EPA-520/7-76-007
   PROGRAM STATEMENT
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       7IRONMENTAL PROTECTION AGENCY


       OFFICE  OF RADIATION PROGRAMS

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    OFFICE OF RADIATION PROGRAMS
         PROGRAM STATEMENT
              MAY 1976
U.S. ENVIRONMENTAL PROTECTION AGENCY
    OFFICE OF RADIATION  PROGRAMS

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                           TABLE  OF CONTENTS
SUMMARY	    1

INTRODUCTION   	    3

   Background   	    3
   Purpose   	    3

THE RADIATION  PROBLEM  	    4

   Nature of  the  Problem	    4
   Health Effects from  Ionizing Radiation  	    4
   Health Effects from  Nonionizing Radiation	    5
   EPA Policy on Relationship Between Dose and Effect	    9
   Sources of Radiation Exposure	   12
   Radiation Problem Trends  	   13

      Trends in  Use and Applications of  	
       Ionizing Radiation   	   13
      Trends in  Use of Nonionizing Radiation  	   15

   Uncertainties Affecting the  Radiation Strategy	   16

      Ionizing Radiation Uncertainties  	   16
      Nonionizing Radiation Uncertainties  	   18
      Policy and  Responsibility Uncertainties  	   18

PROGRAM OVERVIEW  	   20

   Goals and Objectives	   20
   EPA Radiation Authorities  	   20
   Policies  and  Decision Issues   	   22

      Acceptance of the BEIR Health Risk  Estimates	   22
      Acceptance of a Benefit-Risk-Control-Cost Approach  	   22
      Establishment of  Specific  Program Priorities	   22
      Types and  Applications  of  Standards	   22
      Overview  Relationship With  Federal Agencies	   24
      Development of Working Relationships	
       with States  	   25

   Points of EPA Influence 	   25
   The Management  Plan	   26

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   The Operational  Programs	   29

      Criteria and Standards  	   29
      Technology Assessment Program  	   33
      Environmental Quality Analysis	   36
      Radiation Regional  Programs   	   37

   Research and  Operational Studies  	   39
   Public Involvement  Plan   	   40

APPENDIX  A  	

   An Illustrative Example of the Radiation Exposure Trends	
    in Man-Rems for the years  1970 and 2000	   41

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                                     SUMMARY


     The Environmental Protection Agency (EPA) has the responsibility to protect the health and
welfare  of  man  and the environment from adverse  effects due to radiation exposure. This
responsibility is implemented through the Agency's authorities which established EPA in a role to
provide  continuing Federal overview of radiation protection philosophies, policies and controls.
This mandate is  achieved by developing policies and controls based on the soundest available
scientific and technical information, that satisfy the requirement and intent of the law, that are
legally enforceable, and that reflect responsible public policy.

     To meet  these responsibilities in  a timely manner,  EPA pursues the following general
strategy:

     •  Identify  potential radiation problems by assessing  their impact on public health and the
        environment, and determine the trends resulting from radiation source development and
        use.

     •  Assess  the status of current radiation  controls,  and identify sources and  uses with
        inadequate controls.

     •  Focus on  problems based  upon their  criticality,  potential for adverse health and
        environmental effects, costs, and ability to be reasonably controlled.

     •  Determine the importance of the radiation problem area in addressing national priorities.

     •  Establish  radiation standards, guides, and criteria with implementation through other
        Federal agencies, EPA Regional Offices and cooperation with State and local agencies.

     •  Influence  radiation  policies  of other agencies and promote  responsible industrial
        development through this process and use environmental impact statement reviews and
        environmental radiation assessment activities to augment guides and standards.

     •  Assess  public and private compliance with Agency radiation standards, guides, criteria,
        and other actions.

     The programs philosophy in implementing this strategy is guided by three principles:

     1.  Without specific evidence to the contrary, a linear nonthreshold  assumption relating
        radiation exposure to the potential impact on human health should be used as a prudent
        assumption for estimating health risks from exposure to ionizing radiation. Inherent in this
        assumption is the suggestion that all levels of radiation exposure involve some potential
        risks to health.

     2.  All unnecessary sources of radiation exposure should be avoided; the benefits from
        exposures must be justified in  terms  of benefits that would  not otherwise have been
        received from the activity causing the exposures; and all doses and exposures should be
        maintained as low as reasonably achievable, economic and social considerations being
        taken into account. These imply a risk/benefit assessment of radiation sources and a
        cost/benefit assessment  of measures  which are  directed at further reduction  in
        exposures.

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        Although exposure to radiation from different sources may be associated with the same
        general effects on health, e.g., cancer induction, the variety of objectives different groups
        have in establishing radiation protection standards requires a single  Federal agency,
        EPA, to provide national uniformity in radiation control measures from a public health
        protection perspective.
     Radiation Standards and Criteria development are directed toward both short-lived and long-
lived radioactive pollutants. Long-lived pollutants are of major concern because once released
into  the  environment they could persist for hundreds and thousands  of  years, thus being
potentially available in the biosphere. This occurs because of their lengthy physical half-lives and
a general lack of natural occlusion mechanisms. This persistence, coupled with continued release
of these materials, results in a buildup of radionuclides in  the  environment. The resultant
irreversible buildup could have a potential health impact on current and future generations.
Effective control of such pollutants is by careful control of their use and releases. In addition to
planned releases, EPA has a continuing concern with the potential environmental contamination
from accidents and accidental releases of radionuclides, and with the long term controlled
containment of nuclear wastes.

     A major facet of the Agency's role is to influence the radiation programs and policies of other
Governmental agencies to provide a consistent national perspective for radiation protection.
Through influence, EPA can implement its position and  impact the development of the nuclear
industry and other radiation related industries. EPA  accomplishes this role by exercising its
expertise in acquiring and analyzing information and  data, developing and  implementing EPA
philosophy and guidance, publishing various technical  reports, and through analysis  of each
problem area including environmental impact statement reviews. This, in effect, accomplishes
one  of the Agency's goals because it complements the effectiveness of the generic radiation
standards-setting activities; i.e., by giving EPA a case-by-case influence over the interpretation of
the standards. Since EPA has limited direct enforcement authority with respect to most radiation
standards and criteria, the case-by-case analysis and review role provide EPA with an indirect
enforcement authority over radiation producing activities.

     A number of Federal, State, and local agencies have responsibilities with respect to radiation
control. In addition, many industrial, environmental, and  citizen groups have specific interests in
governmental  policies   and  programs concerned   with  radiation  uses and   protection.
Consequently, these interests demand that EPA openly inform these groups of its actions, solicit
and discuss their opinions and recommendations, and make its decisions in a public forum. It is in
this manner that EPA  implements its radiation responsibilities and in doing so, take into  account
and  balance the technological, economic, institutional, social, and physical aspects of radiation
use and releases.

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                                 INTRODUCTION
BACKGROUND

     Since the discovery of x-rays in 1895, man has sought to exploit the many benefits that
radiation can provide to human welfare. Although many of the health hazards from radiation
exposure were recognized, voluntary compliance with recommended exposure level standards
was considered adequate. However, since that time, the sources of radiation have expanded at a
very rapid rate both in scope and quantity. Voluntary compliance is no longer a feasible or prudent
way to handle the  problem; mandatory controls are  now required. To cope with this situation,
various kinds of Federal and State legislation have been enacted to provide the government with
authority for such mandatory controls.

     Through the implementation of these legislative actions, significant strides toward control of
radiation hazards have been made, including the promulgation of certain standards, criteria, and
guides.  However, even with these accomplishments, improved radiation control is needed in
many areas for a number of reasons. First, a great deal of new information about health effects
and environmental transport has been developed since adoption  of some current standards.
Second, radiation standards to the extent possible should be developed using the "As Low as
Reasonably  Achievable" (ALRA) concept. Third, improved  control  technologies in many areas
make it feasible to reduce emissions at a reasonable  cost to levels below current standards and
guides. And fourth,  many new technologies and applications using radiation are being developed
that have either no existing or inadequate standards and controls.

     With the establishment of EPA and the transfer of many Federal radiation responsibilities to
the Agency,  EPA has the general  mandate to ensure that  the public health and quality of the
environment are adequately protected from radiation hazards. Currently, the radiation problems
are primarily in a preventive mode since a fair  degree of control has been achieved as radiation
uses and applications  have evolved. However, for the future the problems may increase as a
result of rapidly growing technology, expansion of nuclear electric power, increased awareness of
natural radioactive materials and nonionizing sources and the potential for hazardous irreversible
environmental pollution from long-lived isotopes released through operations and accidents. To
meet this responsibility the  Agency, through  this statement,  will  consider and evaluate
inadequacies of controls and take appropriate control action.

PURPOSE

     The "Radiation Program  Statement"  forms the  basis for  the development of detailed
program plans of the Office of Radiation Programs. Its purpose is to describe the radiation control
problem  and to specify the significance  of radiation risks in quantitative terms as these  are
currently understood.  Further,  it presents the program goal,  objectives, authorities, and  the
operational plan. Developed through an iterative process, this edition of the "Radiation Program
Statement" has its foundation on earlier documents, but has been revised and updated to reflect
changes in radiation protection priorities and socioeconomic and technological conditions as well
as modifications to the Agency's basic radiation protection philosophy.

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                         THE  RADIATION  PROBLEM
NATURE OF THE PROBLEM

    The problem associated with exposures to radiation and radioactive materials is twofold.
First, because of the various social and individual benefits that are accruable there are many appli-
cations and uses of radiation today, with significant expansion anticipated for the future. Second,
it has been established that exposure to radiation has the potential for causing detrimental health
effects. Consequently, the focal point of the problem solution lies in the establishment of sufficient
control over radiation exposure to strike an effective balance between minimizing adverse effects
and maximizing accruable benefits.

    There are two types of radiation which contribute to the control problem: ionizing which is
produced by radioactive materials and radiation producing machines such as x-ray equipment,
and nonionizing  which is produced by radio and  television transmitters, radars, microwave
devices, ultraviolet light, lasers and high voltage transmission lines. The primary health effects
associated with these two  types of radiation are different; for ionizing radiation - somatic and
genetic effects; for nonionizing  radiation -  heat stress, neurophysiological, and teratogenic
effects.

HEALTH EFFECTS  FROM  IONIZING  RADIATION

    Forms of ionizing  radiation of primary concern are alpha rays (helium nuclei), beta  rays
(electrons); and gamma rays and x-rays (high energy photons). All of these can affect living
organisms by depositing energy in  the organism's  tissue. This energy absorption causes cell
damage and destruction. The extent of the damage depends upon the total amount of energy
absorbed, the type of organism involved, the time period and dose rate, and the portion of the
organism exposed. Very high doses of ionizing radiation can possibly cause acute death, radiation
sickness, cataracts, sterility, cancer and genetic effects. The potential induction of such effects
has been  derived primarily through animal  investigations and  epidemiologic studies of human
populations exposed as victims  of nuclear  weapons and as patients treated medically. Lower
levels of exposure (which are those of concern to  EPA since they  represent the expected
situation) have the potential for causing  some somatic and genetic effects, based on the linear
nonthreshold dose-effect hypothesis, which is discussed in more detail later in this strategy.

    There are also potential environmental effects or environmental risks, such as irreversible
contamination of land, air, water, and natural resources, and temporary use exclusion of specific
land and water areas. While human ill-health is  of primary concern, there is the  potential for
damaging segments 'of the  biosphere, some  parts of which  may have  radiosensitivities
comparable to that of man. It is assumed that protection of human health from radiation risks will
provide  adequate protection  for  the  total  ecosystem  although  biological  concentration
mechanisms and environmental transport processes must be recognized in any total assessment
made.

