DRAFT
ENVIRONMENTAL STATEMENT
ENVIRONMENTAL RADIATION PROTECTION
REQUIREMENTS FOR NORMAL OPERATIONS
OF ACTIVITIES IN THE
URANIUM FUEL CYCLE
m
U.S.ENVIRONMENTAL PROTECTION AGENCY
Office of Radiation Programs
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DRAFT
ENVIRONMENTAL STATEMENT
FOR A
PROPOSED RULEMAKING ACTION
CONCERNING
ENVIRONMENTAL RADIATION PROTECTION REQUIREMENTS
FOR NORMAL OPERATIONS OF ACTIVITIES IN THE
URANIUM FUEL CYCLE
o-v.-r,*. -,_l Fx-:-vr.7 txoa Agency
v .,",'•
U,S, ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RADIATION PROGRAMS
. MAY 1975
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DRAFT ENVIRONMENTAL STATEMENT
ENVIRONMENTAL RADIATION PROTECTION STANDARDS FOR
NORMAL OPERATIONS OF ACTIVITIES IN THE URANIUM FUEL CYCLE
J Prepared by
>••,
•j
, OFFICE OF RADIATION PROGRAMS
j
Approved by
Assistant Administrator for Air and Waste Management
MAY 12, 1975
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SUMMARY
(x) Draft
( ) Final Environmental Statement
Environmental Protection Agency
Office of Radiation Programs
1. The proposed action is administrative.
2. The Environmental Protection Agency proposes standards to limit
radiation doses to the general public and quantities of long-lived
radioactive materials in the general environment attributable to
planned releases from operations contributing to the generation of
electrical power through the uranium fuel cycle. These standards
are proposed to apply to all operations within the fuel cycle,
including the operations of milling, conversion, enrichment, fuel
fabrication, light-water-cooled reactors, fuel reprocessing, and
transportation of radioactive materials in connection with any of
these operations. These operations may occur in any State, although
milling operations are expected to occur primarily in Wyoming, New
Mexico, Texas, Colorado, Utah, and Washington.
3. Summary of environmental impact and adverse effects.
a. The proposed standards would limit irreversible contamination of
the local, national and global environment due to releases of
radioactive krypton-85 (half-life 10.7 years), iodine-129 (half-
life 17 million years), and alpha-emitting transuranics (half-
lives 18 years to 2 million years). The total reduction in
potential health impact attributable to operations through the
year 2000 is estimated to be in excess of 1000 cases of cancer,
leukemia, and serious genetic effects in human populations.
b. Maximum annual radiation doses to individual members of the
public resulting from fuel cycle operations would be limited to
25 millirems to the whole body and all other organs except
thyroid, which would be limited to 75 millirems. Current
Federal Radiation Protection Guides for maximum annual dose to
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individual members of the public are 500 millirems to the whole
body and 1500 millirems to the thyroid from all sources of
exposure except those due to medical use and natural background.
However, most fuel cycle operations are now conducted well
within these guides, and the principal impact of the proposed
individual dose limits will be limited to the relatively small
populations in the vicinity of mills, conversion, and
fabrication facilities.
c. There are no anticipated adverse environmental effects of the
proposed standards.
4. The following alternatives were considered.
a. No standards.
b. Revision of Federal Radiation Guides for maximum annual exposure
of members of the public.
c. Standards for fuel reprocessing facilities only.
d. Standards without a variance for unusual operating situations,
and incorporating standards for annual population dose to limit
environmental burdens of long-lived radionuclides.
e. The proposed standards.
f. Standards based on a lower level of cost-effectiveness than
those proposed.
g. Standards based on use of "best available" effluent controls.
5. The following Federal agencies have been asked to comment on this
Draft Environmental Statement.
Department of Commerce
Department of Health, Education, and Welfare
Department of Interior
Department of Transportation
Energy Research and Development Administration
Federal Energy Administration
Nuclear Regulatory Commission
6. This draft environmental statement was made available to the public,
the Council on Environmental Quality, and the other specified
agencies on , 1975; single copies are available from the
Director, Criteria and Standards Division (AW-560), Office of
Radiation Programs, U.S. Environmental Protection Agency, 401 M
Street, S.W., Washington, D.C. 20460.
V^
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TABLE OF CONTENTS
SUMMARY
I. INTRODUCTION 1
II. THE PROPOSED ACTION 7
III. THE STATUTORY BASIS FOR ENVIRONMENTAL RADIATION
STANDARDS 16
IV. RATIONALE FOR THE DERIVATION OF ENVIRONMENTAL
RADIATION STANDARDS 19
V. TECHNICAL CONSIDERATIONS FOR THE PROPOSED STANDARDS 27
A. Model Projections of Fuel Cycle Environmental
Impacts 35
B. Results from Environmental Assessments under NEPA 48
C. Field Measurements of Environmental Impact 57
D. The Proposed Standards 64
VI. ANTICIPATED IMPACT OF THE PROPOSED STANDARDS 73
A. Environmental impact 74
B. Health Impact 81
C. Economic Impact 85
D. Administrative Impact 89
E. Intermedia Effects 92
F. Impact on Multiple Siting, "Nuclear Parks,"
and Energy Mix 95
VII. ALTERNATIVES TO THE PROPOSED ACTION 97
REFERENCES 112
APPENDIX: The Proposed Rule 117
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TABLES
Table 1. Characteristics of Model Fuel Cycle Facilities 30
Table 2. Principal Radioactive Effluents from the Uranium
Fuel Cycle and their Associated Critical Target
Organs 34
Table 3 Dose and Quantity Levels Implied by Model
Projections 38
Table 4. Environmental Impacts of Normal Releases from
Pressurized Water Reactors 50
Table 5. Environmental Impacts of Normal Releases from
Boiling Water Reactors 52
Table 6. Environmental Impacts of Normal Releases from
Other Fuel Cycle Facilities 54
Table 7. Calculated Doses from Noble Gas Releases at
Operating Plants (1972-1973) 59
Table 8. The Proposed Standards 66
Table 9. Potential Incremental Whole Body Doses Due to
Overlap of Exposures from Airborne Effluents at
Closest Presently Projected Nuclear Facility
Sites 71
Table 10. Potential Health Effects Attributable to Operation
of the Nuclear Fuel Cycle Through the Year 2000 at
Various Environmental Radiation Protection Levels
82
Table 11. Comparison of the Proposed Standards and Alterna-
tive Levels of Control for Environmental Releases 110
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FIGURES
Figure 1. Uranium Fuel Cycle Facility Relationships 28
Figure 2. Projected Nuclear Fuel Cycle Facility Needs 31
Figure 3. Risk Reduction vs Cost of the Uranium Fuel Cycle 37
Figure 4. Cost-effectiveness of Risk Reduction for the
Uranium Fuel Cycle 45
Figure 5. Distribution of Noble Gas Releases from
Boiling Water Reactors in 1971-1973 61
Figure 6. Projected Environmental Burden of Tritium from
the U.S. Nuclear Power Industry 75
Figure 7. Projected Environmental Burden of Carbon-14
from the U.S. Nuclear Power Industry 76
Figure 8. Projected Environmental Burden of Krypton-85
from the U.S. Nuclear Power Industry for
Controls Initiated in Various Years 77
Figure 9. Projected Environmental Burden of lodine-129
from the U.S. Nuclear Power Industry at
Various Levels of Control 78
Figure 10. Projected Environmental Burdens of Alpha-emitting
Transuranics with Half-lives Greater than One
Year from the U.S. Nuclear Power Industry 79
Figure 11. Cumulative Potential Health Effects Attributable
to Environmental Burdens of Long-lived Radio-
nuclides from the U.S. Nuclear Power Industry 86
Figure 12. Risk Reduction vs Cost of Alternatives to the
Proposed Standards 111
^x
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I. INTRODUCTION
Within the last few years, it has become clear that the national
effort to develop a commercially viable technology to generate
electricity using nuclear energy has been successful, and that the
generation of electrical power by this means will play an essential and
major role in meeting national power needs during the next several
decades. However, this extensive projected use of nuclear power has led
to widespread public concern over the hazards to health posed by the
radioactive materials associated with nuclear power generation. Unlike
fossil-fueled power generation, which uses fuels known to man from
prehistoric times, the fissioning of nuclear fuel is a very recently
discovered phenomenon and man is just beginning to learn how to assess
the full implications of its exploitation. Paradoxically it is also
true, however, that we know more about the implications for health of
radioactive materials than of the pollutants released by the burning of
traditional fossil fuels. This knowledge facilitates the process of
assessing the implications of using nuclear energy for the generation of
electrical power. This is particularly true for planned releases of
radioactive materials; the assessment of accidental releases is a much
more difficult task which is heavily dependent upon our limited
capability to predict the probabilities of accidents. As part of the
process of developing these proposed standards, the Agency has made a
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comprehensive assessment of planned releases of radioactive materials
associated with nuclear power generation, so as to assure fhe ber;t
available basis for judgments of what the potential effects on public
health and the environment are, what can be done to minimize these
effects through the issuance of environmental radiation standards, and
the costs and tradeoffs involved.
The Environmental Protection Agency was vested with the
responsibility for establishing environmental radiation standards through
the transfer of authorities to the Agency from the Atomic Energy
Commission (AEC) and the former Federal Radiation Council by the
President's Reorganization Plan No. 3 of 1970. The Agency's role is
complimentary to the responsibilities recently transferred from the AEC
to the Nuclear Regulatory Commission (NRC), which are focused on the
detailed regulation of individual facilities within the standards
established by EPA, whereas the Agency must address public health and
environmental concerns associated with the fuel cycle taken as a whole.
The proposed standards recognize the complementary nature of the roles of
the two agencies, and, in particular, are cognizant of the -Findings of
the former AEC and the NRC with respect to the practicability of various
types of effluent control and of timetables for their implementation.
This statement summarizes the data base and judgments upon which
these proposed environmental radiation standards for planned radioactive
effluents from the uranium fuel cycle are based. It also provides an
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assessment of the anticipated impact of the proposed standards and of
alternative courses of action on public health, the environment, the
industry and upon government. It should be recognized that past growth
of the nuclear power industry has been conducted so that radioactive
environmental contamination is minimal at the present time. Because of
this situation an unusual opportunity, as well as a challenge, exists to
manage future growth in the use of nuclear energy in a preventive rather
than in a remedial context, a situation that is the ultimate aim of all
environmental protection. Within such a context, the tradeoffs between
potential health risks or environmental quality and the costs of control
can be made most easily and with the maximum effectiveness.
In the United States the early development of technology for the
nuclear generation of electric power has focused around the light-water-
cooled nuclear reactor. For this reason the proposed standards and this
statement will consider only the use of enriched uranium-235 as fuel for
the generation of electricity. There are, in all, three fuels available
to commercial nuclear power. These are uranium-235, uranium-233, and
plutonium-239. The first of these materials occurs naturally and the
last two are produced as by-products in uranium-fueled reactors from the
naturally-occurring isotopes, thorium-232 and uranium-238, respectively.
Although substantial quantities of plutonium-239 are produced by light-
water-cooled reactors, large-scale production requires the development of
a commercial breeder reactor. The liquid metal fast breeder, which would
make possible the extensive production and utilization of plutonium fuel,
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is now under intensive development, but is not expected to he
commercially available before the late 1980's, at the earliest. However,
some commercial use of recycled plutonium in light-water-cooled reactors
is proposed for the near future. The third fuel, uranium-233 derived
from naturally occurring thorium, will be used by a new reactor type now
also under active development, the high temperature gas-cooled reactor,
which is expected to be available for substantial commercial use by the
end of this decade.
It has been projected that well over 300,000 megawatts of nuclear
electric generating capacity based on the use of uranium fuel will exist
within the next twenty years. This increase will require a parallel
growth in a number of other activities that must exist to support
uranium-fueled nuclear reactors. All of these activities together,
including the reactor itself, comprise the uranium fuel cycle, which is
conveniently separable into three parts. The first consists of the
series of operations extending from the time uranium ore leaves the mine
through fabrication of enriched uranium into fuel elements. This is
followed by a part consisting only of the power reactor itself, in which
the fuel is fissioned to produce electric power. The final part consists
of fuel reprocessing plants, where the fuel elements are mechanically and
chemically broken down to isolate the large quantities of high-level
radioactive wastes produced during fission for permanent storage and to
recover substantial quantities of unused uranium and reactor-produced
plutonium for future reuse.
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In the uranium fuel cycle these three parts have fundamentally
different characteristics with respect to radioactive effluents. The
first involves only naturally occurring radioactive materials which are,
nevertheless, made available to the biosphere as the direct result of
man's activity. The control technologies appropriate to these materials,
specifically uranium and its associated daughter products, are common to
most components of this part of the cycle. By means of fission and
activation the reactor creates large additional quantities of radioactive
materials. Although these are largely contained by fuel cladding, some
small releases of these materials do occur. However, in spite of their
relatively low levels, reactor effluents are important because these
facilities are the most numerous component of the fuel cycle and are
often located close to large population centers. And finally, although
fuel reprocessing plants are few in number, they represent the largest
single potential source of environmental contamination in the fuel cycle,
since it is at this point that the fuel cladding is destroyed and all
remaining fission and activation products become available for potential
release.
The environmental effects of planned releases of radioactive
effluents from the components of this cycle have been analyzed in detail
by the EPA in a three-part technical report covering fuel supply
facilities, light water reactors, and fuel reprocessing. This technical
analysis assessed the potential health effects associated with each of
the various types of planned releases of radioactivity from each of the
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various operations of the fuel cycle and the effectiveness and costs of
the controls available to reduce such effluents. In addition to this
analysis, there is also available considerable additional information on
planned releases from these facilities. This includes the generic
findings of the AEC (now the NRC) concerning the practicability of
effluent controls in connection with their proposed rulemaking action for
light-water-cooled reactors, extensive findings of the utilities and the
AEC as reflected by recent environmental statements for a variety of
individual fuel cycle facilities, and finally, the results of
environmental surveys conducted by the utilities, the States, the AEC,
and EPA at operating facilities.
These standards deal with planned releases only, although it is
recognized that the potential hazard from accidents could be substantial.
However, since the coupling between controls for planned effluents and
the potential for accidents is minimal, we have concluded that these two
important issues can be addressed separately. In addition to the safety
issue, there are two other aspects of nuclear power production that are
not addressed by these standards. These are the disposal of radioactive
waste and the decommissioning of facilities. These issues are currently
under study and EPA expects to make recommendations in these areas in the
future. In any case, the implications of the controls required by this
rulemaking for radioactive wastes and for decommissioning represent minor
perturbations on existing requirements for waste management for the fuel
cycle.
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II. THE PROPOSED ACTION
The Environmental Protection Agency proposes radiation standards for
normal operations of the uranium fuel cycle in order to achieve two
principle objectives: 1) to assure protection of members of the public
against radiation doses resulting from fuel cycle operations, and 2) to
limit the environmental burden of long-lived radioactive materials that
may accumulate as a result of the production of electrical energy, so as
i_c l_iidt their long-term impact en both current and future populations.
Tnese objectives are proposed to be achieved by standards which would
limit: 3} the annual dose equivalent to the whole body or any internal
organ, except the thyroid, to 25 millirems, and the annual t'.ose
equivalent to the thy;roid to 75 millirems; and 2) the quantities of
krypton-85, iodine-129, and plutonium and other alpha-emitting
transuranic elements with half lives greater than one year released to
the environment per gigawatt-year of power produced by th/i entire fuel
cycle to 50,000 curies, 5 millicuries, and 0.~ millicuries, respectively.
The proposed rule is contained in the appendix.
Standards in the first category are designed to address doses due to
short-lived fission-produced materials and naturally occurring materials,
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while those in the second specifically address long-lived radioactive
materials. The standards for environmental burdens of specific long-
lived radionuclides are expressed in terms of the nuantrlty of electricity
produced in order that society will bo assured that the risk which is
associated with any long-term environmental burden is incurred only in
return for a beneficial product: electrical power. The standard permits
up to the specified amounts of these radionuclides to be released at any
time or location and at any rate that will not exceed the individual dose
limitations. The standards proposed apply to all operations within the
fuel cycle, including milling, conversion, enrichment, fuel fabrication,
light-water-cooled reactors, fuel reprocessing, and transportation of
radioactive materials in connection with any of these operations. A
variance is proposed to permit temporary operation in the presence of
unusual operating conditions so as to assure the orderly delivery of
power.
The importance of the nuclear power industry to future energy supply
and the future public health and environmental implications of continued
operation of this industry at currently required levels of effluent
control combine to provide a major incentive for the establishment of
these environmental radiation standards.
The nuclear power industry is projected to grow from its present
proportion of approximately 4 percent of total electric power capacity to
over 60 percent by the year 2000 (an absolute growth of about 20
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gigawatts to 1200 gigawatts) (1). It is estimated that the capital
investment in current dollars associated with this growth will increase
from 3 to 600 billion dollars, and that the value of electric power
produced annually will grow from about 3 to over 200 billion dollars
during this same period (2).
The President's Energy Message of 1971 reinforced this trend to
nuclear power by endorsing the early development of a commercial breeder
reactor (3). While that decision does not directly bear on this
rulemaking, it does make clear that a national commitment has been made
for major future growth of nuclear power, an industry that is now in the
early stages of significant commercial utilization. It is equally clear
that national needs for electric power cannot be met without a large
increase in the fraction of electric power produced by nuclear energy,
given the present lack of availability of alternative sources, at least
within the next few decades (4).
The development of a large nuclear power industry has, however, the
potential for leading to unnecessary exposure of the public to
radioactive materials and to irreversible contamination of the
environment by persistant radionuclides (5). It is important, therefore,
to establish the environmental radiation standards within which this
growth will take place.
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The principal impact of radioactive effluents on the biosphere is
the induction of deleterious health effects in man. Comparable levels of
impact undoubtedly exist in other biota, but there is no present evidence
that there is any biological species whose sensitivity is sufficiently
high to warrant a greater level of protection than that adequate for man.
Health effects induced in man by exposure to radiation fall into two
broad categories - somatic and genetic. The principal somatic effects
include leukemias; thyroid, lung, breast, bone, and a variety of other
cancers; and, possibly, the impairment of growth and development, as well
as non-specific life shortening. It appears clear that sensitivity
varies with age, the embryo and young children being particularly
sensitive. The range of possible genetic effects encompasses virtually
every aspect of man's physical and mental well-being. The major
exceptions are infectious diseases and accidents, but even here inherited
susceptibilities also play a role (6).
The impact of radioactive effluents can be considered from three
different perspectives. The first of these is the maximum radiation dose
to individuals. This measure has been the one traditionally used for
limiting the impact of radiation, and existing radiation standards are
all related to limits on radiation doses to individuals (7). It is of
interest to note that the origin of existing radiation limits for the
general population, at least for somatic consequences, has been through
taking a somewhat arbitrary fraction (usually 1/10) of the dose limits
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established for radiation workers exposed under controlled occupational
conditions (8). The current Federal Guides for limiting radiation
exposure of members of the general public are 500 mrem/yr to the whole
body of individuals and 5 rems in 30 years to the gonads. As an
operational procedure, it is recommended that a limit of 170 mrem/yr to
the whole body be applied to suitable samples of the population to assure
that the first of these limits is satisfied for any individual. This
procedure automatically assures that the second limit will also be
satisfied (9).
A second perspective is provided by summing the individual annual
radiation doses to each of the members of a population to obtain a
measure of the total annual population impact. This summation may be
made directly on doses, rather than on potential health effects, because
it is the consensus of current scientific opinion that it is prudent to
assume a proportional relationship between radiation doses due to
environmental levels of radiation and their effects on health for the
purpose of establishing standards to protect public health. Although
this impact is usually expressed on an annual basis, it may also be
assessed for longer periods, which leads to consideration of a third
aspect of the complete assessment of the environmental impact of
radioactive effluents - the buildup and persistence of long-lived
radionuclides.
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Much of the radioactivity released from nuclear facilities is short-
lived and is essentially removed from the environment by radioactive
decay in less than one year. However, a few radioactive materials have
greater persistence ard decay with half-lives ranging from decades to
millions of years. These materials may deliver doses to populations
throughout this period as they migrate through the biosphere. The Agency
has characterized the sum of these doses as the "Environmental Dose
Commitment" (5). It is calculated for a specific release at a specific
time and is obtained by summing the doses to populations delivered by
that release in each of the years following release to the environment
until the material has either decayed to innocuous levels, been
permanently removed from the biosphere, or for a specified period of
time, in which case it is necessary to specify that only a partial dose
commitment has been calculated. For the purpose of the analyses made for
these standards, environmental dose commitments were calculated for a
maximum period of 100 years. There are two other dose commitment
concepts in common use. The first is the dose committed to an individual
by intake of internal emitters. This dose commitment is directlv
incorporated into the sum of doses to individuals comprising the
environmental dose commitment. The second is the UNSCEAR dose
commitment, which is defined as the infinite time integral of the average
dose in a population due to a specific source of exposure. This concept
is not, in general, simply relatable to the environmental dose
commitment, but in the limiting case of a population of constant size is
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equal to the environmental dose commitment divided by the (constant)
number of individuals in the population.
