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
                                vai

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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.
                                  12

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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
                                  13

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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
                                  15

-------
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
                                  16

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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.
                                  17

-------
     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

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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

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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

-------
     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

-------
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

-------
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

-------
              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

-------
                               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.

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                                                                    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.

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                     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.

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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?

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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

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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

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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

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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

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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

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     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

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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

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     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

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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

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   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

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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

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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

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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

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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
                                  89

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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
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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.

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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
                                  93

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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
                                  95

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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
                                  96

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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
                                  97

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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,
                                  98

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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.
                                  99

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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,
                                  101

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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
                                  102

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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
                                  103

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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.
                                  105

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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):
                                  106

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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
                                  108

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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) :
                                  109

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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.
                                  110

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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
                                  111

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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
                                  112

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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
                                  113

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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%

-------
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
                                  115

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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"
                                  116

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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
                                  117

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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
                                  118

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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
                                  119

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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
                                  120

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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
                                  121

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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
                                  122

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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.
                                  123

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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.
                                  124

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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
                                  125

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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
                                  126

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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
                                  127

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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
                                  128

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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
                                  129

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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
                                  130

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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
                                  131

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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
                                  132

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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.
                                  133

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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.
                                  135

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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.
                                  136

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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.
                                  137

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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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                                     PRESENT WORTH CUMULATIVE  COST  (MILLIONS OF DOLLARS)
                                                                                                                 20
                                                  30.10                  30.15                  30.20

                                           COST OF ELECTRICITY TO CONSUMER IMILIS/KILOWATT HOUR)


                                                       I8WR CASE!
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                                                                                            t8 "   17
                                                  30.!0                 30.16
                                   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:
                                  140

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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.

-------
     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
                                  142

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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

-------
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.
                                  145

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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
                                  147

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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
                                  148

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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
                                  150

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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
                                  152

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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
                                  153

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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
                                  154

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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.
                                  155

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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.
                                  156

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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
                                  157

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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
                                  158

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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
                                  159

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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
                                  160

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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-
                                  161

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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
                                  162

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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
                                  163

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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

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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.
                                  165

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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)
                                  166

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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
                                  167

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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) .
                                  168

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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
                                  169

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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
                                  170

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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.

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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
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         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
                                  173

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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
                                  180

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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
                                  181

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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.
                                  182

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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
                                  183

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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

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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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                               INFERENCES
  ..  Legassie, R.W.A.,  oversight Hearings on Nuclear Energy-Overview of
     the Major Issues, Energy Research and Development Administration,
     Update of WASfl-1139(74), Statement before the Subcommittee on
     Energy and the Environment, 94th congress, 1st Sess.  (April 28-29,
     May 1-2, 1975) .

  !.  Title 3--lhe President, Reorganization Plan No. 3 of 1970
     (35FR15623, October 6, 1970).

  i.  Energy Reorganization Act of 1974, Public Law 93-438.

     Liquid Metal Fast Breeder Reactor Program, U.S. Atomic Energy
     Commission, WASH-1535  (December 1974).

 .1.  Generic Environmental Statement Mixed Oxide Fuel, U.S. Atomic
     Energy Commission, WASH-1329 (August 1974).

     A convenient summary is contained in Part III of the Nuclear Energy
     Center Site Survey-1975, U.S. Nuclear Regulatory commission,
     NUREG-Q001 (January 1976).

 "'.  Environmental Analyssis of the Uranium Fuel Cycle, Part I - Fuel
     Supply, Office of Radiation Programs, U.S. Environmental Protection
     Agency, EPA-520/9-73-003-B  (October 1973).

  t.  Environmental Analysis of the Uranium Fuel Cycle, Part II - Nuclear
     Power Reactors, Office of Radiation Programs, U.S. Environmental
     Protection Agency, EPA-520/9-73-003-C (November 1973).

  !.  Environmental Analysis of the Uranium Fuel Cycle, Part III -
     Nuclear Fuel Reprocessing, Office of Radiation Programs, U.S.
     Environmental Protection Agency, EPA-520/9-73-003-D  (October 1973).

H .  Environmental Analysis of the Uranium Fuel Cycle, Part IV -
     Supplementary Analysis-1976, Office of Radiation Programs, U.S.
     Environmental Protection Agency, EPA-520/4-76-017 (July 1976).

     Nuclear Power Growth, 1974-2000, WASH-1139(74) , U.S. Atomic Energy
     Commission (February 1974) .

