DRAFT
MAR 7 1986
ADJUSTING RADIONUCLIDE REPORTABLE QUANTITIES --
ISSUES AND APPROACHES
Sections 103(a) and (b) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA) require any person in charge
of a vessel or facility to notify the National Response Center immediately of
any release of a hazardous substance in quantities equal to or greater than
its reportable quantity (RQ). The RQ for radionuclides established by CERCLA
is one pound and has not been adjusted by regulation. The Environmental
Protection Agency (EPA) recognizes that this RQ for radionuclides may not be
appropriate because releases of much less than one pound may present a
substantial threat to public health and welfare and to the environment. As a
consequence, EPA's Emergency Response Division is in the process of reviewing
issues and alternatives for adjusting the radionuclide RQ.
An interagency work group consisting of representatives of the Nuclear
Regulatory Commission, the U.S. Coast Guard, the U.S. Department of Energy
(DOE), the U.S. Department of Transportation (DOT), and several offices within
EPA has met on two occasions (December 13, 1985 and January 29, 1986) to
discuss issues and alternative approaches for adjusting the radionuclide RQ.
The work group meeting on January 29 focused on a draft discussion paper
covering radionuclide RQ adjustment options. This paper is a revision of the
draft discussion paper, incorporating comments received during and subsequent
to the work group meeting on January 29. The paper expands on options that
were found to warrant further study and documents decisions to eliminate other
options from additional consideration. In addition, this revision of the
discussion paper incorporates preliminary findings of an ongoing data
collection effort to characterize the potentially regulated community.
1. BACKGROUND
Before presenting issues and options for adjusting the radionuclide RQ, it
is useful to review several important requirements and policies concerning RQs
in general and how they relate specifically to radionuclides. The following
are statutory and regulatory requirements and EPA policy positions developed
in adjusting RQs for other hazardous substances. These points help focus
issues raised in evaluating options for adjusting the radionuclide RQ.
Radionuclides as a generic class of substances are
included as hazardous under CERCLA because they are
listed as hazardous air pollutants under the Clean Air
Act. Neither CERCLA nor regulation pursuant to the
Clean Air Act expands or restricts this generic term
in any fashion.
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DRAFT
Releases of source, byproduct, or special nuclear
material1 from processing sites designated under
Section 102(A)(1) or 301(A) of the Uranium Mill
Tailings Radiation Control Act are exempt from
response under CERCLA, but not exempt from CERCLA's
reporting requirements.
Releases of source, byproduct, or special nuclear
material from a nuclear incident2 at facilities
subject to the "Price-Anderson Act" are exempt from
all CERCLA requirements, including reporting
requirements. The Nuclear Regulatory Commission has
stated that nuclear reactors are the primary types of
facilities subject to the Price-Anderson Act.3
Releases of source, byproduct, or special nuclear
material that are "federally permitted" are exempt
from CERCLA's reporting requirements.*
All of CERCLA's provisions apply to releases of
naturally occurring and accelerator-produced
radioactive material, or NARM (e.g., radium and
radon), except for naturally occurring source material
under conditions noted above.
lSource material is defined as (1) uranium, thorium, or any combination
thereof or (2) ores which contain 0.05% (by weight) of uranium or thorium
(Section 11(z) of the Atomic Energy Act, and Nuclear Regulatory Commission
Regulations in 10 CFR Part 40). Byproduct material is (1) any material made
radioactive by exposure to radiation in the process of producing or using
special nuclear material or (2) the wastes produced by the extraction or
concentration of uranium or thorium from ore (Section 11(e) of the Atomic
Energy Act). Special nuclear material is defined as plutonium, or uranium
enriched in the U-235 or U-233 isotope (Atomic Energy Act Section ll(aa)).
2A nuclear incident is defined as any occurrence causing bodily injury,
sickness, disease, death, loss or damage to property, or loss of use of
property resulting from the radioactive, toxic, explosive, or other hazardous
properties of source, byproduct, or special nuclear material (Atomic Energy
Act Section ll(q)).
3 Statement from Bernie Weiss, Office of Inspection and Enforcement,
during the work group meeting on January 29, 1986.
"Section 101(10)(k) of CERCLA defines a federally permitted release as
any release of source, special nuclear, or byproduct material in compliance
with a legally enforceable license, permit, regulation, or order issued
pursuant to the Atomic Energy Act of 1954.
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DRAFT
2.
An RQ is not a measure of harm or injury which
should automatically initiate a government field
response. Instead, RQs provide a trigger for
notifying appropriate officials of hazardous substance
releases so that the need for a field response can be
evaluated and, if necessary, such a response can be
taken in a timely manner.
Other agencies have authority over and requirements
to be notified of radionuclide releases. These
agencies include the Nuclear Regulatory Commission,
individual states, DOE, and DOT. In addition, the
Federal Emergency Management Agency (FEMA), in
conjunction with eleven other federal agencies, has
developed the Federal Radiological Emergency Response
Plan (FRERP). The FRERP provides a mechanism for
responding to radiological emergencies. Appendix A
details the radionuclide release reporting
requirements of other agencies and briefly describes
the FRERP.
THE REGULATED COMMUNITY AND THE NEED FOR CERCLA REPORTING OF
RADIONUCLIDE RELEASES
The universe of radionuclide handlers, and thus potential radionuclide
releasers, can be grouped into the following five source categories: (1)
facilities licensed by the Nuclear Regulatory Commission; (2) non-DOE (i.e.,
Department of Defense) federal facilities; (3) DOE facilities; (4) coal-fired
utility and industrial boilers; and (5) mineral extraction industry
facilities, including uranium mining and aluminum, copper, zinc, lead, and
phosphate rock mining. The numbers and types of facilities, the principal
radionuclides involved, and past radionuclide releases from these source
categories are being evaluated as background in support of the radionuclide RQ
rulemaking. A preliminary characterization of the radionuclide source
categories is given in Appendix B of this paper.
Complicated jurisdictional issues arise in deciding precisely which
radionuclide releases are "federally-permitted" under CERCLA and therefore do
not have to be reported to the National Response Center. The Nuclear
Regulatory Commission and its agreement states1 license the possession of
* Agreement states are those states which have entered into an agreement
with the Atomic Energy Commission or its successor, the Nuclear Regulatory
Commission, pursuant to Section 274 of the Atomic Energy Act of 1954, as
amended. Under this agreement, the Commission has relinquished to such states
the majority of its regulatory authority over source, byproduct and small
quantities of special nuclear material.
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DRAFT
source, byproduct, and special nuclear material and any release of these
materials in compliance with a license are exempt from CERCLA's reporting
requirements. Certain DOE and Department of Defense (DOD) facilities,
however, are exempt from Nuclear Regulatory Commission and agreement state
licensing even though they handle source, byproduct, and special nuclear
material. Because these facilities do not operate under a federal license,
permit, regulation, or order pursuant to the Atomic Energy Act, it appears
that releases of source, byproduct, and special nuclear material from DOE and
DOD facilities must be reported to the National Response Center if they meet
or exceed the RQ. Likewise, releases of source, byproduct, and special
nuclear material from the remaining radionuclide source categories (i.e.,
coal-fired boilers and mineral extraction facilities), which are exempt from
Nuclear Regulatory Commission and agreement state licensing, are also subject
to CERCLA reporting.
Additional issues arise when considering requirements to report releases
of NARM. The Nuclear Regulatory Commission, and subsequently agreement
states, have authority under the Atomic Energy Act to license only source,
byproduct, and special nuclear material. All of the agreement states have
extended their licensing authority to cover NARM. Similarly, out of the 22
non-agreement states, all but three have regulatory programs for NARM that are
'equivalent to (or more strict than) the radiation protection requirements
spelled out in 10 CFR Part 20.s It therefore first appears that only
releases of NARM in those few states which do not have adequate regulatory
programs must be reported to the National Response Center. However, because
the states' authority to regulate NARM is not federally derived, releases of
NARM in any state can not, in general, be "federally" permitted. CERCLA
reporting for releases of NARM from all radionuclide source categories may
therefore be necessary.
3. DISCUSSION OF RADIONUCLIDE RQ ADJUSTMENT OPTIONS
This section discusses options for adjusting CERCLA's radionuclide RQ.
Section 3.1 presents options which, based on comments received from the
radionuclide RQ work group, are considered candidates for further analysis.
The principal issues involved with these options are noted, and some general
advantages and disadvantages of each are listed. Exhibit 1 summarizes how the
options compare against each other based on selected criteria. Section 3.2
presents options that were originally considered, but have been eliminated
from further consideration. The rationale for eliminating each of these
options is briefly discussed.
c Telephone communication between Barbara Hostage, EPA, and Lidia Roche,
Nuclear Regulatory Commission. February 1985. There may actually only be two
states which have no regulatory program for NARM -- no information has yet
been obtained on the regulatory program in South Dakota.
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DRAFT
3.1 Options That Warrant Further Analysis
The following are candidate options for adjusting the radionuclide RQ as
envisioned at this time: (1) generic listing, assign no RQ; (2) a
dose-equivalent level for the class; and (3) activity levels for each
nuclide. These options will be evaluated in detail in the Regulatory Impact
Analysis and Technical Background Document supporting the radionuclide RQ
rulemaking.
3.1.1 Option 1: Radionuclides Could Be Considered as a Generic
Class of Substances, Not Assigned an RQ, and Not Subject to
CERCLA Reporting Requirements
In the April 4, 1985 final rule establishing notification requirements and
adjusting reportable quantities for certain hazardous substances (50 FR
13456), EPA decided not to establish RQs for broad generic classes of organic
and metallic compounds even though they are designated as toxic pollutants
under Section 307(a) of the Clean Water Act and thus included in CERCLA's
hazardous substance list. The reasoning for this decision, as stated in the
preamble to that rule, was:
Many of the generic classes of compounds encompass hundreds
or even thousands of specific compounds. It would be
virtually impossible for the Agency to develop a reportable
quantity that would take into account the varying
characteristics of all the specific compounds in the class
(50 FR 13461).
It is unclear whether the same technical argument could be used to support
a decision not to establish an RQ for radionuclides. Although the term
radionuclides encompasses hundreds of radioactive isotopes and countless
chemical compounds involving these isotopes, it is possible to set a single RQ
for the generic class and still take into account some of the unique
characteristics of individual radionuclides (see discussion for Option 2
below). A decision not to establish a radionuclide RQ may be supported,
however, by a finding that existing reporting mechanisms for radionuclide
releases are adequate and that any additional reporting pursuant to CERCLA
would provide no additional benefit. To this end, existing reporting
requirements for radionuclide releases, the likelihood of releases of
particular radionuclides, and other relevant issues are being examined to help
determine whether or not this option is defensible.
