ENVIRONMENTAL RADIATION
      PROTECTION FOR
NUCLEAR POWER OPERATIONS
         PROPOSED STANDARDS
            i40 CFR 190i
  SUPPLEMENTARY INFORMATION
          JANUARY %, 1976

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ENVIRONMENTAL   RADIATION   PROTECTION
  FOR   NUCLEAR   POWER   OPERATIONS
         PROPOSED  STANDARDS
           [10  CFR  190]
     SUPPLEMENTARY   INFORMATION
           JANUARY 5, 1976

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                             PREFACE




     As a result of the review of comments received on these proposed


environmental radiation protection standards for normal operations of


activities in the uranium fuel cycle, the Agency has identified a number


of areas in which additional information would be desirable in order to


provide a reasonable basis for discussion and comment on this proposed


rulemaking at the public hearing scheduled for February 17, 1976.  This


mat'erial has been developed to supplement that contained in the notice


proposing these standards (40 FR 23420), as well as the draft environ-


mental statement and technical reports made available at that time.  It


does not constitute a complete response to comments, since the public


record is still open.  Modifications of the original proposal made as

                                                                     <
the result of comments received and a complete response to comments will
                                                             »
be contained in the final environmental statment and notice of final


rulemaking, which will reflect all the information received, including


that developed at public hearings.


     Three categories of additional information are contained in this


Supplement.  The first includes an extended discussion of the Agency's


intent regarding implementation of these proposed standards, and further


elucidation of the basis used by the Agency for assessing the potential


health impact of exposure to ionizing radiation.  The second consists of


technical discussions of several areas not covered or addressed only


briefly by the original material.  This includes consideration of


multiple reactors on a single site, the nuclear energy center concept,


transuranic effluents resulting from recycled uranium, and nitrogen-16


skyshine doses and control at BWR's.  Finally, in two areas, fuel

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reprocessing and milling, considerable additional technical material has




become available concerning control methods since the original docu-




mentation was prepared.  Although the proposed standards 'reflected this •




information, the technical documents accompanying the proposal did not.




Surveys based on this new information complete this collection of




additional materials.

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                                CONTENTS
A.   Implementation of and Verification of Compliance with
     the Proposed Standards

B.   Dose-Effect Assumptions Used as the Basis of the Proposed
     Standards

C.   Potential Limitations on Multiple Reactor Sites Imposed
     by the Proposed Standards

D.   An Analysis of Control Options for Nitrogen-16 Off-site
     Skyshine Doses at Boiling Water Reactors

E.   The Proposed Standards and the Nuclear Energy Center
     Concept

F.   Control of Krypton and Iodine Discharges from Nuclear
     Fuel Reprocessing Facilities

G.   Transuranium Effluents from Re-enriching or Refabricating
     Reprocessed Uranium

H.   Environmental Analysis of the Uranium Fuel Cycle, Part I
     (Fuel Supply):  Uranium Milling - Revised

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           SUPPLEMENT   A









IMPLEMENTATION OF AND VERIFICATION OF




COMPLIANCE WITH THE PROPOSED STANDARDS

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        IMPLEMENTATION OF AND VERIFICATION OF COMPLIANCE WITH THE
                           PROPOSED STANDARDS
Introduction

     As pointed out in the notice proposing these standards, the primary

responsibility for implementing and assuring compliance with EPA

standards for environmental radiation from nuclear power rests with the

Nuclear Regulatory Commission (NRC) and, in certain cases, "Agreement

States" operating within NRC regulations.  Thus, although EPA must

consider the practicality of implementing its standards, it would clearly

be inappropriate for the Agency to specify the detailed procedures to be

followed.  On the other hand, it is important that the Agency clearly ,

spell out what it would consider to be an appropriate implementation, as

well as ones which are overly restrictive or inadequate, so as to provide

guidance to the NRC for its development of the detailed regulations (and

modifications of existing regulations) required.  The following comments

are intended in the sense of such guidance, as to the the Agency's

intent, therefore, and should not be interpreted as literal dictates of

the regulations required to implement these standards.  That

responsibility rests with the NRC, and will have to be worked out by the

NRC through detailed interaction with the affected components of

industry, with timely consultation by NRC with EPA as to the

appropriateness of any proposed implementing regulations, particularly in

the event that difficulties develop.

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     A similar situation obtains with respect to verification of




compliance.  Enforcement authorities reside in NRC, not EPA.  EPA expects




that the NRC will adequately assure compliance, and EPA's own




"compliance" activities will consists principally of the review of the




performance, as reported by NRC, of fuel cycle facilities and of any




variances permitted by NRC,  As required, EPA will in the future provide




NRC with guidance on the adequacy of its compliance and variance posture




with respect to these environmental standards.








Operational vs. Pre-Operational Application of_ the Standards




     An important consideration relative to these standards is the NRC's




continuing development of design and operating guidance, codified in




10CFR50, which implements the Federal Radiation Guidance that exposures




of the public be maintained as low "as practicable" (25 FR 4402).  The




Commission has already issued such guidance for single light-water-cooled




power reactors and has underway similar guidance for fuel reprocessing,




milling, and fuel fabrication facilities.  The Agency has determined that




the guidance issued thus far for light-water-cooled reactors provides




adequate assurance of compliance (unless the NRC finds that extreme




extenuating circumstances exist for a specific site) for sites containing




up to at least five such power reactors.  Additional guidance may be




required in the future, as noted by the Commission in its opinion filed




with 10 CFR 50, Appendix I, for sites containing larger numbers of




facilities.

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     These standards will supercede, for the nuclear power Industry, the




Federal Radiation Guides codified in 10 CFR 20 as limiting concentrations




in air and water at unrestricted locations.  Just as the development of




the guidance expressed by Appendix I to 10 CFR 50 took place within the




limitations specified by those standards, the development of future 10




CFR 50 guidance will now take place within the limits specified by these




standards.  However, it is not anticipated that the disparity between




standards and guidance will, in general (but not always), be nearly so




great as formerly.  For example, at fuel reprocessing sites, a large




portion of the thyroid individual dose standard could be taken up by new




10 CFR 50 guidance (whereas zero dose may be postulated through liquid




pathways due to the absence of any liquid discharges).   It is thus not




the intent of the Agency that the standards for dose be "apportioned" to




various operations of the fuel cycle.  They apply equally and in full to




doses from any operation or combination of operations in the cycle, and




it is not anticipated that doses from multiple sites will be either




common or significant.  In the few instances where overlap of




significance could occur  this should be dealt with on a site-specific




basis — not generically through apportionment.




     It is particularly important to recognize that the standards apply




only to doses received by individuals and quantities of radioactive




materials released to the environment from operating facilities.  This




situation is in contrast to design guidance set forth,  for example, by




Appendix I to 10 CFR 50 for light-water-cooled power reactors, which




applies to pre-operational considerations, such as licensing for

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construction of nuclear facilities.  While such guidance is useful for



providing the basis for concluding that such facilities can be expected




to conform to standards which apply to actual operations, it is not a




substitute for such standards.




     Consideration of the adequacy of control measures at facilities




during pre-operational stages with respect to these standards should be




limited to a finding, either for specific sites, or on a generic basis,




as appropriate, that the facility has provided or has available to it




adequate means to provide reasonable assurance that these standards can




be satisfied during actual operations.  Such means may include the




provision of cleanup controls on discharge streams, the ability to




modify, if necessary, its mode of operation to mitigate environmental,




discharges, or methods which interrupt exposure pathways in the




environment.  The important point is that the standards specify maximum




doses to real individuals and maximum quantities of certain materials




actually delivered or discharged to the environment, not the specific




design parameters of individual facilities.  Thus, for example, it is the




Agency's view that conformance to Appendix I by a planned reactor on a




site containing up to five such facilities (unless extremely unusual




combinations of liquid and air pathways of exposure are actually present




and are expected to be simultaneously intercepted by real individuals)




should constitute jde_ facto demonstration to the NRC that a reasonable




expectation exists that these standards can be satisfied in actual




operation.  The Agency will, in the course of its continuing review of




Environmental Statements, identify any situations for which it believes

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that such an expectation has not been adequately justified.  A more




detailed exposition of some areas meriting in-depth discussion of the




Agency's view of an adequate demonstration of reasonable expectation of




compliance, such as for adjacent sites, minor releases of specifically




limited radionuclides from fuel cycle facilities, doses from windblown




material originating from mill sites, and transportation-related doses,




is provided below.








Models for Operational Application of_ thes Standards








a)  Limits on doses to individuals.




     Conformance to the standards should be measured using the most




reasonable and, as required, realistic means available.  Thus, in the




case of dose to the thyroid, measurement of the radioiodine content of




milk at the nearest farm, coupled with a determination of the milk




consumption habits of the residents, would constitute a reasonable basis




for a final determination of noncompliance.  Conversely, calculations




based on observed releases and meteorology should generally provide the




basis for a routine finding of compliance.  Sites failing this test would




merit progressively more detailed study, leading finally to the above-




described (or a comparable) determination of noncompliance (or




compliance).




     In the case of potential doses to the whole-body and other organs a




similar sequence of compliance verification methods is available.  The




Agency believes that it may be presumed that existing models for

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calculation of exposure fields due to gaseous and liquid releases, using

measured data on quantities released, local meteorology, and stream-flow

characteristics, are adequately conservative to serve as the basis for

verification of compliance with these standards.  If reason exists to

believe, based on use of such source term measurements and models, that

noncompliance may exist at a particular site, than more detailed field

measurements may be employed (or, of course, the facility could reduce

its emissions to achieve model-based compliance).

     In a very few special situations when two or more sites are in close

proximity, it may be necessary for the regulatory agency to make

allowance for contributions from several sites in order to assure

compliance with the standards at locations intermediate between such
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sites.  For sites as close as a few miles from each other overlapping

contributions of as much as 10 to 20% may be possible.  The NRC should

make the necessary adjustments in the individual technical specifications

of facilities at such sites to provide reasonable assurance of

compliance.  However, in the vast majority of situations the sum of all

reasonably possible contributions from all sources other than the

immediately adjacent site will be small compared to these standards, and

should be ignored in assessing compliance.  It would not be reasonable to

attempt to incorporate into compliance assessment doses which are small

fractions of the uncertainties associated with determination of doses

from the primary source of exposure.

     A number of potential difficulties exist regarding implementation of

the standards at mill sites.  Gamma surveys in the vicinity of some

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existing mill tailings piles show values ranging up to several hundred


mrem/yr in situations where it is logical to assume that these elevated


gamma radiation levels are the result of windblown tailings.  Although


the measurement of 25 mrem/yr increments in such dose rates is possible8


rigorous measurement techniques would be required to identify locations


where new depositions of windblown particulates elevate pre-existing


local levels by 25 mrem/yr.  Furthermore, because of the projected 20-

year operational lifetime of a typical mill and the assumed additive


impact of new depositions, 1/20 of 25 mrem/yr, or approximately one


mrem/yr, would have to be measured if the standard were to be implemented


by a regulation based on verification on an annual, incremental baais.


This would be unreasonable, since one mrem/yr is small compared to
                                                                      4
uncertainties in natural gamma-ray background levels.


     A recent engineering survey report developed for the Nuclear


Regulatory Commission (ORNL-TM-4903, Volume 1) provides an estimation of


the relative ratio of the respirable particles (<10y) to larger particles


(10-80y) blown off the tailings beach of a well-managed tailings


impoundment system.  This ratio averages about one and varies from 0.4 to

1.4 depending on specifics of the milling process and other'variables0

It can be estimated, therefore, that one millicurie/yr of insoluble 0-10y

particles removed from a typical pile by wind could deliver a dose


equivalent of approximately one mrem/yr to the lungs of a person living


one kilometer downwind of the pile.  At the same time, one millicurie/yr

of 10-80y particles might be deposited in a ring one-half to one

kilometer from a pile, yielding a surface contamination level of about 3

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nCi/m2.  This would result in a ganma-ray exposure level of about 10




yrem/yr.  After 20 years of operations, each contributing to surface




contamination at such a rate, this exposure might increase to as much as



approximately 0.2 mrem/yr.




     Accordingly, the critical exposure pathway for windblown tailings is




most likely to be to the lungs through the direct inhalation of




radioactive tailings; and if this source of exposure is controlled, direct




whole-body gamma exposure from windblown tailings will also be controlled



to a considerably greater degree.



     It does not appear at this time to be practical to measure the




annual release of radionuclides from operational tailings piles to the



air pathway.  However, it is practical and reasonable to reduce these




releases to very small values (<1 mCi/yr) by application of control




measures that will insure that maximum doses to individuals in the



vicinity of tailings piles are well within the standards.  These measures



include back-filling of exposed tailings, keeping tailings under waters,



and spraying any tailings "beaches" that develop with chemical binders to



prevent blowing.  In practical terms9 the standards should be implemented



with regard to operational tailings piles by requiring proper and



reasonable dust control measures and by permanent stabilization following



termination of active milling operations,




     It should be noted that the standards apply only to annual doses



delivered as the result of discharges of radioactive materials beginning



two years following the promulgation date.  They do not apply to doses



resulting from discharges before this date.  Decontamination of areas

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contaminated by'windblown tailings from and management of tailings piles




on previously abandoned mill sites are not covered by end are therefore



not required by this standard.




     At a fuel reprocessing or a multi-unit reactor site the number of



shipments of radioactive materials per year in and out of the site could




reach several thousand.  However, even for this large of number of




shipments, doses to nearby individuals under present Department of



Transportation regulations would not reach one mrem/yrj if they are



located, on the average, more than a few tens of meters from the shipping



route, and if the vehicles involved remain in motion while in the



vicinity of the site.  Implementation of the standard does not require,



therefore, modification of existing packaging and shielding requirements.




It probably will be necessary, however, to reguire guaranteed 'non-stop



shipments (a service which is presently obtainable from the



transportation industry) to avoid buildup of doses to bystanders at



habitual stopping places, or to provide restricted access areas for



layovers.  It should be noted that the standards do not apply to



transportation personnel while they are engaged in handling shipments;



such exposure is considered to fall in the category of occupational



exposure.








b)   Limits on quantities of specific radionuclides released.



     Implementation of the nuclide-specific limits on releases of long-



lived materials will require a determination by the NRC of the operating



decontamination factors that must be achieved at locations that are the

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principle potential sources of environmental releases of these materials.



In order to make such a determination it will be necessary to



characterize before 1983, except in the case of transuranlcs, the maximum



average values of environmental releases of these materials from minor



classes of sources to be permitted essentially unrestricted release



(e.g., krypton-85, iodine-129, and transuranic releases from power



reactors or fuel fabrication facilities).  Following this, compliance



should consist of verification that the appropriate decontamination



factors are being realized through frequent inplant measurements at the



principle potential sources reported on a routine basis.



     Monitoring of the DF's achieved by inplant control systems for the



three types of radionuclides specifically limited by the standards
                                                                      t


appears to be readily achievable using conventional monitoring techniques



and analytical procedures, and such measurements appear to be provided



for at the one facility approaching operational status.  Flow-through



ionization chambers are capable of measurements of krypton-85 at



concentratons of less than 1 pCi/cm3, a concentration 1000 times lower



than that corresponding to the standard for a typical stack effluent



volume.  Similarly, x-ray spectrometry is capable of sensitivities of the



order of 1 pCi for iodine-129; at 10% of the proposed limit a charcoal



sample of stack effluent would accumulate, for a 10 minute sample of 0.2%



of the stream, 1000 pCi.  Finally, gas-flow proportional counters, using



24-hour filter samples (collected on 0.1% of the gas stream) would



exhibit detection limits at least 1000 times smaller than activities
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corresponding to the standard.  Periodic confirmation of the isotopic




distribution of transuranics would also be necessary.




     It should not be necessary to routinely monitor minor releases of




these materials from minor classes of sources, once these have been




properly characterized as such, unless normal monitoring of general




releases discloses that an unusual situation exists which indicates that




normal "de minimus" releases of these materials may be being exceeded.




Such an occurrence would, presumably, not constitute a "normal" release




and investigation and correction would be warranted in any case.








c)   The variance provision.




     It is not anticipated that utilization of the variance provision of




the standards is likely to be either required or appropriate for any  '




facility other than a power reactor in the foreseeable future.  That is




not to say that it would be inappropriate to use the variance provision




if circumstances warranted, but that such circumstances appear unlikely.




On the other hand, it is quite possible that a power emergency, either




local, regional, or national, could occur, and that continued production




of power by a reactor experiencing higher than normal releases would be




in the public interest.




     In proposing these standards the Agency purposely did not specify




detailed procedures to be followed to obtain a variance, since these




should be developed by the NRC with opportunity provided for the views of




the interested public and the industry to be heard.  The Agency does,




however, have some general views on the implementation of this provision.
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     First, the use of the variance should be predicated upon a




demonstrable public need for power, and not on the needs of a utility,




as, for example, the inconvenience of scheduling a repair to a control or




a fuel reloading.  Second, the granting of a variance should be publicly




announced, with prior notification of the Agency, and include a brief




preliminary assessment of the extent of the excess exposure and releases




anticipated, the anticipated duration of the variance, the reason for the




excess release, and the reason for granting the variance.  Finally, after




the variance has terminated, a final assessment of each of the above



factors should be issued promptly.




     In general it is anticipated, based upon past experiences, that when



a facility is approaching a condition in which excess releases are




possible that normal monitoring and reporting of facility releases wilj.



provide more than adequate forewarning to permit timely consideration by



NRC of the need for a variance.  However, in order to provide for quick



response in the case of a sudden power emergency, it may be desirable for




the NRC to establish some basic criteria for semi-automatic invocation of



a temporary variance under such circumstances.  Such criteria would hava



to be limited, at a minimum, by considerations such as conforraance with



NRC's safety requirements and FRC occupational exposure limits,



limitations which are not affected by these standards.
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Implementing^ Regulations

     A number of regulations or regulatory actions are affected by these

standards, as the above discussion of implementation indicates.  These

include:

     1)    10CFR20 - Modify, to reflect, by reference, that 40CFR190

supercedes for normal releases from uranium fuel cycle operations.

     2)    10CFR50, Appendix I - Modify to indicate that additional

requirements may be required for sites containing more than five light-

water-cooled reactors, or, if the NRC so determines, in other special

cases.

     3)    Review license conditions for fuel cycle facilities, other

than light-water-cooled reactors conforming to Appendix I, for
                                                                     *
conformance to 40CFR190.

     4)    Determine whether any sites exist which are close enough to

other sites to receive substantial contributions to dose from such sites,

and-make any necessary modifications of technical specifications in such

cases (the Point Beach and Kewaunee sites appear to be the .only such

potential case presently in existence).

     5)    Determine the apportionment to be made for unrestricted

release (relative to 40CFR190) of krypton-85, iodine-129, and alpha-

emitting transuranics of half-life greater than one year at fuel cycle

facilities not major sources of emissions of these nuclides, and

determine the decontamination factors required at major sources.
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     6)    Establish criteria, as required, for granting of variances




under power emergency conditions, and for establishing public need for



orderly delivery of electrical power.




     7)    Establish, where necessary, requirements on transportation of




nuclear wastes and spent fuel to prevent layovers in areas to which




public access is possible.




     Several regulatory activities already required by existing NRC




regulations or underway are also relevant to implementation of these




standards.  These include:



     8)    Continuing development of ALAP guidance for fuel cycle




activities other than light-water-cooled reactors.




     9)    Definition of regulatory models for doses to individuals near



fuel cycle operations.                                                »




     10)   Definition of "temporary and unusual operating conditions" for




implementation of limiting conditions for operation under Appendix I to



10 CFR 50.



     The most significant efforts required, of these that are not already



required or committed, are items 3), 5), 6), and 7).  These concern



directly the implementation of the standards, the balance are either



minor codifications of the standards into existing regulations, or




represent reflection of the existence of these standards into existing



ongoing efforts.
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EPA Verification of Compliance


     The Agency will assess compliance with these standards through its


review of NRC implementing regulations, review of operating data supplied


to the NRC by licensees, and review of any variances issued by NRC.


Supporting activities will include the Agency's continuing review of


draft and final environmental statements for all fuel cycle facilities,


field studies at selected fuel cycle facilities, and assistance to the


NRC, when necessary, through field measurements in cases of possible

noncompliance.


     Under general NEPA and FRC authorities, the Agency routinely reviews


and comments on all NRC regulations, including 10 CFR 50 guidance and

                                     i
regulatory guides, pertaining to environmental releases and exposures of


the public due to nuclear fuel cycle operations.  In the future, this*


review will also include consideration of the implementation of these

standards.  This review will encompass, among others, the appropriateness

of design basis assumptions, environmental transport models, dose

conversion assumptions, environmental monitoring and reporting


requirements, and, finally, operating compliance requirements.  The


Agency will not, however, routinely review technical specifications or

other license requirements pertaining to individual licensees.


     The Agency also maintains a continuing review of the state of the

environment with respect to contamination by radionuclldes and doses to


the public, including contributions from fuel cycle sources.  Beginning

this year, the results of this review will be published annually.  This


report will depend, for fuel cycle sources, primarily upon data collected
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by the NRC.  The Agency has requested that the NRC supply this

information in sufficient detail to permit reasonably detailed annual

assessments of the exposures of members of the public and releases to the

environment at fuel cycle facilities.  Unfortunately, it will apparently

be some time before data for all fuel cycle facilities can be made

available in a suitable form.

     EPA's review of draft and final impact statements for individual

fuel cycle facilities will serve to allow EPA to identify to NRC

situations in which it believes future compliance, when the facility is

completed, may be questionable.  However, such findings will remain

advisory, as in the past, since responsibility for compliance with these

standards during actual operations rests with the facility and the NRC.
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     EPA has for some years conducted special field studies in order to

characterize the environmental releases, transport, and impact of

radlonuclides from fuel cycle facilities.  These have included detailed

general studies at pressurized and boiling water reactors, a fuel

reprocessing facility, and at mill tailings piles.  In addition,

specialized studies of iodine pathways and of nitrogen-16 radiation at

reactors have recently been carried out.  These studies will continue in

the future.  They are of invaluable assistance in providing soundly based

knowledge for assessing the behavior of environmental releases of

radioactive materials, and in judging the adequacy of environmental

models used for assessing compliance.  The measurement capabilities

developed for these studies may also prove useful and will be available
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for situations In which the NRC needs assistance in field verification of



compliance.








Timing of Implementation of the Standards



     It is proposed that these standards become effective' two years from"



the date of promulgation, with the exception of those for krypton-85 and



iodine-129, which are proposed to become effective in 1983.



     All existing reactors are now or will shortly be in compliance.  In



any case, it is considered reasonable to expect that any reactor



facilities not now in compliance with Appendix I will be by 1978, three



years after its issuance and the earliest possible implementation date



for these standards.  The question of timing of implementation of the
                       v


standards is not significant, therefore, as it applies to reactors.   '



     Only one fuel reprocessing facility is now likely to become operable



by 1978, and, on the basis of its environmental statement and EPA's



assessment of its projected control capabilities, this facility should be



able to achieve compliance with the standards at that time.  Future



compliance with requirements for krypton and iodine releases will depend



on the installation of additional controls by 1983.  In this regard, it



should be noted that the effective date of 1983 for this portion of the



standard applies to any release of these nuclides after that date, not to



nuclides produced in fuel irradiated after 1983.