In recent years, it has become increasingly clear that the current
Federal Radiation Protection Guide (500 mrem/yr to individuals, usually
interpreted as an average of 170 mrem/yr to members of critical
populations) for limiting radiation exposure of the public is
unnecessarily high. The National Academy of Sciences, in its recent
report to the Agency on the effects of environmental levels of radiation
exposure (6), expressed what may be regarded as a consensus of informed
scientific opinion when it said:
There is reason to expect that over the next few decades the
dose commitment for all man-made sources of radiation except
medical should not exceed more than a few millirems average
annual dose. [And further,] ...it appears that [societal]
needs can be met with far lower...risk than permitted by the
current Radiation Protection Guide. To that extent, the
current Guide is unnecessarily high.
The potential impact on health caused by effluents from an expanding
nuclear power industry, if it were to operate at the levels permitted by
the current Federal Radiation Protection Guides, would be large. Current
guides do not, in addition, directly address either the second or the
third perspective of radiation exposure described above. However, the
guides are accompanied by the advice that exposures should be kept as far
below the guides for exposure of individuals as "practicable," and major
portions of the industry now operate at approximately one-tenth of the
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level permitted by the current guides. This was accomplished in large
part through the implementation of this concept by the former AEC through
the licensing of individual facilities.
However, attention to individual exposure alone leads to inadequate
control of releases of long-lived radioactive materials, which may give
rise to substantial long-term impacts on populations while contributing
only smal] increases to annual individual exposures. On the other hand,
the reduction of individual dose alone, if carried out without
consideration of the associated population dose and the economic factors
associated with the controls that reduce it, can also lead to the use of
unreasonably restrictive control of short-lived radioactive materials
that achieves negligible improvement in public health protection for
unreasonably large investments in control technology. Reduction of
exposure of individuals to as low as "practicable" levels is therefore
not, by itself, an adequate basis for radiation standards.
Most present regulations for the nuclear industry are applied as
individual licensing conditions for specific facilities. The AEC based
these regulations on standards derived from the recommendations of a
variety of external advisory groups, such as the International Commission
of Radiation Protection (ICRP) and the National Council on Radiation
Protection and Measurements (NCRP) or, in recent years, on the guidance
provided by the former Federal Radiation Council (FRC). These groups
have traditionally focused primarily upon the objective of limiting risk
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to the individual, although consideration of genetic consequences to
entire populations has provided the basis for some general guidance on
upper limits for exposure of entire populations. There has, however,
been no external source of standards or guidance for radioactive
materials from a specifically environmental point of view, such as, for
example, from the point of view of limiting the long-term environmental
buildup of radionuclides, until the President's Reorganization Plan No. 3
created EPA and charged it with that responsibility.
In summary, present radiation protection guidance, as it applies to
the nuclear power industry, requires expansion to satisfy the needs of
the times. Specifically:
a) The consideration of exposures on an annual basis must be
expanded to include the long-term impact of the release of long-
lived radionuclides to the environment.
b) The Radiation Protection Guide for annual dose to individuals is
unnecessarily high for use by the industry.
c) Application of the concept "as low as practicable" must include
explicit consideration of both total population exposure and the
costs of effluent controls.
The proposed action reflects these three considerations in order to
insure that the anticipated major expansion of nuclear power takes place
with assurance of adequate radiation protection of public health and the
environment.
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III. THE STATUTORY BASIS FOR ENVIRONMENTAL RADIATION STANDARDS
These standards are proposed under authority of the Atomic Energy
Act of 1954, as amended, transferred to the Environmental Protection
Agency from the Atomic Energy Commission by the President's
Reorganization Plan No. 3 (October, 1970). That plan provided for the
transfer of environmental standards functions from AEC to EPA:
...to the extent that such functions of the Commission
consist of establishing generally applicable environmental
standards for the protection of the general environment from
radioactive material. As used herein, standards mean limits
on radiation exposures or levels, or concentrations or
quantities of radioactive material, in the general environ-
ment outside the boundaries of locations under the control
of persons possessing or using radioactive material.
This authority is distinct from and in addition to the authority to
"...advise the President with respect to radiation matters, directly or
indirectly affecting health, including guidance to Federal agencies in
the formulation of radiation standards..." which was also transferred to
EPA from the former Federal Radiation Council by the same reorganization
plan. That authority, while it is broad in scope, is most appropriately
applied to the issuance of general radiation guidance to Federal agencies
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and for the use of the States, however, and not to the setting of
specific environmental radiation standards.
Two points are relevant to EPA's authority to set environmental
radiation standards. First, although EPA is not limited to specific
criteria for setting such standards (e.g., requirements for "best
practicable" or "best available" technology, or for effluent levels
having "no health effects"), EPA is constrained to set standards which
apply only outside the boundaries of facilities producing radioactive
effluents. The required environmental protection can be provided within
this constraint. By the same token, this authority may not be used by
EPA to set limits on the amount of radiation exposure inside these
boundaries, consequently occupational exposures of workers inside the
boundary remain the responsibility of the AEC (now the NRC), operating
under existing Federal Radiation Protection Guides for occupational
exposure.
Secondly, EPA can only set standards; the authority to regulate
specific facilities was not transferred by Reorganization Plan No. 3
(10). Application and enforcement of these standards against specific
facilities is the responsibility of the NRC. The division of
responsibilities between EPA and AEC (whose regulatory responsibilities
are now carried out by NRC) for carrying out these objectives was
addressed specifically by the President's message transmitting
Reorganization Plan No. 3 to the Congress as follows:
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Environmental radiation standards programs. The Atomic
Energy Commission is now responsible for establishing
environmental radiation standards and emission limits for
radioactivity. Those standards have been based largely on
broad guidelines recommended by the Federal Radiation
Council. The Atomic Energy Commission's authority to set
standards for the protection of the general environment from
radioactive material would be transferred to the
Environmental Protection Agency. The functions of the
Federal Radiation Council would also be transferred. AEC
would retain responsibility for the implementation and
enforcement of radiation standards through its licensing
authority.
This division of responsibility is not expected to interfere with
effective administration and achievement of these proposed environmental
standards. (See Chapter VII, Section D.)
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IV. RATIONALE FOR THE DERIVATION OF ENVIRONMENTAL RADIATION STANDARDS
Two objectives are of prime importance in considering the choice of
methodology to be used to derive environmental radiation standards for a
major activity such as the uranium fuel cycle. The first is that an
assessment of the potential impact on public health be made that reflects
an up-to-date consensus of currently available knowledge and that as
complete an assessment of this impact be made as possible. The second is
that in addition to public health impact, the cost and effectiveness of
measures available to reduce or eliminate radioactive effluents to the
environment be carefully considered. It would be irresponsible to set
standards that impose unnecessary health risks on the public (unnecessary
in the sense that exposures permitted by the standards can be avoided at
a small or reasonable cost to the industry), and it would be equally
irresponsible to set standards that impose unreasonable costs on the
industry (unreasonable in the sense that control costs imposed by the
standards provide little or no health benefit to the public).
Projections of health effects made in the technical analyses for
this rulemaking have been based on recommendations resulting from the
recently completed study of the effects of low levels of ionizing
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radiation by the National Academy of Sciences-National Research Council's
Advisory Committee on the Biological Effects of Ionizing Radiation (BEIR
Committee) (6). This Committee, which consisted of a broad cross-section
of prominent members of the U.S. scientific community knowledgeable in
the various disciplines appropriate to a review of existing sciantific
knowledge in this area, has provided EPA with the most exhaustive
analysis of risk estimates that has been made to date, Their conGlusiom?
include, among others, the recommendations that it in prudent to use a
linear, non-1 hrenhold, doee-rato-independont model for establishing
standards to limit health effects from environmental levels of radiation,
and that numerical standards for the nuclear power industry should be
established on the basis of an analysis of the cost-effectiveness of
reducing these effects.
Other authorities have suggested, usually on the basis of the same
data, that estimates of health effects based on the first of the above
recommendations may be either too high or too low. Those supporting the
first view argue that (a) risk coefficients have been derived from data
obtained at much higher doses and may, therefore, not properly reflect
any non-linearity that may be present at low doses and (b) that repair
mechanisms may operate at low dose rates to reduce the impact of such
exposures. Those supporting the second view argue that (a) some data
indicate that low doses may be more efficient in producing health effects
than higher doses, (b) the effect of genetic mutations on overall ill-
health is much greater than is commonly assumed, or (c) certain
20
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population subgroups have a predisposition to radiation-induced cancer
and are, therefore, at greater risk than most studies have indicated.
The NAS Committee examined all of these views in some detail and
concluded that while each of these arguments may have validity under
various assumptions or for various specific situations, the weight of
currently available scientific evidence strongly supports the continued
use of a linear non-threshold model for standards-setting. EPA agrees
that this conclusion is the prudent one for use in deriving radiation
standards to protect public health (11). We also recognize that rather
large uncertainties remain for describing the actual situation, an
uncertainty which is presently beyond scientific resolution.
The health assessments made for deriving these standards depart in
two significant respects from practice common in the past for assessing
the significance of radiation exposures. The first of these is the use
of the concept of environmental dose commitment described earlier to
assess the impact of environmental releases. Previous assessments have
usually been limited to the calculation of radiation doses to individuals
in local populations incurred immediately following the release of an
effluent. For short-lived radionuclides this will usually suffice, but
when long-lived materials are involved this practice can lead to large
underestimates of the total impact of an environmental release. The
underlying assumption justifying such a practice has been that individual
doses to other than local populations and at times after the "first pass"
21
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of an effluent are so small as to be indistinguishable from those duo to
natural background radiation and are therefore ignorable. This point of
view is not considered acceptable because it not only neglects the
implications of the non-threshold linear hypothesis for radiation
effects, but also the point that the radiation doses involved are
avoidable man-made doses, not doses due to natural radioactivity.
The second departure from usual practice in the past has been the
use of explicit estimates of potential health effects rather than
radiation dose as the endpoint to be minimized. In carrying out thesn
assessments the results of the exhaustive review and analysis of
available scientific observations on the relationship between radiation
dose at low levels and health effects completed recently for the Agency
by the BEIR Committee were extremely useful. It is perhaps obvious, in
retrospect, that the proper focus for determination of the appropriate
level for a standard should be its public health impact, but in the past
minimization of dose has served as a useful surrogate for this impact
because of uncertainties about the magnitude of the relationship between
dose and effect. Assessments similar to those made for this statement
have also appeared in some recent AEC Environmental Statements for
generic programs, such as those for the proposed liquid-metal fast
breeder reactor program and for plutonium recycle in light-water-cooled
reactors.
22
-------
The health impact analysis thus considers the total impac-i- of
releases of radioactive materials to the environment by including
radiation doses committed to local, regional, national, and worldwide
populations, as well as doses committed due to the long-term persistence
of some of these materials in the environment following their release.
The analysis served to identify which processes and effluents from the
fuel cycle represent the major components of risk to populations, and
leads to a clearer view of the need to control long-lived materials, as
well as of the futility of excessive control measures for very short-
lived radioactive materials.
In order to make a determination of the degree of effluent control
that can reasonably be required by standards, an analysis of the cost-
effectiveness of risk reduction was carried out. The consideration of
the cost-effectiveness of all (or, in some instances, a representative
sampling) of the alternative procedures available for risk reduction
within the fuel cycle reveals where and at what level effluent control
will achieve the most return for the effort and expense involved. Such
an assessment of the costs and efficiencies of various forms and levels
of Affluent control requires that judgments be made of the availability,
efficiency, and dependability of a wide variety of technological systems,
and that for each of these capital and operating costs be determined over
the expected life of the system. Cost data were reduced to present worth
values for use in these cost-effectiveness considerations.
23
-------
Finally, although the first consideration involved in developing
these standards was reduction of the total potential health impact of
radioactive effluents on large populations, doses to individuals must
also be examined, since a few situations exist where individual exposure
to short-lived radionuclides, such as the radioiodines, can occur at
unreasonably high levels even after cost-effective control of population
impact has been achieved. Although the risk to any given individual is
quite small for doses below a £ew hundred millirems, EPA believes that
such doses should also be minimized, especially when the individual at
risk is not the direct recipient of the benefits of the activity
producing them. In these cases, the approach to setting standards for
maximum individual dose was to weigh the cost-effectiveness of individual
dose reduction and the cost of control relative to total capital cost, in
order to arrive at a judgment whether or not it was possible, at
reasonable cost, to reduce these few individual exposures to the same
general levels that are achievable for large populations for other
sources of environmental radiation exposure from the uranium fuel cycle.
Within the context of the methodology outlined above, radioactive
effluents to the environment from the nuclear power industry can be
considered from three points of view:
1) the potential public health impact attributable to each effluent
stream of radioactive materials from each type of facility in
the fuel cycle;
24
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2) the combined potential public health impact of the various
components of the fuel cycle required to support the production
of a given quantity of electrical power; and
3) the integrated potential public health impact of the entire fuel
cycle due to the projected future growth of the industry over
some period of time, such as through the year 2000.
The first of these is useful for assessing the effectiveness of the
control of particular effluent streams from specific types of facilities.
It provides the basic data from which judgments concerning the latter two
perspectives flow. The second viewpoint, which provides an assessment of
the total impact of the industry for each unit of the beneficial end-
product (electrical power) as a function of the level of effluent
control, provides the information required for assessing the potential
public health impact of standards for the fuel cycle taken as a whole.
Finally, although each of these perspectives assists in forming judgments
as to the appropriate level of control and the public health impact
associated with a unit of output from the fuel cycle, only the third
provides an assessment of the potential public health impact of the
entire industry. The magnitude of this future impact, which could be
either considerable or relatively small, depending upon the level of
effluent control implied by the proposed standards, provides an important
part of the basis for EPA's conclusion that environmental standards
defining acceptable limits on the radiological impact of the industry are
clearly required.
25
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The standards-setting method described in the preceding paragraphs
may perhaps be best characterized as a process of cost-effective health
risk minimization which is here applied to the broad class of related
activities constituting the uranium fuel cycle. This method offers, we
believe, the most rational approach to choosing standards to limit the
impact of non-threshold pollutants from an industry encompassing a wide
»
variety of operations which combine to produce a single output.
There are, of course, a variety of alternatives to this approach to
setting environmental radiation standards. These encompass the use of
health considerations alone instead of considering both health risk and
costs, selective instead of comprehensive coverage of the industry, use
of best available technology, and, finally, the option of substituting
the use of EPA influence on AEC (now NRC) regulatory practice for the
setting of standards. These alternative approaches were considered by
the Agency and are discussed in Chapter VII along with some quantitative
alternatives to the proposed standards that also consider both health
risk and control costs.
26
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V. TECHNICAL CONSIDERATIONS FOR THE PROPOSED STANDARDS
The sequence of operations occurring before and after the fissioning
of fuel at the power reactor is shown schematically in Figure 1. Natural
uranium ore (which contains 0.7 percent uranium-235) is first mined and
then milled to produce a concentrate called "yellowcake" containing about
85 percent of uranium oxide. A conversion step then purifies and
converts this uranium oxide to uranium hexafloride, the chemical form in
which uranium is supplied to enrichment plants. At the enrichment plant
the isotopic concentration of uranium-235 in the uranium is increased to
the design specification of the power reactor (usually 2 to 4 percent) by
a differential gaseous diffusion process. The greatest portion of the
feed uranium hexaflouride becomes a plant tail depleted in uranium-235
content and is stored in gas cylinders. At the fuel fabrication plant
the enriched uranium hexaflouride is converted into uranium oxide
pellets, which are then loaded into thin zircalloy or stainless-steel
tubing and finally fabricated into individual fuel element bundles.
These bundles are used to fuel the reactor. After burnup in the reactor,
the spent fuel is chemically reprocessed to remove radioactive waste
products and to reclaim fissile material (mainly plutonium and unused
uranium) for reuse. All of these operations depend upon the
27
-------
Figure 1. URANIUM FUEL CYCLE FACILITY RELATIONSHIPS
28
-------
transportation of a variety of materials, many of which pose the hazard
of radiation exposure.
Table 1 shows basic parameters that are representative of typical
facilities for each of these fuel cycle operations (12). The values
which relate these operations to the number of gigawatts of power
production supported can be used as the basis for an assessment of the
environmental impact of the fuel cycle as a whole. A projection of the
magnitude of fuel cycle operations required to support reactors through
the year 2000 is shown in Figure 2 (13). Currently existing capacity is
expected to be sufficient to accommodate the requirements of the fuel
cycle up to about the year 1980.
The environmental impacts due to radioactive materials associated
with the various operations comprising the uranium fuel cycle fall into
four major categories. These are: 1) doses to populations and to
individuals due to naturally-occurring radioactive materials prior to
fission in the reactor; 2) doses to populations and individuals from
short-lived fission and activation products; 3) doses to populations from
long-lived fission products and transuranic elements; and 4) gamma and
neutron radiation from fuel cycle sites and transported radioactive
materials, which may produce doses to a few individuals close to
facilities, and to large numbers of people at low levels of exposure
along shipping routes.
29
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TABLE 1
CHARACTERISTICS OF
MODEL FUEL CYCLE FACILITIES
Operation
(note 1)
Uranium Mill
(MT U30g)
UFft Production
(MT U)
Isotopic Enrichment
(swu)
UO Fuel Fabrication
(MT U)
Light-Water-Cooled Reactor
(GW(e) capacity)
Spent Fuel Reprocessing
(MT U)
Fuel Cycle Plant
Annual Capacity
Range Model
500-1100**
300-1000
0.04-1.3
300-150Q
1140
5000-10,000 5000
6000-17,000 10,500*
900
1500
Number of Model LWR's
Supported by Facility
5.3
28
90
26
43
* Current operating level of industry and assumed model plant capacity
** Characteristic of about 70% of current facilities
1) The units which characterize each type of operation are abreviated as
follows: Metric Tons = MT, separative work units = swu, and gigawatts
(electric) = GW(e).
30
-------
900
800
700
600
UJ
5:
.0.
BC.
UJ
z
iu
o
y
500
ELECTRICAL ENERGY SUPPLIED
400
300
200
100
1970
1980
1990
2000
YEAR
Figure 2. PROJECTED NUCLEAR FUEL CYCLE FACILITY NEEDS
31
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Standards to limit the above four categories of individual and
population dose can be expressed using three major kinds of units of
measure: 1) limits on annual doses to the whole body or to specific
organs of individuals (millirems/year)? 2) limits on annual population
dose or environmental dose commitment (person-rems/year or person-rems,
respectively); and 3) limits on the total discharge of long-lived
materials to the environment per unit of output from the fuel cycle
(curies/gigawatt-year). Limits on the impact on individuals through each
of the above categories of exposure are most easily expressed directly as
limits on annual dose (millirems/year). Control of population impacts,
both from long- and short-lived materials, can be achieved directly
through application of either of the latter two kinds of units of
measure. However, although the best measure of the population impact of
long-lived materials is environmental dose commitment (person-rems),
standards expressed in person-rems would be extremely difficult to
enforce because of the many pathways and wide choice of models for
transport through the biosphere that are available. The best approach
for long-lived materials is to limit the total quantity of such materials
introduced into the environment by first calculating environmental dose
commitment and health effects and then deciding what limits on the
directly measurable quantity (the quantity released to the environment
measured in curies) best achieve the level of protection indicated.
Furthermore, analysis of dose distributions indicates that the population
impact of short-lived materials is quite adequately limited by a limit on
individual exposure, and that a separate limit for the impact of these
32
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materials on populations expressed in person-rems/year is an unnecessary
redundancy. Thus, standards for the fuel cycle expressed in just two
kinds of units of measure (millirems/year and curies/gigawatt-year) are
adequate to limit both the total population impact of fuel cycle
operations and, at the same time, maximum individual risk.
Table 2 summarizes the principal types of radioactive effluents from
the fuel cycle and the associated target organs of greatest concern. The
degrees of environmental protection available to minimize the public
health impact of these as well as less important effluents may be
assessed using three complimentary sources of information: 1) projections
based upon modeling of source terms, the capabilities of effluent
control, and environmental pathways, 2) measurements of the actual
performance of existing facilities, and projections based upon these
measurements for improved levels of effluent control, and 3) the
performance anticipated by the industry and the Atomic Energy Commission
as reflected by recently filed environmental statements for a variety of
facilities.
The most complete set of information is that derived from model-
based projections. For this reason, the principal criteria for judgments
about acceptably low levels of environmental impact are based upon this
data base. The rationale for the choice of these criteria is described
in Section A below, which also summarizes the results of these
projections. Sections B and C present data from environmental statements
33
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Table 2. Principal Radioactive Effluents from the Uranium
Fuel Cycle and the Associated Critical Organs
Effluent
Noble gases
Radioiodine
Tritium
Carbon-14
Cesium and other metals in liquids
Plutonium and other transuranics
Uranium and daughter products
Gamma and neutron radiation
Principal Critical Organ(s)
Whole body
Thyroid
Whole body
Whole body
Whole body, G.I. tract
Lung
Lung, bone
Whole body
34
-------
and field measurements for specific facilities, respectively. These data
in some instances confirm the conclusions drawn from models, and in
others point out areas where modifying -judgments are appropriate. The
final section describes the conclusions reached by the Agency for the
proposed standards.
