NOTICE


     Since this document contains budgetary Information,  it  is

privileged information until such 'time as it  is approved  by  the

Assistant Administrator -for.jCategoricaJ Programs.

     The documents are serially nuflToered for  accountability  and

to insure that recipients .receive changes as  they are issued.

     Recommended changes or ct/Trezti&ai} should be submitted  to

the Office of Radiation Programs.
                                 W. 1). Rowe
                       Deputy Assistant Administrator
                        .;,• for Radiation Programs
October 27, 1972

-------
                              NOTICE


     Since this document contains budgetary information,-it is

privileged information until such time 'as:it is approved by 1?he

Assistant Administrator for Categorical Programs.

     The documents are serially numbered>for accountability and

to insure that recipients-receive changes as they are'issued.

     Recommended changes or corrections should be submitted-bo

the Office of Radiation Programs.
                                 W. D. Rowe
                       Deputy -Assistant Administrator
                           for Radiation Programs
October 27, 1972

-------
NATIONAL RADIATION PROTECTION PROGRAM -
           STRATEGY AND PLAN
           September 29, 1972

-------
NATIONAL RADIATION PROTECTION PROGRAM
        STRATEGY AND PLAN
  THE OFFICE OF RADIATION PROGRAMS
         29 September 1972

-------
                             FOREWORD

     This document describes the mission of the Office of  Radiation

Programs, Environmental Protection Agency,  for protection  of  the

environment and population against unwarranted radiation insults,

and provides a strategy for carrying out this mission with a  working

plan for its achievement.

     As a result of this planning effort, the Office of Radiation

Programs has developed a revised approach directed toward  setting

environmental standards for all aspects of radiation, as well as

conducting the analysis of the environmental impact of radiation

related Federal activities.

     The management of ORP is committed to carrying out this  plan

within budgetary constraints by applying its resources to  accomplish

the mission and meet the milestones that have been established.  As

the program develops and new information on the dynamic aspects of

radiation protection activities is obtained, this plan will be

changed  in a formal, orderly manner to reflect revised policy and

changes  in resources and schedules.  Official holders of this

document will receive copies of these changes as they are approved.

     Thus, this EPA working document will  reflect the general status  /

of  the operational program at any given  time.
                                   W. D. Rowe
                         Deputy Assistant Administrator
                              for Radiation Programs
 September  30,  1972

-------
                         TABLE OF CONTENTS


                                                                Page

LIST OF ILLUSTRATIONS                                             vi

Glossary                                                        viii

SUMMARY OF NATIONAL RADIATION PROTECTION JPKOGRAM PLAN              x

NEED FOR A NATIONAL PROGRAM PLAN                                   x

AUTHORITY AND JURISDICTION                                       xii

STANDARDS                                                         XV

USE OF THE STRATEGY                                              xvi

Program Goal                                                     xvi
Objectives                                                      xvii
Program Framework                                               xvii
Proposed and Optimum Programs                                   xxii
Risk/Cost/Benefit Analysis                                     xxiii

RESOURCE REQUIREMENTS                                          xxxii

SECTION I    PROBLEM AND APPROACH                                  1

INTRODUCTION                                                       1

NATIONAL RADIATION PROBLEM                                         2

The Threat From Ionizing Radiation                                 2
The Threat From Nonionizing Radiation                              7

HEALTH RISK RATIONALE                                             13

AUTHORITY                                                         20

STANDARDS                                                         22

Types of Standards                                                22
Methodology for Setting Standards                                 23
The Risk/Cost/Benefit Methodology for Standards Setting           25
                                 iii

-------
                    TABLE OF CONTENTS (Cont'd)

                                                                 Page

GOVERNMENTAL COORDINATION                                          36

Atomic Energy Commission                                           37
Bureau of Radiological Health, DHEW                                39
EPA Regional Offices                                               40
Other Agencies                                                     41

STRATEGIC APPROACH                                                 41

IDENTIFICATION OF AREAS OF CONCERN                                 45

PRIORITIES                                                         49

Stages of Action                                                   49

SECTION II    THE NATIONAL RADIATION PROTECTION PROGRAM            54

INTRODUCTION                                                       54

GENERIC FUNCTIONS                                                  58

Risk/Cost/Benefit Analysis                                         58
Strategic Studies                                                  68
Environmental Impact Statement Review                              72
Monitoring                                                         74
Training                                                           78

