual
operating levels of U.S. fuel cycle facilities. These values are
cchieved without any limitation on environmental releases of long-lived
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radionuclides, such as krypton-85 or tritium. Thus, a standard of 1
man-rem per MW (e) would have no impact whatsoever on either population
exposures due to short-lived radionuclides or on local or worldwide
environmental buildup of long-lived radionuclides.
If this alternative were modified so as to apply to the
environmental dose commitment, rather than to the annual population
dose, the value proposed would still have absolutely no effect on
releases of long-lived materials, since the environmental dose
commitment per GW (e) of capacity, assuming release of all tritium and
krypton, is currently approximately 0.3 man-rems. (The above
assessments do not include the impact of carbon-14, since the limits
proposed also did not.)
The economic costs associated with this alternative are only
slightly smaller than those for the proposed standard. It is assumed
that Appendix I would still continue to be implemented for control of
normal releases, since the standards for individual exposure apply to
abnormal, not normal, releases under this alternative. Some cost saving
would result from the absence of any requirement to control releases of
long-lived radionuclides; this is estimated to amount to approximately
0.7 million dollars per gigawatt of fuel cycle capacity. An additional
reduction of capital cost of up 0.3 million dollars per gigawatt of fuel
cycle capacity could result under this alternative from failure to
upgrade fuel supply facilities to "as low as practicable" levels of
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control similar to those required at reactors by Appendix I. These
savings would amount to approximately one-tenth" of one percent of the
capital cost of a unit of power supply capacity.
The principal environmental and health impacts of this alternative
would be that environmental burdens of the long-lived radionuclides
krypton-85 and iodine-129 would be increased by one or two orders of
magnitude and an increase of approximately 1000 health effects
(attributable to releases over the next 25 years) over that associated
with the proposed standards due to lack of control of these long-lived
radionuclides would occur. The administrative impact would be decreased
by lack of a requirement to develop controls for these materials, and
increased by failure to provide standards to assist the development of
design and operating guidance and to facilitate the preparation of
environmental statements for facilities in the fuel cycle other than
reactors,
This alternative is environmentally and administratively
unacceptable: it would provide negligible environmental benefit, would
encourage rather than restrict the continued accumulation of
irreversible environmental burdens of long-lived radioactive pollutants,
and would inject the EPA into an area which is the primary
responsibility of the NRO-the determination of the safety of levels of
abnormal operation.
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Alternative B: Modify Subpart B of the proposed rule by making the
following substitutions:
whole body dose 15 mrem/yr
thyroid dose 45 mrem/yr
other organ doses 15 mrem/yr
krypton-85 25,000 curies
iodine-129 5 millicuries
transuranics 0.5 millicuries
The variance provision would remain in its proposed form; the effective
date for implementation of the standards for krypton-85 and iodine-129
would be 1980.
This alternative could be satisfied by all presently proposed sites
for which environmental statements have been submitted, with two
possible exceptions with respect to the control of iodine emissions. It
is also considered quite likely that krypton-85 and iodine-129 control
capability can easily be available by the proposed date. The weakness
of this alternative is that it would not achieve a significantly greater
level of health protection and would at the same time sacrifice
flexibility for dealing with the possibility of an unusual site. The
earlier effective date for krypton-85 and iodine-129 is not expected to
significantly reduce environmental burdens of these materials, since
only one or two fuel reprocessing facilities are scheduled to go into
operation prior to 1983, and it is anticipated that these will install
such systems ahead of schedule for required demonstration and shakedown
runs prior to the effective date of the proposed standards in any case.
-------
It is estimated that this alternative would require approximately
}.6 M$/GW(e) in capital costs beyond those required to meet the proposed
standards, principally due to increased requirements for iodine control
at reactors, and for particulate control at milling operations. No
significant improvement in environmental or health impact is
anticipated. A significant increase in administrative impact is
anticipated, due to the increased difficulty of assuring compliance.
It is concluded that this more restrictive alternative does not
offer any significant advantage over the proposed action.
Alternative c: Modify Subpart B of the proposed rule by making the
Eollowing substitutions:
whole body dose 5 mrem/yr
thyroid dose 15 mrem/yr
ether organ doses 5 mrem/yr
krypton-85 5000 curies
iodine-129 1 millicurie
transuranics 0,1 millicuries
The balance of the proposed rule is not altered, including the variance
provision.
This alternative would require the incursion of substantial
additional costs for minor improvements in the levels of health
protection and of environmental burdens of long-lived radionuclides.
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The reduction in health effects due to short-lived effluents over that
provided by the proposed action would occur primarily at reactors, which
contribute 90 percent of the residual impact under the proposed action
as shown in Table 10; this improvement would be achieved at a cost
approaching one billion dollars per potential health effect removed, a
clearly unreasonable burden upon society.
The use of the most effective technology available at all fuel
cycle facilities is estimated to cost up to 22 million dollars per
gigawatt(electric) of fuel cycle capacity. Dp to an estimated total of
160 health effects could be avoided through the year 2000 by
installation of such controls at reactors due to reduction of short-
lived effluents. The decrease in health impact obtainable through
improvement of controls over long-lived materials is not possible to
estimate,' given the present state of knowledge of performance capability
of controls for these materials, but in any case would be less than that
for short-lived effluents. The improvement in control achieved for
long-lived materials is not easy to estimate since greater uncertainty
is not associated with how iruch control (i.e., how much cost) will be
needed to satisfy the requirements of the proposed action, but with what
level of effectiveness can be achieved by any of a number of control
alternatives o± approximately equivalent cost when these systems are
placed into operation at commerical facilities. This alternative would
impose a large administrative burden on NRC in order to insure
compliance with standards set at such low levels.
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It is concluded that this alternative, which could impose severe
hardships and expense on utilities at some sites while achieving only a
small improvement in public health at great cost, would place
unreasonable burdens on industry, and therefore on society in general,
for insufficient beneficial return.
Table 12 summarizes the differences between these three
alternatives and the proposed standards, particularly with respect to
health effects, control costs, and control of long-lived radioactive
environmental contamination. The table demonstrates that the total
reduction in potential health impact of the proposed standards over
alternative A is achieved at a present worth cost on the order of one
hundred fifty thousand dollars per health effect, while those of
alternatives B and C over the proposed standards each require costs of
several tens of millions of dollars per health effect. Figure 12 is a
reproduction of Figure 3, showing the risk reduction-versus-costs (per
gigawatt of electric power capacity for the fuel cycle) for the various
controls required to satisfy these alternatives to the proposed action.
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TABLE 12
COMPARISON OF THE PROPOSED STANDARDS AND ALTERNATIVE LEVELS OF CONTROL OF ENVIRONMENTAL RELEASES
Action
Alternative "A"
Proposed Standards
Alternative "B"
Alternative "C"
Health Ef fects/GW(e)
4=7
0.92
0.88
0.32
**
Control Cost/GW(e)
6=7 M$
7.6 M$
10.2 M$
22 M$
Long-Lived Radionuclides
Limited (Year)
None
85Kr, 129I, Transuranics
(1983)
85Kr, 129I, Transuranics
(1980) tit
85Kr, 129I, Transuranics
(1983)
Variance
No*
Yes
Yes
Yes
u>
oo
For thirty years operation of typical facilities over the years 1970-2000. See Note t, Table 10.
Present worth, including capital and operating costs for 30 years plant life. See Reference 48.
^Excludes carbon-14 and tritium, which are not addressed by any of these alternatives. These two
isotopes are estimated to contribute a potential 45 additional health effects, as a result of their
100-year environmental dose commitments, per GW(e) of fuel cycle capacity operated for 30 years.
''This alternative is intended as a limit on abnormal emission levels, beyond which shutdown would
occur.
''"^'Earlier introduction of controls over long-lived materials under this alternative could result in
the elimination of up to an additional 25 potential health effects, worldwide, due to the elimin-
ation of the 100-year environmental dose commitment of potential releases from the fuel cycle
during 1980-1982.
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COST OF ELECTRICITY TO CONSUMER IMILIS/KILOWATT HOUR)
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COST OF ELECTRICITY TO CONSUMER (MILLS/KILOWATT HOURS
30.20
FIGURE 12 . RISK REDUCTION VS. COST FOR THE ALTERNATIVES CONSIDERED. THE SYSTEMS
NOT REQUIRED BY THE ALTERNATIVE LIMITS ARE INDICATED BY SYMBOL.
139
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VIII. MAJOR ISSUES RAISED DURING REVIEW OF THE DRAFT STATEMENT
Each of the many issues raised during review of the draft statement
are treated in the detailed response to comments contained in Chapter IX
of this final statement. However, a few major areas were addressed by a
large number of commenters from a variety of aspects, and are deserving
of a more unified treatment than is possible in a detailed comment-by-
comment response. This chapter of the statement provides such treatment
of issues related to iir.plewentaticn of the standards, the costs of
krypton control, and the assessment of the potential health impact of
radiation doses at levels anticipated beyond the boundaries of nuclear
facilities.
A. IMPLEMENTATION OF AND VERIFICATION OF COMPLIANCE WITH THE PROPOSED
STANDARDS
A number of commenters expressed concern over issues associated
with implementation of the proposed standards (see Chapter IX).
Industry representatives expressed the following concerns and
recommendations:
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1. The UFC Standards, if promulgated by EPA without prior
development of detailed procedures for implementation, could have a
major disruptive influence on licensing and operation of fuel cycle
facilities.
2. Measurement of doses to individuals in the environment at the
level of the standards is not practical.
3. An assessment of the cost-effectiveness of the standards cannot
be made without guidance on implementation.
4. An interpretation that the variance provision apply only to
emergency power situations would result in excessive costs to the public
for a negligible return in public health protection.
Recommendations made included the following:
1. Regulatory Guides for implementation should be issued for
public review and comment prior to promulgation of the standards. These
should include guidance on environmental models, compliance procedures,
multiple facilities, and specification of parameters for realistic
assessment of doses to individuals.
2. The standards should formally incorporate Appendix I to 10CFR50
as implementation for up to 5 reactors on a site.
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These concerns of industry were reinforced by NRC comments, which
included;
1. Substantial modifications of the NRC regulatory system would be
required; and, in addition, 120 licensing actions would have to be
reexamined.
2. Federal Radiation Guidance would require monitoring at 10
percent of the limits set by the standards, and, further, present
techniques for environmental monitoring at such levels are inadequate.
3. Costs for compliance would be excessive, particularly since NRC
presently has no capability of its own for environmental measurements.
1. The standards would require frequent shutdowns, and use of the
variance would not be justified under most situations.
The NRC made no recommendations for implementation.
Environmental groups and the general public expressed concern that
the KRC would te lax in its enforcement of the standards, and
recommended that EPA carefully specify and monitor implementation of the
standard in considerable detail.
The Agency has carefully considered all of the above matters in
developing these proposed standards and is confident, after this
examination, that these concerns are not warranted. Detailed responses
to these specific concerns are provided in Chapter IX, we describe
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below some general guidelines concerning implementation. However, it
remains the Agency's position that detailed implementation is the
function of the NRC (within broad guidelines established by EPA
regarding the intended application of the standards). This division of
responsibility was expressly set forth by the President's message
transmitting Reorganization Plan No. 3 of 1970. As the result of NRC
and industry comment on the original proposal issued May 29, 1975, it
became obvious that more detailed guidance was required than the general
statement of position contained in the original proposal. Supplementary
information issued January 5, 1976, for use at the public hearings held
March 8-10, 1976, contained such an expanded exposition of the Agency1s
view of appropriate implementation. That exposition contined several
major points;
1. Existing NRC models for environmental pathways are, in general,
satisfactory to EPA for use in demonstrating routine compliance through
the monitoring of effluents.
2. Environmental monitoring should be used to supplement such
effluent monitoring in cases of suspected noncompliance.
,3. Conformance with Appendix I design objectives was ordinarily
sufficient basis for a presumption that any reactor site containing up
to 5 units would be able to conform to the standards when in actual
operation.
4. In special cases (as at mill tailings) where both environmental
and effluent measurements are difficult, compliance should be
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demonstrated through the use of operational measures - specifically,
stabilization to prevent wind erosion of tailings.
5. Quantity limitations (40CIR190.10(b)} should be implemented
through a system of apportionment among the various operations of the
fuel cycle, and assignment of required facility effluent stream
decontamination factors where appropriate.
6. Use of the variance should be predicated upon a demonstrable
public need for power.
In view of the continued expression of concern over implementation
issues during the public hearings outlined above, the Agency constituted
a task force of experts from its environmental monitoring laboratories,
which have been long active in assessments of environmental radiation
resulting from releases from fuel cycle facilities, to independently
reexamine the feasibility of implementation of the proposed standards.
The Agency maintains laboratories in Montgomery, Alabama; Las Vegas,
Nevada; and in Cincinnati, Ohio, that each have unique capabilities for
monitoring of environmental radioactivity. The conclusions of the task
force are summarized below, and in general are consistent with the
Agency's previously expressed views on these subjects. In areas where
there are differences between task force recommendations and previous
Agency policy, these are noted in the discussion below. It should be
recognized that these conclusions are intended in the sense of guidance
and should not be interpreted as literal dictates of the regulations
required to implement these standards. Those regulations will be
144
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developed by the NEC, and should be worked out through detailed
interaction with the affected components of industry, with timely
c ansultation by NEC with EPA as to the appropriateness of any proposed
implementing regulations, particularly in the event that difficulties
d avelop.
