NATIONAL RADIATION PROTECTION
PROGRAM
APPENDIX A • RISK/BENEFIT RATIONALES
APPENDIX B • GENERIC FUNCTIONS
APPENDIX D - COORDINATION
APPENDIX E • LEGISLATION
APPENDIX F • PRIORITY COMPUTATIONS
OFFICE OF RADIATION PROGRAMS
ENVIRONMENTAL PROTECTION AGENCY
OCTOBER 1972
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APPENDIX A
RISK/BENEFIT RATIONALES
TABLE OF CONTENTS
RISK/BENEFIT RATIONALES A-l
SELECTION OF RADIATION PROGRAMS A-l
> ENERGY USES A-3
RISKS A-3
Introduction A-3
The Uranium Fuel Cycle - Sources A-5
Relative Threat Analysis - Uranium Fuel Cycle A-24
Plutonium Fuel Cycle - Sources A-31
Relative Threat Analysis - U vs. Pu Fuel Cycles A-35
Thermonuclear Power Generation A-37
Relative Threat Analysis - Thermonuclear A-38
BENEFITS A-39
Introduction A-39
Magnitude Estimates A-41
RISK/BENEFIT TRADEOFFS A-42
Introduction A-42
General A-43
Specific A-44
(NONENERGY USES A-47
RISKS A-47
Sources A-47
Health and Environmental Effects A-51
Long-Term Effects A-52
BENEFITS A-58
Sources A-58
Magnitude Estimates A-60
RISK/BENEFIT TRADEOFFS A-63
General A-63
Specific A-65
»NATURAL RADIATION A-68
RISKS A-68
Sources A-68
Health and Environmental Effects A-69
Relative Threat Analysis A-71
BENEFITS A-72
Sources A-72
Magnitude Estimates A-72
RISK/BENEFIT TRADEOFFS A-73
General A-73
Specific A-74
INONIONIZING RADIATION A-76
Introduction A-76
RISKS A-77
Sources A-77
Health and Environmental Effects A-78
A-i
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APPENDIX A
TABLE OF CONTENTS (CONT'D)
Page
Short-Term Effects A~81
Long-Term Effects A~83
Relative Threat Analysis A-83
Magnitude of Benefits A-85
RISK/BENEFIT TRADEOFFS A~85
General A~85
Specific A~87
LIST OF TABLES
TABLE NUMBER Paee
A-l RADIATION DOSES FROM PRODUCTION OF
URANIUM FUEL FOR 1000 MWE-YR ELECTRICITY A-7
A-2 ESTIMATED NORMALIZED RADIATION DOSES
FROM ROUTINE REACTOR OPERATIONS A~9
A-3 POTENTIAL EXPOSURES FROM 1000 MWE
NUCLEAR REACTOR ACCIDENTS A~12
A-4 DOSES FROM PROCESSING URANIUM FUEL FOR
1000 MWE-YRS. OF ELECTRICITY GENERATION A-15
A-5 PROJECTED FUEL PROCESSING WASTES FROM
TOTAL U.S. NUCLEAR POWER ECONOMY (AQUEOUS
PROCESSING OF ALL FUELS) A~17
A-6 COST FOR RADIOACTIVE WASTE DISPOSAL A-21
A-7 ESTIMATED DOSE RATES FROM TRANSPORTATION
OF SPENT FUEL AND WASTES ASSOCIATED WITH
1000 MWE-YR OF NUCLEAR ELECTRICITY
GENERATION A~23
A-8 ESTIMATED ANNUAL POPULATION DOSES FROM
COMPONENTS OF THE URANIUM FUEL CYCLE IN
YEAR 2000 A~29
A-9 ESTIMATED PRODUCTION OF LONG-LIVED RADIO-
NUCLIDES BY NUCLEAR POWER REACTORS A-34
A-ii
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APPENDIX A
TABLE OF CONTENTS (CONCLUDED)
TABLE NUMBER Page
A-10 NONENERGY SOURCES OF ENVIRONMENTAL EXPOSURE A-48
A-ll PROJECTED PER CAPITA POPULATION DOSE RATES
FOR THE YEARS 1970 AND 2000 A-55
FIGURE NUMBER Pa6e
A-l SCENARIO NO. 1 (NO BREEDERS CURRENT FOSSIL
CAPITAL COSTS): LWR + FOSSIL FUELS A-25
A-2 SCENARIO NO. 2 (MAXIMUM BREEDERS): LWR +
LMFBR + FOSSIL A-26
A-3 SCENARIO NO. 3 (MOST LIKELY): LWR + HTGR +
LMFBR + FOSSIL A-27
GLOSSARY A-iv
A-iii
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GLOSSARY
Acronyms
AEC
ANSI
AQCS
BRH
BUR
CAB
CEQ
CRF
CIA
COMM
CSD
CW
CZ
DCPA
DEPA
DREW
DNA
DOD
DDL
DOT
ECAC
EERL
EIS
ELF
EPA
ER
ERAB
ERMAC
FAA
FCC
FDA
FFTF
FOD
FP
FPC
FRC
FTP
GCBR
GSD
HASL
HTGR
HUD
ICRA
ICRP
IGSY
IRAC
IRAP
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
Central Intelligence Agency
U. S. Department of Commerce
Criteria and Standards Division, ORP
Continuous Wave
Canal Zone, Panama
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
Electromagnetic Compatability Analysis Center
Eastern Environmental Research Laboratory
Environmental Impact Statement
Extremely Low Frequency
Environmental Protection Agency
Environmental Report
Electromagnetic Radiation Analysis Branch, ORP
Electromagnetic Radiation Management Advisory Council
Federal Aviation Agency
Federal Communications Commission
Food and Drug Administration, DHEW
Fast Flux Test Facility
Field Operations Division, ORP
Fission Products
Federal Power Commission
Federal Radiation Council
Full-time Permanent
Gas Cooled Breeder Reactor
Genetically Significant Dose
Health and Safety Laboratory
High Temperature Gas-cooled Reactor
Department of Housing and Urban Development
Interagency Committee on Radiological Assistance
International Commission on Radiological Protection
International Geophysical Study Year
Interdepartment Radio Advisory Committee
Interagency Radiological Assistance Emergency Plan
A-iv
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GLOSSARY (Cont'd)
Acronyms
ITDSN
ITS
JGAE
LMFBR
LORAN
LWR
LV
MLQN
MPG
NAJ
NASA
NBS
NCRP
NEPA
NERC
NEXT
NGS
NIOSH
NOAA
NRDS
NSF
NTS
GAP
OCP
OEGC
OEP
OFA
OGC
OMB
OPE
0PM
ORNL
ORP
OSHA
OSW
OT
OTM
OTP
OWP
PAG
PAHO
PMN
PWR
RAN
RGB
, RPG
RF
Institutional Total Diet Sampling Network, ORP
Institute of Telecommunication Sciences
Joint Committee on Atomic Energy
Liquid Metal Fast Breeder Reactor
Long Range Navigation
Light Water Reactor
Las Vegas, Nevada
Medical Liaison Office Network
Maximum Permissible Concentration
National Academy of Sciences
National Aeronautics and Space Administration
National Bureau of Standards, GQMM
National Council on Radiation Protection and Measurements
National Environmental Policy Act
National Environmental Research Center
National Evaluation of X-ray Trends
Natural Gas Stimulation
National Institute for Occupational Safety and Health, DHEW
National Oceanic and Atmospheric Administration, COMM
Nuclear Rocket Development Station
National Science Foundation
Nevada Test Site
Office of Air Programs, EPA
Office of Categorical Programs, EPA
Office of Enforcement and General Counsel
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 Research and Monitoring, EPA
Oak Ridge National Laboratory
Office of Radiation Programs, EPA
Occupational Safety and Health Administration, DOL
Office of Solid Wastes, EPA
Office of Telecommunications
Office of Training and Manpower, EPA
Office of Telecommunications Policy
Office of Water Programs, EPA
Protective Action Guidance
Pan American Health Organization
Pasteurized Milk Network, ORP
Pressurized Water Reactor
Radiation Alert Network, ORP
Risk/Cost/Benefit
Radiation Protection Guide
Radio Frequency
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Acronyms
SAR
SID
SNAP
STORET
TAD
TLD
TNP
TSS
USBM
USDI
USGS
US IA
USPHS
WERL
WHO
WLM
GLOSSARY (Concluded)
Safety Analysis Report
Surveillance and Inspection Division, ORP
Systems for Nuclear Auxilliary Power
Storage and Retrieval of Water Quality and Hydrologic Data
Technology Assessment Division, ORP
Thermo-luminescent Dosimeter
Thermonuclear Power
Tritium Surveillance Survey
U. S. Bureau of Mines
U. S. Department of the Interior
U. S. Geological Survey
U. S. Information Agency
U. S. Public Health Service, DHEW
Western Environmental Research Laboratory
World Health Organization
Working Level Month
A-vi
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APPENDIX A
RISK/BENEFIT RATIONALES
SELECTION OF RADIATION PROGRAMS
The basic selection of project and program activities involving
radiation should be based on a detailed examination of the growth of
various radiation-related activities over, say, the next fifty years.
The extent of this growth, the component parts of it, the health effects
and costs to society and the economy in general, should form the basis
for the selection of the priority areas with which the Environmental
Protection Agency concerns itself. An examination of these areas
requires, therefore, a long-range projection of the activities using
the best available information and a careful examination of those
aspects of the uses that represent the largest component of environ-
mental risk. Attendant to this examination relative to establishing
program priorities are also identification of gaps in knowledge; the
possibility of controlling environmental impact; and the protection
index acheived from radiation in terms of minimizing or preventing
radiation exposure or long-term irreversible contamination of the
environment with radioactivity. ,
The areas to be examined in developing the radiation rationale
are categorized according to source class as follows:
1. Generation and use of nuclear energy
a. Uranium Fuel Cycle
Fuel Fabrication
Reactor Operation
Reactor Accidents
Fuel Reprocessing
Waste Disposal
Transportation
A-l
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b. Plutonium Fuel Cycle
c. Controlled Thermonuclear Power
2. Nonenergy uses of Radiation
a. Medical
X-ray
Isotope
b. Occupational
c. Isotope Care and Disposal
d. Device Testing
e. Plowshare Projects
3. Natural sources of Radiation
a. Mining and Mill Tailing
b. Construction Materials
4. Nonionizing sources of Radiation
a. Microwave
b. Radio Frequency
c. Laser
Each of these major source classes is examined in detail in the
following sections and attempts were made to evaluate the significant
environmental radiation program areas on the basis of the information
currently available. Each source class is discussed with respect to
risks, benefits, and tradeoffs between the two.
A-2
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ENERGY USES
RISKS
Introduction
In the generation and use of nuclear energy there are three major
sources that contribute to radiation risks: (1) the uranium fuel cycle;
(2) the plutonium fuel cycle; and (3) controlled thermonuclear fusion.
The magnitude oE risks associated with these various uses over the long
term is obviously dependent on projections of growth of each of these
uses. Current projections of the use of uranium fueled reactors and the
associated activities of the rest of this fuel cycle are satisfactory.
The ability to make projections on the plutonium fuel cycle involving
the Liquid Metal Fast Breeder Reactor is a little difficult because
this use of energy is still in the developmental stage. The controlled
thermonuclear energy cycle is still just a conceptual idea; therefore,
very little examination of this problem area relative to environmental
radiation exposure is possible at this time.
It is djfficult to anticipate any environmental levels of radiation
relative to nuclear energy use except those following a major catastrophe
that would result in acute radiation exposure that would be measurable
directly in deaths. For this reason, the perspective for environmental
radiation protection and the justification for programs associated with
it must necessarily consider the effects of the chronic exposure of
large populations, which is best expressed in man-rems. The use of
nuclear energy will, therefore, be examined in terms of those problem
A-3
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areas that represent man-rem exposures to the population of the Nation.
Within this context, the major components of risk are associated with:
(1) chronic low-level exposure from radiation which results from the
conduct of the various activities of reactor operation, fuel reprocessing,
etc., and (2) chronic, but increasing, low level radiation exposure
which occurs as a result of the gradual long-term accumulation of long-
lived radionuclides as general environmental contaminants.
Examples of the second category involving long-term dose commit-
ments are tritium, krypton-85, plutonium and other actinides, and
iodine-129 which have the potential to enter the general hydrologic
and atmospheric environment and expose the entire population of the
Nation or the earth for many generations. Even though these radio-
nuclides are controllable so that exposures of individuals near the
plants and facilities will be small, the long-term dose commitments
in man-rems to the entire population will persist for about a century
for any discharges of krypton-85 or tritium, a few hundred thousand
years for plutonium-239, and millions of years for iodine-129. In
many respects, these radionuclides would not be unlike lead, mercury,
and other heavy metals that are now known to contaminate the environment
as a result of uncontrolled technological change, except that gram-
per-gram they are extremely more toxic. An important risk perspective
relative to long-lived radioactive substances is to consider them in
such a way to assure that they do not follow the same pattern of the
heavy metals and become widely distributed in the environment.
A-4
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The Uranium Fuel Cycle - Sources
A major national effort has been under development for the past
decade or so involving the generation of electricity by light-water
cooled nuclear power plants using enriched uranium for fuel. Although
recently proposed amendments to AEC regulations (10 CFR Part 50,
Appendix I) indicate that routine discharges .of radioactive waste
from nuclear power reactors will be of little environmental consequence,
the current rapid growth pattern of this energy source represents a
considerable increase in other activities of the uranium fuel cycle
for these plants. The volumes of radioactive waste that must be shipped
to burial grounds or from the fuel reprocessing plants to ultimate
disposal sites will increase sharply in a few years. The mining, milling,
and fabrication of uranium will also increase rapidly as the number of
plants go on line.
Since it will be somewhere in the late 1980*s before the fast breeder
reactor can be expected to replace light water reactor growth, it can be
projected that well over 300,000 MWe of generating capacity based on the
uranium fuel economy will exist within the next twenty years. Therefore,
the potential environmental problems associated with the other components
of the uranium fuel cycle can be expected to be in existence for quite
some time and will be similar for even longer periods for the plutonium
fuel cycle. The major environmental problem areas associated with nuclear
power growth thus appear not to be tied to the increase in reactors them-
selves but are related to the growth of the other activities that must
A-5
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exist to support the reactors. The major foci for these potential environ-
mental problems relate primarily to the transportation of spent fuel and
waste, the reprocessing of spent fuel, and the disposal of both low level
and high level radioactive wastes. In the next few years there will be
considerable demands on these components of the industry with potential
environmental effects resulting.
Mining and Fabrication - Uranium
In the production of uranium fuel for nuclear power reactors there
are four major steps from the ore to the final nuclear fuel element:
1. Mining which may be underground or open pit
2. Milling which is often done at the mine site
3. Enrichment of the uranium to a level of 2 - 5 % U-235
4. Fabrication of the fuel
The doses from the four major components of the provision of uranium
fuel are shown in Table A-l. It is evident from these data that the
major individual and manrem exposures are due to the occupational
aspects of mining the uranium and fabricating the fuel. The data
shown are for 1000 megawatt electrical years of electricity generation
at the power plant.
Control costs relative to producing nuclear fuel are dependent
on assumed standard operating situations. In 1970, 84% of the uranium
mined was from underground sources which necessitated costs for control
of radon exposure of the miners. The cost to comply with a standard
of 8 WLM/yr was estimated to be $0.10 per pound of UQ0Q. The cost of
J O
better radon control at a level of 4 WLM/yr has been estimated to
increase to $0.25 per pound of U30g, or about $850 per metric ton of
uranium produced. A mine producing 600 tons of ore per day would
A-6
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TABLE A-l
RADIATION DOSES FROM PRODUCTION OF URANIUM FUEL
FOR 1000 MWE-YR ELECTRICITY
Source
Mining
(Occupational)
Max
Individual
(Rem)
33-112
(bronchia)
Low
(Man-Rem)
100
(bronchia)
High
(Man-Rem)
320
Milling
(Occupational)
Milling
(Environmental)
Fuel Fabrication
(Occupational)
Fuel Fabrication
(Environmental)
Enrichment Plant
(Environmental)
2.5
.0015
2.5
4-20 (kidney)
4-20 (kidney)
15
370
13 (kidney)
2500
-------
/
yield approximately 1 metric ton of uranium per day. If the mine
operated 300 days per year, the annual cost of increased radon control
at A WLM/yr would, therefore, be approximately $255,000 per year or
$29,000 per 1000 MWe-yrs of electricity produced. It appears from the
low environmental dose rates from milling ore that incremental control
costs would be minimal. The control of exposures for fabrication
facilities is related to increased filtration of air streams. The
cost of these measures to reduce exposures to less than 1% of 10 CFR 20
values would be about $39,000 per 1000 MWe-yrs of electricity produced.
The total increased cost for optimum control of exposures from mining
to eventual fuel fabrication is, therefore, about $70,000 per 1000 MWe-yrs
of electricity produced.
Reactor Operations - Uranium
The estimated annual population doses per 1000 MWe-yrs of reactor
operation are presented in Table A-2 as a function of the type of reactor
and exposure pathway. Exposure pathways considered were limited to
•7
(1) local, e.g., within 50 miles, effects of noble gas releases; ^c
(2) iodine (and particulate) ingestion doses via milk; and (3) in- \^
gestion of drinking water and fish. Exposure pathways via other foods
were not included because of their negligible contribution to population
exposure compared with the ones estimated.
The whole body dose rates from gaseous releases were evaluated for
three conditions: current release levels, expected release rates consistent
with the philosophy of "low as practicable" of 10 CFR 50, and abnormal
conditions. In order to predict the future man-rem doses, the ratio of
the man-rem/mrem doses was held constant for future years. The man-rem/
mrem ratio for BWR discharges from the future was assumed to be the same
A-8
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PWR
BWR
TABLE A-2
ESTIMATED NORMALIZED RADIATION DOSES
FROM ROUTINE REACTOR OPERATIONS
Pathway
Airborne0
Iodine®
Water
mrem/GWe
man-rem/GWe-y
mrem —
organ/rem
Current
12
30
Future
10/1970 pop<4>
1100/106 people 30/106 people
man-rem/106 pop 20/106 people 20/106 people
Airborne^ mrem/IWe-y
man-rem/GWe-y
Iodine® organ-i
Water®
-rem
man-rem
HTGR/LMFBR
Airborne^' mrem/GWe-y
man-rem/GWe-y
Iodine® organ-rem
Water® man-rem
40
350
10
25/1970 pop,
1100/106 people 30/106 people
20/106 people 20/106 people
5/1970 pop.
3/106 people
1
Abnorn-.al
10
30/1970 pop.
300/106
20/106
20
50/1970 pc?.
300/106 peopl;
20/106 pecpl:
10
30/1970 pop.
30/106 people
1
*Noble Gas release to local population (50 miles)
Milk and inhalation pathway
Water and aquatic biota consumption
1970 population assumed to be 205,000,000 based on U.S. Bureau
of Census data, "Projections of the Population of the United States,
by Age and Sex 1920 to 2020", U.S. Bureau of the Census, Department of
Commerce, Series P-25, Number 470, November, 1971.
A-9
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as for PWR discharges since future releases from BWR's are anticipated to
be from building vents. Thus, in the future, the man-rem/mrem ratio for
the BWR (currently 8.6) may approximate that for a PWR (2.5). The popu-
lation doses resulting from liquid releases assumed a water dilution factor
of 100 and lOg/day fish consumption.
Since there is little or no operating experience with the HTGR and
LMFBR, only informed estimates could be made regarding their expected
releases. For noble gas releases, it was assumed that the site boundary
dose would be 1/5 of those for the BWR (assumed to be 10 mrem/yr).
Reactor Accidents
Accidents are an important consideration for environmental
radiation protection in that the potential always exists for them
to occur no matter how well a component of the nuclear industry is
managed, operated, or regulated. The total risk to the nation's
environment from the operation of reactors involves the quantities
of radioactive material released, how it is released, the probability
of events, and the consequences.
The most difficult aspect of radiation accidents is the deter-
mination of environmental or public health risks from events with
low probability of occurrence. An additional difficulty is the very
real possibility that events may occur which were totally unexpected
(thus not designed for) with the result that the true risk may never
be known. It is important to arrive at an expression of an environmental
risk commitment (ERG) which is basically the risk that will be taken
by the environment or the public over the 40-year,'lifetime of a *^
V.. __ " " . . '
facility. Such an ERG would be the sum of all estimatable risks. Risks fi>
A-10
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for each incident are proportional to the consequences of the incident
(expressed as man-rems or dollars lost) and the probability of the
event occurring. Within this concept, therefore, events of low con-
sequence may very well carry a higher ERG than events of high consequence
simply because of differences in the probability of occurrence. This
situation appears to be the case for minor reactor accidents, which is
generally believed to be probable, versus, say, the major nuclear
catastrophe, which has an almost incalculably small probability of
occurrence.
As shown in Table A-3 the accidental release of radionuclides
from uranium fueled nuclear reactors could result in maximum exposures
ranging from a fraction of a rem to lethal doses of several hundred
rem, and in cumulative population exposures ranging from less than
one to hundreds of thousands of man-rem. Property damage may range
from negligible to a situation where substantial areas could be made
permanently uninhabitable. Incidents as used in Table A-3 are those
accidents which can be expected to occur relatively more frequently
during reactor operation, but whose consequences are expected to be
minor because facilities are designed to cope with such events. Major
accidents are those which might occur once during the time that the
United States energy consumption philosophy requires the -use of nuclear
fuels and which may result in relatively large scale exposure to the
public. Major accidents are, therefore, assumed to be those which may
have significant consequences beyond site boundaries.
Experience to date with accidents is very limited. No"major
accident" has occurred. Minor accidents which have occurred have been
A-ll
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TABLE A-3
POTENTIAL EXPOSURES FROM 1000 MWe
NUCLEAR REACTOR ACCIDENTS
Exposure Source Individual Dose (Rem) Man-Rem
Incidents (probable) .01-1 1 - 2000
Loss of coolant (improbable) 1-10 10 - 1000's
Major meltdown (highly improbable) > 500 > 100,000
A-12
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limited, so that release of radioactive materials to the environment has
been minimized. We are, at the present time, operating with a U.S. data
base of less than 200 reactor years of experience (accumulated on rela-
tively small units); therefore, our estimation of reactor accident
probabilities and consequences is not well defined. Cost estimates are
also subject to considerable uncertainty, both because of changing
design philosophies and changing economic situations. In general,
however, since accidents relate to overall safety the costs in this
category are assumed to already be at the optimum level of control
and further costs for increments of control are nearly impossible to
develop.
Fuel Reprocessing - Uranium
It is estimated that seven large fuel reprocessing plants will be
needed in the early 1990's to process fuel from the 350 reactors ex-
pected to be in operation. Current capital costs for a reprocessing
facility are estimated to be about 100 million dollars. Since such a
plant processes fuel from 50 reactors, each costing 300 to 400 million
dollars, reprocessing does not contribute significantly to power produc-
tion costs.