    A 1972 study was conducted by the National Academy of Sciences to review the scientific
bases used for the evaluation of risk at low levels of exposure to ionizing radiation and to review

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and re-evaluate existing scientific knowledge concerning the effects of radiation exposure to
human populations.* The basic conclusion of the study is that any radiation exposure may involve
some risk and the biological  risk (particularly cancer induction) associated with low levels of
exposure can for the purpose of deriving risk estimates be assumed to be proportional to risks
observed at higher levels of exposure (the linear, non-threshold concept). Risk estimates are pro-
vided in the report, reflecting the most likely estimates in the judgment of the scientists involved
and the assumptions used in the calculations. Actual effects could be higher or lower, but these
judgments imply an adequate  level  of conservatism. Table 1  represents the quantitative health
risk estimates of exposures to ionizing radiation based on the BEIR Report; Table 2 represents the
statistical annual health effects from major radiation sources; and Figure 1  shows projected health
effects  attributable to long-lived  radionuclides  released from U.S.  nuclear power  production
through the year 2000. The impact of EPA's proposed standards for the uranium fuel cycle is
indicated. The purpose of Table 2 and Figure 1 is to provide some insight to the relative impact of
different sources, not  to provide absolute numbers.

     In order to assess potential health effects on large populations, the "man-rem" concept has
been  introduced.  This concept provides an effective tool  to estimate the magnitude of the
potential health problem from exposure in large  populations to low levels of ionizing radiation,
when such  exposures are expected  to be similar. The "rem" is a unit of radiation dose equivalent
that, as necessary, takes into account the spatial distribution of the energy deposited and the
biological effects of the radiation on the body independent of the type of radiation. The "man-
rem" is an index of the total radiation burden  or risk placed on a given population and is obtained
by summing all the individual  exposures over the population considered provided the range of
exposures is not very large, i.e., within an order of magnitude  at the low levels. Thus, one million
man-rems could be 0.1 rem to  10 million people or 0.01 rem to 100 million people Using the linear
non-threshold dose effect model, estimates of potential health effect are the same in both cases.
The "man-rem" concept is not appropriate for estimating health effects when considering much
larger exposures to only a few individuals.
HEALTH EFFECTS  FROM NONIONIZING RADIATION

     A variety of health effects have been observed or alleged  to be caused by exposures to
various types of nonionizing radiation. These effects have been physiologically categorized as
either thermal or non-thermal. The thermal effects result from temperature increases in tissue
caused by the radiation. These effects  appear at relatively high levels of exposure, above 10
milliwatts per square centimeter (mW/cm2) and include burns, cataracts and temporary sterility.
Research to date has demonstrated and documented these effects at these high levels. At levels
of exposure below 10 mW/cm2 and greater than 0.01  mW/cm2 there is some evidence of nervous
system and  behavioral effects.  Whether these effects  are actually  due to heat  or  local
temperature increases  has not been established. However,  an  exposure level at or below 10
mW/cm2 is not believed to put a stress on the thermoregulatory capability of normal people and
hence in this sense is nonthermal.

*The study was conducted by the National Academy of Sciences Committee on the Biological
Effects of Ionizing Radiation (BEIR). This study, jointly sponsored by EPA and DHEW, resulted in
the report entitled "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation,"
published in  November 1972, known as  the  BEIR Report. The BEIR  Report represents a
compilation  of knowledge on health  effects of ionizing  radiation and the integration of this
knowledge into a single set of precepts based upon the collective expertise of approximately 50
knowledgeable scientists.

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                                 Table 1
        ESTIMATED HEALTH RISK ESTIMATES  OF IONIZING  RADIATION*
    EFFECT                                 CASES PER
                                            MILLION
                                            MAN-REMS
LETHAL CANCER                                  200

OTHER CANCER                                   200

LETHAL GENETIC                                  300

GENETIC ILL HEALTH                        1,000 10,000
*Based on the 1972 NAS report, "The Effects on Populations of Exposure to Low Levels of
Ionizing Radiation."

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                                  Table  2
                                STATISTICAL
        ANNUAL HEALTH EFFECTS FROM MAJOR RADIATION SOURCES*
                                 (U.S. 1973)
NATURALLY OCCURRING RADIOACTIVE MATERIALS AND RADIATION

     NATURAL BACKGROUND	13,000

     CONSTRUCTION MATERIALS  ..."	1,000

     AIR  TRAVEL	100


RADIATION IN  HEALING ARTS	8,000

     (REDUCIBLE COMPONENT 3,000)


NUCLEAR ACTIVITIES

     POWER GENERATION	20

     WEAPONS 	700


OCCUPATIONAL	100

CONSUMER  PRODUCTS	200
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, diabetes,  schizophrenia, epilepsy, and anemia. (P. 82-83, UFC DEIS) They do not
provide absolute bases for risk but imply an adequate level of conservatism.

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     The evidence for nonthermal effects has been reported primarily by investigators in certain
European countries  which significantly have adopted some standards for microwave exposure
one-thousandth of the current standard used in the  United States. However, any significant
nervous system and behavorial effects have not been observed in this country, although several
research programs have been initiated, both within EPA and outside, to determine the existence
and significance of such effects.

     The other major category of effects from nonionizing radiation is related primarily to electrical
interference. Of concern are critical communications systems, electronic life support systems,
such as heart pacemakers, and inadvertant triggering of detonations (blasting).

     Concern with the environmental nonionizing radiation arises from two exposure situations.
One is related to the relatively high levels of exposure in the vicinity of individual high-powered
sources,  such as satellite communications,  airport radars,  broadcast TV, industrial process
applications, and  military electronic applications. The other  is related to the superposition  or
overlapping of radiation from many sources.  Both of these types of situations can result in
exposure of large  populations to significant ambient levels of nonionizing radiation. The radiation
from these sources is currently regulated by a number  of Federal agencies, such as the Federal
Communications  Commission and  the Office of Telecommunications Policy which  issue the
frequency authorizations for privately owned and  government owned  sources, respectively;
Occupational Safety and Health Administration which issues an occupational exposure standard
for frequencies between 10 MHZ and 100 GHZ; and the Bureau of Radiological Health which has
authority to set emission standards for electronic products  under PL 90-602. However, with
respect to environmental effects, there is yet no control  on the ambient level of nonionizing
radiation resulting from either point sources or the combination of low level multiple sources. The
EPA radiation program is providing information on the scope of any environmental problem and
along with other Federal agencies attempting to assess the magnitude of the potential effects on
populations. The underlying principles on the need for this activity are shown in Table 3.

EPA POLICY ON  RELATIONSHIP  BETWEEN  DOSE AND EFFECT

     The actions taken by the Environmental Protection Agency to protect public health and the
environment require that the impacts on contaminants 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 radioactive 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 necessary to formulate the relationships between radiation dose and
effects; relationships derived primarily from human epidemiological studies but also reflective of
prospective research utilizing animals and other biological systems.

     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

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levels of dose, particularly 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 Commitee  on the  Effects of Atomic Radiation
(UNSCEAR),  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, non-
threshold 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 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 inherent uncertainties that exist in
estimating health impact at the  low levels of exposure and exposure rates expected to be present
in the environment 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 forthcoming, 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 that this is a proper policy.

     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 to, at most, a few times  this level.  Within the United States,  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 from 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, non-threshold 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, conditions of exposure, and recipients of the exposure. In
                                           10

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                        Table 3
                 UNDERLYING PRINCIPLES




                  (Nonionizing Radiation)
ADVERSE THERMAL EFFECTS ON BIOLOGICAL SYSTEMS




   OCCUR AT LEVELS GREATER THAN 10 MILLIWATTS




   PER SQUARE CENTIMETER POWER DENSITY FOR




   RADIOFREQUENCY AND MICROWAVE RADIATION.






ADVERSE NONTHERMAL EFFECTS ON BIOLOGICAL




   SYSTEMS HAVE BEEN REPORTED TO OCCUR AT




   LEVELS ORDERS OF MAGNITUDE BELOW THERMAL




   EFFECT POWER DENSITY.






ENVIRONMENTAL LEVELS OF NONIONIZING RADIATION




   CAN SIGNIFICANTLY INTERFERE WITH THE




   OPERATION OF CRITICAL ELECTRICAL SYSTEMS.
                           11

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such situations, estimates may or may not be based on the assumptions of linearity and a non-
threshold  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.

SOURCES OF RADIATION EXPOSURE

    In order to  identify radiation program  objectives, consideration was given to the types of
radiation sources,  their current and projected potential for exposing the population, and the
adequacy of existing and potential controls. While it is quite evident that exposure to radiation can
come from a multitude of activities and source types,  there are four general source  categories
which encompass all of these potential sources of exposure.

        Healing Arts and  Industrial Applications-This area includes all ionizing radiation used for
        diagnostic and medical applications, such as dental radiography, diagnostic radiography,
        therapy, and  nuclear medicine. It also includes industrial uses of radiation, such as
        nondestructive testing, radiography and leak identification.

        Nonionizing  Sources -  Includes sources  such  as  radars,  television  and  radio
        transmitters, microwave transmitters, laser devices, and high voltage transmission lines.

        Natural  Radiation  Sources  - These sources include both  terrestrial  and  cosmic
        background  radiation, construction materials containing significant concentrations of
        radionuclides, fertilizer phosphates and mine, milling and processing residues, energy
        production involving fossil fuels and geothermal systems.

        Nuclear Energy Applications - This broad category includes all activities relating to the
        production of electric power via either fission or fusion. These include the conversion,
        enrichment,   fuel  fabrication,  reactor  operation,  fuel  reprocessing,  and  waste
        management modes of the uranium, plutonium, and thorium fuel cycles. It also includes
        the manufacture and use of nuclear explosives as they apply both to weapons devices
        and peaceful uses, such as gas stimulation products.

     Identification of these four source categories facilitates organization and management of the
complex radiation problem. In general, the kinds of projects developed to provide control and the
types of expertise required  by the control  activities  are unique to  each of these areas;
consequently, grouping in these four areas is appropriate.
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RADIATION  PROBLEM  TRENDS

     The estimated total radiation dose to the population  from ionizing  radiation and from
nonionizing radiation is increasing. This is due to a number of factors:

     •  Increasing population

     •  Increasing variety of radiation related applications

     •  Proliferation of existing applications

     •  Changes in social behavior and lifestyle causing increasing exposure to certain sources.

TRENDS  IN  USE AND  APPLICATIONS OF IONIZING  RADIATION

     Historically, the nation's demand for electricity has been doubling every 10 years. As a result
of economic conditions and conservation efforts this growth rate may not continue. However, the
share of electric  output from  nuclear power is projected to increase from  the  current 39.6
gigawatts generating capacity to an estimated 800 gigawatts capacity for the year 2000, assuming
an 80 per cent capacity factor.

     With the existing prevalence of light-water-cooled reactors (LWR),  most of the potential
radiation problems associated with LWR's are  understood and  technologies  have  been
developed to control them. There still are, however, questions concerning accident probabilities
and consequences, and the adequacy of engineered safeguards for the LWR. Reactors using
mixed oxide fuel reactors (GESMO) and breeder reactors (LMFBR), may provide a share of the
nation's nuclear electric generating  output depending upon satisfactory  resolution of  environ-
mental,  safety, and economic problems. For instance, the  breeder's  future  depends largely on
demonstration of  its economic and  technical feasibility. These reactor types mean new plant
designs, operating criteria, siting criteria and associated radiation control problems.