A. MODEL PROJECTIONS OP FUEL CYCLE ENVIRONMENTAL IMPACTS
There are several elements to the development of a projection of the
potential health impact of radioactive effluents. The first is a
determination of effluent source terms as a function of the level of
effluent control. Next, the assumed radionuclide effluents are followed
using semiempirical models over as wide an area and for as long a period
as they may expose human populations. Human doses are then calculated
from the radionuclide concentrations given by these models for air,
water, and foodstuffs. For each radionuclide this involves modeling of
the penetration of the radiation through body tissues, rates of ingestion
and excretion, and partition among and metabolism in the various organs
of the body. Finally, after doses to various critical organs have been
determined, the probabilities of incurring somatic and genetic health
effects attributable to these doses are estimated.
These projections have been carried out and are described in detail
for each of the major effjjpwrt streams from the various activities
35
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comprising the fuel cycle in the EPA reports entitled "Environmental
Analysis of the Uranium Fuel Cycle" (13) . The results of this analysis
include both the reduction in potential health impact and the costs o f a
large variety of measures that can be instituted within the fuel cycle to
reduce its environmental impact. Thsse have been summarized in. Figures
3a and 3b for the entire fuel cycle by using the normalizing factors
shown in Table 1 for the typical model facilities described in detail in
reference 13. Figure 3a displays the reduction in potential health
effects achieved as a function of cumulative incremental control system
costs to the entire fuel cycle for the case of a typical pressurized
water reactor, for a representative variety of control options on each
component of the cycle. The costs of control have been normalized to one
gigawatt of electric power output and were applied in the order of
decreasing cost-effectiveness of health effects reduction for the fuel
cycle, taken as a whole. A similar curve can be constructed for the fuel
cycle for the case of a typical boiling water reactor, and is shown in
Figure 3b. A detailed discussion of the various control options selected
i
for display on these figures, as well as of alternatives not shown, will
be found in reference 13. The examples shown are typical, however, and
provide a good representation of the options available for effluent
reduction.
Table 3 shows, for the major categories of radiological impact, the
projected doses to maximum exposed individuals and the quantities of
long-lived radionuclides achievable at the levels of effluent control
36
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MO rONTMOIX
KRYPTON REMOVAL (REPHO)
MO FILTtN ICONV HM
ZEOLITE (REPRO)
•AQ (DRYING) FILTER (MILL)
KTTLIMQ PONDt ICONV-WSl
HOLDING POND ICONV-HF)
TRITIUM CONTROL IRf PRO!
LIQUID CAM PWR 1)
CLAV CORt 0AM (MIL .
Intf BAG FILTER (CQNV-WS)
MTUi-tVO TAMKB IHItl
18 DAY WO GAS HOLDUP
HEPA (OB VINO I SYSTEM (MILL)
I COVER (MILL)
n 1
0 1
1
1
234
1
5
1
6
1
7
1 'I
8 9
1 1
10 11
I
12
PRESENT WORTH CUMULATIVE COST (MILLIONS
1
3000
1
3005
1
30 10
1 1 1
13 14 15
OF DOLLARS)
1
30 15
1 1
16 17
1
30 20
1 1
18 19
1
20
1
3O 25
COST OF ELECTRICITY TO CONSUMER (MILLS/KILOWATT HOUR)
IBWR CASE)
250r
CONTROL IREPROI
MTTLtNG TANKS (FUEL FAB)
HEPA IDftvlNGI SYSTEM IMILU
2- COVM (MILL)
fBAG (CRUSHING) FILTER IMIL
)2nd BAG FILTER ICONV-HF)
SEEPAGE RETURN (MILL)
IQUID CASE BWR-4
IODINE CASE BGIE-2
ATMENT (CONV-WSI
« DAY XC CHARCOAL DELAY IBWRI
CIP* • FLOCT< IFUEL FABI
*AG (CRUSHINQI FILTER (MILL)
CHE» TREATMENT ICO«V-HFI
HEP* (FUEL FAB)
I I I L
2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
PRESENT WORTH CUMULATIVE COST (MILLIONS OF DOLLARS)
30 05 30 10 30 15
COST OF ELECTRICITY TO CONSUMER (MILLS/KILOWATT HOUR)
30 20
FIGURE 3. RISK REDUCTION VS. COST FOR THE URANIUM FUEL CYCLE
37
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Table 3. Do»o and Quantity L«vi;la Implied by Model Projection*
teveIt Source
Maximum Annual Individual Doses (mrem/yr) .
1. Whole body
a. Noble gases
b. Tritium
c. Carbon-14
d. Cesium, etc.
Controltt
Limiting Factor
1-5
3
«4
3
PUR
BUR
FR
FR
FR
FUR
BUR
FR
1B-15
2-20
Note 1
None
Note 1
PUR-3
BWR-3
Note 2
C/E
C/E
C/F.
Not available
C/E
C/t
C/E
C/E
2. Lung
a. Plutonium, etc.
b. Uranium, etc.
3. Thyroid-radioiodine
4. Bone - Uranium, etc. 13
FR
HEPA
11
10
2-9
1-8
15
Mill
Fab
PUR
BUR
FR
Filter
HEPA
PGIE-3,0-5
BGIE-2,0-5
Note 3
Mill
Clay core
C/E
C/E
Recovery of uranium
Maximum individual
Maximum Individual
C/E
C/E
B. Maximum Quantities Released to the Environment, Per Gigawatt-Year of Electric Power (Curies) .
1. Tritium 30,000 FR None Not available
2. Carbon-14 ^20 LUR Note 1 C/E
3. Krypton-85 4000 FR Note 1 C/L
4. Iodine-129 <0.002 FK Note 4 C/t
5. Plutonium, etc.
<0.0003
FR
HEPA
C/E
t All doses are rounded to the nearest number of millirems/yenr at the location of maximum dose
outside the facility boundary.
tt System designations are those used in reference 13; the levels at LWR's are for 2 unit?.
* At the nearest farm in the case of elemental release of Iodine, and at the nearest residence
In the case of organic releases; dose ranges shown encompass that for 100% release of either
form.
** Defined as alpha-emitting transuranics of half-life greater than 1 year.
Note 1 Assumes Krypton retention via any of several alternative methods of equivalent cost. Such
control is assumed to permit the retention of the approximately 60% of carbon-14 produced
by the fuel cycle that is released by fuel reprocessing at negligible additional cost. The
balance shown is released at the reactor.
Note 2 In addition to tritium whole body exposures at fuel reprocessing, cesium-137, ruthenlum-106
and iodine-129 may combine to yield comparable whole body doses. The dose shown is that
remaining in the presence of cost-effective levels for control of other major effluents
(particularly transuranics and iodine).
Note 3 Assumes iodine control is available with a removal efficiency of 99.9% for both lodlne-131
and iodine-129. Although some uncertainty exists concerning the performance of Immediately
available systems, systems presently under active development should achieve such efficiencies
and become available prior to expansion of the fuel reprocessing industry to more than one
or two facilities following the year 1980.
38
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consistent with such considerations as acceptable levels of cost-
effectiveness of risk reduction, equitable distribution of radiological
impact, or existing use of technology by industry as the result of non -
radiological considerations. The criteria used for judging the
acceptability of levels of cost-effectiveness of risk reduction are
discussed later in this section. The second and third columns indicate
the type of facility at which each major impact occurs and the level of
control (described in reference 13) which has been assumed, respectively.
The final column indicates which of the above limiting considerations was
controlling for each category of exposure.
The results shown in Table 3 indicate that at these levels of
control of environmental releases the attainable range of maximum annual
whole body dose to an individual at the boundaries of representative
reactor sites (for the case of combined exposure to air and water
pathways) is 0-2 mrem/yr for pressurized water reactors and 1-6 mrem/yr
for boiling water reactors. Three major types of sites (river, lake, and
seacoast) are included in the projections which yield these dose ranges.
Adding a large (1500 metric ton per year) fuel reprocessing facility to
either the PWR or the BWR case increases these maximum doses to 6-10
mrem/yr and to 7-14 mrem/yr, respectively. There are no other types of
facilities in the fuel cycle which produce whole body doses of
significance in comparison to these types of facilities.
39
-------
It should be noted that the cases considered in this analysis assume
two one gigawatt(electric) power reactors on each site. Larger numbers
of reactors would require larger sites in order to achieve these doses at
the boundary, or, alternatively, a greater degree of effluent control.
It is anticipated that sites used for multiple reactor installations
will, in practice, be larger than those for single or twin reactor
installations, and that in those instances where this is not the case the
economies associated with the use of smaller sites and multiple
installation of reactors will readily accommodate the somewhat higher
costs of improved effluent control required to maintain the above dose
levels. An additional factor influencing the maximum doses at sites with
large numbers of reactors is the small likelihood that all of the
limiting fuel failure and leakage parameters assumed in order to model
the effluent source terms will be realized by all of the reactors on a
site simultaneously.
Maximum potential annual doses to the lung and to bone from the fuel
cycle occur at mills and fuel fabrication facilities. These doses result
from the release of dust containing natural or enriched uranium. At fuel
fabrication facilities current releases are restricted to levels
corresponding to maximum lung doses of approximately 10 mrem/yr, due to
the incentive provided by the recovery of valuable enriched uranium.
Cost-effective levels of dose reduction at mills and other facilities
associated with the supply of uranium fuel to reactors lead to comparable
or lower doses to the lung, as well as to bone.
40
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Thyroid doses due to environmental releases of short-lived
radioiodines from the fuel cycle are particularly difficult to model due
to uncertainties in the magnitudes and effective release heights of
source terms and the chemical form in which iodine is released, as well
as complicated environmental pathways, which, in addition to direct
inhalation, typically involve airborne transport of iodine to vegetation
(the extent of which is extremely sensitive to rainfall), immediate or
delayed uptake by cows, and final ingestion by humans in milk. Doses
calculated from milk ingestion are subject to additional uncertainties
due to dilution resulting from milk pooling and the relatively rapid
decay of radioiodine (half-life of iodine-131 =8.1 days). Because of
all of these uncertainties, model calculations of thyroid dose are
anticipated to be markedly more conservative than those for most other
effluents - i.e., actual doses are expected to be considerably lower than
calculated doses. The model calculations project maximum individual
thyroid doses of 1-9 mrem/yr from typical reactor sites at the locations
of either permanent residents or at nearest farms.
The radioiodine situation at fuel reprocessing plants is even more
uncertain than at reactors, because of lack of experience with many of
the control methods for iodine appropriate to these plants. In addition
to the variety of control methods currently available, a number of more
advanced methods are now in final stages of development. Currently
available systems provide cost-effective control of iodine emissions with
anticipated overall decontamination factors of 1000 (13) . Since no fuel
41
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reprocessing facility is expected to become operational until 1978, and
only two or three prior to 1983, it is important to also consider more
advanced systems that are expected to become available during that time
period. These include iodine evolution at the dissolution stage of
reprocessing, iodox systems, and mercuric nitrate scrubbers (14). These
systems should achieve decontamination factors in excess of 10,000, and
are not anticipated to represent a major increase in the cost of fuel
reprocessing. Comprehensive development programs for all of these
systems have been underway for a number of years at Oak Ridge National
Laboratory, and most are in final stages of pilot scale demonstration,
having completed laboratory scale testing. The majority of these systems
are anticipated to be competitive in cost with current systems. It thus
appears reasonable to assume that within the next few years overall plant
decontamination factors of at least 1000 can be readily achieved. On
this basis, the calculated maximum thyroid dose from a fuel reprocessing
facility would not exceed 15 mrem/yr.
The second part of Table 3 reflects the capabilities of cost-
effective control techniques for long-lived radionuclides, where they are
available. It should be noted that although tritium control is not yet
available, the volox process now under active development for fuel
reprocessing for the LMFBR program would also provide effective control
of the largest source of tritium from the uranium fuel cycle. This
development program is not expected to be completed for more than a
decade, however (15).
42
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Carbon-14 has only recently been recognized as an effluent of
potentially large impact from the fuel cycle (16), and control methods
have not yet been extensively investigated. However, retention of
krypton-85 by cryogenic means at fuel reprocessing (one of the principle
control options for this radionuclide) may permit, at negligible
additional cost, the simultaneous removal of carbon-14 as carbon dioxide.
Specific control options for krypton-85, iodine-129, and plutonium
and other long-lived transuranics are discussed in reference 13. The
comments above concerning retention of short-lived radioiodines at fuel
reprocessing also apply to iodine-129. Controls for plutonium and other
transuranics are well established technology; those for krypton-85 and
iodine-129 are either developed (but not yet in commercial use) or
demonstrated in the laboratory and in the final stages of development for
commercial use.
We return now to a discussion of the choice of criteria for
acceptable levels of risk reduction. The display of the options
available for reducing the environmental impact of the fuel cycle shown
in Figure 3 can be examined from several points of view. If a certain
number of health effects were presumed justified in order to obtain the
generation of a given quantity of electricity, then this curve would
allow a judgment to be made as to which controls should be used in order
to meet that criterion at the lowest cost. If, on the other hand, a
determination had been made that the total cost of control should not
43
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exceed a fixed amount, the curve can be used to make a determination of
the maximum amount of health effects reduction possible. However, such
judgments are not available for either of these simple constraints with
regard to the generation of electricity. A judgment of the appropriate
level of environmental control must instead consider a variety of issues.
These include such considerations as: a) the limiting rate up to which
society is willing to incur costs to prevent deleterious effects on
health, b) the availability of improved control technology not yet in
use, as well as present patterns of use of control technology, installed
for the reduction of radioactive effluents, in order to recover valuable
materials, or for other reasons, and c) the distribution of potential
health effects, i.e., may a few individuals incur relatively larger risks
so that others may receive the benefit of an industry's operation.
If the data in the cost versus health effect curves in Figure 3 are
plotted as differential curves, as shown in Figure 4, a display of the
rate of aversion of health effects per unit cost versus cumulative cost
is obtained. An examination of these curves in conjunction with Figure 3
shows that near a cumulative present worth cost of about three million
dollars per gigawatt of power capacity for the entire fuel cycle for the
PWR case (about eight million dollars for the BWR case), a breakpoint
occurs between efficient and inefficient control options. At this point
the rate of reducing potential health effects is roughly one per half-
million dollars. In the region beyond this point, the differential curve
continues to descend rapidly to very low rates of cost-effectiveness
44
-------
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45
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(note that the vertical scale is logarithmic, not linear), and an
insignificant further reduction in health effects is obtainable for
additional control expenditures.
If the sole criterion for choosing an acceptable level of potential
health impact was that expenditures to achieve health effects reduction
stop at such a breakpoint, then no more cost should be incurred beyond
about three or eight million dollars per gigawatt of fuel cycle power
generating capacity (depending upon whether the power reactor is a PWR or
BWR, respectively), no matter how many potential effects were remaining
at that level. At this point resources are being committed at the rate
of about one half million dollars for each health effect averted. Since
the majority of these potential health effects are serious in nature,
involving loss of life or severe disability, this could be taken as
implying acceptance of that rate as limiting for preventing the loss o f
human life due to the impact of effluents from uranium fuel cycle
operations.
It is extremely difficult to estimate what limiting value society
actually places on expenditures to prevent loss of human life, because so
many intangible factors must be evaluated (17). This task becomes
especially difficult when one is faced with the question of preventing
the loss of life; the task is less difficult, but no more exact, when
considering the choice of appropriate compensation for a specific loss
that has already occurred. Leaving aside the moral implications of
46
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assigning a monetary value to compensation for such a specific loss and
considering only the experience we can draw upon for what society has
been willing to spend to prevent future losses, one can distinguish
several characteristics. The amount depends heavily upon whether the
risk of incurring the effect is imposed voluntarily or involuntarily (the
latter case carrying a much greater willingness to spend) and how far
into the future it is anticipated to occur. The amount also depends upon
who is supplying it and upon how the burden of payment is distributed.
In addition, the historical trend is for steadily increasing amounts, and
there is no reason to believe that this trend will not continue.
Most current estimates of the acceptable limiting rate of investment
for the prevention of future loss of life appear to fall at or below an
upper limit of one-quarter to one-half million dollars (18), just below
the value, noted above, at which the cost-effectiveness of health effects
reduction for the fuel cycle reaches a point of rapidly diminishing
return. This range of estimates of the acceptable limiting value for
prevention of future loss of life corresponds to a minimum cost-
effectiveness of risk reduction of two to four effects per million
dollars. Returning to the curves in Figure 4 displaying cost-
effectiveness of risk reduction, it can be seen that most of the systems
which lie above or within this range of cost-effectiveness (with the
important exceptions of krypton and tritium control) have already been
developed and are either available for immediate application or are
already being applied by the industry in response to a variety of factors
47
-------
that are not as well defined, perhaps, as the explicit health effect and
cost considerations developed here, but are present nonetheless. It
seems reasonable, therefore, that levels of environmental protection
achievable by systems of cost-effectiveness greater than this range of
values should be required, and that levels of protection that can only be
achieved using systems of lower cost-effectiveness should not be required
unless other extenuating circumstances exist. Such circumstances may be
that they are currently already included in facility designs for a
purpose not related to radiation control, or that their use may be
indicated in rare instances to bring about the reduction of excessive
doses to specific individuals in the general environment, that is, to
ameliorate extreme maldistribution of impact within the population.
B. RESULTS FROM ENVIRONMENTAL ASSESSMENTS UNDER NEPA
For the past three years, an extensive program has been carried out
by the utilities, manufacturers, and the AEC in order to assess the
expected performance characteristics of nuclear power facilities, for
each of which the AEC (now the NRG) is required to file an Environmental
Statement under the provisions of the National Environmental Policy Act
of 1969. By the end of 1974, Environmental Statements had been submitted
for 152 reactors at 82 different sites. These analyses provide unusually
detailed descriptions of the impact of facilities at specific sites. For
48
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each site such details as the local meteorology, topography, population
distribution, water usage patterns, and land usage patterns (including
the locations of nearby permanent residences, vegetable and dairy farms,
and recreational facilities) are considered with respect to each
pollutant released to the environment. The sample of statements
available encompasses every important power consuming region of the
United States and every significant geographical situation. Individually
and collectively, these assessments represent the most comprehensive
analysis ever performed of the potential impact of an industry upon the
environment.
Tables 4, 5, and 6 summarize the results of these analyses for
radioactive releases from pressurized water reactors, boiling water
reactors, and other fuel cycle facilities, respectively. The results for
reactors are listed in order of the most recently filed Environmental
Statement for each site. In cases where more than one statement has been
filed the most recent has been used. The statements are all final unless
otherwise indicated. For each reactor site the maximum whole body doses
due to gaseous releases, liquid releases, and gamma radiation from the
site, as well as the maximum thyroid dose to a child's thyroid
(calculated at the nearest pasture) are shown. In the case of other fuel
cycle facilities, the maximum whole body, thyroid, lung, and/or bone
doses are shown, as is appropriate for the particular type of facility
considered.
49
-------
TABLE 40 Environmental Impacts of Pressurized Water Reactors
Exposure (mrem/yr)
i«ll--l.X-LCy
(No. of Units)
WPPSS (2)
Farley (2)
Seabrook (2)
South Texas (2)
Greenwood (2)
Callaway (2)
Pilgrim (2)a)
Braidwood (2)
Byron (1)
Comnanche Peak (2)
Belief onto (2)
Fulton (2)f)
St. Lucie (2)
Surry 3 & 4 (2)
Vogtle (4)
S. Harris (4)
Millstone (3)a)
Sequoyah (2)
R. E, Ginna (1)
Catawba (2)
Indian Point (3)
Haddam Neck (1)
Trojan (1)
D, C, Cook (2)
Beaver Valley (2)
Diablo Canyon (2)
Crystal River (1)
Prairie Island (2)
H. B. Robinson (1)
North Anna (4)
Calvert Cliffs (2)
Salem (2)
Waterford (1)
E.J.J
(Date)
12/74 (draft)
12/74
12/74
11/74
11/74
10/74 (draft)
9/74
7/74
7/74
6/74
6/74
5/74 (draft)
5/74
5/74
3/74
3/74
2/74
2/74
12/73
12/73
10/73 (draft)
10/73
8/73
8/73
7/73
5/73
5/73
5/73
4/73 (draft)
4/73
4/73
4/73
3/73
Gaseous Liquid Site Gamma*
(Whole-body)
<1 2 <1
<1 <1 N.R.