     Nuclear Power, Financial considerations, Program Report, Atomic
     Industrial Forum, Vol.1, No.5 (September 1973).
                                  189

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13.  Environmental Radiation Dose Commitment: An Application to the
     Nuclear Power Industry, U.S. Environmental Protection Agency,
     EPA-520/4-73-002  (February 1974),

14.  The Effects on Populations of Exposure to Low Levels of Ionizing
     Radiation, Report of the Advisory Committee on the Biological
     Effects of Ionizing Radiation, National Academy of Sciences-
     National Research council  (November 1972)•

15.  See, e.g., Recommendations of the International Commission on
     Radiological Protection, ICRP Publication 9, Pergamon, Oxford
     (1959J, and Basic Radiation Protection Criteria, Report No. 39,
     National Council on Radiation Protection and Measurements,
     Washington, D.C.  (1971).

16.  Taylor, L.C.,  The Origin and Significances of Radiation Dose
     Limits for the Population, U.S. Atomic Energy Commission, WASH-1336
     (August 1973).

17.  Radiation Protection Guidance for Federal Agencies, Federal
     Radiation Council, FR Doc. 60-4539  (May 1960).

18.  Ionizing Radiation: Levels and Effects, Volume II: Effects, United
     'Nations Scientific Committee on the Effects of Atomic Radiation,
     United Nations  (1972).

19.  Policy Statement:  Relationship Between Dose and Effect, Office of
     Radiation Programs, U.S. Environmental Protection Agency  (March 3,
     1975).

20.  Environmental Survey of the Uranium Fuel Cycle, U.S. Atomic Energy
     Commission, WASH-1248  (April 1974).

21.  See, e.g., Unger, W.E., et a]u_.  Aqueous Fuel Reprocessing
     Quarterly Reports for the Periods Ending:  12/31/72 (ORNL-TM-7141),
     3/31/73 (ORNL-TM-4240), 6/30/73 (ORNL-TM-4301) , 9/30/73  (ORNL-TM-
     4394),  Oak Ridge National Laboratory;  Groenier, W.S.,  An
     Engineering Evaluation of the lodex Process; Removal of Iodine from
     Air Using a Nitric Acid Scrub in a Packed Column, Oak Ridge
     National Laboratory, ORNL-TM-4125  (August 1973) j and  Yarbro, O.O.,
     Mailen, J.C., and M.S. Groenier,  Iodine scrubbing from Off-gas
     with Concentrated Nitric Acid, presented at the 13th AEC Air
     Cleaning Conference  (August 1974).

22,  Voloxidation - Removal of Volatile Fission Products from Spent
     LMFBR Fuels, Goode, J.H., Ed., Oak Ridge National Laboratory,
     ORNL-TM-3723  (January 1973).
                                  190

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21 •.  Magno, P.J., Nelson, C.B., and W.H. Ellett,  A Consideration of the
     Significance of Carbon-14 Discharges from the Nuclear Power
     Industry, presented at the 13th AEG Air Cleaning Conference
     (August 1974) .

2*<.  See, e.g., Mishan, E.J.,  Evaluation of Life and Limb: A
     Theoretical Approach, Journal of political Economy 2£:687 (1971);
     Lederberg, J.,  Squaring the Infinite Circle: Radiobiology and the
     Value of Life, Bulletin of the Atomic Scientists (September 1971);
     Dunster, H.J.,  The Use of Cost Benefit Analysis in Radiological
     Protection, National Radiological Protection Board, Harwell,
     Didcot, Berks, England  (September 1973) ; and Schelling, T.C.,  The
     Life You Save May be Your Own, in Problems in Public Expenditure
     Analysis, Chase, S.B., Jr., Ed., Brookings (1968).

2J; .  See, e.g., Hedgram, A. and B. Lindell,  P.Q.R. - A Special Way of
     Thinking?, National Institute of Radiation Protection, Stockholm,
     Sweden  (June 1970); Sagan, L.A., Human costs of Nuclear Power,
     Science 177  (August 11, 1972); -and Cohen, J.J.,  A Suggested
     Guideline for Low Dose Radiation Exposure to Populations Based on
     Benefit-Risk Analysis, presented at the 16th Annual Meeting of the
     Health Physics Society, New York (July 1971).

2i .  National Environmental Policy Act of 1969, Public Law 91-190, 91st
     Congress, S.1075  (January 1970).