     The radiation control problems resulting from nuclear electric  power  generation are not
limited to  the nuclear reactor. Associated activities, such  as  uranium mining  and  milling,
conversion, enrichment, fuel fabrication, fuel reprocessing, waste disposal, and all transportation
of radioactive material, have radiation problems that require evaluation and control. The growth in
these activities projected for the year 2000 shows the need for adequate controls to govern their
construction and operation. Table 4 compares the number of fuel cycle facilities operable in 1975
versus those projected for the year 2000.

     As more power reactors and associated facilities begin operation, increasing quantities of
radioactive  waste  will be generated. Radioactive waste disposal involves major problems in five
different areas: High Level Waste, Transuranium Contaminated Waste, which includes plutonium,
Low  Level Waste, Natural Radioactive Waste including Mill Tailings, and Decommissioning of
Facilities. While high-level waste poses a programmatic problem of  increasing concern  to the
public and to the  government, actual exposures to population groups from  natural, transuranic
waste, and low-level waste involve more immediate public health problems. Decommissioning of
radioactive facilities is a problem that has yet to be addressed in depth.

     EPA's responsibilities lie in the area of setting basic environmental criteria and guidance for
use by other Federal agencies. These are in turn used in regulating management of radioactive
wastes from nuclear energy applications. In addition, EPA  is  involved in developing standards,
                                          13

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                                   Table 4
          COMPARISON OF THE NUMBER OF FUEL CYCLE FACILITIES
                OPERABLE IN 1975 VERSUS THOSE PROJECTED
                             FOR THE YEAR 2000
             Type


Uranium Mills**

UF Production Plants

Enriched Uranium Fuel
  Processing and
  Fabrication Plants

Plutonium Fuel Processing
  and Fabirication Plants

Fuel  Reprocessing Plant

Irradiated Fuel
  Storage Facilities

Waste Burial Grounds

Enrichment  Plants
1975


18

 2
Planned


   6

   1
Estimated by
 Year  2000
    69

     9
7
5
0
2
6
3
2
-4 * * *
3
3
53

17

0 10
4 18
* U.S. Nuclear Regulatory Commission Annual Report 1975.

* * Some of the mills and waste burial grounds are under Agreement State Licenses.

***Firm plans affected by Pu Recycle Question.
                                       13a

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criteria or guidance in the area of management and disposal of naturally radioactive materials
found interspersed in  minerals, ores, fossil fuels and other materials mined and processed for use
in non-radioactive applications. Ocean disposal and deep bed ocean emplacement of radioactive
wastes are also areas in which EPA is involved and has primary regulatory authority. Finally, EPA
along with NRC has responsibilities for environmental surveillance to evaluate leakage problems,
including those related to low-level commercial waste burial sites.

     In developing criteria for radioactive waste management and carrying out our regulatory
roles in ocean disposal and natural radioactive waste areas, EPA's underlying philosophy is that
waste management means containment of radioactive materials until  they have decayed to
unnocuous levels. The objective is to minimize exposure to present and future populations and to
avoid dilution into the biosphere. Containment may  involve burial, storage, or some form of
assuring that dispersion into the biosphere does not take place.

     EPA further believes that effective and efficient solutions to problems in all five radioactive
waste disposal areas will require close  coordination and cooperation among all  Agencies
involved. In  this  regard, EPA is participating with the Energy Research  and Development
Administration, the Nuclear Regulatory Commission, the Council on Environmental Quality, and
the U.S. Geological Survey to lay the groundwork for the development of  a consolidated national
radioactive waste disposal plan. EPA's role in this plan will be the development of performance
criteria for the containment and control of radioactivity from waste disposal sites.
     The release of long-lived radionuclides to the environment will be of major concern if there is
a continuing growth in nuclear power and nuclear industries. Because of their persistent natures,
these environmental pollutants  not only tend to build up in the environment over time, but those
released to the environment today will continue to be potentially available  to  expose the
population  for thousands of years. Thus, there is an environmental dose commitment which
results in some commitment, uncertain but estimatable, of future adverse health effects for many
years from  the discharge of small quantities of  such persistent environmental  pollutants.*
Currently, the environmental dose commitment is small. However, a lack of adequate controls to
prevent environmental buildup coupled with the anticipated growth in the generation of long-lived
radionuclides could  result in emissions from the  nuclear power industry representing  a large
contribution to total population dose.
     In addition to projected increases in the generation of nuclear electric power, many other
energy  sources are  receiving  increased development effort in order to  achieve energy
independence for the United States. One of these is geothermal energy. There is currently only
one  commercial geothermal electric power plant in operation  in the United States. However,
because of the high potential promise of geothermal sources, a number of such demonstration
and  commercial facilities are being planned for the near future. These plants  rely on directing
steam that is produced deep in the earth to turbines where the thermal energy is converted to
electricity. The steam flowing from the earth carries radioactive radon gas with it. This radon could
expose the workers at the plant, the local environs, and the general population. Because of the
newness and limited use of this energy source, the radiation problem is currently being defined
and identified.

*A detailed discussion  of  this  problem is presented in  the  EPA  publication Environmental
Radiation Dose Commitment: An Application to the Nuclear Power Industry, EPA 520/4-73-002,
February 1974.


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     There are many terrestrial products, such as metallic ores and phosphates, which contain
concentrations of naturally occurring radioactive materials. While the materials are in the earth,
they are of little adverse consequence to man because of natural containment within the earth.
However, materials, like gypsum, are extracted for construction applications; other materials, like
phosphates, are used as fertilizers to grow food. The result is that these radioactive materials
removed from the earth can expose the people working in plants making these products, and as
waste effluents and by-products can enter the biosphere for exposure of man.
     The use of x-rays, isotopes, and other radiation in medical, therapeutic,  and diagnostic
treatment has greatly expanded in recent years and is expected to continue to increase. Although
FDA reported  in 1975  that the genetically significant dose is lower than originally estimated
(primarily due to a correction in the dose model), nevertheless, the dose from the application of
radiation in the healing arts remains rather large as a manmade source. There is agreement that
reductions in exposure can be attained without any significant loss in the  obvious benefits of this
application.

     It is estimated that the total radiation dose to the United States population from natural,
medical, occupational, fallout, nuclear power, and other sources will fall in the range from 46.7
million to 93.4 million man-rems in the year 2000.* This compares with the estimated 43.3 million
man-rems dose in 1970. The lower prediction for the year 2000 reflects an aggressive national
radiation control program using up-to-date techniques and equipment. The higher value might be
expected to result from present practices which are possible but not yet fully implemented.

     An illustrative example of what may be the potential radiation exposure trends in man-rems
for the year 2000, compared with the same estimate for 1970, is shown in Appendix A. It should be
noted that the data for both figures in the appendix are gross estimates to provide comparison of
trends and do not  represent actual  predictions of what may  happen. From this example it is
evident that there must be a well planned and  executed Federal radiation protection control
program to reduce the exposure trends to their lowest practicable level. It is also evident that there
must continue to be a high degree of cooperative effort between the Federal Government, the
nuclear power  industry, the  medical profession, State and  local Goverments and the other
components of our society to prevent and reduce wherever possible the radiation exposure to our
workers, patients and the general population.

TRENDS IN USE OF NONIONIZING RADIATION

     There exists a potential risk to  personnel and equipment from such nonionizing radiation
sources as radar, radiofrequency communication devices, microwave ovens, medical diathermy
devices, high voltage transmission lines and industrial heating equipment. Until about 1945, the
environmental levels of nonionizing  radiation were not considered significant.  Since then, the
electronics, navigation,  and communications industries have flourished. There are thousands of
sources currently operating and the number of radiofrequency and microwave sources alone are
estimated to be increasing at 15% annually. Because of the numbers  of competing sources,
television and  radio station owners are increasing their  power output in order to reach larger
audiences without having their signals obliterated by interference. Thus, there could be increases
in ambient levels of nonionizing radiation at these frequencies.


*U.S. Environmental Protection Agency,  Estimates of Ionizing Radiation Doses in the United
States,  1960-2000, ORP/CSD 72-1, August 1972.
                                          15

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     Initial examination of this country's most powerful sources indicates that there are now 86
sites capable of producing a power density of 10 milliwatts per square centimeter at a distance of
approximately one mile from the source. There are 2,368 sources capable of producing a power
density of 10 microwatts* per square centimeter at the same distance.* The difference in these
values points out that the magnitude for control depends upon the levels which are chosen for
environmental standards. These two power densities also represent the probable extremes of the
range of acceptable power densities for environmental criteria. Table 5 identifies the high power
sources and shows the growth rate of some applications of nonionizing radiation.

UNCERTAINTIES AFFECTING THE RADIATION PROGRAM

     Although the strategic operational program is based upon the best knowledge available and
the current prevailing conditions, consideration must be given to the many important uncertainties
affecting  the Agency's ability to establish effective controls. These unknowns lie primarily in the
areas of health effects and ecological processes knowledge; the availability of  effective control
technologies for specific  radionuclides, nuclear facility operations, and industrial processes, and
policy and responsibility uncertainties. The significance of these unknowns is that, as the program
is implemented, developments in these areas could require minor or major modifications, such as
changing control  procedures, establishing more or less stringent standards, and changing basic
control philosophies and approaches.

IONIZING RADIATION UNCERTAINTIES

     A tremendous body of research knowledge  has developed over the years  about ionizing
radiation. The types of health effects attributable to radiation exposure are well known; however,
the specific probabilities of  occurrence at low environmental levels have not been clearly
demonstrated. Consequently, at this time only a conservative hypothesis can be  used to estimate
the number of potential health effects. The current and projected quantities of many radionuclides
including plutonium and actinides in the environment and their environmental transport modes
and mechanisms are also highly uncertain. The consequence of these uncertainties is that the
environmental  impact cannot be  precisely projected; therefore, conservatism in judgments is
necessary in developing appropriate standards and other controls so that the nation does not find
itself with large-scale irreversible and unacceptable contamination from these materials.

     Although technologies regarding effluent controls and engineered safeguards have been
improving since the introduction of the nuclear industry, a number of uncertainties still remain. The
majority of these lie in the determination of the acceptable levels of risk from  accidents at nuclear
facilities;  the reliability of emergency systems  to mitigate adverse effects in  the  event of an
accident; the development of an environmentally acceptable method for long  term disposal of
radioactive waste; and the development  of systems to control effluents, such as krypton-85,
carbon-14 and tritium. The Reactor Safety Study,  An Assessment of Accident Risks in  U.S.
Commerical Nuclear Power Plants (WASH 1400) published  by NRC in November 1975 helps
define the uncertainties in accident consequences.
* A milliwatt is one thousandth of a watt, a microwatt is one millionth of a watt.

*Environmental Radiation Exposure: A Preliminary Analysis of the Problem and Continuing Work
Within EPA, R. A. Tell, Environmental Exposure to Nonionizing Radiation, EPA/ORP 73-2.
                                          16

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                      Table 5
  NONIONIZING RADIATION EXPOSURE CONSIDERATIONS









HIGH POWERED SOURCES




    SATELLITE COMMUNICATIONS




    AIRPORT RADARS




    BROADCAST TV




    INDUSTRIAL PROCESSING APPLICATIONS




    MILITARY ELECTRONIC APPLICATIONS






HIGH GROWTH RATE OF APPLICATIONS




    MICROWAVE OVENS (1,000,000 in 1974)




    LAND-MOBILE COMMUNICATIONS (459,000 in 1972)




    SMALL BOATS




    PRIVATE PLANES




    MICROWAVE DIATHERMY




    RADARS, BOTH MILITARY AND PRIVATE
                        17

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NONIONIZING RADIATION UNCERTAINTIES

     In  the  nonionizing  radiation  area there are  three  major uncertainties.  First is the
determination of the existing ambient environmental levels and their rates and patterns of growth.
Second is the determination of criteria which can be used to specify acceptable environmental
levels, e.g., thermal stress,  non-thermal health effects, interference with electronic life support
systems, or interference with  television  and radio reception. Lastly is the  determination of the
existence of non-thermal effects, which are detrimental to public health and welfare.