Deciding not to establish an RQ for radionculides would eliminate the
requirement to report sufficiently large releases to the National Response
Center; however, radionuclides would remain listed as a hazardous substance
and subject to CERCLA response requirements and liability provisions. This
approach would rely upon existing release reporting requirements of other
agencies (see Appendix A). If found to be necessary, memoranda of
understanding (MOUs) or interagency agreements (lAGs) could be developed to
assure that all appropriate agencies are notified of radionuclide releases --
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DRAFT
in essence, to assure that the National Response Center's function of dissem-
inating information is carried out. Establishing such a notification network
might simply involve revisions to existing MOUs and lAGs rather than the
development of new ones. As an alternative, a system for disseminating a radio-
nuclide release report among government agencies could be built into the FRERP.
Principal issues raised by this option include:
It is uncertain at this time if there is adequate
justification for not establishing a radionuclide RQ
under CERCLA. Specifically, existing reporting
requirements of other agencies may inadequately cover
NARM and/or may have a different focus than desired by
EPA (e.g., several existing requirements are based
only on potential human health effects or cover only
releases to offsite areas).
It is uncertain whether interagency notification
systems need to be improved and, if so, what would be
the appropriate mechanism for improving them (e.g.,
MOUs, lAGs, or the FRERP).
Advantages to not establishing a radionuclide RQ include:
It would be simple and would generate the least
amount of costs for government and the regulated
community of all the options reviewed in this paper.
Duplication of and conflicts with other Federal and
State reporting requirements would be minimized,
resulting in no increased confusion or interference
for the regulated community.
There would be little to no interference with
existing reporting programs of other agencies, even if
interagency notification systems were modified or
expanded.
If additional release reporting among government
agencies were formalized as part of this option, the
various agencies may benefit from improved
communication and shared expertise.
Disadvantages to this option include:
There may be no requirement to notify the government
of certain releases of which the government would like
to be aware.
Choosing not to regulate radionuclides through
CERCLA RQs may draw significant opposition from the
public and environmental groups.
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C^AFT
3.1.2
Developing or modifying MOUs or lAGs, if found to be
necessary, may be time consuming.
There may be no central clearinghouse of reporting
data.
Option 2: A Dose-Equivalent Level Could Be Established as
the Radionuclide RQ
Radionuclides could be considered as a class with a dose-equivalent level,
or set of dose-equivalent levels,7 assigned to the entire class.
Alternatively, ongoing analyses of the various degrees of hazard posed by
different radionuclides, the extent to which various nuclides are used,
existing regulatory and reporting programs governing particular radionuclides,
and other issues may ultimately lead to a finding that RQs are needed for only
certain radionuclides. In this case, if determined to be useful, the
dose-equivalent level(s) may apply only to releases of those radionuclides
found to be a "problem." Regardless of whether it was for one or for all
radionuclides, an RQ in terms of dose-equivalent would apply to potential
doses as well as to actual doses.
A dose-equivalent level, in units of rems or seiverts, is a measure of the
amount of biological damage resulting from exposure to ionizing radiation.
Estimating a dose-equivalent level can be quite complicated and its magnitude
may vary substantially for different circumstances.1 For example, different
radionuclides, nuclide solubilities and particle sizes, exposure pathways,
periods of exposure, and bodily organs being exposed may yield order-of-
magnitude differences in dose-equivalent levels. Nevertheless, using standard
assumptions for these and other factors, a dose-equivalent level may be
7 Dose equivalent limits are frequently established in groups, such as
25 millirem to the whole body and 75 millirem to the thyroid gland (for
example, see the environmental radiation standards in 40 CFR Part 190 and the
emission standards for hazardous air pollutants in 40 CFR Part 61).
* Calculating dose-equivalents resulting from a level of activity
released into the environment is a two step process: (1) environmental fate
and transport characteristics must be considered to relate a level of activity
released to a level of activity at a point of potential exposure; and (2)
dose-equivalent is calculated based on exposure to the activity level at the
exposure point. A simplified expression relating activity levels at the point
of exposure to dose-equivalent levels is:
r Radioactivity -\ r Human Intake i
|Concentration: j | Rate: |
I |X| |
| Curies | | Milliliters |
L
Milliliter
Dose-Equivalent (Rem)
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r Period of i r Dose Conversion
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J L J L Curie
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DRAFT
directly related to a level of activity for particular radionuclides.
Therefore, in terms of releases that would be reportable, a single
dose-equivalent RQ would not differ much from individual RQs in terms of
activity levels for different radionuclides (see discussion for Option 3
below).
If an RQ in terms of dose-equivalent were established, the following
issues would have to be addressed:
* A particular dose-equivalent level would have to be
established. If this level were inconsistent with
existing reporting levels of other agencies,
conflicting reporting requirements may be in effect
and confusion among the regulated community could
result.
The appropriate entities to be informed of releases
would have to be established. CERCLA provides that
releasers must notify the National Response Center
directly. Would releasers also be required to notify
those entities to which they may already be required
to report? What would be the Center's function once
it was notified of such a release and what would be
the function of other agencies?
If release reports were made to groups other than
the National Response Center, would it be necessary to
formalize an interagency notification network? If so,
what would be the appropriate mechanism for
establishing such a network (e.g., MOUs, lAGs, or the
FRERP)?
Dose-equivalent limits typically specify acceptable
exposures for certain situations, such as a period of
exposure and a particular target organ. Such
particulars would have to be designated for a
radionuclide RQ in terms of dose-equivalent.
* EPA may wish to specify or establish a standardized
methodology for estimating a dose-equivalent level in
order to assure consistency among releasers and to
assure that dose calculations are technically accurate.
Advantages to this option include:
It would be simpler to develop than Option 3 below,
which requires an analysis of individual radionculides.
A dose-equivalent value could be used to assess
potential health effects without having to make
further assumptions or performing additional
calculations.
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It would be in the same units, and therefore easily
compared, to many existing and recommended criteria
for radiation protection and many existing
reporting-level triggers.
*
It would be equally valid for a single radionuclide
and for mixtures of radionuclides.
Disadvantages include:
A dose-equivalent level is more difficult to
estimate quickly during an actual release event than
an activity level (see Option 3 below).
Estimating dose-equivalent levels requires making
numerous assumptions, and the level of dose may vary
drastically under different assumptions. This
potential variability, even with a standardized
calculation methodology, makes it difficult to (1)
assure that the government will be notified of all
radionculide releases that it wants to be notified
about; and (2) enforce a dose-equivalent level RQ.
A dose-equivalent RQ relates solely to human health
effects and not to potential environmental (non-human)
harm, although it may not be difficult to estimate
non-human impacts based on a human dose level.
4.1.3 Option 3: RQs in Terms of Activity Levels Could Be
Established for Each Radionuclide Individually
Radionuclides could be considered individually with a level of activity
set for each one depending on its particular characteristics. A level of
activity, in units of curies or becquerels, is a measure of the rate of
radioactive decay and thus the amount of radiation given off by a substance.
Exposure to a certain number of curies, under specific conditions, will create
a certain level of biological damage or dose-equivalent (i.e., rems).
As mentioned in the discussion for Option 2, RQs in terms of activity
levels could be established for all radionuclides or just for certain ones.
Particular radionuclides that may warrant regulation through a CERCLA RQ could
be those for which release reports are not uniformly required (e.g., perhaps
certain NARMs such as radium), radionuclides which present a significant
health or environmental threat when released, or radionuclides which have been
or are likely to be released frequently.
The adoption of specific RQs for individual radionuclides raises the
following issues:
The same institutional issues raised by Option 2
regarding implementation of an RQ would also have to be
addressed under this option. Namely:
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the appropriate entities to receive reports of
releases would have to be determined (i.e., the
National Response Center and/or some other
group(s)); and
existing interagency notification systems may need
to be refined or new ones developed.
RQs in terms of activity levels would have to be
designed to protect against a certain dose-equivalent
level. Therefore, a particular dose-equivalent level
would also have to be selected to serve as the basis
for the activity limits. As discussed under Option 2,
confusion among the regulators and the regulated
community could result if the dose-equivalent level
selected for radionuclide RQs differs substantially
from any dose-equivalent levels set in existing
reporting requirements.
A well-established and accepted methodology for
deriving activity levels based on a dose-equivalent
limit already exists. However, several variables
depending on the exposure scenario are required in this
calculation, and a "reasonable" scenario would have to
be agreed upon to develop activity level RQs.
* Radionuclide-specific activity limits are typically
established for different environmental media and for
different radionuclide forms because varying these
factors may lead to entirely different dose levels.
The merits of establishing multiple RQs for a single
radionuclide, based on different media and different
radionuclide solubilities, must be weighed against the
merits of establishing a single RQ for each
radionuclide.
Principal advantages to establishing activity level RQs for individual
radionuclides include:
A level of radioactivity is generally much easier to
measure than a dose-equivalent, would be easier to
confirm, and would provide more timely reporting than
an RQ in terms of dose-equivalent.
* Unlike Option 2 which considers radionuclides as a
class, establishing RQs for radionuclides individually
would allow consideration of individual radionuclide
characteristics (e.g., nuclide forms and the potential
to migrate through the environment).
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t :
U.
Unlike dose-equivalent units, a level of
radioactivity is not solely a measure of potential
human health effects. Consequently, an activity level
RQ may be more easily related to potential
environmental (non-human) harm.
However, the nuclide-specific RQ approach also has disadvantages:
Establishing individual RQs would be more complex
than considering radionuclides as an entire class of
substances (see Option 2). However, establishing
individual RQs in units of curies would not
necessarily be very complex if existing activity
limits of the Nuclear Regulatory Commission (in 10 CFR
Part 20) were used or if existing methodologies used
to derive these limits were also used to develop RQs.
The biological effect created by each radionuclide
released together in a mixture is additive. To
account for this effect, there is an established
method for determining the total quantity (level of
activity) and hazard associated with radionuclide
mixtures. Nuclide-specific RQs would require the use
of this or a comparable method to assure appropriate
reporting of releases of radionuclide mixtures. In
this respect, activity level RQs would be more complex
to implement than a dose-equivalent level RQ (Option
2), which is equally valid for one radionuclide and
for nuclide mixtures.
Unlike a dose-equivalent value, a level of activity
by itself does not necessarily reflect a level of
danger to human health. As is presently the case for
the RQs for non-radioactive substances, a case-by-case
evaluation by those people receiving reports may be
necessary in order to estimate the health hazards
associated with an RQ in units of curies.
