-------
or utilize radioactive materials. Ihe responsibilities trans
under Section 301 arc an integral pf.rt 01 tha operating prorn'on: 5t" Ci\P.
Two possible sourct-s of authority which mc.y he utilized by EPA
are container in the Federal Waver Pollul.ion Control Act and in the
C3_ean Air Act. Additional authority exists in Section 4, paragraph 6,
of Executive Order 11S07, "Prevention, Control and Abatement of Air
and Watec Pollution at Federal Facilities," stating that
"Discharges of radioactivity shall be in accordance with the
applicable rules, regulations, or requirements of tha AEG aiid
with the policies and guidance of the Federal Radiation
Council as published in the Federal Register."
The subsequent transfer of these functions by Reorganization Plan Number
3 of 1970 constitutes an additional A^^ncy basis for legal activity.
With regard to the discharge of radioactivity in^o navigable waters,
the Pt-tmf.t Pro^i'aiii c£ L;W Ri/v=i anu rlaiuor Act of 16S'9, cor.n-.only knovzi
as the "Refuse Act," provides EPA the opportunity to establish the
applicable radiological criteria, with the U.S. Army Corps of Engineers
currently being responsible for enforcement of the permit system.
In general, the implementation of EPA program activities is con-
ducted in specific areas; however, through ex^rcLs?. on the guidance
functions inherent in EPA authority the Agency imy exert influence on
the radiation policies of other agencita Lr ovier to T.2et th^ ovi_ra] 1
objectives of the national radiation strategy. This concept of leverage
enables the Agency, with its limited resources in the radiation aieas
to produce a significant impact on radiation protection policy through
such activities as standards setting, guidance LO other agencies and
xiv
-------
i'A review. These uiocha::isrjt3 are censrebt;'::<:>ii. ii.oniuoi.iiij byt»LL".a), ciaLa PI id inforirat in p.
must be obtained. When possible, this data should be obtained from
other agencies, Federal -and State, to minimize duplication of effort
and tc maximize the effectiveness of EPA resources. Data on costs and
benefits also must be obtained elsev;here when possible and a cooperative
effort is required for die free exchange of infomation. The information
received from other agencies vjll, after validation, have significant
influence in the establishment of standards. If cooperative efforts
among other agencies to obtain this data cannot be worked out, then
ORP will use best estimates of risks, costs, and benefits in order to
proceed.
-------
USE or TJIV: STRATIFY
This plan will serve c.s a manageTror.i: tool by thu OZfice of
Radiation Programs for:
o assessing objectives on a continuing basis;
o re-evaluating priorities;
o monitoring technical porforK-ance with respect to achievement
of goals and objectives; and
o providing an overall framework for subsequent programming
and budgeting.
This program plan will be foraially updated as required to serve
as a -working mascer plan to guide the activities of all progress within
ORP.
Program Gpal
The broad s,oal of EPA in the radiation area is to assure that no
additonal risks occur to individuals, the population at lajge, and the
environment due to increased radiation exp&r.ure wic'iout tcie existence
.of offsetting beneficial reasons for *:hese additional risk?.
The risks involve both health and snvi:'crui2r.tjil qualvL^ and include
increased disease to man and ananal, increased adverse genetic effects,
and increased -adverse ecological effects. Health risks should includ-
those fron ion.'--.ns -is '.:ell r.n no-ionisir.u, rr.rxaf;.o:i so^rcca. lieaiLu
considerations should bi coi^Eraed \*ich enhancement of health and
well-being as well as the prevention of disease. The effect on land use
must also be a consideration when locating power plant? ar.d r..Tast£ dis-
posal areas.
xv i
-------
Risks irust be examined on bof.i a short-terra and a Ion;,- Lei m basis
and geographically, world-vide as well a:; ijcai. ?.c-r.l risk from actual
exposures mus: be considered, in addition to the predicted risks from
potential exposures which misht result from an accident.
Objectives
ORP's mandate is to assure that bonericial activities are accom-
plished in a manner to minimize unwarranted risks and costs. Coranen-
surate with the benefits accruing to those at risk, the objectives are
the following:
a) Minimize radiation exposure to individuals
b) Minimize radiation exposure to populations
c) Mininize occupational and radical exposures
e) Enhance lend use practices through effective power plant and
disposal siting decisions.
Program Framework
The overall radiation protection prograu has been s'.ructurcd from
the standpoint of two points of view. The first considers problem areas
within the following four classes or radiation sources:
_nf.r,',y 7-.;3 cia=;c cc-aiaii.i. problem areas rc
to the production of electric power from
nuclear energy.
o Nonerergy Medical and occupational exposure problems
are treated in this class.
o Natural Problem arPas associated -ith ccsr.ic
radiation and radiation emanjtinr, from
construction materials and mining wastes.
xvii
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Railiation Sour(_:__ _C]_av; ^i.
o Nonionizing 'fluso i/oKLcn, arifc fro">. clectro-
is..1 finer _c 7duia:acm ( X> visible
light)
The firsL three classes are concerned with ionizing radiation, the
first two of which arise frora cun-nade sources. The energy classifica-
tion involves the various stages in the nuclear fuel cycles except the
mining related activities. Although much of tiie radioactive mining
wastes arc due to the extraction of uranium and thorium, ('there are
other mining wastes which are not directly associated with these fuels
yet are radioactive; therefore, mining wastes have been placed in the
source class of natural radiation. The ncnenergy class involves
medical applications (thcraputic and diagnostic; internal and external
sources), occupational exposures (nediral technicians, watch rcparinen,
airlines crevs, etc.), isctopic sources, and applications involving
nuclear devices (military and plowshare). (Natural., ronionizing
radiation, such as ultraviolet rays from the sun does jjot fall under
the aegis of ORP./
A listing of the IS major problem areas presently considered in
the program plsn are shown accorcir.g ><> the-Lr «ju--'2 classification in
Table A.
A second suppioconLary nethod of categoriaing required radiation
programs is by the following generic functions:
Generic Function Descripedon
Risk/CosL/Bancfit Analysis This functional class consists of
tradeoff ctudi^'* ^^^ -.^*-i'm--:*--'prt
requiied to support development o.r
criteria and standards.
xv iii.
-------
TABLE A
CATEGORIZATION OF RADIATION PyO^lAlI BY PROBLEM AREA
WITHIN CLASSES OF RADIATION SOLRCCS
SOL'RC" TLAS'S
Energy
1J /'/'
Natural ,j " £ /,
-J P-' *>
Nonionizing
Kon-Lneusv
PROT'TT*! \1*vtQ
L l\\Jljl.i.. i 4ki.\.i_«lO
1)
2)
3)
4)
5)
6)
7)
8)
9)
1)
2)
1)
2)
Accidents
Fuel Reprocessing
Disposal
TliGrmouuclcar
Fabrication-Plutonium
Operation-Plutonium
Fabricat Lon-Uraniu^i
Operation-Uraniun
Transportation (V,7astes)
Construction Materials
Mining and iliil Tailings
Microwave' and Radio Frecuencv
Lis.jy crd Oriif.i Klectrorajgnt-Lic
Raaiatior.
n -rrd. ., ^r..,,. .
2)
t \ %,
>-.; i-i^ciicfin A-rc
4}
5) Device Testing
xix
-------
Strategic .Studies
Environmental Ir.pact
Statements
Monitoring and
Surveillance
DcscrJgtJon
ImerstieaLions which am ait-uc1 at
pvuvTciflL r. hroi.d .u;a?snn.?jL of
coirc..'.c-v .-inc. ccn'-rcv^vsidl issues in
order to assist in formulating the
basJc for setting standards by ORP
arc included in this class. This
functional c'.-.ss also supports
dcveloiir.-.cn£ of suitable nodc]s and
analytics! methodology for setting
standards.
Environmental Impact Assessments are
project specific and are required
for supporting action decisions on
a near-tern basis.
Surveillance of sources and monitoring
of ambient conditions are performed
to support such activities* as field
studies, energency actions, ar.d
assessment of siior;: and lone-term
radiation trcrds. A prir.ary cbj'ctive
of this, function is ;:o provide claua
for use i" the Tctionai Do= "orteJ .
Tnese activities provide assurance
that state and -local agencies have
competent personnel to conduct
radiation protection programs.
These activities are pervasive among all sources and problem areas
described in the first structural program category. The interactions of
the two types of categorisations are showr In Figuii- A. At the epex of
the triangle is ORP's primary responsibility, the establishment of
standards und criteria on a risk/coat/bantljr jasis. l,i*B respoi.siMl i ty
is derived from oreviously designs od authorities and leads to ^fcrcomcnt
actions, as reqaired. The remaining generic functions are generally
applied to the problem areas shown at the base of the triangle.
Traini.-.g
xx
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AUTHORITY
«/ S1A.\'1V'U)S
AM)
CRITEJU-1.
DAS IS
SITvATLCIC STUDKS
irC^NT.-' I. i:'p.\CT
/ i-oxrT- "~"'~7^ A
/ co;.n)T7o:;s r;n SPECIFIC SOLRCKS \
/-- i
rM£-, MK'-tM.»;CY \
1 \TV\T\
FIGURE A
LEVELS OF PROJECTS AND/OR ASSFSSMENTS
LEADING TO STANDARDS AND ENFORCEMENTS
xxl
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Proposed and Optr.r.un; Prtv-rans
A proposed and an optimum u:."03v.'lni for meeting the goal and objec-
tives of ORP have been developed. Tie pTopoc^J program is judged by
ORP to be minimally acceptable if the EPA is to avoid being deficient
in providing adequate support and policy guidance to those Federal,
state and private groups whose actions relate to the generic functions
and the 18 problem areas shown in Figure A. The optimum program is one
which is judged by ORP to be realistic (in terms of attainment) and
desirable (in terns of providing expeditious results and guidance to
decision makers within a suitable time frame) to achieve the radiation
protection goal and objectives in a satisfactory manner within a five-
year planning period.
Tho f^-i f f nvpn,->p<5 h P { v i> n p ("hp- fVO r»r (3 r-r .*>* . per P.r S 1] V . al"(? twofold!
1) The optir.um program allows for achievement of significant
milestones earlier in time, on an accelerated basis.
2) The optimum program allows more thorough investigations to
be conducted in greater technological depth, thereby reducing
uncertainties which affect the quality of scientific and
managenent decisions. /The proposed program is generally based
' X.
on the best available data from already existing snurces.'
The rtfi"?-;] =; of the prcgrair. and -f/arts of c.ccivitics over time for
che proposed and cpticium program ui., pfe^ented in Section II cf the
National Radiation Protection Program Strategy and Plan. The flow
charts depict some 180 events (program elements) within the five generic
xxii
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function categories and the four source classifications. Each element
is characterized by its location in time and its relationship to other
program elements. The generic functions consist of activities which
generally cut across problem areas. Of the five discussed previously,
the Risk/Cost/Benef il Analysis in support o£ review of existing and
development of new criteria and st?ndards is the most significant and
inter-relates most extensively with the remaining four functions.
Risk/Cost/Benefit Standards
The major thrust of the ORP program is to set rtdiation protection
standards using a Risk/Cost/Benef iL (RCT) rationale. This is a new
approach to achieve fair standards and is entirely consistent with the
objectives of the Office of Management and Budget in 'these matters.
The implications of standards set in this manner, as opposed to stand-
jiuo t>iiL on '.ic.iil.ti t i biio 01 health rislxd and cost, nlont:, have wj.ue
ramifications that are not generally visible at first glance.
Risk/Cost/Benefit standards, first, are dynamic since costs
associated with risk reduction change as new technology develops, and
benefits to society for a particular activity involving an associated
health risk vary as scoeity's needs change. 'Further, different applica-
tions have different benefits associated with them, and there can be
major differences in standards for different activities. As an example,
standards fur plutuni1.;:!! cunLiiisiiuiLii.1:! fium o nut.l-j^i' power pidiit -i-ay be
different irom that of a military lacilicy, sJ.uct: ihu belief J.LS ol
adequate energy supply and national defense capability may be quite
different. Although a more detailed explanation of the whole process
of setting RC3 standards is provided in SeccLon I -jl uin aLi_di_hc:u
strategy document, there are several aspects that: shculd be emphasized
here.
xxii i
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Risks
Health risks for any given expojure are based upon a linear non-
threshold model which assigns some lev.-.1, of risk to any level of radia-
tion exposure. A health effects model, which will relate dose from all
sources and isotopes to health cffact levels for individuals and the
population as a whole, will soon be available. The establishment of
this consistent health effects model, in which the ranges of uncertainty
are explicitly expressed, is the basis for agreement nationally and
internationally on the risks associated with radiation. There will
always be uncertainty in any health effects model. ^For radiation, the
present level of uncertainty is two or three orders of magnitude less
uncertain than for most other environmental pollutants./ On the other
hand, the reduction of further uncertainty implies the undertaking of
la^fec.-i.-^a_c, io:i^-i.L'i...i i. tjbtjrt.ii pjLOyLduis wii.ien noc only uxjaru uUierw-ioe
useful resources, hut will take 10 to 15 years to provide useful results.
Since standards must be set now, we must proceed with £ lioalLb effects
model with reasonable limits of uncertainty and make expert value judg-
ments, possibly biased from a conservative viewpoint, when the limits of
uncertainty are too large to be entirely scientific.
Costs
Costs are associated with those actions which reduce the environmental
risk abso-jijL'jd wii.h a:: asiLivity. cjuaip.y possible radiation exposure JIG E
by-producL. ihus, the development of new technology makes possible further
reductions of risk with increased benefits. Thus, cost factors are
dynamic and change as our knowledge changes.
xxiv
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Benefits'
Benefits to .society and to groups within society are mere difficult
to measure than risks or costs, since many benefics are non-monerary and
intangible in nature. ORP lias developed a methodology (see Section I)
which allows benefits, risks, and environmental costs to be measured dn
common units when monetary, non-monetary. n.ic' Lr u^ng'.bj.c. conditions are
considered. 'Thus, health risks are balanced against health benefits,
economic costs versus economic benefits, aesthetic degradation against
aesthetic benefits, and so forth./ This methodology attempts to balance
the risks and benefits for each alternative that can produce a societal
benefit by balancing the marginal costs of risk/cost reduction versus
benefits/cost attainment on a marginal basis.
Complexity
ai.il is iio\v cmd cc/nsiciuiLibly inoi e cio;..i
-------
NOT
DIGITALLY
-------
must be consicifred collectively for the development of generally
applicable standards.
In June 1970, the Federal Radiation Counril ("RC) initiated a
review of the bases for and considerations of radJation exposure
guidance.XliPA has continued this review and is expected to establish
)
a position on the FRC yuid.ar.ce by July 1973. */ Three studies havt? been
planned for this evaluation.£j/?he first study has just been completed
and gives estimates of ionizing radiation doses from 1960-2000. The
,3?
second study estimates the biological effects from low doses of non-
^
specific radiation, and tLe third study to be completed by May 1973
vri.ll develop a means of quantifying benefits fro:r. ra-jiation. The FRC
review will be completed by October 1973, cn^ guidjuico for radiation
doses will be issued. The review wil] bt. bc-c^d partially on the results
*Unless otherwise stated, dates are for the proposed program.
xxvii
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of a "lowest practical dose level" study. /A generally r.^f-licr.Mc guide
for all uses of nuclear energy ?u ro '"nllc : JL.. No\ Briber 1973, and will
be based on the previous studies as well as studies on the U-225 and
Pu-239 fuel cycles. These latter tvo studies are categorized under
the generic function "Strategic Studies." After EPA's -position on FRC
guidance has been established, /special studies on Kr-85, H-3, 1-129,
Pu-239, Ra-226, and other nuclides will be conducted for the issuance
^
of ambient air and water standards and the last nuclide will be completed
by Janujry 1975. J These standards will also be based upon an environmental
pathway model study. The proposed completion date for this phase of the
optimum program is September 1974.
A risk/cost/benefit (RGB) analysis for building materials will be
developed by January 1974, after the completion of a dose :nodcl for
will be developed by Ju.lv 1974. The health effects modal and the
benefit model previously described will be used in the establishment
of the standards.
The health effects and benefit mode-. Is will also be used along with
an evaluation of the current motliral X-ray technology foi a RGB analysis
of medical X-rays to be completed by M^rch 197<». Tne KGB analysis is
due to be completed by January 1974, for the optimum program. Healing
arts guiii^siLt; vill bo ?5=-M-d by FT>A by .Vcvrirb.'r J97'i (February 197"
for the optimum prograni) -iiid s re-tvaluuLJ.&n of medical X-ray dcsa data
is scheduled for completion by July 1977 (Jul> 1976 for optimum program).
xxviii
-------
The coniplcuio'n of each of these items is dependent, on the completion of
the earlier studies. The issuance of healing arts guides is also depen-
dent upon bolh dose assessments for medical X-rays and medical isotopes
and an evaluation of the improved medical X-ray technology. The dose
assessment for medical X-rays will be used for the RGB analysis mentioned
above.
The issuance of radiation source standards (all sources) will begin
in July 1974, and is a further extension of the GRG review and guidance
recommendations. Building ma ferial 'stardai.ds (7/7'+) anil consumer pro-
ducts standards, will be issued by May 1975. Guidance for occupational
exposure will also be issued by this date and is based on the FRC review
and a study of occupational exposure limits. The completion dates for
the optimum program are six months to one year earlier than the above
uuteu.
Upon completion of a nation:1 radiation dose model, the scientific
bases for all standards will be re-evaluated by January 1977. In ]979
the guidance for medical X-ray will be revised based on the current
technology.
Beginning in mid-1973 and continuing until 1975, EPA will establish
policies and issue criteria and standards for nuclear fuel reprocessing. '-'
Studies are planned to determine the magnitude and status of the LWR, the
LMFBR, and Li-.B HTGR f'-al Lapi(jcea^l::i; c>i.las. Initially. EPA '..'ill isc-c a
policy SLatemenu on LWK fuel reprocessing (li//^) as wen as policies
regarding generally applicable environment] standards for fuel repro-
cessing (7/73). A criteria document on LMFBR fuel reprocessing will be
-------
issued by Ji'ly 1975, -->nd E'-andii'Js i:oc L\"R ILK! cycile xfLll be given by
SepLcmber 1975. In early 1976, siting criteria on LMFER. fuel re-pro- , ''"''
'*/
cessing is scheduled to be issued and will be followed by an EPA review
of fuel reprocessing. The optimum program is Lderitica.1 to the proposed
program with 1'ie exception of the L.PA poJicy on generally applicable
standards which will be issued five months sooner. It should be pointed
out that the standards for each fuel reprocessing cycle are interrelated
and cannot be considered separately.
Along with the establishment of standards for the fuel reprocessing
cycles,/siting criteria must be developed for nuclear power plants,
especially regarding accidentsJ Interim action guides for accidents
i
will be issued by 1973 and interim siting criteria and guidance will be
issued by EPA in early 197/4. Accident models foi several reactor typc-s
w'j.j.j. Da co..ipiL:ucio cy tua beginning 01 IV.O. Inc development ot siting
criteria and the issuance of gjidanca for acti«.i £or L'Ji\-ik accidents '"'
will be completed by mid-1975. Generic stc.ndai.iJs for accident prevention
techniques will be issued in later 1975 after a study of accident preven-
tion equipment has been made, and an EPA policy on siting for accidents
is scheduled for 1976. This entire effort is directed at minimizing the
effect of a release of fission products with the use of siting criteria
or accident prevention techniques.
I" thin the next «no;!th Li'A js s-.i»--'-jiej to issue 5-.- v^li-ios L^L
plowshare activities. A component of pLowsliam activities which will
receive considerable attention in the nuxt three years is natural gas
stimulation (NGS). Interim standards, including sale of Rulison produc- */
cion, tor NGS will be issued in 1973,
xxx
-------
.,*
,';
>/
>
an environmental lapacc anjlysic will |JC dtvalon-jd for NGS in 1974,
and a RC3 analysis concernins the con^orci.::. Uyr. c.; KCS will be cosploc.
in 1973 after current exper Jrents have been completed, ri.^lly, EPA
will make a dcci^on on the /u: 1 -:j,.ld r.^clop*^ cl NCS by July 1975.
All of these decisions will be consistent with the health effects model
and the benefit modal derived previously. The optL.ua program for
NGS is the sane as the proposed prograu.
By the end of 1974 a thernal effects and radiation interference
study on nonionizing radiation will be completed. At that tine mterin
guidance to Federal agencies will be given and thenaal and ..ontheraal
standards for nonionizing radiation will be issued by 1976 and 1979
(if there are nonionizing nonch^rcal radiation effects). Each of Lhese
programs will be corpletet! approximately nn* «oar ---rl-'::- -*-- o
pro^rcr^ is follc-./ed.