POLICY  AND RESPONSIBILITY UNCERTAINTIES

     The policy and responsibility uncertainties fall primarily into four categories:

     1.  The enactment of  new legislation, such as the Safe  Drinking Water Act  of 1974, has
required EPA to undertake a substantial  workload in developing an information base, objectives,
and  criteria for  radioactive  contaminants in drinking water. It will also vastly increase EPA's
responsiblities in monitoring and compliance; hard data will be needed based  on surveillance
measurements with analytical and instrumentation quality control.

     2.  EPA has the capability to respond to incidents or accidents at nuclear facilities or during
the  shipment of  radioactive  materials  by  providing on-the-spot emergency teams and  in
evaluating the accident to determine the  cause, the extent of the hazard, and recommend control
measures.  These  support  services  are available to other  Federal agencies  through the
Interagency Radiological Assistance Plan (IRAP).

     In a Federal Register notice, Vol. 40 No. 248 dated December 24, 1975, the GSA's Federal
Preparedness  Agency  published  the  interagency  responsibilities  in Radiological   Incident
Emergency Response Planning; Fixed Facilities and Transportation. This  notice sets  forth the
responsibilities as agreed between the certain Federal agencies and is also  intended to provide a
continuing stimulus to State and local government in  developing their plans for responding  to
radiological  incidents.  Under this  agreement EPA  is  responsible for (1) Establishment  of
Protection Action Guides (PAG) in coordination with appropriate Federal agencies. These guides
will be in terms of projected  radiation doses which might result from radiological incidents at fixed
nuclear facilities or in the transportation of radioactive materials; (2) Recommendations as  to
appropriate protective actions which can be taken by governmental authorities to ameliorate the
consequences of a radiological incident at  a fixed  nuclear facility or from  an  incident  involving
transportation of radioactive materials; (3) Providing assistance, following the guidance issued by
NRC, to State agencies with radiological  emergency response responsibilities in the development
of their emergency plans relative  to nuclear facilities and transportation incidents  involving
radioactive materials;  and (4) The establishment of emergency  radiation  detection and
measurement systems guidelines in  cooperation with NRC.

     Such incidents frequently arise, particularly at the low end of the spectrum of possible
consequences,  and therefore, while the time of their occurrence is not predictable, a temporary
realignment of  priorities  may be necessary as incidents occur  in order  to provide  technical
assistance and field support at the incident site to reduce the consequence  of such  incidents and
to assure protection of the public health.

     EPA also has responsibilities to take actions involving spills of oil and hazardous materials as
required by sections 307 and 311  of the  Federal Water Pollution Control Act,  as amended.
                                          18

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Radioactive material under certain conditions could be designated as a hazardous substance and
as such could impact on program priorities.

     3.  Policy changes may occur as a result of judicial decrees arising from suits against EPA.
One current example involves a suit filed in February 1974, in the United States District Court for
the District of Colorado by the Colorado Public Interest Research Group, Incorporated (COPIRG)
Plaintiffs versus Russell Train, Administrator, Environmental Protection Agency Defendant. The
COPIRG raised the legal issue that all radioactive effluents are subject to regulations pursuant to
the 1972 amendment to the FWPCA. The District Court ruled in favor of the Federal Government.
Subsequently, on appeal of the lower Court decision, the United States Court of Appeals, Tenth
Circuit, on December 9,1974, reversed the decision. In April 1975, the Solicitor General, on behalf
of the Environmental  Protection Agency and its  Administrator, submitted a petition  to the
Supreme Court of the United States for a writ of certiorari to review the judgments of the United
States Court of Appeals for the Tenth Circuit. Arguments were heard on this case in December
1975. Pending the Supreme Court decision, there is a considerable quantity of additional analysis
and procedural involvement by EPA in order to be prepared to comply with the lower Court's ruling
in the event the Federal Government loses the case.

     4.  New Nuclear Regulatory Commission (NRC) and Energy Research and  Development
Administration (ERDA) initiatives,  including those resulting from petitions and suits, may require
EPA to review unanticipated environmental impact statements, regulations, and other policy
directives. These initiatives may have a major impact on the environment. Consequently, EPA
would have to redirect priorities to ensure that the initiatives are fully assessed and appropriate
action taken by the Agency to maintain the quality of the environment and protect the public.
                                         19

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                             PROGRAM  OVERVIEW
    The purpose of this chapter is to provide a program overview by stating protection goals,
objectives, and the authorities. Because of the Agency's authorities, the many different kinds of
sources, the different media through which radioactive materials flow, and the varied people
receiving exposures, no single point of control  or type of standard could comprehensively
minimize the  radiation exposure. Therefore, to complete the  overview the different potential
points of EPA control or influence will be discussed.

GOALS AND OBJECTIVES

    The overall goal of the Environmental Protection Agency implemented through the Office of
Radiation Programs is to protect public health and the environment by assuring that no avoidable
risks occur to  individuals, and the population at large, or the environment due to radiation ex-
posure without the existence of offsetting benefits; and within this framework, to minimize risk in a
cost-effective manner. In accomplishing this goal EPA will be fully responsive, within the limit of
resources available to current problems by cooperating with other Federal agencies, the States,
the public and industry.

    The achievement of this goal will be attained by directing resources to specific source related
objectives.  These objectives  are to minimize radiation  exposures to that necessary from (1)
healing arts, (2) industrial applications, (3) nonionizing radiation, (4) natural radioactivity, and (5)
nuclear energy applications.

EPA  RADIATION  AUTHORITIES

    EPA has the mandate to protect public health and the environment from any adverse effects
due to radiation exposure.  Fortunately, its authorities afford the flexibility to attack the radiation
problems in the order of their relative importance. Table 6 lists these authorities. In addition, EPA's
general authorities include research  and monitoring,  and the authority to perform ecological
studies provided by the transfer of the Council on Environmental  Quality (CEQ) authority under the
President's Reorganization Plan No. 3 of 1970. The two principal  authorities for setting radiation
standards are as follows:

    •  On August 22, 1959,  eight days after the Federal Radiation Council was established by
        Executive Order,  the President designated the Secretary of Health,  Education, and
        Welfare as Chairman of the FRC. In the same press release announcing this decision,
        the President directed that the Department of Health,  Education, and Welfare intensify its
        radiological health efforts and have primary responsibility within the executive branch for
        the collation, analysis, and interpretation of data on environmental radiation levels such
        as natural background, radiography, medical and industrial use of isotopes and x-rays
        and fallout, so that the Secretary of Health,  Education, and Welfare may advise the
        President and the  general public. Although not specifically stated in Reorganization Plan
        No. 3 of 1970, these responsibilities were also transferred from DHEW to EPA.

    •  Authority  transferred  from the Atomic  Energy Commission to establish  generally
        applicable environmental standards for the protection  of the  general environment from
        radiation and radioactive materials.
                                          20

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                                    Table  6
                     RADIATION  PROTECTION AUTHORITIES
                              OF  EPA STANDARDS
o  Reorganization Plan  #3                  o  Federal  Water Pollution
                                               Control Act of 1972,
        General Radiation Protection               as amended
        Guidance  Function for Federal
        Activities (42  USC 20221  (H))             Effluent,  Water Quality,
                                               Toxic  & Hazardous Material,
        Generally  applicable                      &  Federal Facilities for
        Environmental Standards                  Radiation Discharges  in
        Outside AEC-Licensed                    Water
        Facilities
                                          o  Clean Air Act of 1970
o  Ocean Dumping Act of 1972
                                               Ambient &  Emission Standards
        Radiation  Wastes                         for Radiation  Discharges

                                          o  Safe Drinking Water Act of  1974

                           TECHNOLOGY ASSESSMENT

o  NEPA - Section  102 (C)                 o  Federal  Water Pollution Control
                                               Act of 1972,  as amended -
o  Clean Air  Act  of 1970 -                      Sections  301  & 304
    Section  309
                                               Best Practicable & Best
                                               Available  Technology

                                  MONITORING

o  Reorganization Plan  #3                  o  Public Health  Service Act
                                               (42 USC  241) - Section 301
o  General Federal Guidance (FRC)

                      TRAINING & ASSISTANCE TO STATES

o  Reorganization Plan  #3                  o  Public Health  Service Act
                                               (42 USC  243) - Section 311
                                       21

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     Under these authorities, EPA acts as the Federal "overseer" of radiation  protection
philosophies,  policies, and controls.  In this respect, EPA has broader responsibilities in the
radiation area than it has in other environmental areas for it may consider public health protection
related not only to the environment, but also to healing arts and occupational exposures.

POLICIES AND DECISION  ISSUES

     EPA has the responsibility for directing its resources and expertise to problems that can
provide the greatest public protection for the nation from the perspective of reducing adverse
health impact while maintaining a proper socioeconomic balance. Implementing this responsibility
is difficult because of the technical complexity of the radiation problems, the delineation of the
relative roles and responsibilities of various Federal agencies, and the degree of interface among
Federal, State, and local governments in certain areas. However, in  order to most effectively
direct the Agency's resources toward the control of radiation hazards, the following basic policies
have been established to direct the national radiation protection program strategy.

ACCEPTANCE OF THE  BEIR HEALTH  RISK ESTIMATES

     It  has been concluded that  for EPA's radiation standard-setting responsibilities, it is prudent
to generally accept the linear, nonthreshold hypothesis as a dose effect  relationship for assessing
health impact in the dose level range of primary concern. However, where specific evidence for a
dose-effect relationship does exist then EPA will use the more appropriate relationship. Delaying
programs until all uncertainties are resolved by expensive and long-term research would not be in
the best public interest for many activities.

ACCEPTANCE OF A BENEFIT-RISK-CONTROL-COST APPROACH

     The health risks  incurred by radiation exposure are most frequently associated with some
individual or social benefit the  radiation use or application  affords.  For this reason it is not
necessarily prudent to establish radiation standards or other control measures based on some
"acceptable" degree of health risk alone. Rather, the benefits attributable to the radiation use or
application must be at least qualitatively examined as being more advantageous to individuals or
society than any health risks estimated from the exposure. In many cases where the benefit of an
activity is determined to warrant the risk, it might be found that for an incremental cost increase for
additional controls over the radiation releases, a large reduction in health risk could be achieved.
In such instances the cost of additional control versus the reduction in risk achieved must also be
considered and evaluated.

ESTABLISHMENT  OF  SPECIFIC PROGRAM PRIORITIES

     In order  to allocate resources in the best possible  manner it is necessary to develop a
priority-setting methodology to  weigh the various radiation  problems and establish a general
scheme of  relative priorities. The priority setting methodology employed both qualitative and
quantitative analysis  through consideration of six  basic factors as  shown  in Table 7. This
methodology was applied to the overall  problem of radiation protection and the results of this
application are described in subsequent sections.

TYPES AND APPLICATIONS OF STANDARDS

     Generally, there  are three  kinds  of standards (standards is used  here as a generic word);
namely, scientific and technical, industrial, and  regulatory. Examples of scientific and technical
                                         22

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                                 Table 7
      FACTORS  DIRECTING  THE  PRIORITY-SETTING METHODOLOGY
The  range  of potential health  effects  and the  extent of potential environmental dose
commitments from various activities and sources.
The degree and probability of health risk associated with accident situations.


The overall national costs to reduce health risks versus the magnitude of the reduction.
The type of control  function  available (i.e., guidance, standards, enforcement) for each
problem and the EPA role in the application of the controls.
The degree of EPA discretion in the magnitude of resources applied.