3.2 OPTIONS NOT BEING EVALUATED FURTHER
The following options are among the ones that were considered by the
interagency work group: leaving the RQ at one pound; establishing a
non-quantitative RQ; establishing a single level of activity as the RQ for the
class; and assigning activity level RQs to radionuclide groups. After
examination, however, these options are not being evaluated further for the
reasons given below.
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3.2.1 Option 4: The Radionuclide RQ Could Be Left At One Pound
While a one-pound RQ might be useful as a "safety net" (i.e., require
reporting for large, infrequent releases), this RQ level would not be
sufficiently stringent to trigger timely reporting or response for releases of
many radionuclides. In many cases, releases of radionuclides that are several
orders of magnitude smaller than one pound can represent a health and
environmental risk deserving of National Response Center reporting. Other
disadvantages of this option include:
A one-pound RQ does not conform to commonly accepted
units or accepted levels for radiation protection
(e.g., rems or curies, although a pound is easily
related to a number of curies for different
nuclides). A one-pound RQ level would differ
significantly from reporting requirements under other
regulations prepared by EPA and other agencies.
' This option would involve a single RQ level for the
entire class of radionuclides, which would not take
into account the variety of hazards posed by different
radionuclides. Because each radionuclide has a unique
specific activity (i.e., a certain number of curies
for one pound), a single one-pound RQ would relate to
different numbers of curies -- and different risk
levels -- for all radionuclides.
Although this option is not considered viable, it will be evaluated as the
baseline in the economic analysis supporting the RQ rulemaking.
3.2.2 Option 5: Radionuclides Could Be Considered as a Class of
Substances, With a Qualitative RQ Assigned to the Class
A qualitative RQ might be, for example, a requirement for responsible
parties to report releases of radionuclides "in such quantities and under such
circumstances that it appears there is substantial danger to the public health
or welfare or to the environment." This type of reporting requirement, in
conjunction with numerical reporting thresholds, is presently imposed on
licensees of the Nuclear Regulatory Commission (10 CFR Section 20.402(a)).
DOE and several states also have non-quantitative reporting requirements.
Although this option would be useful as a safety net by requiring
reporting for important releases not covered by a numerical RQ, a qualitative
RQ by itself would not be sufficient. The primary shortcoming is that such an
RQ would be extremely difficult to enforce -- what one person considers a
"substantial threat" may differ significantly from that considered by
another. This option would also suffer from the following disadvantages:
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Because all other CERCLA RQs are numeric, the
appropriateness of a qualitative trigger is
questionable. Such an approach would be inconsistent
with the CERCLA legislative history calling for clear
and simple reporting requirements.
A non-quantitative trigger would be subject to
arbitrary interpretation, creating confusion and
inconsistent reporting practices (over-reporting or
under-reporting) among responsible parties.
A non-quantitative RQ would rely on the regulated
community to make decisions concerning the importance
of a release and the need for field response -- not
government officials as intended by CERCLA.
3.2.2
Option 6:
the Class
A Single Level of Activity Could Be Established for
This option has the advantage of being simple and relatively easy to
measure quickly during a release event. It does not, however, account for the
varying degrees of hazard posed by different radionuclides. This point is
best illustrated by example. Exhibit 2 shows the different dose-equivalent
levels which may result from the inhalation of the same number of curies of
different radionuclides.
As shown in Exhibit 2, a release of one microcurie of all five
radionuclides may result in entirely different dose-equivalent levels. This
problem is exacerbated when considering all the different radionuclides
(approximately 200) and their respective potentials to cause biological damage.
Therefore, while simplicity in reporting must be sought, it should not be
accomplished by glossing over substantial differences among individual
radionuclides. It would be extremely difficult to derive an RQ which is a
single level of activity and that would provide timely reporting of the most
hazardous radionuclides while not being overly conservative for others. A
single level of activity could, however, be an appropriate RQ if it was only
applied to a group of similar radionuclides (see Option 7 below). For
example, one activity level RQ may be appropriate for uranium-238, radium-226,
and plutonium-238, which all may yield similar dose-equivalent levels (see
Exhibit 2).
3.2.4 Option 7: Radionuclides Could Be Grouped into Categories with a
Level of Activity Assigned to the Separate Categories
Radionuclides may be segregated into various groups in such a way that a
single level of activity may be an appropriate RQ for all the radionuclides
within a given group. For example, radionuclides that are generally expected
to migrate the same extent through the environment and/or cause similar levels
of biological damage may be grouped together. One RQ, which would assure
timely reporting for releases of the most hazardous radionuclide(s), could
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f >-**
L> .!..
EXHIBIT 2
DOSE-EQUIVALENTS RESULTING FROM THE INHALATION
OF ONE MICROCURIE OF DIFFERENT RADIONUCLIDES
Nuclide
Dose-equivalent to adult lungs
if one microcurie is inhaled a/
(rems)
Hydro gen -3
Technetium-99
Uranium-238
Radium-226
Plutonium-238
1 x 10 "
2 x 10"2
49
56
64
a/ Dose-equivalent levels based on each
radionuclide having the same solubility and the
same particle size.
Source; Dunning et. al., 1981. Estimates
of Internal Dose Equivalent to 22 Target Organs
for Radionuclides Occurring inRoutine Releases
from Nuclear Fuel-Cycle Facilities, Vol. III.
Oak Ridge National Laboratory.
Vol. 3.
NUREG/CR-0150,
then be assigned to the overall group. As another example, radionuclides
could be grouped into "half-life categories" with progressively less stringent
RQs for those categories having shorter half-lives. The RQs for
nonradioactive substances have been established in this fashion, with
different RQs for different groups of chemicals.
The work group does not intend to evaluate this approach further for two
general reasons. First, the option does not appear to have any unique
advantages. Its primary attraction is that it may be simpler to establish an
activity level RQ for groups of similar radionuclides than it would be to
establish separate RQs for each radionuclide individually. However, this
approach may in fact not be simpler because a logical scheme for grouping
radionuclides would first have to be determined. The second major
disadvantage to this option is that it would differ in approach from existing
reporting requirements for radionuclides (existing requirements typically
specify activity levels for individual radionuclides or dose-equivalent levels
for the entire class). As such, activity level RQs established for
radionuclide categories may be confusing and difficult to implement.
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APPENDIX A
EXISTING REQUIREMENTS TO REPORT RADIONUCLIDES RELEASES
This appendix describes the radionuclide release reporting requirements
and processes of the Nuclear Regulatory Commission, the Department of
Transportation, the Department of Energy, and individual states. The Federal
Radiological Emergency Response Plan is also briefly described.
A.I NUCLEAR REGULATORY COMMISSION
The Nuclear Regulatory Commission controls the handling of nuclear
materials through an extensive licensing and regulatory program. This program
includes several different requirements for responsible parties to immediately
report releases of radionuclides.
The extent of the Commission's regulatory jurisdiction is limited to
certain types of nuclear materials and to certain parties who may handle these
materials. First, the Commission only licenses source, byproduct, and special
nuclear material as defined by the Atomic Energy Act. In general, the
Commission does not license naturally occurring and accelerator-produced
radioactive materials (NARM), although naturally occurring radioactive
materials may be subject to Commission regulation when they are associated
with source, byproduct or special nuclear material being used under an active
license. Second, certain activities of the Department of Energy and the
Department of Defense -- even though these activities involve source,
byproduct, and special nuclear materials -- are exempt from Commission license
requirements.
Existing Commission requirements for licensees to report radionuclide
releases immediately are described below. In addition to these requirements,
the Commission has several other requirements to report within a specified
time after a release, but not immediately (e.g., within 24 hours and within 30
days). These "non-immediate" reporting requirements are not presented below
because they could not be used as substitutes for the immediate notification
requirement in CERCLA's section 103. Once the Commission receives such
release notifications it, among other things, oversees the licensee's response
action, provides guidance and expertise, disseminates important information,
and coordinates with other relevant agencies. The Commission does not have a
budget to undertake active cleanup responses on its own.
A. 1.1 Regulations
Nuclear Regulatory Commission regulations in 10 CFR Part 20 set standards
for protection against radiation and are applicable to all persons who
receive, possess, use, or transfer any nuclear material licensed by the
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A-2
Commission. Part 20 is undergoing revision and is expected to be reissued as
a proposed rule in the near future. The following are immediate reporting
requirements contained in the version of 10 CFR Part 20 recently approved for
issuance as a proposed rule.
Each licensee shall report by telephone, immediately
after its occurrence becomes known, any lost, stolen, or
missing licensed material in such quantities and under
such circumstances that it appears to the licensee that
a substantial exposure could result to persons in
unrestricted areas. Such reports shall be made either
to the Commission's Operations Center or to the
appropriate Commission Regional Office (10 CFR Section
20.1201(a)).
Each licensee shall immediately report any event
involving byproduct, source, or special nuclear material
possessed by the licenssee which may have caused or
threatens to cause any of the following (10 CFR Section
20.1202(a)):
an individual to receive a deep dose-equivalent of
25 rems or more, a dose-equivalent to the lens of
the eye of 75 rems or more, or an absorbed dose to
the skin or extremities of 250 rads or more; or
the release of radioactive material, inside or
outside of a restricted area, so that, had an
individual been present for 24 hours: (1) the
individual could have received an intake five times
the occupational annual limit of intake; or (2) for
certain licensees, the individual could have
received an effective dose-equivalent of 5 rems in a
year.
Additional regulations of the Nuclear Regulatory Commission specifically
applicable to the licensing of byproduct, source, and special nuclear material
are given in 10 CFR Parts 30, 40, and 70, respectively. Each of these sets
of regulations contain provisions for licensees to "promptly" report to the
Commission any attempt to steal or unlawfully divert certain quantities of
byproduct (tritium), source, or special nuclear material (10 CFR Sections
30.55(c), 40.64(c), and 70.52(b)). Other immediate notification requirements
in these regulations are:
When a we11-logging source containing byproduct or
special nuclear material becomes irretrievable in a
well, the licensee shall notify the Commission of the
circumstances of the loss by telephone (10 CFR Sections
30.56(b) and 70,60(b)).
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A-3
Each licensee shall report immediately by telephone
and telegraph, mailgram or facsimile any case of
accidental criticality1 and any loss, other than
normal operating loss, of special nuclear material
(Section 70.52(a)).