2".  Of the 1.05 curies per year iodine-131 projected source term for,
     Surry 1 and 2, 1.03 curies per year comes from the condenser air
     ejector and steam generator blowdown vent.  These effluents could
     be treated through minor modification of the existing gaseous
     treatment system.

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
     to maximum potential thyroid dose.

2;).  See, e.g., Mississippi Power & Light Co., Grand Gulf Nuclear
     Station Units 1 and"2, PSAR, AEC Eocket Nos.  50-416 and 50-417.

3).  The draft environmental statement for the Humeca Mill does not
     specify the control technology used.  However, the information
     presented indicates that dust removal capability currently
     available and proposed for use at similar facilities are not
     proposed for air cleaning.
                                  191

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31.  Calculations of Doses, Population Coses, and Potential Health
     Effects Due to Atmospheric Releases of Radionuelides from U.S.
     Nuclear Power Reactors in 1972, Office of Radiation Programs, U.S.
     Environmental Protection Agency, Radiation Data and Reports 15.;477
     (1974); and unpublished data, Office of Radiation Programs, U.S.
     Environmental Protection Agency.

32.  Martin, J.A., Jr., Nelson, C.B., and H.T. Peterson, Jr.,  Trends in
     Population Radiation Exposure from Operating Boiling water Reactor
     Gaseous Effluents, Proceedings of the Eighth Midyear Topical
     Symposium of the Health Physics Society, CONF-741018
     (October 1974).

33.  Kahn, B. , et aX»,  Radiological Surveillance Studies at a
     Pressurized Water Nuclear Power Reactor, U.S. Environmental
     Protection Agency, RD 71-1 (August 1971);  Kahn, B., et aJU,
     Radiological Surveillance Studies at a Boiling Water Nuclear Power
     Reactor, U.S. Environmental Protection Agency (March 1970).

34.  weirs, B.H., Voilleque, P.E., Keller, J.H., Kahn, B.,
     Krieger, H.L.f Martin, A., and C.R. Phillips,   Detailed
     Measurement of Iodine-131 in Air, Vegetation, and Milk Around Three
     Opera-ting Reactor Sites, presented at the Symposium on
     Environmental Surveillance Around Nuclear Installations,
     International Atomic Energy Agency, 1AEA/SM-180/44  (November 1973);
     and unpublished data, U.S. Environmental Protection Agency and U.S.
     Atomic Energy Commission.

35.  Shleien, B.,  An Estimate of Radiation Doses Received by
     Individuals Living in the Vicinity of a Nuclear Fuel Reprocessing
     Plant in 1968 U.S. Department of Health, Education, and Welfare,
     BRH/NERHL 70-1 (May 1970)„

36.  The Potential Radiological Implications of Nuclear Facilities in
     the Upper Mississippi River Basin in the Year 2000  (The ¥ear 2000
     Study) , U.S. Atomic Energy commission, WASH-1209  (January 1973) .

37.  Auerbach, S.J.,  Ecological Considerations in Siting Nuclear Power
     Plants, The Long Term Biota Effect Problems, Nuclear safety 1_2;25
   '  (1971).

38.  Oscarson, E. E«,  Effects of Control Technology on the Projected
     Krypton-85 Environmental Inventory, presented at the Noble Gases
     Symposium, Las Vegas, Nevada (September 1973); Oscarson, E.E.,
     Ellett, W.H., and N.S. Nelson,  Considerations Regarding Timing of
     Krypton Control Implementation, presented at the International
     Symposium on Radiation Protection, Aviemore, Scotland (June 1974);
     see also references 9, 13, and 23.
                                  192

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39.  Yarbro, O.A.,  Oak Ridge National Laboratory, Supplementary
     Testimony Regarding the State of Technology for and practicability
     of Control and Retention of iodine in a Nuclear Fuel Reprocessing
     Plant, at the consolidated Environmental Hearing for Barnwell
     A. G. N.S. , Construction and Operating License, U.S. Atomic Energy
     Commission, Columbia, S.C., Docket Nos. 50-332 and 50-332OL
     (October 1974} .

40.  Concluding Statement of the Position of the Regulatory Staff,
     Public Rulemaking Hearing on: Numerical Guides for Design
     Objectives and Limiting conditions for Operation to Meet the
     criterion "As Low As Practicable" for Radioactive Material in
     Light-Water-Cooled Nuclear Power Reactors, U.S. Atomic Energy
     Commission, Docket No. RM-50-2  (February 1974).