RADIATION SOURCE CLASSES                                           81

Energy                                                             81
Problem Areas (Energy)                                             85
     Accidents                                                     85
     Nuclear Fuel Reprocessing                                     87
     Radioactive Waste Disposal                                    89
     Thermonuclear                                                 91
     Fabrication-Plutonium                                         92
     Operations-Plutonium                                          93
     Fabrication-Uranium                                           95
     Operations-Uranium                                            96
     Transportation                                                97
                                  iv

-------
                     TABLE OF CONTENTS (Cont'd)
Nonenergy                                                          99
Problem Areas (Nonenergy)                                         104
     Medical Isotopes                                             104
     Occupational Exposure                                        105
     Medical X-ray                                                106
     Nuclear Device Testing                                       107
     Plowshare                                                    1°8
Natural Radiation                                                 HO
Problem Areas (Natural)                                           113
     Construction Materials                                       H3
     Uranium Mining and Mill Tailings                             114
Nonionizing Radiation                                             116
Problem Areas (Nonionizing)                                       120
     Radio Frequency and Microwave Radiation                      120
     Laser Radiation                                              122

RESOURCE REQUIREMENTS FOR PROPOSED AND OPTIMUM PROGRAMS
FOR FY '73 AND FY '74                                             123

-------
                       LIST OF ILLUSTRATIONS
FIGURE NUMBER
      B

      C

      D

      4
      8
LEVELS OF PROJECTS AND/OR ASSESSMENTS
LEADING TO STANDARDS AND ENFORCEMENTS

SUMMARY OF MAJOR PROGRAM MILESTONES
(PROPOSED PROGRAM)

SUMMARY OF ESTIMATES WHOLE-BODY RADIATION
MAN-REM DOSES IN THE UNITED STATES

RADIATION CONTROL MECHANISMS AND HEALTH
EFFECTS

LEVEL OF DOSE REQUIRED TO PRODUCE ONE
GIVEN EFFECT PER POPULATION AT RISK

RISK/COST/BENEFIT OVERVIEW

COST-EFFECTIVENESS CRITERIA

RISK/COST/BENEFIT ANALYSIS MATRIX

ELEMENTS OF A SYSTEMATIC RADIATION
PROTECTION STRATEGY

LEVELS OF PROJECTS AND/OR ASSESSMENTS
LEADING TO STANDARDS AND ENFORCEMENTS

PROPOSED PROGRAM - OFFICE OF RADIATION
PROGRAMS

OPTIMUM PROGRAM - OFFICE OF RADIATION
PROGRAMS

RADIATION CONTROL MECHANISMS AND
HEALTH EFFECTS
                                                                 Page
        xxi


       xxv i


          4


         14


         18

         29

         32

         34


         42


         48


BACK POCKET


BACK POCKET


         75
TABLE NUMBER
               CATEGORIZATION OF RADIATION PROGRAM BY
               PROBLEM AREA WITHIN CLASSES OF
               RADIATION SOURCES
                                                   xix
                                  vi

-------
                   LIST OF ILLUSTRATIONS (Cont'd)

TABLE NUMBER                                                     Pag£

      B        SUMMARY OF RESOURCE REQUIREMENTS                xxxiii

      1        RADIATION DOSE AND EXTRAPOLATED HEALTH
               EFFECT ESTIMATES FOR THE U.S. IN 1970
               AND 2000                                             5