In 1975, EPA will issue policy suatements and standards for the
storage and disposal of radioactive wastes. By the beginning of 1979
the EPA policy on national repositories for radioactive wastes will
be forwarded.
A program that will be initiated in 1SS1 is the establishment of
standards for LLTBR exposure. The study will be b*B3-I on both the
anbient plutoninn criteria (7/75) and j-h.- irpact oC L::U ?u -230 fvfi
cycle (7/80) and ia scheduled tc be tJcpleEed m l^j
The optimum program for the last two problem areas described is
identical to the proposed program.
xxxi
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RLSOUIICE XLQUi till' -KITS
The resource requirements for thu present fiscal year along with
the resources required for the Proposed and Optimum Programs for FY 1974
are presented in Tab3c B. The cable shoT.;s the resources Ln in-house
personnel and dollars required for each o£ cighc categories; i.e.,
seven elements and a Picgran llanagement mid Support category.
The budget for FY 1973 is $4.52 raillion including the cost of a
staff of 173 in-house personnel. The proposed budget for FY 1974 is
$4.95 million. This represents an 9.5% increase over tbe FY 1973
budget. The in-house personnel required is 194, slightly vure than a
12% increase over FY 1973. The resources f1j^c&i^<\ to 1 raining and
Management do not increase in FY 1974. All of the increase ir. the FY 1974
budget is allocated to Standards, Itonitorint, av.d Euv\ror.r.^n.tal Irpact
SfcatL..-.^.itc.
As shown in the table, the FY 1974 Optimum Program budget requires
284 in-house personnel and $10.4 million, 110% more than the proposed
FY 1974 budget. In general, the allocation between the five generic
functions (Training is divided into three parts), althougti tiuch larger,
is sinilur to the FY 1974 proposed l>udr»et. In relative terns, the
Optimum Prograr.s reflects a srall increase i.i the relative importance
of Environmental Ip-pact Statement function and a slight decrease in
the relative importance of the Trailing fisnction.
xxxi i
-------
TA'iLE
!-
r--
fU '.MARY
OF
RESOUKCL: .ISQUIREMENTS
PROGRA-l
ELEMES I1
NO.
2F119C
2F2191
2F6120
2F7L93
2F7L94
2F7L95
2R1 197
TITLE
Standards (RGB)
Monitoring
ImpacL SLater-'ent
Ac-idc ,iic Ti aining
Technical Training
Direct Training
Division Management
Progrcin Management
and Support:'*
Toral
FISCAL YEAR
1973
1
Ian Years
29
66
62
-
1
15
14
173
Dollats.
(in Lbois)
757
15.8
12,7
493
67
18
348
350
45 j R
1974
(Proposed)
Man Years
35
73
70
-
1
- 15
14
194
Dollars
(in thous)
887
1688
1448
493
67
i
18
348
350
4949
1974
(Optimum)
tlan Years
50
121
86
-
3
24
14
284
Dollars
(in thous]
1949
3'o74
3366
750
50
76
550
350
10415
AOt included in totals.
-------
SECTION I
PROBLEM AND APPROACH
INTRODUCTION
This document has been developed by the Office of Radiation Programs
to provide an assessment of the Nation's radiation environmental protec-
tion needs and to present the Environmental Protection Agency's strategic
program for providing assurance of this protection. This broad national
strategy would achieve adequate protection of man and his environment
from radiation exposure, consistent with the benefits resulting from
the activity originating the radiation.
The strategy presented identifies the total environmental radiation
threat in both a short and long-term framework. The status of radiation
protection currently is in a preventive mode as opposed to a restorative
mode common to cost other pollution problems.) The principal objective
of this strategy is to control both ionizing and nonionizing radiation
sources in advance of incurring harmful effects from these sources.
The Environmental Protection Agency as the lead Federal Agency con-
cerned with environmental matters must effectively coordinate its prograa
activities with the many other Federal, state and local agencies, and
the private sector having responsibilities and interests in radiation
matters. In order to properly coordinate with these agencies, EPA must
establish clearly defined goals and develop courses of action to be
followed so that resources are expended in a cost-effective manner
throughout both government and industry.
-------
The approach used in the development of the EPA program is to:
(1) define and determine the extent of the threat;(2) develop the strategy
for attacking the problem;(3) identify the resulting program needed to
resolve the problem; and (4) establish the relationship between those
responsibilities and resources of EPA, and those responsibilities and
resources of other agencies.
NATIONAL RADIATION PROBLEM
The Threat From Ionizing Radiation
That ionizing radiation can induce ill-health in man or detrimental
effects on the environment has been clearly established. However, the
extent of the radiation threat at exposure levels currently experienced "
and the magnitude of increase in this threat accompanying any increase
in environmental-polluting radiation sources is not clearly understood.
The physical fact that radioactivity in most instances of concern
is long lasting makes the accumulation in the environment a long-term
problem. Also, a significant biological fact is that the effects induced
in man are primarily long term in nature, e.g., cancer induction and
genetic mutations, and therefore they represent an accumulation of irre-
versible effects.
How large might this threat be at currently accepted radiation limits
of exposure, such as the "FRC" guide of 170 mrem/yr for the general
population, excluding natural background radiation and the exposures
resulting from radiation used in the healing arts? Extimates of the
number of cancer deaths potentially resulting from total exposure of the
U.S. population at this level range from a few thousand to a few tens
2
-------
-:/',
of thousands per year. It has also been estimated that up to 10 percent
of the normal incidence of leukemia and bone cancer deaths might be
attributable to natural background radiation, constituting a death rate
of about 1,500 persons per year. In addition to these deaths must be
added another 5,000 or so for other types of radiation-induced cancer
and other undefinable consequences resulting from genetic mutations.
Although these are estimates based on extrapolation of some limited data,
they imply that radiation exposures should be kept as low as possible.
Perhaps a more realistic picture of the current and projected radia-
tion threat magnitude is indicated by the dosimetry data presented in
Figure 1 and Table 1. Figure 1 depicts the change with time of estimated
whole-body radiation man-rem doses with an indication of the variation
in the estimates depending on the degree of assumed control. The
specific dose values for 1970 and 2000 are shown in Table 1 along with
the control assumptions which can affect these doses. It is evident
from this table that the expanded use of radiation envisioned in the
y,ear 2000 can be achieved without correspondingly expanded risks if
appropriate control measures are instituted.
While this threat has been described above in terms of man's ill-
health, it must be noted that the threat also applies to the total eco-
system, some parts of which may have radiosensitivities comparable to that
of man. Certainly, no loss of species, even through evolution, should
be accepted as a result of man's contribution to the radiation environ-
ment.
-------
100
10
Vertical bars indicate estimated
variation in dose resulting from
varying degrees of control action.
TOTAL
' NATURAL
MEDICAL
CO
0
M
d
0.1
GLOBAL FALLOUT1
MISCELLANEOUS
(TV, air travel,
consumer products
OCCUPATIONAL
OTHER
ENVIRONMENTAL
(Mostly U & Pu,
Fuel Cycles)
0.01
I960 1970 1980 1990 2000
YEAR
FIGURE 1
SUMMARY OF ESTIMATED WHOLE-BODY RADIATION MAN-KEM DOSES IN THE
UNITED STATES
4
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TAB!
RADIATION DOSE AND EXTRAPOLATED HEALTH EFFECT ESTIMATES
FOR THE U.S. IN 1970 AND 2000
SOURCE
N'atural
Medical
Fallout
Occupational
Other Environmental
Miscellaneous
(air travel,
consumer products,
TV)
TOTALS'
FRC Guidance
YEAR 19708
mrem/person
130
74
4.0
0.8
0.06
2.6
211
170
man-rem
26,600,000
15,200,000
820,000
160,000
12,000
550 , 000
43,300,000
35,000,000
V.
Extrapolated1
No . of cancers
(at 1 c nicer/
7000 maii-rcm)
3,830
2.2001
120
23
2
80
6,200
5,000
YEAR 20008
(range estimates)
man-rem
35 , 300 , 000-41 , 700 , 000a
9 , 600 , 000-48, 200 , 000b
1 , 000 , 000-2 , 000 , 000°
280, 000-560, 000d
47, 300-240, OOO6
360, 000-690, 000f
46 , 600 , 000-93 , 400 , 000
(145-290 mrera/person/yr)
55,000,000
Extrapolated
No. of cancers
(at 1 cancer/
7000 man-rem)
5000-6000
.1400-69001
140-290
40-80 '
7-34
50-100
6600-13,400
7900
bAssu-acd natural could be reduced by up to 20 mrera per person (by control of construction materials).
Assumed range of 30-150 mrcm/person/year
Assumed. range of 3.5 - 6 mrcm/person/year
eAssu:iied doubling of original estimate because of poor health physics
Assumed variations in controls on reactors and fuel reprocessing plants, depending on the amount of
holdup of Kr-85 and H-3.
consumer products contribute 0.01 - 1 mrem/person/year
Assumed 3iJl x 10° people in U.S. in year 2000 (reduced population implies reduced man-rems) . (Used 205 x 106
people in U.S. in year 1970.)
All doses are whole-body doses except medical doses which are based on an index of somatic dose. Estimated
^.cancers are based on these doses and thus exclude any additional cancers due to organ-specific doses.
This estimate may be subject to additional uncertainty dus to the nature of the irradiations and to preselection
of the exposed population, although the dose quoted IP due to diagnostic, not therapeutic, uses.
Note: It is estimated that the additional total genetic damage, expressed in terms of "ill-health" being
proportional to the mutation rate, .from an c:
-------
In most instances, the release of radioactivity into the environ-
ment Is an irreversible act. Therefore, to keep the radiation threat
as low as possible, steps must be taken to insure that for the control-
lable radiation, exposures are allowed on the basis of their meeting
a necessary need for man or his environment. Controlling unnecessary
exposure allows more beneficial uses of radiation without increasing
the threat. An approach to this "saving for the necessary" can be made
on a risk/cost/benefit basis for guidance for certain general classes
of application such as nuclear energy, consumer products, and the
healing arts. Specific sources can be controlled by radiation guides
which consider ill-health risk, benefit of the application or source,
and the cost of control. This cost in most instances will be substan-
tial; therefore, the need for expending the resources must be carefully
considered.
Associated with the Agency's articulation of the effects of radiation
on man and his environment must be the recognition that certain knowledge
is not available which allows a better definition of the threat. This
recognition requires continuous assessment of the threat presented.
Models which permit estimates of exposure, specific radionuclide transport
coefficients through the environment, and of health effects(are available,
but must be continually'evaluated to assure their applicability to new
sources and to new radionuclides.j In addition, continuing research and
/
development must be conducted to improve radiation control techniques
-------
and methodology, such as methods for managing the significant quantities
of radioactive waste from nuclear power plants and other nuclear facili-
ties. At present our methods for waste handling are inadequate to cope
with the projections of quantities to be produced in the future. The
ability to define and control the radiation threat, particularly the
long-term threat associated with exponentially increasing sources with
their pollution potential, will be strongly dependent on how well we
develop and apply the best available models, with minimum uncertainties,
and the best or at least a favorable cost effective control technology.
The Threat From Nonionizing Radiation
Background of Problem
The pollution of the environment by nonionizing electromagnetic
radiation (e.g., from sources such as broadcast and ccasnunications systems
and radar, microwave ovens, medical diathermy devices, and industrial
heating equipment) is rapidly increasing. There is cause for concern
because of the alleged existence of nonthermal bio-effects and the uncer-
tain importance of these effects at low levels; in addition, the criteria
for setting an acceptable level of exposure, either for thermal insult
or interference effects, have not been defined for the population at
large. A careful determination of current nonionizing environmental
radiation levels, their rate of growth, and a knowledgeable evaluation
of low-level effects are needed to assess 'the present and future impact
of electromagnetic radiation on health and the environment.
-------
In the U.S. guidelines for permissible exposure of the general
public in non-occupational situations have not been developed. The
current occupational standard could be used; however, exposure to
electromagnetic radiation is but one of several sources of heat input
into the body. In occupational situations it is presumed that the ambient
environment can be controlled or the exposure level reduced to compen-
sate for additional sources of heat; however, this is not the case for
non-occupational situations, and if a guideline for the public at large
is set on the basis of thermal insult, careful consideration must be
given to determining the characteristics of the population that are most
sensitive to heat stress.
Serious questions can be raised concerning the use of -a thermal
basis in setting population exposure standards. First, there is the
possibility that low-level nonthermal effects have a real impact on
health and one must determine a proper threshold value which is safe
and detectable by simple and reliable measurement techniques. Second,
interference with electronic devices which are important to health or
the quality of the environment occurs at radiation levels below those
required to heat tissue; these interference effects must be considered
in arriving at acceptable levels.
Magnitude of Threat from All Nonionizing Sources
Short Term. At the present time only qualitative indications of
threat can be made because of large uncertainties about the ambient
levels of nonionizing radiation in the environment, the rate at which
-------
levels are increasing, and the effects of low levels. The two types of
exposure which are of concern are: (1) the exposure of the entire
population to low levels which result from the superposition of the
fields from multiple sources and (2) the exposure of smaller groups to
potentially higher levels in the immediate neighborhood of specific sources.
The multiple-source/general-population-exposure problem comes
principally from radiofrequency and microwave sources. Ambient levels
already exist which are in the range of uncertainty for the onset of
2
nonthermal effects (10 microwatts/cm ) and which do interfere with health
related devices such as cardiac pacemakers and essential communications
systems. The highest population exposure is thought to occur in urban
areas and in the vicinity of airports, military installations, and
satellite tracking centers.
The exposure to specific sources at potentially higher levels covers
the entire range of frequencies. Exposures in the infrared and visible
portions of the spectrum occur principally in industrial, medical,
research, and military applications. Exposures to frequencies below the
infrared include all groups. Consumers are potentially exposed to
leakage from microwave ovens and radar on pleasure craft. Potential
industrial exposures include areas such as laser applications, infrared
from hot bodies, leakage from microwave drying processes, and occupational
exposure in the vicinity of fields of AM, FM and TV broadcast stations.
Medical applications include 'intentional exposure of patients to lasers
and to microwave and radiofrequency diathermy and the potential inadver-
tent exposure of medical personnel. Individuals engaged in research
-------
are potentially exposed to all frequencies from many different applica-
tions. Military personnel are potentially exposed to devices such as
lasers (range finding), infrared surveillance systems and radar.
Long Term. The number of radiofrequency and microwave sources is
estimated to increase 15% each year. This rate of growth may increase with
new applications and advances in technology. Cheaper microwave and
laser sources are becoming available. Recent technical advances are
opening up the frequency band above 10 GHz for communications. High
power microwave systems have been proposed for use in agriculture as a
substitute for herbicides and pesticides. By 1975, it is predicted that
the annual sales of microwave ovens for the home will reach 200,000.
Industrial and medical applications of heat treatment processes will
increase. Radars are being installed on small boats used for recreation
and the number will increase as prices are reduced. (Radar collision
, /;
avoidance systems for automobiles are in development stages.' /Microwave
power transmission of converted solar energy from satellites to large
c
antennas on the Earth's surface has been proposed as a significant
electrical energy source for the year 2000. )
Environmental ana Health Effects
The direct health effects resulting from exposure of the entire
population to the ^superimposed total of low levels from multiple radiation
t .
sources cannot be determined with confidence. Contributing to this
uncertainty is the controversy over the existence and importance of
low-level nonthermal bio-effects and the limited information that is
10
-------
currently available on environmental levels and their rates of growth.
The resolution of the low-level nonthermal chronic exposure problem
depends upon the results of ongoing and planned research and is several
years away. The effort ar.^r-",-'::aE:r....-^.t .diaitations imposed on the size
of the device as is the case for cardiac pacemakers and hearing aids.
Interference is also a problem for commundcations, especially land mobile
radio used by fire, police and emergency services and consumer products
such as interference with AM, FM, and TV reception.
Thermal versus Nonthermal Biological Effects
Two types of biological effects are distinguished: (1) those due
to tissue heating which are called thermal, and(2) those due to some other
mechanism which are called nonthermal.
Thermal Effects. Exposure intensities high enough and of duration
long enough to generate heat can cause adverse health effects. In
addition to physiologic heat stress, cataract induction and impaired
11
-------
testicu'lar function are thought to be important effects. Permissible
levels of exposure for occupational activities in the U.S., both civilian
and military, are set solely on the basis of heat generation. Implicit
in this standard is the assumption of a threshold, i.e., the heat
produced at or below some power -.V^A'. ,.-^.'-;..j.- falls well within the
heat dissipation capacity of the ir^^-'.Uted individual. If a thermally
based standard is chosen for the protection of the general population,
it will probably need to be set at a level lower than that used for
occupational exposure to provide protection for individuals which, due
^
to their state of health or other reasons, are more sensitive to heat
stress than individuals exposed occupationally. fHowever, once such a level
is chosen, it defines an amount of exposure which can be allocated to
various sources on a priority basis which is independent of health J
considerations.
Nonthermal Effects. Studies of nonthermal biological effects con-
ducted in the USSR and many Eastern European countries have been oriented
toward effects related t& the central nervous system; the overall con-
clusion arrived at through such studies is that biological systems are
more sensitive to nonthermal effects on the central nervous system than
to direct thermal effects. In the USSR these effects are given serious
weight and the guidelines for permissible occupational exposure are
100 to 1,000 times less than those used in the U.S. depending on the
exposure conditions. The USSR and Eastern European exposure standard
2
of 10 microwatts/cm for occupational exposure in the microwave frequency
range represents a lower bound for the onset of nonthermal effects.
12
-------
It is important to note that there is considerable controversy over
the existence of nonthermal effects in the extremely low frequency,
radio frequency and microwave frequency ranges and their hazard potential.
It is not likely that the controversy will be resolved in the next few
years. /However, current research programs and the recent five-year
program recommended by the Electromagnetic Radiation Management Advisory
Council to the Office of Telecommunications Policy should remove a
great deal of uncertainty in this area.' It is also important to note
that ambient levels now exist in the environment that approach and
exceed the lower bound for the onset of nonthermal effects.
HEALTH RISK RATIONALE
Biological and material damage occurs as a result of exposure of
organisms and devices to ambient radiation levels which exist as a
result of a multiplicity of ionizing and nonionizing radiation sources.
To minimize effects or damages, primary control must be applied to the
radiating sources. As shown in Figure 2 there are other areas where
control may be exercised although source control is generally the most
effective.
This figure depicts the several steps involved in ascertaining
health effects from a given source. If one considers a nuclear power
plant as a typical source there are three ways "radiation" may be trans-
ferred from the plant to human beings. Radioactive isotopes may be
released via liquid effluents into rivers or via airborne particulate
emissions through the stack. Under normal operating conditions these
13
-------
SOURCE :
AMOUNTS
RADIOACTIVITY
(CURIES)
RADIOACTIVITY
(CURIES)
RADIOACTIVITY
(CURIES)
MEASURED
CORRELATED
EFFECTS
DEATHS.
PAMPPP
MORBIDITY,,
GENETIC
ETC
SOURCE
CONTROL'
pcpi IICIMT*;
CMICCIftMC
tMloolUIMo
omtLUIIMo
EFFECTS
^^
INDIVIDUAL!
HEALTH j
EFFECTS '
POPULATION
HEALTH
EFFECTS
CfVIWI DOMIW1CMT A 1
EFFECTS
S j
(*
^*
ik.
PATHWAY
'CONTROL :
PATHWAY
MODEL-
bMrt nILAL
CTI miPQ
EFFECTS
MODEL- !
!
EMPERICAL1
STUDIES, ;
ANALYSES '
^" ~^
1 1 I>
E
"\
CONCENTRATIONS
AMB'ENT
LEVELS AND
BACKGROUND
(CURIES/m3)
XPOSURECONTROI
EXPOSURE
MODEL-
EMPERICAL
STUDIES AND
EXPOSURE
MEASUREMENTS,
cLJiri niMf;
DISTANCE
(ROENTGENS)
DOSE
DOSE
MODEL
(REM)
<| J
RADIATION
FIGURE
CONTROL MECHANISMS AND HEALTH EFFECTS
-------
releases are carefully controlled (slowly and in minute quantities).
The third transfer mechanism is by direct radiation of neutrons and
gamma rays (alpha, beta and other charged particles present no danger
in this mechanism except possible for workers in the immediate vicinity
of the reactor equipment). Even for the non-charged radiation (Qn, Y) / /-'' , /.
the direct radiation effects beyond the site boundaries are negligible / ^/^ ^-_.
due to air attenuation and the "inverse square" law. -* /I' ] >^'
For the radioactive particles, source control implies the use of ' '
holdup tanks (so that short-lived isotopes may decay to insignificant
levels before discharge) in conjunction with dilution with large quan-
tities of air or water. For hazardous spills or minor accidents, the
radioactive wastes may have to be bottled for permanent storage else-
where. For the direct radiation, source control implies the use of
shielding in conjunction with requiring a large distance between the
source and the potentially exposed population.