The magnitude of public awareness and concern.
                                    23

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standards are the recommendations for radiation protection established by the National Council
on Radiation Protection and Measurements, and the International Commission on Radiological
Protection. Industrial and professional standards are established by groups like the American
Nuclear Society and the American National Standards Institute for the purpose of obtaining some
specific benefit to the group  members although general society may benefit as well.  Estab-
lishment of standardized reactor parts is an example of this type of activity.

     Regulatory standards are legal, enforceable enactments by Government (including State
and  local) agencies which are directed  to  protection  of the public from various detrimental
impacts. There are  two types of regulatory standards - permissive and restrictive.  Permissive
standards are established by Government to enable particular activities to operate in the public
interest, such as activities where Government intervention of financing is involved, like nuclear
energy. Regulations and standards set in this regard are controls to protect the public health,
safety, economic  interests, etc. Restrictive standards are established by Government solely to
protect the public from adverse action from a variety of causes. The interests of the agencies that
establish these types of standards are evidenced in that a permissive regulator tends to ask dis-
senters to identify and quantify any actions that may have detrimental effects on society whereas
a restrictive regulatory standard asks the promoter of the action to prove the opposite, namely, no
detrimental effects resulting from the activity above the level set by Government.

     While the medical, natural, and nonionizing radiation areas do not have both permissive and
restrictive regulators, like nuclear energy, they do have all three types of standard-setting bodies.
To provide effective coordination among these bodies requires that one Federal agency exert an
overview role with respect to public health and environmental protection. That responsibility lies
with EPA.

OVERVIEW RELATIONSHIP WITH  FEDERAL AGENCIES

     EPA  is emphasizing the Federal  radiation protection overview  role provided by the
authorities of the  Federal Radiation Council transferred to EPA by  Reorganization Plan #3 of
1970. This role has  been carried out in a coordinated manner by formation of a number of inter-
agency committees to address specific problems that are of mutual concern to the involved
agencies. This approach is being pursued in the areas of medical x-rays, occupational exposures,
Plutonium cleanup and restoration, management of radioactive wastes, and publication of the
Annual Report on Radiation Protection Activities. The exercise of EPA authority to set generally
applicable radiation  protection standards requires other Federal  agencies to implement or
enforce EPA's standards and guides  under other authorities. EPA is responsible for enforcing
standards such as those set forth under the FWPCA, Clean Air Act, and Ocean Dumping Act. In
the case of Federal Guidance, it is up to the Federal agencies to  adopt the guidance  and to
establish enforcement procedures. Thus, in establishing this relationship, it will minimize Federal
duplication and maximize the effectiveness of all Federal radiation control programs.

     Radiation research requirements fall into two categories: research programs and operational
programs. The research programs fall under EPA's Office of Research  and Development, and
operational programs are conducted under the direction of the Office  of Radiation Programs. This
split  is similar  to the research programs undertaken by the ERDA and confirmatory research
undertaken by the NRC. The  EPA research and operational needs are developed by means of a
matrix analysis  which identifies  radionuclides of public  health  concern and  sources of
environmental  radiation in relation to specific research, laboratory efforts, and field studies. Such
a technique not only identifies the specific research and operational needs, but also provides a
means to take into account radiation research  efforts by  other Federal agencies. This
                                          24

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coordination eliminates duplication of efforts and identifies complementary research needs. In
this manner,  not only does the Office  of Research and Development provide response to
identified research  needs,  but to ERDA and NRC research programs  as  well. An operating,
working relation with ERDA and NRC has been established to implement coordinated research
undertakings.

    Nonionizing radiation research is carried out by FDA/BRH, DOD and EPA. The BRH efforts
are directed toward research needed to set equipment performance standards. EPA's efforts are
oriented toward ambient and environmental and health effects, and DOD's efforts are directed
toward research on  bioeffects.

    In attaining coordination of activities, each  Federal agency must retain  its legislative
mandates, independence of action, and own points of view. Nevertheless, mutual understanding
of commonalities and differences in all areas and interchange on technical  levels should not in
any way compromise the respective roles of the involved agencies.

DEVELOPMENT  OF  WORKING  RELATIONSHIPS WITH STATES

    A key aspect to the radiation program is the acquisition of information  developed by State
radiation control agencies to use in standard-setting activities and environmental assessment
projects, such as the Environmental Radiation Ambient Monitoring System (ERAMS) and ORP's
annual State  of Environmental Radiation Report. In this regard, the EPA radiation program is
highly dependent upon  the EPA Regional Offices who have primary contact  with the States
themselves.

    Further,  in certain areas, such as medical x-ray guidance, where EPA guides apply only to
Federal agencies, the effectiveness of these guides on a national basis  is dependent upon the
willingness of the States to accept and promulgate them. At present, only State laws exist in these
areas and promulgation of standards and their enforcement rests with the States. Consequently,
in many radiation areas the  Agency's national impact is directly related to its technical and policy
credibility with the States. This credibility can be acquired only through working closely with our
Regional Offices, the States, and the Conference of Radiation Control Program Directors, Inc.,
Gointly sponsored by EPA, DHEW and NRC) to identify radiation problems, develop solutions, and
assist the States in the implementation of the solutions.

POINTS  OF EPA INFLUENCE

    In order to exercise its responsibilities wisely, EPA must examine the points in the exposure
chain  where EPA influence and control will be most useful. Because of the different sources and
uses of radiation, a variety of groups receive exposure. The most significant of these are:

    Persons exposed in their work environment, such as uranium miners, x-ray technicians, and
    nuclear facility workers.

    Patients exposed in diagnostic or medical treatment.

    Persons exposed because they live near a radiation producing activity, such as a nuclear
    facility.

    The general population which is exposed to an accumulation of sources and activities.
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     The best approach in controlling pollutants is to curb them at the source and not allow them
to enter  the  environment. However, in  many  cases this is  not practicable  because of cost
constraints, environmental mechanisms  which concentrate pollutants, or other technical  and
societal reasons. Therefore, in these cases it is necessary to examine the complete pathways of
radiation  flow from the source through the environment and finally to the recipient. In doing this, all
significant factors which  affect the eventual  health impact  can be  identified and from this,
appropriate controls developed and applied to the most significant point or points in the chain.
Figure 2  depicts the generalized flow of  potential radiation exposure through  the environment.
From the example shown in the figure, it can be seen that each source type can have different
situations, a different mechanism of release, be related to a variety of radionuclides, enter the
environment in different modes, and as previously indicated, have impact on different recipients. It
is this multiplicity of potential flow patterns that increases the complexity of the radiation problem.

     In many cases, control at a single point  in the flow will not provide adequate radiation
protection or could be too costly  or socially unacceptable to implement. Although EPA will
consider  such single point controls as siting criteria, protective action guides, specific radionuclide
standards, and occupational exposure guidance, to be most effective, multiple  point controls will
have to be implemented for the total flow pattern in many cases.

THE MANAGEMENT PLAN

     The problem  of  radiation  control is  multifaceted  with  technical, social, economic,  and
institutional aspects. Consequently, to arrive at satisfactory solutions, the work program must
address all these facets. Managing such  a broad-based program is a difficult and complex task.
To bring order to this situation, and also to provide for flexible management of resources, a matrix
of program interaction is depicted in Figure 3. This system will insure that each  radiation problem
is properly involved with four functions, as follows:

     1.   Emerging  radiation producing activities must be studied and  the problem defined  and
identified to determine future courses of  action to control the source and provide public health
protection.

     2.   Environmental quality information must be acquired  and analyzed so that the  current
status of the environment can be determined. When this status is  compared to the  quality
determined to exist a few years ago, projections can be made of future trends and emerging
problems defined.

     3.   Technologies using radiation must be assessed to determine if they are having adverse
impact on human health and the environment and whether it is feasible to reduce this impact.

     4.   Radiation standards, criteria and guides are prepared  using best available information to
make an analysis of controls, health effects, cost/risk estimates and economics. This results in
specific standards and promulgation by due process. An EIS  is also prepared and the resulting
standard, guidance or criteria published in the Federal Register.

     These four functions comprise the responsiblities of the EPA  radiation control program
regardless of the type of source or use under consideration. These functions also represent the
basis of  resource allocation, as well as the lines along which headquarters  components  are
organized to allow it to function as a unified program. A fifth function, assistance and support, is
composed of service activities necessary to tie the control  program together and allow  it to
function  as  a unified program  for identification of problems,  analysis of their  significance,
                                          26

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PROGRAM INTERACTION
       FIGURE 3
        28

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establishment  of  controls,  measurement  of  compliance,  and  maintenance of emergency
response capabilities.

     ORP has initiated a Work Breakdown Structure (WBS) type of management control system.
This system breaks down the overall problem of radiation protection into component areas and
assigns responsibility for work in each area (along with time schedules, manpower commitments,
and specific work outputs to be accomplished). Such a procedure facilitates systematic assess-
ment and rapid recording of monthly inputs from the operational organizations and provides a
mechanism for prompt feedback of any resulting program changes that may occur.

THE OPERATIONAL PROGRAMS

     Analysis of all the sources and points of influence in Figure 3 was used to break down the
radiation protection program into three discrete operational program areas: criteria and standards,
technology assessment, and environmental assessment. Within each of the areas,  specific
projects are conducted to meet the program objectives on a timely basis and are classified as high
and medium priority. The priorities  are basically set by addressing those areas in which health
effects reduction can be most effectively implemented. Such priorities are modified based on the
need for standards, guidance, and criteria as expressed by other Federal agencies and the public
and on the ability of EPA to constructively contribute to resolving the problems. In conduct of its
operational program ORP relies on its Eastern  Environmental Radiation Facility and Las Vegas
Facility located in Montgomery, Alabama,  and Las  Vegas, Nevada, respectively, to provide
technical support and field study capability to the Headquarters Division projects. The program
areas and related major projects are described below.

CRITERIA  AND STANDARDS

     The purpose of this program is to protect, cost-effectively, the health and welfare of man and
the environment from adverse effects due to radiation exposure and in balance with the benefits
of the particular radiation producing activity. There are potential  sources of radiation exposure
where existing controls are deficient or non-existent and where there is a  need to promulgate
generally applicable  radiation protection standards to provide this protection.  Federal Radiation
Guidance is being developed for certain areas  where there is a demonstrated need to use the
Federal Radiation Council transferred authority. Such guidance to  other  Federal agencies
provides  the technical basis for reducing  unnecessary  radiation exposure  and keeping the
exposure of the general public "as low as reasonably achievable." Other activities for protecting
cost-effectively the health and safety of the public are carried out under the authorities set forth
under the Safe Drinking Water Act of 1974, the Ocean Dumping Act of 1972, as  amended, and the
Federal Water Pollution Control Act  of 1972, as amended.

     High Priority Projects

        Uranium Fuel Cycle Standards

     The objective is to promulgate standards for levels of planned releases that meet acceptable
public health and environmental criteria for the total light water reactor fuel cycle such that con-
tinued operation of the industry is acceptable.

     Proposed standards have been published in the Federal Register and  an accompanying
environmental  impact statement has been issued. Public comments are being evaluated, public
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hearings will be held to elicit additional information, and the standards will be developed in the
latter part of FY-76.

        Environmental Plutonium Standards

    The objective is to determine health impacts from exposures to levels of radioactivity from
Plutonium and other transuranic elements; to develop standards for cleanup and resotration of
already contaminated areas; and to develop  standards for  plutonium releases  based on
controlled containment philosophy. Release of long-lived radionuclides represents a long-term
commitment and control  is only practicable at the point of release. Representatives from ERDA,
NRC,  NASA, DOD, State, DOT,  DOI, DOC, and EPA have been appointed to an interagency
committee chaired by EPA. This committee will supply information inputs, will assist in evaluation
of data, and will act in an advisory capacity in the preparation of guidelines, criteria, and standards.