      2        PROBLEM COMPONENTS O'P RADIATION PROGRAMS            50

      3        PRIORITY FORMULA DATA                               51

      4        PRIORITIES AND STAGES OF PROBLEM AREAS              52

      5        RISK/COST/BENEFIT ANALYSIS - PROGRAM
               SUMMARY                                             60

      6        ORP PROPOSED PROGRAM - BUDGET FOR FY 1973          124

      7        ORP PROPOSED PROGRAM - BUDGET FOR FY 1974          125

      8        ORP OPTIMUM PROGRAM - BUDGET FOP FY 1974           126
                                  vii

-------
                                   GLOSSARY
Acronyms

   AEC
   ANSI
   AQCS
   BRH
   BWR
   CAB
   CEQ
   CFR
   COMM
   CSD
   CW
   DCPA
   DEPA
   DREW
   DNA
   DOD
   DOL
   DOT
   EERL
   EIS
   ELF
   EPA
   EBMAC
   FCC
   FDA
   FFTF
   FOD
   FP
   FPC
   FRC
   GCBR
   HTGR
   HUD
   ICRP
   IRAC
   1TDSN
   JCAE
   LMFBR
   LORAN
   LWR
   LV
   NAS
   NASA
   NBS
   NCRP
Atomic Energy Commission
American National Standards Institute
Analytic Quality Control System
Bureau of Radiological Health, DHEW
Boiling Water Reactor
Civil Aeronautics Board
Council on Environmental Quality
Code of Federal Regulations
U. S. Department of Commerce
Criteria and Standards Division, ORP
Continuous Wave
Defense Civil Preparedness Agency
Defense Electric Power Administration
Department of Health, Education, and Welfare
Defense Nuclear Agency, (DOD)
Department of Defense
Department of Labor
Department of Transportation
Eastern Environmental Research Laboratory
Environmental Impact Statement
Extremely Low Frequency
Environmental Protection Agency
Electromagnetic Radiation Management Advisory Council
Federal Communications Coiumission
Food and Drug Administration, DHEW
Fast Flux Test Facility
Field Operations Division, ORP
Fission Products
Federal Power Commission
Federal Radiation Council
Gas Cooled Breeder Reactor
High Temperature Gas-cooled Reactor
Department of Housing and Urban Development
International Commission on Radiological Protection
Interdepartment Radio Advisory Committee
Institutional Total Diet Sampling Network, ORP
Joint Committee on Atomic Energy
Liquid Metal Fast Breeder Reactor
Long Range Navigation
Light Water Reactor
Las Vegas, Nevada
National Academy of Sciences
National Aeronautics and Space Administration
National Bureau of Standards, COMM
National Council on Radiation Protection and
  Measurements
                                   viii

-------
                               GLOSSARY (Continued)
Acronyms

   NEPA
   NERC
   NGS
   NIOSH

   NOAA
   NRDS
   NTS
   OAP
   OCP
   OEP
   OFA
   OGC
   OMB
   OPE
   0PM
   ORM
   ORP
   OSHA
   OSW
   OTM
   DTP'
   OWP
   PAG
   PMN
   PWR
   RAN
   RGB
   RF
   SNAP
   STORE!

   TAD
   TLD
   USBM
   USDI
   USPHS
   WERL
   WLM
National Environmental Policy Act
National Environmental Research Center
Natural Gas Stimulation
National Institute for Occupational Safety and
  Health, D11EW
National Oceanic and Atmospheric Administration, COMM
Nuclear Rocket Development Station
Nevada Test Site
Office of Air Programs, EPA
Office of Categorical Programs, EPA
Office of Emergency Preparedness
Office of Federal Activities, EPA
Office of General Counsel, EPA
Office of Management and Budget
Office of Planning and Evaluation,  EPA
Office of Program Management, EPA
Office of Research and Monitoring,  EPA
Office of Radiation Programs, EPA
Occupational Safety and Health Administration, DDL
Office of Solid Wastes, EPA
Office of Training and Manpower, EPA
Office of Telecommunications Policy
Office of Water Programs, EPA
Protective Action Guidance
Pasteurized Milk Network, ORP
Pressurized Water Reactor
Radiation Alert Network, ORP
Risk/Cost/Benefit
Radio Frequency
Systems for Nuclear Auxilliary Power
Storage and Retrieval of Water Quality and Hydrologic
  Data
Technology Assessment Division, ORP
Thermo-lurainescent Dosimeter
U. S. Bureau of Mines
U. S. Department of the Interior
U. S. Public Health Service, DHEW
Western Environmental Research Laboratory
Working Level Month
                                   ix

-------
                        SUIu-^RY  OF  nATlUI/L j'iwl/.i.'j.v
                   PROTECTION r;;ocf.:ji sriAi'i.^' A..O J'LA:;
NEED FOR A NATIONAL PROGRAM PLAN

     The Environir.cn tal  Protection Agency h^s tit Mandate to protect

public hunlch and  Lo  ii.surc the qua! it'- of I he ur.virriruint with res-, lot

to radiation exposure .   The total radial. Ion ibt * (as neasured in r. ca-

roms) to ths population is  beco-Dlrj more severe si'.iply at. e "result cf

population growth, uhich exposes  uovc. pcay^le Lo potf.rtlal radiation

hazards.  Also, radiation froc a  variety ot sources is liktily to increase.