A similar situation obtains with respect to verification of
c jmpliance. Enforcement authorities reside in NRC, not EPA. EPA
expects that the NRC will adequately assure compliance, and EPA's own
"compliance" activities will consist principally of the review of the
performance, as reported by NRC, of fuel cycle facilities and of any
variances permitted by NRC, As required, EPA will provide NRC with
g lidance on the adequacy of its compliance and variance posture with
raspect to these environmental standards.
1. Recommendations for Operational Application of the Standards
a. Limits on doses to individuals: Compliance with the dose
limits of the standards should be monitored by measuring the quantities
o c radionuclides discharged in aqueous and gaseous effluents and
relating these discharges to the dose commitment rates from all
s ignificant pathways to limiting receptors by utilizing methods similar
t> the Nuclear Regulatory Commission's environmental dose models. The
d »se commitment rates calculated in this manner should be verified by
comparison with those determined through the routine radiological
surveillance program.
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The task force concluded that NRC models for environmental
pathways, as exemplified by Regulatory Guides 1,109 and 1.111, are quite
adequate for compliance assessment, although it is recommended that
these models be supplemented with site-specific parameters to the
maximum feasible extent. Similarly, the task force found that the
environmental monitoring programs exemplified by NRC Regulatory Guide
4.8 specify an essentially adequate program regarding both number, type,
and locations of monitoring points, and instrumental sensitivities.
Finally, the task force recommended the institution of quality assurance
programs for both effluent and field monitoring programs.
Ccnforinance to the standards should thus be measured using
the most reasonable and, as required, realistic means available. Thus,
in the case of dose to the thyroid, measurement of the radioiodine
content of milk at the nearest farm, coupled with a determination of the
milk consumption habits of the residents, would constitute a reasonable
basis for a final determination of noncompliance. Conversely,
calculations based on observed releases and meteorology should generally
provide the basis for a routine finding of compliance. Sites failing
this test would merit progressively more detailed study, leading finally
to the above-described (or a comparable} determination of noncompliance
(or compliance).
In the case of potential doses to the whole-body and other
organs a similar sequence of compliance verification methods is
146
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available. The Agency telieves that it may be presumed that existing
models for calculation of exposure fields due to gaseous and liquid
releases, using measured data on quantities released, local meteorology,
and stream-flow characteristics, are adequately conservative to serve as
the basis for verification of compliance with these standards. If
reason exists to believe, based on use of such source term measurements
and models, that noncompliance may exist at a particular site, than more
detailed field measurements may be employed to verify or disprove the
existence of such a situation (or, of course, the facility could reduce
its emissions to achieve model-based compliance).
In a very few special situations when two or more sites are
in close proximity, it may be necessary for the regulatory agency to
make allowance for contributions from several sites in order to assure
compliance with the standards at locations intermediate between such
sites. For sites as close as a few miles from each other overlapping
contributions of as much as 10 to 20* may be possible. The NRC should
make the necessary adjustments in the individual technical
specifications of facilities at such sites to provide reasonable
assurance of compliance. However, in the vast majority of situations
the sum of all reasonably possible contributions from all sources other
than the immediately adjacent site will be small compared to these
standards, and should be ignored in assessing compliance. It would not
be reasonable to attempt to incorporate into compliance assessment doses
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which are small fractions of the uncertainties associated with
determination of doses from the prxmary source of exposure.
A potential difficulty exists regarding implementation of
the standards at will sites. Gamma surveys in the vicinity of some
existing mill tailings piles show values ranging up to several hundred
mrem/yr in situations where it is logical to assume that these elevated
gamma radiation levels are the result of windblown tailings. Although
the measurement of 25 mrem/yr increments in such dose rates is possible,
rigorous measurement techniques would be required to identify locations
where new depositions of windblown particulates elevate pre-existing
local levels by 25 rnrem/yr. Furthermore, because of the projected 20-
year operational lifetime of a typical mill and the assumed additive
impact of new depositions, 1/20 of 25 mrem/yr, or approximately one
mrem/yr, would have to be measured if the standard were to be
implemented by a regulation based on verification on an annual,
incremental basis. This would be unreasonable, since one mrem/yr is
small compared to uncertainties in natural gamma-ray background levels.
A recent engineering survey report developed for the
Nuclear Regulatory commission (ORNL-TM-4903, Volume 1) (73) provides an
estimation of the relative ratio of the respirable particles (<10jum) to
larger particles (10-80um) blown off the tailings beach of a well-
managed tailings impoundment system. This ratio averages about one and
varies from 0.4 to 1.4 depending on specifics of the milling process and
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o :her variables. It can be estimated, therefore, that one millicurie/yr
o: insoluble 0-10/im particles removed from a typical pile by wind could
d sliver a dose equivalent of approximately one mrem/yr to the lungs of a
person living one kilometer downwind of the pile. At the same time, one
m Lllicurie/yr of 10-80yant particles might be deposited in a ring one-half
tj one and one-half kilometers from a pile, yielding a surface
contamination level of about 0.2 nCi/m2. Ihis would result in a gamma-
r iy exposure level of about lOjam rem/yr. After 20 years of operations,
e ich contributing to surface contamination at such a rate, this exposure
might increase to as much as approximately 0.2 mrem/yr.
Accordingly, the critical exposure pathway for windblown
tailings is most likely to be to the lungs through the direct inhalation
ot radioactive tailings, and if this source of exposure is controlled
direct whole-body gamma exposure from windblown tailings will also be
controlled to a considerably greater degree.
It does not appear at this time to be practical to measure
tie annual release of radionuclides from operational tailings piles to
tie air pathway. However, it is practical and reasonable to reduce
t riese releases to very small values (<1 mCi/yr} by application of
control measures that will insure that iraximum doses to individuals in
tiie vicinity of tailings piles are well within the standards. These
treasures include covering of exposed tailings, keeping tailings under
water, and spraying any tailings "beaches" that develop with chemical
149
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binders to prevent blowing. In practical terms, the standards should be
implemented with regard to operational tailings piles by requiring
proper and reasonable dust control measures and by permanent
stabilization following termination of active milling operations.
It should be noted that the standards apply only to annual
doses delivered as the result of discharges of radioactive materials
beginning after the* effective date. They do not apply to doses
resulting from discharges before this date. Decontamination of areas
contaminated by windblown tailings from and management of tailings piles
on previously abandoned mill sites are not covered by and are therefore
not required by this standard.
The task force recommended that doses due to transportation
activities associated with the fuel cycle be deleted, due to the
difficulty of assuring compliance and the low doses anticipated in any
case. The Agency has this recommendation under study. At a fuel
reprocessing or a multi-unit reactor site the number of shipments of
radioactive materials per year in and out of the site could reach
several thousand. However, even for this large of number of shipments,
doses to nearby individuals under present Department of Transportation
regulations would not reach one miem/yr, if they are located, on the
average, more than a few tens of meters from the shipping route, and if
the vehicles involved remain in motion while in the vicinity of the
site. Implementation of the standard for transportation would not
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require, therefore, modification of existing packaging and shielding
requirements. It probably would be necessary, however, to require
guaranteed non-stop shipments (a service which is presently obtainable
from the transportation industry) to avoid buildup of doses to by
standards at habitual stopping places, or to provide restricted access
areas for layovers, and to make some sort of allocation of the dose
limits for application near operating facilities. It should be noted
that the standards would not apply to transportation personnel while
they are engaged in handling shipments; such exposure is considered to
fall in the category of occupational exposure.
b. Limits on quantities of specific radionuclides released;
V
Compliance with the limits on quantities released to the general
snvironment should be monitored by: 1) the establishment by the
regulatory agency of the quantities of specific radionuclides covered by
the part that may be released to the general environment by each
operation of the fuel cycle, based upon a determination of the most
sconomical places in the fuel cycle where effluent reduction may be
obtained to satisfy the standards, and 2) licensee monitoring, using
affluent and inplant measurements, of the radionuclides discharged and
;he decontamination factors achieved at those operations where effluent
iiontrol measures are required to satisfy the standards.
The task force also recommended that effluent control
Measures should not be required of any fuel cycle operation other than
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fuel reprocessing, for the radionuclides specified. Implementation of
the miclide-specific limits on releases of long-lived materials thus
requires a determination by the NRC of the operating decontamination
factors that must be achieved at locations that are the principle
potential sources of environmental releases of these materials. In
order to make such a determination it would be necessary to characterize
before 1983, except in the case of transuranics, the maximum average
values of environmental releases of these materials from minor classes
of sources to be permitted essentially unrestricted release (e.g.,
krypton-85, iodine-129, and transuranic releases from power reactors or
fuel fabrication facilities). Following this, compliance would consist
of _verification that the appropriate decontamination factors are being
realized through inplant measurements at the principle potential sources
regularly reported on a routine basis.
Monitoring of the DF's achieved by inplant control systems
for the three types of radionuclides specifically limited by the
standards appears to be readily achievable using conventional monitoring
techniques and analytical procedures, and such measurements appear to be
provided for at the one facility approaching operational status. Flow-
through ionization chambers are capable of measurements of krypton-85 at
coneentratons of less than 1 pci/cm , a concentration 1000 times lower
than that corresponding to the standard for a typical stack effluent
volume. Similarly, x-ray spectrometry is capable of sensitivities of
the order of 1 pci for iodine-129; at 10% of the proposed limit a
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charcoal sample of stack effluent would accumulate, for a 10 minute
sample of 0.2% of the stream, 1000 pCi. Finally, gas-flow proportional
counters, using 24-hour filter samples (collected on 0.1/6 of the gas
stream} would exhibit detection limits at least 1000 times smaller than
a ctivxties corresponding to the standard. Periodic confirmation of the
isotopic distribution of transuranics would also be necessary.
It should not be necessary to routinely monitor minor
rsleases of these materials from minor classes of sources, once these
have been properly characterized as such, unless normal monitoring of
g sneral releases discloses that an unusual situation exists which
indicates that normal "de minimus" releases of these materials may be
bsing exceeded. Such an occurrence would, presumably, not constitute a
";iormal" release and investigation and correction would be warranted in
a:iy case.
c. The variance provision: Continued noncompliant operation
b ' any licensee should not be permitted for significant periods of time
in the absence of a variance. Remedial measures for such noncompliance
could include such measures as requirements for corrective or
aneliorative measures which will bring the operation into prompt
compliance, the assessment of fines, and, ultimately, revocation of the
license to operate. In cases where the public interest is served by;
a; the need for orderly delivery of power, or b) an acceptable schedule
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for the timely achievement of compliance capability, a variance may be
issued.
The task force also recommended that, in cases of minor
noncompliance, a proposed compliance plan which would achieve compliance
for the average performance over a three-year period should be
automatically considered as serving the public interest, and be an
acceptable basis for a variance. They further recommended that
variances not be predicated solely on a demonstrated need for the
orderly delivery of power. A number of commenters pointed out that such
a restriction would not be reasonable. For example, a facility may have
installed a control system which, in spite of good faith performance on
the part of the supplier and the user,, may fail to achieve operational
capability on a timely basis, or, once installed may experience
operational failure at some time, yet operation of the facility may not
be essential to "the orderly delivery of electrical power.11 The Agency
agrees that, although in no case should operation continue if the safety
of the operation is compromised, it may easily be the case that only
small excursions above these standards would occur in such cases, so
that the added risk to the general public would be small in comparison
to the economic penalty that would be associated with such operation.
For example, it has been estimated that the incremental daily cost of
power to replace that supplied by a 1 GW(e) power reactor is on the
order of 400 thousand dollars (96) . The Agency is considering
broadening the variance provision in line with the above
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recommendations, so that the regulatory agency may, if it deems it to be
in the overall societal interest, grant a variance on the basis of an
ipproved plan to achieve compliance in a timely fashion, that is, in the
rdnimum time reasonably achievable given the circumstances of each
.specific case.
It is not anticipated that utilization of the variance
provision based upon a need to insure the orderly delivery of power is
.ikely to be either required or appropriate for any facility other than
a power reactor in the near future. That is not to say that it would be
inappropriate to use that variance provision if circumstances warranted,
hut that such circumstances appear unlikely. On the other hand, it is
cuite possible that a power emergency, either local, regional, or
rational, could occur, and that continued production of power by a
3 eactor experiencing higher than normal releases would be in the public
.interest.
In proposing these standards the Agency purposely did not
specify detailed procedures to be followed to obtain a variance, since
these should be developed by the NEC with opportunity provided for the
views of the interested public and the industry to be heard. The Agency
cloes, however, have some general views on the implementation of this
I revision.
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First., the use of the variance should be predicated upon a
demonstrable public need for power, or upon demonstration by a licensee
that a real need exists and compliance will be achieved on a schedule
approved as timely and in the public interest by the regulatory agency.
Second, the granting of a variance should be publicly announced and
include an assessment of the extent of the excess exposure and releases
anticipated, the anticipated schedule for achieving compliance, the
reason for the excess release, and the reason for granting the variance.
Finally, after the variance has terminated, a final assessment of each
of the above factors should be issued promptly.