<1 <1 <1
<1 <1 <1
<1 1 <1
<1 <1 <1
<1 <1 <1
1 2 <1
<1 2 <1
<1 1 <1
<1 <1 <1
1 <1 <1
<1 <1 <1
<1 <1 <1
<1 <1 <1
<1 12b) <1
<1 <1 <1
2 <1 <1
<1
-------
TABLE 4o Environmental Impacts of Pressurized Water Reactors (cont.)
Exposure (mrcm/yr)
r«i_xj.iLj
(No,, of Units)
San Onofre (3)
Davis-Besse (1)
Rancho Seco (1)
Arkansas (2)
Forked River (1)
V,, Summer (1)
Three Mile Island (2)
Zion (2)
Kewannee (1)
Watts Bar (2)
McGuire (2)
Fort Calhoun (1)
Maine Yankee (1)
Turkey Point (2)
Surry 1 & 2 (2)
Palisades (1)
Point Beach (2)
Midland (2)
Oconee (3)
C,1O
(Date)
3/73
3/73
3/73
2/73
2/73
1/73
12/72
12/72
12/72
11/72
10/72
8/72
7/72
7/72
6/72
6/72
5/72
3/72
3/72
Gaseous Liquid Site Gamma
(Whole-body)
<1 <1 <1
<1 3 <1
<1 3 N.R.
<1 <1 N.R.
<1 1 <1
<1 5b) N.R.
1 <1 NoR.
<1 1 NoR,
2 <1 <1
<1 <1 <1
<1 <1 NoR,
<1 <1 N.R.
<1 <1 <1
<1 <1 <1
<1 3 NoRo
1 <1 NoR.
4 <1 NoR,
1 <1 N.R
Iodine
(Thyroid)
<1
1
1
4
8
5d)
3
4
3
<10
10
<1
<1
48e)
1
5
<1
5
N.R.
Not Reported.
500 hours unshielded occupancy of boundary per year.
a)
b)
c)
d)
One BWR and two PWR units„
Assumes public access to cooling water discharge canal and consumption of
18 kg of fish and mollusks raised in discharge per year.
Monitoring and appropriate operational practices will be required by the AEC
to maintain this dose level, however, the AEC considers the dose calculated
without use of such measures (28 mrem/yr) very conservative (i0e., the actual
dose will be lower).
The dose calculated in the EIS (18.5 mrem/yr) will be reduced to this level
by changes in control capability required of the applicant by the AEC.
98% of the release is from the condenser air ejector and steam generator
blowdown, and can be eliminated through simple modifications of existing
control equipment.,
f)
Two HTGR units.
51
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TABLE 5. Environmental Impacts of Boiling Water Reactors
Exposure (mrem/yr)
racj.J-ii-y
(No. Of Units)
Hartsville (4)
Oyster Creek (1)
Allen's Creek (1)
Clinton (1)
Pilfcriiu (2)c)
River Bend (2)
Douglas Point (2)
Perry (2)
Hope Creek (2)
Millstone (3)c)
Nine Mile Point (2) '
Brunswick (2)
Limerick (2)
Dresden (3)
Grand Gulf (2)
Susquehanna (2)
Peach Bottom (2)g)
Fitzpatrick (2)
Duane Arnold (1)
LaSalle (2)
Bailly (1)
Cooper (I)1'
Hanford No. Two (1)
Monticello (1)
Hatch (2)
Zimmer (1)
Shoreham (1)
Brown's Ferry (3)
Quad Cities (2)
Vermont Yankee 0)
Fermi Unit Two (1)
E.J.3
(Date)
12/74 (draft)
12/74
11/74
10/74
9/74
.9/74
5/74 (draft)
4/74
2/74
2/74
1/74
1/74
11/73
11/73
8/73
6/73
4/73
3/73
3/73
2/73
2/73
2/73
12/72
11/72
10/72
9/72
9/72
9/72
9/72
7/72
7/72
*
Gaseous Liquid Site Gamma
(Whole-body)
<1 <1 <1
<1 <1 <1
<1 <1 <1
<1 <1 <1
<1 <1 <1
<1 <1 <1
<1 <1 1
<1 1 3
<1 <1 1
<1 <1 12
1 <1 <5
b)
6
24a,b)
1
10
28e)
<1
7
3
lllh)
11
7
9
5
3
29b)
17a,b)
9
-------
TABLE 5. Environmental Impacts of Boiling Water Reactors (cont.)
FOOTNOTES
N.R. «= Not Reported.
500 hours unshielded occupancy of boundary per year.
The AEC has required installation of additional equipment to maintain
doses to less than 15 mrem/yr in its comments on the EIS,,
At least three-fourths of the projected dose is due to turbine building
exhaust, which is untreated.
C^0ne BWR and one PWR unit.
Includes the contribution from Fitzpatricko The site gamma dose assumes
100 hours in a boat at point of nearest approach per year. The figures
shown are after scheduled 1975 augment of unit one gaseous effluent
control.
e)
The AEC also calculates a dose of 43 mrem/yr through the goat-milk
pathway; more than half of the dose is due to turbine building effluent,
applicant is evaluating improved systems.
'The dose of 22 mrem/yr in Table 5.3 of the EIS for unit one will be
reduced by a factor of 100 by a scheduled augment committed by the
applicant (see p.11-40 of the EIS).
8^Plus one 40 MW(e) HTGR.
Applicant calculates a maximum dose of 0.45 mrem/yr, AEC will require
applicant to reduce iodine dose to "as low as practicable" levels (see
summary comments on EIS),
EIS lists calculated doses of up to 10 mrem/yr (whole-body) and of
95 mrem/yr (infant thyroid), but applicant hag committed to install
additional control equipment to insure no greater than 5 mrem/yr for
both pathways.
•'Assumes a hypothetical cow grazing at the site boundary. Distance to
the nearest pasture was not determined in this early EIS0
53
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TABLE 6U Environmental Impacts of Other Fuel Cycle
Facility
EIS
Exposure (nuem/yr)
(Type)
Hume c a
(mill)
Highland
(mill)
Shirley Basin
(mill)
Sequoyah
(conversion)
Barnwell
(conversion)
Exxon Nuclear
(fabrication)
Midwestb)
(reprocessing)
Barnwell
(reprocessing)
(Date)
12/72 (draft)
3/73
12/74
4/74 (draft)
4/74 (draft)
6/74
12/72
4/74
Whole-body Thyroid Lung Bone
11 42a)
3-12 0-1
6 11
3 <1
<1 1
<1 N.R.
1 1 N.R. 2
4 647
N.R.
Hot Reported.
a)
b)
This early draft EIS contains insufficient information to assess
this dose in detail, but it is at least an order of magnitude
greater than that from other current comparable, facilities.
This facility is not now expected to become operational in the
forseeable future. A cow is occasionally pastured 1^5 mi0 north
of the site; the maximum estimated annual dose to a child's thyroid
from milk supplied by such a cow is 7.4 mrem.
54
-------
Table 4 demonstrates that for over 90 percent of the 52 sites
containing PWR's, maximum whole body doses from gaseous releases no
greater than 1 mrem/yr are anticipated. For three, maximum doses of 2
mrem/yr and for one, 4 mrem/yr are expected. Maximum doses due to liquid
effluents display a similar pattern; the handful of doses shown that are
significantly greater than 1 mrem/yr are calculated for the highly
unlikely situation of individuals postulated to derive a major portion of
their annual animal protein diet from fish grown directly in the
undiluted effluent from the site. (Such situations, although perhaps
theoretically possible, have not been observed, are not anticipated to
actually occur, and could be avoided, if necessary, by restricting
fishing at effluent discharge outlets.) Similarly, no individual is
estimated to receive a dose as great as 1 mrem/yr due to gamma radiation
from the combined impact of all facilities at any site. Finally, 90
percent of sites anticipate doses to a child's thyroid due to ingestion
of milk at the nearest farm no greater than 10 mrem/yr. The single
facility exceeding 15 mrem/yr could control 98 percent of its projected
releases through simple modifications of the handling of untreated air
ejector and steam generator blowdown effluents (19).
Table 5 demonstrates that 80 percent of the 31 sites containing
BWR's anticipate maximum whole body doses from gaseous releases no
greater than 2 mrem/yr, and that all but one will not exceed 5 mrem/yr.
That site (Peach Bottom) predicts 8 mrem/yr at its nearest boundary for
fulltime year-round unsheltered occupancy. The actual dose at the
55
-------
nearest residence would be significantly lower. Doses from liquid
effluents are smaller, with 90 percent estimating 1 mrem/yr or less and
no site exceeding 4 mrem/yr.
Doses due to gamma radiation originating onsite can be significant
at BWR sites because of the circulation of activation-produced nitrogen-
16 through the turbines in this reactor design. Careful design of
shielding and turbine location relative to the site boundary and
topographical features is required. In spite of this, only two BWR sites
project boundary doses greater than 5 mrem/yr to individuals. In one of
these cases (Nine Mile Point) the dose can be reduced by restricting
boating near the discharge canal; in the other (Bailly) the dose is to
steel workers, not permanent residents, on an adjacent site, and appears
to be unnecessarily high.
Of all the effluents from power reactors, iodine releases from BWR's
represent the greatest potential source of maximum exposure to
individuals. Although 70 percent of sites have projected maximum thyroid
doses at the nearest farm of less than 10 mrem/yr, five estimate doses
between 20 and 30 mrem/yr, and one projects doses an order of magnitude
greater. The principal potential source contributing to all potential
doses that are greater than 10 mrem/yr is iodine released from the
turbine building vent (20). Treatment of this source term is possible,
but is made more difficult by the large volume of air released from the
turbine building. Selective treatment of the largest sources in the
56
-------
turbine building is possible, however, at reasonable cost, and is
incorporated in a number of recent designs (21). The need for smch
treatment must be weighed, nonetheless, in the light of the results of
field measurements of potential doses to the thyroid discussed below in
Section C.
Table 6 summarizes the available information on doses to the public
in the general environment due to operation of fuel cycle facilities
other than reactors. It is far less extensive than that available for
reactors, but represents the projected impact of facilities typical of
modern practice. Significant, but relatively small doses are projected
to the lung and bone at mills and fuel reprocessing, as well as to the
thyroid at fuel reprocessing. The single instance of a projected dose
significantly exceeding 10 mrem/yr is for a facility not projecting use
of cost-effective levels of particulate control (22).
C. FIELD MEASUREMENTS OF ENVIRONMENTAL IMPACT
The oldest commercial power reactor, Dresden I, commenced operation
over fifteen years ago, in October 1959. By the end of 1972, there were
26 commercial power reactors in operation at 22 different sites, and in
1973, ten more reactors commenced operatipn. These utilities submit to
the AEC (now the NRC) reports of actual releases on at least a semi-
annual basis. These are reviewed for accuracy and published annually.
57
-------
In addition, EPA and its predecessor organizations have conducted
detailed surveillance programs at selected facilities. These studies
have consistently confirmed the accuracy of reported effluents of noble
gases and liquids and the potential doses associated with these, but
appear to reveal significantly lower potential thyroid doses than would
be expected from reported releases using commonly employed modeling
techniques and parameters for environmental pathways.
Table 7 shows calculated maximum doses at the site boundary for the
reported releases of noble gases from all operating facilities for the
years 1972 and 1973 (23). In a,ll cases, actual releases were less than
those assumed for the model-based calculations discussed in Sections A
\
and B above. Figure 5, which is taken from a recent EPA report (24),
shows the distribution of these releases for all BWR's commencing
operation within the past decade as well as that assumed for the model
calculations of the preceding sections. A similar figure is not
available f or^PWR's due to their extremely low levels of reported
releases. It can be seen from the figure that the average facility
experiences releases a factor of 3 lower than the model assumptions, and
that all facilities were at lea'st 35 percent lower.
The doses shown in Table 7 are expected, on the basis of field
experience, to fairly accurately represent actual doses that would be
received by a hypothetical individual located at the site boundary in the
prevailing wind direction, year-round, and unshielded by any structure.
58
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Actual maximum doses to real individuals would, of course, be
substantially lower. These doses have also been calculated for an
assumed year of full operation (taken to be BO percent of rated capacity,
on the average, on an annual basis) at the level of effluent control in
effect during 1972 and 1973. Finally, on the basis of the retrofits of
these facilities presently committed (all will be completed within the
next year, except for the two small old BWR's indicated as not yet
committed), the doses that would have been observed in these years if the
retrofits had been in place are shown. The data indicate that all PWR's
currently produce maximum potential fence post doses of less than 1
mrem/yr and that all BWR's with currently committed (or assumed minimum)
retrofits would deliver fence post doses of 2 mrem/yr or less. These
results appear to confirm the model projections of the two preceding
sections.
Liquid pathway releases from these facilities result in much smaller
potential doses than do noble gas releases. Detailed studies of several
specific facilities have revealed no actual dose to any individual from
this pathway as great as I mrem/yr (25).
Studies of iodine pathways and potential thyroid doses have been
conducted jointly by EPA and AEC over the past two years at the Dresden,
Monticello, Oyster Creek, and Quad Cities sites (26). In both years,
although atmospheric fallout from bomb testing has prevented the
accumulation of definative long-term measurements, the available results
62
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present a consistent picture of iodine concentrations in milk at least an
order of magnitude less than that projected by models for the milk
pathway currently used for environmental analyses. The difficulty
appears to arise from inadequate assumptions regarding the input
parameters for the airborne transport1 of iodine, although this is by no
means definitively established and such other factors as the influence of
wash-out, chemical form of the iodine, and pasture retention factors are
also in question. Regardless of the exact cause of the discrepancy, the
measurements at these facilities are consistent, and there is no known
data in contradiction. The data for Monticello, Dresden, and Quad Cities
are the most complete, and at pastures near each of these sites the
concentrations of radioiodine in milk that were observed would lead to
maxirftum thyroid doses to infants of a few tenths of a mrem/yr per curie
,/•
of iodine-131 released annually to the environment from the site.
The results of these studies were used to project the expected
maximum doses to a child's thyroid at the nearest pasture at all but 2 of
the 12 BWR sites reporting releases in 1972 and 1973. (The locations of
pastures and meteorological characteristics for two small, atypical
BWR's, Humbolt Bay and Big Rock Point, were not available.) These
projections were obtained by normalizing the meteorological
characteristics for the nearest pasture and the actual releases of each
;/
facility to the same quantities for Monticello and Quad Cities, and
projecting the resulting doses for operation of each facility at 80
percent of full capacity. The results indicate that, based on actual
63
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releases reported in 1972 and 197"? ;>y '>"•<"- "c operating facilities and the
field measurements conducted in tncs^ vo-ar? :+'- :--e two facilities studied
in detail, no facility had orov-r'. .>. ••-,.•-ir •-•". rr-er.i i a] thyroid doses to
an infant as great as 1 mrem/y} , ,y; ,: - ,:h~r w--<:-. for assumed average
annual operation at 80 percent, of f-j.> , ratod • a'v;.;:"'.tv,
Field measurements at othei- f.-.-.-l •_."_•,,- *-'.-.-:: i->;.£., are very sparse.
In 1968 DHEW completed a ntudy :•- c. -j --c-: -..- -.\ -: --.?j-.. .-i'_i facility (27); this
facility is not now in opera birr -in-1 ^ ,• , .•_••.-.-...• !-3';lvf: of the
performance of current techncioq<-, 'Jhe -..'.i^y i-t.-Mcfted rriaximum potential
individual whole body doses of ur fj ••ev-'"••;.; >--.--.-'4.r 3'1 nrein/yr and
comparable maximum organ doses to the bone -•?•?:•:•- rossible at that time due
to ingestion ofs, deer (which had aoc-'^s •<., •; r :,.-c.1 ar.d fish raised in
the plant effluent.
D. THE PROPOSED STANDARDS
Acceptable maximum levels Q\ public ^.josuit: and environmental
contamination by long-lived •-^•''l^acti v;.- rir-n= -:' -1 s due to environmental
releases from the operations corr-.pr.vrnr.g rhe i7"^1 c"de were determined by
considering the cost-effectiveness of rhe reduction of total population
impact, the acceptability of the result ing maximum Individual exposures,
and the potential for environmental contaminarion by long-lived
radioactive materials. The standards '--ere chosen to limit the quantity
64
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discharged or the maximum individual annual dose rate depending upon
whether the radioactive materials concerned were long-lived or short-
lived, respectively. Table 8 summarizes the numerical values of the
standards proposed for the uranium fuel cycle on these bases.
The proposed standard for maximum annual whole body dose to any
individual limits the combined external and internal dose due to short-
lived gaseous and liquid effluents as well as to exposure to gamma
radiation originating from all operations of thei fuel cycle to 25
mrem/yr. Such a value is easily satisfied by levels of control that are
cost-effective for the risk reduction achieved; is achieved by all sites
for which Environmental Statements have been fi}.ed; and, on the basis of
operating experience at existing sites, can be readily achieved in
practice. The combined impact of a fuel reprocessing facility, when
added to that at any reactor site, is such that the standard would
continue to be met by levels of control that are cost-effective at al 1
such sites. This case of mixed types of facilities on a single site is
judged to represent the worst case reasonably anticipatable.
The appropriate level for a standard limiting the maximum annual
thyroid dose of individuals is not easy to determine. On the basis of
existing field measurements a value much less than that proposed would
appear to be appropriate. However, the level pf control assumed
necessary by the AEC in recent licensing actions on the basis of model
projections is somewhat greater than that justified on the basis of cost-
65
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Table 8. The Proposed Standards for
Normal Operations of the Uranium Fuel Cycle
A. Individual Dose Limits
1. Whole body 25 millirems/year
2. Thvroid 75 millirems/year
3. Other organs* 25 millirems/year
B. Limits for Long-Lived Radionuclides
1. Krypton-85 50,000 curies/gigawatt-year
2. Iodine-129 5 millicuries/gigawatt-year
3. Transuranics** 0.5 millicuries/gigawatt-year
C. Variances
At the discretion of the regulator}' agency (licensor) for
temporary and unusual operating circumstances to insure orderly
delivery of electrical power.
D. Effective Dates
1. Two years, except
2. 1983 for krypton-85 and iodine-129.
* any human organ except the dermis, epidermis, or cornea.
** limited to alpha-emitters with half-lives greater than one year.
66
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effectiveness of risk reduction to the entire population alone. This is
because a small number of individuals are potentially subject to
relatively high doses. If actual doses are, indeed, as low as those
indicated by the limited existing number of field measurements, the
degree of control assumed necessary may be unwarranted. For this reason,
the proposed standard is not based upon the evidence of field
measurements, except to the degree that they indicate that the very high
doses projected in a few instances are unrealistic. The standard has
been chosen, instead, so as to reflect a level of biological risk
comparable, to the extent that current capability for risk estimation
permits, with that represented by the standard for whole body dose.
Doses to other organs are readily maintained within 25 mrem/yr using
economical readily available controls for limiting environmental
releases. These doses arise principally from exposure of lung and bone
as a result of airborne effluents from fuel supply and reprocessing
facilities. The single example of a projected value in excess of this
limit in environmental assessments by the industry (bone dose at a mill)
represents an unnecessarily high environmental impact that can and should
be reduced. As in the case for whole body dose, cost-effective levels of
control are available and can be readily achieved in practice.
The proposed standards for long-lived materials fall into two
categories: those which can be achieved using currently available methods
for control of environmental releases, and those that require use of
67
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methods that have been demonstrated on a laboratory or larger scale, but
have not yet achieved routine use. In the former case, exemplified by
the standard for plutonium and other transuranics, the standard limits
the environmental burden to a level consistent with that reasonably
achievable using the best available control methods. In the latter case,
that of the proposed standards for krypton-85 and iodine-129, the
limiting levels of environmental burdens specified are not those
achievable by best available performance, but instead by minimum
performance reasonably anticipated from these new systems. As experience
is gained concerning the ability of the industry to limit fuel cycle
releases of these materials to the environment the Agency will consider
the appropriateness of more stringent levels for maximum environmental
burdens of these persistent radionuclides.
Similarly, as knowledge becomes available concerning the capability
of technology to limit environmental releases of tritium and carbon-14,
the appropriate^levels of environmental burdens of these radionuclides
will be carefully considered by the Agency. However, the knowledge base
now available is inadequate for such a determination, and no standards
are presently proposed for these radionuclides.
The proposed standards are designed to govern regulation of the
industry under normal operation, and therefore a variance is provided, to
be exercised by the regulatory agency, to accommodate unusual and
temporary conditions of facility operations which deviate from such
68
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planned normal operation. This provision is important because the
standards, although they can easily be satisfied with a wide margin at
most facilities, are not intended to provide for operational flexibility
under unusual operating situations. Unusual conditions have not been
addressed by these considerations, which are intended to define currently
acceptable levels of normal operation only, and not acceptable levels of
unusual operation. It is anticipated that such unusual operation will
occur, at some facilities more often than at others, and that every
effort will be made to minimize such operation by the regulatory agency.