The nation's energy requirements  for generating electricity, for example,

are doublin,, about every 9  years.  An increasing portion of these energy

requirements are likely to  'be satisfied in the next 3C-40 years by
installation  of  nuclear power plants, which provides a snail  ir.c.rt.D.r'i.t
concentrations)  have  declined in the latter psrc of the 1960 's because

of the reduction in atmospheric nuclear device tests, a larger popula-

tion is exposed  to  some radiation from this source as well as from

natural sources  (e.g.,  cosmic rays, natural radioactivity in materials).

Increased  exposure  from X-rays and other medical use of radiation  has

grown significantly.   Although the genetically significant dose  from

medical X-rays has  shown a slight decrease from 1965 to 1970 according

to pruli=ii:iuiy rui-ul-.t  ol a re:er.«- -t:;..iy; this cnr^ribucisr.  uo EUH'S,

total is so  large and important that every effort, irjst be made to  insure

that no increase in per capita dose is Forthcoming,  the total man-rera

dose to the  U.S. popul?tinri f>cm natural . medical, occupational, fallout

and other  miscellaneous sources Js estimated to rail j.n thf:  langc  irora
                                 x

-------
 ',6.7 million  ~o  93.4 aUlion  in  chc ycir  2COO.   This con^nrcs with an




 estimated 43.3 million Man-rem cloce ir. .1970.   Part: of those increases




 is strictly duu  to a growing  population.  The  lower figure for the year




 2000 reflects an a^re^siva health  ph,sics  prograr, using up-to-date




 tpr.hniqaes Jic equipniG.it, especailly  in the area of aadical X-rays.




 The higher value might be expected  to  result i'roni a somewhat complacent




 health physics program.




      There is an additional potential  threat to  cquipnsnc  and personnel




 resulting fron nonionizing radiation from sources,  such  as radars,




 radiofrequency conrr.unications devices, microwave  ovens,  medical diathermy




 devices and  industrial heating equipment.   The nuc.ber of radiofrequency




 and nicro;r?ve sources is estimated to'increase 15%  a;ir.uallv).   A great




 Ccal ..u,-c x:-t b.- leii-neH ^hout  the severity of related  health effects;




 both the L-icrrnal  «.r.d  no-tlieical  effects n:u&t be investigited  Jn termy




 of  their short-term and long-term aspects.




      Exposure  of  the  human population and  the  environment  to radiation




 occurs  from a  variety  of  diverse  sources.   The  health and  environmental




 hazard  oust be considered froa the standpoint of the accumulated dose




 to  individuals, the population, and  the environment irons all sources




 collectively over the lifetvne of  the population and the continued




 accuuiui^Li..!. in rhe uijvironfnt.   Ionising  radiation froc the utilization




of nuclear energy sources, aedical and  cccupptional uses, naturally




occurring radiation, both avoidable  and unavoidable, and  all other




sources of relation must be taken into account  in computation of  popu-




lation and individual aos>e.  The sc.r;c is tru^ for  nnniorj.zing radiation







                               y.i

-------
from all sources, although, the health ta.-. art's are less well defined  at


this time.


     While contributions fron specific source categories may  be  relatively


small, thn cumulative effect may be significantly larse and must bs


clearly determined.


     Since diffeircnt sources of radiation have varying degrees of


threats associated with thorn, there must be  a priority oideiing  of the


hazards such that our resources can be focused nost  effectively.


     At our present state  of knowledge,  it  is necessary  that-  we  sss.uue


that any  radiation is harmful to health  and  perhaps  the  environment.


Therefore, it  is the policy of  the Office of Radiation Programs  (ORP)


that there snould be no exposure of  individuals,  the population  or the


envivoairient  to SKV  laveis  oL  rauiacion /unless, uesf l-i-ol^.  oTIai-l.l-i.ii:,


benefits  exist which -.aUr.  the assumption of  risi: worthwhile.