Light water reactor fuels containing plutonium recycle and the
LMFBR fuels are amenable to processing in present day plants. However,
HTGR fuel design will require technology not presently available for
initial processing ("head end" operation) steps, although the same
chemical process (Purex) will probably be used •
Current generation reprocessing plants are designed to eliminate
the routine discharge of radionuclides as liquids. These designs appear
A-13
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to be viable. The discharge of gaseous radionuclides at reprocessing
plants is considerable in that essentially all the krypton-85 and
tritium is discharged to the atmosphere. In addition, considerable
quantities of iodine have been discharged in the past. The recently
developed iodine cleanup systems have not been proven for full scale
routine operation. The discharge of the trans-uranic elements as parti-
culates may also be significant because of the extreme radiotoxicity
of some of them. The discharge of the extremely long lived plutonium-239
and iodine-129 potentially presents an adverse environmental impact be-
cause they will accumulate in the environment.
Operators of fuel reprocessing plants are now required by the AEC
(10 CFR Part 50 Appendix F) to solidify all liquid radioactive wastes
within 5 years of processing and ship them to a federal repository
within 10 years of processing. The solidification of high level wastes
has not been demonstrated on commercial wastes which will have a
considerably higher fission product content than AEC generated wastes.
However, based on limited data, the discharge of semi-volatiles, such
as ruthenium, appears to be considerable with resulting individual
exposures of about 5 mrem/yr per 1000 MWe-yr and about 28 man-rem/yr
per 1000 MWe-yrs. Taking the above factors into account, the population
dose from reprocessing uranium fuel and solidifying the liquid wastes
has been calculated as shown in Table A-4 for 1000 MWe-yrs of electricity
generation. For purposes of these calculations, it was assumed that
the product-on of 1000 MWe-yrs of electricity would require 37 MTU
of uranium fuel to be reprocessed.
A-14
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TABLE A-4
DOSES FROM PROCESSING URANIUM FUEL FOR
1000 MWe-YRS. OF ELECTRICITY GENERATION
Max
Individual Low High
(mrem) (Man-Rem) (Man-Rem)
Xe133- Kr85 17 .01 16
H3 3 x 10~5 .06 50
Iodine (thyroid) 130 3 x 10~3 600
Actinides 210 2 x 10~* 200
Ruthenium 5 28
Total 154 mrem 28 894
A-15
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Radioactive Waste Disposal
The disposal of radioactive wastes is common to every aspect of
nuclear energy use. Areas of concern for radioactive wastes include
not only those generated by the Atomic Energy Commission but also
those wastes assigned to state-licensed commercial solid-waste burial
grounds, and (most critically) the projected amounts of wastes from
reprocessing of both light-water and fast breeder power-reactor fuels
and from power-reactor operations. These wastes are currently being
produced in a variety of solid, liquid, and gaseous forms, are being
treated in complex ways, and are currently being disposed by a variety
of methods to ground, air, and water.
Although the primary principle for radioactive waste disposal is
simply to isolate it from the biosphere until it undergoes radioactive
decay, perspectives on the risks related to storage or disposal are
complex. Decisions on storage or disposal have potentially far-reaching
effects because of the long-lived hazard of some of the wastes, ranging
from tens to several hundreds of years for tritium, to hundreds to a
thousand years for strontium- and cesium-bearing wastes, and more than
100,000 years for plutonium-bearing wastes. The major threat for such
wastes is, therefore, the potential that these products may not always
be isolated from the biosphere.
In view of the energy crisis in the United States, pressures exist
for some immediate decisions on radioactive-waste management and disposal
related to the nuclear industry. This necessity is clearly illustrated
for the projected amounts of such wastes as shown in Table A-5. However,
immediate large economic or environmentally permanent commitments to
any particular schemes of waste disposal do not seem warranted by the
A-16
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Table A-5
PKUJECTKD FUEL PROCESSING WASTES FROM TOTAL U.S. NUCLEAR
POWER ECONOMY (AQUEOUS PROCESSING OF ALL FUELS)
(Source: ORNL-4451, p. 3-59)
Caler.d-ir Year
installed capacity. ] O3 Hu (electrical)*
Volume of waste generated, as liquid15
Annually, 106 gil/year
AccuTiilated, 10 gal
Vol-L-e of waste c">nerated. as solid0
Annually, 103 ft3/year
Accumulated, 103 ft3
Accumulated radioisotopes
Total weight, metric tons
Total activity, negacuries
Total heat-generation rate, megawatts
90
Sr, megacuriea
117
C3, megacuries
1?9I, curies
Q i*
OS
Kr, megacuries
T
•'H, megacuries
H • Q
Pu, megacuries6
239 e
Pu, megacuries
Pu, megacuries6
^•Pu, megacuries6
2U2Pu, curies6
Am, megacuries6
JAm, megacuries
2Lli,
oni, raegdcun.es
2li2
Cm, megacuries
1970
111
0.017
0.017
0.17
0.17
1.75
210
0.91
3.98
5.27
1.85
0.56
0.033
0.002
0.00009
0.00013
0.0295
0.35U
0.0089
0.0009
0.128
0.725
1980
153
0.97
U.liO
"
9.73
Wi.O
Wl
18,900
81.6
962
1280
U76
12U
7.29
1.20
0.022
O.OU09
6.63
91
2.31
0.232
29.9
U3.2
19?0
368
2.69
23.8
26-. 9
238
214-0
8U,5oo
3U3
hShO
65hO
2700
567
36.2
8.28
0.235
0.395
U7.2
910
22.7
1.1*9
137
185
Endirjj
,.'000
735
U.60
60.1
U6.0
600
6200
209,000
807
9550
15,600
7550
1190
39.5
30.7
1.31
1.91
191
U870
121
5.19
255 •
U87
2020
2210
13.7
233
137
2380
2U.600
665, COG
2520
29,100
57,500
32,200
3500
332
166
8.U5
11. U
909
30,900
763
27.0
700
1U90
Data from Phase 3, Case U2, Systems Analysis Task Force (April 11, 1968).
Assumes that wastes are concentrated to 100 gal per 10^ Mwd (thermal) and that there is
a delay of 2 years between power generation and waste generation.
eAssumes 1 ft3 of solidified waste per 101* Kwd (thermal).
Assumes that LWR fuel is continuously irradiated at a specific power of 30 Mw/r.etric
ton to a burniip of 33,000 Kwd/metric ton, and that the fuel is processed 90 days af-.er
discharge from reactor; LMF3R core continuously irradiated to 8*0,000 Kwd/metric ton at
Uj8 Mwd/metric ton, axial blanket to 2500 Kwd/metric ton at U.6 Kw/metric ton, ar.d'
radial blanket to 8100 Mid/metric ton at 8.U Mw/metric ton, and that fuel ia processed
30 days after discharge.
Assumes that 0.5£ of the plutonium in the spent fuel is lost to waste.
A-17
-------
present "state of the art." No better documentation for this can be
obtained than from the AEC's insistence on "interim" storage of its own
high-level wastes for more than 20 years; from certain remedial measures
currently being attempted at several AEC sites; and from the extensive
waste-disposal research and development programs being conducted by AEC.
The general nature of radioactive-waste management problems can
be viewed as related to technologic, economic, and public-health decisions
concerning: (1) the disposal or the concentration of large volumes of
low-level liquid, solid, and gaseous wastes, and (2) the storage or the
disposal of concentrated high-level liquid and solid wastes. The dis-
posal of radioactive wastes is common to all aspects of the nuclear
industry. The nuclear industry will have generated 24,000,000 gallons
of high-level wastes by 1990; by 2000 the rate will be 4,600,000 gallons
per year. Large amounts of solid wastes (675,000 cubic ft. by 1980)
will be shipped and buried in land disposal sites.
The largest amounts of low-level wastes from nuclear energy activi-
ties consist of paper trash, packing material, broken glassware, pro-
tective clothing, and contaminated equipment, or portions of buildings.
Other kinds of materials buried at the commercial sites are reportedly
small in quantity but high in radioactivity and include bottled gaseous
tritium, air filters, air filters, spent resins, and sludges from reactor
operations; irradiated control rods, cladding and hulls from reactor
fuel elements; radioactive sources such as cobalt wafers, and materials
high in induced radioactivity. Some of these highly radioactive materials
are buried on the assumption that their induced radioactivity in "non
available" for release to the environment. Recent discussions with state
A-18
-------
authorities responsible for licensing and monitoring the commercial
waste burial grounds have shown that a great variety of materials,
including those containing low-radioactivity but high-hazard-potential
isotopes such as plutonium are being disposed. Such materials also
have been disposed in AEG burial grounds,/although current AEC policy
indicates that, in future, the wastes containing transuranic isotopes
will be stored in retreivable form.7
From the data at hand it is not possible to estimate radiation
doses from shallow land burial of radioactive wastes because the total
amounts of radioactivity buried are not known; the amounts and "avail-
ability" of radioisotopes of various hazard potentials are not known;
and the short-term, and long-range hydrogeologic factors that may trans-
port radioisotopes into the biosphere are not quantitatively well
determined because of the varied conditions of the sites.
Despite the unknown factors, such as those listed above, it is
not likely that any major adverse radiologic effect of buried "low-
level" solid wastes will be widespread. Effects on underground water
supplies from leaching of buried wastes would be minimized at properly
selected, evaluated, and monitored sites because of the slow rates of
underground water movements and the sorptive characteristics of earth
materials. Release of radioactive materials directly to surface waters
through short paths of underground migration or by erosion and exhumation
could have important effects if the water is an important source of
supply and use by humans.
Solid wastes related to reprocessing of fuel from LWRs and LMFBRs
consists of cladding hulls and associated fuel-assembly hardware which
contain neutron-induced radioisotopes as well as some of the actinides.
Accumulated volumes of cladding wastes are expected to increase from about
300 cubic feet in 1970 to around a million cubic feet in 2000. Total
A-19
-------
volume of solid wastes (including fast breeder fuels) could reach
50 million cubic feet by the year 2000 necessitating nearly 4000 acres
of burial ground for disposal.
High-level wastes generated annually from reprocessing fuel from
light-water reactors would increase from 17,000 gallons in 1970 to 1.58
million gallons in 2000, for an accumulated total of 39.2 million gallons
in 2000 if the wastes were stored as liquid. However, solidification
would reduce the volume by a factor of about 13. If the solidified waste
were placed in salt deposits some 15,000 containers occupying over 800
acrifes of a salt bed would be required.
In sofar as costs are concerned, it is advantageous to reduce the
various requirements for waste disposal to that associated with 1000
MWe yrs. of electricity generation as is shown in Table A-6. Even for
solidification of high level wastes, which is the most expensive but sup-
posedly permanent method, total costs per 1000 MWe-yr. of energy is
on the order of $75,000.
*.
Transportation
Transportation activities exist between all components of the
nuclear fuel cycle, conseuqently a different mode of risk exists for
transportation than is usually characteristic of facility operations.
Most fixedoperations or facilities have materials being transported to
and from them. Ore is shipped to mills. Uranium oxide is shipped from
the mills to the fabrication facilities which in turn, ship fuel to
reactor plants. Reactors ship certain radioactive wastes and spent fuel
to either waste burial facilities or fuel reprocessing facilities. Fuel
reprocessing facilities ship high-level and intermediate-level waste to
various facilities for disposal.
A-20
-------
TABLE A-6
COST FOR
RADIOACTIVE WASTE DISPOSAL
(not including reprocessing or transportation)
Parameters per 1000 MWe
Volume in
Cubic Feet
Land Commit-
ment for
Disposal,
Acres
Cost in Present
Dollars
Low-level Solid Wastes
from Reprocessing 18.1
to
0.01
$90.50
Lov-level Solid Wastes
from Reactor
Operations
1000
to
5000
(2500
average)
0.03
to
0.10
(0.05
average)
$12,500
High-level Wastes
from Reprocessing
Solidified
122
O.U
$1*8,180
to
$58,690
e Liquid in Tank
S torage
$280
A-21
-------
Radiation risk is associated with most nuclear shipments, hut
perhaps the two largest pertain to the shipment of spent fuel elements
from reactors to fuel reprocessing plants and to shipments of radio-
active wastes to burial facilities. These waste shipments consist of
reactor wastes and shipments of high-level waste from fuel reprocessing
facilities to disposal sites. With the increasing generation of electri-
city by nuclear power plants, the number of such shipments will increase
rapidly. It is estimated that by the year 2000 there will he 9500
shipments of spent fuel per year, and about 1000 shipments of high-level
waste per year. This amount of transportation will involve both rail and
trucks and the probability of accidents involving shipped materials is
expected to result in a number of accidents each year. In addition to
r
the accident risk, however,/there is a direct radiation exposure of the
general public as the shipments pass through populated areas.) The amount
of exposure received is, of course, dependent on the radiation levels from
the shipment containers, the length of time the shipment is in transit,
and the population density along the shipping route. Each of these modes
of exposure have been considered and estimated dose rates are shown in
Table A-7. For shipments associated with spent fuel, and waste generated
as a result of the generation of 1,000 Mw electrical years of electricity.
lt is evident from Table A-7 that individual exposures during accidents
which are expected to be infrequent, may approach individual exposure
levels contained in Federal Radiation Council guidance.\ The population
**J
dose (expressed as man rems) for accidents is, however, quite small. On
the other hand, the man rem commitment from normal transportation of
spent fuel is significant. The largest risk, therefore, associated with
A-22
-------
TABLE A-7
ESTIMATED DOSE RATES FROM TRANSPORTATION OF SPENT FUEL AND WASTES
ASSOCIATED WITH 1000 MWe-YR OF NUCLEAR ELECTRICITY GENERATION
Normal Transport
Accidental Conditions
Shipment
Spent Fuel
(whole body dose)
Spent Fuel
(Thyroid dose)
High Level Waste
Maximum
Individual
30 mrem
0.7
Low
man-rem
1
0
High
man-'rem
Jf
.002
Maximum
Individual
500 mrem
690 r
500
Low
man-rem
-6
9 X 10
-4
1 x 10
0
High
man-rem
.03
.35
-4
2.7 x 10
N)
10
-------
transportation in the uranium fuel cycle involves the routine shipment
of spent fuel between reactors and fuel reprocessing facilities. Dose
rates to individuals appear to be relatively small for this mode of
operation.
Relative Threat Analysis - Uranium Fuel Cycle
Perhaps the most significant perspective of the risks associated
with nuclear electricity generation by the uranium fuel cycle is
related to the immense growth of these activities over the next
50 years or so. Figures A-l, A-2, and A-3 represent three scenarios
of potential electrical energy growth through the year 2020. The
Figures indicate that electrical energy use, which is approximately
180 gigawatt years in 1970, will increase to approximately 1680
gigawatt years in the year 2020. The three scenarios indicate
possible variations in the components of the energy production by
fossil fuels and nuclear means. The first scenario is based on a
projection that enough uranium will be available to fuel all light-
water cooled reactors that would be required for the nuclear energy
projections as well as an increasing use of fossil fuel. The second
scenario is indicative of a more usual forecast of fossil fuel
production and indicates a maximum estimate of the use of breeder
reactors which would depend to a large .extent on plutonium. The
third scenario is considered the most likely projection of a nuclear-
fossil fuel mix of power generation and takes into account light-
water cooled reactors, gas cooled reactors, and breeder reactors.
The examinations of the relative threats of various components of the
fuel cycle with respect to potential contributions to radiation risk
A-24
-------
1600
1400 .
1200 '
;1000 •
o
10
800 '
o
600
400
200
1970 1980
1990 2000
YEAR
FIGURE A-l
2010
2020
SCENARIO NO. 1 (NO BREEDERS CURRENT FOSSIL CAPITAL COSTS): LWR +
FOSSIL FUELS
A-25
-------
1600
1400
1200
1000
H
H
800
600
400
200
1970
1980
1990 2000
YEAR
2010
2020
FIGURE A-2
SCENARIO NO. 2 (MAXIMUM BREEDERS): LWR + LMFBR + FOSSIL
A-26
-------
1600 -
1970
1980
1990 2000
YEAR
2010
FIGURE A-3
SCENARIO NO. 3 (MOST LIKELY): LWR + HTGR + LMFBR + FOSSIL
A-27
2020
-------
to the public and to the environment which follow are based on these
energy projections for nuclear means using primarily the third
scenario (Figure A-3).
The estimated population dose commitments presented in the
foregoing sections are summarized in Table A-8 as projected to exist
on an annual basis in the Year 2000. These data indicate that a
considerable number of man rems per year will exist from several
components of the uranium fuel cycle in the Year 2000, especially
from reprocessing of spent fuel. Accidents and waste disposal
operations represent two major unknown exposure situations, a fact
that makes them considerably significant. Accidents have the
potential to actually result in human deaths should they occur
with consequent high releases of radioactive material. The
significance of the unknown risks related to waste disposal is
that if many of the long-lived materials that will be handled within
this activity become available for dispersal in the biosphere they
will represent an irretrievable commitment of exposure to the
population because of widespread environmental contamination.
Although neither accidents nor waste disposal operations should
represent population risk since the principle of control is well
known, (accidents should not happen and waste disposal operations
should isolate long-lived radioactive materials from the biosphere),
these two possibilities represent significant threats and challenges
to any environmental radiation control program. These same
principles of risk estimation would also apply to the plutonium
A-2 8
-------
TABLE A-8
ESTIMATED ANNUAL POPULATION DOSES FROM COMPONENTS
OF THE URANIUM FUEL CYCLE IN YEAR 2000
U Cycle
Component
Fuel
Reactors
Accidents
Fuel Processing
Waste Disposal
Transportation
Annual Man-reins
Environmental
Pathways
5,000
35,000
Unknown
37,000-320,000
Unknown
15,000
Occupational
Exposure
920,000 ' -r»>fr
Undetermined
Unknown
Undetermined
Unknown
Undetermined
A-29
-------
fuel cycle as it begins to replace uranium in the generation of
electricity.
Another major concern for nuclear power reactors is related to
the potential for numerous large facilities to be located on or in a
common water resource or airshed with resultant cumulative contamina-
tion or exposure effects is quite possible. The likelihood of
several such occurrences is especially significant if facilities
are unable to operate at or below current radioactivity discharge
forecasts. Such failures, if they are frequent or common, would
almost assuredly produce widespread increases in the long-term
buildup of environmental contamination with resulting radiation
doses to large populations.
The most important environmental threat of the uranium fuel
cycle is the potential long-term buildup of long-lived radionuclides
that represent irreversible contamination of the environment and the
dose commitments to large populations for many generations. These
dose commitments make even the smallest discharges of long-lived
highly-toxic radioactive substances such as plutonium, the actinides,
and iodine-129 almost totally unacceptable for discharge to the
environment. Within this context, development of radiation control
programs must recognize this threat of irretrievable, long-term
dose commitments from the production of energy by nuclear means.
This threat is much more significant than exposures of individuals.
Whereas it is relatively straight-forward to consider the benefit
of an individual that may be associated directly with any compoaent
A-30
-------
of the uranium cycle, the risk-benefit concept of yet unborn genera-
tions makes the concept of long-term dose commitment an extremely
significant threat that must be dealt with. Since routine
operation of nuclear reactors does not introduce quantities of these
long-lived radionuclides into the environment, the other components
of the fuel cycle are therefore construed to represent the greatest
threat. In this context, fuel reprocessing and waste disposal y
operations which free these materials from the reactor fuel and
increases their availability for discharge to the environment are
most significant.
Plutonium Fuel Cycle - Sources
The plutonium cycle for nuclear power generation represents many
radiation risks similar to those of the uranium cycle. The major dis-
tinction between the two cycles is the increased amount of plutonium which will
be used as a fuel. Since the plutonium is produced in breeder reactors,usual
problems associated with mining and milling do not exist. Plutonium con-
stitutes more of a long term than a short term dose problem. However,
there are situations, such as plant or transportation accidents, where the
short term dose contributions may be of significant importance. In addition
to the plutonium inventories there are large quantities of fission products
produced in plutonium reactors as well as in the uranium reactors. There-
fore, any population dose commitment must take into consideration the short
term contribution from these fission products as well as the longer term
commitment from the actinides. The broad areas of importance in the
plutonium cycle are: fuel fabrication, reactor operation, fuel reprocessing
and waste disposal, and transportation between the various areas.
A-31
-------
Short-Term Effects
There appears to be little increase in potential for routine exposure
from plutonium in the next five years. Most reactors presently operating
or in the construction phase are not planning to use plutonium recycle
within that time frame. Consequently, with present effluent clean up techno-
logy, the quantities of plutonium and other actinides escaping an individual
i
reactor should not present much of an increased population exposure. The
utilization of nuclear power for electrical generation presently provides
only a small fraction of the nations power requirements. In 1970,only
3 gigawatt-years were generated by nuclear reactors compared to a total
generation of 205 GWe-years; nuclear generation comprising only one and one-
half percent of the total. Only three large U.S. fast-reactors presently
exist: the commercial 200 MWt Fermi plant, the 20 MWt SEFOR plant, and the
62.5 MWt EBR-II. There are, however, some new facilities being built,
such as the FFTF and Plutonium fuel fabrication plants, which may increase
the risk to the population surrounding such facilities.
Accidents involving plutonium facilities represent significant risks
should they occur because of the buildup of actinide inventories. To
date, the only major accident which could have caused significant popula-
tion doses was the fire at the AEC Rocky Flats Plutonium Fabrication
Facility. (/As more plutonium facilities go into operation the probability
of accidents increases accordingly. The total inventory of plutonium-239
from civilian reactors in 1970 was approximately 90 curies. The annual
rate of production is presently estimated to be 90 curies per year so that
the magnitude of the potential hazard will increase rapidly.
A-32
-------
Long-Term Effects
Although large scale LMFBR plants will not be oeprable until the late
1980's, they are expected to provide approximately 31% of all electrical
power by the year 2000 . Large quantities of plutonium and other highly
toxic alpha-emitting transuranic elements will be generated in LMFBR
operations, in -addition to production of radionuclides such as tritium,
krypton-85, and iodine-129. These radionuclides have the potential for
irreversibly contaminating the environment for hundreds or thousands of
years with concommitant long-term radiation exposure to successive generations.
Any long-lived radionuclides which are emitted from portions of the plu-
tonium fuel cycle will add to similar releases from the uranium fuel cycle
components. These long-lived radionuclides may also accumulate in the
environment as a consequence of their slow1removal rate due to radio-
active decay. Thus, radionuclides discharged from plutonium-fueled
reactors, unless strictly controlled or for the most toxic radionuclides
prohibited, would have both additive and cumulative impacts on environ-
mental radiation levels. The potential magnitude of these contributions
and the rapid accumulation of these long-lived radionuclides is shown in
Table A-9. Although this table shows the accumulated production of these
radionuclides and not the levels present in the environment, the percen-
tage increases in the latter could be the same without any change in con-
trol technology.