     Implementation of these standards at milling facilities will in many



cases require the installation of updated dust collection equipment, and



institution of dust control methods at tailings piles.  This equipment is
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commonly available in commerce.  The standards do not apply retroactively



to offsite windblown tailings, nor to tailings piles at sites no longer




licensed.  In a few instances large instabilized tailings piles may exist




at sites with active licenses.  The Agency has these special situations




under study.
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          SUPPLEMENT   B









DOSE-EFFECT ASSUMPTIONS USED AS THE




  BASIS OF THE PROPOSED STANDARDS

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               DOSE-EFFECT ASSUMPTIONS USED AS THE BASIS OF THE
    PROPOSED ENVIRONMENTAL RADIATION STANDARDS FOR THE URANIUM FUEL CYCLE
     Many comments were received concerning the Agency's use of the

linear nonthreshold dose response model for estimating the potential

consequences of doses to populations.  While a few commentors believed

this model was insufficiently protective of public health, the majority

of comments questioned the Agency's health effects estimates in the

belief that they were overly conservative.  These comments were confined

to estimates of cancer risk; the Agency's use of a linear nonthreshold

model to estimate genetic risks, perhaps the largest class of potential

health effects, was not questioned.  The Agency agrees that in certain

cases a linear nonthreshold model could over- or under-estimate somatic

health effects, and has adopted a policy of utilizing other dose-effect

models where clinical data clearly indicate better risk estimates can be

made using other assumptions. For example, the Agency has stated that it

is highly probable that a threshold dose is required for the induction

of skin cancer, and therefore such cancers were excluded from considera-

tion in developing these standards(1).



     No specific data was presented by commentors to indicate that any

non-linear dose response model is applicable to exposures from the

uranium fuel cycle. Rather, frequent reference was made to a statement

by the NCRP(2) that extrapolation from the rising portion of dose-

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incidence curves derived from data obtained at high doses and dose rates




cannot be expected to provide realistic estimates of the actual risk of




cancer from low level doses of low LET radiation.  The Agency agrees




that dose incidence curves must be interpreted with care, but believes




much human data, such as that discribed in the NAS-BEIR Report (3), is




useful for estimating radiation risks.









     Three factors have been identified by the NCRP as influencing the




validity of interpolation between zero dose and effects and existing




data based on the linear nonthreshold hypothesis: dose, dose rate and




the LET (linear energy transfer) of the radiation in question(2).  For




high LET radiations, such as alpha particle irradiation due to effluents




from the Uranium Fuel Cycle, NCRP seems to accept the use of linear




nonthreshold hypothesis.  In the case of low LET radiation, such as from




effluents emitting beta particles and gamma rays, the Agency accepts the




fact that the epidemological basis for risk estimates is less straight-




forward and indeed discussed the uncertainties in its technical documents




offered in support of these standards(l).  The Agency is aware that for




low LET radiations in-vitro cell killing experiments generally show




reduced effects at low dose rates, indicating that repair of cell-




killing damage may be taking place.  The case for repair of precar-




cinogenic injury, however, is not nearly as clear-cut.  Demonstrations




of decreasing cancer induction at low dose rates have been confined to a




few studies utilizing laboratory animals, most often mice.  These

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studies provide conflicting results depending on the species, pattern of




irradiation and even the sex of the animals.  The decreases in effects




observed are in any case relatively small; about a factor of 2-5, but




not several orders of magnitude as suggested by some commentors.  It is




important to note that the effect of dose rate on radiocarclnogensis in




animals is not likely to provide an adequate predictor for human risk,




since both the life span and the pattern of cancer induction following




irradiation are different in man and animals.  Nor is it necessary to




limit consideration of this question to animal data.  There is some




cancer incidence data on the effect of dose rate on humans, unfortunately




not cited in NCRP 43, which indicates that low dose rates may be equally




or more carcinogenic, particularly for protracted exposures(3,4). Until




unequivocal contradictory data on radiocarcinogenesis in humans is




available that indicates  protracted low dose rate exposures are less




carcinogenic than acute exposure at high dose rates, the Agency




considers allowance for reduced injury due to low dose rates too specu-




lative to be made part of the basis for standards developed to protect




public health.  While the Agency does not overrule the possiblity that




such data may become available in the future, it does not believe




sufficient data exists now to warrant a revision in its somatic health




effect estimates based on dose rates.








     A separable question from dose rate effects is the question of




interpolation from high doses to low doses.  The point is often made




that interpolation from high doses over-estimates risk if made from a

-------
portion of the dose response curve where the number of cancers is in




proportion to the square of the dose.  However, as pointed out in the




Agency's technical documents(1), interpolations from effects observed




following high doses may also under-estimate the number of cancers




induced because cell killing at high doses substantially reduces the




number of cells at risk for radiocarcinogenic transformations.









     There is growing evidence, as suggested in NCRP 43(2), that the




Kellerer-Rossi model for initial radiation injury (not radiocarcinogenesis




per se), which predicts a summation of linear and dose squared response,




is useful for interpreting at least some radiation effects data.




However, the available data in support of this model indicate that at




doses less than about 100 rem the linear, not the dose squared, term




dominates the predicted response.  Most, but not all, of the health




effect estimates given in the BEIR Report are based on data that include




at least one point for doses less than 100 rems.  Therefore, it is not




considered likely that Agency estimates of radiation-induced cancer are




greatly overestimated by the use of BEIR results.  In a few cases it is




possible to test for this effect directly by comparing the results of




human experience at high and low doses(4).  Such studies show little




difference in effects per rem and may, in fact, indicate an increased




effect at low doses, particularly in cases where the radiation exposure




is protracted over relatively long periods of time.  Again the linear




nonthreshold hypothesis cannot be characterized as being overly con-




servative.  The Agency recognizes that the interpolation of risk estimates

-------
for humans from high to low doses is uncertain(5)9 but believes this is




a more prudent public health policy than extrapolating laboratory data




on short life span animals to man.  None of the comments received




indicated why the latter procedure would be preferable.








     A number of comments were received expressing the view that the




Agency had not recognized the NCRP comment cautioning, "...governmental




policy-making agencies of the unreasonableness of interpreting or




assuming 'upper limit' estimates of carcinogenic risks at low radiation




levels, derived by linear extrapolation from data obtained at high doses




and dose rates, as actual risks, and of basing unduly restrictive




policies on such an interpretation or assumption"(2).  The Agency agrees




with the NCRP that only reasonable interpolations are warranted, and




believes the proposed Uranium Fuel Cycle Standards are both prudent and




reasonable. If there is any disagreement it is in the Agency's adoption




of the NAS recommendation that linear interpolation be used as a "best"




estimate(3) of risk, and not as an estimate on the "upper limit of




risk," which seems to be the current philosophy of the NCRP.  The Agency




has based its health effects estimates on a continuing review of current




scientific information, and it believes these estimatesrepresent the




most reasonable interpretation of the available data.  It will, of




course, review new scientific findings as soon as they become available.








     Some commentors expressed the view that numerical estimates of




radiation-related risks are of little use if they are not compared with




                                   5

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the risk from other environmental pollutants.  While the Agency accepts



that such comparisons, including a comparison with "natural background



radiation," may place the radiation risk from man's activities in a



perspective useful to the public, the Agency does not accept such



comparisons as the primary basis for establishing radiation protection



standards, since at best it could only result in equity between



pollutants - not between costs and benefits.  Having made an assessment



of potential health risks the Agency believes it is more appropriate to



select appropriate limits by means of a cost-effectiveness of health



risk reduction methodology, rather than via comparative risk assessment.







     A number of commentors noted that the reduction of very small risks



even further is either not worthwhile or is not cost-effective. The



Agency agrees that the risk to an individual from certain radioactive



effluents may often be small.  However, unless a threshold for radio-



car cinogenesis can be demonstrated,  the total risk is not necessarily



small, but depends on the number of  persons exposed.   In developing the



proposed standards careful consideration was given to the cost-effectiveness
                                                          V


of various levels of risk reduction for the entire exposed population,



not just for specified individuals.   The standards proposed were chosen



so as to avoid the imposition of any unreasonable costs for control.  It



is the Agency's conclusion that all of the costs incurred will be



justified by the concomitant reduction of a potential risk to public



health.

-------
                             REFERENCES
(1)   Environmental Analysis of the Uranium Fuel Cycle - Part III,
     Appendix C, U. S.  Environmental Protection Agency, EPA-73-003-D,
     October 1973.

(2)   NCRP Report No.  43,  Review of the Current State of Radiation
     Protection Philosophy, National Council on Radiation Protection
     and Measurements,  Washington, D.C.,  January 1975.

(3)   The Effects on Populations of Exposure to Low Levels of Ionizing
     Radiation, Division  of Medical Sciences, National Academy of
     Sciences, National Research Council, November 1972.

(4)   Linearity vs. Nonlinearity of Dose Response for Radiation Carcino-
     genesis, Brown,  J. M., review paper  presented at the 20th Annual
     Meeting of the Health Physics Society, July 15, 1975.

(5)   The Relationship Between Radiation and Effect, Policy Statement,
     U.  S. Environmental  Protection Agency, Office of Radiation
     Programs, March 1975.

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                SUPPLEMENT   C
                                             y


POTENTIAL LIMITATIONS ON MULTIPLE REACTOR SITES

       IMPOSED BY THE PROPOSED STANDARDS

-------
             POTENTIAL LIMITATIONS ON MULTIPLE REACTOR SITES
             IMPOSED BY STANDARDS FOR THE URANIUM FUEL CYCLE
Introduction

     The number of reactors at a given site could be limited, at least in

principle, by an ambient environmental radiation standard applying to all

activities in the uranium fuel cycle (1,2).  In order to examine this

possibility, conclusions developed during the AEC's (now NRC) rulemaking

on as low "as practicable" (ALAP) reactor effluents, AEC and NRC

dosimetric estimates for real sites in environmental statements, the

results of EPA field studies, operating data for reactors, and some

analyses of hypothetical configurations are each examined in turn below.

First, however, we digress for a brief assessment of the number and sizes

of multiple reactor sites to be expected, based on actual commitments by

utilities during the next decade.



Multiple Reactor Site Projections

     Originally, nuclear power reactors were constructed as individual

units, each on its own site.  As nuclear power became more attractive

economically and technologically, multiple reactors were ordered for

-------
single sites.  A recent listing of all reactors in operation, under




construction, or on order (3) reveals that there are only six sites for




which as many as four reactor units are presently committed.   These four-




unit sites are:
Site
Alan R. Barton
Hartsville
North Anna
Shearon Harris
Surry
WPPSS
Commercial Operation •
Expected for Last
Location Unit
Verbena, Ala.
Hartsville, Tenn.
Mineral, Va.
Newhill, N.C.
Gravel Neck, Va.
Richland, Wash.
1987
1982
1981
1990
1984
1982
     TVA also has plans for four more reactor units at as yet unspecified




locations, which may or may not be built on the same site.  Thus, it is




likely to be at least five years before a four unit site could be in




operation.  No sites containing more than four reactor units are




presently committed.  Considering the lead time of eight years necessary




(from contract award to commercial operation) for a single reactor unit,




it will apparently be at least a decade before a five or six unit site




could become operational.








Considerations from the ALAP Rulemaking




     One of the basic questions considered by the NRC in the rulemaking




for as low "as practicable" discharges from light-water-cooled nuclear




power reactor effluents was whether the design objectives of Appendix I




to 10 CFR 50 should apply to each reactor or each site.  The original

-------
proposal would have applied the basic dose Halts to entire sites.

However, in the words of the Commission (4),

           "We have chosen to express the design objectives on
           a per light-water-cooled nuclear power reactor basis
           rather than on a site basis, as was originally
           proposed.  While no site limits are being adopted,
           it is expected that the dose commitment from multi
           light-water-cooled reactor sites should be less than
           the product of the number of reactors proposed for a
           site and the per-reactor design-objective guides
           because there are economies of scale due to the use
           of common radwaste systems for multi-reactor sites
           which are capable of reducing exposures."

Later, in a more detailed discussion of this question (A), the Commission

expressed the view:

           "We are also of the opinion that it will be at least
           several years before sites containing as many as
           five light-water-cooled nuclear power plants are
           developed.  Consequently, we see no way that design-
           objective guides set on a per-reactor basis can, in
           the near future, result in individual exposures that
           are more than 5% of present-day (10 CFR 20)
           radiation standards.  Indeed, we believe that, with
           the required inclusion of all radwaste augments
           justified on a cost-benefit basis and with the
           realization that several reactors cannot physically
           be placed so as to all be a minimum distance from
           the maximally exposed individual, the actual doses
           received by individuals will be appreciably less
           than this small percentage."

Thus, it was the opinion of the Commission that the radiation doses from

multi-reactor sites, containing up to five light-water-cooled nuclear

power reactors, will remain at small percentages of present-day (10 CFR

20) radiation standards, specifically, at less than 25 mrem/yr to the

whole body and 75 mrem/yr to the thyroid.

-------
Results of NEPA Reviews

     For the last few years, the AEC and NRC have filed environmental

statements under the provisions of the National Environmental Policy Act;

these environmental statements assess the expected performance

characteristics for projected nuclear facilities, including nuclear power

reactors.  Table 1 summarizes the results of these analyses for

radioactive releases from all sites projected to contain three or more

reactors.  The table shows that:

     (1)  For the eleven such sites analyzed, in only one case is a whole

body dose by any pathway greater than 2 mrem/yr projected.  The

exception, 12 mrem/yr to a hypothetical individual consuming 18 kilograms

per year of shellfish collected from the reactor discharge canal, is

based upon the assumption that public access to that canal is permitted.

     (2)  For no site is a maximum dose of more than about 15 mrem/yr to

the thyroid of an infant at the nearest farm necessary if reasonable and

readily available control measures are instituted.

     It must be emphasized that the estimated doses in Table 1 have been

calculated using conservative models.  Even though the most recent

environmental statements employ models specified by regulatory guides

which are more realistic than those used in the past, these models are

still conservative.  Again, in the opinion of the Nuclear Regulatory

Commission on Appendix I to 10 CFR 50 (A):

           "It must be understood in discussing the matters of
           calculational conservatism and realism that Appendix
           I means, implicitly, that any facility that conforms
           to the numerical and other conditions thereof is
           acceptable without further question with respect to

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            Table 1. Environmental Impacts of Three and Four-Unit Sites
Site
Four Unit Sites
Hartsville
Alan R, Barton
WPPSS(Hanford) 
Iodine

16
2.2
9
ScS
4
4.9

1.8
2.9
10
7
<1
<1
<1
5
FOOTNOTES

   (a)  Dose equivalent to infant thyroid via oow^nilk-pathway at nearest farm
   (b)  All are final environmental statements except Barton, Davis-Besse, and
       Pilgrim, which are draft statements.
   (c)  500 hours unshielded occupancy of boundary per year
   (d)  The applicant's facility design, as proposed, would result in a dose of
       74 mrem/yr, which was not deemed "as low as practicable" by the NRC staff.
       Addition of a turbine building ventilation treatment system could reduce
       the total dose to about 16 mrem/yr, as indicated in the statement.
   (e)  Does not include dose equivalents from the Hanford N-Reactorj, which is a
       light-water-cooled, graphite moderated reactor.
   (f)  98% of the release is from the condenser air ejector and steam generator
       blowdown tank vent pathways of Units 1 and 2 and can be eliminated or dras-
       tically reduced through simple modifications of existing control equipment.
   (g)  Assumes public access to cooling water discharge canal and annual consumption
       of 18 kg of fish and mollusks raised in discharge.
   (h)  Monitoring and appropriate operational practices will be required by NRC
       to assure that dose levels do not exceed 15 mrem/yr? NRC considers the
       calculated dose without such measures  (28 mrem/yr) very conservative (i.e.,
       the actucal dose will be lower).
   (i)  Based on augmented system committed by applicant  (p.11-40 of EIS)

NR- Not Reported

-------
           section 50.34a...The numerical guidelines are, in
           this sense, a conservative set of requirements and
           are indeed based upon conservative evaluations."

In any event, the results presented in Table 1 indicate that for all

multi-reactor sites for which environmental assessments are available,

the maximum projected dose is less than 5 mrem to the whole body, even.

under the highly unlikely presumption that the maximum whole body doses

for gaseous and liquid effluents add arithmetically.  Thyroid doses would

limit the number of such reactors at a given site to no greater extent

than do whole body doses.  This conclusion is, of course, in harmony with

that reached by the NRC that sites containing as many as five light-

water-cooled nuclear power reactors would result in individual exposures

that are appreciably less than 25 mrem/yr to the whole body and 75

mrem/yr to the thyroid.



Results from Field Studies

     In addition to the estimates of dosimetric impact made using

''realistically conservative" calculational models, the EPA and its

predecessor organizations have conducted detailed surveillance programs

at selected facilities (5-9).  These studies have confirmed the accuracy

of reported effluents of noble gases and liquids, but appear to reveal

significantly lower iodine concentrations in milk than projected by

models for the milk pathway currently used for environmental analysis.

     Field studies conducted by the EPA at Dresden (Unit 1), Yankee Rowe,

and Haddam Neck (formerly Connecticut Yankee) have shown the following

maximum individual doses to the various organs listed (5-8):

-------
                   Maximum Individual Dose (mrem/yr)
Organ
Whole body
Thyroid
Bone
GI (LLI)
Dresden
8.0
0.74
0.026
0.008
Yankee
3.0
0.006
0.20
0.26
Haddam Neck
3.8
6.0
3.0
0.4
It should be noted that these values are absolute maximum doses for each

organ; all pathways possibly contributing dose to a particular organ were

summed to arrive at the above totals.  These doses thus presume that an

individual could be simultaneously exposed to all pathways of exposure

and that he would receive the maximum possible dose from each pathway.

Thus, these doses are extremely unlikely to have been received by any

real individuals, as was pointed out by the authors of the Dresden and

Yankee studies (8):

           "...a farmer near Dresden may eat beef, green
           vegetables, and drink milk, but he would not also
           eat 100 gms of fish per day that had been caught at
           Starved Rock Dam, neither would he consume Peoria
           drinking water, nor does he reside in the areas for
           which inhalation and external whole-body exposures
           were calculated.  Consequently, actual radiation
           exposures to existing populations in the vicinity of
           both nuclear power plants are less than the total
           dose rates listed..."

Furthermore, most of the whole body dose listed for the pressurized water

reactors (PWRs), Yankee Rowe and Haddam Neck, result from direct

radiation originating from stored radioactive waste (gaseous and liquid

storage tanks).  This exposure may be minimized by simple shielding or

-------
careful placement of these tanks relative to the site boundary.




Virtually all of the thyroid dose and bone dose at Haddam Neck results




from the hypothetical consumption of fish (18 kilograms per year) caught




in the discharge canal.  Almost all of the whole body dose listed for



Dresden results from exposure to the gaseous effluent (principally noble




gases) discharged from the stack; boiling water reactors (BWRs) such as




Dresden are presently augmenting (or have already augmented) their noble




gas treatment systems to provide additional dose reduction factors of 8




to 180 beyond those in force at the time the above studies were carried



out (2).  The three reactors studied are also of early design.  Reactors




going into operation today or in design and construction stages



incorporate considerably more sophisticated radwaste treatment systems




having larger processing capacities, greater cleanup efficiency, and



increased flexibility.



     Doses due to gamma radiation (directed and scattered, or "shine")



originating onsite can be significant at BWR sites because of the



circulation of activation-produced nitrogen-16 through the turbines and



associated equipment, particularly the moisture separators„  The EPA



field studies discussed above considered the whole body dose from direct




gamma radiation only for the PWR field studies (Yankee Rowe and Haddam



Neck).  Field measurements made by the EPA, ERDA, NRC, and others have



shown that dose rates on the order of 10 mrem/yr (whole body) at 500



meters are possible without supplementary shielding of turbine building




components; these dose rates, however, decrease very rapidly with



distance so as to produce very small population doses (10-13).  In

-------
addition, dose rates are very dependent upon the design and layout of the




turbine and its associated equipment.  Appropriate design of shielding




and location of turbine components relative to the site boundary can




assure that offsite doses from "turbine shine" are minimized.  The siting




of many reactor units at a single site should also result in




significantly smaller offsite doses from turbine "shine," as the




exclusion distance increases with the number of reactor units on a site.




According to a recent study (14), the exclusion distance averaged 460




meters for single unit BWRs and 860 meters for twin-unit BWR sites; for




PWRs, single units sites averaged 750 meters, while twin-unit sites




averaged 900 meters.  Since the dose from turbine "shine" falls off very




rapidly with distance, such doses should be significantly reduced for




multi-reactor sites.  For example, using the data from the most recent




study (13), the dose rate falls off by/a factor of five as the distance




increases from 460 meters to 860 meters.  Therefore, it is to be expected




that dose rates from turbine "shine" at multi-reactor sites will not be




significant compared to those from the single unit sites at which field




studies have taken place.




     Studies of iodine pathways and potential thyroid doses have been




conducted jointly by EPA and AEC over the past two years at the Dresden,




Monticello, Oyster Creek, and Quad Cities sites (9).  The available




results present a consistent picture of iodine concentrations in milk




less than these projected by models for the milk pathway currently used




for environmental analyses.

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Results from Reactor Operation




     In addition to conservative environmental dose pathway models,




radionuclide source term models have generally been conservative.  For




example, fuel experience for PWRs has been much better than the 0.25%




fuel leakage rate now used as a design basis for calculating




environmental releases.  Westinghouse, which has manufactured the great




majority of operating PWRs, reports that fuel integrity has generally




been in the neighborhood of 99.98% (i.e., a fuel leakage rate of 0.02%)




for zircaloy-clad fuel.  Exceptions to this high level of fuel integrity




occurred in 1969-1970, when hydriding lowered fuel integrity to the 99.8-




99.9% range, and in 1972, when fuel densification lowered fuel integrity




to the 99.9% range (15).  On the other hand BWRs, which have typically




been designed for fuel leakage corresponding to the release of 100,000




uCi/sec of noble gases from the air ejector, after a nominal' 30 minute




delay, exhibit a more variable performance.  Figure 1 shows that this




design value had yet to be reached by BWRs operating through 1973;




indeed, most were very much below the design value (16).  Recent data,




however, indicate a rising trend of releases from BWRs, and EPA is




maintaining a continuing surveillance of this trend, which may indicate




that the present design basis is too low to provide adequate assurance




that Appendix I design objectives will be satisfied in actual operation.