A. 1.2 License Conditions
The Nuclear Regulatory Commission has the authority to incorporate in any
of its nuclear material licenses additional requirements and conditions as it
deems necessary in order to protect public health and welfare and the
environment. If appropriate, based on the particular circumstances involved,
such license conditions may require additional reporting than explicitly
called for in the regulations. Furthermore, because licensees are required
(10 CFR Section 20.1(c)) to maintain radiation exposures and releases to the
environment as low as reasonably achievable (ALARA), the Commission may
establish reporting level triggers that are below those specified in 10 CFR
Part 20. For example, 10 CFR Section 20.105(c) requires uranium fuel cycle
facilities to comply with the offsite dose limit of 25 mrem/year. If several
years worth of monitoring data demonstrate, however, that a facility operates
well below the 25 mrem/year limit, the Commission typically imposes a license
condition requiring notification of and response to environmental releases
that may cause less than 25 mrem/year. As another example, the Commission
commonly requires a licensee to immediately report an environmental monitoring
result that is some fraction of the release concentration allowed in the
regulations. These additional reporting requirements specified through
license conditions may vary substantially from one licensee to the next.
A. 1.3 Radiological Contingency Plans
The Nuclear Regulatory Commission has taken special steps to assure
adequate accident response preparedness at licensed facilities that have the
potential for accidents which could result in (1) offsite doses exceeding 1
rem to the whole body, 5 rems to the thyroid or 3 rems to other critical
organs,2 or (2) potentially serious radiation overexposures of workers from
a nuclear criticality incident or from release of radioactive materials, or
(3) chemical exposures which could impact radiological safety. The Commission
identified 62 fuel cycle and radioactive materials licensees that meet these
criteria, and required them to either submit radiological contingency plans or
to lower the amount of nuclear material kept under their possession. About
half the licensees submitted plans which, after meeting Commission approval,
1 An unplanned, uncontrolled nuclear fission reaction.
2 Radiation doses of 1 rem to the whole body and 5 rems to the thyroid
are the lowest protective action guides established by the EPA for triggering
protective action in public areas following a radiation accident. See
EPA-520/1-75-001, Draft Revision of June, 1980.
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'. i It .5
A-4
have been incorporated as a license requirement.
possession limit or surrendered their license.
The other half lowered their
Radiological Contingency Plans incorporate specific provisions to be
followed in the event of an accident, including steps to assure (1) that
notifications are promptly made to Federal, State, and local agencies, and (2)
that necessary recovery actions are taken in a timely fashion to return a
plant to a safe condition following an accident. The plans specify what
reports will be made to keep various government agencies, corporate
management, and the public informed. Formal agreements between the licensee
and offsite support organizations are also incorporated into the plans.
The Commission is also in the process of evaluating the need for a new
proposed rule to require additional emergency preparedness for certain
licensees. The purpose of the rule, if proposed, would be to require those
licensees who possess radioactive materials in large quantities to have
additional emergency procedures for offsite releases. These procedures would
include steps for notifying offsite authorities and the Commission in the
event of emergency situations.
A.2 DEPARTMENT OF TRANSPORTATION
The Department of Transportation (DOT) is responsible for regulating
safety in the transportation of all hazardous materials. Accordingly, DOT has
promulgated the Hazardous Materials Regulations (49 CFR Parts 171-177) to
govern the transportation of hazardous materials, including radioactive
materials. DOT defines radioactive material as any material having a specific
activity greater than 0.002 microcuries per gram. This broad definition
includes source, byproduct, and special nuclear materials licensed by the
Nuclear Regulatory Commission, as well as NARM outside of the Commission's
regulatory jurisdiction.
The DOT regulations are organized with requirements applicable to all
modes of transportation in 49 CFR Part 171 and requirements applicable to
specific transportation modes (e.g., rail, aircraft, ship, and highway) in
subsequent parts. DOT's release reporting requirements applicable to all
modes of transportation are:
At the earliest practicable moment, each carrier who
transports hazardous materials shall give notice after
each transportation incident involving the shipment of
radioactive material in which fire, breakage, spillage,
or suspected radioactive contamination occurs. This
notice shall be given to the National Response Center by
telephone, and each notice must provide information
spelled out in the regulations (49 CFR Sections
171.51(a) and (b)).
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A-5
Each carrier making an immediate report in accordance
with Section 171.15, just discussed, shall also submit
to DOT (the Materials Transportation Bureau) a detailed
incident report. This written report must be submitted
within 15 days from the date of discovery of the
incident (49 CFR Section 171.16).
Additional reporting requirements specific to different transportation
modes include requirements for carriers to immediately notify shippers of an
incident in which there has been breakage, spillage, or suspected radioactive
contamination. If an accident occurs during the shipment of radioactive
materials by aircraft, the carrier is required to immediately notify the
nearest FAA Civil Aviation Security Office by telephone (as specified in 49
CFR Section 175.45). Fulfillment of this notification requirement exempts the
carrier from having to notify the National Response Center. Additionally, in
cases of obvious leakage of radioactive material aboard the aircraft, DOT
regulations state the carrier should notify the Regional Office of the U.S.
Department of Energy or the appropriate State or local radiological
authorities (49 CFR Section 175.700(b)). For accidents involving radioactive
materials onboard a vessel, the captain of the vessel is required to
immediately notify the nearest Coast Guard Captain of the Port (49 CFR
Sections 176.48(a) and (b)).
According to a Memorandum of Understanding (MOU, 44 FR 38690-2) between
DOT and the Nuclear Regulatory Commission (NRC), DOT will promptly notify the
Commission of any accidents, incidents, and instances of actual or suspected
leakage involving radioactive material packages if such an event occurs in
transit. Also, DOT has the responsibility of encouraging the non-agreement
states3 to impose incident reporting requirements for radioactive materials
on shippers and receivers subject to the states' jurisdiction.
A.3 DEPARTMENT OF ENERGY
The Department of Energy (DOE) plays two entirely different roles in the
area of radionuclide release reporting. First, DOE may be a releaser of
radionuclides subject to reporting requirements. DOE controls many
government-owned, contractor-operated facilities that may release
radionuclides to the environment, including facilities engaged in research and
development, nuclear weapons production, enrichment of uranium for nuclear
reactors, and facilities that process, store, and dispose of radioactive
waste. Many of the research facilities controlled by DOE are accelerators,
which generate accelerator-produced radioisotopes (included under "NARM").
'Agreement states are those states which have entered into an agreement
with the Atomic Energy Commission or the Nuclear Regulatory Commission
pursuant to Section 274 of the Atomic Energy Act of 1954, as amended, under
which the Commission has relinquished to such states the majority of its
regulatory authority over source, byproduct and special nuclear material in
quantities not sufficient to form a critical mass.
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A-6
There are many established requirements for DOE to immediately report on
radionuclide releases. Many of these requirements are self-imposed, being
spelled out in several different internal orders. DOE Order 5000.3 spells out
the Department's system for reporting unusual occurrences, and Order 5484.1
specifies DOE's reporting requirements for environmental and health protection
information. These requirements typically call for individual facilities to
report releases to a regional operations office, which may in turn report the
release to DOE headquarters. Several different criteria for a variety of
"occurrences" and "unusual occurrences" have been established to specify when
reporting is required immediately. As a matter of policy, DOE also requires
reporting to external organizations to keep them apprised of important events
at DOE facilities. Externally-imposed reporting requirements include any of
those specified by EPA and possibly state agencies. DOE is generally exempt
from licensing by the Nuclear Regulatory Commission and is thus exempt from
the Commission's reporting requirements highlighted above.
The other role played by DOE in the event of radionuclide releases is to
provide expertise, guidance, and assistance in response to radiological
hazards created by others. In accordance with the Federal Radiological
Monitoring and Assessment Plan (FRMAP), other parties requiring radiological
assistance may contact DOE. The Department in turn will work with appropriate
State and local agencies to coordinate offsite radiological monitoring and
assessment data. DOE will assess radiological monitoring data and present
them, along with recommendations, to the parties responsible for taking
emergency or remedial action.
A.4 STATE PROGRAMS
States may be classified as either agreement states or non-agreement
states. Agreement states are those who have entered into an agreement with
the Nuclear Regulatory Commission giving the state most of the Commission's
authority to license certain quantities of source, byproduct, and special
nuclear material. There are presently 26 agreement states. Non-agreement
states have not entered into such agreements with the Commission. Regulatory
programs for radioactive material are not necessarily void in non-agreement
states, but these states rely on the Commission to carry out its licensing
program for source, byproduct, and special nuclear material within the state.
State programs for regulating radioactive material, including requirements
to report releases of radionuclides, differ greatly. All 26 agreement states
have licensing programs covering NARM. In addition, the Commission has
reported that out of the 22 non-agreement states, all but three have
regulatory programs for NARM that are reported to be at least as stringent as
the Nuclear Regulatory Commission's regulations in 10 CFR Part 20.*
* Telephone communication between Barbara Hostage, EPA, and Lidia Roche,
Nuclear Regulatory Commission. February 1985. There may actually only be two
states which have no regulatory program covering NARM -- no information has
yet been obtained on the regulatory program in South Dakota.
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A-7
Lit W""Vi
A.5 THE FEDERAL RADIOLOGICAL EMERGENCY RESPONSE PLAN
On December 7, 1979, the President directed that the Federal Emergency
Management Agency (FEMA) assume lead responsibility for all federal off-site
nuclear emergency planning and response. Additionally, the President
delegated to FEMA the responsibility for the development and promulgation of
the National Radiological Emergency Preparedness/Response Plan for Commercial
Nuclear Power Plant Accidents, also known as the Master Plan (45 FR 84910).
This Master Plan has been superseded by the Federal Radiological Emergency
Response Plan, or FRERP (50 FR 46542). The FRERP establishes formal roles and
responsibilities for federal agencies in response to a wide range of peacetime
radiological emergencies (e.g., fixed nuclear facility incidents,
transportation incidents, and other types of events involving radionuclide
releases). FEMA is responsible for coordinating non-technical responses under
the FRERP, providing assistance to state and local governments, and providing
logistic support to federal agencies.
There are at least three important features of the FRERP that should be
noted. First, the FRERP spells out a pre-established system for notifying all
appropriate federal agencies of a radiological emergency. In general, the
owner or operator of the facility (or vehicle) involved in an emergency is
responsible for notifying the appropriate federal and state agencies. The
federal agency that owns, regulates, or is otherwise responsible for the
radiological activity is responsible for notifying FEMA headquarters which, in
turn, verifies that the state has been notified and notifies other appropriate
federal agencies. DOE is required to notify those agencies with monitoring
and assessment responsibilities under the FRMAP. In addition, the FRERP urges
a continuous flow of information between federal and state authorities, and
provides a mechanism for keeping the public informed.