I Even if all nuclear sources were replaced by a new non-nuclear power
source in the year 2000, appreciable quantities of these radionuclides
would still exist for generations.; Table A-9 presents the estimated
activity remaining one hundred years after all nuclear power sources were
A-33
-------
TABLE A-9
ESTIMATED PRODUCTION OF LONG-LIVED RADIONUCLIDES
BY NUCLEAR POWER REACTORS
Radionuclide
H-3 (tritium)
Krypton-85
Iodine -129
Plutonium-238
Plutonium-239
Americium-241
Curium-244
Half-life
(years)
12.3
10.8
17,000,000.
86.4
24,400
458
17.6
Activity (Curies)
Accumulated by*
1970
40,000
60,000
2
700
90
9,000
130,000
2000
90,000,000
1,200,000,000
7,600
31,000,000
1,300,000
120 ,'000, 000
260,000,000
Percentage
Increase
(2000/1970)
225,000
2,000,000
380,000
4,428,000
1,' 444, 000
1,333,000
200,000
Activity Remaining in 2100+
Cu-ries
321,250
- 1,'.>38,200
- 7,600
13,897,800
. 1,296,300
103,. .46, 000
5,065,000
Percent of
1970 Values
800
3,300
380,000
1,985,400
1,440,300
1,146,100
3,900
*Source: USAEC Report ORNL-4451 July 1970 Table 2.1 p 2-9.
-'-Assuming no production after the year 2000.
-------
replaced. All radionuclides, even the relatively short-lived tritium,
krypton-85, and curium-244, would still be present at levels which are
orders of magnitude above current values.
The use of plutonium fuel in light-water reactors is not dependent
on LMFBR introduction as they can utilize plutonium recovered from uranium
LWR fuel. However, the introduction of the LMFBR will greatly increase the
quantities of plutonium available for recycle. ^ The use of plutonium fuel
in LWRs may give rise to larger quantities of heavy actinide elements
(curium, americium, etc.) than produced in the fast breeder as a conse-
quence of different neutron capture characteristics and fuel lifetimes.
Relative Threat Analysis - U vs. Pu Fuel Cycles
The Atomic Energy Commission's proposed fast-reactor development pro-
gram will incorporate requr/Leemnts for the use of the latest waste treatment
technology to minimize radioactive releases to the environment. Thus,
the effluents from these plants should be well below current light-water
reactor releases and the population dose commitment from a single plant
would consequently be small. Because of the use of these advanced waste
treatment systems and the retention of most radioisotopes in sodium, other
portions of the fuel cycle, especially spent fuel reprocessing, could
represent greater potential radiation hazard than the normal operation of
plutonium-fueld reactors.
The liquid metal fast breeder is substantially different in many
respects from the light water cooled nuclear reactors (LWRs) presently
operating or under construction. The principal differences between the
LMFBR and the LWR which could effect releases of radionuclides to the
environment are:
A-35
-------
a. The LMFBR has a higher energy (fast) neutron spectrum than the
light-water reactor. /This alters the production and composisition of
radioactive fission and activation products. Many radionuclides, such
as tritium are produced in greater quantities per unit energy production
in LMFBRs than in LWRs.
b. The LMFBR will use plutonium-239 or uranium-233 rather than
the uranium-235, 238 used in light water reactors. This changes the
i
abundance of radionuclide fission products.
c. The LMFBR will employ different fuel-cladding materials which
could affect radioactive fission product retention characteristics of the
fuel.
d. Molten sodium will be employed as the coolant instead of water.
This will lead to the production of considerable quantities of the long-
lived sodium-22. It also requires coolant purification and liquid
waste clean-up systems which are substantially different than those
presently employed in light water reactors. Disposal of large quantities
of radioactive sodium may entail a considerable risk because of the high
.ehjcmical reactivity of sodium which could lead to violent interactions
with water or air and the radioactive sodium isotopes, fission products,
and actinides present in the sodium.
There may be a greater risk from large accidents at fast breeder
reactors than from current light-water designs. Fast-reactors requite
faster and more stringent control due to their lesser reliance on delayed
neutrons for control. Proposed designs indicate that these plants will
have higher power densities and higher burnups than present LWRs. Thus
the fission-product inventories will be much larger for equivalent sized
A-36
-------
LWRs and proposed LMFBRs will probably be larger than current LWR plants.
Although the sodium coolant will contain less stored energy than the LWR
water coolant, the LMFBR will not be amenable to current emergency core
cooling techniques because of the imcompatability of sodium and water.
Because of the large quantities of radioactive sodium and plutonium that
could be released to the environment in a major accident, engineered safe-
guards different from those in LWRs will be required to limit potential
releases of these materials.
Thermonuclear Power Generation
Short-Term Effects
As the confined fusion reaction has yet to be successfully demon-
strated, there will be no short-term risk to the environment from this
source. Even if a successful reaction were achieved prior to 1980, large
demonstration plants would probably not be operable until the late 1980's
or 1990's.
Long-Term Effects^
A 1,000 MWe thermonuclear power plant may produce 400 million
curies of tritium per year or approximately 220,000 times the tritium
production rate from an equivalent light-water fission reactor. If only
1% of the in-plant inventory were released to the environment and
thermonuclear power sources were used only to supplement existing energy
sources to meet projected electricity demands, the amount of tritium
accumulated in the environment by the year 2250 would be about 210 billion
curies. This would be about 300 times the accumulation projected for the
year 2000 from fission reactor and fuel reprocessing plant releases,
natural cosmic-ray production sources, and thermonuclear device testing.
A-37
-------
Relative Threat Analysis - Thermonuclear
The principal potential radioactive environmental contaminants
produced in fusion reactors are tritium, which is produced by the fusion
reactor and also consumed as a fuel, and activation products produced by
neutrons absorbed b y structurial components. The activation products
will be fixed in the, structurial components and generally short-lived.
Because of these factors, the activation products should not enter the
general environment to any significant degree and any radiation exposure
to the general population will principally arise from direct exposure to
these materials during shipping or disposal operations. Such exposure
should constitute a negligible risk due to the infrequency of these
operations. Because of its long half-life (12.3 years), releases of
tritium to the environment from thermonuclear electricity generation
will accumulate and result in long-term radiation dose commitments.
Uniform dilution of potential amounts of this tritium in all the avail-
able circulating water and ocean surface layers couls lead to an average
dose of^_. 1 mrem/year to every person by the year 2250. As the distri-
bution would not be uniform, large population groups could receive con-
siderably greater doses.
A-38
-------
BENEFITS
Introduction
The use of nuclear energy in the major areas listed above represent
certain benefits to society. These benefits are derived from increased
availability of energy for achieving standards of living by increased
use of technology. The uranium, plutonium, and thermonuclear fuel
cycles represent electricity generation; the use of Plowshare devices
to stimulate natural energy reserves such as natural gas and oilshale
also represents contribution to the overall energy economy. The
societal benefits of each of these forms of energy are both short
term and long term in nature in that they not only change present
day living standards and activities but will determine future society
growth and standards of living. Two major values occur: (1) to the
investors of capital in the growth of technology that is represented
for providing this energy, and (2) to the general public in the
direct benefit that it achieves from the provision of this energy.
The public benefits can be classified generally in economic terms,
health benefits, convenience, improved aesthetics, a general increase
of environmental quality, and other factors.
One key perspective in considering the benefits to the public
is to identify the population that is actually receiving these benefits.
In many respects, the benefits are not distributed equally within the
population, and in some cases the population actually receiving the
benefits associated with energy would not be taking the risk associated
with providing the energy. For example, the stimulation of natural
A-39
-------
gas in the Rocky Mountain Plateau would represent certain risks to the
environment of that region; however, the consumption of the gas and
thus the benefits would more likely be in regions hundreds of miles
away. The consumers of the gas, however, will be exposed to certain
radiation risks while they are consuming the gas and therefore receiving
the benefit associated with it. This situation also exists in nuclear
generation of electricity in that many components of the fuel cycle
must operate in order to provide the electricity which represents the
benefit. Whereas the electricity is distributed within a region near
the source of generation, the mining and manufacture of the fuel, the
processing of spent fuel and the eventual storage of high-level waste
commonly occur in other regions of the country. There is, therefore,
in the benefit perspective of energy use no clear cut indication that
those who receive the benefits of nuclear energy also are assuming
all the risks.
The key factor in relating the benefits of energy uses to the risks
that are incurred from the production of the energy is to establish an
index by which the risk parameters which are fairly well known, can be
compared to the benefits. This accomplishment is quite difficult because
benefits to society are generally not quantified since they represent
concepts such as quality of life, aesthetics, and states of well being
and health. One of the most important benefits related to energy use is
the prolongation of life which could be construed to be a health benefit.
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Other health benefits are most assuredly reduction in fatigue levels
becuase of energy use, the provision of climate controlled environments
J^'-'lr ^
which minimizes physical stress and therefore certain types of diseases,
the provision of elevators and other energy saving devices which reduce
physical strains and consequent reductions of heart diseases and subsequent
deaths that may occur. Combining all of these factors into a common
index so they can be related to the risk concepts associated with energy
is most difficult. Risks are basically represented in dollar cost, which
are fairly easily determined, and health-effects which though poorly
known are at least estimatable in quantifiable terms.
Magnitude Estimates
If one were able to quantify benefits in terms of health effects
and dollars, perhaps the comparison or trade-off of risk and benefits would
be more readily achieved. In order to do this, it appears necessary to
carry out large scale society surveys and develop basic information on
health effects and the general dollar value that people derive from the
provision of energy. Within this context, it would also be important to
arrive at quantification of effects on these benefits should energy
not be provided. One approach that could be utilized, therefore, is
in-depth study of statistics pertaining to power shortages including
brown outs and black outs.
One of the major considerations in arriving at a quantification of
benefits for comparison with risks is whether or not alternative approaches
could be used to achieve the same benefit, even though it may result in
different costs. For example, the use of natural gas to satisfy an energy
demand appears to represent less environmental and public health risk
A-41
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than coal or oil. On the other hand, the costs in economic terms are
higher. A key question, therefore, is whether the health effect reduction
is worth the dollars that have to be expended on an alternative energy
source to provide the benefit or risk reduction.
RISK/BENEFIT TRADEOFFS
Introduction
A rationale for conducting environmental and public health pro-
tection programs should be firmly based on understandings of the risks
as well as the benefits of the energy produced from the various uses.
Since radiation exposure from nuclear energy programs is the best con-
trolled environmental contaminant at the present time, a significant
opportunity and challenge exists to treat further nuclear energy growth
in a preventive context. This situation is the ultimate aim of all
environmental control programs for all pollutants. Within such a mode
tradeoffs between potential risks and benefits can be made with maximum
effectiveness; however, the responsibilities of making correct decisions
is great since the decisions can result in extreme penalties to society
or large benefits depending on the course followed. A proper conduct
of these tradeoffs in environmental radiation protection requires,
therefore, that they be pursued responsibly ahead of developing tech-
nology within a perspective of leadership.
A major concept relative to nuclear energy is the recognition that
it is only a means by which society achieves an overall set of energy-
dependent goals. To the extent that nuclear energy assists society in
its achieving maximum quality for its members it represents significant
benefits. Many of these benefits, though difficult to quantify, usually
roughly parallel the amount of energy supplied in response to demand.
A-A 2
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The clearest indication that benefits accrue to society from energy is
the constant increase in this demand. Because so many benefits are re-
lated to energy use, it could be argued that it ought to be provided
at the lowest costs (hence with minimal controls) so that society could
maximize these benefits at the fastest rate. On the other hand, it is
apparent that the economic viability of American society can obtain
the benefits of energy and support controls to prevent undesirable future
effects. The largest challenge in considering each of these aspects is
to strike the proper balance. Often, only a control agency can do so
because of special interests representing each of 'the extremes. These
considerations are of major importance since energy supply by a com-
bination of the uranium cycle, the plutonium cycle, the thermonuclear
cycle, or energy resource recovery represents essentially an unlimited
energy supply if proper decisions can be made on its use.
General
Two general approaches are immediately apparent for controlling
energy supplied by nuclear means: 1) set controls very lenient and
allow operations to reach these levels in order to develop uses fastest
and cheapest, and 2) set extremely strict controls regardless of con-
trol technology which could restrict growth or be extremely costly. A
third approach somewhere between the first two is most likely justified
when careful examination of the cost effectiveness of reducing the risks
is considered. Use of this latter approach relative to generally appli-
cable environmental standards represents an approach that compromises
neither risks nor benefits associated with energy supplied by nuclear
means.
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Control of nuclear energy uses could proceed on either a case-by-
case approach for each facility operation or could recognize the totality
of the whole nuclear energy supply picture. This case-by-case approach
is not comprehensive enough in terms of the generalized environmental
radiation pollution that can be shown to occur. For example, long-term
disposal of high-level waste becomes a problem not on a case-by-case
basis but as a result of the accumulation of large amounts of material
from many individual activities. Environmental risks associated with
transportation of fuel and waste and accidents associated with individual
facilities become increasingly important with a large number of indivi-
dual facilities and activities. The greatest environmental risks from
nuclear energy uses is the irreversible contamination of the environment
by very long-lived radioactive materials such as plutonium, krypton-85,
tritium, and iodine-129. If unchecked by general controls, these radio-
nuclides may increase to appreciable levels over the long term and
represent risks to the entire population, although discharges at indivi-
dual facilities might be regulated within exposure standards for individual
members of the population. A control perspective focused on the entire
supply of energy by nuclear means is required.
Specific
Even though the greatest potential for controlling environmental or
public health risks within a concept of risk/benefit balancing'is related
to generic approaches, many opportunities exist to satisfy the concepts
of the generic approach by making risk/benefit tradeoffs for various
components of the energy-production cycle. Specific examples of this
concept are as follows:
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Uranium Reactors
Control costs for increased protection of the environment and public
health do not appear to be of major consideration in that current designs
already reflect "lowest practicable level" technology. Population exposure
reductions by use of this technology were just recently implemented;
therefore, additional EPA control programs in this area do not appear to
be feasible in terms of the population dose impact expected. Costs of
the recent increment of protection were about $100,000 per 1000 MWe-yr
of electricity production.
Plutonium Reactors
Plutonium is much more hazardous than any of the fission products
produced in fissionizing it, a fact that is most significant since, as
the fuel for fast breeder reactors, it will be shipped, fabricated, used
in reactors and processed in large amounts requiring extreme precaution
to prevent environmental discharges either routinely or accidentally.
Annual exposure criteria do not adequately represent control because
once in the environment it represents lifetime population dose commit-^
ments to hundreds of generations.
Thermonuclear Power Generation
The abundance of naturally occurring deuterium and lithium-6 for
use in fusion reactors could supply the energy requirements of a world
of 7 billion people for a billion years. This is particularly important
as projections indicate that we have exhausted about half of the existing
petroleum deposits and that, at the current rate of consumption, coal
reserves will not last beyond the next century. The principal risk/
benefit trade-off for thermonuclear power would be the radiation hazards
A-45
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from tritium accumulating in the environment versus the availability of
an otherwise "clean", essentially unlimited energy source.
Radiation Accidents
In consideration of commitments to nuclear energy supply, the
environmental risk being taken over the operating lifetime of plants from
accidents need to be considered. These risks are determined primarily
by consequences (dollars lost or man-rems incurred) and probability of
occurrence of all accidents.
Radioactive Waste Disposal
Costs of certain assurance that the long-lived high level wastes
from nuclear power generation and use of nuclear explosives will be
isolated permanently from the biosphere need to be justaposed against
the benefits of the energy provided. Initial indications of the costs
of such controls indicate that they are minimal compared to the total
cost (hence the net worth to the purchaser) of the energy provided. This
type of tradeoff is based on cost comparisons only; weighing in costs
of inadvertent loss of the wastes to the environment is not possible.
Only the best technology can be considered, and even the cost of this
is a small fraction of the energy worth.
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NONENERGY USES
RISKS
Sources
The utilization of radiation in ways that do not contribute sub-
stantially to the production of electrical power from nuclear energy
is defined as a "nonenergy use." Nonenergy uses do include some energy
producing devices such as "atomic" batteries, etc., but the scale and
application of the energy produced is clearly differentiated from
nuclear power plants. Since such a wide source of nuclear applications
are being considered, it is useful to categorize nonenergy uses.
&
Presently identified categories are listed in Table A-10 ; the miscel-
laneous grouping is included to catch new innovations and limit the
number of categories. The examples of kinds of sources in each category
given below is not exhaustive but should be sufficient to define the
classifications used here. 0
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 tradeoffs
are quite different then those arising from the direct application of
radiation to a patient.
Space applications are broadly defined so as to include everything
from isotopic power sources to interplanetary nuclear rockets. The
risks are obviously different for such a wide range of sources and must
A-47
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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
applications in this category.
TABLE A-10
Nonenergy Sources of Environmental Exposure
Medical Applications
Space Applications
Consumer Products
Industrial Applications
Scientific Applications
Educational Applications
Device Applications (Plowshare and Military)
Miscellaneous
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, especially the crew members.
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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
interfaces in pipelines and the tagging of metals in smelting operations
may result in environmental pollution after control of the radioactivity
is relinguished^/
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
AEC regulated activities not included under the energy program or
military applications are included under this heading.
Educational uses are differentiated from research in that somewhat
different risk-benefit 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-benefit criteria
are related to the set of problems considered under energy production
for civilian uses. Nuclear devices (for military or peaceful uses),
their production and testing are considered in this category.
The Miscellaneous category should be kept as small as possible so
that the number of risk/benefit rationales needed can be limited. At
this time the only radiation application in this category is the sug-
gested X-ray surveillance of boarding passengers to prevent airline
A-49
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hijacking. The likelihood of such a program is not known, but since
the general population would be directly exposed, it obviously has sepa-
rate risk/benefit considerations from other industrial uses.
It should be noted that occupational exposure is considered
separately within each of the categories. The risk/benefit analysis
for exposure to medical personnel engaged in a life-saving activity is
not necessarily the same as the exposure from an industrial process.
Nuclear weapons testing is very difficult to project simply because
of the various international activities concerning the defense priorities
of various countries. The utilization of nuclear explosives in plow-
share projects can be projected using some basic assumptions relative
to the growth of nuclear-stimulated gas and other uses. Because of the
half lives of the radionuclides involved and their point of injection
the hazards presented are both of an immediate and long-term nature.
Plowshare activities can be grouped in three broad areas: excavation,
resource recovery, and scientific experimentation. The major components
of these broad areas are as follows:
1. Surface excavations for canals, harbors, etc.
2. Underground excavation for terminal gas storage (presently
not active), deep radioactive waste disposal and deep storage
of industrial and municipal waste (not active)
3. Resource recovery by stimulation of natural gas fields, in-situ
retorting of ore bodies (not active), and removing overburden
from shallow ore bodies (not active)
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4. Energy production by fracturing of dry geothermal layers for
steam production (not active)
5. Scientific research such as neutron cross section studies,
fission symmetry studies, and isotope production.
Health and Environmental Effects
In general, both individual and populations exposure from non energy
sources will be small, well within the range of FRC guidelines and
clearly within dose levels where the non-threshold linear dose effect
hypothesis is used to predict health risk. An important exception to
this general rule is in medical applications where doses to the patient
are much larger than FRC guidelines. While it is noted that medical
applications are exempted from FRC guidelines, this does not remove the
need for a rationale to consider such exposures on a risk/benefit basis.
Environmental contamination, if not health risk, from space and
military applications has been wide spread. Whether all future appli-
cations of these types should continue to be evaluated on strickly a
health-risk basis is problematical since in some cases the cost of
these applications includes the withdrawal of land usage from other
productive purposes.
Short-Term Effects
The only significant developments expected to occur within the
next five years regarding the various plowshare programs are develop-
mental experiments to test the feasibility of stimulating flows of
natural gas in low permeability gas fields. Two experiments are cur-
rently proposed for large gas fields in Colorado. If these experiments
A-51
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prove the feasibility of producing substantial quantities of natural
gas in such fields, it can be expected that the gas companies will push
for their commercial development with nuclear explosives. The environ-
mental considerations of this activity can be divided into two major
categories: (1) disturbance of the local environment including the
potential of contaminating large underground areas by highly radioactive
materials and (2) the exposure of the general public by the distribution
and the use of the resultant natural gas in widespread areas of the
country. A major risk consideration relative to developing these gas
fields relates to the potential for contaminating underground water
supplies with subsequent public health consequences. This consideration
is particularly important because with hundreds of large (100 kt)
nuclear explosives potentially being used to develop the fields, signi-
ficant quantities of radioactive materials are expected to remain under-
ground after the fields have been depleted. These radionuclides, by
slow migration, may contaminate underground waters, or find their way
to the surface and become airborne, resulting in general population
exposures.
Long-Term Effects
Minimal information is available on the long-term use of nuclear
explosives in Plowshare activities at this time. It is expected that
nuclear gas stimulation will predominate activity in this area for the
next decade or so. Pursuit of this activity will, however, be dependent
on a proved economic and technical feasibility of increasing natural
gas flow in zones of low permeability. Should this objective be
A-52
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realized, it is possible gas fields containing some 300-500 trillion
cubic feet of gas could be stimulated by nuclear explosives over a period
of about twenty-five years. This development would represent potential
releases of radioactive material to the environment from venting or
leakage during the period of field development. The consumption of the
gas from the stimulated wells could well last another fifty years,
during which time the consumers of the gas would assume a radiation risk
from exposures occurring from low-level radioactivity in the gas due
w
primarily to tritium, krypton-85, argon-39, and carbon-lA.
While it is doubtful that surface excavations of any scope will
occur in the near future, it should be pointed out that such excavations
have the potential to introduce large amounts of radioactivity into the
general environment. Consequently, this particular activity would pro-
bably represent the largest short-term and long-term exposure to the
public both from direct releases and from environmental contamination
that could be widespread from fallout of debris. Sub-surface excava-
tions such as the Ketch experiment which was proposed as a gas storage
reservoir in Pennsylvania, may well be actively pursued in the future.
This particular approach involves creating a deep subterranean cavity
by nuclear explosives. Other uses of such cavities is to fill them
with high-level radioactive wastes, toxic chemical and industrial
wastes, or other similar materials. It appears that the mineral recovery
activities and scientific experiments are to be delayed for a number
of years, and possibly may not occur at all.
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Relative Threat Analysis
The total population exposure (including occupational dose) from
nonenergy sources of radiation is incompletely documented. However,
a recent EPA publication "Estimates of Ionizing Radiation Doses in
the United States 1960-2000;" provides enough information to give a
good feel for the problem. Average per capita doses rates for various
categories of radiation use are listed in Table A-ll. The expected
population dose rate from nuclear energy is given to provide a base
line for nonenergy uses.
I
Fallout radiation (Table A-ll) is likely to continue to be the only
significant worldwide source of dose due to U.S. Defense Activities.
The data for the dose rate from consumer products is admittedly incom-
plete but does serve to chow the relative threat. The population dose
rate from major AEG installations gives a base line for the non-occupational
population doses due to scientific and industrial use. Probably most
of the exposure from these two type of non-energy applications comes
from AEC facilities.