In general it is anticipated, based upon past experience,
that when a facility is approaching a condition in which excessive
releases are possible that normal monitoring and reporting of facility
releases will provide more than adequate forewarning so as to permit
timely consideration of the need for a variance. However, in order to
provide for quick response in the case of a sudden power emergency, it
may be desirable for the regulatory agency to establish some basic
criteria for semi-automatic invocation of a temporary variance under
such circumstances. Such criteria would have to be limited, at a
minimum, by considerations such as conformance with NRC's safety
requirements and Federal Radiation Protection Guides on occupational
exposure, limitations which are not affected by these standards.
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2. Operational vs. Pre-Operational Application of the Standards
An important consideration relative to these standards is the
i
IRC's continuing development of guidance for design of facility effluent
systems and for development of operating technical specifications,
codified in 10CFR50, which implements the Federal Radiation Guidance
that exposures of the public be maintained as far below the Federal
Fadiation Guides "as practicable" (25 FR 4402). The Commission has
eIready issued such guidance for single unit light-water-cooled power
reactors and has had underway development of similar guidance for fuel
reprocessing, milling, and fuel fabrication facilities, although
iscently doubt as to the likelihood that issuance of such guidance will
te considered in the near future has been expressed by the NRC (95).
The guidance issued thus far for single unit light-water-cooled reactors
appears to provide adequate assurance of compliance with these standards
during actual cperations (unless the NRC finds that extreme extenuating
circumstances exist for a specific site) for sites containing up to at
1 sast five such power reactors. (See Section VI-F-1.) Additional
g aidance may be required in the future, as noted by the Commission in
its opinion filed with 1QCFR50, Appendix I, for sites containing larger
nambers of facilities (50).
These standards «ill supercede, for the nuclear power industry,
tle Federal Radiation Guides codified in 10CFR20 as limiting doses to
members of the public at unrestricted locations. Just as the
development of the guidance expressed by Appendix I to 10CFR50 took
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plac€ within the limitations specified by those guides, the development
of future 10CFR50 design and operating guidance will now take place
within the limits specified by these standards. However, it is not
anticipated that the disparity between standards and this guidance will,
in general (but not always), be nearly so great as formerly. For
example, at fuel reprocessing sites, all or most of the thyroid
individual dose standard could be taken up by any new 10CFR50 guidance
(whereas zero dose may be postulated through liquid pathways due to the
absence of any liquid discharges). It is thus not the intent of the
Agency that the standards for dose be "apportioned" to various
operations of the fuel cycle. They apply equally and in full to doses
from any operation or combination of operations in the cycle, and it is
not anticipated that significant contributions to doses to any
individual froir. multiple sites will be common. In the few instances
where overlap of significance could occur, this should be dealt with on
a site-specific basis -- not generically through apportionment.
It is particularly important to recognize that the standards
apply only to doses received by individuals and quantities of
radioactive materials released to the environment from operating
facilities. This situation is in contrast to design guidance set forth,
for example, by Appendix I to 10CFR50 for light-water-cooled power
reactors, which applies to pre-operational considerations, such as
licensing for construction of nuclear facilities. While such guidance
is useful for providing the basis for concluding that such facilities
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cin be expected to conform to standards which apply to actual
operations, it is not a substitute for such standards. Both the task
f>rce and industry expressed considerable concern over the possibility
tiat unnecessarily conservative assumptions at the design stage could
1 sad to i implementation that would require greater expenditures for
control systems than those intended by EPA in establishing these
standards. The Agency agrees that such conservatism is not warranted or
ii tended. it is perhaps natural that such a tendency should have
evolved, given previous radiation standards which were more than ten
t:lirtes higher than levels routinely achieved by effluent controls.
Htwever, the proposed steindards are based on a far more realistic
assessment of control capabilities, costs, and benefits, and require an
ecually realistic implementation.
consideration of the adequacy of control measures at facilities
during pre-operational stages with respect to these standards should be
limited to a finding, either for specific sites, or on a generic basis,
as appropriate, that the facility has provided or has available to it
adequate means to provide reasonable assurance that these standards can
be satisfied during actual operations. Such means may include the
provision of cleanup controls on discharge streams, the ability to
modify in the future, if necessary, its mode of operation to mitigate
en/ironinental discharges, or methods which interrupt exposure pathways
in the environment. In calculating potential doses to members of the
pu xlic it is important that realistic models be used, and that
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unnecessary conservancies common in the past when environmental
standards were a factor of twenty or more times higher not be used in
assessing the capability of a proposed site to show a reasonable
probability of being able to operate in conformance with these
standards. Thus, in assessing designs involving multiple units on a
single site, realistic consideration should be made of the site size,
the locations of individual units relative to limiting receptors, the
degree of overlap of independent pathways for limiting receptors, and
the stochastic nature of effluent releases from the various units on the
site. The important point is that the standards specify maximum doses
to real individuals and maximum quantities of certain materials actually
delivered or discharged to the environment, not the specific design
parameters of individual facilities. Thus, for example,, it is the
Agency's view that conformance to Appendix I by a planned reactor on a
site containing up to five such facilities (unless extremely unusual
combinations of liquid and air pathways of exposure are actually present
and are expected to be simultaneously intercepted by real individuals)
should generally constitute de facto demonstration to the NRC that a
reasonable expectation exists that these standards can be satisfied in
actual operation. The Agency will, in the course of its continuing
review of environmental statements, identify any situations for which it
believes that such an expectation has not been adequately justified, A
more detailed exposition of some areas meriting in-depth discussion of
the Agency's view of an adequate demonstration of reasonable expectation
of compliance, such as for adjacent sites, minor releases of
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specifically limited radionuclides from fuel cycle facilities, doses
from windblown material originating from mill sites, and transportation-
related doses, has been provided above.
3. Implementing Regulations
A number of regulations or regulatory actions are affected by
these standards, as the above discussion of implementation indicates,
These include:
a. 10CFR20 - Modify, to reflect where 40CFR190 supercedes for
normal releases from uranium fuel cycle operations.
b. 10CFR50, Appendix I - Modify to indicate that additional
requirements may fee required for sites containing more than five light-
«?ater-cooled reactors, or, if the NEC so determines, in other special
;ases. • •
c. Review license conditions for fuel cycle facilities, other
chan light-water-cooled reactors conforming to Appendix I, for
oonformance to 40CFR190.
d. Determine whether any sites exist which are close enough to
other, sites to receive substantial contributions to dose from such
sites, and make any necessary modifications of technical specifications
;vn such cases (the Point Beach and Kewaunee sites appear to be the only
such potential case presently in existence).
e. Determine the apportionment to be made for unrestricted
release (relative to 40CFR190) of krypton-85, iodine-129, and alpha-
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emitting transuranics of half-life greater than one year at fuel cycle
facilities not major sources of emissions of these nuclides, and
determine the decontamination factors required at major sources,
f. Establish criteria, as required, for granting of variances
when this is in the public interest, including reporting requirements
for any plan to achieve compliance in a timely manner.
g. Recommend, where necessary, additional requirements on
transportation of nuclear wastes and spent fuel to prevent layovers in
areas to which public access is possible.
Several regulatory activities already required by existing NEC
regulations or underway are also relevant to implementation of these
standards. These include:
h. Continuing development of regulatory guidance for fuel
cycle activities other than light-water-cooled reactors.
i. Definition of regulatory models for doses to individuals
near fuel cycle operations.
j. Definition of "temporary and unusual operating conditions"
for implementation of limiting conditions for operation under Appendix I
to 10CFR50.
The most significant efforts required, of these that are not
already required or committed, are items c., e., f., and g,. These
concern directly the implementation of the standards, the balance are
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5ither minor codifications of the standards into existing regulations,
>r represent reflection of the existance of these standards into
existing ongoing efforts,
4. EPA Verification of Compliance
The Agency will assess compliance with these standards through
its review of NSC implementing regulations, operating data supplied to
;he NEC by licensees, and any variances issued by NEC. Supporting
tctivities will include the Agency's continuing review of draft and
:inal environmental statements for all fuel cycle facilities, field
iitudies at selected fuel cycle facilities, and assistance to the NRC,
when necessary, through field measurements in cases of possible
i loncompl i an ce.
Onder general NEPA and FRC authorities, the Agency routinely
reviews and comments on all NRC regulations, including 10CFR50 guidance
and regulatory guides, pertaining to environmental releases and
i exposures of the public due to nuclear fuel cycle operations. In the
ruture, this review will also include consideration of the
;; implementation of these standards. This review will encompass, among
others, the appropriateness of design basis assumptions, environmental
transport models, dose conversion assumptions, environmental monitoring
and reporting requirements, and, finally, operating compliance
requirements. The Agency will not, however, routinely review technical
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specifications or other license requirements pertaining to individual
licensees.
The Agency also maintains a continuing review of the state of
the environment with respect to contamination by radionuclides and doses
to the public,' including contributions from fuel cycle sources.
Beginning this year, the results of this review will be published
annually. This report will depend, for fuel cycle sources, primarily
upon data collected by the NRC, The Agency has requested that the NRC
supply this information in sufficient detail to permit reasonably
detailed annual assessments of the exposures of members of the public
and releases to the environment at fuel cycle facilities.
EPA1s review of draft and final impact statements for
individual fuel cycle facilities will serve to allow EPA to identify to
NRC situations in which it believes the capability ot the operation to
assure future compliance, when the facility is completed, may be
questionable. However, such findings will remain advisory, as in the
past, since responsibility for compliance with these standards during
actual operations rests with the facility and the NRC.
EPA has for some years conducted special field studies in order
to characterize the environmental releases, transport, and impact of
radionuclides from fuel cycle facilities. These have included detailed
general studies at pressurized and boiling water reactors, a fuel
-------
reprocessing facility, and at mill tailings piles. In addition,
specialized studies of iodine pathways and of nitrogen-16 radiation at
reactors have recently been carried out. These studies will continue in
the future. They are of invaluable assistance in providing soundly
based knowledge for assessing the behavior of environmental releases of
radioactive materials, and in judging the adequacy of environmental
models used for assessing both general environmental impact and detailed
compliance by individual facilities. The measurement capabilities
developed for these studies may also prove useful and will be available
for situations in which the NRC needs assistance in field verification
of compliance.
5. Timing of Implementation of the Standards
It is proposed that these standards become effective two years
from the date of promulgation, with the exception of those for krypton-
85 and iodine-129, which are proposed to become effective in 1983.
All existing reactors are now or will shortly be in compliance.
In any case, it is considered reasonable to expect that any reactor
facilities not now in compliance with Appendix I will be by the fall of
1978, over three years after its issuance and the earliest possible
implementation date for these standards. The question of timing of
implementation of the standards is not significant, therefore, as it
applies to reactors.
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Only one fuel reprocessing facility is now likely to become
operable by 1978, and, on the basis of its environmental statement and
EPA's assessment of its projected control capabilities, this facility
should be able to achieve compliance with the standards at that time.
Future compliance with requirements for krypton and iodine releases will
depend on the installation of additional controls by 1983. In this
regard, it should be noted that the effective date of 1983 for this
portion of the standard applies to any nuclides produced after that
date, and not to nuclides produced in fuel irradiated prior to 1983.
Implementation of these standards at milling facilities will in
many cases require the installation of updated dust collection
equipment, and institution of dust control methods at tailings piles.
This equipment is commonly available in commerce. The standards do not
apply retroactively to offsite windblown tailings, nor to tailings piles
at sites no longer licensed.
B. CONTROL OF KEYPTON-85
The proposed standard limits discharges of krypton-85 from
operations in the uranium fuel cycle to 50,000 Ci/GW (e)-yr of power
produced. This proposal was based on a variety of considerations which
were discussed in the draft statement. Comments questioning this
proposed action were received in the following major areas: 1)
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gnvironmental and health effects models, 2) the availability, cost, and
affectiveness of technology, 3) waste storage, and 4) international
considerations.
1. Environmental and Health Effects Models
The major question raised concerning the environmental model
ised was the appropriateness of calculating doses to the world
population instead of to the population within 50 miles of the facility
ar within the borders of the U.S, If population doses are calculated
Eor these more limited areas, the projected health effects committed
«?ould, of course, be smaller and the benefit of the proposed standard
tfould be less. It is well known, however, that krypton, a noble gas,
distributes rapidly throughout the world's atmosphere and persists in a
liluted but uniform concentration for several decades. The Agency
believes that the only appropriate basis for evaluating the
environmental impact of the release of krypton-85 to the environment is
to consider the total population exposed. Since there is ho feasible
nechanism available to confine krypton-85 releases to areas where they
sxpose only either local populations or U.S. citizens, the only
realistic evaluation of the impact of a decision to permit discharge of
icrypton-85 is to calculate exposure of the world population.
Estimation of potential health effects from krypton-85 based on
ioses to the world population was based on the assumption of a linear
aonthreshold relationship between dose and effects. Several commenters
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questioned the appropriateness of basing the krypton-85 health effects
estimates on the sum of a large number of very low doses delivered at
low dose rates. This question apparently is suggestive that these
doses, by being small, are inconsequential and ought not to be included
in such estimates. Such a suggestion requires the assumption that a
threshold exists for radiation effects that lies somewhat above 100
mrem/yr, the average value of background radiation doses to which
exposure to krypton is added. The Agency knows of no basis .for making
such an assumption. Therefore, it has been constrained, in the absence
of scientific information to the contrary, to base its estimates of the
potential health impact of krypton- 85 exposures on the linear
nonthreshold model (see Section viu-c below) .