The proposed standards for maximum doses to individuals were derived
through consideration of the doses arising from effluents released from
single sites. However, since large numbers of sites are projected for
single geographical regions in several parts of the country, the
possibility of additive doses exceeding the maximum limits for
individuals due to the combined effect of effluents from many sites must
also be considered. This problem may be conceptualized as having two
components. The first is the possibility that two sites may be
sufficiently close to each other that the maximum dose to an individual
from one is appreciably increased by the other. The second is the
possibility that the combined effect of all of a large number of sites in
a particular geographical region may give rise to a general increase in
dose levels of significance compared to the maximum dose from any single
site.
69
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Because of the importance of specific meteorological and
geographical parameters, the first possibi 1 i t-y is best r-onsidor«n1 on i \\<-
basis of real cases. The largest potential contribution to individual
dose i's via airborne releases. Since doses due to such releases
generally fall off to less than 10 percent within 10 to 20 kilometers of
site boundaries, only sites separated by less than 20 km were considered.
There are presently only 3 pairs of such sites projected through the year
1985. These were each examined using meteorological parameters
characteristic of these sites. The maximum increases in maximum doses
are shown in Table 9. In no case is the increase as great as 20 percent.
Given the margin of flexibility available in the capability of effluent
control systems, this modest overlap of doses is not judged to pose any
difficulty with respect to compliance with the proposed standard.
The second possibility, that of a general increase due to the impact
of large numbers of facilities in a region, has been extensively examined
in a recent AEC study of the implications of projected future nuclear
facilities in the upper Mississippi river basin (28). This study, which
was carried out, among other objectives, to assist EPA in evaluating the
environmental aspects of expanded use of nuclear power, analyzes the
potential combined impact of approximately 350 reactor facilities and 9
fuel reprocessing facilities projected for this river basin in the year
2000. The study divided the region into 300 areas. The analysis shows
that in none of these 300 areas does the projected average dose to
individuals exceed 1.2 mrem/yr. The average for the entire region is
70
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TABLE 9
Potential Incremental Doses Due to Overlap of
Exposures to Airborne Effluents at Closest
Presently Projected Nuclear Facility Sites
Site Designations , Distance Between Maximum Doset
Sites (km)
Peach Bottom -
Fulton
Point Beach -
Kewaunee
Hope Creek, Salem - ft
2.4
7.0
14.5
1.20
1.06
<1.04
Summit
t Expressed as the ratio of the maximum dose for the two sites together
to the maximum dose in the absence of the second site. In each case
the maximum dose due to overlap occurs at or near the point where the
maximum dose due to a single site would occur.
tt Hope Creek and Salem facilities share a common site.
71
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less than 0.2 mrem/yr. It should be noted that these are average, rather
than maximum, doses, so that these results do not specify the maximum
doses projected in each subarea, but rather the sum of the general impact
of the many sites outside each area plus the average local impact of any
single sites within the area. A substantial portion of even these small
doses must necessarily arise from these average local contributions. The
analysis included a detailed treatment of all pathways, including air,
water, and foodstuffs. Well over 90 percent of all doses result from
pathways involving airborne transport of effluents. It is concluded that
any general increase in radiation doses from regional contributions will
be small compared to the maximum individual dose to which the proposed
standard applies.
72
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VI. ANTICIPATED IMPACT OF THE PROPOSED ACTION
The proposed environmental radiation standards for the uranium fuel
cycle are anticipated to have impacts on lor^g-term contamination of the
environment, on public health, and on the economic cost of producing
electrical energy. The impact of the proposed standards has been
assessed relative to that associated with current standards under which
the nuclear industry has evolved up to the present time. Since the
proposed standards are more restrictive than current standards their
environmental and public health impacts will logically be positive and
not adverse in nature. On the other hand, achievement of improved levels
of protection of public health and the environment will require controls
that will result in increased costs which must be reflected in energy
prices. Standards could also have implications for Federal and State
agencies charged with the responsibility of regulating the industry (or
operating facilities that are part of the fuel cycle), on the
distribution of pollutants between the various environmental media, for
the number of uranium fuel cycle facilities that can be operated at
single or contiguous sites, and even on the mix of nuclear and non-
nuclear fuels used for the production of electricity. These real and
potential impacts are considered in turn in the following sections.
73
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A. ENVIRONMENTAL IMPACT
The environmental impact of fuel cycle operations has been
considered from the point of view of long-term irreversible commitments
of radioactive pollutants to the planet's terrestrial, atmospheric, and
aquatic environments. In the next section, the public health implication
of these commitments, as well as that of short-lived materials, is
considered. However, that consideration of public health impact is
limited to potential health effects initiated by exposure to these
materials during the first 100 years following their introdu ction to the
environment, and cannot, because of our inadequate understanding of their
long-term behavior, comprehend their full potential impact. Effects on
other life forms have not been assessed, since they are not expected to
be significant at levels adequate for protection of human populations.
Environmental burdens of tritium, carbon-14, krypton-85, iodine-129,
and plutonium and other transuranics were examined for projected normal
releases over the next 50 years from the U.S. nuclear power industry
operating under existing standards and regulations (5). The results of
these analyses are shown in Figures 6-10. For those radionuclides now
released without any restriction, the levels that could be achieved with
and without the proposed standards are shown. In cases where releases of
these materials are currently limited, projections for each of several
levels of control are shown.
74
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700
600
500
400
D
0
O
D)
Q)
300
200
100
1970
1980
2020
1990 2000 2010
Year
Figure 6. Projected Environmental Burden of Tritium from the United States
Nuclear Power Industry.
75
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600
500
400
Of.
8
300
200
100
0
1975
1980
1985 1990
YEAR
1995
2000
Figure 7. Projected environmental burden of carbon-14 from the United
States nuclear power industry.
76
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r—\ \
EQUILIBRIUM VALUE
WITHOUT CONTROLS
<1.33x1010Ci)
(D.F.-102)
(1.33 x 108 CO
1970 75
YEAR A.O.
FIGURE 8. PROJECTED ENVIRONMENTAL BURDENS OF KRYPTON-85 FROM THE UNITED STATES
NUCLEAR POWER INDUSTRY FOR CONTROL INITIATED IN VARIOUS YEARS. THE
EQUILIBRIUM VALUES ARE THOSE FOR MAXIMUM POWER PRODUCTION EQUAL TO
THAT PROJECTED FOR THE YEAR 2020.
77
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Q)
'w.
D
U
O
1970
1980
2010
2020
1990 2000
Year
Figure 9. Projected Environmental Burdens of lodine-129 from the United
States Nuclear Power Industry at various levels of control
78
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12
10
8
to
-
on
U
1970
1980
1990
2000
2010
2020
YEAR
Figure 10. Projected environmental burden of alpha-emitting transuranics
with half-lives greater than one year/from the United States nuclear power
industry, assuming release of 10~^ of inventory and operation with
uranium fuel only.
79
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These projections demonstrate several significant characteristics.
In all cases, existing environmental burdens due to nuclear power
operations are small, and in all cases rapid increases are anticipated in
the near future at current levels of control. The public health
significance of these increased burdens, as assessed in the next section
of this Statement for the first 100 years following release, is
significant for all of these radionuclides and is particularly large for
tritium, carbon-14, and krypton-85. The total significance of
environmental burdens of carbon-14, iodine-129, and the long-lived
transuranics, which have half-lives of 5700 years, 17 million years and
from 18 to 380,000 years, respectively, cannot be quantitatively
assessed, but must be assumed to be considerably greater than that
anticipated during the first 100 years alone. The potential future
impact of the release of krypton-85, especially if other releases around
the world are added to these estimates, is strongly dependent not only
upon the level of nuclear power production, but also upon the year in
which controls to limit releases of this radionuclide are implemented
(29). As Figure 8 demonstrates, implementation of controls with a
decontamination factor (D.F.) of 100 in the early 1980's would insure
that the environmental burden never exceeds the equilibrium burden, with
such controls, associated with any power production level projected over
the next 50 years. Although the proposed standard only requires a D.F.
of 10, it is expected that use of the controls needed to satisfy this
requirement will result in an actual performance approaching that shown
in Figure 8. The proposed standards would limit projected environmental
80
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burdens of iodine-129 to 1 percent of that currently projected (30), and
would also require continuation of presently used best practicable
control of releases of transuranics.
The admonition of the National Environmental Policy Act that "... it
is the continuing responsibility of the Federal Government use all
practicable means..to the end that the Nation may...fulfill the
responsibilities of each generation as trustee of the environment for
succeeding generations..." is particularly germane to consideration of
these long-term environmental pollutants. At currently projected levels
of fuel cycle operations it is clear that the potential for future
radiation effects is substantial in the absence of standards to limit
environmental burdens of these materials. This, goal is not satisfied by
these standards for releases of tritium and carbon-14 only because
control technologies for these materials are not yet commercially
available.
B. HEALTH IMPACT
The anticipated impact of these standards on the potential for
effects on public health is shown in Table 10. These estimates of
potential health effects are limited to cancers (including leukemia), and
serious genetic effects (these include congenital abnormalities leading
to serious disability, and increases in diseases that are specifically
81
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Table 10. Potential Health Effects Attributable to Opeiation ot the
Nuclear Fuel Cycle Through the Year 2000 at Various
Environmental Radiation Protection Levels.t
Type of
Radioactive Material
Federal
Radiation
Guides
Current
AEC
Practicett
EPA Generally
Applicable Stds.t+
1. Short-lived materials
2. Long-lived materialsttt
a) Controllable
(85Kr>129I>239pu>etc)
b) Tritium
c) Garbon-14
34,000
1040
440
12,000
170
1040
440
12,000
160
20
440
12,000
1 These projections are based upon the linear non-thresbold assumption,
which, at the current level of understanding of radiation effects in man,
warrants use for determining public policy on radiation protection. It
should be recognized, however, that these projections are not scientific
estimates, but judgments based upon scientific data obtained under dif-
ferent conditions of exposure than those associated with nuclear fuel
cycle operations. Health effects shown are limited to total cancers,
including leukemias, and serious genetic diseases (see text). The entries
are the predicted number of health effects attributable to releases from
the U.S. nuclear industry by the year 2000. The projections assume that
approximately 8300 GW(e)-yr of electric power will be produced by nuclear
reactors in this period, based on AEC case B projections (WASH-1139(74)).
It is also assumed that all nuclear fuel cycles will operate at the same
level of impact as the uranium fuel cycle.
tt Assumes implementation of Appendix I as proposed in the Concluding
Statement of the Regulatory Staff, February 20, 1974.
1tt Effects are projected for the first 100 years following release only.
* The majority of this impact can be eliminated through implementation of
the voloxidation process at fuel reprocessing, if current development
efforts continue and are successful.
** About 60% of this impact may be eliminated as a by-product of the reten-
tion of krypton-85 at fuel reprocessing, however, knowledge concerning
control of this source of health impact is currently limited.
82
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genetic, such as certain forms of mental defects, dwarfism, diabetes,
schizophrenia, epilepsy, and anemia). The genetically-related component
of diseases such as heart diseases, ulcers, and cancer as well as more
general increases in the level of ill-health are omitted from estimates
of genetic effects, as are effects on growth, development and life span,
because of the wide range of uncertainty in existing estimates of their
importance, coupled with a judgment that their total impact is probably
not greater than that of those health effects that have been
quantitatively considered. To the extent that other somatic and genetic
effects are important, the present estimates of the impact of radioactive
effluents on health are not conservative, although such effects are
expected to be reduced by improved levels of effluent control in the same
proportion as are those that have been quantified. In most instances,
the numerical estimates of health effects were derived using the results
of EPA's model projections of fuel cycle operations and health risk
estimates from the recent National Academy of Sciences' report on this
subject (6).
The Table 10 entries in the column labeled "Federal Radiation
Guides" were derived assuming use of the minimum level of effluent
control required to assure a dose to individuals at site boundaries no
greater than 170 mrem/yr. They do not represent the physically
unrealizable assumption of 170 mrem/yr/individual to entire local or
national populations. While these entries are representative of the
levels of operation that are permitted by the current Federal Radiation
83
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Guides (as reflected by the NRC's effluent standards in 10CFR20) , it-
should be recognized that current operations are conducted so as to
maintain maximum doses well below these permitted levels. The proposed
standards will have the effect of removing the possibility that these
unnecessarily high levels of dose could ever be legally incurred by any
normal fuel cycle operations. The second column shows the reduction in
potential effects that has been achieved through application by the AEC
of the Federal Radiation Guidance that annual doses to individuals be
kept "as low as practicable." The entries reflect the levels of
potential impact that could result from the guidance for design and
operation of light-water-cooled reactors proposed by the AEC as Appendix
I to 10CFR50, if it is promulgated by NRC as proposed (31). The final
column shows the estimated levels of effects if the industry were to
operate under the proposed standards. The small reduction shown in the
final column for short-lived materials occurs only as a result of
reductions in dose from components of the cycle other than reactors,
since it is assumed that the proposed standards will be implemented at
reactors by proposed Appendix I.
The proposed standards would result in a reduction of approximately
1000 potential health effects due to releases of long-lived materials to
the environment through the year 2000. The principal residual impact of
the fuel cycle would then be that attributable to carbon-14 and tritium,
and control of a substantial fraction of this impact may be achievable
through inexpensive modification of systems that are installed to meet
84
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the requirements of the proposed standard for krypton. In any case, the
Agency will closely follow the development of knowledge concerning
control of these materials. Figure 11 shows the projected growth of the
potential health impact of these materials through the year 2000. The
projections are for assumed operation of the industry using uranium fuel
only.
C. ECONOMIC IMPACT
The economic impact of the costs imposed by these standards should
be considered from two viewpoints; first, is the cost reasonable for the
protection received, and second, will the costs have any impact upon the
ability of industry to supply needed power. The cost-effectiveness of
the risk reduction achieved by the proposed standards was given careful
consideration. Most of the reduction in potential health effects
required by these standards comes as a result of the reduction of
releases of long-lived materials. This reduction is achieved at a cost
of considerably less than $100,000 per effect (30), a rate of spending
for public health protection considerably less than that already in
effect in the industry for other types of radioactive effluent control.
This is the case because the proposed standards impose increased control
requirements principally on effluents that can deliver doses to very
large populations over long periods of time, instead of in areas where
85
-------
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86
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short-term doses to only relatively few individuals near facilities can
occur.
The capital cost of a new one GW(e) reactor was estimated in 1972 to
be on the order of 450 million dollars. Current estimates are
considerably higher, and values of over 700 million dollars are now
projected (33). The additional capital costs, beyond those incurred by
practice employed in industrial operations prior to the proposal of
Appendix I by the AEC, for control equipment required to meet the
standards are estimated to be approximately 1.5 to 2.8 million dollars
(1972 base) at a PWR and 6.2 to 7.6 million dollars at a BWR, for a 1
GW(e) facility. The range of values reflects the range of iodine control
required at different sites. There are currently approximately 45
reactors in operation, 60 under construction, 105 ordered, and 21 more
planned for construction during the next 10 years. The cost of controls
to meet the proposed standards is less than one percent of the capitol
cost of pressurized water reactor and one to one and one-half percent of
the capitol cost of a boiling water water reactor. The increased annual
operating cost associated with these additional controls would be less
than 1 percent for a PWR and perhaps as much as 5 percent for a BWR. The
higher costs for BWR's are a reflection of a simpler basic design which
produces, however, a considerably larger volume of effluents that must be
treated. It should be particularly noted that these increased costs for
reactors would be required, independently of these EPA standards, if
Appendix I is issued by NRC as currently proposed. Since this increase
87
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has already been anticipated by industry in its current designs and the
NRC is currently informally implementing Appendix I in its license
specifications, the proposed EPA standards would not, in any real sense,
cause any increased expenditures at reactors.
The principal economic impact of the proposed standards is that they
would require up to a 5 percent increase in the capital costs of a fuel
reprocessing plant and about a 1 percent increase in its annual operating
costs, principally to remove krypton-85. The impact on the balance of
other components of the fuel cycle is anticipated to be smaller. The
capital cost of controls to meet the proposed standards at a fuel
reprocessing facility is estimated as approximately 7 million dollars, or
0.2 million dollars per gigawatt(electric) of fuel cycle capacity served.
The combined cost of controls at all other fuel supply and handling
facilities is estimated to be approximately 0.3 million dollars per
gigawatt(electric) of fuel cycle capacity served. Since fuel cycle costs
not directly associated with the power reactor represent less that 20
percent of the total cost of power (34), the impact of these increased
fuel supply and reprocessing costs on the cost of power is anticipated to
be considerably less than 1 percent. This cost, even when added to
increases in capital and operating costs for controls on the reactor
required by proposed Appendix I, is calculated to result in an overall
impact of these standards on the cost of power that is still less than
one percent of its total cost at the busbar from a PWR, and less than two
percent from a BWR. Incremental costs to consumers will be a factor of
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two to four less than even these small increments, due to the presence of
large unaffected fixed costs for power transmission and distribution. It
is concluded that the combined economic impact of these proposed
standards and proposed Appendix I will be small, and cannot realistically
be anticipated to have any impact on the ability of the industry to
supply electrical power.
D. ADMINISTRATIVE IMPACT
The Federal agency principally affected by these standards will be
the Nuclear Regulatory Commission (NRC), which has the responsibility to
insure adherence to EPA's environmental standards in its regulation of
the individual facilities comprising the commercial nuclear power
industry. The Energy Research and Development Administration (ERDA) will
be affected to the extent that the uranium enrichment facilities operated
by ERDA supply the commercial nuclear power industry and additional
development and/or demonstration of effluent controls for krypton-85 and
iodine-129 is carried out by ERDA laboratories. The Department of
Transportation will also be affected to the extent that its regulations
concern shipments of spent fuel assemblies and high-level radioactive
wastes.
It is unlikely that issuance of these environmental standards will
cause any delay due to the need for changes in licensing regulations. In
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the case of reactors, the AEC has proposed new design and operating
guidance (Appendix I to 10CFR50) which, almost four years after it was
first proposed, has not yet been issued. This guidance could, with
certain minor modifications, be issued immediately as regulatory
implementation of these standards for reactors by NRC. The AEC
announced, when it proposed Appendix I to 10CFR50, that it would make any
changes in that proposed guidance that would be required to conform to
EPA standards. Since the standards proposed here for reactors do not
require substantial modification of proposed Appendix I, there should be
no impact on NRC's regulatory process that differs materially from that
already proposed by the AEC.
The standards should also facilitate the preparation and review of
Environmental Statements for individual facilities by providing a clear
statement of environmental radiation requirements from the agency
responsible for determining these requirements. They are not anticipated
to require substantial additional analysis in such Statements due to
their applicability to the total dose from all facilities in any
particular region, because such impacts are, in general, extremely small
in comparison to the proposed standards.
In the case of other components of the fuel cycle, the current
regulatory situation is one of uncertainty and potential change. These
facilities have generally operated within the numerical limits prescribed
in 10CFR20 (which contains a detailed statement of the implications,
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isotope by isotope, of the current Federal Radiation Guides for maximum
exposure of individuals) with no codification of numerical guidance for
these activities of the lowest practical effluent levels. In May 1974,
the AEC announced that it was undertaking rulexnakings to determine " as
i
low as practicable" design and operating conditions for several of these
components of the cycle (35). Issuance pf the proposed standards by EPA
should help to expedite issuance of this "as low as practicable" guidance
by NRC. To the extent that any environmental statement is required of
the NRC for new regulations implementing EPA standards, that process
should also be considerably simplified and shortened by the existence of
these environmental standards, compared to the lengthy procedures now
followed for developing regulations governing environmental releases f rom
the industry. It should be noted that those parts of the proposed
standards which impose significant new requirements have been phased in
time so as to permit orderly regulatory implementation with adequate lead
times for their integration into plant design and construction schedules.
"X
ERDA is directly affected through requirements of these standards at
its uranium enrichment facilities. No substantial impact is anticipated,
however, since these facilities now operate well within the proposed
standard according to published AEC data. In addition, any further
development work required on control systems for krypton-85 and iodine-
129 will probably be carried out by ERDA at the Oak Ridge National
Laboratory (and possibly other facilities), as a continuation of
activities previously underway under the auspices of AEC.
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In addition to the NRC regulation discussed above, certain
facilities in the uranium fuel cycle (some mills and conversion plants)
are now regulated by States under agreements with the NRC. This is also
not anticipated to lead to any difficulty, since such "Agreement States"
must, under terms of the authorizing statute for these agreements,
conform to NRC regulations, which in turn must implement EPA standards.
i
It is anticipated that any necessary modification of procedures and
regulations for transport of radioactive materials associated with
operations of the fuel cycle (especially spent fuel and high-level waste
shipments) will be carried out jointly by NRC and DOT, which share the
responsibility of insuring adherence to radiation protection requirements
in this area. Such modifications are anticipated to consist principally
of measures to insure that such materials do not remain for substantial
periods of time at locations where members of the public may accumulate
substantial doses.
E. INTERMEDIA EFFECTS
The proposed standards encompass pollutants discharged via both a ir
and water pathways. They also imply commitments of land use for the
storage of both the high and low level wastes collected by control
systems. In general, choice of the release pathway that involves the
minimum environmental impact is unambiguous; the only major exception is
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for release of tritium. And in general, the waste disposal implications
of the standards are most serious for long-lived radioactive wastes.