    Public hearings have  been held to  solicit technical information  and  viewpoints, and  a
technical "Statement of  the Problem" and several analyses  have been prepared to define the
scope  of the problem. The project outputs include: (1) analysis of  available data on biological
effects of  inhalation, ingestion, or other exposure to plutonium, and development of a model of
damage function versus body or organ, (2) cleanup, restoration, and occupancy guidelines to be
completed during FY-76 and issued in FY-77, (3) development of  a "controlled containment"
philosophy by the end of FY-77 for use in regulation to keep future additions of plutonium to the
environment at an absolute minimum, (4) development of preliminary guidelines for LMFBR,
defense-related  facilities,  and for commercial  applications of  plutonium in  FY-77,  and (5)
development of generally  applicable environmental  standards for plutonium in  FY-77 and
issuance in FY-78.

        Natural Radioactivity Guidance

    The objective is to define the extent of the problem by assessment of the factors involved
and determine means for implementation of controls for naturally-occuring radioactive materials;
such as uranium, thorium, and their radioactive decay products. Potential sources of population
exposure are: (1) ore mining and milling, (2) phosphate fertilizer industry, (3) building materials, (4)
fossil fuels, (5) ground water, and (6) other industrial activities. The possible need for legislation
and radiation protection guidance will be determined depending upon the findings.

    EPA  is continuing field studies at inactive uranium mill sites to determine the radon emissions
and to verify the dose  model for estimating population dose from uranium  mills. ERDA,  in
cooperation with EPA, is  investigating methods and techniques for stabilizing uranium mill tailings
piles.

    The radiation exposure from the phosphate rock mining and milling industry is a new area
requiring studies to verify the scope of the  problem. Because the phosphate fertilizer business is
growing rapidly, EPA is assessing the environmental problem and determining  effectiveness  of
control options  to prevent any  potential excessive  exposures.  Interim guidance is under
preparation.

    Major outputs from these and longer-range programs include: (1) field studies and analyses,
and issuance of uranium and thorium  mining and milling effluent guides in FY-76; (2) phosphate
findings and policy statement in FY-76; (3) study of radioactivity in coal in FY-76, and (4) study  of
construction materials in  FY-77.
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        Protective Action Planning Guidance

     The objective is to assess the environmental consequences of unplanned nuclear releases
from fixed facilities  and to  develop protective  action guides for use in emergency response
planning for such incidents. As part of an interagency task force on nuclear incident planning for
fixed facilities and transportation, EPA has provided interim numerical dose guidance on when
protective actions following a nuclear incident are warranted, and  interim guidance on  what
protective actions would be applicable. EPA also has issued a manual on this subject, which
provides guidance on planning for accidental gaseous releases. Major outputs in FY-76 include
issuance of additional  sections  of  the manual containing  guidance  on airborne particulate
materials  and  preparation  of the  Interagency  Task  Force report  on Off site  Emergency
Instrumentation Systems. In FY-78 and FY-79, Federal  Radiation Protection Guidance will be
issued for food and water, and  property and equipment.

        Radiation Criteria and Drinking Water Standard

     The objective is to preserve and restore the quality of water used in the United States. The
Adminstrator has mandates under the Federal Water Pollution Control Act of 1972 to develop
criteria for the radiological quality of ambient waters and under the Safe Drinking Water Act of
1974, to develop drinking water  regulations to protect health to the extent  cost-effectively
feasible.

     Draft Water  Quality Criteria  have been supplied  to the Office  of Water Planning and
Standards, and Interim Primary  Drinking Water Regulations were  published  in  the Federal
Register on August 14,1975. Final Interim Regulations will be published in the Federal Registerm
FY-76. Promulgation of Primary Regulations is scheduled for FY-77 following a study and report to
the Administrator by the National Academy of Sciences.

        Medical X-Ray Guidance

     The objective is to reduce the doses being received from medical diagnostic radiology (at
least 90% of the total man-made radiation dose to which the population is exposed) without jeop-
ardizing diagnostic effectiveness.

     EPA's approach  in this  program is  to  work cooperatively  with other Federal agencies
concerned with x-ray exposures to the population. An Interagency Committee, chaired by EPA,
has been established to develop guidance applicable to Federal health care programs on optimal
procedures to assure that the radiation dose, from exposures, is as low as reasonably achievable
while maintaining desirable image-quality  and  concomitantly to assure the efficacy of  such
procedures. The FDA/BRH is  responsible for programs to reduce unnecessary patient exposure
by setting performance standards for medical x-ray equipment.

     In FY-76,  detailed proposed guidance to Federal health care programs will be prepared and
published in the Federal Register. In FY-77, public comments will be reviewed and final guidance
will be issued.

        "As Low As Reasonably Achievable" Guidance

     The objective  is to develop methodology guidance for use in  quantifying  "as  low as
reasonable" levels of radiation exposure. Effective consideration of ALRA involves judgments or
trade-offs  between public health  considerations, cost of effluent controls, and overall benefit
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considerations. EPA is preparing  proposed methodology guidance  in order to  insure proper
interpretation and implementation by Federal agencies. It will be published in the Federal Register
for comment in FY-76 and final guidance will be issued in FY-77.

     Medium Priority Project

        Occupational Exposure Guidance

     The objective is to update and revise the original  FRC guidance on occupational exposures
to take into account new information, source problems, and perspectives which have emerged
from increased nuclear energy applications.

     In carrying out  this program, EPA has established the Interagency Committee on Federal
Guidance for Occupational Exposures to  Ionizing Radiation. In addition to  EPA, membership
consists of representatives from the following Federal agencies: ERDA, NRC, DOD, NASA, DOT,
DOI, and NBS. Consultants and representatives from other public and private sources also will be
used.

     The basic approach will be to evaluate information on exposures, their trends and resulting
effects, and the involved social and economic factors in updating the guidance.  Major outputs
include completion of draft guidance in FY-76,  publication of proposed  guidance  in the Federal
Register'^ FY-77, and issuance of final guidance in FY-78.

     Low Priority Projects

        NPDES Permits for Radioactivity

     On December 10,  1974, the United States Court of Appeals, Tenth Circuit, vs. the Fort St.
Vrain Nuclear Power Plant Case (Colorado Public Interest Research Group vs. Train) ruled  that
the EPA must control radioactive discharges under the provisions of the Federal Water Pollution
Control Act of 1972, as  amended. In essence, the decision states that EPA's legal interpretation
was too narrow and instead should include all  radioactive material. This decision by the Tenth
Circuit Appeals Court has been reviewed by the Justice Department and sent by the U.S. Solicitor
General to the Supreme Court. Arguments on this case were heard  by the Court in December
1975. Depending upon the Court's decision, the priority of this project could change.

     ORP activities in this area are to develop water effluent guidelines as required  to comply with
the court decision. This requires ORP, through the Water Program, to: (1) issue permits in a timely
manner, (2) ensure permit conditions reflect quality technical considerations, and (3) minimize
unnecessary duplication of Federal regulatory restrictions. Priorities for meeting these objectives
have been established as a function of the  magnitude of the insult, potential for delaying national
energy requirements, availability of technical data, and the status of pending permit applications.
In the event of the Federal Government losing the case, first priority will be given to  nuclear power
reactors. Priorities for other facilities have been established and plans are being developed to
implement the program for such facilities depending on  resource allocation. Included in  this
program is the responsibility for operating a monitoring program and assuring overall compliance.

     In addition, it may be required to list some radioactive materials  as toxic substances under
Section  307 of the  FWPCA and  designate such  materials  as hazardous under  Section  3II.
However, as a high priority effort, discharge permits for radium in surface water are being issued
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by the Regional Office's Enforcement Division in  a cooperative effort with ORP Regional
Representatives.

TECHNOLOGY ASSESSMENT PROGRAM

     The purpose of the program is to assess nuclear energy applications and documentation for
EPA's radiation protection standards and to prepare technical guidance. The programs of other
Federal agencies are influenced to assure protection of the environment and public health by
review of their environmental impact statements,  regulations, and  proposed legislation as
required by the National Environment Policy Act, Section 309 of the Clean Air Act of 1970, and
Section 511 of the Federal Water Pollution Control Act of 1972, as amended. Advanced reactor
systems and new applications of nuclear energy are evaluated on a case-by-case basis to learn in
the  development  stage about  potential  environmental  radiation  problems.  From  such
assessments EPA's position on the environmental and economic impact will evolve.

     High Priority Projects

        Radioactive Waste Management

     EPA's goal for the management of radioactive wastes is to assure that no unwarranted risks
are imposed upon  present  or future generations through the establishment of environmental
criteria for all aspects of the management process.

     The objective is to assure that the storage and disposal of all radioactive waste materials is
implemented in a manner to ensure effective isolation of the wastes from the biosphere during
their hazardous lifetimes. All radioactive wastes are included; i.e., high-level, low-level, and alpha
particle wastes from the nuclear industry; wastes containing natural radioactivity, and wastes re-
sulting from the decommissioning  of  nuclear facilities. In carrying out its radioactive waste
management effort, EPA is working with NRC and ERDA to coordinate Federal activities in the
development of an integrated  national  plan for the management of radioactive wastes.  Federal
agencies with major efforts or responsibilities in waste management have agreed on the need for
a coordinated  Federal program. In addition, ORP will work quite closely with the EPA Office of
Solid Waste Management Programs and other appropriate EPA organizations in this activity.

     Outputs in FY-76 include evaluating methods for shallow land burial for low-level wastes and
deep emplacement in land or ocean for both low- and high-level wastes. Studies will be conducted
involving radiological monitoring, waste container technology, site characterization, and food
chains to man. EPA also is  responsible  for acting  on requests  for ocean disposal  permits
domestically and representing the United  States internationally as the lead Federal agency at
IAEA meetings concerned with the ocean dumping of radioactive wastes.

     EPA is participating  in  the development of a national waste management plan and has
provided other Federal  agencies with a  proposed criteria for Federal  Waste  Management
Activities. In FY-76 efforts will be directed towards defining the responsibilities of the agencies for
developing specific criteria and plans for gathering the necessary information. EPA's efforts will
focus on developing the overall rationale to be used for determining environmental  acceptability
and defining the levels of release which would indicate that remedial action should be taken.

     In FY-77,  decommissioning criteria  will be  developed for facilities operating or  under
construction and for future  facilities.  In FY-77, FY-78  and  FY-79, environmental  criteria and
guidance will be developed for disposal of low-level wastes, TRU wastes, high-level wastes, alpha
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wastes and natural radioactivity. Monitoring requirements will be established for these categories
of waste to provide technical guidance to NRC and States for enforcement of the regulations.

        Environmental Impact Statement Reviews

     The objective is to  provide comprehensive technical reviews of environmental  impact
statements (EIS) for facilities and programs which have a potential radiological impact. Through
this activity potential environmental radiation problems are identified and comments submitted on
the draft EIS so that there is time to modify the facilities and/or programs to prevent or minimize
such problems cost-effectively.

     EPA  Regions are now in the process of implementing  Agency policy of  assuming the
complete responsibility for reviews of environmental impact statements for conventional light
water nuclear power plants. EPA Headquarters will update EIS review guidance as better dose
models and data become available and will continue to work to resolve generic issues and, as
required, will provide policy guidance on generic issues.