2. Krypton-85 Control Technology
On the basis of questions on the costs, availability, and
effectiveness of technology to control krypton-85 control at fuel
reprocessing facilities and new information presented at public hearings
on these proposed standards, the Agency has reexamined available
information on the practicability of providing such control in order to
reasonably implement the limit proposed for the uranium fuel cycle.
These considerations, which are summarized here, are discussed in more
detail in a technical supplement (Part IV} prepared for the
Environmental Analysis cf the Uranium Fuel Cycle (10) .
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Three new sources of information or equipment design and costs
have become available since the time of the original consideration of
these proposed standards. First, the public hearings on the proposed
Barnwell Nuclear Fuel Plant (BNFP) during the fall of 1975 developed
extensive information on system design and costs, some of which has been
further updated in comments to the Agency on the proposed standard.
Second, the Exxon Nuclear Corporation has developed a design for a 2100-
ton per year plant (initial start-up to be 1500 ton per year) which
includes a conceptual design for controlling krypton-85 in the dissolver
offgas. Third, a. system to control krypton-85 has been ordered for the
Tokai-Mura fuel plant, a 215 ton per year plant currently in advanced
stages of construction in Japan. The system is being provided by a U.S.
company (the Air Reduction Corporation) and indications are that the
system will be installed and undergoing cold testing by early 1977.
The Agency has discussed the technology and economics of
krypton control with equipment vendors, visited all national
laboratories where krypton control is being developed or applied, and
has discussed detailed aspects of krypton control with experts
knowledgeable in the techniques of fuel reprocessing. From this study,
it has become clear that the cryogenic distillation approach to krypton
control is much closer to application than the flurocarbon absorption
system. The system ordered for the Tokai-Mura fuel plant utilizes
cryogenic distillation to separate krypton-85. The fluorocarbon
absorption process is still undergoing development at the Oak Ridge
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Gaseous Diffusion Plant and will not be ready for testing with
radioactive materials until 1980. Both systems are expected to exhibit
in-plant decontamination factors of greater than 100.
The most detailed and reliable cost estimates for Jorypton-85
control are available for the cryogenic distillation process. Cost
estimates provided by commenters were for the Barnwell Nuclear Fuel
Plant. These estimates ranged up to ^3.5 million dollars (including an
escalation cost of 12.5 million dollars) for removing krypton-85 by
cryogenic distillation from a dissolver offgas stream of 550 scfm. The
Barnwell plant was not designed to minimize the cost of installing
krypton control (although provision was made to retrofit such control,
if it should be required); thus, the offgas flow rate and the resultant
costs of the treatment system are rather high. On the other hand, the
conceptual design of the proposed Exxon plant, which assumes krypton
control will be installed, has an offgas flow rate of 25 scfm.
The volume of offgas to be treated has a large impact on the
cost of systems required to provide krypton control; thus, the Agency
has based its primary consideration of the cost of krypton-85 control on
a cryogenic distillation unit for a future-generation generic plant with
offgas flow rates similar to that of the proposed Exxon plant. In order
to provide some convervatism, costs were estimated for flow rates of 100
scfm and 50 scfm. These costs and the associated reduction in potential
health effects and population dose are shown in Table 13. The Agency's
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TABLE 13
COST-EFFECTIVENESS OF KRYPTON CONTROL AT FUEL REPROCESSING PLANTS
Plant Design
*
Generic Designs
50 SCFM
100 SCFM
**
Barnwell Designs
Partially Redundant
Fully Redundant***
Total
Present
Worth
($1,000)
18,200
24,100
38,300
44,600
Population Dose
Averted (man-kilorem)
Whole
Body Gonads Lungs
187 249 374
187 249 374
131 178 267
141 188 282
Health
Effects
Averted
140
140
100
105
$/Man-Rem Averted
Whole
Body Gonads Lungs
52 26 5
69 35 7
157 77 15
169 85 17
$/H.E.
Averted
130,000
170,000
380,000
425,000
***
2100 MTHM per year (the design capacity of the proposed Exxon facility, which projects an
offgas flow rate of 25 scfm).
1500 MTHM per year; 550 scfm is the reported maximum offgas flow rate for Barnwell (see text).
Affidavit of James A. Buckham, April 2, 1976, submitted with supplemental submission of
Allied-General Nuclear Services in connection with EPA's public hearings March 8-10, 1976,
on Environmental Radiation Protection Standards for Nuclear Power Operations.
-------
estimated costs for retrofitting the BNJEP are also included in Table 13.
In calculating the number of potential health effects and the population
doses averted, it was assumed that the cryogenic system would operate 90
percent of the time needed at a decontamination factor of 100 (i.e., 99%
removal). Of the total number of potential health effects estimated, 60
percent result from whole-body dose, 25 percent from gonadal dose, and
15 percent from lung dose. This breakdown was used to determine the
fraction of the total krypton control cost spent to avert whole-body,
gonadal, and lung doses to the population. The costs per man-rein for
each of these types of dose are small fractions of the interim value of
$1,000 per man-rem to the whole body or thyroid used by NEC to evaluate
the cost-effectiveness of controls for reactors.
Table 12 also contains estimates of the cost effectiveness of
reducing potential health effects. These costs are $130,000 to $170,000
per effect averted for the generic design. A retrofit of the Barnwell
plant would, according to EPA
-------
The Agency has chosen the generic plant designed for krypton-85
removal as the most appropriate basis for considering control costs.
This choice was made because the significant impact on both the
environment and the costs of producing nuclear power will be in the
large amount of fuel reprocessing capacity that will have to be provided
in future years if the fuel cycle is to be operated so as to provide
recovery and recycle of fissile uranium and, possibly, plutonium. For
this reason, the Barnwell facility should be considered as a special,
first-of-a-kind case with unique control cost requirements. The cost
estimates provided to date for this facility are considered to be higher
than should be expect«:d for future plants because they are based on
considerable degree of redundancy, a very high offgas flow rate, and do
not appear to reflect a systems analysis of the plant to optimize costs
associated with krypton control. If the offgas flow rate were reduced
by half, the total costs of krypton control would be reduced by about
30-40 percent. Various alternatives and tradeoffs might be considered
for reducing the offgas flow rate, with potential overall reduction in
current cost estimates for BNFP. For example, design changes in the
dissolver could reduce in-leakage, use of nitrogen or some other gas
instead of air may reduce recombiner requirements, and the air flow
through the treatment system may be reduceable by recycle of the main
offgas stream and use of a bleeder system for effluent control.
Although krypton-85 control systems are judged to be cost-
effective in reducing potential health effects, it is also appropriate
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to consider the effect of such control on the overall cost of generating
electricity. A generic-size fuel recovery plant can process annual
discharges of fuel from 65-70 reactors froducxng one GW(e)-yr of
electricity; thus, the cost of fuel recovery is a very small percentage
of total power cost. Inclusion of krypton-85 control at fuel
reprocessing plants would increase the commercial cost of power
(estimated to he about 40 mills per kwh) by less than 0.1%. Future fuel
recovery plants are expected to be of even larger capacity which would
further lower the overall effect of such controls on total power costs.
It is important also to recognize that the energy and economic value of
recovering fissile material has increased considerably in recent years
as the cost of providing new uranium for fuel has escalated. This trend
has- made the uranium present in unprocessed fuel an important energy
resource that has considerable market value to the nuclear power
industry. This has recently been confirmed by a study by the Allied-
General Nuclear Service company (74) of the recovery part of the fuel
cycle. Not only is the value of fuel recovery taking on new importance
but the industry should be increasingly able to provide for the cost of
controls within the normal course of doing business.
The availability of krypton control systems is, as pointed out
by several cominenters, an important consideration. The various
components of systems that would likely be used are readily available;
however, total systems have not been installed or tested. This was
accounted for in the proposed standard by setting an effective date of
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1983. The several vendors who have done further design work continue to
show a willingness to bid and guarantee systems based on a cryogenic
distillation process. Various studies under ERDA contracts and the
system being provided for the Tokai Mura plant should provide sufficient
information on total system performance to allow achievement of the
proposed effective date, even with any design adjustments that may be
required as a result of initial performance. A similar commitment to
install and test a system for a U.S. plant could also be reasonably
carried out within this time frame.
3. Waste Gas Storage
Several comments were received concerning the additive costs of
storing recovered krypton-85. The systems costs discussed above contain
facilities for two-year on-site storage prior to processing and shipment
to a central repository. The incremental costs associated with krypton
storage at such a repository would not be expected to exceed those
inherent in the storage of other wastes associated with uranium fuel
cycle operations.
In this regard, ERCA contractors are presently evaluating a
variety of methods for krypton waste storage. Particular attention is
being given to storage in pressurized cylinders for several decades and
to confinement in a solid matrix such as sodalite which, if it can be
made insoluble, would offer certain safety advantages for shipment and
storage since the waste material would be at atmospheric pressure.
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4. International considerations
Several countries are committed to the use of an ever-
increasing amount of nuclear power in order to meet their needs for
electrical power. Each of these expansions in nuclear electrical power
generation add to the amount of krypton-85 available for atmospheric
release and its associated worldwide impact. Although the U.S. is
currently the leading nation in nuclear power generation, its
contribution of krypton-85 to the world's atmosphere can be projected to
be overshadowed by that from other nations before the end of the
century. Such a circumstance raises the question of whether the U.S.
should require krypton-85 control from the uranium fuel cycle operations
in the absence of similar commitments by other leading nuclear power
generating countries.
It is the view of the Agency that krypton-85 from nuclear
electrical power generation should be controlled by all major countries
and that as the acknowledged world leader in the development of nuclear
power it has a responsibility to provide leadership, as it has in
development of nuclear energy itself, for controlling adverse impacts on
the environment and the public. This responsibility exists for
localized effects as well as those which distribute and persist so as to
affect large populations. Setting an appropriate example is basic to
providing such leadership.
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In summary, the Agency has concluded that krypton-85 should be
controlled at the level proposed in the draft statement. This
conclusion is based on a reevaluation of the costs, availability, and
effectiveness of control systems balanced against the Agency's
responsibility to ensure that the world's atmosphere is not degraded by
introducing krypton-85 into it with its potential health impact on the
world population for several decades, and its unknown potential for
altering atmospheric properties and behavior. The systems for such
control are in various stages of testing or application in the U.S. and
Japan and are expected to be available at a reasonable cost per effect
averted by the effective data of the standard. Both the effective date
ind the fraction of removal required have been chosen to provide
reasonable leeway for the provision of adequate protection systems to
eliminate this public health problem within a responsible time frame.
:. HEALTH EFFECTS ESTIMATES
Potential health effects associated with radiation doses have been
estimated for this statement by use of the linear nonthreshold model for
radiation carcinogenesis and the application of risk coefficients
ierived from the report of the Committee of the National Academy of
Sciences on the Biological Effects of ionizing Radiation (NAS-BEIR)
(11), Reasons for using a linear nonthreshold dose response
relationship have been set forth in a previously published policy
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statement on the relationship between radiation dose and effects assumed
by the Agency for the purpose of establishing standards to protect
public health (April 3, 1975), which is reprinted here as Appendix B.
In formulating this policy, the Agency has recognized that much of the
data base used in the NAS-BEIR Report was obtained at higher doses and
dose rates than those likely to be encountered under environmental
conditions, and that this may lead to risk estimates which either over
or under estimate the incidence of radiation induced effects on health
(9). The Agency does net, however, believe that sufficient information
is currently at hand to justify either a reduction or an increase in the
N&S-BEIR estimates of the health risk from ionizing radiation.
Comments were received reflecting many different points of view on
health effects issues. One group agreed that the linear nonthreshold
model using NAS-BEIR risk coefficients is appropriate for estimating
radiation risks due to effluents from the uranium fuel cycle. Another
believed this model was not sufficiently conservative to either protect
public health or provide a proper basis for cost-risk balancing, while a
third group believed the the National Academy of sciences' estimates of
health risk are too conservative at low doses and dose rates. Frequent
reference was made to a statement in a recent report of the National
Council on Radiation Protection and Measurements (75) that extrapolation
from the rising portion of dose-incidence curves derived from data
obtained at high doses and dose rates cannot be expected to provide
realistic estimates of the actual risk of cancer from low level doses of
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lew linear energy transfer (LET) radiation. In addition, reference was
made to the recently published Reactor Safety Study (76) which made
numerical estimates of reduced effects at low dose rates and the
suggestion was made that dose-rate effectiveness factors (DREF) of less
than one be utilized in the EPA analysis to show fewer health effects
than would be estimated on the basis of the N&S-BEIR report. The
Reactor Safety Study applied a DREF of 0.2 at low doses and dose rates.
The basis for suggestions that a EREF be applied in making
estimates of the potential impact'of ionizing radiation is centered
around the hypothesis that for low dose rate, low LET radiations the
initial injury is usually repairable and that at low dose rates time is
available for this biological repair to occur. This is in contrast to
high LET particles where the amount of energy transferred locally is so
large that a critical site is assumed to be damaged beyond repair.