However, the incremental amounts of these wastes are very small for the
controls required by these standards, compared to the already existing
quantities produced by nuclear power facilities, i.e., those that do not
result from effluent control choices.
There is no presently available control mechanism for tritium; the
possibility of future control at fuel reprocessing facilities (the
principal source of tritium releases) has been discussed in a number of
investigations (36) . For the present, the alternatives available for
reducing population exposure are limited to dispersal via air-versus-
water. A portion of the population dose delivered when tritium is
dispered to air occurs over the long term and on a worldwide basis. This
worldwide portion of the dose is the same when tritium is dispersed via
water. The balance of the dose is delivered promptly to the U.S.
population, and, if delivered via air, is relatively independent of the
characteristics of the effluent site and approximately three times larger
than the worldwide population dose. If delivered via water, the
population dose is extremely site dependent, ranging from negligible to
approximately ten times larger than the worldwide component of population
dose. The important variable is whether or not the receiving waters are
used for public drinking water supplies. An additional complication is
the possibility of additional contamination by other radionuclides if
water is the dispersal route. Although the proposed standards do not
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address the issue of the most expeditious choice of release pathway for
tritium, it is recommended that the discharge pathway delivering minimum
dose be determined by the regulatory agency and required on a site-by-
site basis.
Disposal of radioactive effluents through dilution and dispersal in
air or water has, in the past, been a common method for satisfying
radiation protection requirements, which have been commonly expressed as
maximum permissible concentrations in air and water. The alternative is
that contemplated by these standards: collection of these materials
through the use of effluent control systems at the source followed by
retention of long-lived materials in a land burial site or in an
engineered storage facility. The environmental question is which
alternative, over the long term, presents the least environmental hazard.
The answer in the case of materials having half-lives less than about 100
years is unequivocally in favor of storage, since this route reduces the
probability of future human exposure to a small value. In the case of
longer-lived materials storage is also the preferred route. However, the
possibility exists that future releases of stored materials may take
place, with attendant human exposure, and the magnitude of this
possibility is not well-defined. These waste management issues are not
addressed by this rulemaking. It is simply assumed that waste management
represents an improvement over disposal, with high probability of success
in the short term, and with reasonable prospects for success over the
long term. Although this issue is basic to the environmental viability
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of nuclear power, it has been treated as separable from the question of
reasonable levels of planned effluents because the. wastes generated by
effluent control systems represent a miniscule addition to the total
waste management problems of the industry.
The issues associated with the decommissioning of facilities are
ultimately again those of waste management. The incremental problems to
decommissioning represented by a few additional effluent control systems
are a small perturbation on the already-existing decommissioning burden
of these facilties as a whole.
F. IMPACT ON MULTIPLE SITING, "NUCLEAR PARKS," AND ENERGY MIX
Uranium fuel cycle facilities in a particular geographical area
could consist of a large number of plants (of the same or mixed types) on
multiple sites in the same general area so that the potential for
overlapping doses to members of the general public exists. The Agency
has investigated the likelihood of such overlapping doses from multiple
sites (Section V-D). The potential for the proposed standards to be
exceeded (or more precisely to require significantly increased control in
order to be met) by overlapping doses from multiple sites was found to be
very small because of the very special physical siting conditions that
would have to exist. Such situations are not expected to occur with any
significant frequency nor with any significant impact.
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A somewhat similar question arises in connection with the proposed
nuclear park concept (37). The Agency has examined the possibility that
"nuclear parks" may exist in the near future, with a dozen or more
nuclear generating facilities and an associated fuel reprocessing
facility located on a single site. The nuclear park concept is not
considered likely to be implemented during the next decade or so (38),
and in view of the need to accumulate operating experience for the new
large facilities now under construction and the Agency's intent to review
these standards at reasonable intervals in the future, it is considered
premature and unnecessary to predicate these standards on conjectures
regarding siting configurations beyond the next decade. Changes in these
standards to accommodate such considerations should be deferred until
they are needed and can be justified by experience.
The proposed standard was also examined with respect to the
possibility that it might influence the mix between the use of nuclear
and non-nuclear fuels for the production of electrical power. The ease
with which the proposed standards can be met, both technically and
economically, leads to the ready conclusion that these standards could
not have any such influence.
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VII. ALTERNATIVES TO THE PROPOSED ACTION
In the course of developing these proposed standards, the Agency has
considered a variety of alternative courses of action. These fall into
two broad categories. The first encompasses what may be characterized as
administrative alternatives, and includes modification of existing
Federal Radiation Protection Guidance for Federal agencies, issuance of
generally applicable environmental standards for the fuel cycle as a
whole (the recommended course of action) or for specific classes of
activities within the fuel cycle separately, and, finally, the
alternative of no standards. The second category encompasses different
levels of generally applicable environmental standards for the entire
fuel cycle, and includes standards with and without variances for
abnormal situations and at various levels of cost-effectiveness of risk
reduction, including the extreme case of applying best available
technology, without regard to the degree of risk reduction obtained.
Each of these alternatives are discussed below, beginning with those
characterized above as administrative.
Existing Federal Radiation Protection Guides for annual radiation
exposure of members of the general public apply independently of the
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source of exposure. These general guides could have been revised
downward, or a portion of the existing guides could have been apportioned
to the nuclear power industry as representing an acceptable level of
health risk for the benefit of receiving electrical power. The
development of such revised or apportioned general guides need not depend
upon a detailed analysis of the capabilities of effluent control
technology, since only a judgment of what level of exposure will result
in either a negligible or an acceptable level of health effects is
required. Such a judgment requires either a) the demonstrated existence
of a threshold for all significant radiation effects (which can be
attained by the industry), or b) public acceptance of some level of dose
as representing a "negligible" or "acceptable" risk. However, the recent
NAS-NRC review of somatic and genetic effects of radiation again rejected
use of a threshold assumption for setting radiation standards, and there
is neither a publicly accepted level of negligible or acceptable risk,
nor any realistic prospect for obtaining agreement on a value for such a
general concept. Finally, when considering the risk to health of nuclear
power in relation to its benefit, it is clearly not acceptable to permit
a health risk equal to that benefit; what is required is to maximize the
residual benefit by minimizing the associated risk to health. However,
since they cannot reflect the detailed control capabilities of different
kinds of sources, guides based on health alone cannot minimize annual
environmental radiation exposures; they can only provide a ceiling on the
permissible level of pollution. Also, it is not clear how to modify or
apportion existing guides so as to prevent environmental buildup of long-
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lived materials. The Agency concluded that this alternative could not
provide adequate environmental protection.
The fuel reprocessing industry represents the largest single
potential source of radioactive effluents from the uranium fuel cycle.
The Agency could have proposed effluent standards based on cost-effective
risk reduction for this portion of the industry alone, as a first step,
and issued standards for other components of the fuel cycle subsequently.
Such a course would provide for satisfactory protection of the
environment, especially from long-lived radioactive effluents, and it
would involve a much shorter initial analysis than is required to set
comprehensive radiation protection standards for the entire fuel cycle.
However, such standards a) would not be nearly as responsive to
legitimate public concerns about radiation from the industry as are
comprehensive standards, and b) could infringe upon the licensing
responsibilities of the NRC for individual facilities (10). Finally,
adoption of this alternative would represent an inefficient use of
governmental resources. As many as six separate rulemakings eventually
would be required to complete the establishment of comprehensive
standards for the industry. This alternative was not adopted because it
is inefficient, is in potential conflict with a reasonable division of
EPA's responsibilities for environmental standards-setting and NRC's
regulation of specific facilities, and would not adequately respond to
public concerns about the environmental implications of planned
radioactive releases from nuclear power.
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EPA could also choose to issue no standards and instead exert its
influence to reduce environmental releases by publishing technical
analyses of the environmental impact and control capabilities of the
various components of the fuel cycle. This alternative would require the
least immediate effort and would not result in the possibility of
substantial environmental degradation during the next few years.
However, the opportunity to establish needed precedents for control of
environmental radiation from nuclear power through issuance of formal
Federal standards for protection against environmental degradation by
long-lived radioactive materials would not be exercised. Of even greater
importance, the Agency would be failing to carry out its basic
responsibility under Reorganization Plan No. 3 to set environmental
radiation standards to insure adequate protection of public health.
In summary, the environmental inadequacies of a revised Federal
guide for individual exposure, the need for definitive EPA standards to
control the environmental implications of the entire nuclear power
industry, and the efficient use of Agency resources argue conclusively
for the administrative alternative adopted. This alternative permits a
balanced consideration of the reduction of deleterious health effects
which takes into account the costs and capabilities of controls, and
which limits the quantity of long-lived radioactive materials released by
the industry so as to minimize irreversible environmental contamination.
It thus best satisfies all environmental concerns and is at the same time
most responsive to the Nation's energy priorities.
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The Agency has, in addition, considered three major quantitative
alternatives to the proposed action. The first alternative incorporates
standards with higher limits on individual dose that would apply to any
operating situation (not just to normal operations) and utilizes annual
population dose rather than quantity of long-lived radionuclides per
gigawatt-year as the unit of measure for standards to limit the
accumulation of these radionuclides in the environment. It is
substantially the alternative proposed by the AEC in their memorandum to
the President (October 19, 1973) concerning the division of
responsibilities between AEC and EPA (39), and for which numerical values
were advanced in subsequent discussions between the two agencies. The
second alternative is similar to that proposed, but is somewhat more
restrictive. It represents the lowest levels that can be justified on
the basis of reasonable levels of cost-effectiveness of risk reduction,
and requires the implementation of restrictions on the release of long-
lived radionuclides on a shorter timetable than that proposed. The final
alternative considered is for substantially lower limits on both
individual dose and quantities of long-lived radionuclides in the
environment than those proposed by this rulemaking action. These limits
represent the lowest ambient environmental levels achievable by the fuel
cycle using the most effective technology available for effluent control,
regardless of the associated cost-effectiveness of risk reduction. The
types of control technology required to achieve the levels contemplated
by each of these alternatives are limited to those either currently
available and used by NRC licensees or those in advanced stages of
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development, in which case sufficient lead time is provided by the
standard for any further development and safety evaluation required prior
to their use by licensees. Detailed analyses of control costs and the
associated levels of environmental and public health impacts of these
various levels of control are provided in references 13 and 40.
Alternative A; Replace the entire proposed Subpart B by:
a) The annual dose equivalent to a member of the public from
radiation or radioactive materials released to the
environment from the entire uranium fuel cycle shall not
exceed 50 millirems to the whole body, 150 millirems to the
thyroid, and 150 millirems to any other organ; and b) the
total annual population whole body dose from radiation or
radioactive materials released to the environment from the
entire uranium fuel cycle shall not exceed 1 person-rem per
megawatt of electric capacity.
The first part of this alternative provides considerably higher
upper limits of dose than those provided by the proposed action for
normal operations and, unlike the standards in the proposed action, these
are intended to be interpreted as shutdown values beyond which any fuel
cycle facility causing the standard to be exceeded would be required to
suspend operations. For this reason no variance is provided.
Justification of this limit must therefore result not from a
determination of what constitutes an acceptable level of normal operation
with respect to environmental impact, but rather from a determination of
an unacceptable level of population risk, or an unsafe level of
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operation. Such a determination is not possible, in general, because
knowledge of the particular conditions associated with each case of
potential or actual operation above such a limit is required. Nor is it
clear, with respect to safety, that EPA rather than NRC bears the primary
responsibility for such a determination.
The environmental benefit to be derived from establishment of
standards at these levels would be negligible, since the potential for
actual operation of any facilities above such limits is already
vanishingly small. There appears to be no known instance of a reactor
having ever delivered such doses to any actual individual in the general
environment, even with the relatively unsophisticated levels of effluent
control in effect over a decade ago (41).
With respect to the second part of this alternative, the current
annual population whole body dose to the world's population is
approximately 0.13 person-rems per megawatt of electric power produced,
or approximately 0.1 person-rems per megawatt of capacity, at present
actual operating levels of U.S. fuel cycle facilities. These values are
achieved without any limitation on environmental releases of long-lived
radionuclides, such as krypton-85 or tritium. Thus, a standard of 1
person-rem per MW(e) would have no impact whatsoever on either population
exposures due to short-lived radionuclides or on local or worldwide
environmental buildup of long-lived radionuclides.
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If this alternative were modified so as to apply to the
environmental dose commitment, rather than to the annual population dose,
the value proposed would still have absolutely no effect on releases of
long-lived materials, since the environmental dose commitment per GW(e)
of capacity, assuming release of all tritium and krypton, is currently
approximately 0.3 person-rems. (The above assessments do not include the
impact of carbon-14, since the limits proposed also did not.)
The economic costs associated with this alternative are only
slightly smaller than those for the proposed standard. It is assumed
that Appendix I would still be implemented for control of normal
releases, since the standards for individual exposure apply to abnormal,
not normal, releases under this alternative. Some cost saving would
result from the absence of any requirement to control releases of long-
lived radionuclides; this is estimated to amount to approximately 0.2
million dollars per gigawatt of fuel cycle capacity. An additional
reduction of capitol cost of up 0.3 million dollars per gigawatt of fuel
cycle capacity could result under this alternative from failure to
upgrade fuel supply facilities to "as low as practicable" levels of
control similar to those that would be required at reactors by Appendix
I.
The principal environmental and health impacts of this alternative
would be that environmental burdens of the long-lived radionuclides
krypton-85 and iodine-129 would be increased by one or two orders of
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magnitude and an increase of approximately 1,QOO health effects
(attributable to releases over the next 25 years) over that associated
with the proposed standards' due to lack of control of these long-lived
radionuclides would occur. The administrative impact would be decreased
by lack of a requirement to develop controls for these materials, and
increased by failure to provide standards to assist the development of
design and operating guidance and to facilitate the preparation of
Environmental Statemants for facilities in the fuel cycle other than
reactors.
This alternative is environmentally and administratively
unacceptable: it would provide negligible environmental benefit, would
encourage rather than restrict the continued accumulation of irreversible
environmental burdens of long-lived radioactive pollutants, and would
inject the EPA into an area which is the primary responsibility of the
NRC—the determination of the safety of levels of abnormal operation.
Alternative B; Modify Subpart B of the proposed rule by making the
following substitutions:
whole body dose
thyroid dose
other organ doses
krypton-85
iodine-129 5 millicuries
transuranics 0.5 millicuries
15 mrem/yr
45 mrem/yr
15 mrem/yr
25,000 curies
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The variance provision would remain in its proposed form; the effective
date for implementation of the standards for krypton-85 and iodine-129
would be 1980.
This alternative could be satisfied by all presently proposed sites
for which Environmental Statements have been submitted, with two possible
exceptions with respect to the control of iodine emissions. It is also
considered quite likely that krypton-85 and iodine-129 control capability
can easily be available by the proposed date. The weakness of this
alternative is that it would not achieve a significantly greater level of
health protection and would at the same time sacrifice flexibility for
dealing with the possibility of an unusual site. The earlier effective
date for krypton-85 and iodine-129 is not expected to significantly
reduce environmental burdens of these materials, since only one or two
fuel reprocessing facilities are scheduled to go into operation prior to
1983, and it is anticipated that these will install such systems ahead of
schedule for required demonstration and shakedown runs prior to the
effective date of the proposed standards in any case.
It is estimated that this alternative would require approximately
0.6 M$/GW(e) in capital costs beyond those required to meet the proposed
standards, principally due to increased requirements for iodine control
at reactors, and for particulate control at milling operations. No
significant improvement in environmental or health impact is anticipated.
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A significant increase in administrative impact is anticipated, due to
the increased difficulty of assuring compliance.
It is concluded that this more restrictive alternative does not
offer any significant advantage over the proposed action.
Alternative C; Modify Subpart B of the proposed rule by making the
following substitutions:
whole body dose 5 mrem/yr
thyroid dose 15 mrem/yr
other organ doses 5 mrem/yr
krypton-85 5000 curies
iodine-129 1 millicurie
transuranics 0.1 millicuries
The balance of the proposed rule is not altered, including the variance
provision.
This alternative would require the incursion of substantial
additional costs for minor improvements in the levels of health
protection and of environmental burdens of long-lived radionuclides. The
reduction in health effects due to short-lived effluents over that
provided by the proposed action would occur primarily at reactors, which
contribute 90 percent of the residual impact under the proposed action as
shown in Table 10; this improvement would be achieved at a cost
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approaching one billion dollars per potential health effect removed, a
clearly unreasonable burden upon society.
The use of the most effective technology available at all fuel cycle
facilities is estimated to cost up to 22 million dollars per
gigawatt(electric) of fuel cycle capacity. Up to an estimated total of
160 health effects could be avoided through the year 2000 by installation
of such controls at reactors due to reduction of short-lived effluents.
The decrease in health impact obtainable through improvement of controls
over long-lived materials is not possible to estimate, given the present
state of knowledge of performance capability of controls for these
materials, but in any case would be less than that for short-lived
effluents. The improvement in control achieved for long-lived materials
is not easy to estimate since greater uncertainty is not associated with
how much control (i.e., how much cost) will be needed to satisfy the
requirements of the proposed action, but with what level of effectiveness
can be achieved by any of a number of control alternatives of
approximately equivalent cost when these systems are placed into
operation at commerical facilities. This alternative would impose a
large administrative burden on NRC in order to insure compliance with
standards set at such low levels.
It is concluded that this alternative, which could impose severe
hardships and expense on utilities at some sites while achieving only a
small improvement in public health at great cost, would place
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unreasonable burdens on industry, and therefore on society in general,
for insufficient beneficial return.
Table 11 summarizes the differences between these three alternatives
and the proposed standards, particularly with respect to health effects,
control costs, and control of long-lived radioactive environmental
contamination. The table demonstrates that the total reduction in
potential health impact of the proposed standards over alternative A is
achieved at a present worth cost on the order of a hundred-thousand
dollars per health effect, while that of alternatives B and C over the
proposed standards each requires costs of several tens of millions of
dollars per health effect. Figure 12 is a reproduction of Figure 3,
showing the risk reduction-versus-costs (per gigawatt of electric power
capacity for the fuel cycle) for the various controls required to satisfy
these alternatives to the proposed action.
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REFERENCES
1. Nuclear Power Growth, 1974-2000; WASH~1139(74), U.S. Atomic Energy
Commission, February 1974.
2. Nuclear Power, Financial Consideration, Program Report, Vol.1, No.5,
Atomic Industrial Forumf September 1973.
3. Message to the Congress from the President of the United States
concerning energy policy, June 4r 1971.
4. The Nation's Energy Future, WASH-1281, U.S. Atomic Energy
Commission, December 1973.
5. Environmental Radiation Dose Commitment: An Application to the
Nuclear Power Industry* EPA-520/4-73-002, U.S. Environmental
Protection Agency, February 1974«
6. The Effects on Populations of Exposure to Low Levels of Ionizing
Radiation, Report of the Advisory Committee on the Biological
Effects of Ionizing Radiation, National Academy of Sciences -
National Research Council, November 1972.
7. See, e.g., Recommendations of the International Commission on
Radiological Protection, ICRP Publication 9, Pergamon, Oxford, 1959,
and Basic Radiation Protection Criteria, Report No. 39, National
Co'jncil on Radiation Protection and Measurements, Washington, 1971.
8. Taylor, L.C., Tha Origin and Significances of Radiation Dose Limits
foi the Population, WASH-1336, U.S. Atomic Energy Commission, August
1973.
9. Radiation Protection Guidance for Federal Agencies, Federal
Radiation Council, Federal Register Document 60-4539, May 1960.
10. Memorandum to Russell E. Train, Administrator, Environmental
Protection Agency, and Dixy Lee Ray, Chairman, U.S. Atomic Energy
ComiTiission, from Roy L. Ash, Director, Office of Management and
Budget, December 7, 1973,
11. Polioy Statements Relationship Between Dose and Effect, Office of
Radiation Programs, U.S. Environmental Protection Agency, March 3,
1975
12. Environmental Survey of the Uranium Fuel Cycle, WASH-1248, U.S.
Atomic Energy Commission, April 1974.
Ill
-------
13. Environmental Analysis of the Uranium Fuel Cycle, Part I - Fuel
Supply/ Part II - Nuclear Power Reactors, Part III - Fuel
Reprocessing, EPA-520/9-73-003, U.S. Environmental Protection
Agency, October and November 1973.
14. See, e.g., Unger, W,E., et al., Aqueous Fuel Reprocessing Quarterly
Reports for the Periods Ending 12/31/72 (ORNL-TM-4141), 3/31/73
(ORNL-TM-4240), 6/30/73 (ORNL-TM-4301), 9/30/73 (ORNL-TM-4394), Oak
Ridge National Laboratory; Groenier, W.S., An Engineering Evaluation
of the lodex Processs Removal of Iodine from Air Using a Nitric Acid
Scrub in a Packed Column,, ORNL-TM-4125, Oak Ridge National
Laboratory, August 1973; and Yarbro, 0.0.; Mailenf J.C.; and
Groenier, W.S., Iodine Scrubbing from Off-gas with Concentrated
Nitric Acid, presented at the 13th AEC Air Cleaning Conference,
August 1974.