41.  Project Independence Report, Federal Energy Administration
     (November 1974).

42.  Magno, P.J. and N..S. Nelson,  U.S. Environmental Protection Agency,
     Testimony Regarding Health Risks Resulting from the Release of
     Krypton-85 and Radioiodine from the Barnwell Nuclear Fuel Plant, at
     the Consolidated Environmental Hearing for Barnwell A.G.N.S.,
     Construction and Operating License, U.S. Atomic Energy Commission,
     Columbia, S.C., Docket Nos. 50-332 and 50-332OL (October 1974).

43.  Power Plant Capitol Costs: Current Trends and Sensitivity to
     Economic Parameters, Division of Reactor Research and Development,
     U.S. Atomic Energy Commission, WASH-1345 (October 1974).

44.  Benedict, W.,  Electric Power from Nuclear Fission, Proceedings of
     the National Academy of Sciences J68:1923 (1971).

45.  "As Low As Practicable" Guidelines for Light-Water-Reactor Fuel  •
     Cycle Facilities, Notice of Intent to Amend AEC Regulations  {10CFJR
     Parts 40, 50, and 70), 39FR16902  (1974).

46.  The Separation and Control of Tritium: State-of-the-Art Study,
     Pacific Northwest laboratories, BMI, D.S. Environmental Protection
     Agency (April 1972); Midwest Fuel Recovery Plant,  Applicant's
     Environmental Report, General Electric Company, Suppl. 1, NED
     14504-2 (November 1971);  Chemical Technology Annual Progress
     Report, Oak Ridge National Laboratory, QRNL-4794  (October 1972);
     and reference 22.

47.  Environmental Radiation Protection for Nuclear Power Operations:
     Proposed Standards, 40FR23420-23425 (May 29, 1975).
                                  193

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48.  Draft Environmental Statement: Environmental Radiation protection
     Requirements for Normal Operations of Activities in the Uranium
     Fuel Cycle, Office of Radiation Programs, U.S. Environmental
     Protection Agency  (May 1975}.

49.  Nuclear News 18_:63 (August, 1975).

50.  opinion of the commission in the Matter of Rulemaking Hearing,
     Numerical Guides for Design Objectives and Limiting Conditions for
     Operation to Meet the Criterion "As Low as Practicable" for
     Radioactive Material in Light-Water-cooled Nuclear Power Reactor
     Effluents, U.S. Nuclear Regulatory commission. Docket No. RM-50-2
     (May 5, 1975).

51.  Kahn, B. , Blanchard, R.L., Brinck, W.L., et al._.  Radiological
     Surveillance Study at the Haddam Neck PWR Nuclear Power Station,
     U.S. Environmental Protection Agency, EPA-520/3-74-OQ7
     (December 1974}.

52.  Blanchard, R.L. and B. Kahn,   Pathways for the Transfer of
     Radiomiclides from Nuclear Power Reactors through the Environment
     to Man, Proceedings of the International Symposium on Radioecology
     Applied to the Protection of Man and His Environment, Rome, EUR
     4800 (September 7-10, 1971).

53.  Lowder, W.M., Raft, P.O., and C.V. Goglak,   Environmental Gamma
     Radiation Through Nitrogen-16 Decay in the Turbines of a Large
     Boiling Water Reactor, U.S. Atomic Energy Commission, HASL-271
     (January 1973) ,

54.  Brinck, w., Gross, K., Gels, G., and J. Patridge,   Special Field
     Study at the Vermont Yankee Nuclear Power Station, Internal Report,
     Office of Radiation Programs, D.S. Environmental Protection Agency
     (1974) .

55.  Hairr, L.M., Leclare, P., Philbin,, T.W., and J.R. Tuday,  The
     Evaluation of Direct Radiation in the Vicinity of Nuclear Power
     Stations, 18th Annual Health Physics Society Meeting  (June 17-21,
     1973).

56.  Phillips, C., Lowder, W., Nelson, C., Windham, S., and
     J. Partridge,   Nitrogen-16 Skyshine Survey at a 2400 MW(t) Power
     Plant, U.S. Environmental Protection Agency, EPA-520/5-75-018
     (December 1975}.

57.  Land Use and Nuclear Power Plants, Case Studies of Siting Problems,
     U.S. Atomic Energy Commission, WASH-1319  (1974) .
                                  194

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53.  Kramer, F.W.,  PWR Fuel Performance -- The Westinghouse View,
     Nuclear Energy Digest, No. 2  (1975).