Dose rate effects are often observed after acute, low LIT exposures
where immediate survival is the end point of interest. Such studies
often show reduced effects at low dose rates, and their observation may
or may not also be accompanied by significant departure from a linear
dose-effect relationship, caution is required however, in translating
these well-known radiation injury studies, where cellular depletion and
survival studies demonstrate that biological repair occurs, to the case
of radiation carcinogenesis. Considering the lack of knowledge of basic
179
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mechanisms for radioearcinogenesis, conservatism in assuming the
efficacy of repair mechanisms for unidentified initial injuries would
appear to be warranted.
Reactor Safety Study. (76) assumed that it is possible to
quantify the role that repair processes may play in reducing cancer risk
due to low dose rate, low LET radiation. The primary reference cited
for this viewpoint is a paper by Mays, Lloyd, and Marshall (77) , who on
the basis of their review of the literature on cancer and leukemia in
relation to low and high dose rate exposures, claim an average DREF of
0.2 applies to low dose-rate exposures. There are several reasons, as
outlined below, for believing that the scientific foundation for this
reduction factor is to weak to allow its application as a basis for
standards to provide public health protection. The analysis fails to
differentiate between studies employing chronic irradiation at low dose
rates, the case of interest here, and studies where a fractionated dose
was delivered at high dose rates intermittently over a relatively long
test period. Health effects following fractionated patterns of
irradiation are a function of two competing factors in addition to the
direct radiocarcinogenic potential of the primary insult. The number of
cells at risk to subsequent exposure may be reduced due to cell death
and, in addition the iirnrane response may be augmented or impaired.
These effects have been shown to have a profound effect on
radiocarcinogenicity and careful experimentation and use of controls is
required to sort out the role of these factors in the analysis of
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results (78) . Until the experiments cited in reference 77 have been
replicated with controls for such effects their interpretation is
inclear, particularly since many of these experiments were not designed
;o test for dose rate effects, but were performed for other reasons.
Experiments with both short-lived species (rodents) and dogs were
examined by Mays, et al_^, for the effect of dose rate on
radiocarcinogenesis. In the case of dogs, the only long-lived species
considered, life shortening was used as a surrogate for radiation
;:arcinogenesis. The analysis compared two dog experiments which were
performed at different times, in different laboratories, and by
lifferent investigators. There was no attempt to control the
iexperiments so as to obtain relevance between them. In particular, the
.rractionation of the exposures, the housing of the animals and the sex
of the dogs irradiated differed. It is also likely that the patterns of
oarcinoganesis were quite different for reasons other than dose-rate
Affects, since the low dose rate experiment (79) was designed to observe
changes in spermatogenesis while the high dose rate experiment (80)' was
performed with female dogs for which a principal end-point, mammary
cancer, resulted in either death or surgical intervention. In the
:l ormer experiment, the low dose rate males were, of course, not at risk
3 or this hazard. Mays, et al., calculated life shortening per rad for
;iow dose rate (0.06 - 0,6 r/day) exposure of males dogs and compared
this parameter to that obtained with the female dogs irradiated at 6 rad
I er minute, and concluded that the efficacy of the higher dose rate was
cbout 12 times that of the lower. In view of the differences between
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the two studies, this conclusion is unwarranted. It is of interest,
however, that there was no significant change in either the average or
median age of death for the male dogs as a function of dose rate. This
is illustrated in Table I, below, taken directly from the cited work
(79). It would appear that either the dose-rate effectiveness factor
was infinite or the experiment, which was designed to test for
sterility, was not sensitive enough to fce useful for examining another
endpoint, premature death. In view of the small number of dogs involved
(Table I) EPA believes the latter interpretation of the results is
preferable and that this data for long-lived species does not support
the hypothesis of reduced radiocarcinogenesis at low dose rates.
Table I
Daily Dose* No. of Dogs Average Age Median Age
R/day at Death (Y) at Death (Y)
0
0.06
0.12
0.60
20
20
10
10
12.97
13.76
13.21
12.33
13.14
14.06
13,78
12.67
*Given in a 10 minute period.
Mays, et al^ (71), also referenced studies with rodents by
Shellabarger and Brown (81); Mole (82); Grahn, Fry and Lea (83); and
Upton, Randolph, and conklin (84). In contrast to the studies with
long-lived species these papers provide DREF values of approximately
0.23-1.0; 0.14; 0.19; 0.08, 0.45, 0.14, 0.26 and 0.1; respectively.
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While these DREF values do suggest that in most of these cases animal
experiments indicate radiocareinogenesis is less at low dose rates, the
admonitions of Upton, et al. (84,85), concerning the interpretation of
data on radiocarcinogenesis and life shortening in mice, should be
considered also. That is, the effects of both "wasted" radiation and
age-specific modulation of radiation sensitivity must be allowed for in
the interpretation of such experiments. Indeed, the paper by Mole (82)
cited by Mays, et a 1•_, illustrates this point. He shows that the length
of time over which fractionated doses are delivered is an important
factor in determining the resultant carcinogenicity and that in some
cases long exposure periods lead to higher, not lower, cancer incidence.
It is also important to note that the effect of dose rate on
radiocarcinogenesis in animals is not likely to provide an adequate
predictor for the pattern of human cancer risk, since the incidence of
naturally occurring cancer, life span and the sites of cancer induction
following irradiation differ in man and in animals. in experiments
involving radiation-induced cancers in inbred strains of laboratory
animals, it must be recognized that the genetic characteristics of the
strain are imposed on the results. In the case of human populations,
the cancers observed following radiation are in part related to the
carcinogens in the environment as well as genetic characteristics.
While the relative importance of these two factors cannot be weighted
properly today, it is unreasonable to assume that general patterns of
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radiation induced cancer in inbred mouse strains are directly applicable
to the heterogenous human population.
The degree to which NAS-BEIR Committee risk estimates might over or
under estimate radiation risk has been reviewed by the Agency in light
of MCRP pronouncements (75) on models of radiation injury. There is
growing evidence, as suggested in NCfiP #43, that the Kellerer-fiossi
model for initial radiation injury (not radiocarcinogenesis per se) ,
which predicts a summation of linear and dose squared response, is
useful for interpreting at least some radiation effects data. However,
experimental measurements of.energy transfer as function of site size
and the available biological data in support of this model indicate that
the dose at which the linear, not the dose squared, term dominates the
predicted response is dependent on the spatial distribution of low LET
radiation (86) and therefore is likely to vary with the end point
considered. Experimental analyses indicate that for genetic effects
linearity dominates for doses less than 100 rad (87), while in the case
of some cancers (e.g., adenomas in mice) linearity has been observed at
doses as high as 750 rad (88). The range of linearity for some
radiogenic human cancers induced by low LET radiation appears to be in
excess of several hundred rads (14) but, in, general, is unknown. Unless
all radiogenic cancers are due to energy transfer in sites of the same
effective diameter, the dose at which the cancer response departs from
linearity will be, according to the Kellerer-Rossi theory, quite
variable, since for low LET radiations specific energy is a very
-------
sensitive function of site diameter. The difference between 100 and 750
r id cited above correspojtids to less than a factor of three in site
diameter, contrary to the position of many critics of the BEIR Report,
tie Kellerer-Kossis theory would seem to indicate that at doses below a
h mdred rads or so the frequency of initial injury would be nearly
Proportional to dose, not dose squared.
One hundred rad is about the low end of the range of data
considered by the BEIR Committee in making their estimates of cancer
r..sk (I2*). Since, in general, the BEIR Committee interpolated linearly
between zero and the lowest dose level where excess cancer was observed,
i ; is unlikely their risk estimates were heavily biased by a dose
response that varied by the square of the dose and hence over predicted
t.ue number of radiogenic cancers, as suggested in NCRP f*»3. In a few
cases it is possible to test for this effect directly by comparing the
results of human experience at high and low doses. Comparisons of the
incidence of both breast cancer and thyroid cancer at high and low dose
levels indicates there is little or no difference in "the number of
excess cancers per rem {89}. Rather than argue that thyroid and breast
c,mcer are unrepresentative of radiogenic cancers in man, and therefore
exceptions to an apparent recovery from precancerous radiation damage
observed in rodents, it would appear more prudent and indeed advisable
to limit exceptions to the N&S-BEIR risk estimates to those human
c< sneers where supporting epidemiological data is available.
185
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The Agency is aware that research in this area is very active at
present and that ongoing studies may result in improved risk
evaluations. However, at this time specific DR1F values for chronic low
dose rate, low LET radiations have only been proposed by ad hoc groups.
No recognized standards-setting body has utilized such data in the
establishment of radiation protection standards or guides. At present,
the Agency considers an allowance for reduced injury due to low dose
rates too speculative to be made part of the basis for standards
•developed to protect public health. While the Agency does not rule out
the possibility that such data may become available in the future, it
does not believe sufficient data exists now to warrant a revision of the
health effect estimates given in this statement.
In contrast to the comments received that the EPA health effects
estimates were too conservative, other commenters believed some risks
had been seriously underestimated. Dr. Ernest Sternglass has presented
the hypothesis that, at low dose rates, low LET radiation is much more
likely to cause injury for a given dose than at high dose rates. The
Agency did not find the materials presented in support of the inverse
dose rate hypothesis persuasive. «hile it has been demonstrated that
lipid bilayers manufactured in the laboratory are susceptible to
increased radiation damage at low dose rates, these artificial membranes
are unlike mammalian cell membranes. NO evidence was presented for a
causal relationship between radiation effects on artifical membranes and
the health impact hypothesized by Dr. Sternglass. The essential
186
-------
concept, relating the chemical experiments on artifical lipid membranes
to living organisms, is not demonstrated in Dr. Sternglass1 testimony or
in the references he cites. The testimony asserted that at low dose
rates the concentration of the superoxide radical, a hypothesized agent
of radiation injury, was enhanced, However, the role of the superoxide
radical in radiation injury has not been demonstrated, contrary to the
experiments cited by Dr. Sternglass, in other reported work (90) the
presumed absence of superoxide in E. coli. did not affect the
sensitivity of these cells to radiation, a result that is consistent
with the proposition that this radical is not involved in the mechanism
of the oxygen effect.
The proposed extension of the inverse membrane theory to human
health is even less convincing. Two studies were cited: one in Oslo
with rats where many of the changes seen at low doses and dose rates
were not statistically significant (91); and a second study by Scott,
et al., on radiation workers (92). Dr. Sternglass alleges that Scott*s
investigations showed evidence for erythrocyte membrane permeability
following low doses (at occupational exposure levels). However,
permeability is apparently not involved, as Scott points out. Rather,
his results show a greater 86Rb uptake, i.e., an active process not
related to membrane rupture.
Even if it were assumed that indirect damage to cell membranes is
enhanced at low dose rates, an assumption which has not been proven, the
187
-------
relationship of membrane damage to cancer has not been established. It
has also not been shown that immune response mechanisms are impaired at
the dose levels that are of concern for the uranium fuel cycle
standards, 25 mrem annually. Observed effects on immune systems occur
after doses of 25 reins (93) , a factor of 1000 higher. Nor is there
epidemiologies1 data in support of the view that an enhanced cancer risk
results from low dose-rate irradiations. The data on vital statistics
supplied are not proof of cause and effect or, in the Agency* s judgment,
even a demonstration of a reasonable cause of concern. For example, in
the case of Japanese studies for childhood cancer cited by
Dr. sternglass, a change in the basis for reporting cancer rates in
Japan in 1950 is the cause for most of the effects attributed to
radiation (94).
Dr. sternglass1 theories are original, and to insure that new ideas
are not neglected, the Agency has followed his analyses for a number of
years. However, it has been unable to identify either a supported
sequence of ideas in his arguments or other responsible researchers on
radiation injury who find similar interpretations of the extensive
radiation effects data in the scientific literature. The Agency has
concluded that Ms testimony on health effects at low dose rates is not
a sufficient basis for revising the estimates given in this statement.
188
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2i . National Environmental Policy Act of 1969, Public Law 91-190, 91st
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2: . More than 75% of the source terms for the River Bend, Perry island,
Hatch, and Monticello sites are from the turbine building, more
than 50% of the source term of the Brunswick site is from this
source, and at Peach Bottom, although only 25% of the source term
comes from this source, this release makes the largest contribution
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2;). See, e.g., Mississippi Power & Light Co., Grand Gulf Nuclear
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191
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31. Calculations of Doses, Population Coses, and Potential Health
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193
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6'. Ibid., Appendix 2, p. 7.67 et. seg..
6 i. Ibid., Appendix 5, p.13.
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195
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71. Final Environmental Statement Concerning Numerical Guides for
Design Objectives and Limiting Conditions for Operation to Meet the
Criterion "As Low AS Practicable" for Radioactive Material in
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Energy Commission, WASH-1258 (July 1973).
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Wastes at Nuclear Power Stations, Oak Ridge National Laboratory,
ORNL-4070 (January 1968J.
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and J.P. Witherspccn, Correlation of Radioactive Waste Treatment
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Know, w., and w.B. Sumner, Nuclear Fuel Cycle Closure
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.75. National Council on Radiation Protection and Measurements, Review
of the current State of Radiation Protection Philosophy,
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77. Mays, C.W., Lloyd, R.D., and J.H. Marshall, Late Radiation
Effects: Malignancy Risk to Humans from Total Body Gamma-ray
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the International Radiation Protection Associated, edited by W. S.
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(1974) .