15. Voloxidation - Removal of Volatile Fission Products from Spent LMFBR
Fuels, Goode, J.H., Ed., (ORNL-TM-3723), Oak Ridge National
Laboratory, January 1973.
16. Magno, P.J.; Nelson, C.B.; and Ellett, W.H., A Consideration of the
Significance of carbon-14 Discharges from the Nuclear Power
Industry, presented at the 13th AEC Air Cleaning Conference, August
1974.
17. See, e.g., Mishan, E.J., Evaluation of Life and Limb: A Theoretical
Approach, Journal of Political Economy, 7J3, 687 (1971); Lederberg,
j., Squaring the infinite Circle: Radiobiology and the Value of
Life, Bulletin of the Atomic Scientists, September 1971; Dunster,
H.J., The Use of Cost Benefit Analysis in Radiological Protection,
National Radiological Protection Board, Harwell, Didcot, Berks,
England, September 1973; and Schelling, T.C.f The Life You Save May
be Your Own, in "Problems in Public Expenditure Analysis", Chase,
S.B., Jr., Ed., Brookings, 1968.
18. See, e.g., Hedgram, A. and Lindell, B., P.Q.R. - A Special Way of
Thinking?, National Institute of Radiation Protection, Stockholm,
Sweden, June 1970; Sagan, L.A., Human Costs of Nuclear Power,
Science 177, August 11, 1972; and Cohen, J.J., A Suggested Guideline
for Low Dose Radiation Exposure to Populations Based on Benefit-Risk
Analysis, presented at the 16th Annual Meeting of the Health Physics
Society, New York, July 1971.
19. Of the 1.05 curies per year iodine-131 projected source term for
Surry 1 and 2, 1.03 curies per year comes from the condenser air
ejector and steam generator blowdown vent. These effluents could be
treated through minor modification of the existing gaaeous treatment
system.
113
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20. More than 75% of the sourca terms for the River Bend, Perry Island,
Hatch, and Monticello sites are from the turbine building, more than
50% of the source term of the Brunswick site is from this source,
and at Peach Bottom, although only 25% of the source term comes from
this source, this release makes the largest contribution to maximum
potential thyroid dose.
21. See, e.g., Mississippi Power s Light Co., Grand Gulf Nuclear Station
Units 1 and 2, PSAR, AEG Docket Nos. 50-416 and 50-417.
22. The draft environmental statement for the Humeca Mill does not
specify the control technology used. However, the information
presented indicates that dust removal capability currently available
and proposed for use at similar facilities are not proposed for air
cleaning.
23. Calculations of Doses, Population Doses, and Potential Health
Effects Due to Atmospheric Releases of Radionuclides from U.S.
Kuclear Power Reactors in 1972, Office of Radiation Programs, U.S.
Environmental Protection Agency, Radiation Data and Reports, 15, 477
(1974); and unpublished data, Office of Radiation Programs, U.S.
Environmental Protection Agency.
24. Martin, J.A., Jr.; Nelson, C.B.; and Peterson, H.T., Jr., Trends in
Population Radiation Exposure from Operating Boiling Water Reactor
Ge.seous Effluents, CONF-741018, Proceedings of the Eighth Midyear
Topical Symposium of the Health Physics Society, October 1974.
25. Kahn, B., et al., Radiological Surveillance Studies at a Pressurized
Water Nuclear Power Reactor, RD 71-1, U.S. Environmental Protection
Agency, August 1971; Kahn, B., et al., Radiological Surveillance
Studies at a Boiling Water Nuclear Power Reactor, U.S. Environmental
Protection Agency, March 1970.
26. Detailed Measurement of Iodine-131 in Air, Vegetation, and Milk
Aroond Three Operating Reactor Sites, Weirs, B.H.; Voilleque, P.E.;
Kel.ler, J.H. ? Kahn, B.; Krieger, H.L.; Martin, A.; and Phillips,
C.R, , (IAEA/SM-180/44), presented at the Symposium on Environmental
Surveillance Around Nuclear Installations, International Atomic
Energy Agency, November 1973; and unpublished data, U.S.
Environmental Protection Agency and U.S. Atomic Energy Commission.
27. Shleien, B., An Estimate of Radiation Doses Received by Individuals
Liviig in the Vicinity of a Nuclear Fuel Reprocessing Plant in 1968,
BRH/1ERHL 70-1, U.S. Department of Health, Education, and Welfare,
May 1970.
114
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28. The Potential Radiological Implications of Nuclear Facilities in the
Upper Mississippi River Basin in the Year 2000 (The Year 2000
Study), WASH-1209, U.S. Atomic Energy Commission, January 1973.
29. Effects of Control Technology on the Projected Krypton-as
Environmental Inventory, Oscarson, E.E., presented at the Noble
Gases Symposium, Las Vegas, Nevada, September 1973; Considerations
Regarding Timing of Krypton Control Implementation, Oscarson, E.E.;
Ellett,- W.H.; and Nelson, N.S., presented at the International
Symposium on Radiation Protection, Aviemore, Scotland, June 1974;
see also references 5, 13 (Part III), and 16.
30. Supplementary Testimony Regarding the State of Technology for and
Practicability of Control and Retention of Iodine in a Nuclear Fuel
Reprocessing Plant, Yarbro, O.A., Oak Ridge National Laboratory, at
the Consolidated Environmental Hearing for Barnwell A.G.N.S.
Construction and Operating License, Docket Nos. 50-332 and 50-332
OL, U.S. Atomic Energy Commission, Columbia, S.C., October 1974.
31. Concluding Statement of the Position of the Regulatory Staff, Public
Rulemaking Hearing on: Numerical Guides for Design Objectives and
Limiting Conditions for Operation to Meet the Criterion "As Low As
Practicable" for Radioactive Material in Light-Water-Cooled Nuclear
Power Reactors, Docket No. RM-50-2, U.S. Atomic Energy Commission,
February 1974.
32. Testimony Regarding Health Risks Resulting from the Release of
Krypton-85 and Radioicdine from the Barnwell Nuclear Fuel Plant,
Magno, P.J. and Nelson, N.S., U.S. Environmental Protection Agency,
a- the Consolidated Environmental Hearing for Barnwell A.G.N.S.
Construction and Operating License, Docket Nos. 50-332 and 50-332
OI,, U.S. Atomic Energy Commission, Columbia, S.C., October 1974.
33. Power Plant Capitol Costs: Current Trends and Sensitivity to
Economic Parameters, WASH-1345, Division of Reactor Research and
Development, U.S. Atomic Energy Commission, October 1974.
34. Benedict, M., Electric Power from Nuclear Fission, Proceedings of
the National Academy of Sciences 6£, 1923 (1971).
35. "As Low As Practicable" Guidelines for Light-Water-Reactor Fuel
Cycle Facilities, Notice of Intent to Amend AEC Regulations (10CFR
Parts 40, 50, and 70), Federal Register 39., 16902 (1974).
36. The Separation and control of Tritium: State-of-the-Art Study,
Pacific Northwest Laboratories, BMI, U.S. Environmental Protection
Agency, April 1972; Midwest Fuel Recovery Plant, Applicant's
Environmental Report, Suppl. 1, NED 14504-2, General Electric
115
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company, November 1971; chemical Technology Annual Progress Report,
ORNL-4794, Oak Ridge National Laboratory, October 1972; and ref. 15.
37. Weinberg, A.M. and Hammond, R.P., Global Effects of Increased Use of
Energy, Bulletin of the Atomic Scientists 28, p.5, March 1972.
38. Evaluation of Nuclear Energy Centers, Division of Reactor Research
and Development, U.S. Atomic Energy Commission, WASH-1288, January
1974.
39. AEC Position on Division of Responsibilities and Authorities Between
the Atomic Energy Commission and the Environmental Protection
Agency, memorandum to the President from Dixy Lee Ray, October 19,
1973.
40. Final Environmental Statement Concerning Numerical Guides for Design
Objectives and Limiting Conditions for Operation to Meet the
Criterion "As Low As Practicable" for Radioactive Material in Light-
Water-cooled Nuclear Power Reactor Effluents, WASH-1258 (3 volumes),
U.S. Atomic Energy Commission, July 1973.
41. Dlomeke, J.O. and Harrington, F.E., Management of Radioactive Wastes
at Nuclear Power Stations, ORNL-4070, Oak Ridge National Laboratory,
January 1968.
116
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APPENDIX
ENVIRONMENTAL PROTECTION AGENCY
[40 CFR Part 1901
ENVIRONMENTAL RADIATION PROTECTION
FOR NUCLEAR POWER OPERATIONS
Notice of Proposed Rulemaking
Reorganization Plan No. 3, which became effective on December 2, 1970,
transferred to the Administrator qf the Environmental Protection Agency the
functions of the former Atomic Energy Commission to establish "...generally
applicable environmental standards, for the protection of the general
environment from radioactive material." The Plan defined these standards
as "limits on radiation exposures or levels, or concentrations or
quantities of radioactive material outside the boundaries of locations
under the control of persons possessing or using radioactive material." On
May 10, 1974, the Agency published an advance notice of its intent to
propose, standards under this authority for the uranium fuel cycle and
invited public participation in the formulation of this proposed rule.
The Agency has reviewed and considered the comments received in
response to that notice and proposes herein environmental radiation
standards which would assure protection of the general public from
unnecessary radiation exposures and radioactive materials in the general
environment resulting from the normal operations of facilities comprising
the uranium fuel cycle. Nuclear power generation based on recycled
Plutonium or on thorium is excluded from these standards because sufficient
operating data and experience concerning fuel cycles utilizing these fuels
are not yet available. Before any of these developing technologies becomes
117
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of potential significance to public health the need for additional
generally applicable standards will be considered.
The environmental radiation standards proposed in this notice
supplement existing Federal Radiation Protection Guidance limiting maximum
exposure of the general public [F.R. Docs. 60-4539 and 61-9402] by
providing more explicit public health and environmental protection from
potential effects of radioactive effluents from the uranium fuel cycle
during normal operation. Numerically the proposed standards are below
current Federal Radiation Protection Guides. The Agency is not, at this
time, proposing revisions in existing Federal Radiation Protection Guidance
for the general public because of its belief that a detailed examination of
each major activity contributing to public radiation exposure is required
before revision of this general guidance should be considered. Existing
Federal Radiation Protection Guidance for workers in the fuel cycle is also
not affected by these proposed standards. In addition, since these
standards are proposed under authority derived from the Atomic Energy Act
of 1954, as amended, they do not apply to radioactive materials and
exposures in the general environment that are the result of effluents from
mining operations because that Act does not provide authority over such
effluents. Finally, since there are no planned releases from existing
radioactive waste disposal sites and these sites primarily serve sources of
waste other than uranium fuel cycle operations, these standards do not
apply to such sites. The Agency has each of these areas of concern under
continuing study.
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It is the intent of the Agency to maintain a continuing review of the
appropriateness of these environmental radiation standards and to formally
review them at least every five years, and to revise them, if necessary, on
the basis of information that develops in the interval.
INTERAGENCY RELATIONSHIPS. Reorganization Plan No. 3 transferred to the
Environmental Protection Agency (EPA) the broad guidance responsibilities
of the former Federal Radiation Council and also transferred from the
former Atomic Energy commission (AEC) the more explicit responsibility to
establish generally applicable radiation standards for the environment.
However, the responsibility for the implementation and enforcement of both
this guidance and these standards lies, in most cases, in agencies other
than EPA as a part of their normal regulatory functions. For nuclear power
operations, this responsibility, which had been vested in the AEC, is now
vested in the Nuclear Regulatory Commission (NRC), which will exercise the
responsibility for implementation of these generally applicable standards
through the issuance and enforcement of regulations, regulatory guides,
licenses, and other requirements for individual facilities.
BASIC CONSIDERATIONS. The Agency has concluded that environmental
radiation standards for nuclear power industry operations should include
consideration of: 1) the total radiation dose to populations, 2) the
maximum dose to individuals, 3) the risk of health effects attributable to
these doses, including the future risks arising from the release of long-
lived radionuclides to the environment, and 4) the effectiveness and costs
of the technology available to mitigate these risks through effluent
119
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control. The Agency also recognizes the findings of the recent study of
the biological effects of low levels of ionizing radiation by the Advisory
Committee on the Biological Effects of Ionizing Radiation (BEIR Committee)
of the National Academy of Sciences - National Research Council. Two of
the principal conclusions of the BEIR Committee were: 1) that current
societal needs appear to be achievable "...with far lower average exposure
and lower genetic and somatic risk than permitted by the current Radiation
Protection Guide. [Thus,] to this extent, the current Guide is
unnecessarily high..." and 2) that "Guidance for the nuclear power industry
should be established on the basis of cost-benefit analysis, particularly
taking into account the total biological and environmental risks of the
various options available and the cost-effectiveness of reducing these
risks."
For the purpose of setting radiation protection standards the most
prudent basis for relating radiation dose to its possible impact on public
health continues to be to assume that a potential for health effects due to
ionizing radiation exists at all levels of exposure and that at the low
levels of exposure characteristic of environmental levels of radiation the
number of these effects will be directly proportional to the dose of
radiation received (a linear non-threshold dose-effect relationship). Even
under these assumptions, the range of estimates of the health risks
associated v/ith a given level of exposure derived from existing scientific
data is broe.d. It is recognized that sufficient data are not now available
to either p?:ove or disprove these assumptions, nor is there any reasonable
120
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prospect of demonstrating their validity at the low levels of expected
exposure with any high degree of certainty. However, the Agency believes
that acceptance of the above prudent assumptions, even with the existence
of large uncertainties, provides a sound basis for developing environmental
radiation standards which provide reasonable protection of the public
health and do so in a manner most meaningful for public understanding of
the potential impact of the nuclear power industry. Standards developed on
this basis are believed to also protect the overall ecosystem, since there
is no evidence that there is any biological species sensitive enough to
warrant a greater level of protection than that adequate for man.
Radiological protection of the public from nuclear power industry
operations has been based to date on guidance which has had as its primary
focus the general limitation of dose to the most exposed individual, rather
than limitation of the total population dose from any specific type of
activity. The proposed expanded development of the nuclear power industry
requires, however, the use of a broader environmental perspective that more
specifically considers the potential radiological impact on human
populations of radioactive effluents from this industry, rather than just
that on the most exposed individual. A number of long-lived radionuclides
are now discharged from various fuel cycle operations which carry a
potential for buildup of environmental levels and irreversible commitments
for exposure of populations that may persist for tens, hundreds, or
thousands of years. The extent of the cumulative population doses which
may occur over the years following release of such radionuclides is related
121
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to their radioactive decay times, the details of their dispersion through
environmental media, the period over which they remain in the biosphere,
and their exposure (both internal and external) of individuals in
populations. The cumulative dose resulting from releases to the
environment of such materials can be termed an "environmental dose
commitment," and quantitatively expressed in terms of the number of person-
rems of dose committed. The proposed standards are based, to the extent
that present knowledge permits, on such projections of the migration of
radioactive effluents through the biosphere and estimates of the sum of
potential doses to present and future populations during that migration.
Since potential effects from radiation exposure are assumed to occur
at any level of exposure, it is not possible to specify solely on a health
basis an acceptable level of radiation exposure for either individuals or
populations; it is necessary to balance the health risks associated with
any level of exposure against the costs of achieving that level. In
developing the proposed standards, EPA has carefully considered, in
addition to potential health effects, the available information on the
effectiveness and costs of various means of reducing radioactive effluents,
and therefore potential health effects, from fuel cycle operations. This
consideration has included the findings of the AEC and the NRC with respect
to practicability of effluent controls, as well as EPA's own continuing
cognizance of the development, operating experience, and costs of control
technology. Such an examination made it possible to propose the standards
at levels consistent with the capabilities of control technology and at a
122
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ro.'st judged hy tho Agency to he acceptable to society, as well as
reasonable for the risk reduction achieved. Thus, the standards generally
represent the lowest radiation levels at which the Agency has determined
that the costs of control are justified by the reduction in health risk.
The Agency has selected the cost-effectiveness approach as that:-best
designed to strike a balance between the need to reduce health risks to the
general population and the need for nuclear power. Such a balance is
necessary in part because there is no sure way to guarantee absolute
protection of public health from the effects of a non-threshold pollutant,
such as radiation, other than by prohibiting outright any emissions. The
Agency believes that such a course would not be in the best interests of
society.
The total population impact associated with a particular level of
effluent control is best assessed in terms of dose commitments to
populations measured in person-rems, which are then converted into
estimates of potential health impact. However, the environmental models
used for deriving these assessments, while useful for making estimates of
potential health impact, are not considered to be so well-defined as to
allow standards for populations to be expressed directly in terms requiring
their explicit use. The Agency believes that future changes and
refinements in models, and thus in the person-rem assessments upon which
these standards are based, will occur on a continuing basis. The standards
are therefore not proposed directly in terms of person-rems, but future
reviews of their adequacy will reflect any changes in model-based
123
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assessments of population dose. Standards have also not been proposed
directly in terms of person-reme because the regulatory implementation of
wuch a requirement does not appear to be administratively feasible for the
fuel cycle under existing widely varying geophysical and demographic
conditions and for doses that may, in some instances, be delivered over
indeterminately long periods of time. The proposed standards are expressed
in terms of 1) limits on individual doses to members of the public and 2)
on quantities of certain long-lived radioactive materials in the general
environment. On the basis of its assessments of the health risks
associated with projected annual population doses and environmental dose
commitments, the Agency has concluded that these two types of standards are
the most appropriate choice of criteria to provide effective limitation of
the potential health impact on populations of short-lived and long-lived
radioactive materials, respectively.
Even though adequate protection of populations considered as a whole
may be assured by standards based upon the above consideration of health
risks and control costs, it may not always be the case that adequate
protection is assured on this basis to some individuals in these
populations who reside close to the site boundaries of nuclear facilities,
because of the distribution characteristics of certain effluents. Such a
situation is possible in the case of thyroid doses due to releases of
radioiodines from reactors and fuel reprocessing facilities. Although the
risk from such doses to nearby individuals is quite small, it is
inequitable to permit doses to specific individuals that may be
124
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substantially higher than those to other members of the population from
other radionuclides. Additional protection for these individuals should be
provided when technology or other procedures are available for minimizing
any additional potential risk at a reasonable cost. The standards proposed
to limit doses to individuals reflect this additional requirement where it
is appropriate to do so.
TECHNICAL CONSipERATlONS. it is convenient to consider effects of
radioactive materials introduced into the environment by the uranium fuel
cycle in three categories. Prior to the occurrence of nuclear fission at
the reactor only naturally occurring radioactive materials are present in
fuel cycle operations. This first category of materials consists
principally of uranium, thorium, radium, and radon with its daughter
products. Radioactive materials introduced to the environment from
facilities for milling, chemical conversion, isotopic enrichment, and
fabrication of fuel from uranium which has not been recycled are limited to
these naturally occurring radionuclides. As a result of the power-
producing fission process at the reactor a large number of new
radionuclides are created as fission or activation products. These may be
introduced into the general environment principally by reactors or at fuel
reprocessing and are conveniently categorized as either long-lived or
short-lived fission and activation products, depending upon whether their
half-lives are greater than or less than one year. Although naturally
occurring radionuclides are of some concern, it is these fission and
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activation products which are of greatest concern from the point of view of
controlling radiation doses to the public due to nuclear power operations.
Standards are proposed for the fuel cycle in two major categories.
The proposed standards would limit: 1) the annual dose equivalent to the
whole body to 25 millirems, to the thyroid to 75 millirems, and to any
other organ to 25 millirems; and 2) the quantities of krypton-85/ iodine-
129, and certain long-lived transuranic radionuclides released to the
environment per gigawatt-year of power produced by the entire fuel cycle to
50,000 curies, 5 millicuries, and 0.5 millicuries, respectively. The first
standards are designed to limit population and individual exposures near
fuel cycle operations due to short-lived fission-produced materials and
naturally occurring materials, and due to transportation of any radioactive
materials, while the second specifically addresses potential population
exposure and buildup of environmental burdens of long-lived materials.
The proposed standard for annual whole body dose to any individual
limits the combined internal and external dose equivalent from gaseous and
liquid effluents as well as exposure to gamma and neutron radiation
originating from all operations of the fuel cycle to 25 millirems. Such a
limit is readily satisfied at all sites for which fuel cycle facilities are
presently projected through the year 1985 (including any potential overlap
of doses from adjacent sites) by levels of control that are cost-effective
for the reduction of potential risk achieved; is in accord with the
capabilities of controls anticipated by the AEC for all sites for which
Environmental Statements have been filed; and, on the basis of present
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operating experience at existing sites, can be readily achieved in
practice. The combined effect of any combinations of operations at the
same location that are foreseeable for the next decade or so was also
examined and is judged to be small, so that the proposed standards can
readily be satisfied by use of levels of control that are similar to those
required for single operations. It should be noted that this proposed
standard for maximum whole body dose, which is higher than that proposed by
the AEC as guidance for design objectives for light-water-cooled reactors,
differs from those objectives in that it applies to the total dose received
from the fuel cycle as a whole and from all pathways, including gamma
radiation from onsite locations. It is also not a design objective, but a
standard which limits doses to the public under conditions of actual normal
operation.