The major threat to public health and the environment from Plow-
share activities appear to be related primarily to nuclear gas stimulation
and potential surface level excavations. The threat from nuclear gas
stimulation is perhaps the greatest over the long term because of initial
indications that experiments to test the stimulation of such gas
fields will be successful. Following completion of these experiments
there could be wide scale development of several such gas fields
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TABLE A-11
PROJECTED PER CAPITA POPULATION DOSE RATES
FOR THE YEARS 1970 and 2000
(mrem/year-total body)
1970 2000
Nuclear Energy 0.06 --0.5
Fallout 4.0 -s>mcA"«*f. ^-5.0
Occupational 0.8 0.9
Television 0.1 0.1
Air Travel 0.05 0.05
Consumer Products 1.5 0.05
AEC Facilities 0.01 0.01
Medical 60.-70.0 90.0
A-55
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in the Rocky Mountain region involving thousands of nuclear explosives.
Whereas the radioactivity from these explosives is expected to be
contained underground, there are still serious questions on whether
these radionuclides would be completely retained in place and whether
the total population impact resulting from exposures during con-
sumption of the resultant gas would be justified.
The largest threat to public health and the environment is associated
with excavations at surface levels with large numbers of nuclear explo-
sives; primarily because of the debris that would be transported
throughout the atmosphere exposing people both short-term and long-
/
term. It is this major threap however, that places the expectation
of any activities in this area in doubt anytime in the near future.
If such excavations were to become routine, however, they would repre-
sent a major source of public exposure not only directly but also
from the accumulation of radioactive fallout debris which would result
in chronic exposures of large populations for a number of years.
Without a doubt most of the exposure to U.S. citizens comes from
the medical use of radiation, mainly in radio-diagnosis procedures.
Noting that the dose commitment from fallout is irrevocable (the Sr-90
is already incorporated into the bone matrix). Table A-ll indicates that
96% of the controllable population exposure is due to the medical uses
i
of radiation. Indeed the average population dose from medical exposure
is at present essentially equal to half the dose from natural background
radiation, 130 mrem per year.
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Within the next five years it is unlikely that any of the dose
rates shown in Table A—11 will change very much. It has been projected
that the dose from consumer products will decrease as radium dial
wrist watches go out of use. No doubt new uses of radiation will be
introduced so that the year 2000 estimate for consumer products may be
optimistic. For medical applications there is some disagreement as to
the short range trend of the population dose. It may or may not have
increased slightly for the last six years but there is no doubt that
long-term trend is upwards as shown in Table A-ll.
It should be noted that the rates in Table A-ll are total body
dose rates, appropriately weighted for partial body exposure in the
case of medical X-rays. In many cases organ doses will be much higher
than the total body dose. This is particularly true for medical
applications. For example, projected yearly dose estimates for the
thyroid are as high as 1000-2000 mrem per person by 1980.
From the foregoing it is seen that to be realistic both the risk
and benefits from non-energy sources should be considered in two broad
categories; medical and non-medical. In a sense, non-medical uses are
somewhat more important than Table A-ll indicates. Even if less than
10% of the dose from non-energy uses are from the non-medical appli-
cations—much of this dose is distributed between persons receiving no
direct benefit. For medical uses of radiation the health risk/benefit
relationship is nearly one to one. Clearly different risk/benefit
considerations are appropriate for medical and non-medical cases.
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BENEFITS
Sources
For each of the applications listed in Table A-10 the benefit
parameters are different and in most cases not really commensurate with
the risk parameters. In the case of medical uses of radiation, the
benefit is improved health ranging from pain relief to life-saving.
Benefits for exposed medical personnel are, however, the same as for
other industrial workers.
Space applications have large ideological and political benefits
as defined by the President in setting national goals. Technological
and scientific benefits from the space program can also be considered.
While the former may be calculated in dollars, scientific benefits.
are less amenable to such a precise evaluation.
For consumer products it may be possible, in some cases, to con-
sider the value added to the product by allowing a population exposure
in relation to the cost of various countermeasures to reduce the dose.
Industrial uses have the benefit of better products with an increase
in dollar value or lower production costs. It is difficult, however,
to relate this direct benefit to the producers of the product with
the benefits derived by the industrial workers exposed to the radiation.
Educational benefits can be related to costs of teaching the same
material at lower exposure levels. Military applications are again
set by national priority considerations.
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In health care, the two very different types of radiation use,
treatment and diagnosis, require different assumptions to be made
concerning the correlation between improvement in health and radiation
exposure. "Where radiation is applied to treat a disease condition,
for example, radiation therapy, the assumption is made that the treat-
ment changes the prognosis of the patient in a favorable manner. A
far larger class of medical uses of radiation is concerned not with
treatment but with diagnosis. Here the assumption is made that the
information gained by using radiation will result in better patient
care so that his prognosis is improved.fThere is some difficulty in
applying this assumption across the board. A dental cavity identified
with a pick can be cleaned and filled just as efficiently as one
identified by means of X-rays. X-ray diagnosis and radionuclide tests
are often used for confirming evidence in diagnosis where, in many
cases, the treatment regime is unchanged by the information gained by
radiation. For some X-ray diagnostic procedures, the efficacy is very
low. For example, in pelvimetry and head trauma diagnosis the
percentage of useful films has been reported as low as 5% and 0.3%
respectively./
Indeed it is unrealistic to assume all medical radiation is nec-
essarily for the benefit of the patient or for medical reasons. There
is good indication that a fair percentage of all head and neck X-rays
are taken as protection against malpractice_suit8 or for other legalis-
tic reasons. In this situation the patient receives the dose but the
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benefits are not directly related to his health and may occasionally
s '
be received by others. While this problem is difficult to probe, it ^
is possible EPA/ORP might have a useful impact here.
For other non-energy uses the relationship between the source
and the assumed benefits is less amenable to discussion. While it is
assumed that the use of radiation in quality control operations results
in a more servicable product, this can only be tested in individual
cases. The best strategy would appear to be to make no general assump-
tions on the relationship of the benefit to the source of exposure.
Rather each non-energy use of radiation must be considered on a case-
by-case basis to see if the benefit is real or not, on whom the benefits
are endowed and with what portion of the public the risks are shared.
Magnitude Estimates
An order of magnitude estimate of benefits from medical radiation
can be made by looking at the cost of radiograms for medical and dental
diagnosis, the largest (and most expensive) source of medical exposure.
Roughly 2 billion dollars per year is spent for the health benefits
resulting from such radiation. This is a significant fraction of the
80 billion dollars direct costs for medical care spent yearly in the
U.S.
Any attempt to estimate the benefits from non-energy sources of
radiation in the military and space programs is not practical at this
time. National security requirements have a major national priority
and the space program has strong Presidential endorsement; any real
measure of the benefits from these programs depends on future develop-
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ments in the political and scientific spheres. Quantification of the
monetary benefits from industrial and consumer products cannot really
be estimated by the prices paid for the services or commodities, since
the differential expenditure between radiation and radiationless
methods of producing the same result are a truer measure of what the
benefit is worth. A long-range program is needed to provide meaningful
measures in this area. Particularly important is the further consider-
ation of the occupational exposure received by industrial workers,
medical personnel, etc. While it is clear that there are benefits
incurred by being employed, what portion of these benefits can be con-
sidered in the balancing of possible health risks from radiation has
not been considered in detail by standard setting bodies.
Assumptions
For medical uses benefits could be expressed in commensurable
units if sufficient analyses were performed. Two approaches are
possible. One very direct one is the dollar cost of medical services
utilizing radiation. This is not putting a dollar sign on human life.
This is the price that Americans are willing (and able) to pay now
for the expected benefits of ionizing radiation. For the most part
differential costs on an alternate service basis need not be consid-
ered since radiationless methods to provide the same information of
treatment are usually either unavailable or contra-indicated for
medical reasons.
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Information on the costs of medical radiation could be obtained
by an analysis of X-ray film sales, blue cross and medicare records
etc. Medical isotope costs probably could be estimated by contacting
professional groups such as the American Society of Nuclear Medicine.
For all the virtues of a benefit analysis based on what society
is willing to pay, medical benefits from radiation would probably be
underestimated by that approach since it is a minimum figure that does
not fully consider the benefits, economic and otherwise, from improved
health. /Nationally for the total of all medical services the monetary
C^
benefits from treatment are estimated to 2.5 times greater than the
cost./ That portion of the increase in life span and increased
earnings experienced by persons who have been helped by medical radi-
ation would be difficult to quantatize since radiation is usually used
for diagnostic rather than curative purposes.
For the other non-energy uses, benefit appropriation is less clear.
Occupational exposures appear to be a large category (Table A-ll).
The industrially exposed worker and the owners of the enterprise using
radiation share the economic benefit if not the dose. However, the
general public als" *-«««»ives benefits insofar as the use of radiation
produces a better product or a lower cost. Perhaps the simplest way
to get at the benefits in these cases is to examine the marginal price
increase following the radiation use. Unfortunately in most cases
other methods could be substituted so that competing costs must be
considered.
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RISK/BENEFIT TRADEOFFS
General
The result of a risk/benefit analysis should be more than a
somewhat philosophical discussion of the "pros" and "cons" inherent
in a given activity. In most cases such a philosophical approach is
not really useful. What is needed for any particular potential appli-
cation of radiation is a quantitative analysis of the risks and benefits
so that a decision can be made on whether the application should pro-
ceed or not. Admittedly, much of the information used in a risk/benefit
analysis is not amenable to quantification in commensurate units.
This does not remove the need for a study that can lead to what must
eventually be a binary decision, e.g., go or no go. Note that the
risk/benefit study is an input into the decision making, not a sub-
stitute for it. The decision will almost invariably be made on a
judgment basis that possibly involves other factors than the results
of the risk/benefit analysis.
Possible benefits stemming from the use of radiation can include:
• Sociological benefits, e.g., increased public health, safety
and convenience.
e Improved personal health (mainly from medical applications).
o Economic or commercial benefits.
• Procurement of National political/ideological goals.
Potential risks resulting from radiation include:
e Increased health risk.
e Environmental degradation (air and water quality and the denial
of land use for alternative purposes).
A-63
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• Political losses stemming from negative impacts.
e Economic losses.
t> Social losses.
It is emphasized that both the risks and benefits from radiation
are potential in that they do not necessarily follow a radiation use
or even misuse. Though the listing given above is not exhaustive, it
is clear that the categorizing of benefits and risks is not controversial.
In any society there are some generally recognized values that are
widely, almost universally, accepted. The controversy comes from the
relative weighting given to different attributes in a particular
situation. This weighting should be confined to the decision-making
process. Proper weighting is not a function of the risk/benefit analysis
and any attempt to do so may lead to a biased input to the decision
making process. Rather, the goal of a risk/benefit analysis should be
to provide some quantitative measure of the pros and cons in as nearly
commensurate units as possible.
Determining only the risks and benefits from the use of a nonenergy
radiation source is not sufficient since the impact of the risk and
benefits must also be considered. The benefits may be confined to a
single geographic economic or social group and risks conferred on all
groups, or vise-versa. For example, the simplest case to consider is
medical radiation where the radiation insult is (for the most part)
confined to the one person who will receive the benefits, if any, to
be derived from this radiation. Space applications are at the other
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end of the spectrum where a nearly worldwide benefit can cause a highly
localized risk. Proper identification of the possibly effected groups
for both risks and benefits, is an important factor in any decision
making process and should be provided in the risk-benefit analysis.
Specific
For medical uses of radiation the risk-benefit analysis should
measure the potential improved health of the patient against the
health risk to the patient and others induced by the radiation. Since
in many instances, the radiation is confined to the individual, the
physicians medical judgment is sufficient. In cases where the radiation
insult is shared by members of the community, for example, an inplanted
radioisotope source, or where the genetic effects of the radiation
must be considered, the risk/benefit rationale must include the risks
and benefits received by the community. An important thing to remember
in considering medical risk-benefit trade-offs is that it is essentially
a one way street. Within limits, proper application of technology can
reduce any potential health hazards to the society without any change
in the potential health benefit to the person receiving the radiation.
Such a procedure may increase the cost of administering the radiation.
This raises the possibility of using this increased cost as a proper
measure of the public benefit (better public health) against the risk,
measured in dollars, that the public must assume corporately for the
radiation insult. Such a strategy largely removes the question applying
a risk/benefit rationale to questions involving a particular patient's
health and confines the analysis to questions of public health which
are more amenable to a public decision-making process.
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In decisions involving stimulation of low permeability gas fields
alternatives of conventional explosives or hydraulic fracturing need
to be balanced against not only the costs but the environmental risks
associated with using nuclear explosives./ Such examinations should also
seriously consider whether the increased production of natural gas by
nuclear stimulation will be sufficient to prolong the national use of
this resource to the extent necessary to justify the risk involved to
underground resources and from consumption of the radioactive gas. It
may well be that the gas reserves could not be extended enough by nuclear
stimulation (or other conventional methods) to allow the Nation any sub-
stantial flexibility in meeting its energy needs.J Other means consistent
with an overall national energy policy that are less vulnerable to
limited reserves will then need to be developed anyway for providing
energy.
For radiation sources not directed towards medical treatment a
specific rationale is needed for each of the various categories listed
in Table A-10. While noting that each of these is of some importance,
collectively they are a small source of environmental health risk
compared to medical radiation. Occupational exposure is common to
all of the sources except consumer products. If it can be assumed
that an occupationally exposed person's dose is directly related to
his function in the organization, his productivity must in some manner
be related to using radiation and that the increase in his productivity
made possible by radiation can be measured in dollars. The nature of
this increased productivity can then be balanced against an expected
A-66
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decrease in his earning capacity due to the health risk from radiation.
This oversimplifies the analysis because benefits to society are not
counted. An obvious extension of this rationale is to count benefits
to society on a separate basis and balance these benefits against the
cost to society of any expected genetic effects induced by the radiation
received occupationally. An allowed use of radiation would have occu-
pational and public health risks much smaller than the personal benefit
to the worker or the social and economic benefits to the community.
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NATURAL RADIATION
RISKS
Sources
There are a number of sources in the category of natural radiation
which present a potential for exposure greatly in excess of that which
is normally encountered from natural and man-made sources. These sources
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
I
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 ^
o (C
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.
4. Exposure to high levels of cosmic radiation in high flying
aircraft. This topic is of particular importance to aircraft crews and
is also discussed under "occupational exposure".
The first three sources of exposure contribute to whole body exter-
nal dose and lung dose due to inhalation of radionuclides, whereas cosmic
radiation contributes only to whole body exposure.
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Health and Environmental Effects
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
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 evidence 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, although
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 reins./ 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.
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Short-Term Effects
On the basis of a 0 to 5 scale, 5 being the greatest risk, the
four risk parameters are evaluated as follows:
1. Housing - 5
2. Exposure of uranium miners to radon daughter products - 4
3. Air and Water Contamination - 3
4. Air Travel - 1
This evaluation is based on the following considerations:
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 whatsoever on the projected use of building
material radioactivity or exposure levels.
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. This risk would warrant a "5" if
no Federal "FRC" action had been taken.
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.
Recent studies have shown that air travel results in inconsequential
radiation exposures as compared to the natural sources. In addition,
man's dependence on high altitude flight suggests that the exposure is
practically uncontrollable.
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Long-term Effects
Over the long-term, it is likely that other sources of fuel will
be found; and, therefore, the need to mine uranium will probably decrease.,
For that reason, it is likely that radiation exposure of uranium miners //
will decrease. In addition to this factor, it is likely that stricter
standards for radon daughter levels within mines will be established.
Therefore, over the long-term, the risk of exposure of uranium miners
would be reduced to "1". In contrast to this, possible exposure due
to the content of naturally occurring radioactivity in building materials
presents a much more substantial threat since the entire population is
involved in this mode of exposure. For this reason and the fact that the
exposure may be easily controlled, the magnitude of risk from natural
radiation within housing materials is given a rank of "5". Similarly,
the amount of air travel will undoubtedly increase, thereby increasing
the portion of the population exposed to this source. For this reason
the risk is increased to a rank of "3". Air and water contamination
with uranium-bearing phosphates will likely remain ubiquitous, but
of low concentration, and is also given a rank of "3".
Relative Threat Analysis^
Based on the consideration of short- and long-term risk from the
four sources of natural radiation exposure, it is likely that exposure
to occupants of dwellings which contain naturally occurring radioactive
materials will present the biggest potential health threat within the
category of natural radiation and perhaps all sources of ionizing radiation.
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BENEFITS
Sources
One of the primary benefit parameters is uranium ore which satisfies
peacetime uses and defense-related needs. In the preceding section it
is noted that this is a primary source of exposure to uranium miners
through the inhalation of uranium daughter products. Other products
which are consistent with the risk parameters identified are housing
and the use of air travel for fast, relatively low-cost transportation.
Magnitude Estimates
The magnitude estimates for housing can best be summarized by
stating the number of new dwellings which will be built if the construc-
tion material is given no consideration whatsoever. In order to deter-
mine the magnitude of the benefit, it is necessary to estimate what
portion of these planned dwellings would be built with lower exposures
to the occupants if restrictive building material regulations were placed
into effect. It is possible that the projected building rate could be
met by utilizing new materials of similar cost to old materials but of
lower radioactivity; and, therefore, the magnitude of benefits would be
great at a reasonably small cost to the consumer.
Benefit-magnitude estimates for uranium mining can be estimated
by computing the value of nuclear power and defense vs. health costs
for miners. In addition to tangible benefits such as the availability
of inexpensive power, it is also necessary to consider the overall U.S.
attitude towards the idle consumption of power, e.g., power for non-
essential, frivolous purposes.
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Needs for Estimating
e Projection of housing (type, number, occupancy, material, geo-
graphical location).
• Survey existing levels of radioactivity in common building
materials; assay projected building materials for natural
radioactivity.
• Determine potential miner's exposure in the future due to the
continued use of uranium as an energy source.
e Project the use of air travel.
• Establish locations of low-uranium content phosphate beds.
RISK/BENEFIT TRADEOFFS
General
Generally applicable standards for building materials may be
established, but these standards must be balanced against the availa-
bility and cost of substitute materials and the willingness of the
consumer to adapt to, say, plastic instead of wood. Such standards
would necessarily consider individual choices for building materials.
For example, should an individual be prevented from building a solid
home of high-radioactivity granite in favor of low-dose frame with
,'
aluminum siding?
Industry-wide standards for uranium mining have already been
established. These standards were based upon recommendations of several
Federal agencies and, therefore, reflect the various interest groups
involved in the production and use of uranium ore. This method of
standards development represents a type of risk benefit analysis;
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however, it would be well to consider the standards in terms of more
easily quantitated parameters such as health costs, power generating
costs, costs of alternate energy sources, and dependability of power
which is being generated.
The risk parameters are related to benefit for the four types of
categories of exposure which are mentioned—uranium mining, housing,
air and water contamination, and air travel—by several different
possibilities. An example of relationships for each type of risk/benefit
is given below; however, it should be pointed out that there are no data
at present which could be used to quantify these relationships. The
relationships are as follows:
1. Housing - The incidence of genetic or somatic effects as a
result of the construction of a given number of dwellings of known
internal exposure level.
2. Uranium Mining - Incidence of lung carcinoma per ton of uranium
ore extracted of a given quality.
3. Air and Water Contamination - World-wide increase in ambient
levels of naturally occurring radioactivity.
4. Air Travel - The incidence of genetic or somatic effects result-
ing from a given number of miles of air travel.
Specific
Specific source standards are desirable for various types of
buildings which may be classified according to occupancy and occupational
vs. public use. Such standards would necessarily consider alternative
means of construction, the necessity of multi-story vs. single-story
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buildings, and ultimately, the goal of providing adequate housing for
the entire population. Other rationales for risk/benefit tradeoffs
in specific instances would be the consideration of different types of
uranium mines as sources of ore. The specific standards would then be
addressed to the adequacy of ventilation in mines or the proper screening
of uranium mine workers prior to the exposure of mine dust and gases.
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NONIONIZING RADIATION
Introduction
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).
A-76
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RISKS
Sources
Extremely Low Frequency - (0-30 KHz: Wavelengths from direct
current to 10,000 meters). The principal application is for power
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.
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.
Microwaves - (30 MHz - 300 GHz: Wavelengths from 10 meters to
1 millimeter). The principal applications are in the area of communi-
cations, including FM braodcast, television, microwave point-to-point,
and satellite communication: radar systems; and heat treatment pro-
cesses including medical diathermy, industrial drying, and home and
commercial food preparation.
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.
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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 present 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.
Health and Environmental Effects
Adverse effects can be divided into three classes - (1) direct
effects on health, (2) indirect effects on health, and (3) interference
effects. The latter two classes overlap in that interference with a
cardiac pacemaker is an indirect effect on health; whereas, interference
with television reception is an aesthetic effect though the source of
interference may be the same in both cases. Direct effects on health
can be further subdivided into thermal effects and nonthermal effects.
Extremely Low Frequency - The principal problem in this frequency
range is the induction of voltages in long conductors such as telephone
lines, fences, and pipelines, which gives the corresponding problems of
electrical shock and interference. Studies of individuals working on
high tension lines have not indicated any specific changes in the state
of health. /Ozone and other oxidants may be produced by corona discharge
on high tension linesy This potential oxidant problem has not been
t
fully studied. The EPA Energy Policy Committee has scheduled a task ^
to examine the environmental aspects of the transmission of electricity
with a first report scheduled for June 1974. The potential for low
A-78
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level chronic effects at 45 and 75 Hertz is currently being evaluated
by the Navy through nine university contracts in connection with project
Sanguine, an extremely low frequency communications system.
Nonthermal biological effects in the frequency range of DC - 50 KHz
are claimed to have been observed by scientists in the USSR and other
East European countries. American scientists are generally skeptical
about these results; however, the research efforts conducted in this
country have been limited to date. The Russian claims include ELF
effects on mortality rate, birth rate, traffic and industrial accidents,
and possible growth retardation at frequencies of 45 to 75 Hz at field
2
intensities of 10-20 volts per meter (~30 - 100 (xW/cm ).
Radiofrequency - The principal problems in this frequency range
are interference with health related devices such as cardiac pacemakers,
hearing aids, monitoring equipment in hospitals, and with communications.
Consideration must also be given to the inadvertent detonation of
ordinance and blasting caps. Standards for permissible occupational
2
exposure (10 milliwatts/cm ) begin at 10 MHz and extend upwards to
100 GHz in the microwave frequency band. These standards are based on
thermal considerations, i.e., dielectric heating of tissue. At the
present time fields sufficient to produce dielectric heating in the
radiofrequency band occur only in the immediate neighborhood of powerful
sources and most exposure occurs in occupational situation.
- Again, scientists in the USSR and East European countries claim
that bioeffects exist in the RF range. These claims include such alleged
2
effects as chromosomal abnormalities in human lymphosites (<100 (iW/cm );
A-79
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2
abnormalities in human fetus development ( < 100 u.W/cm ); reduced rate
—6 2
of cell division for fields above 0.1 volt per meter (3 x 10 mW/cm );
central nervous system reactions which include reversible memory impair-
ment, involuntary motor reactions, reduced sensitivity thresholds for
the senses of touch, smell, and pain, and induced auditory responses;
and the possibility of genetic changes that are evidenced only after
several generations.