59.  Calculation of Releases of Radioactive Materials in Liquid and
     Gaseous Effluents from Pressurized Water Reactors, U.S. Nuclear
     Regulatory Commission, Draft Regulatory Guide l.BB (September 9,
     1975}.

6).  A Statistical Analysis of the Projected Performance of Multi-unit
     Sites, Based upon Operating Data for Existing Facilities, office of
     Radiation Programs, U.S. Environmental Protection Agency, Technical
     Note (in preparation).     •         •

6L.  Weinberg, A.M. and R.P. Hammond,  Global Effects of Increased Use
     of Energy, Bulletin of the Atomic Scientists 28;5 (March 1972).

62.  Attachment to letter, H. Hollister, ERDA, to R.E. Train, EPA,
     entitled, "Staff comments on proposed EPA regulation  (40 CFR Part
     190) 'Environmental Radiation Protection Standards for Nuclear
     Power Operations' and accompanying draft environmental impact
     statement," p. 6  (September 25, 1975).

6J.  Letter, W.D. Crawford, Edison Electric Institute, to Director,
     Criteria and Standards Division, U.S. Environmental Protection
     Agency  (July 24, 1975).

61.  Assessment of Energy Parks vs. Dispersal Electric Power Generating
     Facilities, National Science Foundation, NSF 75-500 (May 30, 1975).

6j.  Evaluation of Nuclear Energy Centers, U.S. Atomic Energy
     Commission, WASH-1288 (January 1974).

65.  Ibid., Appendix 1, p.7.24.

6'.  Ibid., Appendix 2, p. 7.67 et. seg..

6 i.  Ibid., Appendix 5, p.13.

6).  Soldat, J.K.,  Radiological Impact of a Nuclear Center on the
     Environment, Appendix 5 - Evaluation of Nuclear Energy Centers,
     U.S. Atomic Energy Commission WASH-1288  (January 1974).

7i).  AEC Position on Division of Responsibilities and Authorities
     Between the Atomic Energy Commission and the Environmental
     Protection Agency, memorandum to the President from Dixy Lee Ray
     (October 19, 1973).
                                  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
     Light-Water-cooled Nuclear Power Reactor Effluents, U.S. Atomic
     Energy Commission, WASH-1258  (July 1973).

72.  Blomeke, J.o. and F.E. Harrington,  Management of Radioactive
     Wastes at Nuclear Power Stations, Oak Ridge National Laboratory,
     ORNL-4070 (January 1968J.

73.  Sears, M.D., Blanco, R.E., Dahlamn, R.C., Hill, G.S. , Ryon, A.D.,
     and J.P. Witherspccn,  Correlation of Radioactive Waste Treatment
     Costs and the Environmental Impact of Waste Effluent in the Nuclear
     Fuel Cycle for Use in Establishing As Low As Practicable Guides -
     Milling of Uranium Ores, ORNL-IM-4903, Volume 1 (July 1975).

74.  Chalister, R.J,, Rodger, W.A., Frendherg, R.L., Godfrey, W. L. ,
     Know, w., and w.B. Sumner,  Nuclear Fuel Cycle Closure
     Alternatives, Allied-General Nuclear Services (April 1976) .

.75.  National Council on Radiation Protection and Measurements, Review
     of the current State of Radiation Protection Philosophy,
     Washington, B.C., NCRP Report No. 43, p.50  (1975).

76.  An Assessment of Accidental Risks in the U.S. Commerical Nuclear
     Power Plants, WASH-1400,  U.S. Nuclear Regulatory Commission,
     NUREG-75/G14 (1975).

77.  Mays, C.W., Lloyd, R.D., and J.H. Marshall,   Late Radiation
     Effects: Malignancy Risk to Humans from Total Body Gamma-ray
     Irradiation, in Proceedings of the Third International congress of
     the International Radiation Protection Associated, edited by W. S.
     Snyder, U.S. Atomic Energy Commission, CONF-730907, pp.417-428
     (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
     Radiation Biology, edited by Brown, D.G., Cragle, R.G., and T.R.
     Noonan, U.S. Atomic Energy Commission, CONF-68041Q, pp.14.1-14.10
     (1968) .