78. Yuhas, J.M., The Role of the Immune System in the Development of
Radiation-Induced Tumors, presented at the 24th Annual Meeting of
the Radiation Research Society, San Francisco, California (1976).
79. Cassarett, G.W. and H.E. Eddy, Fractionation of Dose in
Radiation-Induced Male Sterility, in Cose Rate in Mammalian
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(1968) .
80. Andersen, A.C. and L.S. Rosenblatt, The Effect of Whole-Body
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197
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94, Segi, M., Kurihara, M., and T. Matsuyama, Cancer Mortality in
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95. Environmental Radiation Protection for Nuclear Power Operations,
Transcript of Public Hearings, U.S. Environmental Protection
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96. Statement of George F. Trowbridge on Behalf of the Utility Group,
presented at the EPA Hearing on Proposed 40CFR190 (March 8-10,
1976).
198
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APPENDIX
EHVIRONMENTAL PROTECTION AGENCY
[40 CFR Part 190]
FOR NUCLEAR POWER OPERATIONS
Not ic e of m _Prgpos_ed_ Ruleroaking
Reorganization Plan No. 3, which became effective on December 2, 1970,
transferred to the Administrator of the Environmental Protection Agency the
functions of the former Atomic Energy Commission to establish "...generally
applicable environmental standards for the protection of the general
environment from radioactive material," The Plan defined these standards
as "limits on radiation exposures or levels, or concentrations or
quantities of radioactive material outside the boundaries of locations
under the control of persons possessing or using radioactive material* " On
May 10, 1974, the Agency published an advance notice of its intent to
propose standards under this authority for the uranium fuel cycle and
invited public participation in the formulation- of this proposed rule,
The Agency has reviewed and considered the comments received in
response to that notice and proposes herein environmental radiation
standards which would assure protection of the general public from
unnecessary radiation exposures and radioactive materials in the general
environment resulting from the normal operations of facilities comprising
the uranium fuel cycle. Nuclear power generation based on recycled
plutonium or on thorium is excluded from these standards because sufficient
operating data and experience concerning fuel cycles utilizing these fuels
are not yet available. Before any of these developing technologies becomes
A-l
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of potential significance to public health the need for additional
generally applicable standards will be considered.
The environmental radiation standards proposed in this notice
supplement existing Federal Radiation Protection Guidance limiting maximum
exposure of the general public [P.R. Docs. 60-4539 and 61-9402] by
providing more explicit public health and environmental protection from
potential effects of radioactive effluents from the uranium fuel cycle
during normal operation. Numerically the proposed standards are below
current Federal Radiation Protection Guides. The Agency is not, at this
time, proposing revisions in existing Federal Radiation Protection Guidance
for the general public because of its belief that a detailed examination of
each major activity contributing to public radiation exposure is required
before revision of this general guidance should be considered. Existing
Federal Radiation Protection Guidance for workers in the fuel cycle is also
not affected by these proposed standards. In addition, since these
standards are proposed under authority derived from the Atomic Energy Act
of 1954, as amended, they do not apply to radioactive materials and
exposures in the general environment that are the result of effluents from
mining operations because that Act does not provide authority over such
effluents. Finally, since there are no planned releases from existing
radioactive waste disposal sites and these sites primarily serve sources of
waste other than uranium fuel cycle operations, these standards do not
apply to such sites. The Agency has each of these areas of concern under
continuing study.
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It is the intent of the Agency to maintain a continuing review of the
ii ppropriateness of these environmental radiation standards and to formally
review them at least every five years, and to revise them, if necessary, on
•he basis of information that develops in the interval.
:: :NTBRAGENCY RELATIONSHIPS . Reorganization Plan NO. 3 transferred to the
Ji ;nvironmental Protection Agency (EPA) the broad guidance responsibilities
of the former Federal Radiation Council and also transferred from the
former Atomic Energy Commission (AEC) the more explicit responsibility to
tustablish generally applicable radiation standards for the environment.
However/ the responsibility for the implementation and enforcement of both
•i;his guidance and these standards lies, in most cases, in agencies other
•i;han EPA as a part of their normal regulatory functions. For nuclear power
operations, this responsibility, which had been vested in the AEC, is now
• Bested in the Nuclear Regulatory Commission (NRC), which will exercise the
responsibility for implementation of these generally applicable standards
iJirough the issuance and enforcement of regulations, regulatory guides/
licenses, and other requirements for individual facilities.
:ilASIC CONSIDERATIONS. • The Agency has concluded that environmental
,:.'adiation standards for nuclear power industry operations should include
:onsideration of: 1) the total radiation dose to populations, 2} the
: laximum dose to individuals, 3} the risk of health effects attributable to
• these doses, including the future risks arising from the release of long-
.ived radionuclides to the environment, and 4) the effectiveness and costs
>f the technology available to mitigate these risks through effluent
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control. The Agency also recognizes the findings of the recent study of
the biological effects of low levels of ionizing radiation by the Advisory
Committee on the Biological Effects of Ionizing Radiation (BEIR Committee)
of the National Academy of Sciences - National Research Council, Two of
the principal conclusions of the BEIR Committee were: 1} that current
societal needs appear to be achievable "...with far lower average exposure
and lower genetic and somatic risk than permitted by the current Radiation
Protection Guide. [Thus,] to this extent, the current Guide is
unnecessarily high—" and 2} that "Guidance for the nuclear power industry
should be established on the basis of cost-benefit analysis, particularly
taking into account the total biological and environmental risks of the
various options available and the cost-effectiveness of reducing these
risks,"
For the purpose of setting radiation protection standards the most
prudent basis for relating radiation dose to its possible impact on public
health continues to be to assume that a potential for health effects due to
ionizing radiation exists at all levels of exposure and that at the low
levels of exposure characteristic of environmental levels of radiation the
number of these effects will be directly proportional to the dose of
radiation received (a linear non-threshold dose-effect relationship). Even
under these assumptions, the range of estimates of the health risks
associated with a given level of exposure derived from existing scientific
data is broad.- It is recognized that sufficient data are not now available
to either prove or disprove these assumptions, nor is there any reasonable
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prospect of demonstrating their validity- at the low levels of expected
exposure with any high degree of certainty. However, the Agency believes
that acceptance of the above prudent assumptions, even with the existence
of large uncertainties, provides a sound basis for developing environmental
radiation standards which provide reasonable protection"of1 the public
health and .do so in a manner most meaningful for public understanding of
the potential impact of the nuclear power industry. Standards developed on
this basis are believed to also protect the overall ecosystem, since there
is no evidence that there is any biological species -sensitive enough to
warrant a greater level of protection than that adequate for man.
•Radiological .protection of the public from nuclear power industry
operations has been based to date on guidance which has had as its primary
focus the general limitation of dose to the most exposed individual, rather
than limitation of the total population dose from any specific type of
activity. The proposed expanded development of the nuclear power industry
•requires, -however,"the use of a broader environmental perspective that more
specifically considers the potential radiological impact on human
populations of radioactive effluents' from this industry, rather than just
that on the most exposed individual. A number of long-lived radionuclides
are now discharged from various fuel cycle operations which carry a
potential for buildup of environmental levels and irreversible commitments
for exposure of populations that may persist for tens, hundreds, or
thousands of years.- The extent of the cumulative population doses which
may occur over the years following release of such radionuclides is related
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to their radioactive decay times, the details of their dispersion through
environmental media, the period over which they remain in the biosphere,
and their exposure (both internal and external) of individuals in
populations. The cumulative dose resulting from releases to the
environment of such materials can be termed an "environmental dose
commitment," and quantitatively expressed in terms of the number of person-
rems of dose committed. The proposed standards are based, to the extent
that present knowledge permits, on such projections of the migration of
radioactive effluents through the biosphere and estimates of the sum of
potential doses to present and future populations during that migration.
Since potential effects from radiation exposure are assumed to occur
at any level of exposure, it is not possible to specify solely on a health
basis an acceptable level of radiation exposure for either individuals or
populations; it is necessary to balance the health risks associated with
any level of exposure against the costs of achieving that level. In
developing the proposed standards, EPA has carefully considered, in
addition to potential health effects, the available information on the
effectiveness and costs of various means of reducing radioactive effluents,
and therefore potential health effects, from fuel cycle operations. This
consideration has included the findings of the AEC and the NEC with respect
to practicability of effluent controls, as well as EPA's own continuing
cognizance of the development, operating experience, and costs of control
technology. Such an examination made it possible to propose the standards
at levels consistent with the capabilities of control technology and at a
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cost judged by the Agency to be acceptable to society, as well as
reasonable for the risk reduction achieved. Thus, the standards generally
represent the lowest radiation levels at which the Agency has determined
that the costs of control are justified by the reduction in health risk.
The Agency has selected the cost-effectiveness approach as thatvJbest
designed to strike a balance between the need to reduce health risks to the
general population and the need for nuclear power. Such a balance is
necessary in part because there is no sure way to guarantee absolute
protection of public health from the effects of a non-threshold pollutant,
such as radiation, other than by prohibiting outright any emissions. The
Agency believes that such a course would not be in the best interests of
society.
The total population impact associated with a particular level of
effluent control is best assessed in terms of dose commitments to
populations measured in person-rents, which are then converted into
estimates of potential health impact. However, the environmental models
used for deriving these assessments, while useful for making estimates of
potential health impact, are not considered to be so well-defined as to
allow standards for populations to be expressed directly in terms requiring
their explicit use. The Agency believes that future changes and
refinements in models, and thus in the person-rem assessments upon which
these standards are based, will occur on a continuing basis. The standards
are therefore not proposed directly in terms of person-rems, but future
reviews of their adequacy will reflect any changes in model-based
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assessments of population dose. Standards have also not been proposed
directly in terms of person-rems because the regulatory implementation of
such a requirement does not appear to be administratively feasible for the
fuel cycle under existing widely varying geophysical and demographic
conditions and for doses that may, in some instances, be delivered over
indeterminately long periods of time. The proposed standards are expressed
in terms of 1} limits on individual doses to members of the public and 2)
on quantities of certain long-lived radioactive materials in the general
environment. On the basis of its assessments of the health risks
associated with projected annual population doses and environmental dose
commitments, the Agency has concluded that these two types of standards are
the most appropriate choice of criteria to provide effective limitation of
the potential health impact on populations of short-lived and long-lived
radioactive materials, respectively.
Even though adequate protection of populations considered as a whole
may be assured by standards based upon the above consideration of health
risks and control costs, it may not always be the case that adequate
protection is assured on this basis to some individuals in these
populations who reside close to the site boundaries of nuclear facilities,
because of the distribution characteristics of certain effluents. Such a
situation is possible in the case of thyroid doses due to releases of
radioiodines from reactors and fuel reprocessing facilities. Although the
risk from such doses to nearby individuals is quite small, it is
inequitable to permit doses to specific individuals that may be
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substantially higher than those to other members of the population from
other radionuclides. Additional protection for these individuals should be
provided when technology or other procedures are available for minimizing
<:.ny additional potential risk at a reasonable cost. The standards proposed
•j.o limit doses to individuals reflect this additional requirement where it
::.s appropriate to do so.
'' 'ECHNICAL CONSIpERaTIONS. It is convenient to consider effects of
: -adioactive materials introduced into the environment by the uranium fuel
<:ycle in three categories. Prior to the occurrence of nuclear fission at
1 he reactor only naturally occurring radioactive materials are present in
:l'uel cycle operations. This first category of materials consists
principally of uranium, thorium, radium, and radon with its daughter
products. Radioactive materials introduced to the environment from
facilities for milling, chemical conversion, isotopic enrichment, and
fabrication of fuel from uranium which has not been recycled are limited to
these naturally occurring radionuclides. As a result of the power-
producing fission process at the reactor a large number of new
2adionuclides are created as fission or activation products. These may be
:! ntroduced into the general environment principally by reactors or at fuel
3: eprocessing and are conveniently categorized as either long-lived or
! hort-lived fission and activation products, depending upon whether their
lalf-lives are greater than or less than one year. Although naturally
<: ccurring radionuclides are of some concern, it is these fission and
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activation products which are of greatest concern from the point of view of
controlling radiation doses to the public due to nuclear power operations.
Standards are proposed for the fuel cycle in two major categories. •
The proposed standards would limit! 1) the annual dose equivalent to the
whole body to 25 millirems, to the thyroid to 75 millirems, and to any
other organ to 25 milliremsj and 2)'the quantities of krypton-85, iodine-
129, and certain long-lived transuranic radionuclides released to the
environment per gigawatt-year of power'produced by the entire fuel cycle to
50,000 curies, 5 millicuries, and 0.5 millicuries, respectively. The first
standards are designed to limit population and individual exposures near
fuel cycle operations due to short-lived fission-produced materials and
naturally occurring materials, and due to transportation of any radioactive
materials, while the second specifically addresses potential population
exposure and buildup of environmental burdens of long-lived materials.