In general, however, fuel integrity at PWRs and for pre-1974 BWR




performance has been considerably better than predicted by conventional




source term models used in environmental analyses.
                                   10

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     5.0r-
>-
 i
ID


I  1.0
LU
Q

§
Q.
CO
    0.5 -
    0.2 -
    01
         I
            J	I
                   I
                       I
                                                                                         30-MINUTE
                                                                                         HOLDUP
                                                                                         BASELINE
        0.010.05010.2  05
  2     5    10    20   30  40  50 60  70   80    90   95
PERCENT OF SAMPLE NOT EXCEEDING PRODUCTION RATE
                                                                                          98   99
99.8 999
       Figure 1  Distribution of noble gas releases in 1971-73 for boiling water reactors that commenced operation after
                1968.   The solid line is a fitted log normal distribution.   (Ref.  15)

-------
     A second important consideration with respect to conservatism in




source term models is the fact that, especially for PWRs, effluents are




postulated for inplant pathways which require simultaneous levels of




degradation of several parameters in order to lead to a postulated




release to the environment.  For example, effluents from the PWR




secondary system (e.g., steam generator blowdown vent or condenser air-




ejector exhaust) require the simultaneous existence of a "design basis"




assumed fuel leakage and a "design basis" assumed steam generator leakage




rate of primary coolant into the secondary coolant.  Since the




probability of each "standard" assumption is generally significantly less




than one, the probability of both occurring at the same time must be



smaller than either of the individual probabilities.  Thus, if the annual




probability of having the "design basis" number of fuel failures is five




percent and the probability of having a- "design basis" primary to




secondary leak is twenty percent, the probability of operating a PWR with



"design basis" fuel leakage and primary to secondary leakage is of the



order of one percent.  ,In .spite of this, light-water-cooled reactors have



been evaluated as if these "design basis'* conditions occur



simultaneously, for periods of time comparable to a year (17).








Analysis of the Additivity of Doses from Multiple Facilities



     Similar considerations apply to the assessment of doses from



multiple facilities on a single site.  A variety of site specific factors



exist, including the site size, the relative location of individual



facilities on the site, and economies available through utilization of
                                   12

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design incorporating shared control measures, each of which mitigate


against arithmetic additivity of doses to a maximum exposed individual


outside the site boundary.  In general, these effects are quite


significant, as is reflected by the low doses projected for those'*sites


which have been subjected to analysis, as, for example,' in the


environmental statements quoted above.  Indeed, these sites project lower


doses than many single unit sites.  In addition, however, there is


significant operational flexibility available at a multi-unit site not


available to sites containing single or double units.  For example, if a


reactor at a four-unit site is experiencing a severe rate of1 fuel


failure, the output of the site could be maintained at- a respectable 75%


of capacity while that reactor is serviced, by operating the remaining


units, at full fuel capacity, a degree of flexibility not available to a


one- or two-unit site without calling upon another portion of .the power


grid to take up the loss of capacity.


     In addition to the above considerations, which in actual situations


should generally be overriding, it is, however, also instructive to


consider the following hypothetical example.  Assume that all units on a


site are located at exactly the same point, and that each is designed to


no more than conform exactly, using "design basis" assumptions, to the


design objective doses specified by Appendix I (say, 5 mrem whole body


dose via the air pathway) to some common hypothetical worst case


receptorj  Assume further, since under Appendix I this dose is to be
\

exceeded only in "temporary" and "unusual" situations (4), that one may


assign some reasonable probability that, on an annual basis, the design
                                    13

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objective dose for any single unit will not, in fact, be exceeded.  For


example, the 0.25% fuel failure assumption currently used as a design


basis for PWRs is not exceeded, on the basis of current operating ,


history, at least 95% of the time.  What then, is the dose that can be


expected to be not exceeded at the same confidence level (95%) for 4, 5',


or 6 such units?  That the answer is not 4, 5, or 6 times 5 mrem/yr is


obvious.  The exact result is dependent upon the variance of the


operating data, and, to a lesser degree, the shape of the distribution of


the data.  A statistical analysis utilizing actual operating data for


PWRs and BWRs yields the following projections (18):


      Dose Levels (mrem/yr) that will be Satisfied 95% of the Timet


      '	4 Units	5 Units	6 Units	


PWR                           15            18            21


BWR	16	19	22	


tFor single units which each satisfy Appendix I at the 95% confidence
level; each value has an uncertainty of approximately 1 mrem/yr.


     Each of these values is significantly lower than that predicted by


an assumption of additivity, even for the extreme case of colocation of


all units, no exercise of operational flexibility, and design for the


maximum release permitted by Appendix I considered here.





Conclusion


     On the basis of a) results projected by the AEC and NRG for all

                                                   0
multi-unit sites presently committed, b) the flexibility available


through proper selection and utilization of future sites, c) the
                                   14

-------
conservative nature of design dose calculations, as opposed to the




applicability of these standards to exposures actually received, d) the



nonadditivity of design basis dose contributions from single units, and




e) the operational flexibility available to sites with multiple units, it




is concluded that the proposed standards can be readily achieved at all '




presently planned and all properly designed future multi-unit sites of up




to at least five units.  It is further noted that in "unusual"



circumstances during which the design objectives specified for light-



water-cooled reactors by Appendix I may be "temporarily" exceeded (4),



that the variance provision of the proposed standards would permit



continued operation in times of necessity.  Questions associated with



even larger configurations of units, such as nuclear energy centers, are



addressed separately.
                                   15

-------
                               REFERENCES
     Environmental Radiation Protection for Nuclear Power Operations:
     Proposed Standards, Federal Register, Vol. 40, No. 104, pp.  23420-
     23425, May 29, 1975.         .  •       -

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

3.   Nuclear News. 18. p. 63, August, 1975.

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

5.   Kahn, B., R. L. Blanchard, H. E. Kolde, et al., "Radiological
     Surveillance Studies at a Pressurized Water Nuclear Power Reactor,"
     U. S. Environmental Protection Agency, RD 71-1, August 1971.

6.   Kahn, B., R.L. Blanchard,  H.L. Krieger, et. al., "Radiological
     Surveillance Studies at a Boiling Water Nuclear Power Reactor," U.S.
     Environmental Protection Agency, BRH-DER 70-1, March 1970.

7.   Kahn, B., R.L. Blanchard,  W.L. Brinck, et ale,  "Radiological
     Surveillance Study at the Haddam Neck PWR Nuclear Power Station,"
     U.S. Environmental Protection Agency, EPA-520/3-74-007, December
     1974.

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

9.   Detailed Measurement of Iodine-131 in Air, Vegetation, and Milk
     Around Three Operating Reactor Sites, Weirs, B.H., Voilleque, P.E.,
     Keller, J.H., Kahn, B., Krieger, H.L., Martin, A., and Phillips,
     C.R., (IAEA/SM-180/44), presented at the Symposium on Environmental
     Surveillance Around Nuclear Installations, International Atomic
     Energy Agency, November 1973; and unpublished data, U.S.
     Environmental Protection Agency and U.S. Atomic Energy Commission.
                                   16

-------
10.  Lowder, W.M., Raft, P.O., and Goglak, C.V., "Environmental Gamma
     Radiation Through Nitrogen-16 Decay in the Turbines of a Large
     Boiling Water Reactor," HASL-271, January 1973.

11.  Brinck, W.,  Gross, K.,  Gels, G.,  Patridge, J.,  "Special Field Study
     at the Vermont Yankee Nuclear Power Station,"  Internal Report, U.S.
     Environmental Protection Agency,  Office of Radiation Programs, 1974.

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

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

14.  ''Land Use and Nuclear Power Plants, Case Studies of Siting
     Problems," U.S. Atomic Energy Commission, WASH-1319, 1974.

15.  Kramer, F.W., "PWR Fuel Performance — The Westinghouse View,"
     Nuclear Energy Digest,  No. 2, 1975, Westinghouse Nuclear Energy
     Systems, P.O. Box 355,  Pittsburgh, Pennsylvania 15230.

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

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

18. ("A Statistical Analysis of the Projected Performance of Multi-unit
     Sites, Based upon Operating Data for Existing FacilitiesJ Office of
     Radiation Programs, U.S. Environmental Protection Agency, Technical
     Note  (in preparation).
                                    17

-------
                  SUPPLEMENT   D









  AN ANALYSIS OF CONTROL OPTIONS FOR NITROGEN-16




OFF-SITE SKYSHINE DOSES AT BOILING WATER REACTORS

-------
     AN ANALYSIS OF CONTROL OPTIONS FOR N-16 OFFSITE SKYSHINE DOSES

                        AT BOILING WATER REACTORS
Introduction


     The turbine system at a boiling water reactor (BWR) is a potentially
                                   ,         !

significant source of radiation due to the presence of nitrogen-16, a


relatively short-lived (^=7.14 sec), high energy (2.75 Mev (1%), 6.13


MeV (69%), and 7.11 MeV (4.9%)) gamma emitter in the steam leaving the


reactor.  Nitrogen-16 is produced in the reactor core by neutron


activation of oxygen in water, and, although short-lived, can be present


in the turbine system in significant quantities due to the rapid transit


of steam from the reactor vessel through the turbine system and to the


condenser.  The result is a flux of direct and scattered gammas which can


result in high occupational exposure rates in and close to' the turbine


building, as well as potentially significant exposure rates to members of


the public beyond site boundaries near the turbine building.


Sources


     Detailed expositions of nitrogen-16 sources are presented in the


safety analysis report for the General Electric standard boiling water


reactor, the BWR/6 (1); and for operating BWR's in a comprehensive report


recently released by General Electric (2).  In these reports a nitrogen-


16 activity concentration of 50 yCi/gm of steam at the reactor nozzles is


assumed, based on experimental measurements of contact dose rates on


cross-around pipe sections of operating BWRs.  Other analyses (3,4) have


assumed nitrogen-16 activities of up to 100 VCi/gm of steam at the

-------
nozzles; however, this is probably due to the desire for conservatism in




the design of shielding.








     In a typical modern boiling water reactor, steam flows directly from




the reactor nozzles through the main steam header to the high pressure




turbine (HPT).  Steam extraction is also made from this flow path for




steam to the steam jet air ejector (SJAE), feed water heaters (FWH),




gland seal system, and the moisture separater/reheater units (MSRH).




Steam leaving the HPT is routed through the shell side of the MSRH's,



where it is dewatered and reheated for injection into the low pressure




turbines (LPT).  Steam extractions are also made at the HPT, MSHR's, and




in several places along the LPT for the various feedwater heater stages



(usually 6).



     Typical delay times to and transit times through these components




are shown in Table 1.  At a concentration of 50 yCi/gm of steam, the



nitrogen-16 source term at the nozzles is 100 Ci/sec.  Thus, it is




obvious that the potential exists for considerable equilibrium activity



to be present in these turbine system components.



     Table 2 lists the calculated inventories for the various turbine




building components.  The dose significance of these sources depends on



the shielding (both exterior and self-shielding of components) as well as



the geometry of the component layout.  The typical order of the dose



significance by component is  a) moisture separater/reheaters, b)




intermediate piping, c) high pressure turbine, and d) all other



components.

-------
Turbine Building Configurations




     The configuration in which components are placed in a turbine




building has undergone several changes in recent years.  Several




different turbine manufacturers have supplied turbines for BWR reactor




plants and component layout has varied as a function of both turbine




manufacturer and of architect-engineer.  Turbines have been supplied by




General Electric, Westinghouse, and Kraftwerk-Union, for example, and




facilities using BWR's have been engineered by a variety of architect-




engineering firms.  The major significant system design changes have been




with respect to the placement of moisture separators and reheaters.




Earlier BWR designs had vertically-oriented moisture separaters and




separate reheaters located on the mezzanine level of the turbine building




(below the operating floor) as shown in Figure 1.  Considerable




shielding was afforded by the concrete structure of the turbine building




around these components, and, particularly above, by the operating floor.




     For a variety of engineering reasons, including Increased efficiency




of turbine operation, reduction in building size, and reduction in time




of construction, recent designs have incorporated horizontally-oriented




combined moisture separaters and reheaters located above the turbine




building operating floor level, as shown in Figure 2.  The high




equilibrium nitrogen-16 activity levels in tube and shell side of these




systems, combined with the relative lack of self-shielding, compared to




that of the thick steel shells and massive internals of turbines, result




in these "exposed" MSRH's and their supply and return piping producing a




potentially high gamma flux in comparison with all other components.

-------
     A system which can perhaps be considered an example of a "worst




case" is the combination of a General Electric BWR with a Westinghouse




turbine system.  In this case the steam piping runs overhead from the top




of the HPT to the top or side of the MSRH.   Since there is considerable




nitrogen-16 activity in these pipes, they can provide a significant



additional source of gamma exposure beyond the MSRH's themselves.




Dose Assessment



     The gamma flux existing at a point outside a turbine building due to




sources of nitrogen-16 inside is difficult to 'calculate.  Gammas may-



arrive at a given point by direct paths, by scattering in shielding and




other components, or from air scattering, as shown in Figure 3.  The




shielding geometry is complicated due to the variety of component 'shapes



and locations, and each component also has different self-shielding



factors for the gammas involved.




     A variety of types of computer codes have been developed to




calculate the air-scattered contrubution to the gamma exposure field



(see, for example, refs. 2,6,7).  The potentially most-accurate of these



are Monte Carlo transport codes.  However, these models have not been



verified by EPA, and they are sufficiently complex and expensive to



prohibit performing such analyses on a case-by-case basis.  No discussion



of analytical techniques for quantitatively analyzing these exposure




rates based on transport codes was undertaken, although the results of



some calculations performed by industry (5) provide the basis for the



present comparison of several options.

-------
     Insight into the relation between various shielding options and


anticipated dose rates can be obtained, however, through an examination


of existing shielding studies in conjunction with field measurement


studies.  This examination indicates the principal contributors to and


magnitudes of potential doses and permits an informed, if not detailed,


understanding of what might be required to reduce such doses.


Shielding of Components


     Because of the high radiation field resulting from nitrogen-16


activity, existing turbine systems are already well-shielded.  This is


not primarily because of consideration of doses beyond site boundaries,


but due to the need to comply with existing occupational exposure limits.


In order to restrict the extent of high radiation areas adjacent to


turbines and to allow more frequent or even uncontrolled access to other


areas in the turbine building, the turbines and MSRH's are heavily


shielded.  Usually this shielding consists of a thick concrete "shadow


shield" surrounding the turbine (as much as 4 ft thick), and upward


extension of the turbine building lower side walls (up to 3 ft thick) to


shadow-shield the MSRH's.  While such shielding substantially reduces the


direct components of the gamma flux, air-scattered contributions from
                                     i

gammas leaving the unshielded top of the turbines and MSRH's can still


produce considerable exposure rates.  Therefore, often as a design
                              f

option, many recent designs have included concrete shields (up to 20"


thick) over the MSRH's and vertical steel plating running between the


turbines and MSRH's to reduce this air-scattered flux  (see Figs. 4,5).


In order to assess the effectiveness of such additional shielding as a

-------
means to reduce site boundary doses we have chosen to analyze a variety



of such shielding options for the turbine building component



configuration shown in Figure 4.  The assumption is made that concrete



walls are already in place around the MSRH/turbine area as shown to allow



required access in the remainder of the turbine building area within



applicable limits for occupational exposure.  These walls are assumed to



consist of three feet of reinforced concrete; this thickness will provide



an attenuation of approximately 99.7% of the incident gamma flux



(neglecting buildup), leaving only the scattered flux as a potentially



significant contributor to, the off-site dose.



     Such a characterization of skyshine as the principle source of



exposure from nitrogen-16 at distances greater than a few hundred meters



from the turbine building is supported by a recent field study performed



at the Cooper Nuclear Station by>EPA and ERDA (8).  Cooper station is a



BWR with a Westinghouse turbine and horizontally-oriented moisture



separaters located on the turbine building operating floor.  Field



measurements were made by EPA in February, 1975, and by ERDA's Health and



Safety Laboratory in April, 1975.  Cooper is a reasonable example of the



"base" case turbine building discussed above, since shielding consists of



side walls only, although in this case these consist of 3 ft of high



density concrete.  A.significant finding of the study was that nearly
                                         \


100% of the dose measured was due to air-scattered (skyshine) gammas.



The contribution to dose of the direct flux was negligible.



     Referring to Table 3, it can be seen that for the base case the



total net equivalent activity above the turbine operating floor is 34 Ci.

-------
Out of this total, 21 Ci are associated with the moisture




separator/reheater and 10.3 Ci are associated with the' intermediate




piping.




     The shielding options considered, calculated doses, and anticipated




costs are presented in Table  4.  These have been derived in part from




information provided the Agency by General Electric (5).  With these




options and their associated dose rates as a basis, and using Means 1975




Building Construction Cost Data (9), we have made independent cost




estimates for installing the additional shielding required by each of the




options considered.  The costs presented do not include any additional




basic building structure which might be required within the turbine




building to support the additional weight of the shielding, because for




most of the cases considered the additional weight involved does not




appear to require any additional support beyond that already available in




the basic structure supporting the turbine and other components.  The




costs presented here are appropriate to plants in the design stage, and




would not necessarily apply to retrofit situations.




     All cases above the base case include the cost of poured-in-place




reinforced concrete, which is supported by an assembly of steel girders




bridging the MSRH's between the exterior turbine shielding wall and




inside panel wall.  The inside panel includes steel columns to provide




additional support for the overhead assembly.  The dimensions required




for each of two overhead shields are conservatively estimated to be 140'




long by 35' wide.  The inside panel walls are assumed to be 140' long by




25' high. . The concrete for exterior side walls and end walls is assumed

-------
to be already present as the "base case."   Costs of materials,




installation, engineering, financing, overhead, and profit, were based on




standard estimating assumptions (10).  Details of the estimation




procedure used are available upon request.  Table 4 provide a summary of



costs for the various shield options, and Figure 6 displays annual dose




at 500 meters vs. cost of shielding.




     Doses are presented for the various shielding options both as




calculated by the industry and as projected from values measured in the



field.  The field study resulted in data which indicates that the



calculated doses are high by approximately a factor of two.  In addition,




the assumption of 100% occupancy, no additional shielding by offsite



building structures, and annual operation at 100% power are considered to




be unreasonably conservative assumptions for estimating real doses to



individuals at real sites.  It is concluded, therefore, that it should be



readily possible to restrict the dose from nitrogen-16 skyshine to a real



individual located at reasonable distances from the center of the turbine



building for realistic occupancy times to less than 2 mrem/yr.   These



dose levels should be attainable for no more than approximately $250,000



and even these costs should be incurred only in those few instances where



actual site boundaries are so close to turbine buildings as to  create the




possibility of significant offsite exposures from nitrogen-16 sources.

-------
Notes
1.  BWR/6 Standard Safety Analysis Report, General Electric Company,
    NEDO 10741, Vol. 8.

2.  Rogers, D. R., "BWR Turbine Equipment Nitrogen-16 Radiation
    Shielding Studies," General Electric Report NEDO-20206
    (December 1973).

3.  "Radiation Shielding Design and Analysis Report - Nine Mile
    Point Nuclear Station Unit 2," Stone & Webster Engineering
    Co., RP-6, (January 1974).

4.  Preliminary Safety Analysis Report - Newbold Island Nuclear
    Station, Public Service Electric and Gas Company of N.J.,
    February 1970.

5.  Information provided EPA by General Electric and Bechtel
    Engineering Staff, (January 1975).

6.  Woolsen, W.A., A.E. Profio, D.L. Huffman, "Calculation.of the
    Dose at Site Boundaries from Nitrogen-16 Radiation in Plant
    Components," JRB 72-507 LJ, JRB Associates, (Dec. 1972).

7.  Ward, J.T., Jr., "A Dose Rate Kernel for Air-Scattered
    Nitrogen-16 Decay Gamma Rays," Ph.D. Thesis, University of
    California, Berkley

8.  Phillips, C., Lowder, W., Nelson, C., Windham, and
    Partridge, J., Nitrogen-16 Skyshine Survey at a 2400 MW(t)
    Power Plant, EPA -520/5-75-018.

9.  Godfrey, R.G., Editor, "Building Construction Cost Date 1975,"
    33rd Ed., 1974, Robert Snow Means Company, Inc.

10. The following markups were applied to materials and installa-
    tions: 25% overhead and profit, 2.5% engineering, 10%
    contingency.  A short term financing factor of 1.375 was then
    applied to the total, representing a 10%/per annum financing
    cost over a period of three years.

-------
                                                   TABLE  1.
                            Nlr> CHARACTERISTICS OF A STANDARD BT,JR TUHBINF  SYSTUi
               Component

Main Stean Line and Header System

  a.  Reactor Nozzle to Main Steam Header

  b.  Main Stream Header to HPT



High Pressure Turbine

Low Pressure Turbines

Moisture Separator Shell-Side  (Steam)

  a.  Inlet to Vanes

  b.  Vanes

  c.  Vanes to Outlet
Moisture Separator Shell-Side  (Liquid)
(Vanes, Drain Trough)
Decay Time
at Inlet
(seconds)
0.00
2.09
3.18
5.86
4.29
4.64
4.73
4.64
Estimated
Mass Inventory
(Ibs)
8. 933x10 3
4. 464x10 3
13. 397x10 3
3. 784x10 2
7. 611x10 2
1. 256x1* 3
3. OOxin 2
2. 119x10 3
3. 675x10 3
4. 059x10 3
"lass Flowrate
(Ib/hr x 10~6)
15.396
14.764
14.743
10.678
13.171
11.460
10.904
1.712
Component
Transit Time
(seconds)
.2.09
1.09
0.0924
0.257
0.343
0.0942
0.700
8.54

-------
                                             TABLE 1 (Continued)
               Oomponent


Moisture Separator Drain System

  a.  Steam

  b.  Liquid

First Stage Reheat System

  a.  Supply Pipe - HPT to Tube Inlet

  b.  Tubes


Second Stage Reheat System

  a.  Supply Pipe-Main Header to Tube
      Inlet

  b.  Tubes



First Stage Reheat Drain System

Second Stage Reheat Drain System
Decay Time
 at Inlet
 (seconds)
   4.73

  13.13



   3.27

   4.33
   2.09

   3.73



  37.3

  37.8
   Estimated
Mass Inventory
     (Ibs)
   2.058xl02

   6.424xl03

   6.630xl03
   2.80xl02

   S.BllxlO3

   6.091xl03
Mass Flowrate
(Ib/hr x 10"6)
    0.555^

    1.712



    0.7011

    0.7011
    0.6145

    0.6145



    0.7011

    0.6145
  Component
Transit Time
  (seconds)
    1.06

   33.0
    1.64

   34.0

-------
                                             TABLE 1  (Continued)
               Cotrponent

Piping System - HPT to MS/MIR

Piping System - MS/RHR to LPT

  a.  MS/RHR to CIV

  b.  CIV

  c.  CIV to LPT



First Stage FWH and Extraction System

  a.  Extraction Point 4

  b.  Extraction Point 5

Second Stage FWH and Extraction System

Third Stage FWK and Extraction System

Fourth Stage FWH and Extraction System

Fifth Stage FWH and Extraction System
(Excluding MS Drain System)
Decay Time
at Inlet
(seconds)
3.27
5.43
5.66
5.75
6.12
6.12
6.12
6.12
6.12
3.18
Estimated
Mass Inventory
(Ibs)
3.717xl03
6.857xl02
2.852xl02
2.812xl02
1. 252x10 3






Mass Flowrate
(Ib/hr x 10~6)
13.171
10.904
10.678
10.678
0.1016
0.6017
0.6301
0.7344
0.4016
0.0126
Component
Transit Time
(seconds)
1.02
0.227
0.0962
0.0948



•



-------
                                             TABLE 1  (Continued)
               Ccmponent

Sixth Stage FWH and Extraction System
(Excluding Reheater Drain Systems)

C3ondenser
(Excluding return from FW Turbine)

Hotwell
(Excluding return from FW Heaters, etc.)