Microwaves - Most of the concern over direct health effects,
especially thermal effects, is focused on the microwave frequency
range, cataract induction being the thermal effect of major concern.
Current occupational exposure standards in the U.S. apply to the
10 MHz to 100 GHz frequency range. These levels 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. The overall
(—rconclusion arrived at through such studies is that biological systems
are sensitive to microwave fields below a level resulting in direct
thermal effects, and this sensitivity results from changes in the
central nervous system. There is considerable controversy concerning
low-level nonthermal effects and whether they can be considered
hazardous.I However, An the USSR these effects are given serious weight
and guidelines for permissible occupational exposure are 100 to 1,000
times less than those used in the U.S.f These alleged effects include
circulatory system and blood effects resulting from perturbations of
A-80
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blood pressure, blood flow, and heart rate; reduction of the electrical
conductivity of the coronary system; and greater vagotonic reactions
due to the effect on neural skin receptors. Biochemical changes which
2
may occur at levels as low as 100 (j.W/cm include the disruption of
sugar metabolism affecting diabetics and an increase in thyroid activity.
Other effects include indirect effects on health through inter-
ference with health related devices such as cardiac pacemakers, hearing
aids, and monitoring equipment in hospitals. Consideration must also
be given to inadvertent detonation of ordinance and ignition of air-
craft fuels as well as interference with communications and TV, and FM
broadcast reception.
Infrared^ - The principal concern with exposure to the infrared
is the production of heat. All hot bodies radiate infrared radiation.
The principal exposure is to occupational and military groups. The
latter arising from the use of surveillance systems.
Visible^ - The principal concern with exposure to visible light
is high-intensity sources including lasers which may cause transient
loss of visual function or irreversible thermal injury of the retina.
Short-Term Effects
At the present time only qualitative indications of risk can be
made because of large uncertainties about the ambient levels of non-
ionizing radiation in the environment, the rate at which levels are
increasing, and the effects of low levels. There are two types of
exposure which are of concern - (1) the exposure of the entire popula-
tion to low levels which result from the superposition of the fields
A-81
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from multiple sources and (2) the exposure of smaller groups to poten-
tially higher levels in the immediate neighborhood of intense sources.
The multiple source general population exposure problem comes
principally from radio frequency 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 communi-
cations 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 laser applications, infrared
from hot bodies, leakage from microwave drying processes, occupational
exposure in the near fields of AM, FM, and TV broadcast stations, etc.
Medical applications include intentional exposure of patients to lasers
and to microwave and radiofrequency diathermy and the corollary inad-
vertent exposure of medical personnel. Individuals engaged in research
are potentially exposed to all frequencies from many different appli-
cations. Military personnel are potentially exposed to lasers (range
finding), infrared surveillance systems, radar, etc.
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Long-Term Effects
The number of radiofrequency and microwave sources is estimated
to increase 15 percent 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 recrea-
tion and the number will increase as prices are reduced. Radar colli-
sion avoidance systems for automobiles are in development stages.
Microwave power transmission of converted solar energy from satellites
to large antennas on the earth's surface has been proposed as a signi-
ficant electrical energy source for the year 2000.
Relative Threat Analysis^
The threat from exposure of the entire population to the low
levels which result from the superposition of the fields from multiple
sources cannot be determined with confidence for direct health effects.
Contributing to this uncertainty is the controversy over the existence
and importance of low-level nonthermal effects and the limited infor-
mation that is currently available on environmental levels and their
rates of growth. The resolution of the low-level nonthermal chronic
A-83
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exposure problem depends upon the results of ongoing and planned research
and is several years away. The effort and resources that should be
devoted to this problem are in part dictated by current levels and, more
importantly for the long term, the rate of growth of environmental levels.
The threat to the general population for indirect effects on health
from interference with health related devices has not been analyzed
quantitatively. Given sufficient resources, most interference effects
can be mitigated through design or shielding. However, mitigation
becomes more difficult as ambient levels increase or when there are
limitations imposed on the size of the device as is the case for cardiac
pacemakers and hearing aids.
Interference is also a problem for communications, especially
land mobile radio used by fire, police, and emergency services and
consumer products such as interference with AM, FM, and TV reception.
The threat from exposure to specific intense sources is for the
most part restricted to occupational, medical, and military situations.
Exceptions may occur in uncontrolled areas immediately adjacent to
powerful broadcast and radar transmitters or for malfunctioning products
such as microwave ovens.
BENEFITS
Benefits derive from the direct application of nonionizing sources
for specific purposes. The benefits include information transfer,
entertainment, health and medical applications, convenience, economics,
and so on. Another method of classifying benefits is to describe benefits
A-84
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accruing to the user in say, consumer, industrial, military, science,
and educational applications. Apart from describing direct benefits
for each particular source or class of sources there does not appear
to be a set of benefit parameters that apply in general to all non-
ionizing radiation sources.
Magnitude of Benefits
The relative magnitude of the benefits arising from the application
of nonionizing radiation depend upon the resolution of questions con-
cerning the type and magnitude of risk. For example, the criteria for
determining the benefit of a consumer convenience device depend on the
existence of low-level nonthermal effects. This subject is treated in
more detail in the following section.
RISK/BENEFIT TRADEOFFS
General
Generally applicable standards for nonionizing radiation will have
S
J the most utility for frequencies below 300 GHz. This is the frequency
i*
range where there is the highest probability of exposure from multiple
sources and where the radiation is intentionally directed at large
population groups. Three possibilities need to be examined; namely,
standards set on the basis of nonthermal effects, standards set on the
basis of thermal effects, standards set on the basis of interference,
including secondary effects on health.
Nonthermal Effects. The USSR and Eastern European countries have
2
adopted an exposure standard of 10 uW/cm for occupational exposure in
the microwave frequency range. Based on current knowledge, this number
A-85
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represents a lower bound for the onset of nonthermal effects. It is
important to note that there is considerable controversy over the
^•*3K t*TI ,<"
existence of nonthermal effects in ELF, RF, and fiWave 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 5-year program recommended by the Electromagnetic Radia-
tion Management Advisory Committee 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./ If there are significant individual nonthermal health and
socio-economic effects at the low levels indicated then risk/benefit
criteria will have to be framed in these terms. This will require
developing a quantitative method or methods of evaluating the health
benefit of communications, collision avoidance systems, navigational
aids, and convenience sources such as microwave ovens, two-way radio,
etc. Allocations for fractions of the permissible exposure will have
to be made for national security and vital communications. Alternatives
to free space broadcasting such as laser communications links may have
to be developed.
Thermal Effects. Occupational exposure standards in the U.S. for
radiofrequency and microwave exposure 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 density level
falls well within the heat dissipation capacity of the irradiated
A-86
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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.
However, 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 considerations.
Interference Effects. Interference with electronic devices which
are important to health such as cardiac pacemakers does occur at levels
far below those which have been demonstrated to heat tissue. Most
interference effects can be eliminated through design or by shielding.
The magnitude of the problem is directly related to the ambient level
of interfering radiation. Size constraints on implantable devices such
as pacemakers increase the problem of interference mitigation. In this
area criteria need to be developed to assess the trade-off between the
cost of reducing environmental levels and the cost of mitigating inter-
ference effects. The criteria need to include an evaluation of the
mitigation of aesthetic effects such as interference with FM and TV
reception.
Specific
Specific source standards have been developed for microwave ovens
and lasers. The laser standard is currently under review. These stan-
dards are based on real or hypothesized health effects and provide,
within the state of current technology, for control of emissions at the
A-87
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source either through shielding or exclusion. Specific source standards
are subject to the same rationale for risk/benefit trade-off as generic
sources. For nonthermal effects consideration must be given to a direct
balance for health effects, for thermal effects implying a threshold,
priorities for allocation of levels below the threshold are necessary,
and for interference effects, the cost of reducing environmental levels
must be balanced against the cost of designing interference resistant
devices or providing shielding.
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APPENDIX B
TABLE OF CONTENTS
GENERIC FUNCTIONS B~1
C RISK/COST/BENEFIT B~1
PROGRAM DESCRIPTION B~£
Background B"
Scope B~
LEGISLATIVE STATUS B~£
COORDINATION B~^
Interagency and Extramural B"^
Intra-agency B~
ALTERNATIVE APPROACHES B~°
OPTIMUM PROGRAM B~7
PROPOSED PROGRAM B"Q
COMPARISON OF THE OPTIMUM AND THE PROPOSED PROGRAMS f
MEASURES OF GOAL ATTAINMENT B~^T
G STRATEGIC STUDIES B"^
PROBLEM DESCRIPTION B"g-
Component Problems ,„
sco^ til
COORDINATION ° rL
Interagency ~ .,-_
Intra-agency 90~~
ALTERNATIVE APPROACHES ri
OPTIMUM PROGRAM B~^_
MEASURES OF GOAL ATTAINMENT ^
9 MONITORING B~2g
INTRODUCTION B"
PROBLEM DESCRIPTIONS B"^
Component Problems K38
Scope 8^40
LEGISLATIVE STATUS » 7"
11 Lt\J
General Authority " ^
Specific Authorities Related to Monitoring Tp,
COORDINATION B"^
Interagency ~ 9~
Intra-agency _.
ALTERNATIVE APPROACHES ^
OPTIMUM PROGRAM z~53
Level B~54
Design 61
Networks B-65
External Needs R67
Data Management n~7S
PROPOSED PROGRAM Tf,
External Needs
-------
APPENDIX B
TABLE OF CONTENTS (Continued)
Optimum and Proposed Data Management Program Differences B-101
MEASURES OF GOAL ATTAINMENT B-106
Environmental Radiation B-108
Medical Radiation B-108
Occupational Radiation B-109
Miscellaneous Radiation B-109
TAB 1 - INTERACTION WITH THE OCP B-lll
Introduction B-lll
Field Operations Division B-lll
TAB 2 - VALUE AND COST OF MONITORING B-115
Description of Monitoring Activities B-115
Information Derived from Monitoring Data B-117
Alternative Approaches B-117
TAB 3 - NATIONAL QUALITY ASSURANCE PROGRAM B-131
Current Programs B-131
New and Projected Programs B-134
Radionuclide Distribution and Calibration Program B-135
State Participants B-137
Utility Companies B-138
Collaborative Studies B-138
TAB 4 - RELATIVE COST OF RADIATION MONITORING B-139
ENVIRONMENTAL IMPACT STATEMENT ' B-143
PROBLEM DESCRIPTION B-143
Component Problems B-143
Background and Legislative History B-143
ALTERNATIVE APPROACHES B-148
Nuclear Power EIS's B-148
Nonpower EIS's B-150
OPTIMUM PROGRAM B-150
Nuclear Power EIS's B-150
Nonpower EIS Review B-157
TRAINING B-159
PROBLEM DESCRIPTION B-159
Component Problems B-159
Background B-159
Scope B-164
LEGISLATIVE STATUS B-176
COORDINATION B-177
Interagency B-177
Intra-agency B-177
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APPENDIX B
TABLE OF CONTENTS (Continued)
Page
I. i 79
ALTERNATIVE APPROACHES ""
OPTIMUM PROGRAM B-183
Headquarters - B-188
Regions B_189
States • B-192
Other EPA Coordination . B-192
Other Agency Coordination , B-192
Private Sector Coordination
PROPOSED PROGRAM B-194
Headquarters .,
IMPACT OF PROPOSED PROGRAM COMPARED TO OPTIMUM ]»
TAB 3 - COMPUTATION OF ORP'S TRAINING PRIORITIES I
TAB 4 - TRAINING GRANTS AND FELLOWSHIPS 2l
FINDINGS AND RECOMMENDATIONS v-216
Introduction B-216
Current Programs B-218
Assumptions B-219
Findings and Recommendations
LIST OF TABLES
TABLE NUMBER -^
B-l RISK/COST/BENEFIT EVALUATIONS FOR THE
OPTIMUM PROGRAM B"10
B-2 LIST OF MONITORING AND SUPPORT TASKS B-33
B-4 MONITORING OBJECTIVES ' B'35
B-5 SCOPE OF MONITORING DATA AND PROGRAM
REQUIREMENTS B"5b
B-6 DATA BASE SOURCES B'73
B-7 MAJOR MILESTONES - DATA MANAGEMENT MODELING
SYSTEM B
B-8 INTERAGENCY IMPLEMENTATION . B-80
B-9 MODEL SUMMARY B"88
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APPENDIX B
LIST OF TABLES (Continued)
TABLE NUMBER Page
B-10 MONITORING BUDGET B-94
B-ll REQUIREMENTS FOR MONITORING DATA B-118
B-12 PRESENT SCOPE OF AMBIENT TREND MONITORING-
ACTIVITIES B-122
B-13 COST OF SAMPLE ACQUISITION PLUS COST OF
SAMPLE ANALYSIS B-124
B-14 QUALITY/COST RATIO B-126
B-15 NETWORK MONITORING VALUE VS. COST (FY 1973-
FY 1974) - COST/VALUE OF CURRENT MONITORING
'OF SOURCES B-127
B-16 TRAINING GRANTS - FY 1972 B-164
B-17 RANKED ORP TRAINING PRIORITIES BY ORGANI-
ZATION B-175
B-18 EXAMPLE FORMAT - REQUEST FOR TRAINING
ASSISTANCE B-191
B-19 PROGRAM ELEMENTS FOR THE PROPOSED AND
OPTIMUM PROGRAMS B-196
B-20 SHORT-TERM TRAINING B-200
B-21 GRADUATE PROJECTS B-201
B-22 HISTORY OF THE TRAINING GRANTS PROGRAM B-202
B-23 INSTITUTIONS RECEIVING GRANTS B-203
B-24 EPA FUNDING GRADUATE TRAINING GRANTS B-204
B-25 ORP PROBLEM AREAS B-207
B-26 ORGANIZATIONS B-209
B-27 ORP PROBLEM AREAS B-211
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APPENDIX B
LIST OF TABLES (Continued)
TABLE NUMBER
B-28
B-29
ORGANIZATIONS
LIST OF ORGANIZATIONS REQUIRING RADIATION
PROTECTION TRAINING ACCORDING TO COMPUTED
PRIORITY
Page
B-214
B-215
FIGURE NUMBER
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
B-9
B-10
B-ll
B-12
Page
MILESTONES OF THE OPTIMUM PROGRAM B-ll
GENERALIZED STRATEGIC STUDY ACTION SEQUENCY -
COORDINATION TAD B-23
ORP AMBIENT AND SOURCE MONITORING B-39
ESTIMATED NUCLEAR GENERATING CAPACITY IN THE
U.S. THROUGH THE YEAR 2000 B-41
MAJOR AREAS OF INTERAGENCY RELATIONSHIPS -
MONITORING B-47
INTERAGENCY COORDINATION FOR MONITORING OF
NUCLEAR FACILITIES B-48
FLOWCHART FOR CONTROL OF A TYPICAL RADIO-
NUCLIDE B-52
RADIATION CONTROL MECHANISMS AND HEALTH
EFFECTS B-55
PATHWAYS BETWEEN THE RADIOACTIVE MATERIALS,
RELEASED TO THE OCEANS, SURFACE WATERS AND
THE GROUND, AND MAN B-63
INTERAGENCY IMPLEMENTATION B-68
ORP INTEGRATED TECHNICAL DATA MANAGEMENT
AND MODELING SYSTEM B-70
MILESTONE CHART FOR THE PROPOSED PROGRAM
MONITORING B-90
B-v
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APPENDIX B
LIST OF TABLES (Continued)
FIGURE NUMBER Paee
B-13 COMPARISON OF METHODS IN OPTIMUM AND PRO-
POSED PROGRAMS B-103
' B-14 COST VERSUS CAPABILITY FOR DATA MANAGEMENT
AND ANALYSIS B-105
B-15 FORECAST AVERAGE WHOLE-BODY RADIATION DOSE
IN THE U.S. B-107
B-16 (Missing Due to Misnumbering)
B-17 IONIZING RADIATION POLLUTION FLOW CHART B-119
B-18 IONIZING RADIATION - AMBIENT TREND MONITORING
INFORMATION FLOW CHART B-120
B-19 TEMPORAL STATUS OF RADIATION POLLUTION -
GENERAL ILLUSTRATION B-121
B-20 COST-VALUE ANALYSIS OF RADIATION PROGRAMS B-128
B-21 COST-VALUE ANALYSIS OF OPTIMUM PROGRAMS B-129
B-22 MONITORING GUIDE FOR PLUTONIUM B-142
B-23 REVIEW PROCEDURE FOR A NUCLEAR POWER PLANT
ENVIRONMENTAL IMPACT STATEMENT B-146
B-24 EIS TIMELINE (OPTION I) • B-153
B-25 EIS TIMELINE (OPTION II) B-154
B-26 EIS TIMELINE (OPTION III) B-155
B-27 EIS TIMELINE ( OPTION IV) B-156
B-28 ORGANIZATIONS REQUIRING RADIATION PROTECTION
MANPOWER AND TRAINING B-206
B-29 ORGANIZATIONS PROVIDING OR SUPPORTING
RADIATION PROTECTION TRAINING B-210
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APPENDIX B
GENERIC FUNCTIONS
RISK/ COST/BENEFIT
PROGRAM DESCRIPTION
Radiation is an environmental pollutant which arises from man's
application of radiation sources and from his natural environment. Any
controlling of radiation to protect the environments which includes
both man's health and his ecosystem, must consider the benefits enjoyed
by society either from man-made sources or from materials used by man,
which inherently contain natural occurring radioactive materials.
In order to describe a standards program for evaluation of risks,
costs, and benefits, certain fundamental priciples are accepted. These
are:
1. All radiation exposure can be described in some manner which
relates to energy absorption or dose in man or his ecosystem. (For
this document the unit to describe this energy absorption or radiation
dose will be the REM.)
2. The ill-health, or the risk of ill-health, will be directly
6t-
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 is
extrapolatable 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 a qualitative benefit can be described. (An
exception to this must exist for some natural radiation sources such
as cosmic radiation but perhaps not for radium in drinking water.)
B-l
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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 radiation source and then the benefit to be derived by society
from this source. Subsequent to quantifying the risk and deriving a
judgement on the benefit, the control program must also consider the
cost of technology to minimize the risk.
As a generic problem, a 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.
Background
Since the discovery of X-rays and natural radioactivity, man has
considered both the risks associated with and the beneficial application
of radiation to man's welfare. Discovery of nuclear fission with its
application to weapons development and the production of electrical
energy accelerated the information available on the biological effects
of ionizing radiation. Thus, we have considerable data upon which to
base any judgements on risks. While these judgements on risks can
be articulated and judged scientifically, judgements on benefits are
much less quantifiable since they are primarily societal.
B-2
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Scope
The problem area program will initially confine itself to defining
risk of ill-health only to man, concentrating on somatic effects. Risk
associated with the total ecosystem such as species loss or environmen-
tal degradation leading to changes in evolution will not be undertaken
as an immediate concern. Benefits will be limited in consideration to
those derived for health, available power, industrial and agriculatural
purposes and economics. In some cases comparative benefits of alter-
native approaches will be considered.
Models developed for evaluating the assessments of radiation
exposures within these limits are considered to be sufficient unless
future activities are to be oriented toward comparative evaluations
for other pollutants, including similarities in costs for reductions
in risk of ill-health. The present scope of the program will confine
T
itself to radiation alone, limiting any comparisons to relative risks
between radiation sources, including any that may be associated with
natural radiation.
The accomplishments of a standards program involving risk/cost/
benefit evaluation are best described in terms of the end points for
radiation protection which can be in the form of standards, guides, or
EPA position pronouncements. Currently, the projected end points are
(1) EPA publication of an overall "FRC" guide for Federal Agencies
for allowable dose to individuals and population, (2) possible alloca-
tion of exposure guides based on general application of radiation, and
B-3
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(3) potential environmental guides for specific types of sources and/or
specific radionuclides.
LEGISLATIVE STATUS
No specific legislative requirements are necessary for a risk/cost/
benefit evaluation activity. The mission of EPA is environmental
protection which includes assessment of proposed actions on public health
and the overall need for a pollutant to exist.
The currently existing authority which can be used by EPA in the
setting of radiation guides are those derived from the President's
Reorganization Plan. This authority resulted from the transfer of
functions of the Federal Radiation Council to adivse the President on
all radiation matters; the transfer from the U.S. Atomic Energy Commis-
sion of the responsibilities for the setting of generally applicable
environmental standards; and the transfer from the Public Health Service,
under the general Public Health Service Act, responsibilities for
examining the state of the environment and general public health as
affected by radiation pollution.
COORDINATION
The nature of such effort as risk/cost/benefit evaluation must
obviously involve many public and private contracts. These contacts
must include national and international groups. On the national basis
Federal, State, and local considerations must be recognized. Scientific
expertise in radiation and economics must be solicited for input and
creditability of EPA's action.
B-4
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Interaeencv and Extramural
It is vital to this program that close working relationships with
other Federal agencies be utilized on a continuing basis. Many of these
agencies will have the enforcement authority for implementing recommen-
dations as standards arising from the risk/cost/benefit evaluations.
Other agencies will also have available major sources of data which can
be utilized in the evaluations. A listing of these is as follows:
o AEC - information on biological effects, cost of technology,
application of nuclear energy;
o USPHS - information on biological effects, demographic data;
o ORP - information on communication networks utilizing
microwave and radio frequency systems; and
o DOD - information on biological effects, new application
of radioactive sources. .
Likewise there are many professional societies and non-Federal
groups which make valuable contributions in describing the risks
associated with radiation and have published guides for radiation
protection. Some of these sources are:
o Professional Societies
Health Physics Society
International Radiation Protection Association
Radiation Research Society
American Nuclear Society
B-5
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o National and International Technical Groups
National Academy of Science
National Committee on Radiation Protection and Measurements
International Commission on Radiation Protection
United Nations Scientific Committee on Effects of Atomic
Radiation
Continuing liaison with these groups can provide the necessary
creditability of EPA's action in radiation protection and enhance the
acceptability of such actions.
Intra-agency
The organization of EPA along lines of both function and pollutant
or media requires for any radiation risk/cost/benefit evaluation a
working relationship with most of the other.EPA offices. Input will be
required as follows:
o ORM - research on long term health effects of radiation,
pathway models, exposure/dose modeling, benefit modeling,
and comparison risk/cost/benefit evaluations;
o 0PM - computer services, economic analysis; and
o OAWP/OCP - consistency in approaches for radiation and
other pollutants, implementation of specific recommendations
on radiation problems.
ALTERNATIVE APPROACHES
A possible alternative to a risk/cost/benefit evaluation is to
limit the decision-making to judgements based solely on health risk.
B-6
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However, for the major radiation sources of concern the risks are
relatively small and therefore the rationale of protection is directed
toward prevention rather than cure.