The proposed standard for annual whole body dose to any individual
limits the.combined internal and external dose equivalent from gaseous and
liquid effluents as well as exposure to gamma and neutron radiation
originating from all operations of the fuel cycle to 25 millirems. Such a
limit is readily satisfied at all sites for which fuel cycle facilities are
presently projected through the year 1985 (including any potential overlap
of doses from adjacent sites) by levels of control that are cost-effective
for the reduction of potential risfc achieved} is in accord with the
capabilities of controls anticipated by the AEC for all sites for which
Environmental Statements have been filed; and, on the basis of present
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operating experience at existing sites, can be readily achieved in
practice. The combined effect of any combinations of operations at the
same location that are foreseeable for the next decade or so was also
examined and is judged to be small, so that the proposed standards can
readily be satisfied by use of levels of control that are similar to those
required for single operations. It should be noted that this proposed
standard for maximum whole body dose, which is higher than that proposed by
the KBC as guidance for design objectives for light-water-cooled reactors,
differs from those objectives in that it applies,to the total dose received
from the fuel cycle as a whole and from all pathways, including gamma
radiation from onsite locations. It is also not a design objective, but a
standard which limits doses to the public under conditions of actual normal
operation.
The appropriate level for a standard limiting the maximum annual total
dose to the thyroid of individuals is not easy to determine. A standard
for maximum total thyroid dose based on considerations limited to the same
criteria as for maximum whole body dose (cost-effectiveness of reduction of
total population impact and achievability) would permit unacceptably high
doses to individuals near some site boundaries. The proposed standard of
75 millirems per year to the thyroid has therefore been chosen to reflect a
level of biological risk comparable, to the extent that current capability
for risk estimation permits, to that represented by the standard for dose
to the whole body. The effluent controls required to achieve this limit
have been examined extensively by EPA, &EC, and the industry, particularly
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in regard to the ABC's proposed Appendix I to 10 CFR 50 for light-water-
cooled reactors, and, in the view of the Agency, this level of maximum
annual individual dose to the thyroid can be achieved at reasonable effort
and cost.
The principal potential doses to internal organs other than the
thyroid are to the lung via inhalation of airborne particulates and to bone
due to ingestion via water and other pathways of the naturally occurring
materials processed in the several components of the fuel cycle required to
convert uranium ore into reactor fuel. The impact on populations due to
effluents from these operations is generally quite small (due to their
predominately remote locations and lack of widespread dispersion), however,
significant lung doses are possible to Individuals near to these
operations, particularly in the case of mills and conversion facilities.
The use of well-established, efficient, and inexpensive technology for the
retention and control of particulate effluents can readily achieve the
levels of control required to meet the proposed standard of 25 millirems
per year for limiting dose equivalent to the internal organs (other than
thyroid) of individuals.
Environmental radiation exposures from transportation operations are
due to direct radiation. Although average radiation doses to individuals
in the general public from transportation activities are very small,
situations in which individuals could receive higher doses may reasonably
be postulated. It is recognized that exposures due to transportation of
radioactive materials are difficult to assess and regulate because as
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shipments move in general commerce between sites the exposed population is
constantly changing. Transportation activities should be conducted with
every effort made to maintain doses to individuals as low as reasonably
achievable, consistent with technical and economic feasibility. In any
case, the maximum dose to any member of the general public due to uranium
fuel cycle operations, including those due to shipments of radioactive
materials, should not exceed the proposed standard of 25 millirems per year
to the whole body of an individual. The Agency will continue to examine
potential exposures due to transportation of radioactive materials with a
s/iew to further action, if necessary.
Among the variety of long-lived radionuclides produced in the fuel
^ycle, tritium, carbon-14, krypton-85, iodine-129, plutonium, and certain
3ther long-lived transuranic radionuclides are of particular significance
as environmental pollutants. Environmental pathways of tritium, carbon-14,
and krypton-85 are worldwide. Even though the balance of the above
radionuclides may not rapidly become widely dispersed, they are significant
oecause of their potential for extreme persistence in environmental
pathways, possibly for thousands of years for plutonium and other
transuranics, and for even longer periods for iodine-129.
Because of their high toxicity and long half-lives, the cumulative
Impact of releases of plutonium and other transuranics to the environment
;ould be large. However, due to very large uncertainties concerning their
invironsiental behavior over long periods of time, as well as a lack of
definitive information concerning the relationship between exposure to
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these materials and health effects, the limits of this potential impact
cannot be more than roughly estimated. Therefore prudence dictates that
the environmental burden of these materials be minimized to the lowest
levels reasonably achievable. Similarly, although its toxicity is less
than that of the alpha-emitting transuranics, in view of the extreme
persistence of iodine-129 (half-life 17 million years) and great
uncertainty concerning its environmental behavior, environmental releases
of this isotope should be also maintained at the lowest level reasonably
achievable. The prevention of unlimited discharges of krypton-85 to the
environment from fuel cycle operations is of high priority because of its
potential for significant long-term public health impact over the entire
world. Finally, carbon-14 and tritium, both of which rapidly enter
worldwide pathways as gaseous radioactive materials, are of particular
concern because carbon and hydrogen are principal constituents of the
chemical structures of all life forms.
These long-lived radionuclides should only be discharged to the
environment after careful consideration of the tradeoffs between the
societal benefits of the power generated, the current and projected health
risks to populations, and the costs and effectiveness of methods available
to limit their release, since the anticipated maximum dose to any single
individual from any of these materials is very small, the primary concern
is the cumulative risk to population groups over long periods of time. For
this reason, it is not of primary importance where or when in the fuel
cycle any such materials are released, since the committed impact will be
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similar. What is important is to assure that any permitted discharge has
been offset by a beneficial product, i.e., a quantity of electricity, and
that every reasonable effort has been made to minimize it. It is also
important to assure that society is not burdened with unreasonable
expenditures to minimize these risks in order to gain the necessary
benefits of electric power. Fortunately the vast majority of potential
health effects due to release of these radionuclides can be avoided at a
reasonable cost. The Agency estimates the cost of implementing the
proposed standards for these long-lived radioactive materials to be less
than $100,000 per potential case of cancer, leukemia, or serious genetic
effect averted (less than $75 per person-rem). in view of the above
considerations, the Agency believes that the proposed standards, which
limit the number of curies of certain of these radionuclides released to
the general environment for each gigawatt-year of electricity produced by
the fuel cycle, represent the most reasonable means of providing required
protection of the general environment for present and future generations.
The standards will assure that any environmental burdens of long-lived
radioactive materials accumulate only as the necessary result of the
generation of an offsetting quantity of electrical energy.
The proposed standards for long-lived materials fall into two
categories: those which can be achieved using currently available methods
for control of environmental releases, and those that require use of
methods that have been demonstrated on a laboratory or larger scale, but
have not yet achieved routine use. In the former case, exemplified by the
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standard of 0.5 millicuries per gigawatt-year for plutonium and other long-
lived alpha-emitting transuranics, the standard limits the environmental
burden to the lowest level reasonably achievable using currently available
control Methods. In the latter case, that of the proposed standard of
50,000 curies per gigawatt-year for krypton-85 and 5 millicuries per
gigawatt-year for iodine-129, these limiting levels of environmental
burdens are not those achievable by best demonstrated performance, but
instead by minimum performance reasonably anticipated from introduction of
these new systems into commercial operations. As experience is gained with
the ability of the industry to limit fuel cycle releases of these materials
to the environment, it may be appropriate to reconsider the standards
limiting the maximum environmental burdens of these particular
radionuclides.
Similarly, as knowledge becomes available concerning the
practicability of limiting environmental releases of tritium and carbon-14,
the appropriate levels of maximum environmental burdens of these
radionuclides due to fuel cycle operations will be carefully considered by
the Agency. However, the knowledge base new available is inadequate for
such a determination, and no standards are presently proposed for these
radionuclides. The potential for a long-term impact due to carbon-14
released from fuel cycle operations was not recognized until the Agency
considered environmental dose commitments from the industry in the course
of developing these standards? thus consideration of methods for limiting
its release to the general environment are only now beginning. Tritium
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levels in the general environment from fuel cycle operations are not
expected to become significant until the late 1980"s, and development
programs are in existence for control of releases of this radionuclide from
its principal source, fuel reprocessing operations. The Agency believes
that the development and installation of controls to minimize environmental
burdens of both carbon-14 and tritium are important objectives, and will
carefully follow the development .of new knowledge concerning both the
impact and controllability of these radionuclides.
To allow adequate time for implementing the standards for krypton-85
and iodine-129 control, including the necessary testing and analysis
required prior to licensing of these control systems, the effective date is
proposed 'as January 1, 1983. Implementation by this date would result in
control of these releases before any substantial potential health impact
from these materials due to uranium fuel cycle operations can occur and
would, in the judgment of the Agency, provide adequate protection of public
health thereafter.
The proposed standard for maximum dose to organs excludes radon and
its daughter products. Radon is released as a short-lived (3.8 days half-
life) inert gas, mainly from tailings piles at mills, and produces its
principal potential impact through deposition of its daughter products in •
the lung. There exists considerable uncertainty about the public health
impact of existing levels of radon in the atmosphere, as well as over the
best method for management of new sources of radon created by man's
activities, which remove this naturally occurring material and its
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precursors from beneath the earth's protective crust. Radon levels in the
general environment are substantial and are dominated by natural sources,
except in the immediate vicinity of man-made sources. Exposures from radon
and its daughters have previously been the subject of Federal Radiation
Protection Guidance, in the case of. underground uranium miners (F.R, Doc.
71-7210 and F.R. Doc. 71-9697}, and of guidance from the Surgeon General,
in the case of public exposure due to the use of uranium mill tailings in
or under structures occupied by members of the general public ("Use of
Uranium Mill Tailings for Construction Purposes," Hearings before the
Subcommittee on Raw Materials of the Joint Committee- on Atomic Energy,
October 28 - 29, 1971, pp.226-233). The Agency has concluded that the
problems associated with radon emissions are sufficiently different from
those of other radioactive materials associated with the fuel cycle to
warrant separate consideration, and has underway an independent assessment
of man-made sources of radon emissions and their management.
IMPLEMENTATION OF_THE STANDARDS. These proposed standards are expected to
be implemented for the various components of the uranium fuel cycle,
operating under normal conditions, by the Nuclear Regulatory Commission.
The mechanisms by which these standards are achieved will be a matter
between the NRC and the industries that are licensed to carry out various
uranium fuel cycle operations, but, in general, will be based on
regulations and guides for the design and operation of the various
facilities. The Agency is confident that these proposed standards can be
effectively implemented by such procedures.
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Current rules and regulations applicable to fuel cycle operations
generally contain provisions which have the effect of limiting doses to
individuals, thus implementation of the proposed standards for maximum
doses to individuals should be straightforward. Protection of the public
from the environmental accumulation of long-lived radioactive materials may
require some changes in regulatory requirements. For example, this
standard limits environmental accumulations of certain radionuclides
associated with the generation of a gigawatt-year of electrical energy,
which is generated only at the power reactor. Since other operations in
the cycle which do not generate power are more likely to discharge such
materials, it may be necessary for the regulatory agency to make an
appropriate allocation to each facility and to determine the emission rates
required to satisfy the standard for the entire fuel cycle. This is
especially the case for a radionuclide like krypton-85 which can be
released either at reactors, during fuel storage, or during fuel
reprocessing. The standards do not specify the time, location, or
concentration of emissions of long-lived radionuclides. Once a given
quantity of electrical power has been generated the specified amount of the
radionuclide may be released at any time and at any rate or location that
does not exceed the individual dose limitations. Demonstration of
compliance with the sta,ndard requires'only that the total quantity of
electricity generated after the effective date of the standards be recorded
to determine the maximum quantity of these long-lived radionuclides that
may eventually be released.
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The Agency recognizes that implementation of the standards for
krypton-85 and iodine-129 by the proposed effective date of January 1,
1983, will require successful demonstration of control technology for
commercial use that is now in advanced stages of development. The Agency,
as stated above, intends to review all of these standards in at least five
year intervals. If substantial difficulty should develop for implementing
the standards for krypton-85 and iodine-129 with respect to the proposed
levels, facility safety, or cost, the Agency will give these factors
careful and appropriate consideration prior to the effective date.
With respect to operations associated with the supply of electrical
power it is important not only to set standards which will provide
satisfactory public health protection, consistent with technical and
economic feasibility, but also to minimize societal impacts which may occur
as the result of temporary interruptions in those fuel cycle operations
that are necessary to assure the orderly delivery of electric power. Such
a two-fold objective requires consideration of the question whether to
impose stricter standards which achieve lower levels of radiation exposure
and environmental burdens of long-lived radioactive materials, but which
may force temporary shutdowns which may not be justified on a risk-benefit
basis for such periods? or to establish more liberal standards which
decrease the possibility of such shutdowns, but may be overly permissive
with respect to public exposure and long-term environmental releases. The
Agency has attempted to avoid this dilemma by proposing standards that are
not permissive with respect to either public exposures or long-term
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environmental releases arid at the same time providing a variance which
allows the standards to be temporarily exceeded under unusual "conditions.
The use of such variances by the regulatory agency will depend to a large
degree upon their value judgments concerning the necessity of the fuel
cycle operation concerned to a region, overall facility safety, and the
possible impact on public health. The proposed variance provides that
temporary increases above) the standards for normal operations are allowable
when the public interest is served, such as to maintain a dependable source
of continuous power or during a power crisis. The Agency anticipates that
the need to use such variances will be infrequent and of short duration,
and that the overall impact on population and individual radiation doses
from the operations of the entire fuel cycle will be minimal.