SJAE First Stage System

  a.  Off-Gas

  b.  Driving Steam Supply Line

  c.  First Stage Driving Steam

Recombiner System
(Second Stage Air Ejector Driving Steam)

Gland Seal System

  a.  From HPT

  b.  From Valve Stem

Feedwater Turbine System
Decay Time
at Inlet
(seconds)
3.27
6.12
"36
-7
2.09
4.33
4.33
3.27
3.18
5.66
Estimated
Mass Inventory Mass Flowrate
(Ibs) (Ib/hr x 10 ~G)
0.857
8.207
0.0016
8.207
0.0016
1. 12x10 * 0.0180
0.0080
0.0100
0.0186
0.0029
0.2259
Component
Transit Time
(seconds)

"30 (liquid)
" 1 (gas)


2.24






-------
                                      Table 2.                 x)
             N16 Inventories For A Standard BWR Turbine System

                                                                      N-16
                                                                    Inventory
                Component                                             (Curies)

Main Steam Line and Header System                          '            263

High Pressure Turbine                                                  6.3

Low Pressure Turbines  (1)                                              n.8

Moisture Separator and Reheater Shell-side Steam                       53

Moisture Separator Shell-side Liquid                                   41

!loisture Separator Drain System                                        56

First Stage Reheat System (2)                                          33

Second Stage Reheat System  (2)                                         32

First Stage Reheat Drain System (3)                                    1.4

Second Stage Reheat Drain System (3)                                   1.1

Intermediate Piping System - HPT to MS/HH                              59

Intermediate Piping System - MS/RH to LPT                              17

First Stage - FWK & Extraction System  (4)                              26

Second Stage - FWH & Extraction System  (4)                             23

Third Stage - FWH & Extraction System  (4)                    .          27

Fourth Stage - FWH & Extraction System  (4)                             15

Fifth Stage - FWH & Extraction System                                  .6
  (Excluding Moisture Separator Drain
   System Activity Listed Above).

Sixth Stage - FWH & Extraction System                                  42
  (Excluding First and Second Stage Reheat
   Drain System Activities Listed Above)

-------
                                   Table 2  (Continued)


                                                                         N-16
                                                                       Inventory
                 Ocnponent                                               (Curies)

Condenser                                                   '           287 '
   (Excluding Residual Activity Returned from
   Feedwater Turbine).

Hotwell                                                                18
   (Excluding Residual Activity Returned from
   Feedwater Heaters and Gland Seal System)

SJAE First Stage System (5)                                              .6

SJAE Off-gas System                                                      .4

Gland Seal System  (6)                                                    1.0

F.W. Turbine System  (6)                                                  8.8

     Total                                                           1022.0


Ttotes

(1)  6-Flow machine.

(2)  Includes inventory in liquid and steam in reheat tubes and in steam
     supply line.

(3)  Includes total inventory beyond reheater outlet.

(4)  Includes total inventory beyound extraction point.  Distribution of this
     will depend on equipment arrangement and sizing.

(5)  Includes inventory in steam supply line.

(6)  Includes total inventory beyond inlet at steam supply line.

-------
              Table 3., Turbine equipment typical total and net
                    16N inventories  (Ci) for a 1200 Mfe plant.
                            TOTAL    ABOVE OPERATING FLOOR
COMPONENT
Main Steam Lines
HP Turbine
HPT to MS/R Piping
MS/R
MS/R to LPT Piping
LP Turbines
FW Heaters &  Extraction
Condenser
Hotwell
 SJAE & Gland Seal
 FW Turbine
260
6
60
220
17
10
130
290
18
2
9
GROSS
5
6
2
150
17
10
—
—
—
—
—
NET
EQUIVALENT
1.6
0.3
1.3
21
9
0.5
—
—
* •••
—
—
                             1022
190
                                                      34

-------
                                  Table 4.  Summary of  Shielding Cost Estimates
Shield

rH
(3
(0
. v
•H
to
c
H
-
6"
6"
1'

1'
-
6"
1'
2'
2'3"
Design


H
o
0
33
CO
*
-
3"
6"
1'

1'
-
6"
1'
1'
2'
i-i
0)
§
0)
c
,0
3
H
-
-
-
_

6"
-
-
-
-
6"
Estimated dose at 500




calculational models
100%
Occupancy
&
Capacity
33
13
8.8
5.9

3.0
37
16
8.6
5.8
2.8
50%
meters (mrem/yr)


, based on:


Estimated cost


of shielding


(k$)


field measurements
100%
Occupancy Occupancy
80%
Capacity
13
5.2
3.5
2.4

1.2
15
6.4 .
3.4
2.3
1.1
&
Capacity
15
5.9
4.0
2.7

1.4
17
7.3
3.9
2.6
1.3
50%
Occupancy
80%
Capacity
6.0
2.4
1.6
1.0

0.5
6.7
2.9
1.6
1.1
0,5
Industry '-*'


1 2
'base' 'base1
720
745
890
255**
915
'base' 'base'
745
895
' 255 990
1,250
EPA


Min.
'base'
96
122
205

258
'base'
122
205
•257
348



Max.
'base'
136 '
169
271

347
'base'
169
271
327
469
* Two estimates were provided, both are shown
** This costCthoughtf to represent an option [inbetween] the final two in this category
Note: First five options for turbine perpendicular to) boundary, second five options for turbine parallel to
      boundary.

-------
NM\
                                  ir-n
                                      x
                             BWR TURBINE BUILDING LAYOUT WITH
                             MOISTURE SEPARATORS LOCATED
                             BELOW THE OPERATING FLOOR
                             *.
J \
                        MOISTURE
                        SEPARATOR

                          \~*
                                          LOW PRESSURE
                                          FEED WATER
                                          HEATERS-
                                            CONDENSER
VT
\  v-
V
                               "A
                               MOISTURE
                               SEPARATOR
   FIGURE 1. TYPICAL COMPONENT LAYOUT IN EARLY BWR TURBINE BUILDING DESIGNS.5

-------
N\l\
                          rr
           n
                    -H
ROOF SLAB LOCATION
WHEN USED
INSIDE PANEL
WHEN USED

                                                              MOISTURE
                                                              SEPARATOR
                                          // // //
                                                            LOW PRESSURE
                                                            FEED WATER
                                                            HEATERS
    FIGURE 2. TYPICAL COMPONENT LAYOUT IN CURRENT BWR TURBINE BUILDING DESIGNS.5

-------
                                                   AIR-SCATTERED
                                            BUILDING
                                              SCATTERED
                                                                           DETECTOR
                                                         DIRECT (EQUIPMENT
                                                         BE.LOW FLOOR)
FIGURE 3. CONTRIBUTIONS TO DOSE RATE FROM N-16 IN TURBINE BUILDING COMPONENTS.

-------
FIGURE 4. TOP VIEW OF TURBINE COMPONENT LAYOUT SHOWING TYPICAL "ACCESS" SHIELD
        DESIGN ALONG WITH VARIOUS SHIELD OPTION.5

-------
                                                                   HEATER fl 3 -°
                                                                          4THPT
                                                                         /HEATER
                                                                                             -MEZZANINE
                                                                                              FLOOR
                                                                                              EL 277'-«"
Figure 5. Transverse sectional view of [line Mile  Point 2 nuclear plant  turbine building,

          showing  shielding of moisture separators  and turbines.^  '

-------
I/)
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            8.0-
            6.0-
           4.0-
           2.0-
           0.0
                                     . MAX
                      MIN
                                      I

                                     200
                                                            I

                                                           400
  100        200        300

COST OF  ADDITIONAL SHIELDING ($  1000)
500
         Figure 6. ANNUAL DOSE AT  500 METERS VS.  COST OF SHIELDING
                           (Turbine  parallel to  boundary)-

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        SUPPLEMENT   E










THE PROPOSED STANDARDS AND THE




NUCLEAR ENERGY CENTER CONCEPT

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            EPA PROPOSED STANDARDS FOR THE URANIUM FUEL CYCLE
                  AND THE NUCLEAR ENERGY CENTER CONCEPT
Introduction

     The Federal Register notice proposing these environmental radiation

standards for the uranium fuel cycle pointed out that "...in view of the

need to accumulate operating experience for the new large individual

facilities now under construction and the intent of the Agency to review

these standards at reasonable intervals in the future, it is considered

premature and unnecessary to predicate the standards on any siting

configurations (e.g., nuclear energy centers) postulated for the next

decade and beyond.  The Agency will consider changes in these standards

based on such considerations when they are needed and justified by

experience..." (1).  The proposed standard does not itself specify

standards for any specific siting configuration, nor is any siting

concept excluded from its applicability.  EPA's conmitment is simply to

reconsider the standard when data is available on vhich to base an

evaluation of the nuclear energy center (NEC) concept.

     A number of commenters on the proposed standards addressed the NEC

concept in somewhat general terms.  They expressed two types of concerns.

The first was expressed by one commenter as follows: ''...however, the

proposed limits may discourage plans for energy parks for the following

decades.  Since the (sic) energy parks may well offer reduced overall

radiation and health effects to the general public (at the expense of

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slightly higher individual exposures) along with possible cost savings


and safeguards improvements, the long range implications of the standards


on the parks should be explictly addressed..." (2).  The second concern


seen is: "By specifically excluding nuclear parks from the standards, EP^


makes utility planning for the design, purchase and construction of


future nuclear power plants difficult" (3).  None of the commenters


provide any quantitative information to support their concerns.





Background


     Only a few studies of nuclear energy centers have been published.


One, titled "Assessment of Energy Parks vs. Dispersed Electric Power


Generating Facilities," and sponsored by the National Science Foundation


(4), did not treat radioactive effluents in enough detail to indicate


whether the proposed standards could or could be met.  That study


referenced "Evaluation of Nuclear Energy Centers" (WASH 1288) on this


matter (5).
                             !

     WASH 1288 provides the most complete treatment of NEC's available to


date, and evaluates two real sites in enough detail to draw some


conclusions (albeit imprecise)  prior to the more detailed studies of the


NEC concept now almost completed by NRC.  Appendix 1 of WASH 1288


provides a discussion of the Hanford reservation in Richland, Washington


as a potential site, which includes an evaluation of potential


radioactive effluents.  The results indicate that 25 reactors and a


reprocessing plant could be sited at Hanford with a radiological impact

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which should be significantly less than permitted by the proposed




standards (6).




     Appendix 2 of WASH 1288 provides a similar treatment of a site at




River Bend, Louisiana, and also estimates an impact less than that




permitted by the proposed standards (7).  It should be noted that VASF




12R8 was written in 1973, and the authors were concerned with meeting the




then proposed Appendix I.  Thus, effluent controls are assumed in the




discussions that will achieve calculated doses in accordance with




proposed Appendix I.




     Appendix 5 of WASH 1288, "Radiological Impact of a Nuclear Center on




the Environment" contains a generic treatment of radioactive effluents by




Soldat.  Based on his evaluation, it appears that the proposed standards




for atmospheric releases would be met if prudent site selection is made




and reasonable levels of effluent control provided.




     One potential problem indicated by Soldat that would require special




attention is liquid releases.  If radionuclides are released from a large




number of reactors into a single body of water, special radwaste or




operating procedures may be necessary, such as onsite receiving ponds.




This would depend on the specific characteristics of the water body for




receiving possibly large quantities of radionuclides (8).




     WASH 1288 does not answer all of the concerns expressed by




commenters on the proposed standards.  Existing analyses are of a scoping




nature and do not address the advantages and disadvantages of NEC's




versus dispersed siting, nor in any detail the impact of other




considerations (thermal and potential accidents, for example), which

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would certainly be appropriate to any decision on standards specifically




designed for NEC's.




     The "Nuclear Energy Center Site Survey" (NECSS) now underway by the




NRC is expected to provide much of the data and analysis necessary to




make a sound decision on the viability of the NEC concept.  A number of




surrogate sites, as well as hypothetical sites, will be analyzed and




various combinations of reactors and fuel cycle facilities will be




considered.  It is EPA's understanding that the NRC staff conducting this




survey has considered these proposed standards and the associated DEIS




during its study of potential NEC's.  An examination of the preliminary




results of the NRC study does not reveal any significant conflicts




between the proposed standards for the uranium fuel cycle and the




feasibility of the NEC concept.  Such a preliminary finding does not, of




course, preclude a later finding, based on a more detailed study, that




some specific provisions may be required in the standards for such sites.








Piscussion




     The task of completely assessing the potential impact of the




proposed standards on NEC's is beyond the scope of this discussion.




However, some of the unique aspects of NEC's that are involved can be




briefly mentioned.




     There are some characteristics of NEC's that will make doses to




members of the public less than might be expected on the basis of




assessments for conventional sites.  The exclusion distance or the




distance to the nearest boundary from such a large group of plants can be




expected to be greater than for smaller numbers of facilities on




conventional sites.  A distance of one to one and one half miles may be

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typical versus the typical one half or less miles for conventional sites.




The sites for NEC's are likely to be quite large (50-75 square miles)




with the plants dispersed over the site in order to minimize effects from




thermal releases to the atmosphere.  NEC sites may_also be relatively




remote.  Economies of scale and shared systems may also make some




effluent control systems available that would not be cost-effective at




conventional sites.




     The dose at the site boundary will not be the multiple of the number




of reactors times the dose from the nearest reactor to the site boundary.




Soldat (8) has calculated that the increase in dose over that due to the




nearest facility (or group) would be a factor of from two to five.  A




scoping calculation carried out by EPA for thyroid doses arrives at a




factor of three.  Of course this would vary depending on actual site




factors and could increase with the addition of other fuel cycle




facilities, such as fuel reprocessing.  However, on a large site one




would expect that such other fuel cycle facilities would be placed well




away from the boundary of the large sites required for NEC's and not




contribute a disproportionate part of the total dose.




     Before definitive conclusions can be drawn, all pathways will have




to be considered on a consistent basis; the sensitivity of doses to a




variety of site factors will require evaluation; the effect of adding




fuel cycle facilities must be quantified; quantification of the total




population dose reduction and related benefits achieved by such sites in




relation to any increased maximum individual dose will be necessary; and

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any benefits that could be achieved through shared effluent control




systems will have to be evaluated.




     Based on the Information now available, the lack of any other




quantitative input from any source to the contrary, and the expectation




of prudent and sound siting decisions, it appears unlikely that nuclear




energy centers would be unable to meet the proposed standards.  However,




EPA will review the entire spectrum of analyses of expected impacts and




benefits that should be provided in part by the NECSS, in part by future




more detailed assessments of specific sites, and in part by experience in




the immediate future with existing facilities, in order to arrive at a




judgment on the appropriateness of these environmental radiation




standards for nuclear power to such possible future siting




configurations. •'

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                               References

1.  Federal Register, 4£, May 29, 1975, p. 23424.

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

3.  Letter, W.D.  Crawford, Edison Electric Institute, to Director,
    Criteria and Standards Division, EPA, July 24, 1975.

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

5.  Evaluation of Nuclear Energy Centers, January 1974, U.S.
    Atomic Energy Commission, WASH 1288.

6.  Ibid., Appendix 1, p. 7.24.

7.  Ibid., Appendix 2, p. 7.67 et. seq.

8.  Ibid., Appendix 5, p. 13.

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             SUPPLEMENT   F










CONTROL OF KRYPTON AND IODINE DISCHARGES




FROM NUCLEAR FUEL REPROCESSING FACILITIES

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                CONTROL OF KRYPTON AND IODINE DISCHARGES
                FROM NUCLEAR FUEL REPROCESSING FACILITIES
I.   Introduction

     Radioactive krypton-85 and iodine-129 discharges from reprocessing

facilities have chemical and physical properties which make their

collection and retention technically difficult.  Krypton is a chemically

inert gas, and iodine is volatile at normal temperatures and pressures,.

It has been the practice to discharge to the atmosphere all of the

krypton-85 present in spent reactor fuel.  Iodine-129 in spent fuel has

been recognized as a potentially significant environmental contaminant,

and efforts have been made in the past to control the discharge of this

species of radioactive iodine.  These efforts were only partially

successful, however, and it has become increasingly apparent that

improved control of long-lived radio-iodine discharges from fuel

reprocessing facilities is necessary (1,2).  Current estimates of the

costs and control efficiencies of a variety of improved control systems

for iodine-129 and the most important options for control of krypton-85

are reviewed below.  The benefits to be gained by reducing the

environmental dose commitments associated with releases of these

materials through installation of such systems are then set forth.

Finally, the level of cost-effectiveness of each of the control options

is determined.

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II.  Source Terms for Iodine and Krypton




     The quantities of iodine-129, iodine-131, and krypton-85 present in




spent fuel have been previously reported, based on calculations using the




computer code ORIGEN (3).  These values, expressed in curies per metric




ton of heavy metal in the fuel, are:




     Kr-85:      10,500 Ci/MTHM




     1-129:         0.4 Ci/MTHM




     1-131:         0.9 Ci/MTHM




for the following fuel parameters, used in this report:




     Burnup = 33,000 MWd/MTHM




     Average Specific Power = 30 MW/MTHM




     Cooling Time = 160 days.




     It is assumed that a light-water-cooled power reactor operates at




33% thermal efficiency, producing approximately 33 MTHM of spent fuel




with this burnup for each gigawatt-year of electric power[GW(e)-yr], and




that a typical fuel reprocessing plant has a throughput capacity of 1500




MTHM per year.  Such a plant would be capable of processing the spent




fuel from about 45 such reactors each year.




     If no iodine or krypton control systems were installed at a 1500 MT




plant, the number of curies discharged annually would be:




     Kr-85:      16,000,000 Ci




     1-129:              60 Ci




     1-131:           1,400 Ci




It is assumed that these contaminants are discharged to the atmosphere,




rather than into liquid pathways, since currently projected plants use

-------
complete recycle of process liquids and thus no liquid discharges are




planned.




     Although the source term for 1-131 could theoretically approach 1400




Ci per year, it is highly unlikely that such quantities will be available




for discharge in actual operations because of its relatively short half-




life (8.08 days).  Even if all spent fuel was process at 160 days cooling




time, any delay of iodine-131 in the various inplant processes or off-gas




streams would permit additional decay and reduce the quantity available




for discharge.  Other factors that would reduce the quantity of iodine-




131 available for discharge include: a) the existing large backlog of




spent fuel, which indicates there is no need, at least in the foreseeable




future, to process fuel that has been cooled for only 160 days, b)




cooling requirements for spent fuel shipping casks may be such that the




fuel cannot be loaded for shipping from the reactor to the reprocessor




until it has cooled for periods greater than 160 days, and c) for those




reprocessing plants using in-line solidification of high level waste,




cooling periods in the range of a few years may be required to permit




sufficient decay of radioactive ruthenium.  Thus, it is considered highly




unlikely that the 1-131 source term at fuel reprocessing will approach




the theoretical maximum value.




III. Control Technologies for Krypton &t_ Reprocessing Plants




     Since krypton is a chemically inert noble gas, it follows the




process off-gas stream in the fuel reprocessing plant and will be




discharged to the atmosphere unless specially designed air-cleaning




systems are used to capture it.  Standard air-cleaning systems based on

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chemical processes are ineffective in collecting noble gases.  Most of




the krypton produced by the fission process in the reactor is released to




the off-gas stream during dissolution of the spent fuel (4,5).  A small




fraction is also released during the shearing operation, but this




fraction is also routed to the main off-gas stream.  Thus, all of the




krypton-85 present in the spent fuel is collected in one stream, along




with other contaminants, such as oxides of nitrogen, hydrocarbons, and




other radioactive materials.




     Two basic systems are in advanced stages of development for the




control of krypton-85; the the cryogenic distillation system and the




selective absorption system.   These are discussed in turn, briefly,




below:




     1.  Cryogenic Distillation




         This process is widely used in industry, where it is better




known as the "liquid air" process and is used to condense and separate




the various gaseous components of air.  Heat is removed from air in the




gaseous form in a closed system until the boiling points of the various




gaseous components are reached.  As the boiling point of each component




is reached, it liquifies and can be separated from the remaining gaseous




components having lower boiling points.  Since krypton has a boiling




point of minus 224 °F and the two major constituents of air, nitrogen and




oxygen, have boiling points of minus 322 °F and minus 297 °F,




respectively, liquifaction and separation of the krypton poses no serious




technical problem.  Several descriptions of applications of such systems




to nuclear power plants are available (6-13).

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         The most serious potential difficulty associated with cryogenic



systems is the possibility of explosions due to a buildup of hydrogen,


                A,
acetylene, hydrocarbons, and oxygen (or ozone) in the system (10).  This



can be avoided by chemically removing all oxygen before the gas stream ia



introduced into the cryogenic apparatus (6).  Thus, in order to use this



process, two additional systems are required: a) a catalytic converter



system to convert oxygen to water and carbon dioxide, followed by, b) a



system for removal of these products.  While this entire system has not



yet been reduced to commercial practice through demonstration in an



operating fuel reprocessing plant, on the basis of existing laboratory



and pilot plant experience it appears feasible for such use and is



expected to be available by 1983 (10).   In addition to determining that



the explosion potential of the cryogenic systems is effectively removed



by precleaning the gas stream following use of a catalytic converter, a



full assessment of the remote operation and maintenance capabilities of



this system must be completed in the interim.



         The cryogenic system itself is expected to exhibit a



decontamination factor (DF) of at least 1000 (6).  However, the overall



efficiency for removal of krypton from the plant is expected to be



somewhat lower because of potential leakage through the system during



startup and shutdown operations, maintenance, etc.  Therefore, an



effective plant DF of between 10 and 100 has been projected for routine


                                                      3
operation of such a system (14).

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         2.  Selective Absorption


             This process was developed at the Oak Ridge National Laboratory


     (ORNL), specifically for the control of krypton-85 at fuel reprocessing


    plants  (15,16).  The process is based on preferential dissolution of


    noble gases in a fluorocarbon sorbent, such as the refrigerant freon-12.


    The off-gas stream is passed through the sorbent in an absorber column at


    a relatively low temperature and high pressure.  Essentially all of the


    krypton and xenon present are dissolved in the sorbent, along with other


    components of the gas stream.  The other components are then removed in a


    fractionating desorption system and, essentially free of krypton and


    xenon, recycled to the off-gas stream.  The sorbent is then transferred


    to a stripper system where a product gas concentrated in krypton and


    xenon is evolved and collected.  The pure sorbent is then regenerated and


    returned to the absorber column.