Pathway control applies to the two categories of radioactive iso-
topes (airborne, and waterborne), in the particulate or gaseous state.
For example, airborne particles may be deposited on the ground, be absorbed
by grass, eaten by a cow and appear in the milk supply. Probably the
easiest way for providing control in this pathway would be to impound
a particular batch of milk. A corollary control mechanism would be to
convert the quickly spoiled milk into cheese. This technique is effec-
tive if the isotope(s) in question is short-lived since cheese can be con-
veniently stored for long periods of time before releasing for consumption.
15
-------
In the first phase the "concentrations" step is concerned with the
ambient levels of particulates and/or gases in one's immediate surround-
ings (air and water). These levels would be an indication of the poten-
tial radioactivity that could be inhaled or injested. Control here might
be in the form of using one's air conditioner to filter much of the
particulate matter out of the air. The second phase of "concentrations"
would be in the body itself. One form of control would be drinking
large quantities of liquids in the attempt to eliminate the radioisotopes.
In this section exposure control refers to che radiation field
surrounding a person as opposed to the concentration of radioactive
particles. The former affects the body from the outside while the latter
(for all practical purposes) is considered to affect the body internally
through inhalation and injestion. Elsewhere in th*s paper "exposure"
generally refers to the radiation field together with the ambient con-
centrations. For this diagram, however, it is desirable to differentiate
between internal and external (to the body) radiation. As mentioned
earlier such exposure control is unnecessary for an atomic power plant
since the general population is too far removed. However, there may be
workers in or near an atomic power plant who would benefit by having
shielding surround their particular work areas. This shielding is
opposed to that which surrounds the source itself.
The next step involves computing the dose to various organs of the
body once the external exposure and the injested concentrations of
radioactive materials are known. The dose due to injested (or inhaled)
16
-------
isotopes is more difficult to ascertain since it requires a knowledge
of how the isotope behaves chemically in the body; in other words, does
a particular isotope migrate to selected organs of the body or is the
effect uniformly distributed? Another question involves possible syner-
gistic effects from doses to different parts of the body. In this step
there is little meaning to talking about control.
The dose levels having been ascertained, the many different kinds
of effects (to individuals, to populations, and to other living organisms)
can be analysed. Currently two hypotheses prevail for assessing biologi-
cal damage from electromagnetic and particulate radiation. The first of
these indicates that there is some threshold below which no apparent
permanent damage is incurred. This implies that there is a level where
the injury is balanced by a recovery or repair mechanism. The second
hypothesis assumes no threshold and further assumes that permanent
damage is linear with dose. This theory is based primarily on genetic
consequences and assumes no recovery or repair mechanism. It is further
assumed that mutations in general are deleterious.
The significance of these hypotheses is shown graphically in
Figure 3. This graph depicts the level of dose in microrems required
to produce a given effect for a particular population level. For
4
example, 10 microrems (10 millirems) can be expected to produce one
death per 10 exposed population, while one millirem would produce one
death per 10 million population exposed. These estimates are based on
a linear model which is bounded by an optimistic and a pessimistic
17
-------
<«
ta
O
H
U
Cfl
H
a
e
Q)
M
O
M
O
H
II
00.
4-1'
-H
10'
10
10'
10
10"
10
10'
io2
-.xl:
High Level
Validation
Threshold Concep
Mean of Optimistic
Non-Linear Model\
N
Invalidation \ \
j \
Deaths
Cancers
Genetics
Increased
*- Sensitivity ?
Mean of Background
' k = 1
Mean of Pessimistic-
;Non-Linear Model
10° 10
10
10 '3 10
10 5 10 6
10
10
10
.Population at Risk
FIGURE 3
'LEVEL OF DOSE REQUIRED TO PRODUCE
ONE GIVEN'EFFECT PER POPULATION AT RISK
18
-------
limit.' The pessimistic limit suggests that a dose of 10 millirem would
produce one death per 10 population exposed. Curves depicting non-
linear models are also shown. The LD-50 (dose which would be lethal
for 50 percent of the population exposed) can be found in the upper
left-hand corner to be about 450 rem. The threshold concept implies a
dose level below which there are no deleterious health effects regardless
of the population; in this case the dose level is about 5 x 10 microrems
(500 millirem). For doses above this level the linear model would apply.
The information in Figure 3 is still subject to further scudy. The
curves are approximate and are primarily intended to present concepts.
In fact, the dotted regions of the graph depict the only regions where ^ *>* 'J^
reliable data are available. It should be pointed out that the uncer-x2o*4 ' '
tainties in radiation-related data are in general much less than those ?te^ "
/<^f
for other environmental topics (nonradiation air, water, and land ./. '
pollutants - pesticides, noise, BOD, etc.). The dose axis has a sliding
scale using a coefficient k which is given as "1" for the effects of
death and cancer. The coefficients for genetic effects have only recently
been quantified and those for increased sensitivity effects are not
presently known.
The radiation protection philosophy currently used internationally
is the non-threshold hypothesis that any radiation exposure carries with
it some associated risk. This is the health effects model used by EPA
with the further stipulation that a necessary (but not sufficient)
condition of any permitted radiation exposure is that definable benefits
19
-------
must be demonstrated. In order to develop a radiation protection stra-
tegy consistent with this approach, a rationale has been promulgated
which utilizes a risk/benefit concept that is inter-related to a
cost-effectiveness evaluation of control technology upon which the
establishment of environmental radiation standards can be based.
AUTHORITY
The Environmental Protection Agency has available two primary
sources for its authority to conduct radiation protection programs:
(a) the general Federal radiation guidance function of the former Federal
Radiation Council, with its specific statutory authority; and (b.) the au-
thority formerly vested with the Atomic Energy Commission to set generally
applicable environmental radiation standards, which has no specific
statutory basis. Also transferred to EPA from the Department of Health
Education and Welfare (DHEW), was the authority to protect the public
health with regard to radioactivity (Section 301 of the Public Health
Service Act, 42 USC 241). Included in this transfer were program areas
such as (a) collation, analyis and interpretation of data on environmental
radiation levels; (b) research and epidemiology on radiation exposure
to man; and (c) technical assistance to the States, in addition to other
related functions. These authorities were transferred to EPA by
Reorganization Plan Number 3 of 1970. In addition to these specialized
radiation authorities, the Agency has a prime responsibility to provide
comments on Environmental Impact Statements to other Federal agencies as
20
-------
required by Section 102-C of the National Environmental Policy Act
(NEPA) of 1970,
The transferred Federal Radiation Council functions give EPA the
responsibility for examining all radiation threats and providing, through
the President, guidance on radiation protection policy to all Federal
agencies. The environmental standards-setting function transferred from
the AEC gives the Agency the direct responsibility for setting standards
for radiation exposure or radioactivity concentration limits in the
general environment outside the boundaries of facilities under the
control of persons licensed by the AEC or by Agreement States to possess
or utilize radioactive materials. The responsibilities transferred
under Section 301 arc sn integral part of the operating program of ORP.
Two possible sources of authority which may be utilized by EPA
are contained in the Federal Water Pollution Control Act and in the
Clean Air Act. Additional authority exists in Section 4, paragraph 6,
of Executive Order 11507, "Prevention, Control and Abatement of Air
and Water Pollution at Federal Facilities," stating that
"Discharges of radioactivity shall be in accordance with the
applicable rules, regulations, or requirements of the AEC and
with the policies and guidance of the Federal Radiation
Council as published in the Federal Register."
The subsequent transfer of these functions by Reorganization Plan Number
3 of 1970 constitutes an additional legal .basis for Agency activity.
With regard to the discharge of radioactivity into navigable waters,
the Permit Program of the River and Harbor Act of 1S99, commonly known
as the "Refuse Act," provides EPA the opportunity to establish the
21
-------
applicable radiological criteria, with the U.S. Army Corps of Engineers
currently being responsible for enforcement of the permit system.
In general, the implementation of EPA program activities is con- '^7*
ducted in specific areas; however, through exercise of the guidance
functions inherent in EPA author .:-, *.:-.«": ;;-:.icy may exert influence on
the radiation policies of other ageac.jp.s in order to meet the overall
objectives of the national radiation strategy. This concept of leverage
enables the Agency, with its limited resources in the radiation area,
to produce a significant impact on radiation protection policy through
such activities as standards setting, guidance to other agencies and
and NEPA review. These mechanisms are considered essential for the
Agency since EPA Joes not have enforcement authority in the radiation
area.
STANDARDS
Types of Standards
The types of standards most useful in protecting or maintaining
a given level of environmental quality may generally apply to sources,
media, or resources. In the case of radiation, for example, source
standards apply to a specific activity and are designed to limit the
total environmental or human health threat which may occur from that
source. One would determine a standard in terms of a certain allowable
radiation dose per year within varying distances from nuclear power plants.
Media standards, on the other hand, would deal with specific allowable
radioactivity concentrations in soil, water and air, with a limitation
applying to each medium regardless of the source or activity contributing
22
-------
to the-ambient level. Another method of achieving protection from radiation
is by setting standards which apply to utilization of various resources.
These standards would generally limit or regulate the manner or the amount
of use of the resources. For example, uranium ore extraction and pro-
cessing might be limited to -''i?^t'r-il>. u*»r-" cate, and criteria for
i
power plant siting might affecteL-.:,^-.-- .-^.-.r-of locations on which nuclear
plants could be built.
Methodology for Setting Standards
The establishment of a standard requires that a specific strategy
or method be utilized for the quantitative derivation of the applicable
numerical standards.
The following nethodologies arfv-osf-Irequeutly used:
A. Zero Emission - Zero Risk:
The underlying theory is that in order to have zero
environmental or human health risk due to an activity
it is required that there be zero emission of pollutants
to the environment. This approach eliminates the environ-
mental health risks associated with the activity. The
cost of implementation is usually prohibitive; in many
cases the only way to accomplish the objective is to
halt the activity; otherwise this approach can result
in expending too many resources to sustain a particular
activity.
B. Best Available Technology:
This approach is based on the philosophy that the best
methods available for reducing pollution or emissions
23
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUBJECT: Distribution of EPA/ORP Radiation Strategy DATE:|^/\Y 31 1973
FROM: Deputy Assistant Administrator
for Radiation Programs
TO: Administrator, Region V
This is in reply to the memorandum from James M.
Conlon, dated May 16, 1973, subject as above, and
received by me on May 29, 1973.
The policy on distribution of the Radiation,Strategy,
as I stated at the Portland meeting, is as follows:
a. The "blue" portion of Vol. 1, which is the
summary, may be distributed to State agency
personnel after deletion of budgetary information.
b. The remaining portion of Vol. 1, and Vols. 2
and 3 may be made available for review in your
office by State agency personnel. At this time
copies of the three-volume set should not be
distributed outside of the Regional Office.
cc: Regional Administrators
EPA Form 1320-6 (Rev. 6-72)
-------
should be utilized. Factors favoring this approach are
that additional environmental contamination and the
associated health risks from the particular activity
are held to a minimum. On the other hand, cost may be
prohibitive. As tecir .' -....-.Droves, the activity may
have to upgrade new emission control equipment frequently.
In some instances, this approach may require installation
of emission control equipment that is not cost-effective.
C. "Lowest Practicable"Technology:
The basic philosophy in this approach is that emissions
should be kept to a level that is "as low as practicable."
Utilization of this apprn?r.K keeps emissions and asso-
ciated health risks to a low level; the cost of emission
control equipment and alternative courses of action would
affect the amount of emissions allowed. This approach,
however, allows greater risk than the first two approaches;
/neither benefits nor risks are necessarily considered.^
D. Cost-Risk Balancing:
The basic philosophy in this approach is that the cost of
reducing an emission should be balanced against the
environmental and health risks associated with that
emission. This approach keeps' health and environmental
risks low by considering the practical parameters of
cost-effectiveness and public health assurance. Use of
-------
this approach, however, allows greater risk than the first
two approaches (A and B), and requires difficult qualitative
and quantitative balancing of costs versus known or assumed
risks.
E. Balancing of Risk/Cost/Benefits:
This philosophy is based on ihe approach that the benefits
created by an activity should be cost-effectively balanced
against the associated risks. This approach keeps health
and environmental risks at a low level; it requires that
environmental or health-risk producing activities have
offsetting benefits. Allowable risks, however, may be
greater than for the first two approaches; it requires a
difficult assessment and balancing of- benefits and risks .v
The RJsk/Cost/Benefit Methodology for Standards Setting
Standards, whether they be dose standards or specific radionuclide
standards, should be based on the concept of considering the risks,
costs, and associated benefits. The former type of standard would involve
a recommendation of an overall guidance number for a particular type
radiation source, e.g., nuclear power, which would be principally
based upon the determination of health risks. This would imply the
public acceptance of a potential radiation risk comparable to the
potential for other types of risks, such as from air pollution or auto-
mobile accidents. Within this general overall guidance, dose allocation
could be addressed which would involve the determination of risk, expected
25
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cost of risk reduction (control), and a judgement of the benefit to be
derived from a particular type of application. (The major question
]
would be how to make this judgement./ Would, for example, the use of
\J
diagnostic X-rays be judged to have a benefit factor of one, whereas
the use of radium in luminous eli&'ls faVeati benefit factor approaching
zero?
Perhaps the most needed standards or guides that should be defined
are those for specific radiation applications and specific radionuclides.
Examples might include various types of nuclear power plants, fuel repro-
cessing plants, radioactive burial grounds, or radium in drinking water.
Also the evaluation and establishment of criteria for siting of facilities
and a careful evaluation of the. multi-j ].£* regulations which exist for
their control are interrelated with these aforementioned specific
standards.
The establishment of standards, numerical or otherwise, can have
great impact upon the risks which the population assumes for various
threats which result as side effects from otherwise beneficial actions.
Standards set too low imply extra direct expense which eventually
through either higher taxes or prices is paid for by the public at
large. Standards set too high imply increased health and environmental
risks which indirectly may have higher cost to the population through
higher medical bills and environmental cleanup costs. The risk/cost/
benefit means of setting standards ak.temp.ts to balance the risk and
benefits in a cost-effective manner for a given period of time to achieve
the proper balance in determining the standard.
26
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While it is a fair method of setting standards, this methodology
is a difficult one, since it requires the quantifications (within limits
of uncertainty) of intangible measures in many cases. This inherent
limitation can be overcome to a large degree by recognizing that much
of the quantification involv4-.iiV.ir s^Ae th: ? .gh value judgements. All
methods of setting standards uS-e /a/.ua.judgements. These value judgements
can be made, not only by people having special expertise, but also to a
degree by the people who are involved in assuming the risks and benefits
directly. Within limits of uncertainty, value judgements can be mean-
ingfully made visible, traceable, and repeatable.
Another facet of the risk/cost/benefit methodology for standards
setting involves the dynamic nature of the balances. Although a balance
between risk/cost/benefits may be achieved for a given period of time,
both risks and benefits, along with the associated costs of achieving
these, change over time, requiring a new balance point to be found.
Under these circumstances it is necessary that future risk/cost/benefits
be projected and taken into account/in order to allow a standard once
set to remain so for a long enough time for it to be effective. Changes
in the standard may be scheduled in advance on a periodic basis, con-
ceivably based upon the achievement of cost-effective control technology
for particular parameters upon which the standard is based. But in
any case the period of change must be long enough for industry to adapt
to these standards and to anticipate changes through a predetermined
schedule.
There are two levels at which risk/cost/benefit methodology must
be applied. The first case is for generally applicable standards which
27
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are for major types of sources. The second case involves setting a
standard based upon a particular activity affecting health and the
environment which requires a risk/cost/benefit analysis to be made in
terms of that specific activity. The methodology must then cover both
general and specific cases. Because of their greater generality,
^9
/generally applicable exposure standards will be based on a risk/cost/
benefit methodology which has higher levels of uncertainty than that
for specific cases. ) This will be required because it is harder to
quantify general terms than specific ones.
It must be understood that uncertainty will always exist in the
standards setting process since parameters involved can never be measured
to an absolute degree, nor can intangibles be quantified below certain
levels of uncertainty. However, in the development of these standards
the limits of uncertainty can be ascertained and reasonable value judg-
ments made.
For a standard relating to the general population, projections
must be made for all environmental actions from all sources using
risk/cost/benefit methodology.
For specific situations which have environmental impact, a risk/
cost/benefit analysis should be made to determine either acceptable
standards for the environmental impact in terms of the allocation of
dose or to evaluate the environmental impact in terms of an impact
statement. Figure B, the Risk/Cost/Benefit Overview, illustrates the
process that is involved. The proposed action is undertaken for some
benefit, such as generation of nuclear power or a plant for treatment
of domestic wastes. The various alternative actions may be considered
28
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ro
vo
WORTH
LONG-TERM
AND
SHORT-TERM
PROPOSED ACTION
TO OBTAIN SOME
BENEFIT OR DECREASE
ADVERSE EFFECTS
WORTH TO
INVESTOR
WORTH TO
PUBLIC
(INCL GOVTJ
ADVERSE
ENVIRONMENTAL
EFFECTS
ADVERSE
HEALTH
EFFECTS
ECONOMIC
COSTTOPU3LIC
(INCL GOVT)
' ECONOMIC WORTH
OTHER
ECONOMIC WORTH
HtALTII BENEFIT
CONVEN11NCE BENEFIT | &
AF.STHF 1IC UbNEFIT
ENVinONMUMI AL BENEFITS
OIIIHII [jENEfllS
IDENTIFI-
CATION OF
POPULATION
RECEIVING
BENEFITS
INVESTMENT
TRADE-OFF AND
ANALYSIS
RETURN ON
INVESTMENT VS
RISK
OIIP APFA OF DIRECT RESPONSIBILITY
r-
AMELIORATIVE
ACTION
RESULTANT
ENVIRONMENTAL
EFFECTS
COST OF ACTION
I.1 RESUL
' '"]_ BENEF
RESULTANT HEALTH
BENEFITS
COST EFFECTIVENESS
ERIA
V
COSTS-
BENEFIT
ANALYSIS
MATRIX
r
IDENTIFICATION
OF POPULATION
PAYING COSTS
1
J.l'.._".7. .UI^J TOTAL COST TO PUBLIC
COST TO THE
INVESTOR
ECONOMIC
FIGURE B
TOTAL COST TO
INVESTOR
RISK/COST/ BENEFIT OVERVIEW
-------
and must each go through the same process to be described here so that
they may be evaluated against each other.
For this action there are both long and short-term costs and long
and short-term worth as a result of the proposed action. The worth or
benefit is focused on at least two groups, the investor who is initiating
the action and the public at large, including the government. The
investor primarily looks at worth in terms of income. This income is
offset by the capital and operating costs over time with the proper
discount rate. The balancing of the income and costs over time allows
one to make an estimate of his return on investment versus the risk in
achieving that planned return. The public also receives benefits which
may be economic in terms of both direct cash and indirect monetary
benefits. Also, there may be benefits in terms of health, aesthetics,
convenience, indirect benefits to the environment, and acquiring valuable
information. These benefits, tangible and intangible, are received by
different groups in the population and the group that bears the cost
is not always the same group that achieves the benefit. However, it is
these benefits to the various groups in the population that must be
balanced against the costs to the population.
On the cost side, there are direct costs to the investor and indirect
costs to the public. The costs to the investor are again primarily
economic, but the costs to the public include not only economic costs
but the cost involved in adverse environmental and health effects. In
order to reduce health risks and environmental effects, there are a
variety of ameliorative actions that may be taken to reduce effluents
from a plant. However, each of these actions has a certain cost
30
-------
associated with it which must be borne indirectly by the public or
directly by the investor or a combination of the two. The choice of
actions taken can be governed by a cost-effectiveness criterion which
relates the cost of the action to the reduction in environmental impact
of health effects. This cost-effectiveness criterion is illustrated in
Figure C. The degree to which the cost effectiveness criterion can be
applied depends upon the degree or departure of the curve shown from
a linear relationship. The more the curve deviates from the linear
relationship, the higher the degree of applicability of this criterion.
/The cost-effectiveness criterion is to select a point on the knee of
the curve where one gains a great deal of effectiveness for a much smaller
cost than at other pointsJ Assuming that fixed and comparable units
for both costs and effectiveness can be obtained, the criterion for
selecting the knee is where the slope of the curve is unity. At this
point the marginal cost equals the marginal effectiveness; to the right
of this point one gets decreasing effectiveness for every dollar spent.