OPTIMUM PROGRAM
An overall optimum program for application of risk/cost/benefit
evaluations to radiation protection standards development would be a
program that compares the risks and benefits with similar risks and
benefits in the reduction and control of other environmental pollutants.
This, however, is EPA's responsibility and should not describe ORP's
activity. Therefore, recommendations are limited to a optimum program
for ORP.
For the development of EPA guides pertinent to radiation protection,
a review by FRC of the bases and requirements for standards was requested
by the Chairman of the former FRC (Secretary, DHEW). This review was
to consist of four activities involving: (1) a basic review by the
National Academy of Science; (2) a review of specific radionuclides by
the National Council on Radiation Protection and Measurements; (3) a
review of the current and long range exposure protection situation in
the U.S.; and (4) the development of a risk/cost/benefit model to be
applied to the setting of radiation standards.
A study of the population exposure to radiation in the U.S. was
recently conducted and published by ORP. In summary, this report
indicated that there were two major sources of radiation exposure, namely
exposures received from natural background radiation and exposures
B-7
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received from the application of radiation in diagnostic medicine. The
study also identifies a much lower exposure attributable to nuclear
power plants and various types of consumer products.
A review conducted by the NAS on the basic scientific information
available was submitted to ORP in September 1972. On the basis of this
report and the exposure study, EPA will develop a health effects model.
The relevance of such models to the controllable man-made sources of
radiation exposures will permit the establishment of an overall radia-
tion guide by EPA based upon the concept of an acceptable risk. It is
expected that the issuance of such a guide will be made during fiscal
year 1975.
The development of a risk/cost/benefit model is dependent upon
the initial development of a benefit model. Based on such information,
it is anticipated that apportionment of radiation exposure to general
classes of sources can be made. The three major classes for consider-
ation, based upon their accessibility to be controlled, are (1) nuclear
energy, (2) radiation used in the healing arts, and (3) the radioactive
materials and radiation producing machines used in consumer products.
The issuance of the exposure guides for these classes will be made such
that their summation will not exceed a general guide, based primarily
on an acceptable risk.
On the basis of the study being conducted by NCRP, other studies
of radionuclides, and source identifications from the ORP problem areas,
EPA will ascertain the need for specific radiation source guides for
B-8
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specific sources and various radionuclides. An example of possible
specific source standards required are those for fuel reprocessing
plants, fuel fabrication plants, and gas stimulation activities. In
the case of specific radionuclides, particular attention will be devoted
to the various radioiodine nuclides, krypton, plutonium, radium, and
tritium. /Plutonium will receive considerable attention since this
v
radionuclide is highly toxic and any widespread contamination results
is essentially an irreversible situation. | These particular guides
will be consistent with air and water guides used by EPA and with
overall maximum permissible concentrations recommended by ICRP.
Table B-l describes the Optimum Program in terms of data and
information input requirements from specific functions and the expected
accomplishments. More specific details and schedule of milestones are
shown in Figure B-l.
PROPOSED PROGRAM
The program elements of the Proposed Program are essentially the
same as the program elements of the Optimum Program. The completion
dates for the Proposed Program are generally six months to one year
later than the completion dates for the Optimum Program after fiscal
year 1974.
COMPARISON OF THE OPTIMUM AND THE PROPOSED PROGRAMS
The major difference between the Optimum and Proposed Programs
is the depth of the analysis associated with the program elements. The
Optimum Program is based on more detailed research efforts than the
B-9
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TABLE B-l
RISK/COST/BENEFIT EVALUATIONS FOR THE OPTIMUM PROGRAM
DATA NEEDS
Exposure and
Pathway Data
Health Statistics
Bioeffects/Dose
Control Data
Technologic
Economic
Benefit
Descriptors
RESEARCH NEEDS
Source Field Studies
Long-term, Low
level Experimental
and Epi-demiologic
Studies
"Lowest practicable"
technology studies
Model for
Quantification
ORGANIZATIONAL
INPUTS
AEC, HEW, EPA
(ORM, ORP)
HEW/NCVS
AEC, HEW, EPA
(ORM, ORP),
NAS, NCRP
AEC, HEW, EPA
(ORM, ORP,
0PM)
AEC, HEW, EPA
(ORM, ORP,
0PM)
ORP
ACCOMPLISHMENTS
"FRC" overall guides
Application Alltoments
Nuclear Energy
Consumer Products
Healing Arts
Specific guides for
sources and situations
Specific Guides for
radionuclides :
Plutonium
Tritium
Radium
FISCAL YEAR SCHEDULE
BEGIN
71
73
73
74
74
74
73
COMPLETE
74
75
74
78
75
76
75
M
O
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AVAIL ABL
DIGITALLY
-------
Proposed Program, while the completion dates for the two programs
are nearly the same. Many of the guides and standards for the Proposed
i/
Program will necessarily be interim, since they will be established on
a case-by-case basis. The Optimum Program, therefore, will be able to
provide generally applicable guides for all sources of radiation sooner
than the Proposed Program.
MEASURES OF GOAL ATTAINMENT
The expected accomplishments of the radiation programs are shown
in Table B-l and Figure B-l, in terms of standards and guidance.
Attainment of goals for which these guides are developed will be
determined by the degree of compliance by the regulatory agencies and
the public acceptance of EPA's image as a "Radiation Protector."
B-l 2
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STRATEGIC STUDIES
PROBLEM DESCRIPTION
Component Problems
Strategic Studies are 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 for technical
evaluations 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 are 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 four significant points. There will be models for
B-13
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(1) source terms, (2) for releases to the environment, (3) for environ-
mental transport pathways on a nuclide-by-nuclide basis and finally (4)
for the interaction of the contaminant material with man and the
resultant potential effects. Although the individual models at these
four points may 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 pathways, 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.
Nuclear Fuel Cycle Analysis - Coordination TAD
The components of both the uranium and plutonium fuel cycles are
represented in various specific problem areas. Still, there must be
a realization that when a power plant is built a commitment is made to
develop commensurate support through additional capacity in other parts
of the fuel cycle. This Strategic Study would take cognizance of this
fact, pull together applicable portions from the individual problem
areas, and analyze their significance in the context of the total fuel
cycle. This would include models for predictions of future fuel
scenarios and analysis of alternatives. The recent exercise to evaluate
all components of the fuel cycle relative to their contributory dose
and the cost of dose reduction is illuatrative of this effort.
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Alternate Electrical Energy Technologies - Coordination CSD
From the point of view of both the electric power industry and the
general public, two overriding questions EPA has to answer are, "What
is the cleanest source of electrical power?" and "What are its costs?"
Put less naively, "What are the trade-offs between the available alter-
nate energy technologies, when they are abating their pollutants in the
most cost-effective manner?"
Although ORP is not in a position to directly formulate EPA policy
in this area, the potential for ORP contributions to an overall EPA
policy, as well as the implications for ORP's own programs, are sub-
stantial. The outputs of the ORP energy-related problem areas and
strategic studies for the various fission and fusion alternative should
provide an important input for the development of an EPA position on
electrical energy alternatives. Conversely, the evaluation of impacts
of alternate non-nuclear technologies on health and the environment can
provide an essential backdrop for the standards-setting and impact
review processes for nuclear electrical power technologies.
The prime role of the group managing such a study should be to
define and maintain an appropriate relationship between ORP, the Energy
Policy Committee, ORM, and the air and water programs, so as to maximize
the generation and flow of relevant information in this area. The study
should have as its first objective the definition of common measures
and models for long and short term impacts, so as to provide a common
framework for useful inputs from each of the other relevant problem
areas and/or strategic studies, as well as a framework for communication
B-15
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with other parts of the agency. Later objectives might include defin-
ition of areas of research needs, assessment of the implications of
alternate (nuclear and non-nuclear) electrical power technologies for
specific standards-setting activities, and development of ORP policy
alternatives related to an agency-wide electrical energy position in
EPA.
Regional Geographical Areas - Coordination FOP
/Several of the sources counted as problem areas may exist in the
same geographical region and thus may contribute to contamination of
the same environment) Prime examples of such regions are major river
basins and some of the great lakes. Furthermore, several instances are
arising where certain types of facilities are located in juxtaposition,
e.g.,/the Midwest Fuel Recovery Facility next to the Dresden Reactors,
and the proposed fuel fabrication facility next to the Nuclear Fuel
Services fuel reprocessing facility./ Such activities, perhaps best
exemplified by the developing concept of nuclear parks, make it imper-
ative that a program be carried out to evaluate the cumulative effect
of various sources on a regional and river basin basis. This will
require inputs from all elements of ORP for: (1) evaluation of present
situations, (2) criteria that are related to regions as well as to
sources, and (3) examination of planned sources within the context
of existing sources on a regional and on a river basin basis. This
study should include the development and evaluation of jnodels for
predicting the short and long range_environmental impacts on the region -
such as the currently underway "year 2000" study being conducted by the AEC.
B-16
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Long-Lived Radionuclides from Multiple Sources and Long Term
Cycling - Coordination FOP
Many of the radionuclides of long term concern from an environmental
viewpoint are not restricted to any one of the sources identified in
the individual problem areas. Examples are the actinides, tritium,
and krypton. These radionuclides, and probably some others, are of
sufficient importance that coordinated efforts are required to evaluate
them as environmental contaminants on their own merits, regardless of
the source from which they come. It will be necessary to develop models
for the long (and short) term transport behavior of these nuclides,
and then to develop consistent models for assessment of the potential
dose to man, on a local, national, and international basis, for both
the long and short term cases. Although these radionuclides certainly
also are a part of the individual problem area source evaluations and
the regional evaluation mentioned above, a central focus on them as
issues requiring strategy development needs to be established.
A related issue that is not specifically covered in any of the
individual problem areas is the generic one of movement of radionuclides
in the local environment. Some consideration of this will certainly be
necessary in each problem area as well as in the previously described
Strategic Studies. There is again a necessity, however, to pull to-
gether and evaluate models and data developed throughout a spectrum of
activities. There is also a need to develop new studies which are
specifically oriented toward developing new modeling and data in this
area. An example of this has been the H. B. Robinson study which is
B-17
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intended to evaluate the potential long term buildup of radionuclides
in a confined reactor cooling lake. These activities, while often
requiring "research" techniques are necessary to the day-to-day
activities and evaluations performed by ORP and therefore should be
conducted within its confines.
Comparative Evaluation of Major Program Areas (Energy Production.
Natural Sources, Nonionizing. Nonenergy Uses^ of Radiation) -
Coordination CSD
The spectrum of concerns facing the ORP over the four major program
areas are so diverse that a designated effort is required to keep them
in perspective. It appears that the most legitimate technique to apply
in this perspective comparison is to utilize health effects indices, other
costs to society, and costs of control. Regardless of which specific
indices ultimately prove most useful, an overall model for ranking long
and short term environmental impact must be developed in order to allow
comparative evaluation of the major program areas. The current status
and state of knowledge of each of the indices for each of the four
program areas will be periodically reviewed in order to assess where
efforts might best be expended to achieve the greatest reduction in
detrimental effects. In many cases this will be expected to depend
heavily upon the evaluation of biological effects.
These activities will be developed in such a way as to augment
the corollary activities being carried out in the individual problem
areas and to develop policy statements which can be expressed in moni-
toring guidance, exposure or contamination standards, and reviews of
environmental impact statements.
B-18
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Scope
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
information as well as require overall comparative evaluation. Further-
more, 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
responsibility 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.
COORDINATION
Interagency
The Strategic Studies should provide an important focus for
identifying necessary coordination areas with other agencies. Primary
among these will be interrelationships with the AEG, the CEQ, and the
FPC. Some of this coordination is depicted in the Figure B- . It
should also be recognized that much of the interagency coordination
will be carried out in the context of the individual problem areas.
Intraagency
Strategic Studies serve as a focal point for technical coordination
within ORP. Each study will have a lead division but will usually
B-19
-------
require input from all divisions. Overall coordination of these
studies will be the responsibility of RAD, in close liaison with ORP
management.
In the course of the conduct of various strategic studies problems
will be identified which will require input from various other parts
of the agency. For instance, in the examination of alternatives to
the nuclear power cycle, it would be desirable to work with other
offices in the agency on health effects and environmental impact from
alternative fossil fuel power cycles. Also, this program area should
be instrumental in identifying and formulating research problems best
carried out by ORM. Some of the necessary coordination is reflected
in the milestone chart (Figure B-2).
ALTERNATIVE APPROACHES
Raster than include all of the studies mentioned herein as a part
of a separate strategic studies effort new generic areas could be created
to handle several of them. For instance, we could have a generic area
for environmental behavior of critical nuclides. This could include
both assessment of environmental levels and predictions relative to
future development. Another approach would be to assign the areas
discussed here to the most closely related specific problem area, with
a mandate to coordinate with the related problem areas. The recommended
approach is to identify them as a part of Strategic Studies with input
from the various problem area and organizational units of ORP.
B-20
-------
OPTIMUM PROGRAM
The time scale of the program for Strategic Studies will be highly
dependent on the time scales developed in the individual problem areas.
At the same time, the results of the efforts of Strategic Studies should
have a direct influence on the programs in the problem areas, and
expecially in determining the priority of effort that will be expended
in these areas. With this realization and the concurrent understanding
that many new Strategic Studies may evolve as the ORP proceeds on its
point in time has been restricted to those areas discussed above as
requiring a Strategic Study.
The program for Strategic Studies shown in Figure B-2 gives an
indication of the timing and chronology and the work area assignments.
These time schedules are somewhat tentative as the studies are dependent
*»
on the time frames of the problem area programs. There is also the
aspect that in some cases Strategic Studies will be iterative. That is,
the same evaluatory cycle may be repeated many times as information is
developed from the inputs.
The primary external and internal needs should be expressed in the
plans for the problem areas. For instance, the problem areas of opera-
tions plutonium and fabrication plutonium both include many of the
research needs related to the behavior at the long-lived actinides in
the environment. The coordination of these needs with involvements of
other problem areas with the actinides is a part of the function of the
Strategic Study. The carrying out of the effort involved in the broad
evaluations for the Strategic Studies generic area is estimated to require
B-21
-------
5 nan years and $100,000 per year. This presumes that most contracts
will be attributed to individual problem areas.
COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS
It is primarily dependent on the individual problem areas to express
the impact of Proposed Program compared to Optimum Program. The differ-
ences as reflected in Strategic Studies will be those of delays in
accomplishments and loss of some depth in analaysis for the Proposed
Program.
MEASURES OF GOAL ATTAINMENT
The individual concrete accomplishments of the ORP in terms of
health risk reduction can best be evaluated within the structure of the
problem areas. Accomplishments and the measurement of their attainment
in the area of Strategic Studies will be more reflected in: (1) the
degree of coordination in ORP, (2) the ability to set meaningful effort
priorities, and (3) the ability to meet the needs of the individual
problem areas in developing knowledge of generic concern.
B-22
-------
10
to
ORP
Management
Problem
Area i
Groups
Strategic
Study
Group
ORP
Technical
Resources
EPA
Technical
Resources
Extra-agency
Technical
Resources
Assist
Definition
_L
Define Scope
and Resource
Requirements
0)
4J
(0
-------
Uranium Fuel Cycle I-
Plutonium Fuel Cycle |-
-FX7J-
-FY73-
—FY74-
-FY74—
-FY75—I
T
N>
ORP
Management
/DAARP and \
IDiv.Directors)
R&D
Monitoring
Information
Criteria
and
Standards
Technology
Assessment
Field
Operations
Fuel Cycle
Problem
Areas
AEC
Reevaluation of
Problem Areas
on Basis of
Effort Priorities
Initial Estimates
of Potential
Exposures and
Costs of Control
Develope
Programs
to Fill
Common
Gaps
Notify
Related
Problem
Areas
Connnon
Knowledge
Gap
Programs
Revised Estimates
of Potential
Exposures and
Costs of Control
FIGURE B-2 (PART II)
NUCLEAR FUEL CYCLE ANALYSES - COORDINATION TAD
-------
-FY73•
-FY74-
-PY75-
Ul
ORP
Management
Energy Policy
Committee
Air & Water
Programs
Research &
Monitoring
AEC, & Other
Outside
Resources
CSD
Aid in Definition
'of Problems and
Info. Sources
Strategic Energy
Studies & Related
Problem Areas
(Mainly TAD)
Identify Alternate
Technologies and
Impact Info. Needs
Assess and Assign
Major Research
Needs, as Approp.
Standards
Development
for Problem
Areas
FIGURE B-2 (PART III)
i
ALTERNATE ELECTRICAL ENERGY TECHNOLOGIES - COORDINATION CSD
-------
-FY73-
-FY75 | FY76
ORP
Management
/DAARP & \
(Division )
\0irectors'
R&D
Monitoring
Information
Criteria &
Standards
Technology
Assessment
Field
Operations
Fuel Cycle
Problem
Areas
AEC
ecision
on Siting
iteria
Environmental
Monitoring
from Critical
Regions
Predict Future
Total Effluent!
in Critical
Regions
Develop
Models for
Regions
Environmental | Effluents
Determine Present
and
Environmental
Levels in
Critical Regions
Standard
Source
Terms and
Industry
Growth
FIGURE B-2 (PART IV)
REGIONAL GEOGRAPHICAL AREAS - COORDINATION FOD
-------
for Pu,H3.
,Kr85,Rn , I—
-FY.73-
-FY74 •
-FY75-
NJ
R&D
Monitoring
Information
Technology
Assessment
Criteria &
Standards
Field
Operations
Fuel Cycle
Problem Area
AEC
Predict Future
Technology Effluents
and Long term
Contaminants
Research Studies on
Movement and Bio-
logical Effects
Determine Present
Environmental Levels
of Potential
Critical Radio-
nuclides
Identification of
Critical Long Lived]—•
Radionuclides
Continuing Evalua-
tion of Environmen^
tal Levels
Determine Biologica]
Significance of
Environmental
Contaminant
AEC Research on
Environmental
Movement and
Biological.Effects
Environmental and
Siting Criteria
FIGURF, B-2 (PART V)
MULTIPLE SOURCE LONG LIVED RADIONUCLIDES AND LONG TERM CYCLING - COORDINATION FOD
-------
-FY73-
-FY74-
-SV75-
T
KJ
00
ORP
Management
R&D
Monitoring
Information
Criteria '&
Standards
Technology
Assessment
Field
Operations
Major
Program
Problem
Areas
Outside
Research
Contracts
Grants &
AEG
Review for Priority
of Effort Expendi-
tures
Establish Necessary
~l Research Efforts
Establish Present
Degree of Control
Develop Methods for
Comparing and
Relating Health
Effects and Identify
Knowledge Gaps
Compare
Health
Effects
Determine Costs of
Reducing Equal
Health Effects
Establish Basic
Control Costs
Cost Effectiveness
Analysis of Monitoring
S "
Control Costs for
Problem Areas
I Request Necessary
Research Efforts
FIGURE B-2 (PART VI)
COMPARATIVE EVALUATION OF MAJOR PROGRAM AREAS - COORDINATION CSD
-------
MONITORING
INTRODUCTION
The Office of Radiation Programs (ORP) is undertaking an active,
comprehensive, and dynamic approach to meet the mandate of the
Environmental Protection Agency (EPA) to protect the quality of the
environment and the health of the population from radiation hazards.
This approach implies a strategy for total radiation protection which
includes all radiation threats, and requires close coordination and
cooperation with other offices and programs of EPA, other Federal
agencies, States and localities and with universities and private
industry.
The approach developed here is problem-oriented and covers all
problem areas in which radiation is a threat, but the logical assignment
of priorities and allocation of resources require a monitoring and
information system of impeccable quality. Provisions have been made
to focus on all problem areas on a continuing basis since even the
lowest priority problems may be of a critical nature. The timing and
phasing of our program allows different levels of resources to be
applied from cognizance and problem recognition all the way to
operational programs.
This program identifies eighteen problem areas and five generic
capabilities for focusing resources in a cost-effective manner which
represents a major departure from the functional program element for
the present organization. Thus, the development of the program and
its strategy is iterative and sequential.
The basis for ORP action is the establishment of ambient standards
and effluent emission standards and guidelines. The basic philosophy
B-29
-------
for this standard-setting activity is that both environmental and
source-oriented radiation are harmful to health, and that there must be
definite measurable benefits established to offset the health risks
undertaken when levels above the zero effluent level are considered.
This does not imply a zero effluent strategy but only that the risks
undertaken must be balanced by the benefits gained in processes which
increase the threats of radiation hazards. The means of establishing
these standards and criteria on a risk/benefit basis is a generic issue
that cuts across all of EPA and ORP activities.
A major issue of generic nature is that of monitoring. Monitoring
is used to measure the present status of the environment on two bases.
The first is ambient monitoring which seeks to establish long-term
trends in the environment and to alert officials to major changes or
incidents that have been detected in the environment. The second function
is that of source monitoring which includes field studies for specific
problems, emergency procedures during accidents, surveillance of the
environment in the vicinity of nuclear facilities which discharge
radioactivity into the environment, and surveillance for enforcement.
The last-named function is exercised by the Office of Enforcement and
General Council and is not an ORP function, although ORP is responsible
for insuring proper quality control for environmental measurements at
both headquarters and for the States.
B-30
-------
In the radiation field, it should and can be possible to substantially
prevent persistent, irreversible pollution of the world by toxic radioactive
materials and hazardous electromagnetic fields by an effective system of
technology assessment and monitoring, and establishment of environmental
radiation standards. Abatement~.now -the rule .in .environmental protection—
would be needed rarely and probably only as a consequence of inattention
and apathy on the part of environmentalists, governments, and the people.
Within the EPA and the ORP our principal concerns are:
1. Ambient monitoring—determining trends and changes, and providing
an alert for environmental radiation.
2. Source monitoring—to identify radiation sources requiring control.
3. Special studies—technical support data for generic purposes, ,
specific sources, and emergency response capability, and to determine
effectiveness of controls.
Therefore, this paper will address a monitoring program that is
intended to:
1. Measure the present radiation state of the environment;
2. Determine trends through comparison of indices from measurements
over a period of time;
3. Identify sources requiring control;
4. Identify presence and character of new threats allowing prevention
at source prior to time required for control in the environment;
5. Provide a base for expansion to meet emergency or protective
action needs for environmental pollution;
6. Determine distribution of radiation levels including regional
and local differences;
B-31
-------
7. Make a continuous and valid record of environmental radiation
levels and other data required to assess dose to the U. S. population
and its critically sensitive segments;
8. Develop environmental pathway dose models for specific sources.
9. Develop regional and national dose models.
10. Provide a record of information and study to assist in making
decisions regarding research or enforcement by EPA; and
11. Provide data and biological information which will assist in
technology assessment and standards setting.
The primary objective of radiation monitoring is to provide a
technical basis for the guidance of EPA policy and program planning.
This requires ambient and source monitoring addressed to baselines,
buildups and long-term trends and a comprehensive data quality manage-
ment program in order to put specific problems in perspective relative
to standards, other problems, sources, or background. The monitoring
tasks are listed in Table B-2, the problems in Table B-3 and objectives
in Table B-4.