             The selective absorption process has exhibited a decontamination


    factor greater than 1000 in tests with nitrogen"o^cides and carbon


    dioxide (10).  However, further investigations are expected to be
V

    accomplished to define the relevant auxiliary systems required for


    successful application of the selective absorption process.  An effective


    DF of between 10 and 100 has been conservatively designated for this


    process.  The selective absorption system is free from explosion and fire


    hazards, and can be operated routinely for sustained periods with low


    maintenance requirements.  This system has also not been demonstrated at


    an operating commercial reprocessing plant.  However, it has been offered


    commercially for use on the gaseous effluents from nuclear power

-------
reactors (17).  A recent review concluded that additional testing is




required for this system using off-gas containing significant amounts of




contaminants and estimated that the process could be reduced to practice




by 1983 (10).




     Estimated costs for installation and operation of these two systems




are listed in Table 1.  Cryogenic distillation system costs are based on




industry estimates of equipment costs (18,19) corrected to installed




costs.  Estimated costs for the selective absorption system are based on




ORNL estimates of equipment costs (10).




     In order to satisfy the proposed standards, storage for 40-70 years




would be required, depending upon the degree of initial decontamination




achieved, in order to insure adequate decay.  The management of krypton-




85 following its collection has been addressed by Foster and Pence (20)




and appears to present no serious problems.  They reviewed the advantages




and disadvantages of long-term storage of krypton-85 in high pressure




steel cylinders and concluded that this  appears to be a practical method




for fission-product noble gas storage.  Final storage of krypton-85 could




take place either at the fuel reprocessing facility or at a properly




designed central waste repository.




IV.  Control Technologies for Iodine at  Reprocessing Plants




     The control of iodine at reprocessing plants is a significant




technical challenge (7).  During the last few years a number of promising




systems for control of iodine in gaseous waste streams have been




investigated and most are now in various stages of final demonstration




for commercial use.  The principal remaining problem, as pointed out in

-------
the previous EPA report concerning fuel reprocessing (1), is that, until




recently, inadequate attention has been given to the control of iodine in




low-level liquid waste streams.  Any iodine present in these liquid




streams, whether from off-gas scrubber solutions or from other sources,




can potentially be discharged to the environment because of its high




volatility.  Evaporative processes are used to reduce the volume of these




low-level liquid wastes and to provide for discharge of tritium to the




atmosphere.  Such processes will, of course, also drive off any iodine




present for subsequent discharge to the atmosphere, and systems developed




for removal of iodine from gaseous streams are not, in general,




applicable to evaporator discharges because of their high water content.




     A simplified schematic of waste streams appropriate to the




discussion of iodine control systems for current designs of reprocessing




plants is shown in Figure 1.  Most of the iodine present in spent fuel is




released to the off-gas system during the fuel dissolution and initial




processing steps.  The fraction released to the off-gas has been




estimated at no less than 90% (21).  The balance is collected in liquid




waste streams.  The off-gas system for a specific plant will not




necessarily be designed just as shown in the schematic, since the




detailed design can vary due to the order in which contaminants are




removed.  For example, it may be advantageous to remove the oxides of




nitrogen from the dissolver off-gas stream before dilution by process




off-gas inputs.




     Table 2 summarizes iodine control system capabilities and costs.




The iodine control system DF's assumed are, for the most part, those used

-------
In a recent study of effluent controls for fuel reprocessing by




ORNL (10).  It should he noted that there are differences between the




estimates of systems performance in the ORNL report and those presented




in testimony at a recent licensing hearing for the Barnwell fuel




reprocessing facility (21).  In general, the ORNL analysis predicts




higher DF's for off-gas systems.  For example, the DF's shown on Figure 1




yield an effective overall DF of about 100 for 1-129 and about 500 for




1-131.   Those presented in the Barnwell hearing (21), in contrast, are




approximately 20 for 1-129 and about 40 for 1-131 for the plant overall.




That testimony assumes that the mercuric nitrate scrubber bottoms are




discharged into the low-level liquid stream.  The management of these




scrubber bottoms is the major source of the difference between these




estimates.  It will be necessary to retain the bulk of iodine in the




scrubber bottoms in order to achieve effective control of iodine.




     The difference in control efficiencies for 1-129 and 1-131 shown in




Table 2 for Ag-Z and macroreticular resins are due primarily to the




differences in half-lives of these radionuclides, as discussed in detail




by Davis (22).  This difference is to be expected in any system which




relies upon delay as part or all of its operating .principal".  Thus, it is




essential to both isolate and contain long-lived radionuclides to insure




that they will not eventually re-enter a discharge stream.




     The chemical form or species is an important characteristic of the




iodine when considering cleaning efficiencies, environmental transport,




and iodine dosimetry.  In general, it is believed that iodine evolved




during the dissolution process will be in the elemental form (23).

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However, any iodine discharged to the off-gas system during or following




the separation processes is considered likely to have a large organic




component (24).  The relative fractions of iodine evolved from the




dissolution process step and from the various subsequent separation




processes is not known, nor is the organic component of either fraction




(21).  Estimates of these fractions vary widely (21,25) and these




differences will probably not be resolved until studies are conducted




during actual operations of a large facility (25).   For the purposes of




this analysis it is assumed that 90% of iodine is discharged to the off-




gas system, with the balance going to liquid waste streams (21).   The




fraction of the iodine discharged to the atmosphere following all control




systems is assumed to be about 50% organic and 50% elemental.  Factors




contributing to an expectation of a significant organic component of the




final discharges are:  a) iodine from the low-level liquid pathway has




passed through organic processing steps and thus can be expected to have




a significant organic component, b) iodine in the off-gas stream is




expected to contain a significant organic contribution from separation




processes, and c) most iodine cleaning systems are more efficient in




removing elemental than.organic iodine, and thus selectively allow




passage of organic iodides.




     A brief description of each of the iodine control systems considered




follows:




     1.  Caustic Scrubbers




         Caustic scrubbers are widely used in the chemical industry to




remove contaminants from off-gas streams (26).  They have been used in
                                   10

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the nuclear industry to control both ruthenium and iodine (27).  Tests




have indicated that DF's of 100 and greater for elemental iodine are




attained (27), but DF's are less for organic iodine species.  The



fraction of organic iodine in the primary off-gas stream is not known,



but is predicted to be low (21).  It has been assumed that the organip




fraction is less than 10% and that caustic scrubbers will, therefore,




operate routinely with a removal efficiency of no less than 90%.  Cost




estimates for a caustic scrubber are abstracted from the ORNL work (10).



     2.  Mercuric Nitrate Scrubbers




         Mercuric nitrate-nitric acid scrubbers have been used at the AEC



(now ERDA) reprocessing facilities at Idaho Falls, as well as at a



commercial facility (Nuclear Fuel Services) to control the discharge of




iodine.  While this type of scrubber removes both elemental iodine and




organic iodides, tests have indicated that it is also more efficient in



removing iodine in the elemental form (28).  Based on the predicted



relative fractions of organic iodides present (21), it is assumed to



remove about 90% of all iodine from the off-gas stream (28,29).  Costs



for mercuric nitrate scrubbers are expected to be similar to those for



caustic scrubbers (1).



     3.  Silver Zeolite Adsorbers



         Silver zeolite adsorbers have not been used to treat



reprocessing plant off-gas, but are scheduled to be installed in future



plants.  Most of the development work for this system was conducted at




Idaho National Engineering Laboratories Falls (30).  Silver nitrate is



impregnated into an alumina-silica matrix and the resulting material is
                                   11

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arranged in a relatively deep bed, since a longer residence time of the




iodine in'the adsorber appears to enhance its efficiency.  High removal




efficiencies have been observed for all chemical species of iodine using




this process (30).  Although considerably higher values are reported for




small-scale systems, ORNL assigned a DF of 10 for 1-129 and a DF of 100




for 1-131 for a silver zeolite adsorber, pending the-development of




additional data for plant-scale usage (31,32), and these conservative




values have been assumed here.  The costs, which are abstracted from




previous EPA work (1), are subject to some uncertainty related to the



loading rate of the system and thus the quantities of silver required.




     4.  Macroreticular Resins



         Adsorption of iodine from both neutral and slightly acidic



solutions on macroreticular resins has been shown to be about 99%




efficient in laboratory studies (33).  However, performance of this



system has not been demonstrated in commercial-scale practice and, until



proven under operating conditions, a conservative DF of 10 for 1-129 and



a DF of 100 for 1-131 are assigned.  Costs for this system are estimated




to 'be small (10) .



     5.  Suppression in Evaporator by Mercuric Nitrate




         Mercuric nitrate, when added to liquid evaporators, will




suppress the evolution of iodine into the overheads.  The Barnwell



Facility includes provision (34) for this method of iodine emissions



control from liquid waste streams.  Yarbro has estimated a DF of 2 to 10




ac'ross the final vaporizer for this addition (21).  A conservative value
                                   12

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of 2 is assumed for this analysis.  Costs are estimated to be similar to




those for a macroreticular resin system.




     6.  Advanced Systems




         Figure 2 displays a simplified schematic of an advanced iodine




control system.  The basic principle of this system is to force




essentially all of the iodine into the off-gas system so as to avoid the




difficulty of removing iodine from liquid streams, and then to use highly




efficient systems to remove and retain iodine from the off-gas.  In the




schematic this objective is achieved by using an iodine evolution process




at the dissolver to drive the iodine into the off-gas, and the lodox




system to efficiently remove the iodine from the off-gas.  The




voloxidation step is primarily used for tritium control.  However, a




significant fraction of both the iodine and krypton present in the spent




fuel will also be driven off by this process.  After tritium has been




removed from the voloxidation off-gas, this stream is routed to the




dissolver off-gas stream for subsequent krypton and iodine removal.




         The lodox process itself effectively scrubs both elemental and




organic iodine from off-gas streams with concentrated  (^20M) nitric




acid (23,35).  Laboratory-scale studies have indicated that DF's in




excess of 10,000 for methyl iodine have been obtained in tiulti-staged




bubble-cap columns (24).  The efficiency with which iodine is scrubbed




from off-gas streams with nitric acid is dependent on the oxidizing power




of the concentrated nitric acid, which converts the volatile iodine




species to the nonvolatile HI308 form.  The cost estimates in Table 2 are




abstracted from the ORNL work (10); there is no provision made at this
                                   13

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time for the additional cost of a fractionation/system to permit recovery




of the acid at low concentrations for recycle to the dissolver and lodox




systems.




         The Voloxidation process effectively removes such volatile




fission products as iodine and krypton from sheared fuel, by heating the




fuel to about 550 °C in air or oxygen to release these fission products




by thermal evolution or by oxidation (36,37).  The process equipment




would consist of: a) a rotary kiln to oxidize the fuel, b) a recombiner




to form tritiated water, and c) a drier to collect the water and separate




it from iodine and krypton which then flow to the lodox equipment




(36,37).  Laboratory-scale tests with highly-irradiated sheared fuel show




that up to 75% of the iodine and 45% of the krypton are volatilized.  The




costs shown are based on the ORNL work (10).




     ORNL is currently conducting development work on these advanced




systems.  Cost estimates and projected DF's are abstracted from their




recent summary (10).  ORNL has projected that these systems will be




demonstrated and available for installation in new reprocessing plants by




about 1983.




V.   Cost Evaluations




     Estimated capital costs and annual operating costs for the various




krypton and iodine control systems described are listed in Tables 1 and




2.  For those systems for which only equipment cost estimates were




available, a factor of 1.49 times the equipment cost was applied to




estimate total capital cost.  This factor includes engineering,
                                   14

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construction, installation, quality assurance, miscellanous, contingency




and some interest costs  (10).




     The total annual cost listed in Tables 1 and 2 is the sum of the




annual operating costs and the annualized cost of capital.  An annual




fixed charge rate of 18% was used to calculate annual fixed charges.




This rate is based on the following assumptions:




     Plant  (equipment) lifetime                       20 years




     Capital investiment in bonds                     30%         ,  ^ *? 6~-^  7




     Capital investment in equity                     70%         /.3~-f //.^




     Interest rate on bonds                            5%




     Rate of return on equity (after taxes)           16%




     Local property tax rate                          3.2%




     Annual cost of replacements                      0.35%




     Annual property insurance rate                   0.25%




The annual fixed charge rate was calculated as:




     Return on Investment                  =          12.7%




     Sinking Fund Factor at 10%            =           1.75%




     Miscellaneous                         =           3.8%




     Annual Fixed Charge Rate              =          18.25%




This value is lower than that calculated by ORNL (10), which was based on




a series of earlier cost evaluations (38,39).  A review of these




evaluations indicates that economic conditions have changed sufficiently




to warrant the use of the revised rate caOculated above (41).  In




particular, the debt-equity ratio has significantly increased during the




past decade and equity returns have decreased proportionally thus
                                   15

-------
 producing lower  annual fixed charge rates,  although interest rates on

 bonds  may be higher than the rate used above.   Further,  the investment

 tax credit for pollution control equipment  allows  for  increased benefits

 to the reprocessing  industry which installs the various krypton and

 iodine control systems described in Tables  1 and 2 (41).  Other tax

 advantages that  industry receives by investing in  such systems are fast

 tax writeoffs for depreciation (42),  all incurred  state and local taxes

 (42),  some expense-oriented  outlays such as insurance  (44), and favorable

 treatment for adjustments to the capital basis of  equipment (45) .  These

 tax considerations,  recent trends toward low rates of  return on equity

v(considerably less than 16%) for those industries  that have nuclear

 reprocessing interests, and  their higher leverage  investment status

 (higher debt-equity ratios)  would also tend to reduce  the annual fixed

 charged rate below the 18% rate calculated  above,  which ignores these

 additional factors.   Finally, a discount rate of 10% was used for both

 sinking fund and present worth calculations.

 VI.  Doses and Potential Health Impact Attributable tx? Krypton and Iodine^
     Discharges  from Fuel Reprocessing

     Cumulative  environmental dose commitements to the whole body, lungs,

 and the gonads,  as well as estimated potential health  effects

 attributable to  release of krypton-85 from  a model 1500 MTHM/yr plant are

 given  in Table 3 for a variety of levels of control efficiency.   Plant

 startup in 1983  and a useful lifetime of control equipment of 20 years is

 assumed.   A simple model for krypton transport which assumes immediate

 and uniform dispersion into  the world's atmosphere was used to estimate
                                   16

-------
worldwide doses.  Total doses calculated using this simple model agree




with results from a more detailed multicompartment treatment described by




Machta, Ferber, and Hefter (46,47) within a few percent, although the two




models do differ regarding the regional distribution of doses delivered




immediately following release.  Other parameters, such as population




growth and distribution, dosimetry, and dose-effect relationships, were




handled as described in the previous analysis (1).




     Partial cumulative environmental dose commitments to the thyroid and




estimated potential health effects attributable to discharges of iodine-




129 from a model 1500 MTHM/yr plant were calculated using the specific




activity method (1), and are presented in Table 4.  These values




represent a partial assessment of the total potential dose and health




impact of iodine-129 in that the period of assessment following release




of this extremely long-lived material (17 million years half-life) is




limited to 100 years.  Dose commitments were cumulated for releases over




an assumed control equipment lifetime of 20 years commencing in 1983.




These partial cumulative environmental dose commitments and their




associated health impacts are shown for representative values of overall




plant decontamination factors obtainable using the control methods




described above.  The dose-effect assumptions used were derived from more




recent values (47,49) than those used in the original analysis (1): a




population age weighted value of 60 thyroid cancers per million rems to




thyroid was used.




     Health effects may also result from exposure of local populations




immediately following release of both iodine-131 and iodine-129, in
                                   17

-------
addition to the long-term effects described above.  Using methods




described previously (1) and short term pathway parameters noted below,




it is estimated that uncontrolled release of 1400 Ci/yr of 1-131 could




result in 35 health effects and the release of 60 Ci/yr of iodine-129




could result in 15 health effects over a 20-year period of plant




operation commencing in 1983.  These values should be added to those




listed in Table 4 to obtain a complete estimate of potential health




effects attributable to uncontrolled release of radioactive iodines for




the first 100 years following release.




     In addition to the population doses and impacts calculated above,




maximum potential thyroid doses to individuals may also be significant.




Tables 5 and 6 list calculated maximum individual thyroid doses from




iodine-129 and iodine-131 discharges for a variety of age groups and




release fractions.  The values for iodine-131 were calculated using dose




conversion factors previously described (48).  Dose conversion factors




for iodine-129 were based upon those used for iodine-131, corrected for




differences in pathway and dosimetry dependent upon half-life and




effective energy of decay products (1).  It is assumed that 50% of the




iodine released is in elemental form and 50% is in organic form, and that




X/Q is equal to 5 x 10"8 sec/m3.   Although specific sites could vary




significantly from this assumption, it is expected that site selection




criteria for fuel reprocessing facilities will reflect particular




attention to minimization of the possibility of dose to the thyroid of




nearby individuals.
                                   18

-------
 VII.  Cost-effectiveness  Considerations






     Table 7 displays the estimated cost-effectiveness of risk reduction




of the various options considered for both krypton and iodine control.




The cost-effectiveness of both options for krypton control is high,




compared to that for typical control systems currently in use in the




nuclear power industry, and satisfies the criteria used in judging the




reasonableness of the proposed standards (50).




     Analysis of the options available for control of iodine is




complicated by a) the multitude of alternatives available, and b) the




variability of the current stage of development of the different




processes.  It is clear that iodine evolution and the iodox cleanup




process represent the most effective improvements over the basic cleanup




of gas streams by scrubbers (with or without backup by Ag-Z) and the




cleanup of liquid waste streams by macroreticular resins characteristic




of current design practice.  Unfortunately, reduction to commercial




practice of these systems has not been projected to be completed until




1983.  Thus, for the few facilities projected to go into operation prior




to that date, utilization of less efficient (and, in the case of Ag-Z,




less cost-effective) systems will be necessary.  However, with the




exception of some secondary systems for liquid cleanup (HgN03 suppression




and, in the case of iodine evolution,  macroreticular resin), all of the




options display acceptably high levels of cost-effectiveness.  It should




also be noted that although a second scrubber has apparently greater




cost-effectiveness than does Ag-Z, use of the latter system may be




preferable due to its anticipated higher level of performance for removal




of organic iodines.
                                   19

-------
      Although Table 7 does not display overall plant  decontamination




 factors,  it can be seen from Tables 2, 5,  and 6 that  conformance with the




 proposed  thyroid dose limit of 75 mrem/yr  can be readily achieved through




 use of a  variety of combinations of systems exhibiting DF's of  100 or




 more.   However, conformance with the proposed limit of 5 mCi/GW(e)-yr or




 1.4 kg/yr for iodine-129 (0.225 Ci/yr from a 1500 MTHM facility)  by 1983




 will require a plant DF of no less than 300.  This would be readily




 achieved  by utilization of iodine evolution followed  by the iodox




 process.   Successful achievement of this level of cleanup without use of




 the iodox process will depend to some extent upon future operating




 experience with less sophisticated systems.   Present  estimates  of their




 performance are quite conservative because of a paucity of  operating




 experience, especially regarding their performance with iodine-129.




 However,  it is anticipated and highly probable that DF's greater than 300




 for iodine-129 could be achieved by 1983 using appropriate  combinations




 of scrubbers and Ag-Z, since a variety of  options are available for




 improving, if necessary, the conservative  levels of performance currently




 projected.  These include a) tandem operation of systems, b)  additives,




 such as thiosulfate to caustic scrubbers,  to improve  their  efficiency




 (51) c) use of iodine evolution to reduce  the fraction of iodine in the




 liquid waste stream and increase the efficiency of scrubbers by reducing




 the organic content of the gas streams, and d)  demonstration of more




refficient cleanup of liquid streams than currently assumed.
                                   20

-------
                               REFERENCES

1.   "Environmental Analysis of the Uranium Fuel Cycle, Part III- Nuclear
     Fuel Reprocessing," U.S. Environmental Protection Agency, EPA-520/9-
     73-003-D, October 1973.

2.   Magno, P.J., et. al., "Liquid Waste Effluents from a Nuclear Fuel
     Reprocessing Plant," BRH/NERHL 70-2, November 1970.

3.   Oak Ridge National Laboratory Plants and Waste Management
     Facilities," ORNL-4451, July 1970.

4.   Cochran, J.A., et. al., "An Investigation of Airborne Radioactive
     Effluent from an Operating Nuclear Fuel Reprocessing Plant,"
     BRH/NERHL 70-3, July 1970.

5.   Goode, J.H., "Hot Cell Evaluation of the Release of Tritium and
     Krypton-85 during Processing of ThO - UO Fuels," ORNL-3956, June
     1966.

6.   Davis, J.S., and J.R. Martin, "A Cryogenic Approach to Fuel
     Reprocessing Gaseous Radwaste Treatment," in "Noble Gases," Stanley,
     R.E., and Moghissi, A.A., Editors, U.S. Environmental Protection
     Agency, CONF-730915, Las Vegas, September 1973.

7.   Schmauch, G.E., "Cryogenic Distillation - An Option for Off-Gas
     Treatment," ASME, 74-WA/NE-2.

8.   Feibush, A.M., "Cryogenic Distillation, Separation Process for Power
     Reactor Gaseous Radwaste," Airco/BOC Cryogenic Plants Corp., Murray
     Hill, N.J.

9.   Thrall, G.M. and D.F. Pilmer, "A Cryogenic System for Processing
     Waste Gas From a PWR Generating Station," 19th Annual Meeting of the
     Institute of Environmental Sciences, Anaheim, April 1973.

10.  Finney, B.C., et. al., "Correlation of Radioactive Waste Treatment
     Costs and the Environmental Impact of Waste Effluents in the Nuclear
     Fuel Cycle for Use in Establishing "As Low as Practicable" Guides -
     Nuclear Fuel Reprocessing," ORNL-TM-4901, May 1975.

11.  Bendixsen, C.K., and F.O. German, "Operation of the ICRP Rare Gas
     Recovery Facility at the Idaho Chemical Processing Plant," Idaho
     Nuclear Corp., IN-1221, April 19, 1969.

12.  Bendixsen, C.L. and F.O. German, "Operation of the ICRP Rare Gas
     Recovery Facility During Fiscal Year 1970," Allied Chemical Corp.,
     ICRP-1001, October 1971.
                                   21

-------
13.  Nichols, J.P., and F.T. Binford, "Status of Noble Gas Removal and
     Disposal," ORNL-TM-3515, August 1971.

14.  Buckman, James A., "Second Supplement to the Direct Testimony of
     James A. Buckman," Barnwell Hearings, AEC Docket No. 50-332.

15.  Merriman, J.R. and J.H. P'ashley, "Engineering Development oz an
     Absorption Process for the Concentration and Collection of Krypton
     and Xenon," Union Carbide K-1770, March 1969.