With respect to regulatory implementation of the flexibility provided
by this proposed variance provision, the Agency has carefully examined the
guidance for design objectives and limiting conditions for operation of
light-water-cooled nuclear power reactors as set forth recently by the NRC
in Appendix I to 10 CFR 50. It is the view of the Agency that this
guidance for reactors will provide an appropriate and satisfactory
implementation of these proposed environmental radiation standards for the
uranium fuel cycle with respect to light-water-cooled nuclear reactors
utilizing uranium fuel. The various monitoring and reporting procedures
required by the AEC in the past and supplemented by Appendix I are expected
to provide continuing information sufficient to determine that these
standards are being satisfied during the course of normal operations of the
fuel cycle.
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Although the Agency has attempted to limit the effect of radioactive
discharges from the fuel cycle on populations and on individuals through
these proposed standards, it has not attempted to specify constraints on
the selection of sites for fuel cycle facilities, even though the Agency
recognizes that siting is an important factor which affects the potential
health impact of most planned releases from operations in the fuel cycle.
The standards were developed, however, on the assumption that sound siting
practices will continue to be promoted as in the past and that facility
planners will utilize remote sites with low population densities to the
maximum extent feasible.
The Agency has also considered the need for special provisions for
single sites containing large numbers of facilities, of single or mixed
types, as exemplified by the "nuclear park" concept. Present construction
projections by utilities indicate that no such sites are likely to be
operational during the next ten years. In view of the need to accumulate
operating experience for the new large individual facilities now under
construction and the intent of the Agency to review these standards at
reasonable intervals in the future, it is considered premature and
unnecessary to predicate these standards on any siting configurations
postulated for the next decade and beyond. The Agency will consider
changes in these standards based on such considerations when -they are
needed and justified by experience.
It is the conclusion of the Agency that implementation of the proposed
standards for normal operations of the nuclear power industry based on the
uranium fuel cycle will provide society protection of its environment and
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the health of its citizens and that this protection is obtained without
placing unreasonable financial burdens upon society. In this context,
these standards are. responsive.to the President's energy messages of June
4, 1971, and April 18, 1973, which challenged the Nation to the twin
objectives of developing sufficient new energy resources while providing
adequate protection for public health and the. environment.
REQUEST FOR COMMENTS. Notice is hereby given that pursuant to the Atomic
Energy Act of 1954, as amended, and Reorganization Plan No. 3 of 1970 (F.R,
Doc. 70-13374), adoption of Part 190 of Title 40 of the Code of Federal
Regulations is proposed as set forth below. All interested persons who
wish to submit comments or suggestions in connection with this proposed
rulemaking are invited to send them to the Director, Criteria and Standards
Division (AW-560), Office of Radiation Programs, Environmental Protection
Agency, Washington, D.C. 20460, within 60 days after publication of this
notice in the Federal Register. Within this same time period, interested
parties are also invited to indicate their desire to participate in a
public hearing on the proposed rulemaking to be scheduled after the comment
period ends. Comments and suggestions received after the 60-day comment
period will be considered if it is practical to do so, but such assurance
can only be given for comments filed within the period1specified. Single
copies of a Draft Environmental Statement for the proposed standards and a
technical report entitled "Environmental Analysis of the Uranium Fuel
Cycle" are available upon request at the above address. The above-
mentioned technical documents and comments received in response to this
notice, as well as comments received in response to the Agency's advance
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notice of this proposed rulemaking published on May 10, 1974, and the
Agency's response to these comments, constitute part of the background for
this rulemaking and may be examined in the Agency's Freedom of Information
Office, 401 M Street, S.W., Washington, D.C. 20460,
DATED;
Russell E. Train
Administrator
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ENVIRONMENTAL RADIATION PROTECTION STANDARDS^FOR
NORMAL OPERATIONS OF ACTIVITIES IN THE URANIUM FUEL CYCLE
A new Part 190 is proposed to be added to Title 40, Code of Federal
Regulations, as follows:
PART 190 - Em^OJ||E!frAL RADIATION PROTECTION STANDARDS FOR NUCLEAR POWER
OPERATIONS
SUBPART A -GENERAL PROVISIONS
190.01 Applicability
The provisions of this Part apply to radiation doses received by
members of the public in the general environment and to
radioactive materials introduced into the general environment as
the result of operations which are part of a nuclear fuel cycle.
190.02 Definitions
a) "Nuclear fuel cycle" means the operations defined to be
associated with the production of electrical power for public
use by any fuel cycle through utilization of nuclear energy,
b) "uranium fuel cycle" means all facilities conducting the
operations of milling of uranium ore, chemical conversion of
uranium, isotopic enrichment of uranium, fabrication of
uranium fuel, generation of electricity by a light-water-
cooled nuclear power plant using uranium fuel, reprocessing of
spent uranium fuel, and transportation of any radioactive
material in support of these operations, to the extent that
these support commercial electrical power production utilizing
nuclear energy, but excludes mining operations and the reuse
of recovered non-uranium fissile products of the cycle.
c) "General environment" means the total terrestrial, atmospheric
and aquatic environments outside sites upon which any
operation which is part of a nuclear fuel cycle is conducted.
d) "Site" means any location, contained within a boundary across
which ingress or egress of members of the general public is
controlled by the person conducting activities therein, on
which is conducted one or more operations covered by this
Part.
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e) "Radiation" means any or all of the following! alpha, beta,
gamma, or x rays; neutrons; and high-energy electrons,
protons, or other atomic particles; but not sound or radio
waves, nor visible, infrared, or ultraviolet light.
f) "Radioactive material" means any material which emits
radiation.
g) "Uranium ore" is any ore which contains one-twentieth of one
percent (0.05%) or more of uranium by weight.
h) "Curie" (Ci) means that quantity of radioactive material
producing 37 billion nuclear transformations per second, (One
millicurie (mCi) = 0.001 Ci.)
i) "Dose equivalent" means the product of absorbed dose and
appropriate factors to account for differences in biological
effectiveness due to the quality of radiation and its -spatial
distribution in the body. The unit of dose equivalent is the
"rem." (One millirem (mrem) = 0_, 001 rent.)
j) "Organ" means any human organ exclusive of the dermis, the
epidermis, or the cornea.
k) "Gigawatt-year" refers to the quantity of electrical energy
produced at, the busbar of a generating station. A gigawatt is
equal-to one billion watts. A gigawatt-year is equivalent to
the amount of energy output represented by an average electric
power level, of one gigawatt sustained for one year.
1) "Member of the public" means any individual that can receive a
radiation dose in the general environment, whether he may or
may not also be exposed to radiation in an occupation
associated with a nuclear fuel cycle. However, an individual
is not considered a member of the public during any period in
which he is engaged in carrying out any operation which is
part of a nuclear fuel cycle.
m) "Regulatory agency" means the government agency responsible
for issuing regulations governing the use of sources of
radiation or radioactive materials or emissions therefrom and
carrying out inspection and enforcement activities to assure
compliance with such regulations.
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SUBPART B - ENVIRONMENTAL STANDARDS FOR THE URANIUM FUEL CYCLE
190.10 Standards for Normal Operations
a) The annual dose equivalent shall not exceed 25 millirems to
the whole body, 75 millirems to the thyroid, and 25 millirems
to any other organ of any member of the public as the result
of exposures to planned discharges of radioactive materials,
radon and its daughters excepted, to the general environment
from uranium fuel cycle operations and radiation from these
operations.
b) The total quantity of radioactive materials entering the
general environment from the entire uranium fuel cycle, per
gigawatt-year of electrical energy produced by the fuel cycle,
shall contain less than 50,000 curies of krypton-85, 5
millicuries of iodine-129, and 0.5 millicuries combined of
• plutonium-239 and other alpha-emitting transuranic
radionuclides with half-lifes greater than one year.
190.11 Variance for_Unusual_Operations
The standards specified in Paragraph 190.10 may be exceeded
if:
a) The regulatory agency has granted a variance based upon its
determination that a temporary and unusual operating condition
exists and continued operation is necessary to protect the
overall societal interest with respect to the orderly delivery
of electrical power, and
b) Information delineating the nature and basis of the variance
is made a matter of public record.
190.12 Effective Date
a) The standards in this Subpart, excepting those for krypton-85
and iodine-129, shall be effective 24 months from the
promulgation date of this rule.
b) The standards for krypton-85 and iodine-129 shall be effective
January 1, 1983.
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POLICY STATEMENT
Relationship Between Radiation Dose and Effect
Office of Radiation Programs
Office of Air and Waste Management
U.S. Environmental Protection Agency
Washington, D. C. 20460
ISSUED: March 3, 1975
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EPA Policy Statement on
Relationship Between Radiation Dose and Effect
The actions taken by the Environmental Protection Agency to protect
public health and the environment require that the impacts of.contami-
nants in the environment or released into the environment be prudently
examined. When these contaminants are radioactive materials and
ionizing radiation, the most important impacts are those ultimately
affecting human health. Therefore, the Agency believes that the public
interest is best served by the Agency providing its best scientific
estimates of such impacts in terms of potential ill health.
To provide such estimates, it is necessary that judgments be made
which relate the presence of ionizing radiation or radioactive materials
in the environment» i.e., potential exposure, to the intake of radio-
active materials in the body, to the absorption of energy from the
ionizing radiation of different qualities, and finally to the potential
-effects on human health. In many situations the levels of ionizing
radiation or radioactive materials in the environment may be measured
directly, but the determination of resultant radiation doses to humans
and their susceptible tissues is generally derived from pathway and
metabolic models and calculations of energy absorbed. It is also nec-
essary to formulate the relationships between radiation dose and effects;
relationships derived primarily from human epidemiological studies but
also reflective of extensive research utilizing animals and other
biological systems.
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Although much is known about radiation dose-effect relationships at
high levels of dose, a great deal of uncertainty exists when high level
dose-effect relationships are extrapolated to lower levels of dose, par-
ticularly when given at low dose rates. These uncertainties in the
relationships between dose received and effect produced are recognized
to relate, among many factors, to differences in quality and type of
radiation, total dose, dose distribution, dose rate, and radiosensitivity,
including repair mechanisms, sex, variations in age, organ, and state of
health. These factors involve complex mechanisms of interaction among
biological chemical, and physical systems, the study of which is part
of the continuing endeavor to acquire new scientific knowledge.
Because of these many uncertainties, it is necessary to rely upon the
considered judgments of experts on the biological effects of ionizing
radiation. These findings are well—documented in publications by the
United Nations Scientific Committee on the Effects of Atomic Radiation
(UNSGEAR), the National Academy of Sciences (NAS), the International
Commission on Radiological Protection (ICRP), and the National Council
on Radiation Protection and Measurements (NCRP), and have been used by
the Agency in formulating a policy on relationship between radiation
dose and effect.
It is the present policy of the Environmental Protection Agency
to assume a linear, nonthreshold relationship between the magnitude of
the radiation dose received at environmental levels of exposure and ill
health produced as a means to estimate the potential health impact of
actions it takes in developing radiation protection as expressed in
criteria, guides, or standards. This policy is adopted in conformity
with the generally accepted assumption that there is some potential ill
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health attributable to any exposure to ionizing radiation and that the
magnitude of this potential ill health is directly proportional to the
magnitude of the dose received.
In adopting this general policy, the Agency recognizes the inhterent
uncertainties that exist in estimating health impact at the low levels
of exposure and exposure rates expected to be present in the environ-
ment due to human activities, and that at these levels the actual health
impact will not be distinguishable from natural occurrences of ill
health, either statistically or in the forms of ill health present.
Also, at these very low levels, meaningful epidemiological studies to
prove or disprove this relationship are' difficult, if not practically
impossible,' to conduct. However, whenever new information is forth-
coming, this policy will be reviewed and updated as necessary.
It is to be emphasized that this policy has been established for
the purpose of estimating the potential human health impact of Agency
actions regarding radiation protection, and that such estimates do not
necessarily constitute identifiable health consequences. Further, the
Agency implementation of this policy to estimate potential human health
effects presupposes the premise that, for the same dose, potential
radiation effects in other constituents of the biosphere will be no
greater. It is generally accepted that such constituents are no more
radiosensitive than humans. The Agency believes the policy to be a
prudent one.
In estimating potential health effects it is important to recognize
that the exposures to be usually experienced by the public will be
annual doses that are small fractions of natural background radiation
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to at most a few times this level. Within the U.S. the natural background
radiation dose equivalent varies geographically between 40 to 300 mrem
per year. Over such a relatively small range of dose, any deviations
frqm dose-effect linearity would not be expected to significantly affect
actions taken by the Agency, unless a dose-effect threshold exists.
While the utilization of a linear, nonthreshold relationship is
useful as a generally applicable policy for assessment of 'radiation
effects, it is also EPA's policy in specific situations to utilize the
best available detailed scientific knowledge in estimating health impact
when such information is available for specific types of radiation, con-
ditions of exposure, and recipients of the exposure. In such situations,
estimates may or may not be based on the assumptions of linearity and
a nonthreshold dose. In any case, the assumptions will be stated
explicitly in any EPA radiation protection actions,
The linear hypothesis by itself precludes the development of
acceptable levels of risk based solely on health considerations.
Therefore, in establishing radiation protection positions, the Agency
will weigh not only the health impact, but also social, economic, and
other considerations associated with the activities addressed.
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