This is a dynamic concept and does not involve putting a dollar value
on a health effect but determines, for example, the point where further
expenditures for reducing a health effect have less impact than those *,... . 'f
t^p ' 'i
to the left of the point. <^<-ii-/ f
As a result of applying this cost effectiveness criterion, the 't""f''-l.^
resultant costs to the public, both tangible and intangible, may be "^
determined along with the particular groups in the population which
bear the costs. The increased cost of ameliorative action must be added
to the direct costs and in terms of the investor this is what he
balances his return on investment with; while for the public a risk/
31
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Slope = Unity, i.e. AC= AE /
0)
LU
. DEGREE OF DEPARTURE /
Note that Actions are Basically Discrete.
0
(C) Cost
Figure C. Cost- Effectiveness Criteria
32
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cost/benefit matrix must be used to determine the relative risk/cost/
benefit impact.
The nature of this risk/cost/benefit matrix and its application is
shown in Figure D. Three different matrices are shown, one behind the
other, to illustrate the point that the balances must be made at diff-
erent points in time. The first indicates a balance must be made in
terms of the initial investments involved at the time the project is
undertaken. The second one indicates that when problems of operation
are added to the initial investment, another benefit balance must be
made; and finally the balance must be made in the long term.
The matrix compares the costs on the vertical axis and the benefits
on the horizontal axis. Within each category of costs the different
groups in society upon whom the costs are levied may also be shown.
The benefits are shown in the same manner. It is important to note
that balances can only be made on the diagonal elements of the matrix.
The off -diagonal elements indicate possibilities for cost effectiveness
criteria but may not be used directly in the balancing. /Thus, it is
not valid to put dollars on a health effect, but a health effect may
be traded off against other health effects. For example, the health
effects due to radiation from a new nuclear power plant may be offset ,//".
C- J ,<* '" />
by the health benefits derived by preventing brownouts and blackouts. «// ^. '//
* 0.)* it*
In other words, health effects may be traded against health effects^/, "
aesthetic effects may be traded off against aesthetic effects, and ffe* / '
«y
costs to the investor may be traded off against the economic returns ^
i It'-
ll H "~ '
to the investor// q
'i
33
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\
^v
>w
X. BENEFITS
X°
COSTS ^.X.
COST TO INVESTOR
COST TO PUBLIC
GROUP A
GROUPS
0
0
e
o
e
HEALTH COSTS
GROUP A
ENVIRONMENTAL COSTS
GROUP A
AESTHETIC COSTS
GROUP A
CONVENIENCE COSTS
GROUP A
OTHER COSTS
GROUP A
cc
O
co
LU
>>
WORTH TO IN\
II
t = 0
a
j
CD
=) <
WORTH TOP
GROUP
Wm
l.'if !':!^
:-r:: '.:.."
CO
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:sjj:;J!!f
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o e e'<
'
F ' r I '
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LL
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GROUP A "
il" ',
CO
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ENVIRON. BE
GROUP A
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u.
LU
LU
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GROUP A
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CONVEN.'BE
GROUP A
^ ! 1 i i
lj|fij!
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U)
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GROUP A
iTi'j
W
f4i
n
INITIAL
t = 1
SHORT TERM
t=2
LONG TERM
DIRECT-TRADE-OFF
COST-EFFECTIVENESS TRADE OFF ONLY
FIGURE D
RISK/COST/BENEFIT ANALYSIS MATRIX
34
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While it makes sense to trade health effects versus health effects,
one must be careful to assure that the units involved in the measure-
ment scale are totally consistent. Thus, for health effects, there
may be chronic health effects, acute health effects and episodic health
effects. Thus, even the 'bal-g&ece.aff -K£ "JI^Hff. -t&r^yg is not necessarily
straightforward.
/The objective in the risk/cosL/benefit balancing is to assure that
for each diagonal intersection that the benefits outweigh the costs or
risks at that point/. If they do not, actions may be taken to reduce
the costs or increase the benefits until a balance is obtained. Each of
these actions causes changes in either the economic costs or benefits.
Presumably, as these actions take ?]-rr} the cost to the investor will
rise, and as long as his return on investment is adequate, the project
will presumably take place. Thus, the process is attempting to balance
each diagonal intersection until the benefit is equal to or exceeds
the cost.
It is conceivable in a variety of situations that there may be
some diagonal intersections which cannot be balanced. For example, it
may never be possible to balance the aesthetic effect of an open piece
of land versus the construction of an industrial facility. In this case
a straightforward risk/cost/benefit balance may never be obtained and
one must go to the off-diagonals intersections to determine how far
one should go on a cost-effectiveness basis and when this is inadequate,
rely strictly upon value judgment since no information is available.
When value judgments are required, the problem then is who makes the
value judgment. One criterion is to look at the value groups affected
35
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and to benefit the greatest number while minimizing the number of
people upon which adverse effects occur. There are other criteria de-
pending upon the situation involved.
The methodology put forward here is a framework for reviewing the
problem. [The extent to which tdJ-J Oj*th0ilo1agy can be carried out because
of the necessary quantification -- -- ts/vgi-bjies and the level of uncer-
tainty can only be determined through actual utilization in test modes. /
GOVERNMENTAL COORDINATION
ORP's primary responsibility is to set generally applicable
environmental standards and through a national dose assessment monitoring
system determine the degree to which .these standards are being met.
(Once established, the implementation of control and enforcement to meet
those standards is the responsibility of other parts of EPA (Refuse
Act, Air and Water Quality, etc.) and of other agencies, such as AEC,
DHEW, and USBM.J
36
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The standards are to be set on a risk/cost/benefit basis. In order
to deterjnine the level of risk and state of the environment (through
the dose assessment monitoring system), data and information must be
obtained. When possible, these data should be obtained from other
agencies, Federal and State, to minimize duplication of effort and to
maximize the effectiveness of EPA resources. Data on costs and benefits
also must be obtained elsewhere when possible. If cooperative efforts
among other agencies to obtain these data cannot be arranged, then ORP
will use best estimates of risk, cost, and benefits in order to proceed.
This cooperative effort requires free exchange of technical information.
The information received from other agencies will, aiter vaiidation,
have significant influence in the establishment of standards.
Atomic Energy Commission
Under the Atomic Energy Act of 1954, the Atomic Energy Commission has
jurisdiction over all activities within the site boundaries of licensed
and contractor-operated facilities, as well as for control of certain
radioisotopes made in these facilities. Unquestionably, they also have
interests in the environmental impact outside these boundaries, and by
the act itself are charged with the responsibility for protecting the
public health and safety. EPA has the responsibility for setting generally
applicable environmental standards outside these boundaries. The
establishment of the national dose assessment monitoring system to
determine levels of risk and the degree to which environmental standards
37
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are being met requires the development of pathway models for all types
of facilities that discharge radioactive materials to the environment.
Once pathway models are established, validated operating data obtained
from AEG can be used directly for dose assessment. Further, the cost
of various processes to contain discharges to the environment and other
abatement actions, as well as the benefits from the activities involved
can often best be supplied to ORP by the AEG. Therefore, it is essential
that there be an exchange of technical data on an ongoing basis between
AEG and OEP. EPA has no authority or responsibility for enforcement
and inspection of AEC-licensed facilities within site boundaries.
The establishment of generally applicable environmental standards
for classes of activities on a risk/cost/benefit basis is most desirable.
There may be specific cases within an activity class which may warrant
individual action. The establishment of such standards should be
extremely desirable from AEC's point of view.
Another ORP activity which relates to AEG is the review of environ-
mental impact statements from nuclear facilities. Once environmental
standards exist, impact statement reviews can be based upon a determination
of the proposed activity's/ability to meet these standards. In the
interim, it is necessary that ORP evaluate the facility to the extent
that EPA can assure that "lowest-practicable" technology is being used
for all pathways to the environment.
38
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It is felt that the above ORP policy is consistent with the intent
of Congress under the establishment of EPA and the transfer of standards
activities of the AEG to EPA. /This progra^ should compliment AEC
activities, yet provide sufficient independence of the standards-setting
process to assure that environmental control and promotion of nuclear
energy are separate^/ Further, while the role of each agency is not
explicit, it is hoped that this policy can minimize duplication of effort
and use the resources of each agency to the maximum effectiveness to
achieve the objectives of both agencies through technical interchange.
Bureau of Radiological Health. HEW
The Bureau of Radiological Health is responsible for standards-rela-
tive to the safety of electronic products which emit ionizing or nonion-
izing radiation. The overall environmental problem is the responsibility
of EPA under both its general Federal radiation guidance function and its
role in setting applicable environmental standards. Since medical X-rays
result in the greatest man-made radiation exposure to the individual at
the present time, it is important that total environmental control of
this source of radiation be undertaken such that there is no exposure to
radiation unless there are definable, offsetting benefits.
In this regard, EPA through ORP, and the Bureau of Radiological
Health can work jointly to establish environmental standards which are
consistent with environmental requirements, as well as product safety
requirements to provide reductions in dose and health risk which are
39
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unwarranted. The Bureau of Radiological Health is providing assistance
to ORP in development of our plans and our standards , and is looking
for guidance from EPA for further actions for them to undertake and
enforce through general Federal guidance. Thus, through the general
Federal radiation guidance function, ORP will be able to influence the
Bureau of Radiological Health to carry out their programs for reduction
of dose to the population.
EPA Regional Offices
Implementation of the programmed solutions to ORP problems will be
through the EPA-ORP Regional Offices to a large extent. Program direction
will be provided by ORP headquarters. It is considered desirable that
the major part of the environmental monitoring of nuclear power plants,
fuel fabrication plants, and other nuclear installations be performed
I ^
by authorities such as State agencies acting under guidance from EPA.X'' - 1"'*
,>
/f f "
The regional office will be the liaison with local authorities, and // _//'''
"
will assist in preparation, negotiation, and administration of contracts. / ,.,,
The regional office will perform initial analysis of the monitoring ' c
results as well as checking for validity and format and report to ORP
headquarters. Results of EPA-ORP headquarters analysis will be trans-
mitted to the regional offices and to local authorities through the
regional offices.
The regional offices will also support the other generic capabilities
of ORP by assisting on request in the review of environmental impact state-
ments from their regions, review and comment on proposed standards and
-------
>< .
criteria that particularly refer to that region, and assisting in * *V /
strategic studies as needed. The regional offices will be expected to
assist in coordinating ORP-originated actions with other Federal agencies
with local authorities.
Other Agencies
Issues dealing with other agencies such as the Bureau of Mines,
NASA, etc. are detailed in Appendix D.
STRATEGIC APPROACH
A'strategic approach is used to define the radiation problem and
develop effective programs to attack the problem. The Systematic
Radiation Strategy is a dynamic strategic plan for the radiation program
of the EPA. It is dynamic in that it is iterative in nature and program
efforts can be directed or redirected as needs and priorities may warrent,
with continual monitoring of progress and evaluation of attainment of
the goal. It is systematic in that a systems approach is used in deve-
loping programs, assessing alternatives, implementing the selected programs,
a'nd monitoring progress. It is strategic in that it is based on a sound
allocation of resources and direction of efforts to attack radiation
problems of highest priority and with the greatest impact on achieving
radiation protection as defined by EPA.
The elements of the Systematic Radiation Strategy are shown in
Figure 4. The first element is the establishment of the broad goals
of EPA in the radiation area. These goals are to assure that no additional
risks occur to individuals, the population at large, and the environment
due to increased radiation exposure without the existence of off-setting
beneficial reasons for these additional risk's.
-------
Establish Coals
and
Measures of
Goal Attainment
Evaluate
Attaincent
of
Goal
Monitor
Progress
Establish Objec
Elves in Terms
of
Standards
Implement
Programs
Determine Existing
and
Predicted Stale of
Environment
Select
Proposed
Programs
Select
Problem
Areas
Develop
Alternate
Programs
FIG1.-.: 4
ELEMIN7S OF A SYSTEMIC FLAHi;. no:: P:
-------
The attainment of these goals should guide direction of all radiation
activities of the Agency. Next is the establishment of measures of goal
attainment and, based on these, the establishment of sub-goals or objec-
tives. These are:
a) Minimize radiation exp.o.vv,--- .-.: ..vidividuals
b) Minimize radiation exposure to populations
c) Minimize occupational and medical exposures
d) Minimize contamination of the environment -''£ ( */"
~ 1 ' - e''
e) Enhance land use practices through effective power plant and
waste disposal siting .. ,.
rf
It is here that the relationship of standards to the objectives must be
examined, particularly in the context-.of using standards as the frame
of reference for measuring progress toward meeting the objectives and
attainment of the goals. The risks and benefits of major classes of
activities involving radiation must be identified and quantified and the
raionale for trade-offs between risks and benefits explored. Rationale
tor trade-offs between cost of control actions and benefits of control
actions also must be explored and developed.
It is vitally important to the total strategy that the existing
state of the environment and the population with regard to radioactive
pollution and radiation exposure be known and understood and that the
best possible estimates of future trends and potential problems are
available. This is essential for the development of programs and
activities which are directed to those problems of highest priority and
greatest achievable impact and which will lead to an upgrading of an
-------
undesirable situation or maintenance of an existing acceptable situation
to prevent degradation, consistent v/ith off-setting benefits.
Based upon the goals, objectives, and knowledge of the existing
and predicted state of the environment, appropriate problem areas are
selected and ranked by priority. The problem areas may be specific
problems within the general classes of radiation activities or they may
be generic issues which cut across specific problem boundaries.
Alternative programs or ways to attack the problem areas are then
developed. Alternative approaches may include legislative needs and
opportunities, knowledge, research and development, enforcement and
control, interagency implementation, and others. The alternative pro-
grams are assessed using risk/benefit analyses and cost-effectiveness
criteria to arrive at the selection of an optimum program - with no
legislative or institutional constraints - and a proposed program which
is realistic in terms of legislative authorities and resource allocation.
The relative impact of the optimum versus the proposed program is
evaluated.
The summation of the selected proposed programs becomes the proposed
total program, and if approved, the operating guide for the Office of
Radiation Programs, EPA. Implementation of the programs may be by direct
ORP Operations, through cooperative intra-agency efforts within EPA,
through exertion of leverage upon other Federal agencies and State
agencies, or combiations of these approaches.
Important to the effective management of the strategic approach is
the control function, i.e., monitoring of the progress of the programs
44
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in meeting the stated objectives. Finally, an evaluation must be made
of the degree of attainment of the goal. Throughout this control func-
tion are feedback loops which permit the direction or redirection of
efforts to assure continued progress leading to goal attainment.
IDENTIFICATION OF AREAS OF CONCERN
Thorough analysis of the sources and magnitudes of possible radiation
threat within the specified and implied function of ORP indicate that
there are several broad problem areas in which the judicious application
of resources may produce significant reductions in radioactive pollutants
and population dose. In addition to the specific problem areas to be
addressed, it is evident that there are associated activities that are
common to all problem areas. The five generic functions identified are
to provide the common data for all problem areas and organizational
functions.
The basis for ORT thrust is the establishment of ambient, effluent
and emission criteria, standards and guidelines. The basic philosophy
for this standard setting activity is that any radiation is harmful to
human health and the environment; thus, there must be definable measurable
benefits to offset the health risks imposed when radiation levels are
above zero (background). This does not imply a zero effluent strategy,
but rather that the risks undertaken must _be balanced by the benefits
gained. The means of establishing these standards and criteria on a
risk/cost/benefit basis is a generic area that cuts across all ORP
activities.
45
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The Atomic Energy Commission, the major protagonist of nuclear
power, has generally been approaching environmental protection on a
case-by-case basis. It is necessary to undertake overall studies of
radiation hazards from all sources that can affect large segments of
the population to rationally ass/S* M«e. -total risks. These investiga-
tions must include both the short-term and long-term possibilities to
ensure adequate preventive controls. Only through broad and strategic
studies of this nature can the radiation impact of combinations of programs,
such as the liquid metal fast breeder reactor and gas stimulation
projects, be ascertained and weighed against potential benefits which
are really necessary to our total well being. Thus, strategic studies
that ask pertinent questions and assess alternate solutions on a total
basis are also of a generic nature.
Another generic area is that of monitoring. Monitoring is used to
measure the status of the environment on two bases. The first is ambient
monitoring to determine long-term trends in the environment and to
alert the appropriate officials to measurable changes or incidents that
have been detected in the environment and which require corrective action.
The second is source monitoring which involves field studies for general
and specific problems, emergency response procedures during accidents
and surveillance.
The fourth generic area involves analyses and evaluations of
environmental impact statements which are generated according to pro-
visions of Section 102 of the National Environmental Policy Act. The
46
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evaluation of these statements must be considered as a means to influence
environmental protection, but not as a full control measure to attain
the environmental protection goals. The basic information required for
the timely evaluation of these impact statements must be established
on a generic basis from strategic study efforts noted above. Adequate
analysis also requires the maintenance of continuing expertise in the
areas for which impact statements are prepared.
The last generic function is that of training, which is necessary
to insure that enough qualified personnel are available to monitor
radiation sources, provide emergency clean-up actions, develop pathway
and dose models, study fuel cycles, and the many other phases of an
effective radiation protection program.
Eighteen problem areas have been established but have been broken
down into four major areas relating to the class of radiation source.
These are: (1) the generation and utilization of energy through nuclear
power, (2) natural sources of radiation, (3) nonionizing radiation, and
(4) non-energy uses of radiation.
Figure 5 shows the inter-relationship among the generic function
and problem areas. At the apex of the triangle is ORP's primary respon-
sibility, the establishment of standards and criteria on a risk/cost/
benefit basis. This responsibility is derived from previously designated
authorities and leads to enforcement actions, as required. The remaining
generic functions are generally applied to the problem areas shown at
the base of the triangle. The projects within ORP associated with these
47
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/KOIIITORL'
COIIDTIO'JS A:,"
MONITORING FOR A."BIE:fT
AND SPECIFIC SOURCES
\
FIGURE 5
LEVELS OF PROJECTS AND/OR ASSESSMENTS
LEADING TO STANDARDS AND ENFORCEMENTS
48
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problem areas and generic functions generally tend to contribute to
ORP's primary responsibility establishment of criteria and standards.
PRIORITIES
Table 2 shows a detailed breakdown of the strategic radiation problem
components. The table is a comprehensive list of significant sources of
potential radiation exposure. The eighteen problem areas were established
by extracting the essential problems from Table 2 and grouping them
according to similarity.
Four factors, shown in Table 3, were used to establish the prior-
ities for the eighteen problem areas. The overall priority is the
product of these four factors and this has a range from cen (highest)
to zero (lowest). The priorities derived for the problem areas are
shown in Table 4. The actual weighted computations are given in
Appendix F.
Stages of. Action
Attention will be given to all eighteen problem areas but there
are five different stages through which the project proceeds. These
are:
1. Cognizance and recognition.
2. Problem assessment.
3. Solution determination.
4. Implementation.
5. Operations.
49
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TABLE 2
PROBLEM COMPONENTS OF RADIATION PROGRAMS
Ln
O
1. GENERATION AND USE OF NUCLEAR ENERGY
Fuel Cycle
Uranium Cycle
Extraction
Fabrication*
Operation Uranium*
Normal
Abnormal
Shutdown
Accidents*
Minor Accidents
Actual
Potential
Major Accidents
Actual
Potential
Fuel Reprocessing*
Disposal*
Temporary
Ultimate
Transportation*
Mine to Fab
Fab to Plant
Plant to Reprocess
Reprocess to Disposal
Plutonium Cycle
Extraction
Fabrication (Potential)*
Operation*
Normal
Abnormal & Shutdown
Shutdown
Accidents*
Minor Accidents
Actual
Potential
Major Accidents
Actual
Potential
Fuel Reprocessing*
Disposal*
Temporary
Ultimate
Transportation
Mine to fab
Fab to Plant
Plant to Reprocess
Reprocess to Disposal
Tritium Cycle, Thermonuclear*
Others
2. NATURAL SOURCCS OF RADIATION
Mining and Mill Tailings*
Construction Materials*
Air Travel*
Others
3. NONIONI21NC SOURCES OF RADIATION
Microwave*
Radio Frequency*
Laser*
Other F.lcctromagnetic & Perhaps
Sonic Radiation
4. NON-ENERGY USES OF RADIATION
Modical*
X-ray*
Isotope (care and disposal)
Occupational
Device Testing*
Atmospheric Testing
Underground Testing
Plowshare Projects*
Other
^Problem Area Grouping.
-------
TABLE 3
PRIORITY FORMULA DATA
EXPOSURE CONDITION SF
An Irreversible potential
exposure condition results. 5
An acute (timeuise) high
level, short-term potential
exposure condition results. 4
A chronic (timewise) low
level, long-term potential
exposure condition results. 3
An acute (timewise) low
level, short-term potential
exposure condition results. 2
A special potential exposure
situation results. '1
POTENTIAL POPULATION ^
AT RISK SF
Total population poten-
tially at risk. 2
Large population group
potentially at risk. 1.5
Small population group
potentially at risk. .5
Occupational .25
CONTROL MECHANISM SF
Standard of regulation. .