16.  Stephenson, et. al., "Experimental Investigation of the Removal of
     Krypton and Xenon from Contaminated Gas Streams by Selective
     Absorption in Fluorocarbon Solvents," Union Carbide K-1780, August
     1970.

17.  Hogg, R.M., "New Radwaste Retention System," Nuclear Engineering
     Institute 17. (189), 1972.

18.  Personal communication, J.S.  Davis, Union Carbide Corp., Linde Div.,
     to J.L. Russell, U.S. EPA., March 1974.

19.  Personal communication, Dr. A.M. Feibush, Airco Cryoplants Corp., to
     J.L. Russell, U.S. EPA, July 1974.

20.  Foster, B.A. and D.T. Pence,  "An Evaluation of High Pressure Steel
     Cylinders for Fission Product Noble Gas Storage," TID-4500, February
     1975.

21.  Yarbro, O.O., "Supplementary Testimony Regarding the State of
     Technology for and Practicality of Control and Retention of Iodine
     in a Nuclear Fuel Reprocessing Plant," Barnwell Hearings, AEC Docket
     No. 50-332, October 1974.

22.  Davis, W., Jr., "Models for Calculating the Effects of Isotopic
     Exchange, Radioactive Decay,  and of Recycle in Removing Iodine from
     Gas and Liquid Streams," ORNL-5060, September 1975.

23.  Yarbro, O.O., J.C. Mailen, and W.S. Groenier, "Iodine Scrubbing From
     Off-Gas With Concentrated Nitric Acid," 13th AEC Air Cleaning
     Conference, 1974.

24.  Groenier, W.S., "An Engineering Evaluation of the lodix Process:
     Removal of Iodine from Air Using a Nitric Acid Scrubbing in a Packed
     Column," ORNL-TM-4125, August 1973.

25.  Newman, R.I., "Fourth Supplement to Direct Testimony of Robert I.
     Newman," Barnwell Hearings, AEC Docket No. 50-332.
                                   22

-------
26.  U.S. Public Health Service, "Air Pollution Engineering Manual," 999-
     AP-40, 1967.

27.  Staff of the Chemical Technology Division, Aqueous Processing of_
     LMFBR Fuels - Technical Assessment and Experimental Program
     Definition. ORNL-4436, June 1970.

28.  Staff of the Chemical Technology Division, Aqueous Fuel Reprocessing
     Quarterly Report for Period Ending June 30^ 1973, ORNL-TM-4301,
     August 1973.

29.  Staff of the Chemical Technology Division, Aqueous Fuel Reprocessing
     Quarterly Report for Period Ending March 31, 1973, ORNL-TM-4240,
     June 1973.

30.  Pence, D.T., et. al., "Application of Metal Zeolites to Nuclear Fuel
     Reprocessing Plant Off-Gas Treatment," ANS Trans. _15, 1, Las Vegas,
     1972.

31.  Ackley, R.D. and R.J. Davis, "Effect of Extended Exposure to
     Simulated LMFBR Fuel Reprocessing Off-Gas on Radioactive Trapping
     Performance of Sorbates," ORNL-TM-4529.

32.  Allied-Gulf Nuclear Services, Barnwell Nuclear Fuel Plant -
     Environmental Report, Docket No. 50-332, November 1971.

33.  Unger, W.E., et. al., LMFBR Fuel Cycle Studies Progress Report for
     August, November and December 1970, ORNL-TM-3281, ORNL-TM-3127, and
     ORNL-TM-3250.

34.  Allied-General Nuclear Services, Barnwell Nuclear Fuel Plant Final
     Safety Analysis Report. October 1973.

35.  Staff of the Chemical Technology Division, Aqueous Fuel Reprocessing
     Quarterly Report for Period Ending March 31. 1974, ORNL-TM-4587,
     June 1974.

36.  Staff of the Chemical Technology Section, "Voloxidation"Removal of
     Volatile Fission Products from Spent Fuels," ORNL-TM-3723, January
     1973.

37.  Staff of the Chemical Technology Division, "Voloxidation-Removal of
     Volatile Fission Products from Spent LMFBR Fuels," ORNL-TM-3723,
     January 1973.

38.  U.S. Atomic Energy Commission, "Reactor Fuel Cycle Costs for Nuclear
     Power Evaluation," WASH-1099, 1971.
                                   23

-------
39.  Salmon, R., "A Review of Computer Code POWERCO to Include Breakdowns
     of Power Cost and Fixed Charge Rates," ORNL-4116, August 1969.

40.  Stauffer, C.H., "Position Paper on Tax Relief and Other Federal
     Subsidies for Pollution Control Costs," Office of Planning and
     Evaluation, U.S. Environmental Protection Agency, April 3, 1973.

41.  Complete Internal Revenue Code of 1954 (June 1, 1975 Edition)
     Prentice-Hall Inc., Sections 38, 46, 48 (Credit for Investment in
     Certain Depreciable Property).

42.  Complete Internal Revenue Code of 1954 (June 1, 1975 Edition)
     Prentice-Hall Inc., Section 169 (Amortization of Pollution Control
     Facilities).

43.  Complete Internal Revenue Code of 1954 (June 1, 1975 Edition)
     Prentice-Hall Inc., Section 164 (Deductions for Taxes).

44.  Complete Internal Revenue Code of 1954 (June 1, 1975 Edition),
     Prentice-Hall Inc., Section 162 (Trade or Business Expenses).

45.  Complete Internal Revenue Code of 1954 (June 1, 1975 Edition),
     Prentice, Hall Inc., Section 1016(la) (Adjustments of Basis).

46.  Machta, L., Ferber, G.J., and Heffter, J.L., "Regional and Global
     Scale Dispersion of Krypton-85 for Population Dose Calculations," in
     Physical Behavior of Radioactive Contaminants in the Atmosphere,
     International Atomic Energy Agency, Vienna, 1974.

47.  "Krypton-85 in the Atmosphere-Accumulation, Biological Significance,
     and Control Technology," National Council on Radiation Protection
     and Measurements, Report No. 44, July 1975.

48.  "Environmental Analysis of the Uranium Fuel Cycle, Part II - Nuclear
     Power Reactors," U.S. Environmental Protection Agency, EPA-520/9-73-
     003-C, November 1973.

49.  United Nations Scientific Committee on the Effects of Atomic
     Radiations, "Ionizing Radiation: Levels and Effects," Vol. II,
     United Nations Publication E.72.IX.18, New York, 1972.

50.  "Environmental Radiation Protection Requirements for Normal
     Operations of Activities in the Uranium Fuel Cycle," Draft
     Environmental Statement, U.S. Environmental Protection Agency, May
     1975.

51.  Cederberg, G.K. and O.K. MacQueen, "Containment of Iodine-131
     Released by the RALA Process," IDO-14566, October 1961.
                                   24

-------

n—— T-TST = — — — ri?E — ™
1 IIODINE
1 1
1 1
• I IODINE
1 1 STORAGE
1 1
PRODUCT
'SHFAR — ni'J'jm vr — PROCFSS STEPS —

SYSTEM
(T) CAUSTIC
SCRUBBER
(2) MERCURIC
NITRATE SCRUBBER
AgZ
@ MACRORETICULAR
RESIN
© MERCURIC
NITRATE
SUPPRESSION
(*)
	 ^ MACRORETICULAR
RESIN
®
DF ' 	
	 	 LOW LbVbL LIUUIU
10 10o/o * tWVPUKAIOR "
10 OF IODINE
10(1-129) HIGH LEVEL
100(1-131) WASTE OPTION
10(1-129) STORAGE "*~
100(1-131) ,
2. i.. i i i i .ii -
INTERMEDIATE
s LEVEL WASTE
. STORAGE
--•4 STACK
I
t
I
I
I
I
I
I
I
-, I
I I
FINAL
VAPORIZER
-
FIGURE 1. SIMPLIFIED SCHEMATIC OF CURRENT IODINE CONTROL SYSTEMS AT REPROCESSING PLANTS

-------
                                re)

OFF-GAS 99%
r T °F~~
1 IODINE
1
1
1
I
|
TRITIUM
CONTROL
»
! • 
-------
                                 Table 1.   Krypton control  cost summary.
                                                                         a)

Annual
Capital Operating
Process DF Cost (M$) Cost (M$)
1.

2.

Cryogenic 10-100 3.4 0.12 "
Distillation
Selective 10-100 3.9 0.40
Adsorption
Present
Worth
Total at
Annual ized 10% and
Cost (M$) 20 years (M$)
0.73 6.2

1.1 9.4

a)  All costs are expressed in millions of 1974 dollars,

-------
                             Table 2.  Iodine control  cost summary.
Process
1.
2.
3.
4.
5.
6.
A.
B..
Caustic Scrubbing
Mercuric Nitrate
Scrubbing
Silver Zeolite Beds
Adsorption on Macroreticular
Resins
Mercuric Nitrate Suppression
lodox
Vol oxidation5)
Iodine Evolution
DF
10
10
10 (1-129)
10 (1-131)
10 (1-129)
100 (1-131)
2
10,000
4C)
200 C^
Capital
Cost (M$)
0.34
0.31
0.44
0.14
0.14
2.07
2.74
0.75
Annual
Operating
Cost (M$)
0.04
0.12
0.15
0.04
0.04
0.22
0.29
0.08
'Total Present Worth
Annual i zed .@"10%"& 20 years
Cost (M$) (M$)
0.10
0.18
0.13
0.065
0.065
0.59
0.78
0.21
0.82
1.5
2.0
0.56
0.56
5.0
6.6
1.8
a)  All costs are expressed in millions of 1974 dollars'.

b)  This system is not installed, primarily, to facilitate iodine control, and is listed only for
    completeness.

c)  These values do not represent actual DF's, but represent a process efficiency factor. .

-------
        Table 3.   Comulative  environmental  dose  commitment  and  potential  health effects  attributable
                  to  Kr-85  discharges  from  a  1500 MTHM/year reprocessing  plant3)
Source Term (Ci/yr)
1.6 x/107


1.6 x 106


1.6 x 105


DF Exposed Organ
1 whole body
lungs
gonds
10 whole body
lungs
gonads
100 • whole body
lungs
gonads
Dose Commitment (person-kilorems)
150
300
82
15
30
82
1.5
3.0
0.82
Health Effects
60
14
25
total 99
6.0
1.4
2.5
total 9T9~
0.60
0.14
0.25
total 0799"
a)  Dose commitments are displayed  for a  plant  operating  life  of  20 years  beginning  in  1983.

-------
    Table 4.   100-year cumulative  environmental dose commitment and estimated health  effects
              attributable to  release  of  1-129 from a 1500 MTHM/yr-reprocess ing plant. a»b)
Source Term (Ci/yr)
$0
6
1.2
0.6
0.3
.06
DF
1
10
50
100
200
1000
Thyroid Dose Commitment (person-kilorems)
1700
170
34
17
8.6
1.7
Health Effects
100
10
2
1
0.5
0.1
a)  Partial  environmental  dose  commitment  and health effects are-calculated for 100 years following  release
    only and for a plant operating  life of 20 years.

b)  Doses and health effects  do not include  short term, local  impact of either iodine-129 or iodine-131.
    These are estimated to be 15 and 35 health effects, respectively, for  a DF or  1.

-------
      Table  5.   Maximum Individual thyroid doses from 1-129 discharged from a 1500 MTHM/year
                                            reprocessing plant .
DF


1
10
50
100
200
1000
a)
Source Term (Ci/yr)


60
6
1.2
0.6
0.3
0.06

6 month old

1100
110
22
11
5.5
1.1
1-129 Thyroid
4 year old

1600-
160
32
16
8
1.6
Dose (mrem/yr)
14 year old

600
60
12
6
3
0.6
b)
adult

140
14
2.8
1.4
0.7
0.14
a)  The elemental  Iodine fraction is assumed to be 50.
                                                    Q
b)  Atmospheric dispersion coefficient equals 5 x 10 seconds per cubic meter; only the milk pathway is
    considered.

-------
                      Table 6.  Maximum individual  doses  from 1-131 discharged
                                  from a 1500 MTHM/year reprocessing plant.
a)
DF Source Term (Ci/yr)
6 month old
1-129 Thyroid Dose
4 vear-old
(mrem/yr)
14 year old

adult

1 1400 1900
10 140 190
100 14 19
200 7 9.5
500 2.8 3.8
1000 1.4 1.9
10000 0.14 ' 0.19
2300
230
23
12
4.6
2.3
0.23
430
43
4.3
2.2
0.86
0.43
0.043
110
11
1.1
0.54
0.22
0.11
0.011
a) Fuel  cooled for 160 days before processing;  the elemental  iodine fraction is assumed to be 50%.

b)  Atmospheric dispersion coefficient equal  5  x 108  seconds  per cubic meter;  all  pathways.are considered.

-------
Table 7.  Cost effectiveness of krypton and iodine control  system.
System
1 . Krypton

2. Iodine (for off -gas without
iodine evolution)


3. Iodine (for off -gas with
iodine evolution)


4. Iodine (for liquid streams
without iodine evolution)
5. Iodine (.for liquid streams
with evolution)
Cost
Sncrement
Equipment (M$)
(a) Cryogenic
distillation
(b) Selective
absorption
(a) Scrubber (HgN03 )
(b) lodox (no scrubbers)
(c) Second caustic scrubber
(d) Silver zeolite (one
(one scrubber)
(a) Scrubber a)
(b) lodox (no scrubbers)3'
(c) Second scrubber
(d) Silver zeolite
(one scrubber)
(a) Macroreticular resin
(b) Mercuric nitrate suppression
(a) Macroreticular resin
(b) Mercuric nlitrate suppression
6.2
9,4
1.5
5.0
0.82
2.10
3.3
6.8
0.82
2.06
0.56
0.56
0.56
0.56
Health
Effects
Adverted
89-98
89-98
121
135
12
13
135
150
13
14
14
0.75
. Q.68
. 0.038
Cost/Health
Effect (M$/HE)
0.063-0.070
0.096-0.106
0.012
0.037
0.068
0.154
0.024
0.045
0.063
0.143
0.040
0.75
0.82
14.7
a)  Add incremental iodine evolution cost

-------
             SUPPLEMENT   G









TRANSURANIUM EFFLUENTS FROM RE-ENRICHING




  OR REFABRICATING REPROCESSED URANIUM

-------
TRANSURANIUM EFFLUENTS FROM RE-ENRICHING OR REFABRICATING REPROCESSED

                           URANIUM
     Uranium feed material, either to an enrichment plant or to a



fabrication plant, which has been previously used as fuel in a



nuclear power plant may still contain trace amounts of radioactive



impurities after decontamination at fuel reprocessing.



     Spent reactor fuel is typically allowed to decay either at the



reactor plant site or at the chemical reprocessing plant site a



minimum decay time of 150 to 180 days.  The fuel is then dissolved



in nitric acid and processed by solvent extraction



     The UF  product from chemical reprocessing will contain small
           6


quantities of fission products and transuranium isotopes.  Specifications



have been published by the Atomic Energy Commission  ' which indicate



the maximum acceptable limits for radioactivity resulting from these



impurities.  These are:  gross alpha due to transuranium isotopes --



1500 dis/min/(g of U); gross beta due to fission products and



transuranium isotopes -- 10% of the beta activity of aged normal



uranium; and gross gamma due to fission products and transuranium



isotopes -- 20% of the gamma activity of aged normal uranium.



     Such processed uranium may then be sent to the enriching plant.



The above maximum acceptable limit for gross alpha radioactivity can



be translated into the following typical distribution (assuming total

                                                           (2)
solvent extraction plus conversion decontamination factors     for

-------
                             -2-


               3                7                         g
neptunium of 10 , plutonium - 10', and transplutonium - 10 ):


                  2                                           2
neptunium - 9 X 10  alpha dis/min/(g of U), plutonium - 5 X 10  alpha

                                            2
dis/min/(g of U) and transplutonium - 1 X 10  alpha dis/min/ (g of U).



The actual alpha activity distribution will depend on reactor type,



fuel irradiation history, type•of chemical process, and the additional



conversion and purification operations used in converting uranyl



nitrate hexahydrate to UF., but  should not vary significantly from these
                         6


typical values.



     The above beta-gamma radioactivity limits are based on gross



radioactivity measurements related to the background of aged normal



uranium.  The beta activity limit is based on direct measurement of the



beta counting ratio, and therefore depends upon the variation of counting



efficiency with energy.  The gamma specification is based -on a



comparative measurement using aged natural uranium and a high pressure



ion chamber.  A reasonable gamma comparison with natural uranium can



therefore be equated to 20% of the gamma power of aged normal  uranium.



The gamma power of aged normal uranium can be calculated to be 269 MeV/



sec/(g of U), which results in a gamma specification of approximately



54 MeV/sec/(g of U).



     Typical reactor return material has shown the fission product



gamma radioactivity distribution given in Table 1.  Technetium and



uranium beta and uranium and transuranium alpha radioactivity levels

                       i

found are also indicated.

-------
                               -3-

                             TABLE 1

CALCULATED GAMMA RADIOACTIVITY DISTRIBUTION OF FISSION PRODUCTS, GAMMA
AND BETA RADIOACTIVITY OF ALL FISSION PRODUCTS, AND ALPHA RADIOACTIVITY
OF TRANSURANIUM AND URANIUM ISOTOPESa(2)
Isotope
of Gamma
Ru-106

Zr-95-Nb-95

Cs-137

Ce-144
 75

 22

  1

  1
Other fission products   1



Tc-99

 U-237



              c
Transneptunium

Np-237

 U-232

 U-233

 U-234

 U-235

 U-236

 U-238
Typical distribution
      based on
gamma specification
  (Y MeV/sec/g U)
Radioactivity
  (Ci/g U)
                                                 Y Radioactivity
         40.0

         12.0

          0.054

          0.054

          0.054
42.2 X 10
                                                                      -10
 9.3 X 10
^6.9 X 10
         -10
^6.9 X 10
         -11
         -11
                                      ^6.9 X 10
                                                                      -11
                            Radioactivity
                                       3.16 X 10

                                       2.41 X 10

                          a Radioactivity

                                       2.43 X 10

                                       4.32 X 10

                                       9.01 X 10

                                       4.70 X 10

                                       7.59 X 10

                                       1.71 X 10

                                       2.88 X 10

                                       3.14 X 10
                                                -8
                                   -6
                                   -10
                                   -10
                                   -9
                                   -11
                                   -7
                                   -8
                                   -7
                                   -7
            reactor returns are based on an initial feed of 3.2% U-235,
specific power 30 MW/metric ton uranium, exposure 33,000 MW day/metric
ton, decay 180 days.

      These fission products consist principally of Sr, Sb, Sn, and Te.
     cPu-238, Pu-239, Pu-240, Pu-241, Pu-242, Am-241, Cm-242, Cm-244

-------
                             -4-



     These radioactivities can be used to determine the annual



inputs and system equilibrium concentrations at an enrichment plant



(Table 2).  The technetium-99 beta will contribute the remaining



beta radioactivity and is also included.  Plutonium and neptunium



concentrations are based on the above specifications for transuranium



isotopes in the reactor return material.



     Gaseous diffusion operating experience, although of almost 30



years duration, has been very limited in terms of large throughputs



of power reactor returns.  Although there has been considerable produc-



tion reactor material returned to the cascade, irradiation exposure



of that material has been ten- to twenty-fold less than that for power


                                                          (2)
reactors.  Experience to date has indicated the following:



     1.  A significant quantity of all non-uranium radioactivity



(neptunium, plutonium, and fission products) is retained in the



feed cylinder  (UFg tank) and will be removed when and where the



returned cylinder is washed.



     2.  PuF, and NpF, are easily reduced and therefore removed by



trapping with CoF-  MgF~, NaF, Cryolite, etc.



     3.  Fission product removal (except technetium) by these traps may



also be significant.  However, good data based on low-level radio-



activity feed materials have not been obtained.



     4.  Technetium, compared to other fission or alpha emission



products, is less likely to be removed by any process.  Experience at



ORGDP* indicates that technetium release to the environment would be



10% of feed to the liquid effluent and 1% of feed to the gaseous



effluent.



*0ak Ridge Gaseous Diffusion Plant

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                             TABLE 2

     CALCULATED FISSION PRODUCT AND TRANSURANIUM ISOTOPE*
    ANNUAL INPUTS AND EQUILIBRIUM SYSTEM6 CONCENTRATIONS
                         Annual Input               Equilibrium System
   Isotope                (Ci/year)                      burden
                                                          (Ci)
   Ru-106                     9.3                        13.5

   Zr-95-Nb-95                2.0                         0.5

   Cs-137                     0.16                           (
                                                   0.16 fl-e
                                                            0.0266

   Ce-144                     0.16                        0.17
                                                            _c
   Other fission products     0.16                        0.7

   Tc-99 (g only)          -70.0                        70.0Td

   Np-237                     0.9                         -0.9Td

   Transneptunium  -           0.5                         0.5T



   aBased on fuel specifications of Table 1.

    Not an equilibrium condition since Cs-137 has a 26-year half-life
and true equilibrium would only be approached in 130 years.  Therefore,
activity depends on time, T (years of operation).

   °Assuming an average effective half-life of 3 years.

   "Very long half-life, never reaches equilibrium.

   e8.75 MSWU

-------
                             -6-




     5.  Experience also indicates that other fission products and



alpha radioactivity release fractions should be no more than one tenth




of that for technetium.  Measurements of gaseous and liquid effluents



have failed to identify any other fission products.  However release



fractions of 1% to the liquid effluent and 0.1% to the gaseous



effluent for other fission products will be used below to estimate




environmental releases.



     6.  Cobaltous fluoride traps exhibit decontamination factors of




400 for neptunium and 10  for plutonium prior to feeding to the



cascade or conversion facility.  Releases for the system after



trapping can then be proportioned to those exhibited for uranium in




ORGDP release data.  Thus, alpha release fractions will be 4 X 10



to the liquid and 2 X 10~  to the gaseous effluents for neptunium




and 1.6 X 10"  to the liquid and 8.0 X 10"10 to the gaseous effluents



for plutonium.



     7.  A large portion of the radioactivity entering a settling pond



will be entrained in the sludge of the pond.



     Releases to the environment can occur in three physical states



(gas, liquid, and solid).  The bulk of the radioactivity will be



released as solids, either entrained on adsorbate or equipment



removed from service for disposal.  Liquid waste will be generated



by rinsing (decontamination) of recycled equipment.  The first rinse



solution, which contains the bulk of the radioactivity, are saved to



be used as the dilute acid wash solution.  Subsequent rinses are sent




to the primary holding pond.

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                             -7-

     Gaseous wastes can result from purge system venting, venting of

evaporator overheads at the uranium recovery facility, and venting of

decontamination hoods in the recycle facility.  However, the exact

breakdown for retention and release factors for each step is not known.

One can only make assumptions based on experience with gaseous diffusion.