The appropriate level for a standard limiting the maximum annual total
dose to the thyroid of individuals is not easy to determine. A standard
for maximum total thyroid dose based on considerations limited to the same
criteria as for maximum whole body dose (cost-effectiveness of reduction of
total population impact and achievability) would permit unacceptably high
doses to individuals near some site boundaries. The proposed standard of
75 millirems per year to the thyroid has therefore been chosen to reflect a
level of biological risk comparable, to the extent that current capability
for risk estimation permits, to that represented by the standard for dose
to the whole body. The effluent controls required to achieve this limit
have been examined extensively by EPA, AEC, and the industry, particularly
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in regard to the AEC's proposed Appendix I to 10 CFR 50 for light-water-
cooled reactors, and, in the view of the Agency, this level of maximum
annual individual dose to the thyroid can be achieved at reasonable effort
and cost.
The principal potential doses to internal organs other than the
thyroid are to the lung via inhalation of airborne particulates and to bone
due to ingestion via water and other pathways of the naturally occurring
materials processed in the several components of the fuel cycle required to
convert uranium ore into reactor fuel. The impact on populations due to
effluents from these operations is generally quite small (due to their
predominately remote locations and lack of widespread dispersion), however,
significant lung doses are possible to individuals near to these
operations, particularly in the case of mills and conversion facilities.
The use of well-established, efficient, and inexpensive technology for the
retention and control of particulate effluents can readily achieve the
levels of control required to meet the proposed standard of 25 millirems
per year for limiting dose equivalent to the internal organs (other than
thyroid) of individuals.
Environmental radiation exposures from transportation operations are
due to direct radiation. Although average radiation doses to individuals
in the general public from transportation activities are very small,
situations in which individuals could receive higher doses may reasonably
be postulated. It is recognized that exposures due to transportation of
radioactive materials are difficult to assess and regulate because as
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shipments move in general commerce between sites the exposed population is
constantly changing. Transportation activities should be conducted with
every effort made to maintain doses to individuals as low as reasonably
achievable, consistent with technical and economic feasibility. In any
case, the maximum dose to any member of the general public due to uranium
fuel cycle operations, including those due to shipments of radioactive
materials, should not exceed the proposed standard of 25 millirems per year
to the whole body of an individual. The Agency will continue to examine
potential exposures due to transportation of radioactive materials with a
view to further action, if necessary.
Among the variety of long-lived radionuclides produced in the fuel
cycle, tritium, carbon-14, krypton-85, iodine-129, plutonium, and certain
other long-lived transuranic radionuclides are of particular significance
as environmental pollutants. Environmental pathways of tritium, carbon-14,
and krypton-85 are worldwide. Even though the balance of the above
radionuclides may not rapidly become widely dispersed, they are significant
because of their potential for extreme persistence in environmental
pathways, possibly for thousands of years for plutonium and other
transuranics, and for even longer periods for iodine-129.
Because of their high toxicity and long half-lives, the cumulative
impact of releases of plutonium and other transuranics to the environment
could be large. However, due to very large uncertainties concerning their
environmental behavior over long periods of time, as well as a lack of
definitive information concerning the relationship between exposure to
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these materials and health effects, the limits of this potential impact
cannot be more than roughly estimated. Therefore prudence dictates that
the environmental burden of these materials be minimized to the lowest
levels reasonably achievable. Similarly, although its toxicity is less
than that of the alpha-emitting transuranics, in view of the extreme
persistence of iodine-129 (half-life 17 million years) and great
uncertainty concerning its environmental behavior, environmental releases
of this isotope should be also maintained at the lowest level reasonably
achievable. The prevention of unlimited discharges of krypton-85 to the
environment from fuel cycle operations is of high priority because of its
potential for significant long-term public health impact over the entire
world. Finally, carbon-14 and tritium, both of which rapidly enter
worldwide pathways as gaseous radioactive materials, are of particular
concern because carbon and hydrogen are principal constituents of the
chemical structures of all life forms.
These long-lived radionuclides should only be discharged to the
environment after careful consideration of the tradeoffs between the
societal benefits of the power generated, the current and projected health
risks to populations, and the costs and effectiveness of methods available
to limit their release. Since the anticipated maximum dose to any single
individual from any of these materials is very small, the primary concern
is the cumulative risk to population groups over long periods of time. For
this reason, it is not of primary importance where or when in the fuel
cycle any such materials are released, since the committed impact will be
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Bimilar. What is important is to assure that any permitted discharge has
been offset by a beneficial product, i.e., a quantity of electricity, and
that every reasonable effort has been made to minimize it. It is also
important to assure that society is not burdened with unreasonable
expenditures to minimize these risks in order to gain the necessary
benefits of electric power. Fortunately the vast majority of potential
health effects due to release of these radionuclides can be avoided at a
reasonable cogt. The Agency estimates the coat of implementing the
proposed standards for these long-lived radioactive materials to be less
than $100,000 per potential case of cancer, leukemia, or serious genetic
effect averted (less than $75 per person-rem). In view of the above
considerations, the Agency believes that the proposed standards, which
limit the number of curies of certain of these radionuclides released to
the general environment for each gigawatt-year of electricity produced by
the fuel cycle, represent the most reasonable means of providing required
protection of the general environment for present and future generations.
Th« standards will assure that any environmental burdens of long-lived
radioactive materials accumulate only as the necessary result of the
generation of an offsetting quantity of electrical energy.
The proposed standards for long-lived materials fall into two
categories: those which can be achieved using currently available methods
for control of environmental releases, and those that require use of
methods that have been demonstrated on a laboratory or larger scale, but
have not yet achieved routine use. In the former case, exemplified by the
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standard of 0.5 millicuries per gigawatt-year for Plutonium and other long-
lived alpha-emitting transuranics, the standard limits the environmental
burden to the lowest level reasonably achievable using currently available
control methods. In the latter case, that of the proposed standard of
50,000 curies per gigawatt-year for krypton-85 and 5 millicuries per
gigawatt-year for iodine-129, these limiting levels of environmental
burdens are not those achievable by best demonstrated performance, but
instead by minimum performance reasonably anticipated from introduction of
these new systems into commercial operations. As experience is gained with
the ability of the industry to limit fuel cycle releases of these materials
to the environment, it may be appropriate to reconsider the standards
limiting the maximum environmental burdens of these particular
radionuclides.
Similarly, as knowledge becomes available concerning the
practicability of limiting environmental releases of tritium and carbon-14,
the appropriate levels of maximum environmental burdens of these
radionuclides due to fuel cycle operations will be carefully considered by
the Agency. However, the knowledge base now available is inadeguate for
such a determination, and no standards are presently proposed for these
radionuclides. The potential for a long-term impact due to carbon-14
released from fuel cycle operations was not recognized until the Agency
considered environmental dose commitments from the industry in the course
of developing these standards; thus consideration of methods for limiting
its release to the general environment are only now beginning. Tritium
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levels in the general environment from fuel cycle operations are not
expected to become significant until the late 1980's, and development
programs are in existence for control of releases of this radionuclide from
its principal source, fuel reprocessing operations. The Agency believes
that the development and installation of controls to minimize environmental
burdens of both carbon-14 and tritium are important objectives, and will
carefully follow the development of new knowledge concerning both the
impact and controllability of these radionuclides.
To allow adequate time for implementing the standards for krypton-85
and iodine-129 control, including the necessary testing and analysis
required prior to licensing of these control systems, the effective date is
proposed as January 1, 1983. Implementation by this date would result in
control of these releases before any substantial potential health impact
from these materials due to uranium fuel cycle operations can occur and
would, in the judgment of the Agency, provide adequate protection of public
health thereafter.
The proposed standard for maximum dose to organs excludes radon and
its daughter products. Radon is released as a short-lived (3.8 days half-
life) inert gas, mainly from tailings piles at mills, and produces its
principal potential impact through deposition of its daughter products in
the lung. There exists considerable uncertainty about the public health
impact of existing levels of radon in the atmosphere, as well as over the
best method for management of new sources of radon created by man's
activities, which remove this naturally occurring material and its
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precursors from beneath the earth's protective crust. Radon levels in the
general environment are substantial and are dominated by natural sources,
except in the immediate vicinity of man-made sources. Exposures from radon
and its daughters have previously been the subject of Federal Radiation
Protection Guidance, in the case of underground uranium miners (F.R. Doc.
71-7210 and F.R. Doc. 71-9697), and of guidance from the Surgeon General,
in the case of public exposure due to the use of uranium mill tailings in
or under structures occupied by members of the general public ("Use of
Uranium Mill Tailings for Construction Purposes," Hearings before the
Subcommittee on Raw Materials of the Joint Committee on Atomic Energy,
October 28 - 29, 1971, pp.226-233). The Agency has concluded that the
problems associated with radon emissions are sufficiently different from
those of other radioactive materials associated with the fuel cycle to
warrant separate consideration, and has underway an independent assessment
of man-made sources of radon emissions and their management.
IMPLEMENTATION OF THE STANDARDS. These proposed standards are expected to
be implemented for the various components of the uranium fuel cycle,
operating under normal conditions, by the Nuclear Regulatory Commission.
The mechanisms by which these standards are achieved will be a matter
between the NRC and the industries that are licensed to carry out various
uranium fuel cycle operations, but, in general, will be based on
regulations and guides for the design and operation of the various
facilities. The Agency is confident that these proposed standards can be
effectively implemented by such procedures.
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Current rules and regulations applicable to fuel cycle operations
generally contain provisions which have the effect of limiting doses to
individuals, thus implementation of the proposed standards for maximum
doses to individuals should be straightforward. Protection of the public
from the environmental accumulation of long-lived radioactive materials may
require some changes in regulatory requirements. For example, this
standard limits environmental accumulations of certain radionuclides
associated with the generation of a gigawatt-year of electrical energy,
which is generated only at the power reactor. Since other operations in
the cycle which do not generate power are more likely to discharge such
materials, it may be necessary for the regulatory agency to make an
appropriate allocation to each facility and to determine the emission rates
required to satisfy the standard for the entire fuel cycle. This is
especially the case for a radionuclide like krypton-85 which can be
released either at reactors, during fuel storage, or during fuel
reprocessing. The standards do not specify the time, location, or
concentration of emissions of long-lived radionuclides. Once a given
quantity of electrical power has been generated the specified amount of the
radionuclide may be released at any time and at any rate or location that
does not exceed the individual dose limitations. Demonstration of
compliance with the standard requires only that the total quantity of
electricity generated after the effective date of the standards be recorded
to determine the maximum quantity of these long-lived radionuclides that
may eventually be released.
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The Agency recognizes that implementation of the standards for
krypton-85 and iodine-129 by the proposed effective date of January 1,
1983, will require successful demonstration of control technology for
commercial use that is now in advanced stages of development. The Agency,
as stated above, intends to review all of these standards in at least five
year intervals. If substantial difficulty should develop for implementing
the standards for krypton-85 and iodine-129 with respect to the proposed
levels, facility safety, or cost, the Agency will give these factors
careful and appropriate consideration prior to the effective date.
With respect to operations associated with the supply of electrical
power it is important not only to set standards which will provide
satisfactory public health protection, consistent with technical and
economic feasibility, but also to minimize societal impacts which may occur
as the result of temporary interruptions in those fuel cycle operations
that are necessary to assure the orderly delivery of electric power. Such
a two-fold objective requires consideration of the question whether to
impose stricter standards which achieve lower levels of radiation exposure
and environmental burdens of long-lived radioactive materials, but which
may force temporary shutdowns which may not be justified on a risk-benefit
basis for such periods; or to establish more liberal standards which
decrease the possibility of such shutdowns, but may be overly permissive
with respect to public exposure and long-term environmental releases. The
Agency has attempted to avoid this dilemma by proposing standards that are
not permissive with respect to either public exposures or long-term
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environmental releases and at the same time providing a variance which
allows the standards to be temporarily exceeded under unusual conditions.
The use of such variances by the regulatory agency will depend to a large
degree upon their value judgments concerning the necessity of the fuel
cycle operation concerned to a region, overall facility safety, and the
possible impact on public health. The proposed variance provides that
temporary increases above the standards for normal operations are allowable
when the public interest is served, such as to maintain a dependable source
of continuous power or during a power crisis. The Agency anticipates that
the need to use such variances will be infrequent and of short duration,
and that the overall impact on population and individual radiation doses
from the operations of the entire fuel cycle will be minimal.
With respect to regulatory implementation of the flexibility provided
by this proposed variance provision, the Agency has carefully examined the
guidance for design objectives and limiting conditions for operation of
light-water-cooled nuclear power reactors as set forth recently by the NRC
in Appendix I to 10 CFR 50. It is the view of the Agency that this
guidance for reactors will provide an appropriate and satisfactory
implementation of these proposed environmental radiation standards for the
uranium fuel cycle with respect to light-water-cooled nuclear reactors
utilizing uranium fuel. The various monitoring and reporting procedures
required by the AEC in the past and supplemented by Appendix I are expected
to provide continuing information sufficient to determine that these
standards are being satisfied during the course of normal operations of the
fuel cycle.
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Although the Agency has attempted to limit the effect of radioactive
discharges from the fuel cycle on populations and on individuals through
these proposed standards, it has not attempted to specify constraints on
the selection oE sites for fuel cycle facilities, even though the Agency
recognizes that siting is an important factor which affects the potential
health impact of most planned releases from operations in the fuel cycle.
The standards were developed, however, on the assumption that sound siting
practices will continue to be promoted as in the past and that facility
planners will utilize remote sites with low population densities to the
maximum extent feasible.
The Aqency has also considered the need for special provisions for
single site>s containing large numbers of facilities, of single or mixed
types, as exemplified by the "nuclear park" concept. Present construction
projections by utilities indicate that no such sites are likely to be
operational during the next ten years. In view of the need to accumulate
operating experience for the new large individual facilities now under
construction and the intent of the Agency to review these standards at
reasonable intervals in the future, it is considered premature and
unnecessary no predicate these standards on any siting configurations
postulated for the next decade and beyond. The Agency will consider
changes in these standards based on such considerations when they are
needed and justified by experience.
It is th<5 conclusion of the Agency that implementation of the proposed
standards for normal operations of the nuclear power industry based on the
uranium fuel cycle will provide society protection of its environment and
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the health of its citizens and that this protection is obtained without
placing unreasonable financial burdens upon society. In this context,
these standards are responsive to the President's energy messages of June
4, 1971, and April 18, 1973, which challenged the Nation to the twin
objectives of developing sufficient new energy resources while providing
adequate protection for public health and the environment.
REQUEST^ FOR COMMENTS. Notice is hereby given that pursuant to the Atomic
Energy Act of 19r>4, ae amended, and Reorganization Plan No. 3 of 1970 (F.R.
Doc. 70-13374), adoption of Part 190 of Title 40 of the Code of Federal
Regulations is proposed as set forth below. All interested persons who
wish to submit comments or suggestions in connection with this proposed
rulemaking are invited to send them to the Director, Criteria and Standards
Division (AW-560), Office of Radiation Programs, Environmental Protection
Agency, Washington, D.C. 20460, within 60 days after publication of this
notice in the Federal Register. Within this same time period, interested
parties are also invited to indicate their desire to participate in a
public hearing on the proposed rulemaking to be scheduled after the comment
period ends. Comments and suggestions received after the 60-day comment
period will be considered if it is practical to do ao, but such assurance
can only be given for comments filed within the period specified. Single
copies of a Draft Environmental Statement for the proposed standards and a
technical report entitled "Environmental Analysis of the Uranium Fuel
Cycle" are available upon request at the above address. The above-
mentioned technical documents and comments received in response to this
notice, as well as comments received in response to the Agency's advance
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notice of this proposed rulemaking published on May 30, 1974, and the
Agency's response to these comments, constitute part of the background for
this rulemaking and may be examined in the Agency's Freedom of Information
Office, 401 M Street, S.W., Washington, D.C. 20460.
DATED:
Russell E. Train
Administrator
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ENVIRONMENTAL RADIATION: PROTECTION STANDARDS FOR
NORMAL OPERATIONS OF ACTIVITIES IN THE URANIUM FUEL CYCLE
A new Part 190 is proposed to be added to Title 40, Code of Federal
Regulations, as follows:
PART 190 - ENVIRONMENTAL RADIATION PROTECTION STANDARDS FOR NUCLEAR POWER
OPERATIONS
SUBPART A - GENERAL PROVISIONS
190.01 Applicability
The provisions of this Part apply to radiation doses received by
members of the public in the general environment and to
radioactive materials introduced into the general environment as
the result of operations which are part of a nuclear fuel cycle.
190.02 Definitions
a) "Nuclear fuel cycle" means the operations defined to be
associated with the production of electrical power for public
use by any fuel cycle through utilization of nuclear energy.
b) "uranium fuel cycle" means all facilities conducting the
operations of milling of uranium ore, chemical conversion of
uranium, isotopic enrichment of uranium, fabrication of
uranium fuel, generation of electricity by a light-water-
cooled nuclear power plant using uranium fuel, reprocessing of
spent uranium fuel, and transportation of any radioactive
material in support of these operations, to the extent that
these support commercial electrical power production utilizing
nuclear energy, but excludes mining operations and the reuse
of recovered non-uranium fissile products of the cycle.
c) "General environment" means the total terrestrial, atmospheric
and aquatic environments outside sites upon which any
operation which is part of a nuclear fuel cycle is conducted.
d) "Site" means any location, contained within a boundary across
which ingress or egress of members of the general public is
controlled by the person conducting activities therein, on
which is conducted one or more operations covered by this
Part.
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o) "Radiation" means any or all of the following: alphft, beta,
gamma, or x rays; neutrons; and high-energy electrons,
protons, or other atomic particles; but not sound or radio
waves, nor visible, infrared, or ultraviolet light.
f) "Radioactive material" means any material which emits
radiation.
g) "Uranium ore" is any ore which contains one-twentieth of one
percent (0.05%) or more of uranium by weight.
h) "Curie" (Ci) means that quantity of radioactive material
producing 37 billion nuclear transformations per second. (One
millicurie (mCi) = 0.001 Ci.)
i) "Dose equivalent" means the product of absorbed dose and
appropriate factors to account for differences in biological
effectiveness due to the quality of radiation and its spatial
distribution in the body. The unit of dose equivalent is the
"rem." (One millirem (mrem) = 0.001 rem.)
j) "Organ" means any human organ exclusive of the dermis, the
epidermis, or the cornea.
k) "Gigawatt-year" refers to the quantity of electrical energy
produced at the busbar of a generating station. A gigawatt is
equal to one billion watts. A gigawatt-year is equivalent to
the amount of energy output represented by an average electric
power level of one gigawatt sustained for one year.
1) "Member of the public" means any individual that can receive a
radiation dose in the general environment, whether he may or
may not also be exposed to radiation in an occupation
associated with a nuclear fuel cycle. However, an individual
is not considered a member of the public during any period in
which he is engaged in carrying out any operation which is
part of a nuclear fuel cycle.
m) "Regulatory agency" means the government agency responsible
for issuing regulations governing the use of sources of
radiation or radioactive materials or emissions therefrom and
carrying out inspection and enforcement activities to assure
compliance with such regulations.
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SUBPART B - ENVIRONMENTAL STANDARDS FOR THE URANIUM FUEL CYCLE
190.10 Standardo for Normal Operations
a) The annual dose equivalent shall not exceed 25 millirems to
the whole body, 75 millirems to the thyroid, and 25 millirems
to any other organ of any member of the public as the result
of exposures to planned discharges of radioactive materials,
radon and its daughters excepted, to the general environment
from uranium fuel cycle operations and radiation from these
operations.
b) The total quantity of radioactive materials entering the
general environment from the entire uranium fuel cycle, per
gigawatt-year of electrical energy produced by the fuel cycle,
shall contain less than 50,000 curies of krypton-85, 5
millicuries of iodine-129, and 0.5 millicuries combined of
plutonium-239 and other alpha-emitting transuranic
radionuclides with half-lifes greater than one year.
190.11 Variance for Unusual Operations
The standards specified in Paragraph 190.10 may be exceeded
if:
a) The regulatory agency has granted a variance based upon its
determination that a temporary and unusual operating condition
exists and continued operation is necessary to protect the
overall societal interest with respect to the orderly delivery
of electrical power, and
b) Information delineating the nature and basis of the variance
is made a matter of public record.
190.12 Effective Date
a) The standards in this Subpart, excepting those for krypton-85
and iodine-129, shall be effective 24 months from the
promulgation date of this rule.
b) The standards for krypton-85 and iodine-129 shall be effective
January 1, 1983.
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