Criteria or guideline
.8
Impact Statement. .7
Public pressure. .6
Advisory only. .5
Minimal desired/
possible .1
Not required/possible. .0
RISK AS A FUNCTION OF TIME SF*
Significant risk. 1
Potential increasing risk.
0.9
Potential future risk. 0.3
Limited risk. 0.7
Potential decreasing risk. 0.5
Risk controlled at acceptable
level. 0.3
No risk. 0.0
Ranking Factor - Exposure x Population x Control x Time function
RF-ExPxCxT OSRFS10
SF - Scale Factor
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TABLE 4
PRIORITIES AND STAGES OF PROBLEM AREAS
SHORT TERM
PROBLEM
AREA
Accidents
Disposal
Fuel Reprocessing
Microwave and RF
Medical X-ray
Operations Plutonium
Operations Uranium
Construction Material
Fabrication Plutonium
Plowshare
Medical Isotopes
Occupational
Fabrication Uranium
Mine & Mill Tailings
Device Test
Tritium
Transportation
Laser
RANKING
FACTOR
8
8
7.2
4.8
4.5
4.5
4.3
4.2
2.7
1.8
1.5
1.5
1.4
1.2
1.1
0.9
0.5
0.5
PRIORITY
1
2 .£\
3
4
5
6
7
8 $
9
10 $
11
12
13
14 $
16
16
17 ^
18
STAGE
3
3
3
2--
1
1
4
2
2 <
3
1
1 -
2 -
4
5
2 .
4
1 -
LONG TERM
PROBLEM
AREA
I'tCV- & > ( _ ' .' ^u *0- *-* ^
Disposal
Fuel Reprocessing
Tritium
Operations Plutonium
Accidents
Plowshare
Medical X-ray
Fabrication Plutonium
Microwave and RF
Construction Material
Medical Isotopes
Occupational
Operations Uranium
Laser
Device Test
Fabrications Uranium
Transportation
Mine & Mill Tailings
WEIGHT
10
9
6
5.3
5
5
4.5
3.2
3
3
1.5
1.5
1.5
1.5
1.1
0.9
0.2
0.1
STAGE
3
3
4
4
5
3
2^
3
4
4
2 -r
2 *
4
2
5
3
4
4
-------
/ Cognizance and recognition implies that one or more people have
been assigned responsibility to establish expertise in the area and to
bring proper attention to any major changes or problems arising in that
i
area. We do not consider this assignment as fulltime, but to be accom-
plished while doing other activities. At any other phase of a project
ORP believes that it is important that fulltime personnel be assigned
to the problem, and that there should be a minimum critical number of
two people for each problem area.
The stage of action for each problem area for both a short-term
and a long-term outlook is shown in Table 4. The table shows that
seven of the 18 problem areas have the same stage classification for
the short and long-term outlook. Most of the problem areas, however,
show an increase. Generally this upgrading reflects an added responsi-
bility of ORP for a particular project. For example, ORP currently has
no authority to monitor for medical x-rays. Future legislation, however,
may provide this authority and OEP may play a more important role.
53
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SECTION II
THE NATIONAL RADIATION PROTECTION PROGRAM
INTRODUCTION
The National Radiation Protection Program can be described in terms
of nine broad categories. The first five categories are called generic
functions and the last four categories are labeled as radiation source
classes. A description of each category is given below:
Generic Function Description
Risk/Cost/Benefit Analysis This functional cl£.ss consists of
trade-off studies and activities
required to support development of
criteria and standards.
Strategic Studies
Environmental Impact
Statements
Monitoring
Training
Investigations which are aimed at
providing a broad assessment of
complex arid controversial issup? in
order to assist in formulating the
basis for setting standards b> OR?
are induced in this class. This
functional class also supports develop-
ment of suitable n;ocels and analytical
methodology for setting standards.
Environmental Impact Assessments are
project specific and are required for
supporting action decisions on a
near-term basis.
Surveillance of sources and monitoring
of ambient conditions are perforned to
support such activities as development of
standards, field studies, emergency
actions, and assessment of short and
long-term radiation trends. A primary
objective of this function is to pro-
vj.de~.data for use" in the national dose
model.
These activities provide assurance that
state and local agencies have competent
personnel to conduct radiation protection
programs.
54
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Radiation Source Class Description
Energy This class contains problem areas
relating to the production of
electric power from nuclear energy.
Nononergy Medical and occupational exposure and
"-'.-'-'1.^7i=oblems not associated with
cr.srs? Production are treated in this
Natural Problem areas associated with cosmic
radiation and radiation emanating from
construction materials and mining
wastes.
Nonionizing These problems arise from electro-
magnetic radiation [\ > X. (visible)].
The first three classes are concerned with ionizing radiation, the
first two of which arise from man-made sources. The energy classification
involves uhe various stages in the nuclear fuel cycles except the mining
related activities. Although much of the radioactive mining wastes
are due to the extraction of uranium and thorium, there are other mining
wastes which are not directly associated with these fuels yet are
radioactive; therefore, raining wastes have been placed in the source
class of natural radiation. The nonenergy class involves medical
applications (theraputic and diagnostic; internal and external sources),
occupational exposures (medical technicians, watch reparimen, airlines
crews, etc.), isotopic sources, and applications involving nuclear
devices (military and plowshare). Natural, nonionizing radiation, such
as ultraviolet rays from the sun does not fall under the aegis of ORP.
Figures 6 and 7* provide a detailed description of a Proposed and
Optimum Program developed by ORP to meet the goals and objectives
-
Figures 6 and 7 appear separately in a pocket at the back of this
document.
55
-------
required for radiation protection. The Proposed Program is the
"Minimally Acceptable" program required to develop criteria and to
issue guidance and standards for radiation protection. The Optimum
Program is one that is both realistic and desirable in terms of a five-
/
year planning period./In addition to an accelerated time schedule, the
Optimum Program allows more thorough investigations to be conducted
in greater technological depth. The Proposed Program is generally
based on the best available data from already existing sources. The
individual program elements shown in Figures 6 and 7 are linked together
in series within the nine categories described previously. The generic
functions and the radiation source classes are cross-linked in many
cases to indicate the interrelationships between the generic functions
and the source classes. While most of the links depict sequences of
events, some of the links simply indicate that the program elements
must be considered collectively for the development of generally
applicable standards. A number of the individual elements could have
been placed in either a source class category or a generic function
category. A general rule that was followed was to place an element in
a source classification if the element related to a specific type of
radiation and to categorize the element by generic function if more
than one radiation source was applicable. Most of the cross-links
represent connections between research efforts and either the develop-
ment of criteria or the issuance of guidance or standards. Criteria
and standards are located in the generic function category "Risks/Cost/
56
-------
Benefits." Since tho issuance of guidance and standards represnet
ultimate objectives of the Radiation Protection Program the "Risk/Cost/
Benefit" category provides an abbreviated summary of the total program.
The Proposed and Optimum programs are each given for the period
beginning with fiscal year 1973, and continuing until the year 2000.
The fiscal years are shown separately, however, only through FY 1979.
The individual programs shown in bold type in Figures 6 and 7 are the
critical programs that ORP believe must be completed, if the National
Radiation Protection Program is to be successful. A description of
each generic function and radiation source class will be given in the
next subsections.
57
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GENERIC FUNCTIONS
Risk/Cost/Benefit AnaJysis
Description
The principal EPA Radiation Standards efforts which are foreseen
as potential solutions of priority radjfltion problems are: (1) a over-
all guide for allowable dose to individuals and populations; (2) estab-
lishing standards according to the general application involving sources
of radiation; and (3) development of specific source and radionuclide
guidance. These efforts will be approached using a risk/cost/benefit
analysis based on the following assumptions:
1. All radiation exposure can be described in some manner which
is related to e'nergy absorption or dose in man or his ecosystem.
2. The ill-health, or the risk of ill-health, will be directly
proportional to the radiation dose, and unless specified will not be
dependent upon the rate of exposure.
3. The relationship between the risk of ill-health and dose may
be extrapolated to zero risk at zero exposure, except for cataract
induction in the lens and perhaps skin erythema.
4. No radiation exposure is considered to be necessary unless a
tangible or at least an offsetting benefit can be described. (An
exception to this must exist for some natural radiation source such
as cosmic radiation but perhaps not for radiun in drinking water.)
Acceptance of these fundamental principles requires that radiation
control programs exist to protect man and his environment and that these
programs carefully consider first the risk associated with a particular
58
-------
radiation source and then the benefit to be derived by society from
this source. Subsequent to quantifying the risk and deriving a judg-
ment on the benefit, the control program must also consider the cost-
effective applications of technology to minimize the risk.
As a generic problem, risk/cost/benefit consideration enters the
decision making process of all specific problem areas from reactor
accidents to laser applications. Overall pathway, exposure, dose/health
effects, and benefit models developed for evaluating risk and benefits
are applicable to specific problem areas with appropriate modification
of parameters.
The problem area program will initially confine itself to defining
risk of ill-health only to man. Risk associated with the total ecosystem
such as species loss or environmental degradation leading to changes
in evolution will not be undertaken as an immediate concern since they
are considered Lo be less sensitive than man to radiation insults.
Benefits will include those derived for health, available power,
industrial and agricultural purposes, and economics. When possible,
comparative benefits of alternative approaches will be considered.
Program
The Proposed and Optimum program elements for the RGB analysis are
summarized in Table 5. In June 1970, the Federal Radiation Council
(FRC) initiated a review of the bases for'and considerations of radia-
tion exposure guidance. EPA has continued this review and is expected
to establish a position on the FRC guidance by July 1973.* Three studies
have been planned for this evaluation. The first study has just been
Unless otherwise stated, dates are for the. Proposed Program.
5P
-------
TABLE 5
RISK/COST/BENEFIT ANALYSIS - PROGRAM SIB-WARY
PROPOSED OPTIMUM STATUS*
PROGRAM ELEMENT DATE DATE
FY 1973
Special Study on Population Exposure 6-1-72 6-1-72 C
Continue Cognizance: Compliance wiu.
USBM Standard (4 WLM) 7-1-72 7-1-72
Issue Guidance: Plowshare Activities 9-1-72 9-1-72 >J
EPA Policy: LWR Fuel Reprocessing 11-1-72 11-1-72 ~'-'
Begin Siting Criteria: Accidents 1-1-73 1-1-73 C
EPA Health Effects Model 3-1-73 3-1-73 C
Complete Benefit Model & Analysis 5-1-72 5-1-73 C
EPA Policy: Interim Standards, NGS 5-1-73 5-1-73 C
FY 1974
EPA Policy: Generally Applicable
Standardj Fuel Reprocessing 7-1-73 2-1-73
EPA Position on FRC Guidance 7-1-73 7-1-73 C
," Issue Interim Standards: NGS 8-1-73 8-1-73
i ~x
",\- \ Issue PAG: Fuel Reprocessing 9-1-73 9-1-73 C
r» tf \
£*1 J Complete FRC Review & Issue Guidance 10-1-73 10-1-73 C
Issue Nuclear Energy Guidance 11-1-73 11-1-73
Issue Standards for Air and Water
(Kr-85, H-3, 1-129) 1-1-74 1-1-74
Complete Interim Siting Criteria 1-1-74 1-1-74 C
i/; '"Develop RGB Analysis of Building
"<. -"0s Materials 1-1-74 1-1-74
tj ».M
," "" Issue Interim Guidance on Siting:
Accidents 2-1-74 1-1-74 C
Issue Standards for Air and Water
(Pu-239, Ra-226) 3-1-74 1-1-74
Complete CRB Analysis: Medical X-ray 3-1-74 1-1-74
Begin Issuance of Source Standards 6-1-74 1-1-74 C
60
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TABLE 5 (CONT'D)
PROGRAM ELEMENT
FY 1975
Develop Building Materials Radioactivity
Standards
Interim Guidance to Federal Agencies:
Nonionizing
Issue Standards for Other Nuclides:
Air and Water
R.C.3. Analysis: Commercial Use of NGS
Issue Guidance for Action: LMFBR
Accidents
Complete EPA Policy: Storage and
Disposal (AEC Wastes)
FY 1976
Issue Criteria; LMFBR Fuel Reprocessing
Complete Siting Criteria
Standards for Accident Prevention
Equipment
Issue Standard: LWR Fuel ReprocessiT6'?
Issue Siting Criteria: LMFBR Fuel
Reprocessing
EPA Policy on Siting: Accidents
FY 1977
Issue Nonionizing Standards (Conditional)
Review EPA Policy: Fuel Reprocessing
Re-evaluate Dose Data: Medical X-ray
Re-evaluate Scientific Basis for all
Standards
FYs 1979-2000
Revise Non-Thermal Standards:
Nonionizing (Conditional)
PROPOSED OPTIMUM STATUS
DATE DATE
7-1-74
9-1-74
11-1-74
1-1-75
1-1-75
1-1-77
7-1-74
9-1-73
2-1-74
9-1-74
1-1-75
3-1-75 3-1-75
4-1-75 4-1-75
1-1-77
C
C
C, E
C
7-1-75
7-1-75
9-1-75
9-1-75
3-1-76
3-1-76
7-1-75
7-1-75
9-1-75
9-1-75
3-1-76
3-1-76
r
C
C
c,
C
E
E
7-1-76 7-1-75
7-1-76 7-1-76
7-1-76 7-1-76 C
1-1-79
1-1-78
61
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TABLE 5 (CONCLUDED)
PROGRAM ELEMENT PROPOSED OPTIMUM STATUS*
DATE DATE
FYs 1979-2000 (Cont'd)
Revise Guidance: Medical X-ray 7-1-79 7-1-79 E
Initiate Study: LMFBR Exposure Standard 1-1-81 1-1-81
Issue Plutonium Facility Effluent Criteria 1-1-83 1-1-83
Issue LMFDR Exposure Standard 7-1-83 7-1-83
*
C = Critical
E = End Product
62
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completed and gives estimates of ionizing radiation doses from 1960-
2000. The second study estimates the biological effects from low doses
of non-specific radiation and the third study to be completed by May
1973, will develop a means of quantifying benefits from radiation. The
FRC review will be completed by October 1973, and guidance for radiation
doses will be issued. The review will be based partially on the results
of a "lowest practical dose level" study. A generally applicable guide
for all uses of nuclear energy is to follow in November 1973, and will be
based on the previous studies as well as studies on the U-235 and Pu-239
fuel cycles. These latter two studies are categorized under the generic
function "Strategic Studies.". After EPA's position on FRC guidance has
been established, special studies on Kr-85, H-3, 1-129, Pu-239, Ra-226, . ^
and other nuclides will be conducted for the issuance of ambient air
and water standards by January 1975. These standards will also be based
upon an environmental pathway model study. The proposed completion date
fcr this phase of the optimum program is September 1974.
A risk/cost/benefit (RGB) analysis for building materials will be
developed by January 1974, after the completion of a dose model for building
materials, and radioactivity standards for building materials will be
developed by July 1974. The health effects model and the benefit model
previously described will be used in the establishment of the standards.
The health effects and benefit models will also be used along with
an evaluation of the current medical X-ray technology for a RGB analysis
of medical X-rays to be completed by March 1974. The RGB analysis is
63
-------
due to be completed by January 1974, for the optimum program. Healing
arts guidance will be issued by EPA by November 1974 (February 1974
for the optimum program) and a re-evaluation of medical X-ray dose data
is scheduled for completion by July 1977 (July 1976 for optimum program).
The completion of each of these items is dependent on the completion of
the earlier studies. The issuance of healing arts guides is also
dependent upon both dose assessments for medical X-rays and medical
isotopes and an evaluation of the improved medical X-ray technology.
The dose assessment for medical X-rays will be used for the RGB analysis
mentioned above.
The issuance of radiation source standards (all sources) will begin
in July 1974, and is a further extension of the FRC review and guidance '
recommendations. The source standards ara needed to develop the building
material standards (7/74) and the consumer products standards which will
be issued by May 1975. Guidance for occupational exposure will also be
issued by this date and is based on the FRC review and a study of
occupational exposure limits. The completion dates for the optimum
program are six months to one year earlier than the above dates. ,'
I*'
*/ " /'
Upon completion of a national radiation dose model, the scientific ***'(').
Cf»f"?
bases for all standatds will be re-evaluated by January 1977. in 1979
the guidance for medical X-ray will be revised based on the current
technology.
Beginning in mid-1973 and continuing until 1975, EPA will establish
policies and issue criteria and standards for nuclear fuel reprocessing.
Studies are planned for the magnitude and status of the LWR, the LMFBR,
and the HTGR fuel reprocessing cycles. Initially, EPA will issue a
64
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policy statement on LWR fuel reprocessing (11/72) as well as policies
regarding generally applicable environmental standards for fuel repro-
cessing (7/73). A criteria document on LMFBR fuel reprocessing will be
issued by July 1975, and standards for LWR fue] cycle will be given by
September 1975. In early 1976, s^.,.6 criteria on LMFBR fuel reprocessing
is scheduled to be issued and wii: Vr lollowed by an EPA review of fuel
reprocessing. The optimum program is identical to the proposed program
with the exception of the EPA policy on generally applicable standards
which will be issued five months sooner. It should be pointed out that
the standards for each fuel reprocessing cycle are interrelated and
cannot be considered separately.
Along with the establishment of standards for the fuel reprocessing
cycles, siting criteria must be developed for nuclear power plants,
especially regarding accidents. Interim action guides for accidents
will be issued by 1973 and interim siting criteria and guidance will be
issued by EPA in early 1974. Accident models for several reactor types
will be completed by the beginning of 1975. The development of siting
criteria and the issuance of guidance for action for LMFBR accidents
will be completed by mid-1975. Standards for accident prevention
equipment will be issued in later 1975 after a study of accident preven-
tion equipment has been made, ^nd an EPA policy on siting for accidents
is scheduled for 1976?) This entire effort is directed at minimizing the
effect of a release of fission products by the use of siting criteria
(or accident prevention equipment")
65
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Within the next month EPA is scheduled to issue guidelines for
plowshare activities. A component of plowshare activities which will
receive considerable attention in the next three years is natural gas
stimulation (NGS). Interim standards for NGS will be issued in 1973,
an environmental impact analysis wi-1 bi- developed for NGS in 1974, '
and a RGB analysis concerning the commercial use of NGS will be completed
in 1975 after current experiments have been completed. Finally,/EPA
will make a decision on the full field development of NGS by July 1975.'/
All of these decisions will be consistent with the health effects model
and the benefit model derived previously. The Optimum program for NGS
is the same as the Proposed program.
' By the end of 1974, a thermal effects and radiation interference
study on nonionizing radiation will be completed. At that time interim
guidance to Federal agencies will be given and thermal and non-thermal
standards for nonionizing radiation will be issued by 1976 and 1979
(if there are nonionizing non-thermal radiation effects). Each of these
programs will be completed approximately one year earlier if the Optimum
program is followed.
In 1975, EPA will issue policy statements and standards for the
storage and disposal of radioactive wastes. By the beginning of 1979
the EPA policy on national repositories for radioactive wastes will be
forwarded.
A program that will be initiated in 1981 is the establishment of
standards for LMFBR exposure. The study will be based on both the
66
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ambient plutonium criteria (7/79) and the impact of the Pu-239 fuel
cycle (7/80) and is scheduled to be completed in 1983.
The Optimum program for the last two problem areas described is
identical to the proposed program.
67
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Strategic Studies^
Description
Strategic Studies arc conceived of as the programmatic effort to
develop long-term operational strategy for matters that pertain to more
than one of the exposure sources identified as problem areas. One' of
the major efforts of Strategic Studies will be to pull together the
information developed in the problem areas where they focus on a broad
program area or, occasionally, on technical problems connected with a
generic issue. As presented here, Strategic Studies _are conceived of
as having a technical evaluatory nature only and exclude evaluations of
a management nature which are the responsibility of either the Deputy
Assistant Administrator for Radiation Programs or are generic matters
concerning one of the Division Directors.
In developing the Strategic Studies there art several focal points
that will receive particular emphasis. These relate to typical exper-
tise that are required for the studies. Many aspects of technology
assessment will fall in this category. Attention will be given to
assuring that technology that is applicable for radiation exposure
reduction for one source will be evaluated for applicability to other
sources or systems. Common types of releases and exposures will be
examined together to assure a uniformity in approach toward solutions.
Another area that will receive special attention is in the area of
modeling. Each of the exposure pathways from source to man will require
modeling at three significant points. There will be models for source
terns, for releases to the environment, for environmental transport
6£
-------
pathways on a nuclide-by-nuclide basis and finally the interaction of
the contaminant material with man and the resultant potential effects.