A second important feature is that a radiological emergency initating
response under the FRERP is defined as any "type of radiological incident that
poses an actual or potential hazard to public health or safety or loss of
property." Therefore, action under the FRERP can be taken for releases of
NARM as well as for releases of source, byproduct, and special nuclear
material. Additionally, there is not a quantitative trigger level which must
be met in order for the FRERP to be initiated. Third, the FRERP charges that
owners or operators of an affected nuclear facility have primary
responsibility for actions within the facility's boundaries, and that state
and local governments have primary responsibility for action in areas outside
of those boundaries. In general, federal resources are used to support state
and local measures if requested.
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i Iff ii I
APPENDIX B
THE REGULATED COMMUNITY
Radionuclide emissions are most closely identified with the nuclear power
industry but are commonly released from other industrial processes as well.
The Nuclear Regulatory Commission (NRC), the Department of Defense (DOD), and
the Department of Energy (DOE) all license or oversee a variety of industrial
facilities which emit radionuclides. In addition, coal-fired utilities and
industrial boilers emit radionuclides in their ash. Mineral extraction
industries such as uranium, aluminum, zinc, copper, lead, and phosphorous
mining all release certain amounts of radionuclides during the mining and
processing operations.
The following sections briefly discuss each of the industry categories
cited above, describing the source and type of radionuclide emissions, the
number of plants and production processes, and, where appropriate, general
trends in the industries. Section B.I discusses Nuclear Regulatory Commission
licensees; Section B.2 discusses Department of Defense facilities; Section 8.3
discusses Department of Energy facilities; B.4 and B.5 discuss coal-fired
utility and industrial boilers, and primary mineral extraction industries
respectively. These source categories are summarized in Exhibit B-l. The
data in Exhibit B-l are considered preliminary at this time -- they
demonstrate the size and complexity of the regulated community, but will
likely change after additional information becomes available.
The majority of information presented in this appendix was extracted from
background information documents supporting EPA's standards for radionuclide
emissions to the ambient air (40 CFR 61). As such, most of the discussion
focuses on airborne releases from the various source categories. Information
on principal radionuclide-bearing liquid and solid wastes from the different
sources is being collected and will be incorporated into the final industry
profile supporting the radionuclide RQ rulemaking.
B.I NUCLEAR REGULATORY COMMISSION (NRC) LICENSED FACILITIES
For purposes of this discussion, NRC licensees have been divided into five
general categories: research and test reactors, accelerators, radiopharma-
ceutical manufacturing, radiation source materials, and other NRC licensees.
All of these facilities, being under NRC license control, are subject to the
NRC's release reporting requirements spelled out in Appendix A of this paper.
Power reactors are also licensed by the commission but are not included in the
following discussion because they are generally subject to the financial
protection requirements of the Price-Anderson Act, and are thus exempt from
CERCLA's reporting and response requirements (see CERCLA Section 101(22)(c)).
B. 1.1 Research and Test Reactors
A reactor is an apparatus in which a nuclear-fission chain reaction can be
initiated, sustained, and controlled, for generating heat or producing useful
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radiation. As of 1983, there were 70 reactors in operation for basic and
applied research and for teaching purposes. The research conducted includes
testing of reactor designs, components, and safety features as well as work in
the physics, biology, and chemistry fields. These reactors are licensed by
the KRC and are subject to the limits for airborne and liquid discharges to
unrestricted areas under 10 CFR Part 20, Appendix B, Table II. However, not
all research and test reactors are required to submit air emissions data on
radionuclides to the NRC.
The design types for test reactors vary, and include heavy water,
graphite, tank, pool, homogeneous solid, and uranium-zirconium hybrids.
levels range from near zero to 10 megawatts.
Power
Air emissions from test reactors are generally limited to two principal
radioactive materials, argon-41 and tritium. In addition, very small amounts
of other inert gases and some fission products may be emitted. Air emissions
vary greatly among test reactors according to design type and power level,
from zero to over 8500 curies per year (Ci/y).*
B.I. 2 Accelerators
Atomic particle accelerators are devices which impart high velocities to
charged particles by electrical or magnetic fields. The accelerated particles
travel through an evacuated enclosure and strike a metallic or gaseous target,
producing secondary radiation.
Accelerators are used in a number of applications including radiobiology,
industrial radiology, ion implantation for integrated electron circuit
fabrication, activation analysis, medical radiation therapy, and research.
The use of accelerator-produced radionuclides has increased, particularly in
the field of medicine. There has been significant growth in the number of
electron accelerators used as an alternative to cobalt-60 units in radiation
therapy.2
According to the Bureau of Radiological Health, forty-seven states
reported 1,048 operational accelerators in 1980 (not including federally owned
accelerators), of which 78.7 percent were licensed.1 States have
1 Corbit C.D., Herrington W.N., Higby D.P., Stout L.A., and Corley J.P.,
Background Information on Sources of Low-Level Radionuclides Emissions to
Air, PNL-4670, Prepared for EPA under U.S. DOE Contract by Battelle Memorial
Institute, September 1983.
2 Nuclear Regulatory Commission, Regulation of Naturally Occurring and
Accelerator-ProducedRadioactive Materials. A Task Force Review, Office of
Nuclear Material Safety and Safeguards, Washington, O.C., June 1977.
3 Bureau of Radiological Health, Report of Stateand Local Radiological
Health Programs,Fiscal Year 1980. HEW Pub. No. 18-8034, FDA, Department of
Health, Education and Welfare, June 1982, p. 20.
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ffe**. * rJ*
L*- « ijr '»" I
B-5
jurisdiction over the operation of commercial accelerators, and all states
have adopted emission standards equivalent to the maximum permissible
concentrations issued by the NRC in 10 CFR Part 20, Appendix B, Table II.*
Particle beam energies in these accelerators range from less than one MeV
(million electron volts) to several hundred GeV (billion electron volts). The
large majority of non-DOE accelerators are small units with less than 10 MeV
particle energy and produce only small volumes of radioactive wastes
containing low activity.5 Accelerator-produced radioisotopes are relatively
short-lived, with half lives usually ranging from minutes to months, and in
some cases a few years. Because these wastes can usually be discharged within
regulatory dilution requirements and are subject to rapid decay, they are
generally exempt from government regulations.
B.I.3 Radiopharmaceutical Manufacturing
Radiopharmaceuticals are radioactive chemicals used for medical purposes
and research. This discussion covers not only manufacturers and suppliers,
but users of radiopharmaceutical products as well.
In 1979, there were twenty-six industrial suppliers of radiopharmaceu-
ticals producing sixty-five generally used radionuclides. These twenty-six
firms exclude firms that purchase radiopharmaceutical products in bulk and
repackage them into smaller containers (repackagers). All suppliers are
licensed by the NRC or agreement states.
In 1977, there were over 10,000 medical facilities licensed by the NRC and
agreement states to use radiopharmaceuticals, while the number of facilities
licensed by non-agreement states is unknown. In 1946, over 30 years prior,
only thirty-eight medical facilities were licensed, showing an extremely large
growth rate in the use of radionuclides in medicine. The radionuclides
identified by EPA as having the greatest potential for release as airborne
effluents from medical facilities are technetium-99m, iodine-131, iodine-125,
and xenon-133.'
An estimated 60 to 80 percent of radiopharmaceuticals are manufactured in
nuclear reactors, with the remainder produced in accelerators. In addition,
an increasing number of nuclear pharmacies (repackagers) are operating
* U.S. Environmental Protection Agency, Radionuclides Background
Information Document for Final Rules, Volume II, Office of Radiation
Programs, EPA 520/1-84-022-2, October 1984, p. 3.2-6.
s U.S. Environmental Protection Agency, Radioactive Contamination at
Federally-Owned Facilities, prepared by Rogers and Associates Engineering
Corp., Salt Lake City, Utah, June 1982, p. 10-1.
* U.S. Environmental Protection Agency, Radionuclides Background
Information Document for Final Rules, Volume II, EPA, October 1984, p. 3.3-5.
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B-6
radioisotope generators to produce certain short-lived radionuclides.7
Emissions are possible from all of these production methods.
Medical facilities use radionuclides in all forms including solids,
liquids, and gases. Radioactive gases such as xenon, which is used in
lung-imaging procedures, can potentially emit effluents into the air. Also,
iodine-131 is easily volatilized and can thus be emitted to the air when used
in certain therapeutic procedures. Technetiura-99m is of concern in air
emissions because of the large quantities used in hospitals. The table below
shows the estimated quantities of these radionuclides received and used by
hospitals in 1977. Releases in liquid and solid form are possible during use
or during treatment at a sewage treatment plant because most radionuclides
used in hospitals are released into sanitary sewage systems. NRC regulations
in 10 CFR Section 20.303 govern radionuclide releases to sanitary sewage
systems.
Estimated Quantities of Radionuclides Received
and Used by Hospitals, 1977
Quantity (Ci)*
Radionuclide
Received
Used
Iodine-131
Xenon-133
Technetium-99m
900-1,500
2,700-3,300
26,000-34,000
300-1,350
1,600-2,000
15,000-30,000
* Curies
Source: Teknekron, Inc., Draft Final Report, A
Study of Airborne Radioactive Effluents
from the Radiopharmaceutical Industry,
March 1979.
B.I.4 Radiation Source Manufacturing
"Radiation sources," which refer to radioactive materials enclosed in
sealed containers, are found in a number of industrial and consumer products,
such as radioisotope gauges used to measure thickness, static eliminators for
industrial machinery, testing equipment, self-illuminating signs and watch
dials, and smoke detectors.
7 Teknekron, Inc., Draft Final Report, A Study of Airborne Radioactive
Effluents from the Radiopharmaceutical Industry, EPA Contract No. 68-01-5049,
March 1979.
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:;...-.FT
B-7
Manufacturers of radiation sources process bulk quantities of radioactive
materials received from radionuclide production facilities such as
accelerators or reactors. They have inventories of radioactive materials in
quantities ranging from ten curies (Ci) to 100,000 Ci. Being NRC licensees,
they are subject to the air and liquid discharge limitations of 10 CFR Section
20.106.
During manufacturing of radiation sources, the radioactive materials are
handled with remote manipulators and custom-made enclosures. Because
radiation source manufacturers handle a wide variety of radionuclides and
combinations thereof, emission characteristics vary from site to site.
B.1.5 Other NRC Licensees
Other NRC or agreement state licensees include laboratories, low-level
waste disposal sites, mineral and metal processing facilities, and fuel cycle
facilities. They are all subject to the emission requirements of 10 CFR Part
20, Appendix B, Table II and the release reporting requirements of Part 20.
Laboratories
Approximately 700 laboratories are licensed to handle radioisotopes in
unsealed form, and it is assumed that an equal number of unlicensed
laboratories handle unsealed radioisotopes, resulting in an estimated total of
1400 laboratories that are potential sources of low-level radioactive
emissions." These laboratories are established in industry, government
agencies, and academic and research institutions. They perform testing and
research and development, and vary a great deal in size. While some
facilities have only one small, multi-purpose laboratory, others have up to
300 individual laboratories in several buildings.