The limited experience available was used to arrive at the following

estimates (see Table 3) about gaseous, liquid, and solid discharges

for non-uranium radioactivity.^ J


                           TABLE 3

ASSUMED DISTRIBUTION OF FISSION PRODUCTS AND TRANSURANIUM ISOTOPES
   TO ATMOSPHERE, PRIMARY HOLDING POND, AND BURIAL GROUND
Fraction released •
Isotope
Np-237
Other Transuranium
Tc-99
Fission Products
Fraction released
to atmosphere
2 X 10~
8 X ICf10
0.01
0.001
to primary
holding pond
4 X 10"6
1.6 X 10"8
0.10
0.01
Fraction input
to burial ground
VI. 0
M.O
0.89
0.989

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                             -8-



     Primary enrichment plant sources of gaseous radioactive wastes


are the product and waste purge systems.  Uranium particulates are



removed from these process streams by the high-efficiency-particulate


absolute (HEPA) filter, which has an efficiency greater than 99.95%.


Removal of gaseous uranium is achieved through the use of two chemical


traps in the product and waste withdrawal systems, in series, between


the cold trap and point of discharge into the air.


     The first trap contains sodium fluoride that provides for the


adsorption of uranium and certain fission or alpha emitting products.


Through heating and proper valving, the trapped uranium may be


desorbed and subsequently returned to the cascade.  The second trap


in the series contains alumina that is used for further removal of


uranium prior to discharbe of the gas stream to the atmosphere.  This


trap is nonreversible and uranium recovery is accomplished by leaching


with nitric acid.


     The fraction of the feed made up of reactor returns is passed

                                                                    (2)
through cobaltous fluoride traps prior to being fed into the cascade   ;


the traps remove plutonium, neptumium, and a major fraction of the


fission products.  These products are removed from the gas stream


by-reduction with Cof^ to the tetraflouride forms that, being particulates,


are entrained within the traps.


     Quantification of potential gaseous effluents is difficult because


of uncertainties about the behavior of certain fission products in


feed cylinders, traps, piping, and equipment.  In attempting to analyze

-------
                              -9-



possible  releases  to  the  environment, all assumptions, where necessary,



have been made  so  as  to overestimate the magnitude of the source term.



Uranium and  technetium releases were estimated by comparison with



operating experience  and  extrapolated to higher operating levels.



Fission product releases  were based on current fission product



specifications, with  releases being assumed proportional to that of


technetium,  with the  exception that a decontamination factor  (DF)  and/or



retention factor 10 times that for technetium was assumed.  This



assumption is very conservative,  since current experimental, investigations

                                                                 (2)
indicate  that the  actual  factor might be as high as  100 to 1000.



Releases  of  the alpha emitters, neptunium and plutonium, were estimated by



assuming  an  alpha  specification of 1500 dis/min/Cg of U) in reactor  returns,

                                                   5
with a neptunium DF of 400 and a  plutonium DF of 10  through Cop2  traps.



Once fed  into the  cascade,  neptunium and plutonium are assumed  to  be



released  to  the environment in the same proportions  as uranium.



     The  estimated constituents of an effluent under the above  assumptions



are  listed in Table 4.



     It may be  concluded that recycled uranium which has been re-enriched


will present no particular problem at the fabrication plant because most


of the impurities of higher isotopes  have been taken out in the enriching



process,  and could not make a significant contribution to  an industry


limit of 0.5  mCi/GW(e) for alpha-emitting transuranics of  half-life


greater than  one year.

-------
                             -10-
                           TABLE 4

     ESTIMATED RADIOACTIVITY RELEASED TO THE ATMOSPHERE FROM
                    AN ENRICHMENT PLANTd
     (Transuranic alpha specification = 1,500 dis/min/g U)
            Isotope                          Radioactivity
                                             (Ci/year)/Gw(e)

              U-232                          2.75 X 10"8
                                                      -10
              U-233                          1.5  X 10

              U-234                          3.25 X 10~5

              U-235                          1.25 X 10"6

              U-236                          0.92 X 10"6

              U-238                          5.3  X 10"6

              Transneptunium                 3.3  X 10~
                    c                                 -10 .
              Np-237                         1.7 X  10

              Tc-99                          4.5 X  10"4

              Ru-106                         6.0 X  10~6

              Zr-95-Nb-95                    1.25 X lo"6

              Cs-137                         0.92 X 10"7

              Ce-144                         0.92 X 10".

              Other fission products         0.92 X 10
     aRelative to Tc-99, the retention of all fission
products in equipment or traps is greater by a factor of 10.

      Cobaltous fluoride trap decontamination factor for
Pu-239 = 10 .

     cCobaltous fluoride trap decontamination factor for
Np-237 = 400.

     d8.75 MSWU Plant

-------
                             -11-

     If, however, recycled material goes directly from reprocessing

to fabrication, cleanup systems will have to be designed and installed

to collect the impurities as the material is converted from UFg to

UCL for blending and/or pelletizing.  These systems should have

efficiencies and decontamination factors similar to those described

above for the enrichment plant.  They would, therefore, be expected

to also reduce transuranium isotopes in the U0_ to levels resulting in

negligible releases compared to the proposed standard of 0.5 mCi/GW(e).



                         REFERENCES

(1) 32 FR 16289, November 29, 1967.

(2) "Environmental Statement - Expansion of U.S. Uranium Enrichment
    Capacity," U.S. Energy Research and Development Administration,
    DRAFT ERDA-1543, June 1975.

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                 SUPPLEMENT   H









ENVIRONMENTAL ANALYSIS OF THE URANIUM FUEL CYCLE,




PART I (FUEL SUPPLY):  URANIUM MILLING - REVISED

-------
                                 CONTENTS



                                                                   Page

 1.0  Introduction	    1

 2.0  General Description of the Milling Process	    2

 3.0  Releases of Radioactive Effluent from Uranium Mills	    6

      3.1  Airborne Releases	    6
      3.2  Waterborne Releases	    9

 4.0  The Model Uranium Mill	   15

 5.0  Radioactive Effluents from a Model Uranium Mill	   17

 6.0  Radiological Impact of a Model Mill	   20

 7.0  Health Effects Impact of a Model Mill	   23

 8.0  Control Technology for Uranium Milling	   24
   i
      8.1  Airborne Effluent Control Technology                     24
      8.2  Waterborne Effluent Control Technology and Solid  Waste
           Control Technology	   2&

 9.0  Effluent Control Technology for the Model Mill	   31

10.0  Retrofitting Control Technology to Operating Uranium Mill...   33

References	   34

                                  TABLES

 Section 2

 2.0-1  Uranium Mills in Operation as of March 1975	    3

 Section 3

 3.1-1  Predicted Airborne Releases of Radioactive Materials from
        the Highland Uranium Mill	    8

 3.2-1  Concentrations of Radioactive Effluents in Waste Liquor
        from the Highland Uranium Mill	   10

 3.2-2  Estimates of Quantities of Radionuclides Seeping Through
        the Impoundment Dam of a Uranium Mill Initially and  at
        2-1/4 Years	   12

-------
                          CONTENTS (CONTINUED)

                                                                 Page

3.2-3  Analysis of Plant Tailings Effluents from the Humeca
       Uranium Mill (Alkaline Leach Process)	  14

Section 5

5.0-1  Discharge of Radionuclides to the Air from Model Uranium
       Mills and Tailings Piles with Base Case Controls	  18

Section 6
_        •                                       t

6.0-1  Radiation Doses to Individuals Due to Inhalation in the
       Vicinity of a Model Mill with Base Case Controls	  21

6.0-2  Collective Dose to the General Population in the Vicinity
       of a Model Mill with Base Case Controls	  22

Section 8

8.1-1  Cost and Efficiencies of Control Technology for Mills....  26

Section 9

9.0-1  Radiological Impact of Airborne Effluents versus Control
       Costs for a Model Uranium Mill	  32
                                   ii

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1.0  Introduction




     The EPA recently completed a technical review (1) of the




uranium milling industry as part of an overall analysis of the




uranium fuel cycle (2) (3).  This review included a description of




the milling process, estimations of radioactive effluent releases,




radiological impact, health effects impact, and the costs and




effectiveness of control technologies for mills.  An analysis of




the tailings piles associated with mills was also included.  This




review was prepared in support of EPA's proposed standards for the




nuclear fuel cycle, 40 CFR Part 190 (4_).




     Since publication in 1973, considerable new information on the




uranium milling industry has become available (JL»Ji»Z».§)» ^n Particular,




the engineering survey report (j6), "Correlation of Radioactive Waste




Treatment Costs and the Environmental Impact of Waste Effluents in




the Nuclear Fuel Cycle for Use in Establishing 'as Low as Practicable'




Guides - Milling of Uranium Ores," has been prepared by Oak Ridge National




Laboratory for the Nuclear Regulatory Commission (NRC).  This report con-




tains an extensive review of the costs and the effectiveness of various




control technology systems for uranium mills and mill tailings piles.




     The EPA believes it to be worthwhile to revise its previous




technical review of the milling industry, taking into account these




new sources of information.  Because radon-222 releases from fuel




cycle facilities have been specifically excluded from EPA's proposed




standard, analysis of radon-222 releases from uranium mills and




uranium mill tailings piles has been omitted from this document.




Rador-222 will be the subject of separate regulatory actions at a




later date.



                                 1

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2.0  General Description of the Milling Process



     A uranium mill extracts uranium from ore.  The product is a



semi-refined uranium compound (UQ00) called "yellowcake" which is
                                J O


the feed material for the production of uranium hexafluoride  (UFg).



As of March 1975, seventeen mills (_7_) were operating in the United

       x_,


States (table 2.0-1) with nominal capacities ranging from 250 to

          \


7,000 tons of ore per day.  These mills are characteristically



located in arid, isolated regions of the west.  Areas with significant




high grade ore reserves are (6):  Wyoming, 55 million tons; New Mexico,



50 million tons; Texas, 11 million tons; Colorado - Utah, 6 million



tons; all other areas combined, 7 million tons.



     Eighty percent of yellowcake is currently produced by a process



that uses sulfuric acid to leach the uranium out of the ore; the remainder



is produced by a sodium carbonate, alkali leach process.  Exact details



vary from mill to mill, but, as an example, the principal steps in an



acid leach process mill are as follows:



     a.  Ore is blended and crushed to pass through a 2.5 cm  (1 inch)



screen.  The crushed ore is then wet ground in a rod or ball mill



and is transferred as a slurry to leaching tanks.



     b.  The ore is contacted with sulfuric acid solution and an



oxidizing reagent to leach uranium from the ore.  The product liquor



is pumped to the solvent-extraction circuit while the washed residues



(tailings) are sent to the tailings pond or pile.



     c.  Solvent extraction or ion exchange is used to purify and



concentrate the uranium.

-------
                                             Table 2.0-1 (7)

                               URANIUM MILLS IN OPERATION AS  OF MARCH 1975
      COMPANY
         LOCATION
YEAR OPERATIONS
   INITIATED
NOMINAL CAPACITY
(Tons of Ore/Day)
Anaconda Company

Atlas Corporation

Conoco & Pioneer
Nuclear, Inc.

Cotter Corporation

Dawn Mining Company

Exxon, U.S.A.

Federal-American
Partners

Kerr-McGee Nuclear

Petrotomics Company

Rio Algom Corp.

Union Carbide Corp.

Union Carbide Corp.
Grants, New Mexico

Moab, Urah

Falls City, Texas


Canon City, Colorado

Ford, Washington

Powder River Basin, Wyoming

Gas Hills, Wyoming


Grants, New Mexico

Shirley Basin, Wyoming

La Sal, Utah

Uravan, Colorado

Natrona County, Wyoming
     1953

     1956

     1961


     1958

     1957

     1971

     1959


     1958

     1962

     1972

     1950

     1960
       3000

     800-1500

     220-1750


     150-450

       0-400

       2000

     500-950


    3600-7000

     525-1500

        500

       0-1300

       1000

-------
                                         Table 2.0-1 (Continued)
      COMPANY
          LOCATION
YEAR OPERATIONS
   INITIATED
NOMINAL CAPACITY
(Tons of Ore/Day)
United Nuclear-
Homestake Partners

Utah International,
Inc.

Utah International,
Inc.

Western Nuclear, Inc.

TVA (Mines Develop-
ment ,  Inc.)
 Grants,  New Mexico
 Gas Hills,  Wyoming
 Shirley Basin, Wyoming
 Jeffrey City,x^yoming

 Edgemont,  South Dakota
v.
 \
     1958


     1958


     1971


     1957

     1956
    1650-3500


     750-1200


       1200


     400-1200

     250-500

-------
     d.  The uranium is precipitated with ammonia and transferred




as a slurry.




     e.  Thickening and centifuging are used to separate the




uranium concentrate from residual liquids.




     f.  The concentrate is dried at 400°F and is sometimes




calcinated at 750 to 950°F.




     g.  The concentrate or yellowcake is packaged in 208 liter




(55 gallon) drums for shipment.




     Large amounts of solid waste tailings remain following the




removal of the uranium from the ore.  A typical mill may generate




1,800 metric tons per day of tailings solids slurried in 2,500




metric tons of waste milling solutions.  Over the lifetime of the




mill, 100 to 200 acres may permanently be committed to store this




material.  These "tailings piles" will have a radiological impact




on the environment through the air pathway by continuous discharge




of radon-222 gas (a daughter of radium-226), through gamma rays given




off by radium-226, radon-222 and daughters as they undergo radioactive




decay, and finally through air and water pathways if radium-226 and




thorium-230 are blown off the pile by wind or are leached from the pile




into surface waters.

-------
3.0  Releases of Radioactive Effluent from Uranium Mills




     The radioactivity associated with uranium mill effluents comes




from the natural uranium and its daughter products present in the




ore.  During the milling process, the bulk of the natural uranium




is separated and concentrated, while most of the radioactive daughter




products of uranium remain in the uranium-depleted solid residues that




are pumped to the tailings retention system.  Liquid and solid wastes




from the milling operation will contain low level concentrations of




these radioactive materials, and airborne radioactive releases include




radon gas and particles of the ore and the product uranium oxide.




External gamma radiation levels associated with uranium milling




processes are low, rarely exceeding a few mrem/hr even at surfaces




of process vessels.




3.1  Airborne Releases




     Airborne releases from uranium milling operations include both




particulate matter and gases.  Dusts containing uranium and uranium




daughter products (thorium-230 and radium-226) are released from ore




piled outside the mill.  Dusts containing uranium and uranium daughter




products are released from the ore crushing and grinding ventilation




system, while a dust containing mostly uranium without daughters is




released from the yellowcake drying and packaging operations.  These




dusts are discharged to the atmosphere by means of low stacks.




     Because uranium is discharged to the air pathway as ore dust




and as calcinated yellowcake, it will be considered as an insoluble




aerosol.  Radium-226 and thorium-230 discharged as ore dust will also

-------
be  considered  insoluble aerosols.




     The air flow through a typical crushing and grinding ventilation




system is about 27,000 cfm; that through the yellowcake drying and




packaging ventilation system is about 6,000 cfm.  Because of the




different air  flows, dust characteristics, and locations within the.




plant, separate air cleaning equipment systems are usually required;




a mill is therefore usually considered to have two separate airborne




effluent release streams, each with its own control systems, costs,




and source terms.




     Radon gas is released from the leach tank vents,  ore piles,




tailings retention system, and the ore crushing and grinding ventila-




tion system.  There is no practical method presently identifiable




that will prevent the release of radon gas from uranium mills.




     As an example, table 3.1-1 gives the estimated maximum release




rates and conservative estimates of site boundary concentrations




considering all potential sources of airborne dust fumes and mists




as predicted for the Highland Uranium Mill in Wyoming (9_,10) .   The




capacity of the Highland Mill is about 1,200 MT/yr of yellowcake.




     Toward the end of the operating lifetime of a tailings retention




system, some of the tailings will no longer be under water and will




dry out to form a beach (6) .  Wind erosion can then carry off tailings




material as airborne particulate matter unless control measures are




taken to prevent such erosion.

-------
00
                                                 -Table 3.1-1 (1,10)

             Predicted  airborne  releases of  radioactive materials  from  the  Highland  Uranium Mill
Release rate Site boundary A a
Radionuclide

Uranium-natural
Thorium-230
(insoluble)
Radium-226 -
(insoluble)
(Ci/yr)
•»
0.1
.06


.06
4
Air concentration
(pCi/m3)
0.003
.001


.001
Site boundary B
Air concentration
(pCi/m3)
0.0004
.0001


.0001
                  aDistance  to site  boundary  A  assumed  to  be  800  m (2,600 ft)  west of mill.
                   Distance  to site  boundary  B  assumed  to  be  5,200 m (12,700 ft)  east of mill.

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 3.2  Waterborne Releases




     The following discussion refers to the best of current procedures




 of handling mill liquid wastes,in which these wastes plus tailings




 are stored in a tailings retention pond system which uses an




 impervious clay-cored earth dam combined with local topographic features




 of the area to form an impoundment.




     The liquid effluenc from an acid-leach process mill consists




 of waste solutions from the leaching, grinding, extraction and washing




 circuits of the mill.  These solutions, which have an initial pH of




 1.5 to 2, contain the unreacted portion of the sulfuric acid used




 as the leaching agent in the mill process, sulfates, and some




 silica as the primary dissolved solids, along with trace quantities of




 soluble metals and organic solvents.  This liquid is discharged with




 the solids into the tailings pond.




     Concentrations of radioactive materials predicted in the 2,500




 MT/day of waste liquor from the Highland milling plant are shown in




 table 3.2-1 (9_, 10) .  Radioactive products of radon decay may also be




present in small concentrations.  Since the concentrations of radium-226




and thorium-230 are about an order of magnitude above the specified




 limits to 10 CFR 20, considerable effort must be exerted to prevent any




release  of this material from the site.  The waste liquor is, therefore,




 stored in the tailings retention pond which is constructed to prevent




 discharge into the surface water system and to minimize percolation




 into the ground.  This is a continuing potential problem requiring




monitoring programs to insure that there is no significant movement




of contaminated liquids into the environment.

-------
                   Table 3.2-1


    Concentrations of radioactive effluents in

waste liauor from the Highland uranium mill (9.,1_0)
                            Concentration
       Radionuclide            (pCi/1)
     Uranium-natural            800a

     Radium-226                 350

     Thorium-230             22,000
     aAbout 0.001 g/ml.
                         10

-------
     If an earth-fill, clay-cored dam retention system serves as




a collection and storage system for the liquid and solid process




wastes generated in the mill, it will permit the evaporation of most




of the contained waste liquids and serve as a permanent receptacle




for the residual solid tailings.  However, after the initial




construction of the retention system, it is to be expected that




there will be some seepage of radionuclides through and around the




dam (9_,_10_) and downward into the soil beneath the impoundment area.




It has been estimated that this seepage will diminish over a period




of about 2 years because of the sealing effect from accumulation




of finer particles between the sandstone grains.  On the other hand,




sealing may not occur.  Examples of the total quantities of radionuclides




that are estimated to be released through and around the dam are shown




in table 3.2-2.  Radium-226 is a radionuclide of concern in this case.




Radium-226 levels as high as 32 pCi/1 (11) have been found in seepage




from current operating mills.  Assuming a seepage rate of 300 liters




per minute, the concentration of radium-226 seeping into a stream of




140 liters per second (5 cubic feet per second) is approximately 1 pCi/1




which is 1/5 of EPA's proposed interim Primary Drinking Water Regulation




for radium-226 (12).  In the applicant's environmental report for the




Highland Uranium Mill (9_,10) , a seepage concentration of 350 pCi/1




radium-226 was assumed, bringing the concentration of radium in such an




offsite stream up to 12 pCi/1.  The Highland Uranium Mill is also esti-




mated to release to the tailings pond 22,000 pCi/1 thorium-230 and trace




quantities of short-lived radon daughter products.
                                11

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                             Table 3.2-2

    Estimates of quantities of radionuclides seeping through the

impoundment dam of a uranium mill initially and at 2-1/4 years (9.,JO_)



                        Initial seepage              Seepage per day(a'
Radionuclide                per day                  after 2-1/4 years


Uranium                     350 yCi                  35 yCi to 3.5 yCi


Thorium-230               9,600 yCi                 960 yCi to 96 yCi


Radium-226                  150 yCi                  15 yCi to 1.5 yCi



     U)$eepage assumed to be inhibited due to seal ings effect from
accumulation of fines between sandstone grains.
                                  12

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     As an additional example, the analysis of plant tailings




effluents for the Humeca Uranium Mill, which uses an alkaline lead




process, is given in table 3.2-3 (13).




     The radiological significance of seepage from tailings ponds




will depend on the location of the pond.  In arid regions, the




seepage may evaporate before leaving the site, leaving the radio-




activity entrained and absorbed on soil.  Should the tailings pond




be located near a river, minor leakage might be diluted sufficiently




by the additional river water to meet relevant drinking water standards.




Discharge of pond seepage into streams providing insufficient dilution




and not under the control of the licensee would not be acceptable.  In




such cases,  a secondary dam may be built below the primary dam to




catch the seepage which may then be pumped back into the tailings ponds.
                                13

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          Table 3.2-3  (13.)

Analysis of plant tailings  effluents
   from the Humeca Uranium Mill
     (alkaline leach process)

   Radionuclide           pCi/1

 Radium-226         10 to 2,000
 Thorium-230            0.1
 Uram'um-238              4,000
              14

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4.0  The Model Uranium Mill




     A model plant has been assumed in order to achieve a common




base for the comparison of radiation doses, committed health effects,




and radioactive effluent control technology.




     The model mill is defined in terms of contribution to the




nuclear fuel cycle that is consistent with current designing and




projected commercial industry practice (6).  However, it is not




necessarily representative of presently operating facilities.




Characteristics of the model mill are assumed to be:




     a.  600,000 MT ore milled per year,




     b.  1,140 MT U-jOg as yellowcake produced per year,




     c.  use of the acid leach process,




     d.  a tailings retention pond system which uses a clay-core earth




dam and local topographic features of the area to form the* impoundment,



     e.  collection and return of any seepage through the dam to the




tailings pond, and




     f.  location in a western State in an arid, low-populated density




region.




     While Reference 1 considered the radiological impact of seepage




through a model clay core impoundment dam, it is now believed to be




standard practice (6) to collect and return any such seepage to the




tailings pond so that there are no routine liquid discharges of radio-




nuclides to water pathways from mills.  The cost of a seepage control
                                 15

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system is nominal compared to the cost of the tailings impoundment




system itself.




     Radiation dose rates and health effects that might result from




the discharges of airborne radioactive effluents from the model mill




were calculated using standard x/Q values, dose conversion factors, •




model pathways, and health effect conversion factors that are similar




to those for other facilities in the previous discussion of the fuel




supply cycle.  These factors and assumptions are discussed in Appendix




A of Reference 1.