Although the individual models at these three points nay take different
forms due to the nature of the problem, there must be assurance that
they are compatible, that the assumptions are consistent, and that the
output from one may be fed into the next in the chain. The basic
responsibility for the model development is dispersed through the ORP
divisions-- TAD for sources and releases, FOD for environmental path-
ways, and CSD for the interaction with man. All the divisions will need
to utilize the composite results. It will be an objective of the
Strategic Studies to make sure these models fit together.
The problem based program effort directs itself to evaluating and
finding solutions to source related radiation exposures. Many of these
sources are interrelated and require the development of the same infor-
mation as uell as require overall compdracive evaluation. Furthermore,
there is a need to comparatively evaluate the overall ORP program effort
to insure the maximum benefit to the public from the effort expended.
,The area of Strategic Studies is seen as the vehicle through which the
technical aspects of this coordination will take place./ Final decision
making on effort priorities and other matters is of course the respon-
sibility of ORP management. Although several examples of Strategic
Studies have been listed here, it is expected that additional studies
will be established as the need arises.
69
-------
Program
Each of the program elements listed under the generic function
"Strategic Studies" are supporting studies for program elements in
"Risk/Cost/Benefit". Two strategic studies that are scheduled for
completion within the next two months are the U-235 Fuel Cycle Study
and the Pu-239 Fuel Cycle Study. These studies include mining, fuel
reprocessing and waste disposal and will have a significant bearing
on the nuclear energy guidance issued in November, 1973. Following
completion of the Pu-239 Fuel Cycle Study, a series of strategic studies
are planned in order to issue criteria for plutonium effluents by 1983.
A plutonium pathway model will first be refined (7/77) followed by a
complete review of the current actinide control technology (7/78).
Finally, an assessment of the impact of the Pu-239 Fuel Cycle will
be made by July 1980 based upon the results of the preceding strategic
studies. The U-235 Fuel Cycle Study will be used for the verification
of compliance to Federal regulations for the release of wastes from
nuclear power plants (11/73). Compliance to Federal regulations for
reactor operations will become a routine operation after 1973.
A strategic study designed to determine the lowest practical _
radiation level from all radiation sources will be completed by !/
/-
July, 1973 and will be used to issue guidance on radiation levels by . '
the end of 1973. ^
Two other strategic studies that are scheduled for completion by'
mid-1973 include an evaluation of the current medical x-ray technology
and a study regarding, the use^of land on which-nuclear power plants are
located. These studies will be used to complete a BCB analysis of
70
-------
medical x-rays and to issue siting criteria, respectively.
An analysis of the accident prevention equipment used to prevent
the release of radioactive products from nuclear power plants will be
made during the first six months of 1973 and the standards for such
equipment will be issued in late
All of the completion dates shown for the strategic studies are
identical for both the proposed program and the optimum program. The
two programs differ in the depth and quality of the analysis of the
individual program elements.
71
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Environmental Impact Statement Review
Description
The National Environmental Policy Act of 1970 (NEPA) requires that
Federal Agencies prepare environmental impact statements (EIS) for the
projects they sponsor. The administration of this act requires that EPA
review a wide variety of the EIS's. Review of the environmental impacts
resulting from radiation is the responsibility of ORP.
To perform this review function, ORP must develop and maintain a
capability for the independent evaluation of the potential impact of
all activities which involve radiation.
A major portion of the anticipated workload will be devoted to the
review of EIS's for nuclear power projects, (jt will sustain a full-time
management and technical appraisal workforce. y/Three alternative levels
of effort are identified, representing three options, having descending
degrees of thoroughness with which the format and content of nuclear
power project EIS's would be specified.
ORP would issue thorough guidelines to ensure complete and
»
consistent evaluation of radiation impacts.
e ORP would state the broad principles that should be the basis
of an EIS.
o ORP would not guide the content of an EIS, but would review
each EIS on the basis of the content "chosen by the sponsor
agency.
The review of EIS's for projects, other than nuclear power projects,
requires too wide a range of technical speciality, and too sporadic a
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workload, to be served by a fulltime technical workforce. The work will,
therefore, utilize all specialists on the OR?'staff.
Program
By mid-1973 EPA is scheduled to complete the guidance for the review
of environmental impact statements. Currently, EIS reviews are
being completed for both energy and non-energy sources of radiation.
Once these reviews are finalized a decision on whether to regionalize
the non-nuclear power EIS's or not will be made (4/73). /Regionalization
of the EIS's for nuclear power will begin in 1973 and will be completed
in 1974. /
An EIS review of plutonium facilities (fabrication, reprocessing,
breeder reactors) is being made at the present time and this review will
contribute both to the liquid metal fast breeder reactor (LMFBR) effluent
review (7/73) and the AEC year 2000 study (a study to project the build-
up of nuclides in river waters by the year 2000). The AEC study is also
scheduled for completion by July, 1973. Another environmental impact
statement that will be issued by EPA in early 1975 concerns natural gas
stimulation. This EIS is to be a part of a Risk/Cost/Benefit analysis
for the commercial use of natural gas stimulation.
The completion dates of the program elements for the optimum program
are similar to the completion dates for the proposed program. The
decisions on regionalization of EIS's will be made three months sooner
for the optimum program and the EIS on natural gas stimulation will be
completed six months earlier.
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Monitoring
Description
The ORP monitoring program will provide data and analytical techniques
that will permit the computation of radiation dose to (he population and
relate dose levels to radiation sources. This capability will be the
basis for ORP estimates of dose trends, population risk, standards develop-
ment and environmental impacts.
The principal components of the ORP monitoring effort are:
o Ambient Trend Monitoring, using the national surveillance networks
for monitoring concentrations of radioactivity in air, water,
milk, food, and bone.
o Source Monitoring of effluents and emissions, to compute popula-
tion dose (outside nuclear plant boundaries) due to individual y
plants, utilizing AEC licensee operating data and validated
pathway models.
\
The effort requires model development, data management, and dose
determination. /Meteorology, hydrology, demography and pathway data will ^
' ' }
be required for the operation of the model./ The program includes assis-
tance to States for the collection of source monitoring data. In fact,
monitoring can occur at any of the stages of the radiation "cycle" as
shown in Figure 8.
The radiation activities expected to generate the most significant
environmental impact are the use of nuclear fuels, medical use of radio-
active isotopes and plowshare activities. In particular, nuclear power
generation is expected to increase sixfold during the next 30 years.
The expected rapid improvement in nuclear technology will require contin-
ued revision of monitoring techniques.
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Ln
SOURCE
AMOUNTS
RADIOACTIVITY
(CURIES)
RADIOACTIVITY
(CURIES)
RADIOACTIVITY
(CURIES)
MEASURED
CORRELATED
EFFECTS-
DEATHS.
CANCER.
MORBIDITY,
GENETIC.
. ETC.
SOURCE
CONTROL
EFFLUENTS
EMISSIONS
SHIELDING
EFFECTS
^^
INDIVIDUAL
HEALTH
EFFECTS
POPULATION
HEALTH
EFFECTS
ENVIRONMENTAL
EFFECTS
>-
$
PATHWAY
CONTROL CONCENTRATION'S
PATHWAY
MODEL-
EMPERICAL
STUDIES
E
EFFECTS
MODEL-
EMPERICAL
STUDIES.
ANALYSES
_- x^
»
-*
AMBIENT
LEVELS AND
BACKGROUND
(CURICS/m3)
XPOSURE CONTROL'
EXPOSURE
MODEL-
EMPERICAL
STUDIES AND
EXPOSURE
MEASUREMENTS.
'JHII'LDING.
DISTANCE
(ROEMTGENS)
DOSE
DOSE
MODEL
(REM)
RADIATION CONTROL MECHANISMS AND HEALTH EFFECTS
-------
Program
By the end of calender year 1972 ORP is scheduled to publish a
general guide for the surveillance of radiation sources and the monitoring
Y
of ambient conditions. I A number of monitoring studies will be undertaken
in the next few years to validate dose models to register registration
sources, and to assess short and long-term radiation trends. /The
monitoring of ambi-en-t conditions to validate radiation dose models for
U-235 will' begin in 1973 and continue until 1978. Annual impact evalu-
ations will be made for the U-235 facilities during this period. The
monitoring of air, soil, and bones for the presence of plutonium has
already begun and each of these studies will be a part of the long-
lived nuclidc study to be finished by July, 1973.
A program for the registration of radiation sources began in
Illinois (9/72) and this program will initiate a series of registra- ' H" /.
^£-
tion studies in order to establish an inventory of radiation exposures./ <5t-
&6C&*
After the special Illinois study is completed a plan for the coordination .
of a nationwide registration of source will be developed and a Federal
governmental source registration will be completed for ionizing radiation
by July, 1976. The computerization of radiation dose data and the '
development of a national dose model will parallel this effort and a
national dose computation program will be operational by mid-1977. The
national radiation dose model is scheduled for completion by July, 1976.
All of this program will be completed six months to one year sooner if
the optimum program is followed.
76
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A number of field studies v/ill be conducted during the period
1973-1980 to develop and validate radiation dose models and radiation
pathway models. Beginning in 1979 studies involving a breeder demon-
stration plant will be conducted and these studies will run to 1981.
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Training
Description
EPA's legislative mandate includes the authority to promote
education and training, necessary to ensure an adequate supply of
qualified personnel to perform environmental protection duties. In
pursuance of this mandate, in the area of radiation protection, ORP
proposes a program comprising of:
o Continued Assessment and forecast of the demand and supply
of qualified personnel at national and regional levels,
and identification of existing and potential personnel
shortages.
c Selection of efficient mechanisms for increasing the
supply of all types of qualified personnel.
Implementation of training programs to counteract existing
and potential shortages.
The U.S. Government has been involved in the training of radia-
tion protection personnel since the late 1940fs. The involvement is
distributed among many agencies. In 1970, responsibility for some
existing training programs was transferred to EPA. This multi-agency
distribution of training responsibilities, together with the wide
geographic and institutional distribution of the employers of radiation
protection personnel, requires that the ORP training programs be con-
ducted with a strong emphasis on coordination with other government and
private institutions. To ensure consistency of purpose of the EPA
training programs, and the efficient use of qualified staff for the
planning and possible instructional effort, coordination is necessary
within EPA:
78
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o The Office of Training and Manpower (OTM), in the Office
of Planning and Management, EPA.
e The Office of Research and Monitoring (OEM), EPA.
To ensure consistent purpose and efficient use of other Federal
resources, coordination is necessary with:
o The Bureau of Radiological Health, DREW.
o The Atomic Energy Commission.
e The U. S. Department of Labor.
o The National Institute for Occupational Safety and
Health (NIOSH), DHEW.
Estimation of the supply and demand levels for qualified personnel,
and evaluation of possible training programs will require continuing
interaction with state and local governments, educational and pro-
fessional institutions.
The ORP responsibility for ensuring the adequacy of trained per-
sonnel presents a problem in two dimensions:
o The quality of training.
o The quantity of personnel.
Estimates of adequacy will involve continuous review of the quality
of training currently available and determination of the training require-
ments appropriate to each radiation protection task. Adequacy of the
personnel force will then be expressed in terms of the numbers of
personnel in each training category.
There are two virtually distinct sectors of training activity:
o Long-term (or program related) training concentrates on
basic education in the scientific and technological fields
79
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associated with radiation protection. Long-term training
support normally constitutes assistance to individual students
or to educational establishments. It is provided through
Training Grants, which are administered by ORM and Research
Grants or Problem-Solution Training Grants, which are admin-
istered by ORP.
o Short-terra (or problem related) training concentrates on
providing suitably educated personnel having familiarization
with the technical and administrative details required to
perform specific radiation protection tasks. /The nature of
ORP involvement in short-term training is not yet determined. )
Program
In early 1973 regional training committees will be established to
determine the training needs in the area of radiation protection and to
make recommendations for the implementation of training activities. Two
decisions that must be made concern the
1) continuance of the training task force; and
2) continuance of training grants.
If either or both programs are continued, implementation will begin by
June 1974. In 1975 ORP will evaluate its role with respect to the train-
ing activities,and the training of regional and state personnel in the
area of-radiation protection will take place by 1976. Once the effective-
ness of the training has been evaluated, ORP will make a decision of the
proper strategy to adopt for further training activities. The completion
dates for the optimum program and the proposed programs are identical.
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RADIATION SOURCE CLASSES
The Proposed and Optimum programs for the four radiation source
classes, Energy, Nonenergy, Natural, and Nonionizing, are described in
this section. These four radiation source classes are further sub-
divided into 18 major problem areas and the problem areas for each
source class are discussed following each subsection description,
respectively.
Energy
Description
This radiation source category refers to the production and use
of energy. The four major sources of energy that contribute to radiation
risks are: (1) the uranium fuel cycle, (2) the plutoniura fuel cy'cle,
(3) controlled thermonuclear fusion, and (4) the use of nuclear
explosives to release natural gas. Both short-term and long-term
projections are needed for each of these sources in order to develop
adequate risk/cost/benefit rationales. Radiation as a result of energy
producing activities can further be divided into the nine problem areas
listed below.
e Accidents
e Disposal
o Fuel Reprocessing
« Thermonuclear
o Fabrication-Plutonium
o Operation-Plutonium
o Fabrication-Uranium
81
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e Operation-Uranium
o Transportation (wastes)
A description for each of these problem areas follows the program
description.
Program
Subsequent to coordination of the Energy Policy Committee, the /l^' (I
*S t*"^^
Alternate Sources of Energy Study will be completed in January of 1973.
The ongoing effort to establish criteria for health hazards from radio-
active wastes will be completed in early 1974. These criteria will be
used to develop the Agency policy (4/75) on the storage and disposal
of AEC radioactive wastes. This policy will be used, in turn, to develop
the complete policy and standards (9/75) for the disposal and storage
of all radioactive wastes. The standards and policy for storage and
disposal will be combined with the health hazards criteria to arrive
at an Agency policy for the National Repositories for Radioactive Wastes.
The results of the U-235 Pathway Study will be available in late
1972. These xesults will be combined with the results of other pathway
studies to complete the Environmental Pathway Models Study in November
1973. The U-235 Pathway Study results will also be used in conjunction
with the evaluation of U-235 Fission product effluent and emissions data
to complete the verification of compliance of U-235 Reactor Operations
and as a major input to the long-lived nuclides study scheduled for
completion in mid 1973. Other inputs to the long-lived nuclides study
are the completed review of tritium dose models (1/73); plutonium soil
82
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monitoring; and plutoniura food chain pathway, long-term resuspension and
inhalation dosimetry models.
The results of the long-lived nuclides study will be used to issue
air and water standards for Kr-85, H-3 and 1-129. The study results will
also be used to complete the study of all radionuclides in August of 1974.
The results of the radionuclides study will "be employed to issue air and
water standards for other nuclides, to update the tritium effects model,
and to develop criteria for ambient Kr-85. These latter two elements
will be utilized to develop the criteria for ambient tritium (7/77).
Two interrelated programs were initiated in July of 1972, viz., the
review of LMFBR effluents and the development of the plutonium studies
program. These two efforts will be followed by initiation of a review
of the AEC Year 2000 Study. The initial Year 2000 Study review will
provide information necessary for completion of the Pu-239 Fuel Cycle
Study an,d for the initiation of plutonium food chain pathway, plutonium
long-term resuspension and plutonium inhalation dosimetry model efforts.
Initial results of these latter three efforts will be employed to com-
plete (1) the LMFBR effluent review, (2) the regional plutonium transport
model, (3) the plutonium studies research program, (4) the review of
plutoniura facilities effluents, and (5) the review of the AEC Year 2000
Study.
The results of these five programs will be combined to provide
integrated plutonium bio-effects and dosimetry data for use in the
plutonium inhalation dosimetry model. The completion of this model
in the fall of 1974 will lead to an interim plutonium resuspension
83
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report in mid 1977. This report will provide the information necessary
to issue ambient plutonium criteria (7/79) and to refine the plutonium
transport model. The ambient plutonium criteria will provide the basis
for a final plutonium resuspension report to be released in January of
1983. The issuance of these criteria will also provide the starting
point for a study to determine LMFBR exposure standards and an assessment
of the Pu-239 Fuel Cycle impact.
In November of 1972 interim monitoring guides will be developed
for the accidental release of radioactive products. These guides will
help initiate the development of an accident model for the eight "water
reactors which will be completed by July 1973. The model will be an
aid in the issuance of protective active guidance (PAG) and interim
guidance for nuclear power plant sitings to be issued by early 1974.
Accident models and PAG for the other types of reactors (LMFBR, HTGR)
will be completed approximately one year later.
During 1974 and 1975 special studies designed to investigate the
status and magnitude of fuel reprocessing for the different types of
reactors (LWR, LMFBR, HTGR) will be conducted. These studies will be
used to develop 'siting criteria and standards for fuel reprocessing of
the different types of nuclear reactors and they will all be issued by
early 1976.)
The dates for the optimum program correspond to the dates given
above for the proposed program. The energy studies for the optimum
program, however, will be more thorough; resulting in more reliable
standards for nuclear energy installations.
84
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Problem Areas (Energy)
Accidents
Nuclear power plants have the potential for environmental radiation
impact in: (1) normal operational releases, and (2) minor and major
accidental releases. The effort proposed would, in collaboration with
the AEC, determine the potential environmental consequences from the
accidental release of radioactive material and would assess the methods
available for minimizing these releases.
The program would include an analysis of accident assumptions,
consequences, and frequencies of occurrence. The environmental impact
of accidents both in terms of their incremental contribution to the
total release of radioactivity over the lifetime of the plant, as well
as in terms of the consequences of a single large release affecting the
health and safety of a segment of the total population would be
considered. The results of such investigations can be utilized in
the formulation of standards, guides, and criteria dealing with radiation
exposures of the general population.
The overall impact of an accident evaluation program by ORP would
be in terms of developing general energy use and siting policies,
development of emergency plans, and public information with respect
to nuclear accidents. This type of analysis would be applicable to
each type of nuclear reactor, including light-water and fast breeder
reactors, as well as to other aspects of the nuclear energy cycle such
as transportation of nuclear materials and to processing facilities.
85
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The specific program proposed by ORP includes detailed consideration
of the factors leading to an accident and the fission product release
pathways to the environment. Environmental factors affecting the
dispersion of fission products into the environment such as meteorology
and hydrology, as well as the food chain pathway to man would also be
included. Probabilities of accidents would be evaluated in terms of
the engineering data for specific components, and consequences in terras
of predicted failures for specific components. The program would
attempt to develop the risk potential to the environment and to the
general population for the operation of current and proposed future
nuclear reactors.
The expected accomplishments of such a program would include:
(1) increased knowledge of accident probabilities rnd consequences,
(2) establishment of emergency action criteria, (3) establishment of
monitoring facilities for abnormal releases,/(A) establishment of local,
regional, national, and international siting criteria,/(5) public
information availability, (6) decrease of accident probability and/or
consequences, (7) development of uniform emergency plans, (8) establish-
ment of reclamation criteria (decontamination guides).
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Nuclear Fuel Reprocessing
The objective of this program is to fulfill the obligations of
ORP/EPA set forth in Public Law 91-190,that is: (1) to mitigate the
impact of the environmental radiation .challenge by consideration of
environmental, ecological and social costs associated with nuclear fuel
reprocessing plants; and (2) to assist decision makers by indication
of the cost and benefit of the various alternatives available for
controlling any projected adverse impact associated with such plants.
The development and implementation of a publically acceptable
administrative method for controlling any projected adverse environmental
impact associated with nuclear fuel reprocessing plants constitutes
a major problem to be solved by EPA since such plants are a necessary
component of the nuclear-electric power industry. Any policy which can
provide control that will alleviate public concern will in turn contri-
bute to the avoidance of the projected energy shortage.
The proposed program would (1) determine the electrical energy
(power) requirements for both long and short-term and what fraction of
these requirements must be met by nuclear systems, (2) establish criteria
for establishing policy for the siting, operation and decommissioning
i -<~ ~ ^
of LWR, LMFBR and GCBR nuclear fuel reprocessing facilities considering
the conditions under which reprocessing is justifiable, with particular
consideration of the overall environmental impact, (3) issue protective
action guides (levels and methods) for both normal and abnormal operations
for each of the fuel cycles (LWR, LMFBR, GCBR) as a function of time,
87
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and (4) establish control techniques (engineering and/or administrative)
and compliance assessment procedures appropriate for each fuel cycle.