B-H2
-------
TABLE B-2
List of Monitoring and Support Tasks
AMBIENT
Tritium Network
Surface Water Network
Pasteurized Milk Network
Institutional Diet Network
Human Bone Network
Radiation Alert Network -x^x-
7 Interstate Drinking Water fl/**-"**^
*j e Radium Monitoring Network
,/'fifc-PAHD Air >
<>^ _PAHO Milk >^x-"
Community Water Supply^^
Eskimo Surveillance Network
SOURCE
Nuclear Facilities Surveillance
Nuclear Facilities Evaluations
Weapons Tests Monitoring
Plowshare Activities Monitoring
Non-ionizing Radiation Monitoring
SUPPORT PROGRAMS
Technical Assistance to States
Analytical Quality Control
Automatic Data Management System
Computer Model System
Radiation Data and Reports
State Radiation Source Inventory
Special Monitoring Studies
Study of Exposure from all Sources
Extraterrestrial Monitoring
State Monitoring contracts
B-33
-------
TABLE B-3
Problems
Fuel Cycle - Plutonium
Fuel Cycle - Uranium
Natural Gas Stimulation
Waste Disposal
Natural Radioactive Materials
Medical Radiation Exposure
Non-ionizing Electromagnetic Radiation
B-34
-------
TABLE B-4
Monitoring Objectives
Provide basis for environmental standard setting and modifications
.Provide basis for environmental impact evaluation
Provide basis for population dose and risk assessment
Provide capability and base for incident-accident response
Provide technical basis for establishing program priorities and policies
Provide basis for nuclear facility siting criteria
.Provide data for trend evaluations
Provide basis for evaluating abatement needs and accomplishments
Provide dispersion and exposure pathway information
Provide basis for comparing radiation pollution to other pollutants
Provide data basis for public and Congressional information
Confirm compliance with environmental standards
Provide alert for protective action needs
Indicate the presence of new sources
Provide basis for international negotiations and agreements
Provide technical basis for relief of unjustified public fear
Identification of critical environmental sources requiring control
Provide data for use by other government agendies and industry
Ensure credibility
Satisfy legal requirements
Provide information for prediction of effect of new sources
Evaluation of simulated or actual accident conditions
Indication of effectiveness of source control technology
Regional and local impact of nuclear facilities
Provide data to meet case preparation requirements
Provide data to assist in defining research requirements in equipment,
methodology, and effects
Enable determination of methods and mechanisms for removal of radionuclides
Provide a basis for determining influence of non-ioniaing radiation on
quality of life
™y
«/
B-35
-------
PROBLEM DESCRIPTIONS
Environmental levels of harmful radiation are affected by:
• Releases of radioactive material as a byproduct of nuclear
industry operations and nuclear medicine
• Man's redistribution of natural radioactivity
• Biological and physical concentration and transport of
radionuclides
• Radioactive decay
• Emissions of non-ionizing radiation
The problem is to obtain data sufficiently comprehensive to
calculate population radiation dose. Population dose information will
be used to evaluate environmental impact, trends,and population risk, as
well as for ORP program planning and policy decisions. Data resulting
from these measurements must be detailed, comparable, and subject to
singular interpretation. This requires management of environmental
monitoring programs and quality control at the Federal level.
Component Problems
Monitbring may be divided into components dealing with sample
collection, sample analysis, data management, data analysis, and
reporting. Each of these components requires specific services and
resources in order to function effectively. These resources include
laboratory facilities, data management, equipment, quality control
service, technical and logistic support services, and a system for
the orderly accumulation, retrieval, analysis and reporting of data
and information.
All types of environmental radiation monitoring except direct
B-36
-------
radiation measurements require the collection of environmental samples.
The types of media to be sampled from a particular area are dependent
on sources contributing to environmental radiation in that area and the
radioisotopes involved. The media types are also dependent on demographic
characteristics and population -exposure -pathways. -Considering ,(1) the
many environmental media with potential for concentrating or transporting
radioactivity, (2) the number of radioisotopes requiring different types
of analyses, (3) the random nature of contributing sources, (A) the
difficulty in identifying small but meaningful increments in environmental
radioactivity, and (5) the rapid increases in use of nuclear technology,
no simple monitoring program for environmental radiation will suffice.
Background
The existing sources of environmental data are:
• EPA National Surveillance Networks
• State Surveillance Networks
• AEC Facility Operator Programs
• AEC Licensee Programs
• EPA Water Quality Monitoring Programs
The EPA National Surveillance Networks were originally established
for the purpose of monitoring fallout in the environment. Although
still effective in this area, these networks have been expanded to
monitor the background, ambient trends, pathway dose and population
exposure concerned with nuclear facility effluents. The networks
presently in operation monitor air, milk, food, water, and bone.
State Surveillance Networks arc uncoordinated and vary widely in
scope because of varying State priorities and resources. In many cases
-------
gross beta measurements are performed in the environment and those are
not suitable for EPA objectives which are concerned with monitoring
environmental trends and acquiring information to confirm dose
calculations based upon emission data, pathway transport and demographic
data. Similar conditions exist for AEC Facility Operator Programs,
AEC Licensee Programs, and EPA Water Quality Programs wherein the
measurements are primarily limited to gross beta activity.
The Office of Radiation Programs has recently completed the
"Environmental Radioactivity Surveillance Guide" which provides guidance
for establishing surveillance programs around light-water-cooled nuclear
power facilities. Adoption of this guide by AEC licensees and States
will greatly strengthen the resulting surveillance data.
Scope
Present
The scope of the present ORP Environmental Radiation Monitoring
Program is presented in Figure B-3. This figure summarizes the sources
of environmental data, the types of data reported and the anticipated
used for the data. It also shows the relationship of the data to the
data management system and dose models.
Future
Rapid growth has been projected for several components of the nuclear
industry. The principal areas expected to influence environmental
radioactivity levels are related to the nuclear fuel cycle, medical
applications of radioactive isotopes, and plowshare activities. Of
particular concern in the current programs is the expansion of the
B-38
-------
IHPW
Naclbnal Environmental Radiation Data System
OUTPUT
USB
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vo
AMBIENT MONITORING DATA
Survo 11 lance Network!
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Nuclear F.icillty Survelllanc
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Basis for
Environmental Standards
Standards
Development
Baals for
Environmental Impact Review
Baals for
Population Risk Assessment
Prediction of Effect
of Continued Nuclear
Development
Identification of
Abatement Needs
Discharge Abatement
through AEC and/or
State Action
DAARP
Environmental Intimation
Effective Program
Planning
Public Information
— >
Credibility
Das Is for Intcrna-loml
Negotiation b Agreement
Reduction In Worldwide
Contamination
Alert for Protective
Action Needs
Dose Reduction
Throuch Protective
Action
FIGURE B-3. ORP AMBIENT AND SOURCE MONITORING
-------
nuclear fuel cycle. Figure 8-4 shows the anticipated growth rate of
the use of nuclear energy for nuclear power with a factor of six increase
in capacity by the year 2000. It is anticipated that the scope of
the monitoring programs associated with the fuel cycle will increase
at a corresponding rate. Any reduction in surveillance requirements
resulting from improved emissions control technology and increased
knowledge and exposure and environmental trends will be offset by
changes in nuclear technology and applications requiring new monitor-
ing applications and techniques.
LEGISLATIVE STATUS
General Authority
On August 14, 1959, the President issued Executive Order 10831,
establishing the Federal Radiation Council "to advise the President
with respect to radiation matters directly or indirectly affecting
health, including guidance for all federal agencies in the formulation
of radiation standards and in the establishment and execution of pro-
grams of cooperation with states."
The Secretary of Health, Education and Welfare was subsequently
designated as the chairman of the Federal Radiation Council and DHEW
was directed to:
... intensify its radiological health efforts and have
primary responsibility within the executive branch for
the collation, analysis and interpretation of data on
environmental radiation levels such as natural back-
ground, radiography, medical and industrial use of
isotopes and x-rays, .and fallout, so that the Secretary
of Health, Education and Welfare may advise the President
and the general public.
B-40
-------
'~- 1962 REPORT TO
THE ?REs:.car
FIGURE B-4. ESTIMATED NUCLEAR GENERATING CAPACITY IN THE U.S.
THROUGH THE YEAR 2000
B-41
-------
Environmental radiation monitoring networks were established to
meet these assigned responsibilities. Pursuant to the President's
Reorganization Plan No. 3 of 1970, the responsibility was transferred
from DREW to the Radiation Office (now the Office of Radiation Pro-
grams) of EPA. "The 'February 1971 -i-asue -of -Radiological -Health -Data
and Reports (renamed Radiation Data and Reports beginning with the
January 1972 issue) carried an editorial, signed by the EPA Adminis-
trator, indicating the role of the publication as excerpted below in
reporting environmental radiation data.
The National Environmental Policy Act of 1969, Public
Law 91-190, provides for the development of reports on
governmental actions that may have impact on the environ-
ment, for the accumulation of data and other information
for a continuing analysis of changes or trends, and for an
interpretation of their underlying causes.
Now in its twelfth year of publication, Radiological
Health Data and Reports has served governmental agencies,
scientific and technical communities, and the public as a
qualified source of information in its field, and as a use-
ful record of trends in environmental radiation and its
impact on the population.
We...recognize the interrelationship of all forms of
environmental hazard. The role of this journal may well
be enlarged to provide a continuing record of data that will
help qualified investigators to evaluate the total impact of
environmental hazards in a highly complex technological society.
Any future expanded role will develop as we progress
in formulating systematic procedures to correlate the find-
ings of studies and surveys relating to ecological systems
and environmental quality. In pursuit of these aims, the
cooperation of investigators at all levels of government,
and that of other involved organizations, will be sought.
EPA has broad authority to act as far as the environment is con-
cerned and can provide guidance to set general environmental radiation
B-42
-------
protection standards based on authority which has been transferred from
the AEG to EPA and by the transfer of the FRC function by Reorganization
Plan No. 3.
The best approach to determiaati^s c-f. environmental levels of
nonionizing radiation is 'to use EPA'''s broffd manda'te -to, among o'ther
things, "by itself and together with other agencies, monitor the
condition of the environment - biological as well as physical" as
provided in Reorganization Plan No. 3 of 1970. This plan further
states the role of EPA to be able "in concert with the States - to
set and enforce standards for air and water quality and for indiv-
idual pollutants."
B-43
-------
Specific Authorities Related to Monitoring
Public Health Service Act, as Amended
This gives EPA the authority to perform research and development,
surveillance and inspection, assistance to States, and training and
research grants.
AEG Act of 1954. as Amended
This gives EPA the authority to establish generally applicable
environmental radiation standards for the protection of the general
environment from radioactive materials.
Federal Radiation Council Functions
These give EPA the authority to "advise the President with
respect to radiation matters directly or indirectly affecting health,
including guidance for all Federal agencies in the formulation of
radiation standards and in the establishment and execution of programs
in cooperation with the States."
National Environmental Policy Act of 1970
This requires EPA to evaluate the environmental impact of Federal
activities as described in the Act.
EPA Organization
The principal activities of our radiation program are grouped
into three functional areas:
• Standards and Guidance,
• Surveillance and Inspection, and
• Technology Assessment.
B-44
-------
The Administrator has made the following policy and program
decisions regarding the management of monitoring within EPA.
Definitions
EPA uses four types of monitoring:
e Ambient Trend Monitoring, to measure conditions and trends
in the ambient environment in relation to standards and
guidelines.
• Source Monitoring, to locate and measure effluent emissions,
and to assess the compliance status of pollution sources.
• Case Preparation Monitoring, to gather evidence for enforce-
ment actions.
• Research Monitoring, to support ORM's research activities.
The National Program Manager for ambient trend radiation
monitoring is the Assistant Administrator for Categorical Programs.
For further information relative to EPA organization for radiation
monitoring, see Tab 1.
B-45
-------
COORDINATION
Interagency
The major areas of interagency coordination with ORP for
monitoring are shown in Figure B-5. A special type of relationship
exists with other agencies on nuclear facility coordination and is
discussed in some detail. Coordination between EPA, NBS, AEC and
the States is required relative to monitoring efforts associated
with nuclear power facilities. A summary of the required coordina-
tion is charted in Figure B-6.
The AEC licensees and AEC operating facilities which include
operational reactors, must report their discharge, operating, and
surveillance data to the AEC Division of Compliance or the AEC
Division of Operational Safety. Nuclear ship operators and operators
of shipyards, which perform maintenance on nuclear ships, provide
discharge and environmental surveillance reports to the Naval Reactor
Branch of the AEC. Most States in which nuclear facilities operate
also arrange to receive these reports.
R-46
-------
Agencies
Problem Areas
AEG - power reactors
- research & test
reactors
- national
laboratories
- test sites
- production facilities
- radioisotope sources
State & Local Governments
- radioisotope use
- waste disposal sites
- occupational - medical
- hospitals - institutions
iFabrication-
NASA
- test reactors
- SNAP sources
- space vehicle launch sites
POD - Army - power reactors, weapons
- Navy - nuclear ships, weapons
- Air Force - weapons, space sources,
missile test facilities
Department of Labor
- mines
- mills
Accidents
Waste Disposal
Fuel reprocessing
Thermonuclear
-plutonium
Operation-plutonium
Operation-uranium
Fabrication-uranium
Transportation
Construction Materials
Mining and Mills Tailings
Microwave and RF
Agencies
NOAA - trajectories for fallout studies
PHEW - milk & food collection
- data processing
- biomedical research, EMS standards
NBS - standards, instrumentation
PAHO - technical & laboratory assistance
Laser and Other Electro-
magnetic Radiation
Government - surveillance around
nuclear barge STURGIS
WHO - data for worldwide dose model
Industry - comparison of data
POT - transportation regulations
Agriculture - crop data
NAS - Consultants
CEQ - Continuing Liaison
DTP - EM Programs
Plowshare Projects
Pevice Testing
Medical Isotope
Occupational
Medical X-ray
FIGURE B-5. MAJOR AREAS OF INTERAGENCY RELATIONSHIPS—MONITORING
-------
National
Bureau of
Standards
St-p.Jard
Sources
I
KA
AQCS
AEC
Licensees,
AEC
Facilities
Discliarj;Ci
operating &
surveillance
reports
AKC Divisions
Ox Compliance
or Operational
Safety
Operator &
AEC inter-
pretive
reports
—\Coordination
Regional
Offices
State Radiation
Control Agencies
Technical
Assistance
Of I ice of
Research &
M"nJ forirg
Office of
Radiation
Progra-ns
Monitoring
Reports
Research
Ais is'tancc &
Monitoring
Hata
Discharge &
Surveillance
Reports
FIGURE B-6
INTERAGENCY COORDINATION FOR MONITORING OF NUCLEAR FACILITIES
-------
The "AEC in many instances, interprets and summarizes reports
from facilities under its jurisdiction. The EPA/ORP should receive
both facility operator reports .and th^AEC interpretive^ and summary
reports. State radiation control agencies should also receive these
.reports. Evaluations will be,.made by ,ORP relative to environmental
radiation standards and any abatement needs will be transmitted to
the appropriate AEC divisions via the EPA Office of Enforcement and
General Counsel.
Based on surveillance program needs, EPA/ORP will provide technical
assistance and support services (e.g., laboratory and Quality Assur-
ance Program) to State agencies for environmental monitoring. QAP
will also be provided for Federal and industrial monitoring programs.
The sources used for QAP standards will be traceable to the National
Bureau of Standards. Monitoring reports from States, as needed,
will be provided to EPA to supplement data from other sources.
Intra-agency
Office of Water Programs. The Water Supply Program Division
performs radiological analyses in support-of the Community Water
Supply Study and its special sub-studies, and the Interstate Carrier
Drinking Water Analysis Program.
Office of Air Programs. Coordinate the Radiation Alert
Network.
B-49
-------
ALTERNATIVE APPROACHES
The approach to radiation pollution can be seen from a flow
chart such as that in Figure B-7. The first level shows the flow of
a pollutant from the source into the environment, from the environ-
ment to population exposure via an exposure pathway (some exposure
pathways such as direct exposure may bypass the environment), from
population exposure over a period of time to population dose, from
population dose integrated over population living time to health
effects, and finally from population dose integrated over population
liefetime to residual buildups of radionuclides in bones, tissue,
or organs. The flow of pollutants from the source to an environ-
mental media is shown by an arrow. A circle around an arrow indi-
cates a control point. The flow of pollutants from the environmental
media to the point of population exposure via population exposure
pathways is similarly shown by arrows.
The second level indicates the availability of- computer-models— -
that can be used to calculate the transport of radioactive pollutants;
for example, the transport of source discharges to the environment.
Each model begins with a sampling point and ends with a sampling
point. In theory, one might be able to monitor all discharges and
calculate everything else./Unfortunately, the computer models are
/
inadequate for this purpose and furthermore it isn't practical to
monitor everything. Consequently, a carefully selected monitoring
program of both discharges and environmental samples, supplemented
by the use of computer models appears to offer a reasonable compromise
B-50
-------
between need, cost, and effectiveness.
The third level indicates the type of samples that are obtained
and the fourth level shows the various types of monitoring that can
be performed.
Finally, the flow of data to the point of analysis and evalu-
ation and the flow of this information to ORP headquarters for
decisions related to the control (or for special evaluation of a
problem) of pollutant flow is shown. The feedback loop is closed
by exercising the control capability, usually via other regulatory
agencies (guidelines) or by State Health Departments (recommendations).
In considering alternative strategies, two points should be
kept in mind. First, a flow chart, such as that shown in Figure
B-7, could be drawn for every source of each radionuclide that is
considered to be serious enough to warrant attention, and the details
of the flow chart would be different for each source. Secondly,
the level of population exposure or dose rate to a specific source
is usually smaller than the error of the sum of the calculated
population exposures due to natural radiation and other nonenviron-
mental sources or radiation; consequently, there exists a need to
measure natural and nonenvironmental radiation more accurately in
order to fully assess the importance of a specific source of radiation
pollution.
Except for fallout and widespread nuclear incident surveillance,
the current ambient trend monitoring is not adequate for ORP priority
requirements. The current and anticipated ORP problems are being
B-51
-------
SffJRCE
ENVIRONMENT
PATIRAY
KAN
DIRECT
W
m
to
0—Monitor!
Nctwo -k
H—Control ;
Pol lull on
Flew
Reg.
folcieline3 \Agcy
XX . ,
Effects Kon.1 iRcsiducl Kci
FIGURE B-7
FLOWCHART FOR CONTROL OF A TYPICAL RADIONUCLIDE
-------
evaluated at this time. From this evaluation, a comprehensive
ambient trend monitoring program that will be integrated with other
EPA monitoring programs is expected to be defined. Such a program
is expected to include the current networks, which are addressed
to most of the major exposure pathways (food, water, and milk) and
to require a small but a well-planned comprehensive ambient trend
network that may be integrated with other EPA programs, e.g., analysis
of water samples routinely obtained by other agencies, etc.
ORP source monitoring needs are at two levels. A broad
inventory of low-level discharges of radionuclides is needed; this
may be provided by a review of information obtained by OEGC. An
in-depth study that is addressed to exposure pathways is needed to
evaluate the radionuclide discharges from facilities such as
reactors, hospitals, etc. The latter source monitoring, usually
referred to as Special Field Studies will be more cost-effective
if conducted by OCP Support Facilities rather than by the regions.
OPTIMUM PROGRAM
Level
ORP has responsibility for source monitoring outside nuclear
plant boundaries. Carrying out this function to the ultimate would
involve continuous offsite source monitoring of every facility. A
program of this extent is unwarranted since the AEC, through its
licensee and State contracts, can provide the operating data and
offsite surveillance required for determination of dose by use of
pathway models. Because of the relatively low level population risk
B-53
-------
from exposure to plant effluents under normal operating conditions,
it is inefficient to carry out an independent measurement program at
this level.
The optimum monitoring program is one that acquires the
proper format all of the information that matches the monitoring
requirements at the time that it is needed. The optimum cost-
effective program would be an optimum monitoring program conducted
at a minimum cost.
The Optimum Program constitutes carefully selected monitoring
of both discharges and environmental samples, supplemented by the
use of computer models. It would be low cost, using available AEC
licensee operating data, a set of validatedjpathway models and a
computer program, to estimate dose to the population from individual
plants. A national population dose will be obtained by summation
of these estimates.
Design
Figure B-8 is a flow chart relating the sources contributing to
environmental radiation to population dose and to environmental
effects of these sources. The relationship of environmental
monitoring, pathway models, effects models, and empirical studies
in evaluating the measured effects is also shown.
Monitoring data must provide a technical basis for solution to
the 18 problem areas defined for ORP. Data and program requirements
to provide this information are summarized in Table B-5 which shows
B-54
-------
Ui
Ui
SOURCE
AMOUNTS
RADIOACTIVITY
(CURIES)
RADIOACTIVITY
(CURIES)
RADIOACTIVITY
(CURIES)
MEASURED
CORRELATED
EFFECTS-
DEATHS.
CANCER,
MORBIDITY.
RFMFTIP
ETC.
SOURCE
CONTROL
FPFI UFNTC
cik/iiccinivic
CIVIIoolUINo
oHIhLUIIMo
EFFECTS
^^
INDIVIDUAL
HEALTH
EFFECTS
POPULATION
HEALTH
EFFECTS
FWVI ROMMPNTAI
EFFECTS
|
5
4— 1
PATHWAY
CONTROL
PATHWAY
MODEL-
C It/IDC Dir* A 1
tlvlrtmUAL
STUDIES
EFFECTS
MODEL-
EMPERICAL
STUDIES.
ANALYSES
E
^
-*
CONCENTRATIONS
AMBIENT
LEVELS AND
BACKGROUND
(CURIES/m3)
XPOSURE CONTROl
EXPOSURE
MODEL-
EMPERICAL
STUDIES AND
EXPOSURE
MEASUREMENTS.
cuici niNin
DISTANCE
(ROENTGENS)
nncc
DOSE
MODEL
(REM)
*— 1
FIGURE B-8
RADIATION CONTROL MECHANISMS AND HEALTH EFFECTS
-------
TABLE B-5
SCOPE OF MONITORING DATA AND PROGRAM REQUIREMENTS
Problen
Monitoring Data Requirements
Monitoring Progr.Ti Requirements
1. Accidents
2. Waste Disposal
T
U»
3. Fuel Reprocessing
4. Plowshare
1. Capability for emergency monitoring following an accident
2. Inventory and categorization of past accidents related to
their environmental impact
3. A network to detect major unrcportcd releases which can be
expanded to monitor an accident trajectory
1. Forecast analysis concerning mounts of high-and low-level
wastes scheduled to become available
2. Evaluation of present facilities for disposal of those
wastes
3. Projections of requirements for future facilities and the
locations of these sites
4. Quantity, types and locations of disposal sites
5. Source and pathway monitoring data from the vicinity of
facilities
1. Quantification of the rate of growth of the nuclear fuel
processing industry
2. Industrial-ecological analysis to optimize the environmental
Impact of facilities
3. Development of pathway eonltorlng prograrj to evaluate
population exposures
4. Feedback of data for the control of plant operations and
waste disposal
5. Source cor.ltorlng data from the vicinity of the facilities
6. Facility discharge data
1. Source monitoring data around project arena
2. Sourre monitoring data for affected consumer products
3. Ambient monitoring data nationwide for nuclldcs in potential
exposure pathways
1. Continued aid expandable capability for source
and pathway monitoring, bloassay capability
2. Accident reglitry
3. Ambient monitoring networks for radlonuclldes in
potential patlw.iys for exposure from accidents
Source and pai'-vay monitoring prograns in the
vicinity and .-rbient monitoring prograns
nationwide for comparison
1. Emissions monitoring
2. Occupational tonitorlng
3. Source and prthway monitoring
4. Anbicnt mopitorlng
Prograns as indlcitcd In colurm 2
-------
TABLE B-5
T
SCOPE OF MONITORING DATA AND PROGRAM REQUIREMENTS
(Continued) ..