     The  radiation protection problem is technicall} complex because


of  the need  to control  a variety of  diverse sources on a cost-effective


basis  taking into  account  risk  and  benefit  from each source.   For this  /^
                                                                         i*

reason it is imperative to have an  explicit Strategic National Program


for Radiation Protection  to effectively  manage the technical complexities


of  the problem.



AUTHORITY AND JURISDICTION


      The EnvironD-.eutal Protection Agency has available two primary


 sources for its authority to conduct radiation protection programs:


 (n) tho r;?di?f-;on gviH.ince function of the  forcer Federal Radiation
                                  xti

-------
 Council,  with its specific statutory authority; and (b) the authority




 forrerly  vested with the Atomic Enerpy Connie sion to sot gen^reil.ly




 applicable  onvironr.ental radiation standirds, which has no specific




 statutory b-isis.   Also transferred co E?A Irom the Ueparlnent of Health,




 Education and l-'elfare (PHEW),  was the authority to protect the public




 health with regard to radioactivity (Section 201 oi' i'he Public Health




 Service Act,  42 USC 2ie .Agency n«s 'a. piii.ie iv-a^u.-.-lli^lity la «r">•>?!f'n




 comments  on  Environmental  Inpact Statements to other federal agencies as




 required  by  Section 102-C  of  the National Environmenta1 Policy Act (NEPA)




 of 1970.




     The  transferred ""ederal Radiation Council functions give KPA the




 responsibility  for  examining all radiation threats and providing, through




 the President,/guidance  on radiation  protection policy to all Federal




 agencies.  The  environmental star.oards-satting function transferred frora




 the AEC gives  the Agency the direct:  tebponsibili'.j  lor sr:r.ci::y st-mn^rds




for radiation  exposure or  radioactivity concentration limits in LUC




general environment  outside the boundaries of Tacilities under the




control of persons  licensed by  die ADC cr cy A{jr
-------
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

-------
      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
                                  trade—off  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=
-------
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

-------
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 .•*>*•
-------
 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

-------
      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

-------
      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

-------
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

-------
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

-------
                                                     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

-------
               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

-------
 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

-------
     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

-------
  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

-------
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

-------
                 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

-------
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

-------
\
^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
GROUP




:sjj:;J!!f
'•'$..•• ;!l




















o e e'<






• '
F ' r I '
I '"\'<

















) e o e










flllU












CO
t-
LL
LU
HEALTH BE^
GROUP A "











il" ',










CO
t- '

LU
ENVIRON. BE
GROUP A













jjj;j||
|ii ||j
V ' ' 1







u.
LU
LU
AESTHETIC!
GROUP A
















I'll-'
|;!'il




CO
I-

LU
z
CONVEN.'BE
GROUP A


















^ ! 1 i i
lj|fij!



CO

u.
U)




OTHER BEN
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

-------
     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

-------
 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

-------
      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

-------
 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

-------
      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

-------
 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

-------
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

-------
     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

-------
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

-------
           /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

-------
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

-------
                                                          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

-------
                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

-------
                             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

-------
       •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

-------
 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

-------
                              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

-------
                          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

-------
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  •***'(•').
-------
  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

-------
       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

-------
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

-------
  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

-------
 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
                               72

-------
 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.
                                    73

-------
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.






                                      74

-------
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

-------
     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.
                                  77

-------
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

-------
     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

-------
         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.
                                      80

-------
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

-------
       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

-------
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

-------
 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

-------
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

-------
      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).
                                     86

-------
     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

-------
and (4) establish control techniques (engineering and/or administrative)




and compliance assessment procedures appropriate for each fuel cycle.
                                   88

-------
     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

-------
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.
                                     90

-------
     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.
                                       91

-------
      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

-------
     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.
                                   93

-------
     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.
                                     95

-------
     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

-------

              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 •
                                  98

-------
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.
                                     99

-------
      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

-------
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

-------
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

-------
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

-------
      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

-------
      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

-------
     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

-------
 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

-------
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

-------
      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

-------
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

-------
     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

-------
     '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

-------
 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

-------
     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

-------
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

-------
                  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

-------
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

-------
 PAGE NOT
AVAILABLE
DIGITALLY

-------