88
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Radioactive Waste Disposal
The disposal of radioactive wastes is common to every aspect of
nuclear energy use. Areas of concern for the Environmental Protection
Agency include (1) the projected amounts of wastes that will be produced
from operations of light-water and fast-breeder power reactors, and the
high-level and low-level wastes that will be produced from fabricating
and reprocessing fuels for these reactors; (2) the commercially produced
low-level wastes from reactor operations, research, medical, and other
sources that are currently being disposed in State-licensed commercial
burial grounds; (3) the AEC-generated low-level solid, liquid, and
gaseous wastes currently being disposed at AEC facilities and laboratories;
and (4) the AEC-generated high-level and transuranic-contaminated
wastes currently being stored at AEC facilities and laboratories.
The ORP program would address the four component problem areas,
or subactivities (discussed above), in sufficient depth to accomplish
the ORP missions connected with Environmental Impact Statements,
radiological-health criteria and standards, assistance and consultation
to States, and the Resource Recovery Act of 1970 (P.L. 91-512). The
program would provide a consistent national approach to the immediate
public-health and safety concerns related to existing AEC and other
radioactive wastes.
The program would consist of three phases. The phases would consist
of (1) establishing a comprehensive data base, (2) analyzing and evalu-
ating existing disposal practices and conceptual methods to develop EPA
89
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radiation-health criteria and interim positions, and (3) developing EPA
general policy, criteria, standards, regulations, and overall recommen-
dations to Congress which would lead, potentially, to establishment of
carefully selected, evaluated, and regulated national repositories of
various kinds of radioactive wastes.
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Thermonuclear
It is possible that towards the end of the 20th century thermonuclear
power (TNP) will be in use as a major source of electrical energy.
This program would develop a system for estimating the environmental
impact of TNP so that meaningful decisions can be made regarding its
introduction into the energy economy.
The program would provide a means of informing OEM of identified
research needs and for reassessing research needs as new information on
potential problems develops. The program would: (1) review available
health risk estimates and tritium dose models, (2) establish fusion
power plant siting criteria, effluent regulation and waste disposal
practices, (3) consider the monitoring needs engendered by a national
program in fusion energy and thn possible decommissioning and contamin-
ation of fission reactors and fission fuel reprocessing sites, and
(4) develop prediction models for: (a) worldwide mixing, (b) HT-HTO
exchange, (c) washout in surface waters, (d) intake, distribution, and
(e) retention in humans and food stuffs.
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Fabrication-Plutonium
This problem area encompasses the routine fabrication of plutoniura
fuels for fast breeder reactors, radioisotopic heat sources for space
and terrestrial application, and nuclear devices. Also included are
operations involving plutonium scrap recovery, and the inventory con-
trol for plutonium in research, educational institutions, hospitals as
well as nuclear power facilities. The major emphasis of the program
is the protection of health and environment through minimized release
of plutonium.
This program would develop dose assessment models and perform the
research required to provide the experimental evidence needed for the
model parameters. These research programs would identify the mechanisms
and the importance of environmental pathways for the transport of plutonium
and would be used as a base of information for criteria and standards
development.
*This problem area excludes, but is related to, Operations-Plutonium
and Fuel Reprocessing.
92
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Op era tlons-Plutonium
This problem area encompasses the potential radiation exposure to
the public from the routine operations of the proposed liquid-metal
cooled fast breeder reactors (LMFBRs) and the light-water cooled
reactors (LWRs) which employ plutonium fuel. The major emphasis of
this program would be related to the direct radiation dose to adjacent
population groups from the operation of these facilities.
This program would: (1) develop a systematized approach to assess
the magnitude of potential health risks and environmental effects ij^oln'
from plutonium-fueled reactor operation and formulate radiation standards
and environmental criteria to minimize these risks, (2) investigate
control technology, and (3) study in-plant radionuclide transport.
EPA research efforts would fall into the areas of evaluating waste
treatment systems and radioactive waste disposal techniques; and
determining the health risks from plutonium and other actinides and
the significant food chain pathways for these elements in man's diet.
The principal external outputs from the program would be
environmental radionuclide criteria and a radiation exposure standard
for the LMFBR and plutonium-recycle LWR's.
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Fabrication-Uranium
The problem is to determine and assess the environmental impact of
normal operations of nuclear fuel processing, enriching and fabrication
facilities in terms of dose to the population and other environmental
effects.
The general approach of this program would be to obtain plant
effluent and environmental data from AEC and to use these data to
calculate doses. Specific steps in this program involve: (1) characteri-
zation of the radioactive effluents from the facilities, (2) definition
of all significant exposure pathways, (3) development of exposure path-
way models to predict doses, (4) field studies to validate-exposure
pathway models and reported effluent data, ami (5) computation and
interpretation of individual and population doses.
In addition to the dose assessment, a technology assessment would
be made of the operating facilities to obtain the technical base for
Environmental Impact Statements and to assess effluent control technology
to assure discharges of radioactive material to the environment are as
low as practicable.
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Operations-Uranium
The problem is that of determining and assessing the environmental
impact of normal operations of uranium fueled nuclear power plants in
terras of dose to the population and other environmental effects. In
assessing population dose there are related parameters that must be
taken into consideration. These are: (1) characterization of the
radioactivity releases from plants, (2) a definition of all significant
exposure pathways, (3) development of exposure pathway models to predict
doses and (4) computation and interpretation of doses.
The general approach of this program would be to obtain and verify
plant effluent data from the AEC and to use these data to estimate, dose
to the population. Specifically, the program would consist of (1) acqui-
sition of effluent data from the AEC, licensees' reports, and surveillance
reports from states; (2) monitoring of the radioactivity releases from
selected power plants to validate the reported data; (3) adoption of and
development of computational models of the significant exposure pathways,
i j -
<4) in-depth field studies at selected representative power plants to <<
verify the computational models,/(5) to compute by use of the models,
the distribution of the released radioactivity in the environment and
the exposure of the population, and (6) reporting of the results.
Further, the program would provide information for technology assessment
including the review of Environmental Impact Statements, and information
for the evaluation and development of criteria and standards.
96
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Transportation
By 1990 the AEC projects 350 to 400 operating nuclear power plants
in the U.S. Each plant will ship about 100 truckloads of spent fuel
(the most hazardous form) per year, an average distance of 500 miles.
Thus, the total mileage for spent- fuel shipments will be about 20 million
miles annually. The accident rate for large trucks is about two accidents
'/ per million miles with about ten percent of the accidents classified
^ S'f( as serious or causing considerable damage. Thus, 40 accidents per year
'" J/)V involving spent nuclear fuel in shipment from reactors to reprocessing
plants can be expected./In addition to potential releases from accidents,
the routine exposure to populations along the route must also be con-
sidered. This exposure may become significant near reprocessing centers
where shipments will be concentrated on a few routes./
A second problem is the shipment of recycled plutonium fresh fuel
to LWR's and of U-233:U-235 fresh fuel to HTGR's. Plutonium and U-233
require greater shielding for external exposure than enriched uranium
atid, of course, present more of a criticality problem under certain
conditions. Radioactive shipments to medical and industrial users are
also expected to increase significantly.
It appears the largest potential problem is the shipment of spent
fuel from LMFBR's to reprocessing plants. The combination of much
larger quantities and a shorter cooling time (30 day estimate) indicate
.j that transportation will quite likely be the limiting factor in both
tt',tl. .' Site selection and size of LMFBR's. Although much work is required,
-------
it is suspected that the economics of transportation may well dictate
the necessity of nuclear energy parks in a breeder power program.
This program would: (1) estimate nuclear power projections and
related transportation requirements, (2) identify potential problems
related to the multiple regulatory agencies involved with the inevitable
inconsistencies in regulations, (3) investigate the status of shipping
cask development, (4) derive accident statistics for hazardous material
shipments, (5) review the status of various modes of shipment (air
transport will be proposed for fresh fuel shipments, railroads are
refusing to ship radioactive material, etc.)» (6) analyze the potential
consequences of radioactive material shipment accidents, (7) analyze
the potential impact of routine radioactive material shipments,
(8) determine costs of shipments, especially spent fuel, and (9) investi-
gate the capabilities of state and local jurisdictions for emergency
response.
The program would also perform research and development to develop
f '
emergency response models and plans; and to develop TLD system for \ '
7
selective monitoring along much travelled routes.
'
A
'v >-l
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Nonenergy
Description
The utilization of radiation in ways that do not contribute sub-
stantially to the national energy economy is defined as a "nonenergy
use". Nonenergy uses do include some energy producing devices such
as "atomic" batteries, but the scale and application of the energy pro-
duced is clearly differentiated from nuclear power plants or other prime
energy sources. Since a wide source of nuclear applications are being
considered,it is useful to categorize the most important nonenergy uses
as follows.
o Medical Applications
e Space Applications
e Consumer Products
e Industrial Applications
o Scientific Applications
o Educational Applications
o Military Applications
o Plowshare Applications
Medical applications include such uses of radiation as diagnostic
and therapeutic X-rays, nuclear medicine, and life-saving devices like
atomic batteries for pacemakers and artificial heart pumps. Medical
research uses are not included since the relevant benefit/risk trade-offs
are quite different than those arising from the direct application of
radiation to a patient.
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Space applications are broadly defined so as to include everything
from isotope power sources to interplanetary nuclear rockets. The
risks are obviously different for such a wide range of sources and must
be evaluated on a case-by-case basis. The benefit scale for space
application is heavily weighted by national policy considerations, so
that the evaluation of the benefits is somewhat similar for all appli-
cations.
Consumer products causing radiation exposure include radiophosphor-
escent watch dials, anti-static devices, atomic batteries, T.V. sets,
etc. Any commercially available radiation device which is not subject
to further control after being placed in use is defined here as a
consumer product. Also included in this category is the exposure
received by consumers of air transportation.
Industrial applications include beta-ray thickness gauges, X-ray
machines, and other testing devices which presumably are subject to
effective control by some public or private authority. However, some
industrial radioisotope applications such as the marking of fuel inter-
faces in pipelines and the tagging of metals in smelting operations
may result in environmental pollution after control of the radioactivity
is relinquished.
Scientific applications include by-product materials and radiation
from accelerators and research, reactors and all research using radio-
active isotopic tracers including particularly medical research. All
AEG regulated activities not included under the energy program or
military applications are included under this heading.
100
-------
Educational uses are differentiated from research in that somewhat
different risk/cost/bcnefit criteria must be.used where the reason for
the exposure is to familiarize students with useful techniques rather
than the potential accumulation of new knowledge.
Military applications do not include military reactors since they
are treated as large energy sources and their risk/cost/benefit criteria
are related to the set of problems considered under energy production
for civilian uses. Nuclear devices, their testing, and their production
are considered in this category.
The peaceful applications of nuclear devices (Plowshare Program) are
considered in the nonenergy category and include activities such as
nuclear stimulation of natural gas and horbor excavation.
Fivei^roblem areas identified with nonenergy radiation have been
designated from the topics described in this subsection: (1) Medical
Isotopes, (2) Occupational Radiation, (3) Medical X-rays, (4) Device
Testing, and (5) Plowshare. Summary descriptions of these problem areas
follow this subsection.
Program
The effort, presently underway, to estimate the extent and distribu-
tion of the radiation dose from diagnostic medical radiography, and
forecast these dose levels to the year 2000, will be completed by
January 1974 (July 1973 in the Optimum Program). RGB analysis, of
possible measures to'limit the dose from medical X-rays, will be
completed by March 1974 (January '1974 in the Optimum Program), permitting
All dates refer to the Proposed Program, unless otherwise stated.
101
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ORP to issue guidance on the use of medical X-rays by November 1974
(February 1974 in the Optimum Program).
Rapidly advancing X-ray technology will offer opportunities, both
for reduced dose and improved diagnostic service. Re-appraisal of the
ORP position on medical X-rays will involve a re-evaluation of the dose
estimates, by July 1976. Evaluation of technological developments,
by October 1976. Revised guidance on Medical X-ray usage will be issued
by July 1979.
Experimental projects, employing nuclear explosions to stimulate
the recovery of natural gas, are underway. If successful, these pro-
jects will lead to a high level of commercial Natural Gas Stimulation
(NGS), probably by the late 1970's. The ORP effort to assemble data
and perform RGB analysis on NGS will begin in October 1973, and continue
through January 1975. An EPA position on NGS will be available by
July 1975.
The present system for controlling the rapidly increasing population
dose due to occupational exposure is inadequate. ORP studies on
»
occupational exposure limits will begin by September 1973 (September 1972
in the Optimum Program) and be completed by January 1974 (January 1973
in the Optimum Program). Guidance on Occupational Exposure will be
^ ^ -..^u t
issued by May 1973 (May 1974 in the Optimum Program).
Responsibility for the safe transportation of radioactive materials
is shared between EPA, AEC and DOT. The ORP program will develop
preparedness for emergency response to incidents involving transportation
of radioactive materials. The plan will be completed by January 1973, and
102
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tested by July 1973. A continuing program of emergency response exercises
will begin by July 1974.
Current studies concerning the uptake of fusion products to the
human body, and its relation to body metabolism will be completed by
July 1975.
ORP studies associated with the radioactive cleanup of Bikini Ato$ |/i''
and the Nevada Test Site will be completed by July 1973.
£
The study of radioactivity in ground water in the vicinity of the --(r~jl
Nevada Test Site will be completed by July 1974. <==>&
Assessment of dose to the resident population of Alaska by the
measurement of whole body count, on a sample of the resident population,
will be completed by July 1975.
The current study, to determine the dose to r.cr.-patients. due to the -&
use of medical isotopes, will be completed by January 1974. The study "
results will be incorporated in the ORP guidance on the use of radiation
in the healing arts, to be issued in November 1974 (February 1974 in
the Optimum Program).
103
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Problem Areas (Nonenergy)
Medical Isotopes
This problem area is concerned with the radiation exposure, con-
tamination, and body burdens of the medical community other than physi-
/
cians, technicians, nurses, aides, other patients, housekeeping staff,
administrative personnel and visitors, and with the general population
outside the hospital but in the vicinity of the nuclear medical center.
To date, the general population in the vicinity of nuclear medical
facilities are exposed to undefined quantities of radiation since the
total radioactivity released to the sewer systems is not limited by law.
This program would: (1) determine the degree of internal environ-
mental radiation exposure to the medical community, (2) determine the
degree of external environmental radioactive contamination, (3) evaluate
the health risk associated with present and future levels of internal
and external environmental radiation exposure, (4) establish the maximum
permissible limits (new standard) for nuclear medicine release to the
external environment, and (5) provide guidance to the state agencies and
the Atomic Energy Commission.
104
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Occupational Exposure
The problem is that personnel are being occupationally exposed to '
radiation in various industries thaf ar£..rapidly expanding and little
or no effort is being expended to prsvewT exposures from increasing at
a similar rate. Under present regulations each individual classified r.e ,.-'* /,,«~ ^
*S~*'
as "occupational" is limited to an average annual dose of five rems.
However, there is no limit as to the number of persons who may be so
classified and receive this dose for a particular activity. Thus, the
potential raan-rem exposure is almost unlimited and presents an unaccept-
able situation on a national basis.
The program would establish the requirements for uniformity in
collecting and reporting of all occupational exposure to radiation and
would recommend standards for accuracy in personnel exposure measurements.
The program would also recommend regulation changes to further control
occupational exposure.
105
-------
Medical X-ray
Medical diagnostic x-ray procedures contribute about 90 percent of
all manmade radiation exposure. Some of this exposure can probably be
reduced by improved technology and techniques.
The Environmental Protection Agency (EPA) has the authority to
issue guidance on medical radiation protection through the Federal
Radiation Council functions which were transferred to EPA. The
Bureau of Radiological Health (BRH) has authority to implement much
of the guidance, and the states can institute radiation control through
their own standards.
A program of dose, risk/benefit, technology and methodology assess-
ment in cooperation with BRH would be undertaken. This assessment
program will lead to FRC-type guidance to be issued by EPA. A program
of EPA/BRK cooperation with the States in monitoring and in setting
standards would also be initiated.
106
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Nuclear Device Testing
Nuclear devices testing activities have the potential of releasing
large quantities of radioactive materials to the general environment.
The primary problem facing EPA is.the qualitative and quantitative
assessment of the effects of this potential exposure on the U.S.
population.
This program would document and evaluate the radiological situation
through monitoring and sampling programs conducted by NERC-LV. The
program at NERC-LV maintains continual surveillance activities in
the Nevada Test Site (NTS) off-site area to detect and document
environmental radioactivity levels regardless of the causes. An
immediate action readiness posture is maintained to assist in protecting
the population from exposure to environmental radiation. Extensive
evaluations are made of the possible doses to which the population may
be exposed from AEC activities at NTS. In addition, NERC-LV conducts
field and laboratory studies into the effects on the ecology of man-made
and natural radiation. NERC-LV also provides advice to medical personnel
throughout the country who are faced with radiation problems which may
be attributable to NTS activities. Similar activities are carried out
relative to wildlife and domestic animals.
107
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Plowshare
The component problems of the Plowshare Program are: (1) surface
excavation, (2) underground engineering, (3) scientific research,
(4) mineral recovery, and (5) gas stimulation. These components,
because of the associated residual radioactivity and geophysical
effects, pose significant health and environmental risk. The proposed
program would limit the environmental impact of Plowshare activities.
At present these activities are confined almost exclusively to gas
stimulation. If the experimental phase of the gas stimulation program
proves the technique to be technologically and economically feasible,
a program of full field development will follow. This development
would require the use of several hundred^megatons of nuclear explosives.
A major objective of this program is to gain EPA/ORP controljover
the impact of the Plowshare Program. This requires that all voids in
the data base be filled with ORP and OEM participating directly in study
programs. Also required in this degree of control is ORP management of
*
surveillance and monitoring programs and the authority to enforce EPA
Standards and Protective Action Guides (PAG).
Under this program, information would be obtained concerning: gas
well and device test results (from AEC), gas resources (from Federal
Power Commission) and conventional stimulation technology (from
consultants or contractors).
108
-------
Research and development will be conducted concerning: (1) investi-
gation of gas-to-man exposure pathways for CH T and dose models for H,
(2) improved instrumentation for tritium monitoring, (3) devitrification )
of resolidified rock and the transport of nonvolatile radionuclides,
(4) assessment of nuclear stimulation technique, and (5) investigate
reconcentration mechanisms for H.
109
-------
Natural Radiation
Description
There are several sources in the category of natural radiation
which present a potential for exposure greatly in excess of that which
is normally encountered from natural sources. These sources of exposure
contribute to whole body external dose and lung dose due to inhalation
of radionuclides and include:
1. High levels of natural radioactivity occurring in materials
used for the construction of buildings, roads, parks, and other places
of public use. It has recently been stated that over one million
people in the United States are receiving natural exposures greater
than five times the normal, or 500 mrems/yr.
2. Exposure of uranium miners to high levels of radon daughter
concentrations.
3. Contamination of air and water with naturally occurring radio-
isotopes, principally uranium-238 and its daughters, which are present
in phosphate deposits at levels 10 to 50 times greater than that in
most soils. The phosphate deposits in the United States have been
widely distributed due to the use of that mineral as a fertilizer.
Two natural radiation problem areas are construction materials
and mining and mill tailings, and are summarized following the "program"
subsection.
There are two significant health effects as a result of natural
radiation exposure. First, there are effects associated with whole
body exposure resulting from gamma radiation associated with decay of
110
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naturally occurring radionuclides. The effects of chronic and small,
long-term exposures are unknown but are generally assumed to scale
down linearly from higher doses. Since the exposures are generally
in the range of 100 mrems/yr and in some very isolated cases up to
1,000 mrems/yr, there have been no documented biological effects
associated with these levels. It is generally assumed that low chronic
doses of radiation have genetic and somatic effects, although no evi-
dence has been shown to substantiate this claim. One of the major
problems in evaluating this theory is that such large populations are
required to perform epidemiological studies in support of this theory;
moreover, until recently there have not been sufficiently detailed
radiation exposure data on which to base such studies.
The second major effect of natural background radiation, and
perhaps the more significant of the two health effects, is the dose
delivered to lung tissue resulting from radon daughter decay products
which are retained in the lung. /The average lung dose equivalent in
the U.S. population is between one and two reras.) It is this type of
exposure that has been of primary concern in the evaluation of exposure
to uranium miners, it has been conclusively demonstrated that an
increased incidence of lung carcinoma is associated with high levels
of radon daughter inhalation.
Steps have already been taken to reduce uranium miner exposure;
future action will depend upon how effective present controls are in
reducing lung cancer in the miners.
Ill
-------
Natural radiation exposure to building occupants represents the
largest, and perhaps controllable, source of radiation exposure in the
United States. The magnitude of the problem is suggested by the fact
that approximately 20 million homes will be built in the current decade,
and there is no information w]!atset--..5r-'on the projected use of building
material radioactivity or exposure levels.
Phosphates will continue to be widely used as fertilizer. Although
the population exposure resulting from this source is unknown, it is
likely that a minimum amount of study into the location of low-radio-
activity phosphates could reduce exposure.