Small laboratories tend to specialize in a limited use of radionuclides
for a single specific testing purpose. Academic and industrial laboratories
use byproduct materials in research and testing. Medical laboratories conduct
basic chemical and applied radionuclide research related to disease and health
problems. Government laboratory facilities may use radionuclides for purposes
such as food and drug testing or water and air quality monitoring. The most
commonly used radionuclides in laboratory work are tritium, carbon-14,
xenon-133, iodine-125, and iodine-131. Testing and industrial laboratories
tend to use larger quantities of radionuclides than academic or other research
laboratories; conversely, academic and research laboratories tend to use a
wider variety of radionuclides. The annual usage of any single radionuclide
is usually less than 0.5 Ci, and rarely exceeds 10 Ci.
* Corbit C.D., Herrington W.N., Higby D.P., Stout L.A., and Corley J.P.,
Background Information on Sources of Low-Level Radionuclides Emissions to
Air, PNL-4670, Prepared for EPA under U.S. DOE Contract by Battelle Memorial
Institute, September 1983.
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L* i .. .1 I
B-8
Waste Disposal Sites
Although there are six low-level radioactive waste disposal sites licensed
by NRC, only three are operational. These sites accept low-level radioactive
wastes in a stabilized form from three major sources: power-reactor and fuel
cycle operations, laboratory research, and medical facilities. Wastes
accepted by these facilities for disposal by shallow-land burial must meet
specific site acceptance criteria. The disposal sites do not accept special
nuclear materials, transuranics (elements having a higher atomic number than
uranium), or spent reactor fuel. Radionuclide emissions to the air are
minimized by burying wastes at the disposal site in the transport containers
in which they arrive.
Mineral and Metal Processing Facilities
NRC or agreement state licensees include facilities which extract metals
from thorium- and uranium-bearing ores. Ten such facilities are licensed in
the following nine states: Alabama, California, Colorado, Florida, Illinois,
New Mexico, Oregon, Pennsylvania, and Tennessee. These facilities generally
process ores for either refractory metals and their oxides (such as zirconium,
columbium/niobium, tantalum and hafnium), or for rare earths (such as cerium,
praseodymium, neodymium, dysprosium, ytterbium). Thorium is also used in some
of these facilities to manufacture welding-rods and to cast machine parts.
The industrial processes used in mineral and metal processing facilities
vary from wet chemical and solvent extraction to high temperature sintering
and smelting. These processes are sources of radioactive releases, and are
subject to provisions of 10 CFR Parts 40 and 20.
Fuel Cycle Facilities
The NRC also licenses the use of source, byproduct, and special nuclear
material at facilities engaged in the production of nuclear fuel. These
facilities include operating uranium mills, uranium hexafluoride conversion
plants, and uranium fuel fabrication plants. There is currently no plutonium
fuel fabrication being done in the U.S. Uranium mills are described in
Section B.5.1 of this paper. The other facility types are described
separately below.
Uranium Hexafluoride (UF^) Conversion Facilities.
o
There are two operating facilities that convert yellow
cake
C03°8>
from uranium mills to UF,, one in
Oklahoma and the other in Illinois.
The UF, produced
o
from these facilities is used as the feed material in
uranium enrichment plants operated by DOE (see Section
8.3). Routine releases to ambient air and water from
these plants contain low concentrations of uranium, as
well as nonradiological contaminants (e.g., fluoride).
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^/.FT
B-9
These releases are regulated by the NRG under 10 CFR
Parts 20 and 40. For accident situations, the principle
health and environmental threat is a release of large
quantities of UF- when it is in a liquid or gaseous
state. When released to the ambient air, UF, reacts
o
with atmospheric moisture to form hydrofluoric acid
which is a corrosive acid vapor.
Uranium Fuel Fabrication Plants. Uranium fuel
fabrication plants generally receive UF, enriched in
o
the uranium-235 isotope, convert it generally into
highly refractory uranium oxides, form the uranium
oxides into pellets, and load the pellets into
metal-clad fuel elements for shipment to nuclear power
plants. In most facilities the uranium-235 is enriched
to less than five percent, but at several plants the
enrichment exceeds 93 percent. There are approximately
16 fuel fabrication plants in the U.S., although not all
facilities perform all of the fuel fabrication steps.
The only radionuclide present at these facilities, and
which may be released in important quantities, is
uranium.
B.2 DEPARTMENT OF DEFENSE (DOD) FACILITIES
The Armed Forces Radiobiology Research Institute (AFRRI). located at the
National Naval Medical Center in Bethesda, Maryland, operates both a thermal
research reactor and a linear accelerator (linac), mainly in support of
research on the medical effects of nuclear radiation and the effects of
transient radiation on electronics and other equipment.
The AFRRI reactor is licensed by the NRC for operation. Emissions from
both the reactor and linac are released through a common stack, and include
the radionuclides argon-41, nitrogen-13, and oxygen*15.
The U.S. Army Test and Evaluation Command operates two reactors which are
similar in design and are used to support studies in the effects of nuclear
radiation. Both are fueled with enriched uranium. The reactors operate at
power levels up to 10 kilowatts. Concrete structures around one of the
reactors act to reflect and thus lower the energy of neutrons streaming from
the reactor. This neutron "moderation" enables activation of stable argon-40
in air, forming the radionuclide argon-41. Very little agron-41 is produced
at the other facility because concrete structures are further removed from the
reactor.
Army Regulation 385-11, Chapter 5, and Army Technical Manual 3-261
requirements limit airborne emissions from Army facilities. While the
concentration limits are equivalent to NRC 10 CFR Part 20 limits, the
allowable averaging periods are shorter (i.e., less than one year), allowing
for less variability over the year.
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B-10
Nine naval shipyards contribute almost all the airborne radionuclide
emissions from U.S. Navy facilities. Pressurized water reactors power the
nuclear fleet at the naval shipyards. Standard operations at the shipyards
include construction, startup testing, refueling, and maintenance of the
reactors. Radioactive wastes generated by these operations are processed and
sealed, then shipped to commercial waste disposal sites. The processing and
packaging of radioactive wastes present the primary source of radioactive
emissions into the air at the shipyards. Shipboard nuclear reactors also
release small amounts of radioactive carbon-14 into the air, although most of
this is released at sea during operations.
U.S. Navy facilities are not licensed by the NRG, and are not subject to
radionuclide emission standards.
B.3 DEPARTMENT OF ENERGY (DOE) FACILITIES
The U.S. Department of Energy (DOE) is given authority by the Atomic
Energy Act of 1954 (Section 161 of Public Law 83-703) "to protect the public
health and safety" from the operation of so-called "GOCO" facilities --
Government Owned, Contractor Operated. This authority includes protection
from the emissions of radionuclides.
Major DOE facilities include national laboratories, facilities associated
with the Formerly Utilized Sites Remedial Action Program (FUSRAP), the Uranium
Mill Tailings Remedial Action Program (UMTRAP), the Grand Junction Remedial
Action Program (GJRAP), the Surplus Facilities Management Program (SFMP), and
facilities involved in specific research and development programs.9 DOE is
also responsible for operating uranium enrichment facilities, a step in the
nuclear fuel cycle. There are presently three DOE enrichment facilities,
although one has recently ceased operations. Other DOE operations involving
radionuclides include nuclear weapons research, development, and production;
medical and biological research; and industrial applications and development.
As of 1980, 78 facilities in 24 states were subject to the health and
safety requirements contained in DOE Order 5480.1. The existing standards
governing airborne releases of radionuclides center around concentration
limits in air at the site boundary. Concentration limits, established by DOE
for each radionuclide, are those which may yield a "dose equivalent to the
whole body, gonads, or bone marrow of 500 millirem (mrem) per year, or 1500
mrem per year to any other organ."10
9 Rogers and Associates Engineering Corp., Radioactive Contamination
at Federally Owned Facilities, June 1982, pp. 3-2, 3-3.
10 U.S. Environmental Protection Agency, Radionuclides Background
Information Document for Final Rules, Volume II, October 1984, p. 2.0-2.
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_*" 4 -- .J 3
B-ll
In 1982, there were thirty "active" OOE complexes, many of which have
several operating facilities. Active is defined to mean facilities currently
generating radioactive waste. Fourteen of these complexes are laboratories
operating diversified programs. Other complexes operate programs including
primarily : (1) weapons production and testing, (2) nuclear materials
production, and (3) physical research.
B.3.1 Weapons Production and Testing
Although many of the DOE facilities originated in support of the U.S.
effort to develop nuclear weapons, most have diversified into other program
areas. Thirty DOE facilities, as of January 1986, are involved in the DOE
weapons program11 which began 40 years ago during the Manhattan Project and
is codified in the Atomic Energy Act.12 There are eight nuclear weapons
facilities in the U.S. -- five in the western portion of the U.S., three in
the eastern portion. Most of the DOE laboratories cluster around these
facilities, while production facilities are scattered all across the nation.
Construction of new plants is not expected in the near future (e.g., no new
plutonium plants have been built in the past two years), and money, instead,
is being targeted for maintenance of existing production equipment.11
Much of the waste from DOE bomb plants and laboratories is mixed with
industrial chemicals. The department uses surface cribs (the equivalent of
septic tanks and leach fields) to dispose of this waste. In theory, the
radioactive materials in the waste remain in place for thousands of years by
bonding with the soil, thus allowing time for radioactive decay. In practice,
though, although the radionuc1ides bond with the soil, minimizing migration,
the other chemical constituents in the waste do migrate, potentially causing
environmental releases.1*
11
Engineering News Record, cover story, January 30, 1986, p. 28.
12 Each one of these 30 facilities is not necessarily "active" under the
above definition. The Rogers and Associates Engineering Corporation report
lists eight "active" weapons production and testing laboratories concerned
with nuclear weapons from the design and testing phases to the full production
phase. Three of these eight facilities, however, are part of larger DOE
complexes operating diversified programs.
13 Engineering News-Record. "Nuke Weapons Cleanup Marching," January
30, 1986, p. 29.
14 Ibid., p. 30.
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B-12
B.3.2 Nuclear Materials Production
Four of the DOE active facilities, as of 1982, were nuclear materials
production facilities devoted to manufacturing nuclear fuels and metal
compounds.15 These facilities include:
Two gaseous diffusion (i.e., uranium enrichment)
plants -- Construction of a new facility began in 1979
next to an existing site;
One plant that primarily purifies uranium metal
compounds for use at other DOE sites; and
One plant that primarily extrudes ingots of depleted
uranium into tubes and fabricates ingots of slightly
enriched uranium into bullets.