     Outputs for FY-76, FY-77 and FY-78 include review and  analysis  on  non-routine
environmental  impact statements. In addition, ORP will work with the Regions and the Office of
Federal Activities to develop guidelines for interaction with NRC under the Second Memorandum
of Understanding between  EPA and NRC. This procedure will enable EPA to fulfill its  NEPA
responsibilities as required under the Federal Water Pollution Control Act of 1972, Section 511 for
new source permits.

        Environmental Impacts of Operating Facilities and of New Technology Projects

     The objective is to  evaluate  the effectiveness  of radioactive effluent control systems
currently in use and to compare the environmental impacts of nuclear and non-nuclear energy
projects for use in supporting standards and in evaluating EIS's.

     In addition to information being supplied by the EPA Office of Research and Development, in
FY-76 ORP is preparing technical information documents on effluent control systems, reviewing
standardized reactor designs for generic applications management facilities, and is preparing
technology performance  reviews for confirmation of predictive evaluation techniques with
operational data. In FY-77, ORP will  prepare a summary evaluation of advanced reactor energy
systems and of some non-fission energy systems and will evaluate the potential environmental
impacts of advanced nuclear energy systems.

     Medium Priority Projects

        A ccident Analysis

     The objective is to review safety considerations for nuclear fuel cycles and to assess the
environmental  and public health  implications of possible accidents. This effort will be directed
toward examining the available information on equipment failures and nuclear incidents severe
enough to cause potential release of radioactivity, with emphasis on the probability of such events
and their potential consequences. Although previous efforts have been concentrated on severe
accidents, the whole  range of potential  inadvertant releases of radioactive materials will be
considered, so that each class of release can be properly weighed. To date, EPA has completed
contract studies on accident risks from non-nuclear, man-originated activities and on potential
risks from a generic fuel reprocessing facility.
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     Major outputs will include: review of the Reactor Safety Study (WASH 1400) in FY-76; and in
FY-77 and beyond,  preliminary examination of low-consequence/high probability accidents to
consider their contribution  to overall reactor risks and  evaluate techniques for  determining
acceptable levels of risk; examination of the risks associated with other nuclear technology appli-
cations; and comparison of safety implications of advanced reactor systems. Related efforts will
be directed at relative risk determination at real  sites with respect to emergency response
planning.

        Plutonium Recycle Evaluation

     The objective is to determine technically the potential radiological impact of the proposed
use  of recycled  plutonium  in light-water reactor fuel. The  need for  additional standards or
guidance, beyond the proposed uranium fuel cycle standards, will also be considered.

     Licensing by NRC will be required for commercial use of plutonium in the reactor fuels, even
in LWR's already licensed for full power operation with uranium fuel. EPA is concerned with the
potential changes in reactor technical specifications and operations to accommodate plutonium
bearing fuel and  with the potential environmental impact from plutonium fuel fabrication facilities
as they progress from small scale laboratory-type facilities to large-scale industrial facilities and
operations.  In evaluating this problem, and  consistent with the EPA approach in handling the
overall environmental plutonium standards program, close coordination will be maintained with
other Federal Agencies  through the established interagency plutonium committee. A detailed
standards development program with  milestones will be specified after NRC decides whether to
approve the commercial use of plutonium recycle, and will  be based  on EPA's independent
analysis of the need for any additional standards.

        Liquid Metal Fast Breeder Reactor (LMFBR) Evaluation

     The  objective  is to maintain  up-to-date technical expertise in the developing LMFBR
technology and to consider the need  for additional standards or guidance for potential LMFBR
fuel cycles.

     EPA has reviewed and commented on a draft EIS for the initial LMFBR demonstration plant
concept and on another draft and proposed final EIS for the overall proposed LMFBR program. In
addition, EPA has reviewed and commented on the draft generic EIS on low ratio (4%) plutonium-
uranium mixed oxide facilities and operations  in  conjuction with the  LWR plutonium  recycle
program.

     During FY-76, the review of the final LMFBR Program EIS will be completed, as well as the
EIS review of the  Clinch River Breeder  Reactor Demonstration  plant. These reviews, supported by
information developed by EPA and through  contracts, will provide the major technical support
required for a decision on the need for EPA to propose and issue LMFBR fuel cycle standards or
guidance for facilities and operations involving high ratio (16%) plutonium-uranium oxide mixtures.
The need for any  additional information, and a development plan with milestones, will be specified
at this decision point. Subsequently, depending on technology developments, similar decisions
may be needed for fuels containing plutonium carbides and plutonium nitrides.

        Transportation Guidance

     The  objective is to evaluate  the accident hazards of  shipping radioactive material via
different modes of transportation, and to provide guidance for protection of passengers and the
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public. Results of this program will be factored into other ORP programs concerning generally
applicable environmental standards, Federal radiation guidance, accident risk assessment, siting
criteria, and emergency response planning.

     To date, recommendations for the radiation protection of passengers on aircraft have been
completed and  sent  to FAA; and studies have been completed on accident hazards, and on
routine exposures to the public, from shipments of radioactive materials in the uranium fuel cycle.
In FY-76, decisions will be made on the desirability of requesting EIS's on cask licensing and on
the need for Federal radiation guidance on transportation of radioactive materials.

        Siting of Nuclear Facilities

     The objective is  to develop the methodology for determining the criteria needed to evaluate
the environmental acceptability of proposed sites from a radiological perspective for nuclear
power plants, for nuclear energy centers, and for advanced nuclear energy systems.

     Based on ORP's accident analysis effort on the assessment of the potential impacts of
accidental releases from nuclear power plants, and additional information concerning long-term
as well as short-term effects from normal releases, ORP will make continuing evaluation of NRC's
siting criteria. ORP is actively participating in interagency efforts relative to the siting of nuclear
facilities and in the NRC-sponsored State-Federal Siting Committee. An  EPA position relative to
nuclear facility siting will be recommended when sufficient information is available.

ENVIRONMENTAL QUALITY ANALYSIS

     The objective is to determine individual and population doses from all sources of ionizing and
nonionizing environmental radiation. The gathering of such a total radiation data base is unique to
EPA. The rationale for analyzing environmental radiation in the most  cost-effective manner is to
maximize the use of available data reported by others and validated by EPA. Information from this
program  is used by  EPA in  five  ways: (1) to analyze trends in environmental radionuclide
concentrations, (2) to identify radiation problems, (3) to support standard setting activities, (4) to
provide guidance for public health protection, and (5) to provide public information. One output of
this program is the publication of an Annual Report on Radiological Quality of the Environment. In-
depth reports evaluating the radiation exposure from individual classes of sources and guidance
in the conduct of surveillance and surveillance data analysis are also issued.

     High Priority Projects

        Nonionizing Radiation Guidance

     The objective is to determine the health  and environmental impact of radiofrequency and
microwave radiation  in order  to assess  the need for providing  guidance  for controlling
environmental exposure to such radiation.

     Field measurements  at  three major  metropolitan  areas  are being made in FY-76 with
measurements at three additional areas in FY-77. In parallel, information  that can be obtained on
biological effects of various levels of nonionizing radiation will be assessed and any necessary
proposed guidance will be developed during FY-77 and FY-78, with issuance of final guidance in
FY-78 or FY-79. Throughout this entire effort, interagency liaison and cooperative efforts will be
carried on with  other cognizant activities, such as OTP-ERMAC-IRAC, OSHA, BRH, ANSI, and
IEEE.  Field studies  have  been initiated to measure and evaluate  health and environmental
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impacts from extra high voltage power transmission lines. A notice published in the Federal
Register solicited  information  on environmental impact,  health effects, and instrumentation
techniques evaluations associated with extra high voltage (EHV) power transmission lines. An
analysis of this information in 1976 will assist in determining the scope of the problem. EPA plans
to complete  field  studies in 1976  at selected  EHV power transmission  lines to measure
environmental parameters and assess the potential health problem.

        Environmental Radiation Ambient Monitoring System (ERAMS)

     The purpose  is to operate a comprehensive  and coordinated system to determine the
ambient levels of radioactivity in the environment. Sampling  locations  are selected to provide
coverage of the United States. The frequency of collection and types of laboratory analysis has
been determined by cost-effective analysis of data requirements. The  environmental radiation
data from this project will be  made available  to the public  in a quarterly report  and will be
summarized annually in the State of the  Environmental Radiation Report.

     The ERAMS  and special studies conducted at operating nuclear facilities are the only
independent  assessment of environmental radiation and estimates of population exposure
carried out as a continuing activity outside of the energy producing industry.

        Radiological Quality of the Environment

     The objective is to publish  an annual report of radiation in the environment beginning with
data from calendar year 1973. The first report will be a prototype for future reports in that it will
primarily describe the available data base and present dose information estimated by others. For
subsequent reports, additional  data  will be included on reported environmental contamination
levels and ORP estimates of  population  dose from  this data. The  first  report will contain
information on ionizing radiation in the ambient environment from natural sources and from fallout,
nuclear fuel cycle  operations, Federal facilities, medical, occupational and industrial sources.
Nonionizing radiation sources will also be included. This report, in conjunction with the report on
Radiation  Protection Activities  in the U.S.-1975,  will provide a comprehensive evaluation of
radioactivity in the environment and indicate trends and problems.

     Medium Priority Project

        Facility Data Analysis

     The objective is to develop techniques for data analysis and to apply these techniques to
evaluate facility surveillance programs. Based on these findings updated surveillance guidance
for use by facilities, States, and others will be prepared. This guidance would include all aspects of
surveillance programs from sampling methodology, to sample preparation and analyses, to data
reduction, interpretation, reporting, and quality assurance.

     The project output includes (1) develop ambient criteria in FY-76, (2) develop data analysis
methods in FY-76, (3) complete prototype study of a selected facility in FY-76, (4)  develop
surveillance program  evaluation criteria,  (5) acquire data and analyze several facilities for
completion in FY-77, and (6) prepare surveillance guidance in FY-78.

RADIATION REGIONAL PROGRAM

     The role of the Regional Offices in  the radiation program is a combination of prime functions,
some general activities, a national regional output and some specific outputs related to radiation

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problems unique to each region. A prime activity is the regionalization of routine nuclear power
plant EIS reviews which was initiated in FY-76 and should be operational in FY-77. This activity
requires involvement of the Regional Offices on a frequent basis with national programs that have
an impact at the State and  local  levels. Technical and program consultation with States is a
continuing effort directed toward the goal of greater State self-sufficiency in the environmental
radiation protection area. This applies particularly to those States that are developing capability to
assume responsibilities in implementing the monitoring provisions of the Safe Drinking Water Act
of 1974.

    The  radiation   protection program  strategy  provides  for  centralized  headquarters
management of priority projects for standard setting, technology assessment and environmental
assessment. To the maximum extent possible the Regions and States are requested to partici-
pate in the development of standards to assure that their views have been adequately considered.
In this approach, specific problem  area requirements and resources may be assigned to certain
Regions on a case-by-case basis.  As the headquarters develops specific standards and guides,
continuous study will  reveal those functions or problem areas that can  be decentralized to the
Regions. Emphasis is also being placed on coordination of, involvement in, and utilization of State
radiation control programs in the national program as a  means to effectively and efficiently
integrate environmental radiation programs. Regional-specific radiation programs are developed
through consultation between headquarters and each  Regional Office when  such programs are
related to ORP priority projects.

    Because of the  necessity to  act from a unified position on radiation issues which involve
other Federal agencies with responsibilities in the radiation area it is important that the Regional
Office coordinate with the  Office of General Council and the ORP prior to taking any action  on
Regional issues that impact on national policy.

    High Priority Projects

    Conduct the technical review and review management of routine nuclear power plant EIS's
(or other assigned technical reviews). Initiate in Fy-76 and complete in Fy-77.