Program
The current investigation of the use of radioactive waste products
from uranium mines, at Grand Junction, Colorado, will be extended to
the study of mine control measures by September, 1972. Study to deter-
mine the requirements for standards controlling gamma radiation dose in
mines will begin by November, 1972, and be completed by May, 1973.
Coordination of these studies on mine control measures will be completed
by July, 1973 and aimed at the achievement of legislation, to control
the use of mill tailings, by July 1975.
A model relating population dose to the level of radioactivity in
building materials will be developed by September, 1973 (March 1973 in
the Optimum Program). It will be used to develop standards controlling
the level of radioactivity in building materials by July, 1974. A
program to control the level of radioactivity in building materials,
through licensing of their manufacture, would be established by January,
1977.
112
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Problem Areas (Natural)
Constructdon Materials
Construction materials account for the largest exposure to the
United States population resulting from man-caused radiation sources.
The problem has not been considered previously by the radiation pro-
tection community due to the consideration of the problem as a component
of natural radiation, a subject which has been generally neglected.
Although construction materials generally attenuate man's exposure to
natural terrestrial radiation sources, the reduction is usually offset
by the contribution from construction materials themselves.
This program would determine the present nationwide level of
radiation exposure in man-reins due to natural sources in construction
materials. In particular, the following sources of exposure would be
investigated: (1) whole body exposure to the gamma radiation from K-40
and daughter products of Th-232 and U-238 within the construction material,
and (2) the inhalation of radon daughters which emanate from the con-
struction materials and result in lung exposures to occupants of
dwellings.
113
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Uranium Mining and Hill Tailings
Uranium mining is limited essentially to ten western states and
has been a declining activity in recent years. Numerous mines have
been closed, creating the necessity for Agency action to determine if
the closures were primarily attributable to the implementation of the
four working level months (WLM) per year exposure standard for under-
ground uranium miners.
Many of the uranium mills have closed, exposing the problem of
abandoned tailings sites. These mill tailings are radioactive sand-
like waste products which comprise over 99 percent of uranium ore
processed. Following mobile and house-to-house surveys, tailings
were found to be widely used in construction in the Grand Junction,
Colorado, area. Control of abandoned mill tailings sites and the lack
of an optimum disposal method have since come under question, with
Agency response by providing the States with model regulations to con-
trol these problems. A land use policy is required to resolve the
problems generated by mill tailings.
(This program will seek Federal legislation to authorize the t^/1"''
promulgation by USBM of miner exposure standards, with the Agency /^'L *
pyl"'s
serving in an advisory capacity. State legislation will be sought in .SVv'-
. .. - /
the Agreement States to control the use of mill tailings in construction,
establish control and disposal policies, and insure the adequacy of
monitoring programs for radioactivity release. )
114
-------
Research and development will be conducted to support technical
assessment of the accuracy and reliability of air and personnel monitoring
equipment for use in mining. R&D will also be required to determine
(1) biological consequences of radiation exposure from tailings;
(2) optimum method of disposal; and (3) methods of treating tailings
to minimize exposure.
115
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Nonionizing Radiation
Description
During the last 25 years there has been significant development
and increased use of equipment that produces nonionizing electromagnetic
energy. Modern society is dependent on the useful applications of
radiant energy in communications, marine and air navigation, radar,
industrial processes, etc. The object here is to examine ways to
balance these benefits with the risks that occur as side effects to
useful applications.
Electromagnetic radiation at all frequencies, including ionizing
radiation,affects living systems. The type of effect depends upon the
frequency. The frequency dividing point between ionizing and nonionizing
electromagnetic radiation is arbitrary but is commonly taken to lie in
the ultraviolet. Thus, nonionizing electromagnetic radiation includes
frequencies which range from direct current to the ultraviolet and
covers the range from electrical transmission systems at low frequencies
to powerful coherent light sources, lasers, at visible and ultraviolet
frequencies.
Because of the rapid increase in technological development,
application of technology, and uncertainty about effects, particular
emphasis is placed on the radiofrequency and microwave bands, i.e., the
bands with wavelengths covering the range between 10 kilometers to
1 millimeter (30 kilohertz to 300 gigahertz).
The five major sources of nonionizing radiation are briefly
described below.
116
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1. Extremely low frequency (0-30 KHz: wavelengths from direct
current to 10,000 meters). The principal application is for power
t*ffe>
transmission at 60 Hertz. Some military communications operate in
this frequency range. Of particular note is the ELF communications
system called Sanguine because of its high power and the requirement
for burying an extensive antenna array (100 square miles) in a location
accessible to the public.
2. Radiofrequency (30 KHz - 30 MHz: wavelengths from 10,000
meters to 10 meters). The principal application is for communications
including AM standard broadcast and amateur radio. Other applications
include radionavigation, radiotelephone, LORAN, medical diathermy,
and radio astronomy.
3. Microwaves (30 MHz - 300 GHz: v/avelengths from 10 meters
to 1 millimeter). The principal applications are in the area of
communications, including FM broadcast, television, microwave point-
to-point, and satellite communication: radar systems; and heat
treatment processes including medical diathermy, industrial drying,
and home and commercial food preparation.
4. Infrared (wavelengths from 750 nanometers to millimeters).
The principal applications for infrared radiation, including laser
sources, are for heating, cooking, industrial cutting, and military
applications such as communications, surveillance and guidance. All
hot bodies radiate in the infrared and exposure occurs from heat
sources in industrial processes.
117
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'5. Visible Light (wavelengths from 380 to 750 nanometers).
The principal applications are for illumination and the military,
industrial, and research applications of lasers. (Lasers also pre-
sent an exposure problem in both the infrared and ultraviolet
frequency bands.) The high intensity sources include lasers, the
sun, artificial light sources, incandescent bodies, and arc processes
such as welding.
The nonionizing radiation problem areas, microwave and radio
frequency and laser and other radioactive electromagnetic radiation
are summarized following the program description.
Program
The program for monitoring nonionizing radiation, from its many c^j^
industrial sources, will be started by September 1972. Study of the t'<~ '/
J <&">'?/'
thermal effects, of this type of radiation, will be completed by August ^l1-'^.
1974 (August 1973 in the Optimum Program). Guidance on the protection
from nonionizing radiation sources will be issued by September 1974
(September 1973 in the Optimum Program). EPA policy on the control of
the manufacture and use of nonionizing radiation sources will be developed
by July 1975 (January 1975 in the Optimum Program). If it is determined
that standards are necessary in the non-thermal, nonionizing phase of this
area, they would be issued by July 1976 (July 1975, Optimum Program).
The assessment of the non-thermal effects of nonionizing radiation
will be completed by October 1976 (April 1976 in the Optimum Program).
If the need for control of these effects is established, interim
guidelines for control will be issued by January 1977. Based on this
118
-------
assessment, EPA will develop its policy tcward ambient monitoring and
compliance standards by July 1977 (Janaury 1977 in the Optimum Program),
Necessary revisions to the standards, to protect from possible non-
thermal effects, will be made by January 1979 (January 1978 in the
Optimum Program).
119
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Problem Areas (Nonionizing)
Radio Frequency and Microwave Radiation
The pollution of the environment by nonionizing electromagnetic
radiation is rapidly increasing. There is concern about two types of
exposure: the exposure of the entire population to low levels which
result from the superposition of the fields from multiple sources such
as broadcast and communications systems, and the exposure of smaller
groups to potentially higher levels from sources such as radar, micro-
wave ovens, medical diathermy devices, and industrial heating equipment.
The concern arises because the existence and importance of nonthermal
effects at low levels are uncertain and the criteria for setting an
acceptable level of exposure, either for thermal or interference
effects, have not been defined for the population at large.
Permissible levels of exposure for occupational activities in the
U.S., both civilian and military, are set solely on the basis of heat
generation. Studies of effects conducted in the USSR and other Eastern
European countries have been oriented toward effects on, or mediated
by the central nervous system, and the overall conclusion arrived at
through such studies is that biological systems are more sensitive to
central nervous system effects than to direct thermal effects. Many
other nonthermal effects have been reported. There is considerable
controversy concerning these low level nonthermal effects and whether
they can be considered hazardous. However, in the USSR these effects
are given serious weight and the guidelines for permissible occupational
exposure are either 100 to 1,000 times less than those used in the U.S.
depending on the exposure conditions.
120
-------
The program has two primary objectives: (1) to identify the effects
and impact of electromagnetic radiation on health and environment, and
(2) to develop and implement a control program for the protection of
health and environment.
The objectives will be accomplish*j within four program elements:
(1) determination of the status of the environment through measurement
of environmental levels, (2) determination and evaluation of effects,
(3) development of guidelines for acceptable environmental levels, and
(4) development of a control program which may require enactment of
standards. The program also includes development of an emergency
response capability, response to requests for technical assistance,
review of environmental impact statements, identification of needed
research, and development of a field support capability.
121
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Laser Radiation
The potential for irradiation of the general population by the
light emitted by laser systems is small. Lasers are not generally used
in applications which affect the environment, but are usually confined
in use to areas restricted in accessibility. A few exceptions do exist,
however, where lasers are used in the environment and could conceivably
create hazards to individuals through thoughtless or careless application
and control of the laser system and area in which it is used.
The ORP program for minimization of environmental and biological
effects due to use of laser systems would mainly be one of maintaining
cognizance in this area because of the minimal risk for exposure of
the general population. Cognizance will be maintained through the
implementation of the Information Inventory Development program element
of the Radiofrequency and Microwave Radiation Program within ORP.
Up-to-date awareness of the extent of general population exposure to
applications of laser systems will permit modifications in the ORP
program to be made if required, and in addition, permit evaluation of
Environmental Impact Statements.
122
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RESOURCE REQUIREMENTS FOR PROPOSED AND OPTIMUM PROGRAMS FOR FY '73 AND
FY '74
The resource requirements for the present fiscal year along with
the resources required for the Proposed and Optimum Programs for
FY '74 are presented in Tables 6, 7 and 8. The tables show the
resources required for each of eight categories; i.e., four generic
functions (Training is divided into 3 parts) , Division Management,
and a Program Management and Support category. Additional detail
with respect to the allocation of each program category's resources
to the five generic functions and the 18 problem areas is provided
where appropriate. The numbers preceeding the slashes represent the
number of in-house man-years of effort. All other numbers are the
dollar resources required.
The budget for FY '73 (see Table 6) is $4.52 million including
the cost of a staff of 173 in-house personnel. The major portion of
the resources are allocated to the five generic functions which
account for 52% of the total resources. The three generic areas
associated with training (i.e. elements 2F7193, 2F7194 and 2F7195)
account for slightly less than 13% of the total or 26% of the resources
associated with the five generic areas. Twenty-six percent of the
total resources are needed to conduct the work necessary to support
*0n the vertical axis the strategic studies category has been included
in the EIS category.
123
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TABLE 6
ORP PROPOSED PROGRAM - BUDGET FOR FY 1973
PERMANENT POSITIONS AiO EX?ESD1TURES
(IN Tl.OUSA.NDS OF DOLLARS)
^x^^
\^ GENERAL FUNCTIONS
^v^ ANT) PROBLEM AREAS
PROGRAM ^S^
ELEXENT Vw
STAND\RDS *P- 29/537
(RCB) C- 200
2F1190 \~
29/757
XKlTOftXNC P- 66/1218
2F2191 C~ 195
ZF2m E- ICO
I- 35_
66/15i8
E1S P- 62/1237
r "\n
2F6120 ^~ 23
I- ~
62/1287
SUBTOTALS: P- 157/2992
C- 425
E- 140
I- 35
157/3592
ACADOUC TRAINING A93
2F.9T
TLC MCAL TRAINING 67
:ri9i
DIRECT TRAINING I/ 18
21195
DIVISION MANAGEMENT IS/ 348
2R1197
PROGRAM KANAGEKENT
AND SUPPORT 14/ 350
<; C8TOTAL-KAN ACEMENT
AM) TRAINING 30/1276
TOTAL 187/4868
H
tZ
Cil
RISK/COST/BtNl
EVALUATION
6,
200
20
6/
200
20
1
en
u
M
STRATEGIC STU1
18/
18/
MONITOKING
38/
175
15
38/
175
15
tj
b
** u
ENVIRONMENTAL
STATEMENT REVl
16/
U/
ACCIDENTS
4/
3/
3/
10/
DISPOSAL
4/
3/
5/
20
12/
20
u
FUEL REPROCCSS
3/
2/
10/
20
15/
20
THERMONUCLEAR
I/
I/
i
FABRICATION
pLtrro:;iUM
* / '
*
2/
3/
OPERATION
PLUTONIUM
I/
I/
OPERATION
URANIUM
I/
3/
«/
8/
-
FABRICATION
UKA.MUM
W
3/
TRANSPORTATION
I/
I/
?/
CONSTRUCTION
MATERIALS
j
MIMING AND MIL
TAILINGS
2/
1
\
7/
^
RADIO FREQUENC
AND MICROWAVE
5/
20
100
20^
5'
?0
too
20
a u
1 LASER ANU OTHE
ELECTROMAGNETI
RADIATION
M
I MEDICAL ISOTOP
I/
I/
OCCUPATIONAL
I/
I/
(MEDICAL X-RAY
;/
2/
IDLVICE TESTING
Ul
s
1
u
§
,/
3/
j/
LO
S/
10
*
P Positions
C - Contracts
£ Equipaent
1 m Intcrageney Agreements
i
-------
TABLE 7
OR? PROPOSED PROGRAM - BUDGET FOR FY 1974
Permanent Positions and Expenditures
(in thousands of dollars)
^X. GENERAL FUNCTIONS
^x. AMD PROBLEM AREAS
PROGRAM ^x.
ELEMENTS ^v^
STANDARDS *p- 35/647
(RGB) C- 220
E- 20
2F1190 I-
35/887
MONITORING P- 73/1343
C- 280
2F2191 E- 40
I- 25
73/1688
EIS P- 70/1393
C- 30
2F6120 E- 25
I-
70/1443
SUBTOTALS:- P- 178/3383
C- 530
E- 85
1- 25
ACADEMIC TRAINING 493
2F7193
TECHNICAL TRAINING 67
2F7194
DIRECT TRAINING 1/18
2F7195
DIVISION KUJACLMENT 15/348
2R1197
PROGRAM MANAGEMENT iifitn
AND SUPPORT 14/350
SLBTOTAL-MAXACLMEST
ANT) TRAINING 30/1276
TOTAL 208/5299
H
£
b]
RISK/COST/BEN
EVALUATION
13/
220
20
13/
220
20
IA
P
STRATEGIC STU
IB/
15
)
39/
280
40
25
18/
__
15
_ _
280^
25
P*
ss
EKVIROWENTAL
STATEMENT REV
20/
vs
(^
20/
ACCIDENTS
3/
5/
3/
ll/
f
DISPOSAL
3/
3/
5/
20
ll/
20
in
FUEL REPROCES
2/
2/
IS/
10
19/
10
THERMONUCLEAR
__
__
FABRICATION
PLUTONIUM
I/
._
1
I/
,
!
2/
,
OPERATION
PLUTONIUM
2/
I/
3/
OPERATION
URANIUM
I/
3/
2/
6/
FABRICATION
URANIUM
3/
3/
TRANSPORT AT 10
I/
I/
CONSTRUCTION
MATERIALS
I/
5/
__
6/
j
MINING AND MI
TAILINGS
?,
RADIO FREQUEN
AiND MICROWAVE
I/
5/
._
6/
OtfU
LASER AND OTK
LLCCTRO!L\GShT
RADIATION
__
-
td
MEDICAL ISOTO
2/
3/
__
5/
OCCUPATIONAL
I/
_._
_
I/
MEDICAL X-RAY
2/
__
__
2/
DLVICE TCSTIN
~
r
id
I'LOUSIIARC PRO
5/
3/
4/
10
12/
10
,
l/« ' S *
u * ' '/ , P Positions
C Contracts
\ 1 ,. E - Equipment
, l 1 Interagency Agreement
I/
.
-------
TABLE 8
ORP OPTIMUM PROGRAM - BUDGET FOR FY 1974
Permanent Positions and Expenditures
(In thousands of dollars)
^S. GENERAL FUNCTIONS
\^ AND PROBLEM AREAS
PROGRAM ^\-
ELEXZNf ^^
STAMJARDS *p- 50/924
(P.CB) C- 1000
E- 25
2F1190 I
50/1949
MONITORING P- 121/2225
C- 1000
2F2191 E- 398
I- 100
121/3674
EIS P- 86/1711
C- 1615
2F6120 E- 40
I-
86/3366
SUBTOTALS:- P- 257/4860
C- 3566
E- 463
I- 100
TOTAL 257/8989
ACADEMIC TRAINING 750 -
2F193
TECH.MCAL TRAINING 50
2F7194
DIRECT TRAINING .," .' 3/76
2f7195 \"/iV t
DIVISION MANAGEMENT 24/550
2R1197
PROGRAM MA;; \CLMENT
A.SD SUPPORT 11/550
SUBTOTAL-MANAGEMENT .
AND TRAINI'.C 41/1776
TOTAL 298/10765
H
RISK/COST/BENEFI
EVALUATION
18/
300
25
IB/
300
25
CA
IH
U
g
C/l
22/
1370
22/
1370
MONITORING
60/
600
600^
\ ^
h
EIIVIROXIIENTAL IM
STATENENT REVIEW
25/
25/
265
ACCIDENTS
4/
200
4/
4/
65
12/
35
DISPOSAL £^-
** " *
6/
3/
6/
35
15/
225
20
FUEL
REPROCESSING
150
21
13/
75
20
19/
THERMONUCLEAR
If
if
21
FABRIC A f ION
PLUTOMUM
J/
21
if
35
OPERATION
PLUTOKIUM
3/
I/
35
4/
35
y
OPERATION
URANIUM
if
10/
96
10
5/
20
16/
96
20
10
FABRICATION
URANIUM
«/
if
51
TRANSPORTATION
I/
21
3f
CONSTRUCTION
MATERIALS
If
100
8/
190
85
9/
290
85
MIMING AND HILL
TAILINGS
21
5/
25
11
25
RADIO FREQUENCY
A.ND MILROWAVE
21
ill
40
313
90
19/
'a
3* :
9v
LASER A.-.D OTHER
ELECTROMAGNETIC
RADIAIION
MEDICAL ISOTOPE
I/
50
if
50
OCCUPATIONAL
I/
I/
MEDICAL X-RAY
if
100
if
100
DEVICE TESTING
if
if
y>
c.
c.
51
100
3/
5/
35
13/
135
I \ *
> P - Positions
C Contracts
^ / E Equipment
x I Interagcncy Agreements
^ . ^ ^.h '
.\ (/
-------
the nine problem areas associated with the gelieral classification of
energy related radiation. The remaining resources (22% of the total)
are for the other three classifications of radiation sources ( i.e.
natural, nonionizing, and nonenergy soui _->j-s) and management.
The proposed budget for FY '74 of S-.'95 million is presented in
Table 7. This represents an 9.5% increase over the FY '73 budget.
The in-house personnel required is 194, slightly more than a 12%
increase over FY '73.
In general, the allocation of resources to the generic and
problem areas is only slightly different than the FY '73 budget.
Management, and efforts directed toward problem areas in natural,
nonionizing and nonenergy sources of radiation account for the
approximately the same percentage of the budget. The only major
change in the allocation of resources is the increase in funds
allocated to the generic functions from $2.4 million in FY '73 to
$2.9 million in FY '74. In' terms of percentages, this amounts to
an increase from 42% to 59% of the total budget. The resources
allocated to the energy related problem areas decreases from 26% to
22% of the total budget. In absolute terms, this reflects a slight
decrease in funds allocated to this area. The slight shift in emphasis
in the FY '74 budget reflects the general objectives presented in
this plan. That is, to place the major emphasis in the early years
of the execution of the plan on developing a system-wide framework
for future use in the guidance and direction of efforts directed
127
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toward specific problem areas. The relatively large percentage of
funds allocated to the energy problem areas reflects the resources
needed to complete on-going projects. It is anticipated that the
trend observed in the FY ' 73/ FY '74 budget will stop or reverse
once the necessary system-wide framework is established.
Table 8 presents the budget for FY '74 for the "Optimum" Program.
The total resources required, i.e., 284 in-house personnel and
^ \
$10.415 million, is' 110% larger than the FY '74 proposed budget.
'
When compared to the proposed FY "74 budget, the Optimum Program budget
shows a large increase in the percentage of funds allocated the
problem areas categorized as natural, nonionizing and nonenergy,
i.e., from 12% in the Proposed Program budget to 20% in the Optimum
Program budget. This increase conies primarily from a decrease in
funds allocated to the generic functions which decrease from 59% to
53% of the total budget.
128
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