B.3.3 Physical Research
In 1982, four of the DOE active facilities were physical research
laboratories devoted to basic research at universities.1' At three of the
laboratories, accelerators are the primary ionizing radiation instrument,
Co-60 sources are the primary ionizing radiation instruments at the fourth.
B.4 COAL-FIRED UTILITY AND INDUSTRIAL BOILERS
From 1974 to 1977, about 18 percent of the energy needs in the United
States were met by burning coal. Large coal-fired boilers are used to
generate electricity for public and industrial use and to provide process
steam, process hot water, and space heat. Boilers used in the utility
industry are designated as utility boilers, and those used to generate process
steam, process hot water, space heat, or electricity for in-house use are
designated as industrial boilers.
More than 600 million tons of coal are burned each year in utility and
industrial boilers. Coal contains mineral matter including trace quantities
of naturally occurring radionuclides. Uranium-238 and thorium-232 and their
decay products are the radionuclides of concern with respect to air emissions
from the burning of coal for two reasons: (1) the large quantity of these
radionuclides in coal, and (2) the high levels of radioactivity in the decay
products in coal.l7
15 Rogers and Associates Engineering Corp., Radioactive Contamination at
Federally Owned Facilities, June 1982, pp. 3-125 to 3-130.
18 Ibid., p. 3-144.
17 U.S. Environmental Protection Agency, Radionuclides Background
Information Document for Final Rules. Volume II, October 1984, p. 4.0-1.
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B-13
The emission of radionuclides to the air from coal-fired utility and
industrial boilers is small. In promulgating radionuclide emission standards
under the National Emission Standards for Hazardous Air Pollutants (NESHAPs),
EPA concluded that good reasons exist for not regulating radionuclide
emissions from these boilers (50 FR 5190).
B.4.1 Utility Boilers
In 1983, coal-fired steam electric power units accounted for 63 percent of
total capacity and 55 percent of total energy generation by U.S. electric
utility generating units.11 In 1979, there were 1,224 coal-fired units with
a total generating capacity of 225 gigawatts (GW).1* In early 1985, there
were 1,281 coal-fired units on-line with a capacity of 281 GW.2D
Coal consumption is expected to exhibit moderate growth from about 920
million tons in 1985 to about 1 billion tons in 1990, an annual growth rate of
less than 1.7 percent per year. The overall growth in electricity generation
between 1985 and 1990 will be moderate (about a 2 to 3 percent annual average
in most regions). However, growth in coal consumption will be sluggish. Most
of the growth in electricity generation is expected to be nuclear.21
Coal combustion in utility power plants produces an ash that is either
returned within the boiler (bottom ash) or carried out of the boiler with
combustion gases (fly ash). A portion of the fly ash is removed from the flue
gas by a particulate control system before it is released to the atmosphere.
The remaining fly ash, which contains radionuclides, is released. Fly ash,
bottom ash, and the sludges from the particulate control system are removed
from the boiler and accumulate in solid waste piles until disposal.
The emission of radionuclides in the fly ash generated during combustion
depends on the mineral content of the coal used and concentrations of uranium,
thorium, and their decay products. Other factors influencing radionuclide
emissions include furnace design, capacity, heat rate, ash partitioning,
enrichment factors,.and emission control efficiency.
lg U.S. Department of Commerce, Statistical Abstract of the U.S.
(1985), 105th Edition. Government Printing Office, Washington, D.C., p. 564.
19 U.S. Environmental Protection Agency, Radionuclides Background
Information Document for Final Fules. Volume II, October 1984, p. 4.1-1.
20 ICF Energy Service, Summer/Fall 1985 Coal and Electric Utilities
Market Assessment, p. 1-2 (1985).
21 Ibid., p. 1-9.
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rr
B-14
B.4.2 industrial Boilers
Coal-fired industrial boilers are used mainly to produce process steam and
hot water, generate electricity (for the producer's own use), and provide
space heat. The major users of industrial boilers are the steel, aluminum,
chemical, and paper industries. There are approximately 51,187 coal-fired
industrial boilers operating in the United States.22
Industrial boilers also produce both bottom ash and fly ash. The
fractional distribution of ash between the bottom ash and fly ash directly
affects the particulate emissions rate and is a function of the boiler firing
method, the amount of coal burned, and whether the boiler is wet or dry bottom.
(Dry bottom furnaces produce more fly ash.) Like utility boilers, the
emission of radionuclides in the fly ash depends on the mineral content of the
coal used and the concentrations of uranium, thorium, and their decay products.
B.5 MINERAL EXTRACTION INDUSTRY
Almost all mineral extraction industries that involve the removal and
processing of ores to recover metal, release some radionuclides into the air.
The Office of Radiation Programs at EPA has identified the following mineral
extraction industries as having potential for significant releases of
radionuclides: the uranium mining industry, the aluminum industry, the copper
industry, the zinc industry, the lead industry, and the phosphate industry.
These industries were identified because of the large quantity of ore mined
domestically and because the mining processes used create a likelihood for
radionuclide emissions.23 Only underground uranium mining and elemental
phosphorus plants were found to warrant radionuclide emission standards under
the Clean Air Act (50 FR 5190). Each mineral extraction industry is
discussed below.
B.5.1 Uranium Mining and Milling
Uranium mining and milling operations remain one of the largest sources of
radionuclide releases, despite a downturn in the industry since 1980. This
section reviews the activity of these industries separately, though their
ultimate inextricability should be considered.
Uranium Mining
There are several different types of uranium mines and extraction
processes. These include: open pit, underground, and in-situ (solution)
mining operations. In 1982, there were 24 open pit uranium mines, 139
22 U.S. Environmental Protection Agency, The Radiological Impact of
Coal-Fired Industrial Boilers (Draft), Office of Radiation Programs,
Washington, D.C., October 1981.
23 U.S. Environmental Protection Agency, Radionuclide Background
Information Document'for Final Rules. Volume II, October 1984, p. 7.1-1,
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B-15
underground uranium mines, and IB in-situ mines in operation, producing about
86 percent of the total uranium oxide domestic production in that year. Total
uranium oxide production was 13,400 tons.2* Exhibit B-2 gives total uranium
production from 1966 to 1984, illustrating the gradual, but fairly continuous,
increase in domestic production of uranium until 1980 and then a precipitous
decline.
Domestic uranium is almost exclusively mined in the western portion of the
United States, mostly in New Mexico, Wyoming, and Texas. As of 1984, uranium
production in these states collectively accounted for approximately 65 percent
of the national total. Several other states (including Arizona, Colorado,
Florida, South Dakota, Utah, and Washington) together accounted for the
remaining 35 percent of the total.25
The majority of the uranium industry is owned by large, publicly held
corporations. During the early and mid-1970's, the industry experienced rapid
growth, spurred by expectations of increasing demand. This demand, however,
did not materialize and, as a result, the industry is presently faced with an
excess of capacity and supply, and the potential for increased competition
from imports. The decline in the demand for domestic uranium in the past five
years can be attributed to three factors:
The growth in electricity generated by nuclear plants
and the expansion of nuclear power capacity has been
much slower than forecasted in the mid-1970's;
Imports have begun to play a major role in the U.S.
uranium market; and
Large inventories are being held by both producers and
utilities.
The principle radionuclide of concern in uranium mining and processing is
radon-222. As part of the underground mining process, ventilation shafts are
installed along the ore body. Typical ventilation flow rates in these shafts
are about 200,000 cubic feet per minute. The amount of radon-222 gas emitted
through the vents varies, depending upon many factors including: ventilation
rate, ore grade, production rate, age of mine, size of active working areas,
mining practices, and several other variables. Both radon-222 and other decay
products of uranium are emitted as a result of surface operations at the
underground mine as well. Underground uranium mining activities produce more
air emissions (i.e., radon-222) than surface mining or in-situ mining.
24 U.S. Department of Energy, Statistical Data of the Uranium Industry,
GJO-100(83), Grand Junction, Colorado, January 1983, p. 9.
25
Ibid., p. 9.
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. I
B-16
Exhibit B-2
Historical Production by Uranium Mills and Other Sources
Grade of Ore
Year
Short Tons U.O.
J O
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
10,589
11,253
12,368
11,609
12,905
12,273
12,900
13,235
11,528
11,600
12,747
14,939
18,486
18,736
21,852
19,237
13,434
10,579
7,441
0.229
0.203
0.195
0.208
0.202
0.205
0.213
0.208
0.176
0.170
0.157
0.154
0.131
0.105
0.119
0.114
0.121
0.126
Not Available
Sources: U.S. Department of Energy, United States Uranium
Mining and Milling Industry: A Comprehensive Review,
DOE/5-0018, May 1984.
U.S. Department of Energy, Statistical Data of the Uranium
Industry. GJO-100 (83), Grand Junction, Colorado, January
1983.
U.S. Environmental Protection Agency, Proposed Standard for
Radon-222 Emissions from Licensed Uranium Mill Tailings;
Draft Economic Analysis, Office of Radiation Programs, EPA
520/1-86-002, January 1986.
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L. 4 ..
B-17
Inhalation of uranium and thorium dust from an ore spill is also a
potential concern associated with releases from mines. However, U.S. uranium
ores (generally from sands and sandstones) tend to contain from six to
fourteen percent moisture and only about one percent respirable dust by
weight.2* EPA has estimated that the health risk posed by particulate
uranium and thorium resulting from erosion of ore piles and loading/unloading
operations is smaller (by a factor of 100) than the risk from radon.27
In surface mining operations, mining and reclamation processes take place
simultaneously. The overburden and topsoil removed from the ore zone is
backfilled into the mined-out pits. Radioactive emissions from the process
consist of radon-222 and fugitive dust containing uranium and its decay
products.
The amount of radon-222 released from in-situ mining operations is
relatively small compared to the conventional underground and surface mining
methods. The in-situ method involves the injection of a leaching solution
into wells in order to dissolve the uranium while it is still underground.
Production wells bring the uranium to the surface while it is still in
solution. Small amounts of radon are released from the waste impoundments
that store the contaminated liquids, but radon release from this mining method
is estimated to be less than twenty percent of the release from a conventional
(open pit or underground) uranium mine.1*
Uranium Milling
Uranium ore is delivered to mills where it is crushed and ground, and
uranium oxide (lLOg) is chemically extracted. The mill product, also
called uranium concentrate or "yellow cake," is then sent to conversion
facilities, where it is chemically converted to uranium hexafluoride (UF,).
o
Uranium milling activity has declined even more rapidly than mining,
because it is dependent on "conventional" mining; i.e., open-pit and
underground mining. Most of the decline
in U_0Q production has come from
J o
2S Nuclear Regulatory Commission, Generic Environmental Impact Study on
Uranium Milling, Washington, D.C., 1979.