80.  Andersen, A.C. and L.S. Rosenblatt,   The Effect of Whole-Body
     x-irradiation on the Median Lifespan of Female Dogs  (Beagles),
     Radiat. Res. 39:177-200  (1969).
                                  196

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81.  Shellabarger, G.J. and R.D. Brown,   Rat Mammary Neoplasia
     Following Co Irradiation at 0,03 R or 10 R per minue, Radiat. Res.
     51:Abstract ED-3  (1972}.

82.  Mole, R.H.,   Patterns of Response to Whole-Body irradiation; The
     Effect of Dose Intensity and Exposure Time on Duration of Life and
     Tumor Production, Brit. J. Radiol. 312:497-501 (1959) .

83.  Grahn, D., Fry, R.J.M., and R.A. Lea,   Analysis of Survival and
     Cause of Death Statistics fo'r Mice under Single and Duration of
     Life Gamma Irradiation, Life Sciences and Space Research JLQ_: 175-186
     (1972).

84.  Upton, A.C., Randolph, M.L,, and J.W. Conklin,   Late Effects of
     Fast Neutrons and Gamma-Rays in Mice as Influenced by the Dose of
     Irradiation; Induction of Neoplasia, Radiat, Res. .1.1:467-491
     (1970).

85.  Upton, A.C., Randolph, M.L,, and J.W. Conklin,   Late Effects of
     Fast Neutrons and Gamma-Rays in Mice as Influenced by the Dose Rate
     of Irradiation: Life Shortening, Radiat. Res. 32:493-509  (1967).

86.  Ellett, W.H. and L.A. Braby,   The Microdosimetry of 250 kVp and 65
     kVp X rays, *oco Gamma-Rays, and Tritium Beta Particles, Radiat.
     Res. 51:229-243  (1972).

87.  Abrahamson, S,,   IAEA International Symposium on Biological
     Effects of Low Level Radiation Pertinent to Protection of Man and
     His Environment  (1975).

88.  Yuhas, J.M.,   Dose Response Curves and Their Modification by
     Specific Mechanisms, in Biology of Radiation Carcinogenesis, edited
     by Yuhas, J.M,, Tennaut, R.w., and J.D. Regan, Raven Press, New
     York, pp.51-61 (1976).

89.  Ellett, W. H. and A. C. B. Richardson, Estimates of the Cancer Risk
     Due to Nuclear-Electric Power Generation, "Origins of Cancer", Vol.
     VI, Cold Spring Harbor Cell Proliferation Series, in press,

90.  Goscin, S.A. and I. Fridovitch,   Superoxide Dismutase and the
     Oxygen Effect, Radiat. Res. 5_6:565-569  (1973).

91.  Stokke, T., Oftedal, P., and A. Pappas,   Effects of Small Doses of
     Radioactive Strontium on the Rat Bone Marrow, A eta Radiol.
     7:321-329  (1968).

92.  Scott, K.G., Stewart, E.T., Porter, C.D., and E. Sirafinejad,
     Occupational x-ray Exposure, Arch. Environ. Health 2J>: 64-66  (1973).
                                  197

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93.  Stoner, R.D.r Hess, M.H., and G. Terres, Primary and Secondary
     Antibody Responses Related to Radiation Exposure, in Interaction of
     Radiation and Host immune Defense Mechanisms in Malignancy,
     Brookhaven National Laboratory, Brookhaven, New York, BNL 50418,
     pp. 152-166 (197H).

94,  Segi, M., Kurihara, M., and T. Matsuyama,   Cancer Mortality in
     Japan  (1899-1962), Department of Public Health, Tohoku University
     School of Medicine, Sendai (1965).

95.  Environmental Radiation Protection for Nuclear Power Operations,
     Transcript of Public Hearings, U.S. Environmental Protection
     Agency, Washington, D.C. (March 8-10, 1976}.

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.
                                   A-2

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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
                                  A-3

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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
                                   A-4

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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
                                  A-5

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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
                                   A-6

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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
                                  A-7

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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
                                   A-8

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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
                                  A-9

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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
                                  A-10

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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
                                  A-ll

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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
                                  A-12

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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
                                  A-13

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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
                                 A-14

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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
                                  A-15

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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
                                  A-16

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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
                                 A-17

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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.
                                      A-18

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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.
                                  A-19

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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
                                      A-20

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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.







                                    A-21

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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







                                  A-22

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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
                                   A-23

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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
                                  A-24

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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





                                   B-2

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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
                                   B-3

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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.
                                     B-4

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