     The operating lifetime of a uranium mill is commonly from 12




to 15 years, depending upon the local ore supply and the demand for




uranium.  In a few instances, the operating lifetime may be longer,




and allowances are sometimes made for that possibility if it appears




feasible.  For the model mill, an operating lifetime of 20 years has




been selected.
                                 16

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5.0  Radioactive Effluents from a Model Uranium Mill




     Because regulations have not required uranium mills to report




the total amounts of each radionuclide discharged per year, the




source terms chosen for model mills are based on somewhat limited




operational information (6).  Source terms listed in table 5.0-1




for model mills are believed, however, to be reasonably accurate




estimates of the quantities of radioactive materials discharged to




air pathways with base case controls.  The controls assumed as the




base case consist of an orifice scrubber on the crusher and fine ore




bins, and a wet impingement scrubber in the yellowcake drying and




packaging areas.  The milling procedures are so similar for acid and




alkaline leach processes that source terms for the two types of mills




are considered identical, except that the alkaline leach process does




not remove thorium from the ore so that, in this case, there is very




little thorium-230 as an impurity in the yellowcake dust.




     The model mill is also assumed to use clay-core dam impoundment




technology for tailings with a catch basin if required to contain




seepage through the dam.  Unless the impoundment area is lined with an




impervious material, considerable quantities (as much as 10 percent)




of the liquid effluent from the mill will leak out through the bottom




of the pond.  However, because of the ion-exchange properties of most




soils, radionuclides dissolved in this effluent will attach to soil




particles and will not reach offsite locations or ground water.  The




model mill is considered, therefore, to deliver no radiation exposure




to members of the general population through liquid pathways.
                                 17

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                                                     Table 5.0-1

              Discharge of Radionuclides to the Air from Model Uranium Millsa' and Tailings Piles  (6_)

                                               With Base Case Controls
              Radionuclide
                              Chemical or
                            Physical State
                           Acid Leach Hill
                                   i
                             Source Term
                               (mCi/yr)
                  Alkaline Leach" Mill
                      Source Term
                        (mCi/yr)
00
Uranium-238 and 234

Radium-2 26

Thorium-230

Uranium-238 and,234

Radium-226

Thorium-230

Uranium-238 and  234

Radium-226

Thorium-230
   ore dust (oxides)

       ore dust

       ore dust

 yellow cake (oxides)

      yellow cake

      yellow cake

tailings sand (0-10 y)

tailings sand (0-10 y)

tailings sand (0-10 y)
   9.0

   4.5

   4.5

 170.

   0.2

   4.7

0.2 - 0.8

1.3 - 4.2

1.4 - 4.5
   9.0

   4.5

   4.5

 170.

   1.7



 0.3  - 2.2

2.3 - 1.5

2.4 - 1.5'
                   (a)
                      6% moisture ore,  radon-222  releases excluded

-------
     Each site must be evaluated individually.  If  the ground




water table is high and the soil is low in ion exchange capacity




so that it becomes likely that radium-226 and thorium-230 will escape




from the tailings impoundment into underground waters, then the pond




area could be lined with an impervious membrane of  asphalt to minimize




seepage.  Acid wastes would have to be neutralized  beforehand to




prevent damage to this type of liner.




     The amount of radioactive particulate material removed from the




tailings beach by wind erosion is believed to depend on the area of the




beach, the wind velocity, and particle size distribution of the tailings




(j>).  Estimates of this source term are included in table 5.0-1.  Par-




ticles greater than lOy in diameter are not considered to be respirable




particles and are not included in the inhalation source term pathway.




Historically, windblown tailings have caused elevated gamma exposure




levels around piles, however, the inhalation pathway has been determined




to be the critical pathway.  Levels of control sufficient to limit radi-




ation exposure through the inhalation pathway will  also prevent, to a




significantly greater degree, exposures through the ground deposition,




whole body exposure pathway.
                                19

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6.0  Radiological Impact of a Model Mill




     Estimates of the radiation doses to individuals through the air




pathway in the vicinity of an acid leach model mill using base case




controls from routine emissions are shown in table 6.0-1.  The esti-




mated collective lung doses to the population in the vicinity of an




acid leach mill are given in table 6.0-2.  The collective lung dose




is determined by summing the average individual radiation dose equiva-




lent to individuals living within 80 kilometers of the mill over the




total population within 80 kilometers of the mill.  The models for the




dispersion and dose calculations are discussed in detail in Appendix A




of Reference (1).  Based on the information available at the time that




analysis was performed, an effective half-life of 1,000 days was used for




insoluble class Y compounds in the pulmonary region of the lung in cal-




culating the lung doses from mill emissions.  In accordance with what




is now becoming accepted practice, in this report all dose conversion




factors are calculated using a 500-day effective half-life (18), and




are, therefore, reduced by a factor of two from the previously used




values.




     The dose conversion factor used to calculate the lung dose is




believed to be an order of magnitude more conservative than the dose




conversion factor used in Reference (6).  Reasons for this difference




which relate to assumptions regarding lung model parameters, are dis-




cussed elsewhere.  It is also assumed that food consumed by individuals




living near the mill is not produced locally so that exposure through
                                20

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                                    Table 6.0-1
                Radiation Doses  to  Individuals  due  to  Inhalation
              in the Vicinity of  a Model Mill with Base Case  Controls
Dose Equivalent to Critical Organ
Radionuclide
Uranium-234
and 238
Thorium-230
Radium-226
Source
Term
(mCi/yr)
180
15
10
Critical
Organ
Lung
Lung
Lung
Individual at Plant
Boundary
(mrem/yr)
170
15
15
Average Individual
Within 80 kms
(mrem/yr)
3.9 x 10~2
3 . 4 x 10~3
2.2 x 10~3
Total    205
200
4.5 x 10~2

-------
                                    Table  6.0-2
                Collective Dose to the General Population in the

                Vicinity of a Model Mill with Base Case Controls
                           a
                     ^O11 T"f* P*
   n  ,.    . . ,        „       _  .,     Critical  Collective  Critical  Organ Dose
   Radionuclide       Term    Pathway                                   &

                     (mCi/yr)                              (person' rem/yr)





Uranium-234 and 238    180      Air      Lung                 2.2





Thorium-230             15      Air      Lung                 0.2





Radium-226              10      Air      Lung                 0.1
                                         Total                '2.5
aReleases to water pathways assumed equal to zero, and doses from radon-222 are

 not included.
                                       22

-------
food chains is not significant compared to lung exposures resulting




from the direct inhallation of radioactive particulate matter.  The




radon exposure pathway was excluded from this report.




     Because there are no liquid releases from the model mill, there




is no projected radiological impact through water pathways.






7.0  Health Effects Impact of a Model Mill




     Potential health effects to members of the general population




in the vicinity of a model mill using base case controls are esti-




mated to be 0.0002 lung cancers per year of operation, or 0.005




such effects for 30 years of operation.  The models used for the cal-




culation of health effects are given in Appendix A of reference (1).
                                23

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8.0  Control Technology for Uranium Milling




8.1  Airborne Effluent Control Technology




     Hazardous airborne gaseous and particulate wastes are generated




in the milling operation from a number of different sources.  The




major areas of the milling operations in which gaseous and particulate




matter effluents must be controlled are the ore crushing area, the




fine ore bins, and the yellowcake drying and packaging areas.  Mills




often prefer to use multiple dust collection systems rather than design




a single, more elaborate system.  There will usually be two or more ore




dust collectors and separate systems for the yellowcake dryer and for




the yellowcake packaging rooms.




     Dust collector systems that are currently used or that can be




adapted for use by uranium mills are discussed in reference (j>) .




They are for the most part control technologies that have been proven




and are standard industrial equipment.




     Briefly, these treatment methods are:




     a.  Orifice Scrubbers - The dusty air flows through a stationary




baffle system coated with a sheet of water.   The dust particles




penetrate the water film and are captured.




     b.  Wet Impingement Scrubber - The dusty air carrying water




droplets added by preconditioning sprays passes through perforated




plates to atomize the water and to wet the dust.   Particles are then




collected by impingement on baffle plates and a vaned demister.




     c.  Venturi Scrubber - The dusty air is passed through a venturi,




increasing its velocity.  Water is added which atomizes in the gas




stream and collects the dust by impingement.  The wetted dust is
                                24

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removed by demisters.  Raising the pressure drop across the




venturi increases the collection efficiency, but this requires




higher energy levels and raises the costs.




     d.  Bag Filters - These filters are made of woven or felted




fabric and have high collection efficiencies provided the air




being filtered is cool and dry.




     e.  HEPA Filters - These filters are made of fiber glass.




They have very high efficiencies but have a number of limitations;




in particular, they can only be used in conjunction with a




prefilter and on dry air streams.




     Current practice involves the use of wet dust control systems,




although several mills use bag filters for air flows from ore




handling and from the yellowcake packaging area.  The costs and




percent effluent reduction for the various control systems suitable




for effluent streams of the model mill are given in table  8.1-1.




     Particulate material can be prevented from being windblown off




the tailings pile beach by back filling with overburden and,as an




interim measure, by chemical stabilization by spraying with




petroleum derivatives.  Chemical stabilization lasts about a year and




must be repeated on a regular schedule.




     Other sources of gas and dust which can be controlled are the




open pit mine haul roads and the ore storage and blending piles.  In




some instances,  the liquid content of the ore as mined may be




sufficiently high to eliminate most dust formation in the ore




storage and blending area; due to insufficient information,  this case
                                25

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                                                   Table  8.1-1

                            Cost  and Efficiencies  of Control Technology  for Mills

Control Method
A. Gaseous (Crusher and Fine Ore Bins)
1. Orifice Scrubber
2. Wet Impingement Scrubber
3. Low Energy Venturi Scrubber
4. Bag Filters
B. Gaseous (Yellowcake Drying and Packaging)
1. Wet Impingement Scrubber 'c'
2. Low Energy Venturi Scrubber (c)
3. High Energy Venturi Scrubber
4. High Energy Venturi Scrubber + HEPA
Filters

Capital Cost
(dollars)

101,000
116,000
173,000
300,000
(35,000)
(35,000)
46,000
106,000


Annual
Operating Costs
(dollars)

7,200
$,600
17,000
21,000
(3,500)
(6,900)
15,000
22,000


Present Worth(b)
(dollars)

172,000
200,000
340,000
506,000
(69,000)
(103,000)
193,000
322,000

Percent
Effluent
Reduction
(%)

93.6
97,9
99.5
99.9
97.9
99.5
99.9
>99.99

C.  Liquids,  Solids, and Windblown Particulate
    Matter
    1. Clay Core Dam Retention System with          2,250,000
       Seepage Return and 0.6 Meters (2 feet)
       of Earth Cover Plus Rock Stabilization^6)
    2. Chemical Control of Windblown Dust from         63,000
       Tailings Pond Beach
    3. Asphalt Liner for Tailings Pond^6)             800,000
50,000


 8,000

   0
      (d)
2,750,000


  142,000

  800,000
100.00

100.00
     (a)l974 dollars, radon-222 emissions not included.
     (^Present Worth = Capital Cost + (Annual Cost  x 9.818);  8% Discount Rate,  20 yr.  Plant Lifetime.
     ^c'Costs for all yellowcake effluent control are shown for  completeness.   In actual practice, the value of
        recovered product more than compensates the  cost of control options Bl and B2.
     ^Includes investment to provide for perpetual care.
     'e'160 acre tailings pile.

-------
will not be considered at present beyond stating that the problem




appears potentially significant and, that it can be controlled in




principle through sprinkling and by use of wind breaks.  Dust genera-




tion on ore haul roads can also be controlled by sprinkling.
                                 27

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8.2   Waterborne Effluent Control Technology and Solid Waste Control
      Technology

     New mills in the Rocky Mountains area are using impoundment

technology in order to approach zero liquid discharge levels.  Recent

practice for treatment of solid and liquid wastes is to select a

natural ravine which has three basic qualifications for waste

storage:  (a) limited runoff, (b) dammable downstream openings,

and (c) an underlying impermeable geologic formation.  Diversion

systems (dams and canals) are used to limit the runoff area

emptying into the storage basin to prevent flooding of the ravine

during a postulated 50-100 year maximum rainfall occurrence.  The

tailings dam, which should be clay-cored, is keyed into the underlying

impermeable formation, which, in one example, is a low porosity

shale.  Tailings solids slurried in waste process liquids are

pumped to the impoundment reservoir for storage and liquid reduction.

Liquid reduction is accomplished primarily by evaporation, but

also by seepage through the dam, the reservoir walls and floor.

By filling a dammed natural depression with tailings, a relatively

flat,  stable contour is achieved.

     Two methods for seepage collection and return are being

considered for new mills.  Seepage has been estimated to occur from

a clay-core retention dam at a rate of 300 liters per minute.  In

that situation when an impermeable geological formation underlies

the retention system, seepage can be collected in a catch basin

located at the foot of the dam.   The collected seepage can be pumped
                                28

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back into the retention 'pond thus eliminating release to the offsite




environment.  In that situation where either an underlying imper-




meable geological formation is not existent or is not continuous,




vertical seepage may occur to the underlying ground water formation.




Wells may be drilled downstream of the retention system into the




subsurface formations where seepage will collect, and this water




is pumped back to the retention system.  Such a system requires




specific favorable subsurface conditions.  In both cases, these




control costs are small compared to the cost of the clay core dam




retention system (1) .




     Impoundment of solids is being accomplished in older mills




merely by construction of a dike with natural materials and




filling the diked area with slurried tailings.  When full, the




height of the dike is increased with dried tailings to accommodate




even more waste material.  Process liquids which overflow the tailings




dike or seep through the dike are sometimes routed through a treat-




ment system and discharged to the environment.  The diking procedure




which is less costly initially, creates an above-ground pile of




tailings which is difficult and costly to stabilize.  While the




mill is operating, this type of pile is also subject to wind and water




erosion.  Field studies at tailings piles after mill shut-down have




shown high gamma radiation levels in the vicinity of such piles,




elevated radium-226 levels in water supplies, and high airborne levels




of thorium-230 and radium-226 due to wind blown tailings (14,15,16,17).




For these reasons, new mills are not likely to be built using this type




of solid waste control.
                                29

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     Stabilization of tailings piles requires grading of the tailings




area to lessen side slopes, establishing drainage diversion, covering




with nonradioactive material, and revegetating the area.  In




semiarid regions it may be necessary to initially irrigate the pile




to achieve vegetation growth.  Other types of stabilization may also




be feasible.  One method involves the covering of the tailings




with large aggregate gravel from a river bottom.  Silt fines which




accompany the river gravel will blow away in a short time leaving




what is affectively a wind-proof rip rap, thus significantly




reducing or eliminating migration of the tailings outside the




controlled area.  The costs of such stabilization has recently been




estimated (6) at $350/acre-ft for earth, and $2,000/acre-ft for rock.



The cost associated with stabilizing a diked surface pile is sig-




nificantly higher and probably less effective because of difficulties




faced in grading, covering, and revegetating the potentially steep




side slopes.,




     Uranium mill tailings piles are long half-life, low-level




radioactive wastes.  As such, they will require perpetual care.  This




will include occasional inspection and maintenance to insure integrity




of the stabilizing cover, fencing, and of the warning signs around




the pile.  An annuity should be included as part of the cost of the




control technology to pay for this care.  The maintenance associated with




perpetual care of a stabilized dike system would probably be higher




than that for the depression fill system, since there is tendency toward




collapse of side slopes and possibly inadequate drainage of precipition




from the pile.






                                30

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9.0  Effluent Control Technology for the Model Mill




     Typical current effluent control systems were assumed for




the model mill.  They were:




     a.  Ore Crusher and Ore Bin Dust - Orifice Scrubber.




     b.  Yellowcake Dryer and Packaging Dust - Wet Impingement




Scrubber.




     c.  Liquid and Solid Waste - Clay-core dam retention system




(160 acres) with seepage return and exposed beach.  To be stabilized




with 2 feet of earth cover and 6 inches of rock cover.




     The radiological impact of total airborne effluent versus




successively more effective control systems for a model uranium mill




are listed in table 9.0-1.  Each improvement in control is the most




cost-effective available at that level of control.




     The output of the model plant using base case controls is 1,140




MT U^Og of which approximately 1% is recovered by the wet impingement




dust collector system during drying and packaging operations (6).   The




value of 11,00 kilograms (24,000 Ibs) of recovered yellowcake more than




compensates for the cost of this control system.  The low energy venturi




scrubber is 1.6% more efficient that the wet impingement scrubber and



will recover an estimated additional 200 kilograms (440 Ibs)




of yellowcake per year.  The value of this additional recovered yellow-




cake is approximately equal to the increased annual operating costs of




the low energy venturi scrubber as compared to the wet impinger.  The




present worth of these systems are, therefore, not included as a control




cost for the model mill.
                                 31

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                                                     Table 9.0-1

               Radiological Impact of Airborne Effluents versus Control Costs for a Model Uranium Mill
u>
NJ
Controls
(Table 8.1)
None
Al; Bl(c)(d)
Al; B2(d)
Al; B3
A2; B3
A2; B3; C2
A2; B4; C2
A3; B4; C2
A4; B4; C2
cKO
Source Term'3'
(mCi/yr)
>20,000
205
75
35
25
15
6
1.5
0.3
0
Maximum Lung
Dose to an
Individual 20,000
200
73
34
24
15
6
1.5
0.3
0
Present Worth
(1974 $/facility)
0
172,000
172,000
262,000
290,000
432,000
561,000
701,000
867,000
2,750,000
               (a)Alpha emitting radionuclides as insoluble, respirable particulate matter.
               ('b)For the assumed worst case of an individual permanently occupying a location exhibiting
                  a x/Q of 6 x 10~6 s/m3.
               (c)Assumed current level of controls for new mills.
                    sts for control options Bl and B2 not included, since they are more than compensated by
                  the value of product recovered.

-------
10.0  Retrofitting Control Technology to Operating Uranium Mill




      The cost and practicality of retrofitting control technology




 systems to an operating uranium mill was not included in Reference




 (j6).   The cost is judged to be approximately the same order of




 magnitude as the cost to install the same control system in a new




 mill.




      The cost and practicality of retrofitting control measures




 to operational tailings piles that do not use clay core dam impound-




 ment  technologies must be considered on an individual basis.
                                 33

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                               REFERENCES
1.  U.S. ENVIRONMENTAL PROTECTION AGENCY.  Environmental Analysis of
    the Uranium Fuel Cycle, Part I - Fuel Supply, EPA-520/9-73-003-B,
    Office of Radiation Programs, Environmental Protection Agency,
    Washington, D.C.  20460 (October 1973).

2.  U.S. ENVIRONMENTAL PROTECTION AGENCY, Environmental Analysis of
    the Uranium Fuel Cycle, Part II - Nuclear Power Reactors, EPA-
    520/9-73-003-C, Office of Radiation Programs, Environmental Pro-
    tection Agency, Washington, D.C.  20460 (November 1973).

3.  U.S. ENVIRONMENTAL PROTECTION AGENCY.  Environmental Analysis of
    the Uranium Fuel Cycle, Part III - Nuclear Fuel Reprocessing,
    EPA-520/9-73-003-D, Office of Radiation Programs, Environmental
    Protection Agency, Washington, D.C.  20460 (October 1973).

4.  U.S. ENVIRONMENTAL PROTECTION AGENCY, Environmental Radiation
    Protection for Nuclear Power Operations, 10 CFR Part 190, Federal
    Register, Vol. 40 No. 109 (Thursday, May 29, 1975).

5.  U.S. ATOMIC ENERGY COMMISSION.  Draft Environmental Statement
    Related to the Utah International, Inc. Shirley Basin Uranium
    Mill, Shirley Basin, Wyoming, Docket No. 40-6622, Fuels and
    Materials Directorate of Licensing, U.S. Atomic Energy Commission,
    (June 1974).

6.  SEARS, M.B. et.al.  "Correlation of Radioactive Waste Treatment Costs
    and the Environmental Impact of Waste Effluents in the Nuclear Fuel
    Cycle for Use in Establishing 'as Low as Practicable1 Guides -
    Milling  of Uranium Ores," ORNL-TM-4903, Two Volumns, Oak Ridge
    National Laboratory, Oak Ridge, Tennessee  37830 (May 1975).

7.  TEKNEKRON, INC.  "Scopping Assessment of the Environmental Health
    Risk Associated with Accidents in the LWR Supporting Fuel Cycle -
    Draft Report"-EPA Contract No. 68-01-2237, Teknekron, Inc.
    Washington, D.C.  20036 (September 2, 1975).

8.  "Controlling the Radiation Hazard from Uranium Mill Tailings" Report
    of the Congress by the Comptroller General of the United  States
    RED-75-365 (May 21, 1975).

9.  HUMBLE OIL AND REFINING COMPANY.  Applicant's Environmental Report,
    Highland Uranium Mill, Converse County, Wyoming.  Minerals Depart-
    ment, P.O. Box 2180, Houston, Texas  77001 (July 1971).
                                   34

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10.  HUMBLE OIL AND REFINING COMPANY.  Supplement to Applicant's Environ-
     mental Report, Highland Uranium Mill, Converse County, Wyoming.
     Minerals Department, P.O. Box 2180, Houston, Texas  77001 (January
     1972).

11.  U.S. ENVIRONMENTAL PROTECTION AGENCY.  Evaluation of the Impact of
     the Mines Development, Inc. Mill on Water Quality Conditions in the
     Cheyenne River.  EPA Region VIII, Denver, Colorado  80203 (September
     1971).

12.  U.S. ENVIRONMENTAL PROTECTION AGENCY.  Interim Primary Drinking
     Water Regulations - 40 CFR Part 141 - Federal Register, Volumn 40,
     No. 158 (Thursday, August 14, 1975).

13.  U.S. ATOMIC ENERGY COMMISSION.  Draft Detailed Statement on the
     Environmental Considerations Related to the Proposed Issuance of
     a License to the Rio Algom Corporation for the Humeca Uranium
     Mill, Docket No. 40-8084.  Fuels and Materials Directorate of
     Licensing, U.S. Atomic Energy Commission, Washington, D.C.  20545
     (December 1972).

14.  SNELLING, R. N. and SHEARER, S. D., Jr.  Environmental Survey of
     Uranium Mill Tailings Pile, Tuba City, Arizona.  Radiological Health
     Data and Report 10:475-487 (November 1969).

15.  SNELLING, R. N.  Environmental Survey of Uranium Mill Tailings Pile,
     Monument Valley, Arizona.  Radiological Health Data and Report 11:511-
     517 (October 1970).

16.  SNELLING, R. N.  Environmental Survey of Uranium Mill Tailings Pile,
     Mexican Hat, Utah.  Radiological Health Data and Report 12:17-28
     (January 1971).

17.  U.S. ENVIRONMENTAL PROTECTION AGENCY.  Radium-226, Uranium, and Other
     Radiological Data from Water Quality Surveillance Stations Located
     in the Colorado River Basin of Colorado, Utah, New Mexico, and Arizona,
     January 1961 through June 1972.  8SA/TIB-24, EPA Region VIII, Denver,
     Colorado (July 1973).

18.  International Commission on Radiological Protection, The Metabolism
     of Compounds of Plutonium  and  Other  Actinides, Adopted May 1972,  ICRP
     Publication 19, Pergammon  Press, New York  (1972).
                                                                   GPO 900-1 90
                                    35

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