27 U.S. Environmental Protection Agency, Draft Background Information
Document: Proposed Standards of Radionuclides, 1983, EPA 520/1-83-001.
i§ Brown S.H. and Smith R.C., A Model for Determining the Overall Radon
Release Rate and Annual Source Term for a Commercial In-Situ Leach Uranium
Facility, Proceedings of International Conference on Radiation Hazards in
Mining: Control Measurement, and Medical Aspects, Colorado School of Mines,
Golden, Colorado, October 1981.
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B-18
conventional sources, whereas in-situ production has remained relatively
constant. As of November 1985, there were only three active uranium mills in
the U.S. (one of which is expected to go on standby status). An additional 17
mills are already on standby status. Total U,0Q production from mills was
J o
about 7,400 tons in 1984, down from a high of 21,800 tons in 1980. Milling
information for individual companies are collected by DOE but are not
available to the public.2'
B.5.2 Aluminum Industry
Several materials are used in the production of aluminum. Bauxite is the
principle aluminum ore found in nature. The ore is processed at the mine to
produce alumina, the basic feed in the aluminum reduction process. Bauxite
contains elevated levels of both uranium-238 and thorium-232. Twelve domestic
firms produce primary aluminum. Almost all of the bauxite ore used in
aluminum production is imported. Only five of the twelve firms that own
primary aluminum plants also own domestic plants that produce alumina. These
five firms own 73 percent of the current U.S. primary aluminum capacity.
Currently, there are 32 operating primary aluminum smelters in the United
States. With one exception, all of the plants are located in rural areas.
The particulate emissions from the aluminum production process reflect the
composition of the feed materials and include alumina, carbon, cryolite,
aluminum fluoride, and trace elements. Generation of particulate emissions
varies with the type of production process used and the radionuclide
concentrations in the alumina processed. The radionuclide released in the
largest quantity is radon-222.
No federal or state regulations currently exist that limit radionuclide
air emissions from alumina plants or aluminum reduction plants. EPA decided
that these emissions did not warrant regulation under NESHAP. Particulate
emissions from these sources are limited to the quantities established by the
states in their State Implementation Plans (SIPs) for meeting Ambient Air
Quality Standards.
Several states have established specific SIP limits for aluminum reduction
plants, ranging from 15 to 20 Ibs. of total suspended particulate per ton of
aluminum produced. In states where no specific limits have been established
for aluminum, emissions from these sources are regulated according to the
limits established in the SIPs for general processing sources.
29 U.S. Environmental Protection Agency, Proposed Standard for Radon-222
Emissions from Licensed Uranium Mill Tailings; Draft Economic Analysis,
Office of Radiation Programs, EPA 520/1-86-002, January 1986.
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B-19
B.5.3 Copper Industry
Most firms in the copper industry perform all production processes from
mining through refining. Copper mills and smelters are located near copper
mines. There are fifteen operating primary smelters in the United States.
All smelters are located in rural areas with low population densities. Ninety
percent of U.S. copper smelter capacity is located in the arid and semi-arid
climates of Arizona, Montana, Nevada, New Mexico, Texas, and Utah. The other
10 percent is located in areas of moderate to high precipitation of
Washington, Michigan, and Tennessee, reducing dust particle emissions. The
sites tend to be large and generally contain associated mining and milling
operations. In 1978, 1.5 million metric tons of primary copper was
produced.3e
Radon-222 is the only significant radionuclide that is emitted from
underground copper mines. At open-pit copper mines and at the copper mills,
radioactive particulates, including uranium-238 and thorium-232 are emitted
primarily during truck loading, dumping, and crushing. Particulate emissions
from copper smelters contain small quantities of radionuclides. EPA has
decided that radionuclide releases from the copper industry do not warrant
regultions under NESHAP (50 FR 5190).
No Federal or state regulations currently exist that limit radionuclide
emissions from copper processing operations. Particulate emissions from these
sources are regulated by New Source Performance Standards (NSPS) or by limits
established by the states in their SIPs for Ambient Air Quality Standards.
Several of the states where copper smelters are located have adopted specific
emission limits for different smelting operations, while other states regulate
these sources under the general processing category limits established in
their SIPs.
B.5.4 Zinc Industry
Zinc is usually found in nature as a sulfide ore called sphalerite. The
ores are processed at the mine to form concentrates typically containing 62
percent zinc and 32 percent sulfur. In the past 10 years, U.S. demand for
zinc metal has grown slowly, but U.S. smelting capacity has declined by more
than 50 percent. Plants closed because they were obsolete, could not meet
environmental standards, or could not obtain sufficient concentrate feed.
Consequently, the metal has replaced concentrate as the major form of import.
This situation is expected to continue.
There are five operating primary zinc production facilities in the United
States. Domestic zinc smelters use electrolytic reduction to reduce the
quantity of sulfur and particulate emissions. The amount of radionuclides
emitted from a zinc smelter is a function of the concentrations of
10 Schroeder H.J., Mineral Commodity Profiles -- Copper, U.S.
Department of the Interior, Bureau of Mines, Washington, D.C., 1979.
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B-20
radionuclides in the materials processed. Radon-222 is the principal
radionuclide emitted to the air from zinc mining and milling, while
participate uranium-238 and thorium-232 and their decay products are also
released in smaller quantities. EPA has decided that radionuclide releases
from the zinc industry do not warrant regulations under NESHAP (50 FR 5190).
Particulate emissions from zinc smelting are regulated by NSPS, or by the
limits established in SIPs for meeting Ambient Air Quality Standards.
B.5.5 Lead Industry
Galena is the principle lead-bearing ore found in nature. It contains
small amounts of copper, iron, zinc, and other trace elements (including
radionuclides). Lead smelting involves three processes: sintering,
furnacing, and dressing. Sintering converts the ore from a sulfide to an
oxide or sulfate form and prepares the feed materials for furnacing.
Furnacing reduces the oxide feed to lead metal. Dressing reduces the copper
content of the lead bullion from the furnace. After drossing, additional
refining steps, which are dictated by the specific impurities present and the
intended end-use of the product, are performed to produce the purified lead
metal.
There are five primary lead smelters in the United States. Three
facilities have integrated smelter/refining complexes and two facilities ship
their drossed lead bullion away for final processing. Three of the smelters
are located in Missouri and process only ores from the Missouri lead belt.
The remaining smelters are located in Texas and Montana. The two western
smelters are custom smelters that are designed to handle larger variations in
ore composition than the Missouri smelters. Both domestic and foreign ores
are smelted at the western plants. In 1979, total production from primary
lead smelters was 594,000 tons.31
The radionuclide emissions from a lead smelter depend on the
concentrations in the materials processed. Since enrichment takes place when
nuclides volatilize during the high-temperature phase of production, the
concentration of some radionuclides will be higher in the particulates than in
the original ore.
No federal or state regulations currently exist that limit radionuclide
air emissions from lead smelting. Particulate emissions from lead smelters
are regulated by NSPS, or by SIPs.
B.5.6 Phosphate Industry
The two major components of the phosphate industry which release
radionuclides into the environment are phosphate mining and elemental
phosphorous production.
11 U.S. Department of Commerce, U.S. Industrial Outlook for 200
Industries with Projections for 1984, Washington, D.C., 1980.
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u..." ;v >
B-21
Phosphate Rock Processing Plants
Mining of phosphate rock is the fifth largest mining industry in the U.S.
in terms of quantity of material mined. Total 1978 production was
approximately 57.9 million metric tons. Prior to 1983, twenty firms were
operational, with plants in thirty-one locations. The ten largest producers
control about 84 percent of the capacity, with the two largest firms
controlling over 34 percent.32
Phosphate rock contains from 20 to 200 parts per million (ppm) of uranium,
which is 10 to 100 times higher than the 2 ppm concentration level typically
found in soils and rocks, thereby making phosphate rock a potential source of
high radionuclide emissions. The principle radionuclides found in phosphate
are uranium and its decay products. Phosphate rock dust is a particular area
of concern because the dust particles have approximately the same level of
radioactivity as the phosphate rock itself.
Particulate emissions from phosphate rock during extraction is unlikely
because over 98 percent of the phosphate rock produced is mined from ground
having sufficient moisture content to prevent dust particle emissions. During
processing, phosphate rock is beneficiated, then dried and ground to a uniform
particle size. Beneficiation does not pose an air emission problem because it
is performed in a water slurry. During drying and grinding, however,
radionuclides can be emitted into the air because of the large amounts of rock
dust created. Sometimes the phosphate rock must be calcined before processing
(heated to temperatures of 1400° to 1600°F to remove organics, in this case
hydrocarbons), which may result in radionuclide emissions because the high
temperatures may volatilize lead-210 and polonium-210 uranium decay
products). Conveying and storage of the ground rock can also result in
fugitive emissions of particulates.
Radionuclide emissions from phosphate rock drying, calcining, and grinding
procedures are not specifically limited under current federal or state
regulations. However, New Source Performance Standards and State
Implementation Plans do limit particulate emissions from these operations.
Elemental Phosphorus Plants
Another type of phosphorus plant produces elemental phosphorus, which is
used primarily in the production of high grade phosphoric acid,
phosphate-based detergents, and organic chemicals. Almost half of the
elemental phosphorus produced domestically is used in the production of
detergents. Metal treatment, foods and beverages, and chemicals are the other
major end uses for elemental phosphorus. Approximately ten percent of the
total U.S. marketable phosphate rock mined is used for elemental phosphorus
32 U.S. Environmental Protection Agency, Phosphate Rock Plants,
Background Information for Proposed Standards, EPA 450/3-79-017, Office of
Air Quality Planning and Standards, 1979, p. 7-5.
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B-22
production. Four major corporations operate six plants in the U.S. The total
amount of elemental phosphorus produced in 1983 was approximately 366,000
tons."
Production of elemental phosphorus includes crushing and screening, and
then calcining. After cooling and storage, phosphorus nodules are fed to
electrical furnaces in which calcium phosphate is reduced to elemental
phosphate and then processed. Emissions can potentially occur during
calcining, cooling, and transfer. Also, emissions are possible during the
reduction process as off-gases are vented from the furnace. While emissions
during these processes are generally controlled, fugitive emissions and radon
gas emissions are not controlled. EPA has established radionuclide emission
standards under the NESHAPs for these plants.
13 U.S. Environmental Protection Agency, Radionuclides Background
Information Document for Final Rules. Volume II, October 1984, p. 6.3-1.
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