    Implement the radiological portion of the EPA Drinking Water Standards in support of the
Water Supply Program. Assist States in development of their capability to assume responsibility
for implementing the Drinking Water Standards.

    Perform environmental reviews  of  radiological  aspects  of  selected  Federal activities
pursuant to E.0.11752.

    Provide the following services:

    a.  Provide technical and program consultation and assistance to States where required.

    b.  Respond to public and Congressional inquiries.

    c.  Stimulate productive functioning of Regional Training Committees to meet State training
        needs.

    d.  Facilitate and coordinate ORP activities with States.
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     e.  Participate in EIS reviews of non-routine nuclear activities to extent delegated and/or
        capable.

     Obtain, compile, and report technical information on selected nuclear and radiation facilities,
including facilities with potential naturally-occuring radioactivity problems.

     Medium Priority Projects

     Assist  States in   FY-76  in  the  development  testing,  evaluation, modification,  and
maintenance of State radiological emergency response plans, and, as warranted, promote the
development of  interstate, intraregional, and interregional emergency response coordination.
Such assistance to States will be  primarily through  Regional participation  on the Regional
Steering Committees and in the Federal Cadre operation. Particular emphasis  should be placed
on working with States to assure integration of EPA Protective Action Guidance into the State
plans.  In addition, the  Regional  Office provides Regional radiological emergency  response
coordination should an emergency occur within the Region.

     Initiate activities in FY-77 for implementation of EPA radiation standards and guidance, such
as generally applicable environmental standards for the uranium fuel cycle, plutonium cleanup
and  restoration and Federal  Radiation  Guidance in the  healing arts use of radiation and  in
occupational exposures to radiation.

     Supporting the Regional National Pollution Discharge Elimination System (NPDES) program
for those  activities involving  radioactivity (a change  in  Regional  priorities  may be required
depending upon the Supreme Court ruling in the case of COPIRG vs. Train).

RESEARCH AND OPERATIONAL STUDIES

     The radiation control  program requires a vigorous  scientific research effort. The purpose  of
research and operational investigations is to eliminate many of the uncertainties associated with
health effects  and environmental processes that currently face the program. In addition, field
studies will be directed toward evaluating technical radiation control alternatives and overall
program alternatives. It  is anticipated that the results of these studies will direct the Agency's
future radiation program thrusts and also point out specific areas where legislation is needed.

     The scientific research  program,  which covers  both ionizing  and nonionizing radiation
studies, will have its thrust in two major areas.  The first area  involves operational research  in
ecological processes and environmental transport, and investigation of  specific health effects
from exposure to radionuclides such  as plutonium, tritium and krypton.  Work in this  area  is
necessary to reduce the uncertainties in migration patterns, resuspension factors, and other
general pathway parameters. With these uncertainties reduced, more definitive action  can be
taken in preparing Standards and Federal Guidance. The second is health effects research which
will  be  primarily directed toward the establishment of definitive  knowledge in the area  of
nonthermal health effects of nonionizing radiation.

     Operational  studies  are  necessary  to  adequately  reflect  socioeconomic and  control
technology considerations in  the Agency's actions. Studies will  be undertaken in  key areas
including the following:

     Development of methodologies for risk/cost analyses.
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     Development of a basis for evaluating environmental risks associated with nuclear power.

     Comparison of the relative environmental impact of electric power sources.

     Comparison  of control alternatives for specific categories of sources and their resultant
     costs and degrees of health risk reduction.

     Examination  of the need for control in various areas  of  background  radiation  and
     socioeconomic feasibility of instituting controls.

     Determination of the viability of new equipment and technologies for controlling specific
     effluents, such as tritium and krypton, and the implication of instituting guidance of standards
     demanding their use.

     A morphological approach is being used to identify the ORP research and operational needs
for FY-77. This method will utilize information on research acitvities of other Federal agencies to
maximize use of available resources, avoid duplication of efforts, and  permit development of
complementary research programs. An operating, working relationship with ERDA and NRC has
been established to implement coordinated research undertakings.

PUBLIC INVOLVEMENT PLAN

     The final major thrust of the radiation strategy is the conduct of a program to encourage
public involvement in the Agency's  radiation protection activities and to  inform the public about
the radiation problems,  EPA's  concerns and policies. EPA  will  develop its philosophy and
rationale for its  standards,  criteria, and guides  in  a  manner that  will  openly allow  public
participation and scrutiny. Further, this approach is directed toward always explaining the EPA
radiation protection in terminology and language readily comprehensible by the public.

     In order to provide for these objectives, EPA will publish notice of its  proposed standards,
criteria and  guides in  the Federal  Register, conduct open  hearings during various phases of
standard-setting procedures, and allow public comment and input to our proposed standards and
guides.  Further, materials will be developed for use through television, exhibits, and general
distribution  to inform the  public  about  EPA's radiation  responsibilities,  programs,  and
accomplishments. The goal is to have specific pamphlets and films that  explain all facets of the
radiation control program.
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                                  APPENDIX  A
          An  Illustrative  Example of the Radiation Exposure Trends
                   in Man-Rems for  the Years 1970 and  2000
    The potential radiation exposure flows in man-rems for the year 2000 versus those in 1970 in
the United States are shown in Figures 1 and 2. These figures identify the important parameters
governing radiation exposure and graphically denote the relative importance of these parameters
to the potential radiation exposure. The data for both figures are gross  estimates to provide
comparison of trends and do not represent actual predictions of what happens. The characteristic
parameters considered are:

           Source of exposure (nuclear power, medical, etc.)

           Release mechanism (planned or unplanned)

           Mode or media (air, terrestrial/water, direct, food chain)

           Situation causing exposure (site, transportation, waste disposal)

    In Figure 1, the current  exposure case, the flow of potential exposure is shown from its
origins to the final recipients where the health impact is imposed. The flow is depicted as potential
"manrems." The purpose of the graph is to illustrate relative magnitudes and flow patterns.

    Outside the dotted line are located three major ionizing radiation sources - medical radiation,
natural radiation, and nuclear power radiation. For both medical and nuclear power, we observe
that much of the potential exposure flows from the site where the source is generated or used
through transportation as it is moved from place to place to a waste disposal site and a final sink
where it is completely removed from the biosphere. From the width of the flow lines on the graph,
it is evident that much more potential exposure flows to the sink in the nuclear power base than in
the medical case. It should  be  noted that the  medical  exposures arise primarily from direct
exposures to x-rays, i.e., the equipment (or site) whereas for nuclear power it is from radioactive
materials, primarily intakes and therefore away from the site.

    Inside the dotted boundary (which indicates the million-to-one  scale change) flow lines
indicate that there is potential exposure to various recipients through each of the situations for
medical, natural and  nuclear power sources.

    The flow patterns of both planned and unplanned releases can be observed. On the planned
side, most of  the exposure  is shown to come  from natural sources, with  a smaller though
comparable amount coming  from medical  sources. The smallest amount arises from nuclear
power production. By taking the total planned exposure and, for clarity, expanding the scale, it can
be seen that of the exposure  modes or media, the air and direct modes are the most significant.
Because the natural and medical sources constitute the major exposure sources, the primary
recipients of this exposure are patients, general population, and  occupational workers. Around
specific sources like  nuclear facilities, the exposures are generally limited to local populations.
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    The right-hand side of Figure 1  depicts the unplanned release mechanism. To derive the
estimates for the accidental exposures a number of assumptions were made. For medical sources
the exposure was assumed to arise from improper maintenance of x-ray equipment or releases of
radionuclides due to mishaps at the medical facilities, or during transportation, or waste disposal.
For nuclear power sources, the unplanned exposure was assumed to occur due to either a single
waste disposal or fuel reprocessing accident or a particular design-basis nuclear plant accident.
Comparison between the planned and unplanned case will show  that the composition of the
media dispersion  is quite different. In addition, the composition of the  recipient exposure is
different  from that of the planned case. Here, most of the exposure is directed toward the
occupational personnel and the residents of the area around the sources although the general
population and patients would receive some exposure.

    For  the year 2000, the situation  may have substantial changes, as  indicated by Figure 2
which has been drawn to the same scale as Figure 1. The potential exposure flow through the
nuclear power industry is now increased by a factor of approximately 30, however, the majority of
this still flows to a removal sink. The  planned medical and natural radiation potential exposures
have increased only slightly, that  is, proportional to population, whereas because of industry
expansion, the nuclear power industry planned potential exposure has increased significantly.
Thus, the nuclear power potential exposure, though still only a relatively small portion of the total
planned potential exposure, has now become significant.

    The unplanned potential exposure for the nuclear industry is estimated to triple in the year
2000 over 1970. Although the medical unplanned exposure has slightly increased over 1970, the
effect of it has diminished relative to the unplanned nuclear industry  potential exposure. Because
of the potential for large unplanned exposure from the nuclear industry, the problem of radiation
containment is shown to be very acute. The projected amount of planned vs. unplanned exposure
for the nuclear power industry already includes a high degree of control on releases from nuclear
power sources. Any failure of the nuclear power industry to maintain these high levels of release
control would greatly increase the  planned radiation exposure from the nuclear  power industry.
The extent to which actual accidents will occur will be highly dependent upon the control and
regulatory steps which  are currently being  implemented. The expected possible range of the
unplanned  radiation is  quite high.  It  can range from about the  level indicated  to many times
greater.

     In the year 2000, the general trend in terms of recipient exposure will be primarily an increase
in the exposure to nearby residents from both planned and unplanned nuclear industry releases.
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     SOURCES
    Scale Chdnqe Boundary
                                                                   NUCLEAR POWER
                                                                 INDUSTRY  RADIATION


EXPOSURE FLOWS IN MAN-REMS FOR THE YEAR 2000
irge)

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                                                                 NATURAL  RADIATION
TENTIAL RADIATION
 970
                           MEDICAL
                          RADIATION
   NUCLEAR
 —I POWER
  I INDUSTRY
  I RADIATIOfs
    MI
              BOTH DRAWINGS ARE
              ON THE SAME SCALE.
              THE OVERALL POTENTIAL
              EXPOSURE FOR THE  YEAR
              2000 IS MUCH LARGER THAN
              THAT FOR 1970
        Legend:
70
NATURAL  RADIATION EXPOSURE
PLANNED  MEDICAL RADIATION  EXPOSURE
UNPLANNED  NUCLEAR  POWER INDUSTRY
RADIATION EXPOSURE
PLANNED  RADIATION EXPOSURE
UNPLANNED  RADIATION EXPOSURE
UNPLANNED  EXPOSURE
PLANNED  N.P.I. RADIATION

EXPOSURE MEDIA:

F      FOOD CHAIN

T/W    TERRESTRIAL WATER

A       AIRBORNE

D       DIRECT
                              THE DOTTED LINE IS A
                              SCALE CHANGE BOUNDARY
                              INSIDE THE BOUNDARY
                              THE SCALE IS EXPANDED
                              1,000,000 TIMES
                                                                     FIGURE 2  POTENTIAL RADly
                                                                               (With 1,000,000:1 S

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COMPARATIVE  REPRESENTATION OF THE MAGNITUDES OF  PO
              FLOWS  BY THE  YEAR 2000  VERSUS THOSE IN
    MEDICAL
    RADIATION
                      Natural
                     Radiation
                                      SOURCES
   THE DOTTED LINE IS A
   SCALE CHANGE BOUNDARY.
   INSIDE THE BOUNDARY
   THE SCALE IS EXPANDED
   1,000,000 TIMES
                                                          UNPLANNED
            FIGURE 1 POTENTIAL RADIATION EXPOSURE FLOWS IN MAN-REMS FOR THE YEAR 19

                   (With 1,000,000:1 Scale Charge)

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