Problem
Monitoring Data Requirements
i. Thermonuclear
6. Vadiofrequeney and
Microwave
7. Construction
Materials
S. Flutonlua
Fabrication
9. Qperation-
Flutonlun
Anblent and pathway data for tritium, nationwide
1. Inventory of all RF sources
2. Power level density plots for all densely populated areas
3. Monitoring Instruacntatlon to measure emergency or high-
level rodiofrequcncles
1. Inventory of varieties of construction materials with
ranges of radioactivity levels Including rndlolsotopes
2. Radioactivity levels as a function of material source.
e.g., mining areas
3. Surveys to apportion population dose as a function of
radiation from construction materials
4. Data on which to base cost/risk analyses
5. Data for economic impact evaluation of changis In
construction materials
1. Reiuspenslon factors
2. Eolsslons data
3- Source and pathway monitoring data
4. Ambient plutoniuo levels
1. Ambient plutonlun levels In environmental neitia & pathways
2. Special studies concerning emission from operating facilities
and plutoniun fuel reprocessing
Monitoring Program Requirements
Program as irdicated in column 2
See column 2
1. Special s- uiles relative to pathway,
dose, and resuspension.
Some as Item " Above
-------
TABLE B-5
SCOPE OF MONITORING DATA AND PROGRAM REQUIREMENTS
(Continued)
Problem
Honleorlng Data Requirements
Monitoring Program Requirements
I
00
10. Operation-
Urnr.lun
11. Medical Isotope
12. Occupational
13. Medical X ray
14. Device
Testing
13. Mining and
Mill Tnllings
1. Routine discharge data related to Isotope tine and release rate
2. Data relating operations to discharges
3. Routine source monitoring data from the area
1. Present and future requirements of radlopharnaceutlcals, degrees
of environmental radiation exposure to medical community, and
degree of environmental contamination
2. Health risk associated with present and future levels of radio-
pharoaceuticals
3. Emissions associated with these facilities
1. Inventory of exposure of oecupatlonolly exposed personnel by
industry - operation - profession
2. Inventory of causes and current methods of prevention of
occupational exposure
1. Present and future requirements foe medical x rays •
2. The degree of occupational and medical exposure as a (unction
of procedures, equipment and training
1. Ambient trend monitoring network which can be used for alert
and cloud trajectory
2. Source monitoring relative to Nevada Test Site
1. Source and pathway monitoring data in the vicinity of uranium
mines and mills
2. Mine monitoring for occupational exposure
3. Ambient trend monitoring
1. Source and pathway monitoring programs
2. Ambient trend no.iltoring
3. 'Special studies relative to pathway and
population dose
Speclt studies to determine need for abate-
ment or continued source monitoring
1. Observation and itudy of conditions associ-
ated with occupational exposure
2. Occupational exposure monitoring program
Continued assessment of exposure from medical
x rays both occupatlonnlly and medically
As Indicated In colian 2
See column 2
-------
Problen
16. Fabrication
Uranium
17. Transportation
TABLE B-5
SCOPE OF MONITORING DATA AND PROGRAM REQUIREMENTS
(Continued)
Monitoring Data Requirements
1. Routine discharge data including discharge race, tlce and
release route
2. Data relating operations to discharges
3. Routine surveillance of the area around opera dig facilities
Monitoring data requirements will be nlnlnal except under
accident conditions
There la a need for the developrcnc of an environmental TLD aystea
Monitoring Proernm Requirements
Source monitoring .irogroms
f
Ul
18; Ltaer and Other
Electromagnetic
riullftlBn
Not yet defined
Special studies to determine hazards end
data needs
-------
that monitoring data will be required to support each of the problem
areas and that in many cases different problems require similar types
of data. This is particularly true for the establishment of ambient
background levels to which source monitoring data may be compared.
A systematic approach to defining and implementing an optimum
monitoring program is to:
1. Identify the needs or uses of monitoring data in detail.
This is currently being pursued within ORP.
2. Specify in detail the monitoring requirements and how
the resulting data is to be used, (siting, frequency,
accuracy, precision, media, response time, etc.) The
current ORP review of present and future radiation
pollution problems is expected to provide the basis for
this step.
3. Determine alternative monitoring systems for each
requirement.
4. Select an overall monitoring system that meets the speci-
fications of a maximum number of requirements. (This
leads to a selection of a minimum number of sampling
sites, a common sampling frequency, multiple analyses
of each sample, and a considerable reduction in the cost
of data management).
5. Phase the new monitoring system in and phase the current
monitoring system out with sufficient overlap to provide
orderly transition.
B-60
-------
6. Continue to examine critically the output and use of
the monitoring information and phase out unproductive
monitoring data and phase in new or modified monitoring
requirements.
Networks
The optimum monitoring system should include a blend of
networks. It should be kept in mind that a network is a means of
systematically collecting information from a set of selected sample
sites for a specific purpose; consequently, the blending of these
individual networks should be done by selecting sample sites and
sampling frequencies that are common to different networks. (^If
these networks can also be blended at this step with networks con-
ducted by other agencies or other program offices, a considerable
saving in effort may be accomplished, particularly in regard to
obtaining auxiliary data, e.g., demographic, hydrologic, geologic,
meteorologic, etc. The following sets of netwolrkdS should be
blended:
Pollution Indices. A network of carefully selected sample
sites that acquires the data needed for radiation pollution indices.
Protective Action. A set of networks that can be used to
monitor the radiation pollution in critical pathways following an
episode. They would be used periodically to test the capability
and to maintain baseline data and following an episode, selected
parts of the networks would be activated to define the geographical
region of Interest and then the network in that geographical area
B-61
-------
would be activated to acquire the data necessary to evaluate the
impact of the episode.
Ambient Trend Monitoring. Ambient Trend Monitoring should be
addressed to:
• trends of pollutants in pathway__and-
• trends of pollutants in the environment.
The most effective sampling technique is to monitor the path-
ways because of concentration factors and because this provides the
most direct data that is useful for calculating population exposure
(Figure B-9). The most effective way of measuring other pollutants,
such as radioactive noble gases, tritium, airborne particulates,
sediments, etc., may be by strategically located environmental
sampling. In some cases, source monitoring may be the most effective
method for specific radionuclides. Also, in certain cases, e.g.,
particulates or shortlived radionuclides-environmental samples in
small geographic areas for example around' large population centers
may be the most effective monitoring technique.
Source Monitoring. The purpose of source monitoring are to
measure:
a) the amount and kind of pollutants from specific classes
of sources,
b) where the pollutants go in the environment for a specific
class of source, and
.B-62
-------
RADIOACTIVE
MATERIAL
T
SOIL
. SURFACE cr
3Rou;;D I'.ATZ:
RADIOACTIVE
MATERIALS
•DIRECT RADIATIO;.1-
1
Aq'i:{ic
Fl::.ts
S.^.I -~J
t.uJ k..i'J
Ssdin-i-iit
Soil
Fishing ?rd
Sports G::r
Plants
*—i 1
Land
Animals
FIGURE B-9
PATHWAYS BETWEEN THE RADIOACTIVE MATERIALS, RELEASED
TO THE OCEANS, SURFACE UATiiRS A1,TD THE GROUIID, AND M-'
B-63
-------
c) the contribution and trends of pollution from specific
classes of sources to the ambient pollution.
For radiation pollution, parts a and b are usually accomplished by
special field studies that examine each class of source in detail.
Part (c) is accomplished by:
(1) monitoring the effluents from all known major sources
of a specific class; for example, the effluents of all
nuclear power plants are compiled to ascertain the radia-
tion pollution from the operation of nuclear facilities
as a whole, in specific geographical areas, and in local
regions about each plant.
(2) monitoring the effluents from a few facilities that
represent a class of sources, such as hospitals.
(3) monitoring media extensively, sensitively and representa-
tively and by appropriate models determining source
specific contributions to environmental pollution and
human radiation exposure.
(4) With the aid of transport and pathway models, the
exposure to the population from these sources can be
calculated. As a check on the computer transport models
it is desirable to obtain environmental samples and
pathway samples for analysis for empirical comparison with
values computed by the transport models. (Note: Sample
acquisition - The overall sampling program for all of the
B-64
-------
networks should be designed such that a minimum number
of sample acquisitions satisfy all of the needs described
above.)
(5) Exposure measurements - Needs should be defined for this
activity.
(6) Effects monitoring - Needs should be defined for this
activity.
(7) Residual monitoring - The long-term buildup of long-lived
radionuclides such as strontium-90 and plutonium that are
observed by analysis of biological samples and that can
be correlated with population health effects provides the
most reliable relation between population exposure to
these radionuclides and health effects that are needed
to determine minimum exposure limits.
External Needs
Legislative Needs
The current authorization for EPA in the control of environ-
mental radiation is through the President's Reorganization Plan
No. 3 which transferred the responsibility for environmental
controls from the Public Health Service to EPA.
B-65
-------
Knowledge Needs
The accomplishment of goals related to population dose and
effects requires considerable knowledge in areas other than monitor-
ing data. Population dose calculations require knowledge of
environmental conditions such as meteorology, geology, hydrology,
demography, and exposure pathway data. Much of this information
is available from government agencies and from nuclear facility
operators. An information system will be required to make the
data available for input into calculational models.
Mathematical models used for population dose calculations will
require verification through_enviEO"""»"j^fi monitoring. Much of this
verification much be accomplished through special studies of specific
sources and environmental conditions.) Routine monitoring programs
— — /
can be established and modified based on knowledge gained from these
special studies.
Research and Development Needs
The effects of radiation exposure at the low levels encountered
from man-made influences on natural background are not well known
and will require continued research to improve this knowledge base.
Research will also be needed for the development of more sensitive
and economical methods for analyzing environmental samples and
radiation levels. The use of new technology will produce new
pollutant problems and will require continued R&D for improved monitoring
techniques and equipment.
B-66
-------
Enforcement and Control Requirements
Enforcement of environmental radiation standards is presently
accomplished through AEC or State agencies. This method of control
has been adequate.
InteTageney -Implement-ation
Implementation of the optimum monitoring program will require
cooperation among EPA, AEC, DOD, NASA, DOL, DOI, NBS, and other
government agencies. Figure B-10 is a diagram of interagency
coordination for monitoring of nuclear facilities.
Data Management
The recommended data management system must have the capability
to fully support ORP's Systematic Radiation Strategy and provide data
support services for the solution of ORP's 18 problem areas. Specific-
ally, the system should:
e Provide data and information to determine the existing state
of the environment.
o Provide measures of radiation parameters which serve to
indicate the progress of ORP programs designed to control
and reduce radiation in the environment.
o Provide data and information services as required for the
solution of the 18 major ORP problems.
B-67
-------
AEC,
States,
& DOD
NOAA
C & G S
& States
FDA
Bureau of
Census
DOA
not
Discharge &
Surveillance
Data & Reports
Data
Hydrological
Data
Diet Data
Demographic
Data
Food Production
& Distribution
Data
Fish & Wildlife
& Mining Data
-**
AEC &
DOT
Occupational
Exposure Data
EPA/OR?
Standards,
Guides,
Evaluations,
Trends, and
Control
Recommenda-
tions
FIGURE B-10
INTERAGENCY IMPLEMENTATION
B-68
-------
The determination of the existing state of the environment can
be achieved in two ways. One is through both source and ambient
monitoring. The other is through modeling of the dispersion and
diffusion of source effluents through the environment, determining
concentrations in pathways, and estimating the dose to man.
Data obtained from monitoring provides factural measured infor-
mation about environmental status. /Data obtained by modeling is
theoretical and subject to error due to inadequacies in the state
of the modeling art for the dispersion and diffusion of effluents.
Nevertheless, somewhat imprecise modeling can provide valuable
information concerning environmental status. ./Through modeling the
contribution of low level concentration of nuclides to dose can
be determined. /Additionally modeling of environmental status can
be used to predict future environmental status in light of plans
for additional radiation sources, and thus possible environmental
contamination in the future may be foreseen and avoided.
Through use of a data management information system combined
with appropriate models the progress of ORP programs for the control
and reduction of environmental radiation can be measured. Similarly,
information needed to assist in the solution of ORP problems can be
generated. Figure B-ll depicts a conceptual combined data manage-
ment and modeling system to achieve these goals. Essentially the
system would consist of a series of computational models which would
serve to simulate pathway diffusion and calculate environmental
B-69
-------
Source term
data base
roblem
Solution
Data
Monitoring
Data
Base
Pathway data
base
PATHWAY MODEL
Environ-ental
Concentrations
Exposure
Model
rob lem
Solution
Data
Agricultural
& Demographic
Data
Base
/^Population
I Health
V Effect
InaiviauaTX
Health )
Effects J
Correlated
Effects
[ Control "N /Program *\ /^Reports & ~"\
\Ef fectivpnpsj/ \^ Progress J \Public Info./
FIGURE B-ll
ORP INTEGRATED TECHNICAL DATA MANAGEMENT AND MODELING SYSTEM
B-70
-------
concentrations, an exposure model to calculate dose resulting from
environmental concentrations (calculated or measured by monitoring)
and an effects model which would produce health effects and environ-
mental effects. A data management system would be used to organize
the various data bases required by the models and would provide the
capability to manipulate data base information and model results in
order to provide problem solution information. The results of the
effects model would be used to assess control effectiveness, program
progress, provide trend analysis for effects, provide data for
reports and public information and data for problem solutions. To
design, develop, and place the system in operation a considerable
effort would be required. Discussed below are the external and
internal needs for the system.
External Needs
Legislative. None..
Knowledge. Knowledge of other EPA technical data management
systems and modeling capabilities is required in order to take
advantage of existing capabilities within the agency, prevent dupli-
cation, and achieve economy through common use of existing data,
hardware, and computer software if advantageous to ORP.
Research and Development. A health effects model must be
developed which relates dose from ionizing and nonionizing radiation
to health.
Enforcement and Control Requirements. None.
B-71
-------
Interagency Implementation. A large scale model which calculates
environmental concentrations and dose on a regional basis based upon
source term effluent exists. This model is being used by the AEC.
This model with modifications was recommended for ORP use in a systems
design study for a system to collect, assimilate, and manipulate
environmental radiation data. Joint AEG/EPA use of the mode, or
development of its data base and program modifications is being
considered.
Internal Needs
Legislative Needs. None.
Knowledge. A systems design study has been conducted under
contract. This study will serve as a basis for the design of the
total integrated optimum system and must be updated, revised, and
expanded to include health effects. The total system design study
would include complete definition of inputs, processing requirements
to include response time, model selection, and output definition.
Based upon this study, technical system specifications can be
prepared. These specifications would then be used to implement the
system either by contractor internally, depending upon resources.
A major part of the implementation effort would lie in the develop-
ment of data bases for pathway and exposure modeling. Table B-6
shows the general categories of information that would be required
and their sources and Table B-7 shows the major milestones for an
optimum data management modeling system.
B-72
-------
TABLE B-6
DATA BASE SOURCES
Category
Monitoring' Data'Base
e Source
o Ambient
o Background
Source Term Data Base
Pathway Data Base
o Meteorological
o Hydrological
Demographic Data Base
Agricultural Data Base
Source
States, utilities, Federal Agencies
EPA Networks, States
AEC Safety Guide 21 Reports
(data from utilities)
Other facilities in the Nuclear
Fuel Cycle
National Oceanographic and
Aeronautic Administration
U.S. Army Corps of Engineers
U.S. Bureau of Census
U.S. Dept. of Agriculture
Although these agencies are listed as sources, the data they
possess will in most cases require extensive data reduction
in order to be used.
B-73
-------
TABLE B-7
MAJOR MILESTONES
•7-'«p» -r- -
^aiTG ^SYSTEM
Complete Systems Design July 73 FY-74
Study for Integrated System
Contract for System Oct. 73 FY-74
Development
Test System Oct. 74 FY-75
System Operation Dec. 74 FY-75
-------
PROPOSED PROGRAM
The Office of Radiation Programs supports the following
monitoring activities:
, Q Operation of nationwide ambient monitoring networks for
air, food, water, and milk;
e Development of guidance for source monitoring;
o Technical assistance to States for source monitoring and
(7
/','-'' ' reporting data;
o A nationwide quality assurance program;
o Capability for automatic data processing and computer
modeling;
• A monthly publication, Radiation Data and Reports;
o Evaluation and field studies of environmental impact of
operating nuclear facilities; and
o Offsite monitoring support for device tests.
Programs are also being developed to monitor nonionizing
radiation and natural radioactivity.
Our current approach is to provide laboratory services at WERL
and EERL for ambient monitoring. Source monitoring with the excep-
tion of device test monitoring by WERL, is conducted by States with
laboratory support and technical assistance provided by ORP, as
required. Analytical quality control will be provided by EERL.
All program management, data analysis, and reporting are provided by
headquarters. Ambient and source monitoring programs as well as
field studies must be conducted in support of all ORP programs.
B-'/i
-------
External Needs
Legislation
The proposed program will be conducted under the legislative
authority transferred to EPA by the Reorganization Plan No. 3 of 1970.
Specific authorities are:
0 AEC Act of 1954. as Amended, gives EPA the authority to
establish generally applicable environmental radiation
standards for the protection of the environment from
radioactive contamination.
0 Federal Radiation Council Functions, which give EPA the
authority to "advise the president with respect to radiation
matters directly or indirectly affecting health, including
guidance for all Federal Agencies in the formulation of
radiation standards and in the establishment and execution
of programs in cooperation with the States."
e National Environmental Policy Act of 1970 empowers EPA to
evaluate the environmental impact of Federal activities as
described in the Act.
No further legislation is necessary to conduct the program as
presently planned. The radiation data which is needed can be acquired
B-76
-------
by cooperative effort of Federal, State, and local agencies.
Knowledge
With samples for the monitoring program being collected and
analyzed by many different agencies and laboratories, it is essential
to develop standardized sampling and analytical procedures in order
to obtain reliable data which will be used to provide
• a public source of information on radiological conditions
in the environment,
• a source of radiological information for the evaluation of
environmental trends and the influence of radioactive waste
discharges,and
• data for the calculation and estimation of population
radiation dose and a data base for the development of
environmental standards.
It is also imperative to know what quality control methods are
presently employed by State and local agencies to assure precision,
7
accuracy, and reliability of data.
In line with the need to obtain uniformity in analytical results
and to obtain environmental radiation surveillance data from operating
nuclear facilities, the Environmental Radioactivity Surveillance Guide
was developed by SID. This Guide recommends methods for conducting
a minimum level of environmental radiation surveillance in the
vicinity of light-water-cooled nuclear power facilities. The Guide
discusses preoperational and operational programs, site selections,
B-77
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sample collection and analysis, analytical quality control methods,
reporting procedures and dose estimate calculations.
Research and Development Needs
ORP needs to establish an optimum dose calculation model.
The current proposed plan is to contract for this work with another
agency in a cooperative venture.
ORP needs to develop laboratory methods and techniques to
operate a nationwide monitoring program for measurement of specific
radionuclides that could accumulate in the environment over a long-
term period. Specifically, the radionuclides that need to be investi-
gated are: Pu-239, Kr-85, 1-129, the actinium series (Actinium-227),
and H-3 in media other than gas.
Enforcement and Control Requirements
The Office of Radiation Programs does not have any enforce-
ment authority under the present legislation. With increase levels
of radioactivity in the environment resulting from emergencies or
incidents requiring controls, action would be carried out under the
emergency planning procedures developed by State health agencies in
cooperation with the AEC and EPA. The Protective Action Guides of
the FRC are the basis for control. The protection of the health
and safety of the public and the authority to assure this protection
is the responsibility of the State health agencies.
The data from the monitoring program would be provided to the
AEC and the States. These data (by other agencies) could be used
as a basis for control actions by the agencies vested with authority
to take such action.
B-78
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Intgragency Implementation
This information is presented in Table B-8.
ORP Networks
The following networks are managed uy"URP:
o Pasteurized Milk Network (PMN),
o The Institutional Total Diet Sampling Network (ITDSN),
o The Tritium Surveillance System (TSS),
o Pluconium in Airborne Particulates,
o ^°PU in Human Bone Network, and
o Gross Radioactivity in Surface Waters Network.
These networks monitor the environmental radiation trends and
baselines in selected population exposure pathways for specific
radionuclides of reactor origin. The networks, originally designed
to monitor fallout and baseline radiological conditions, are of
limited value in detecting radioactive environmental contamination
from nuclear facilities. They are currently operated as follows.
The samples are collected at no cost by State and local Public
Health Departments, and analyzed at EPA laboratories (EERL and WERL)
with analytical quality control provided by ORP. The data are
collated, evaluated, and published by ORP.
The Quality Assurance Program is discussed in Tab 3.
The relationship of these networks to the need for information
for Protective Action and Episode Evaluation is discussed above.
"The information from these networks is aiso expected to be of value
B-79
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TABLE B-8
INTERAGENCY IMPLEMENTATION
Information Required
Discharge Effluent
Data
•
Nucloar power facility
Fuel Fabrication
AEC - Contractor facilities
Waste Disposal Facility
Nuclear Hospitals
Naval facilities
Fuel Reprocessing
Radioactive Cloud trajectory
Collection of samples for
networks.
Data Processing for the ORP
Surveillance Networks
Analytical Quality Control
Service
Source of
Information
facility .qperators via
AEC, State, or direct
AEC or direct
Naval Reactor Branch
of AEC
AEC, State, or direct
NOAA (AEC)
State and local agencies
PAHO
Canal Zone and U.S. Army
BRH/FDA/DHEW
National Bureau of
Standards (for
primary & secondary
standards)
Existing
Arrangements
Informal
None
Formal
Agreement
Informal/AEC
Inforssal
Agreements with
FDA for milk &
food;
Contracts with
institutions
for bone;
Memo, of agree-
ment with PAHO;
Agreement with
Canal Zone &
Department of
the Army to
monitor arou.id
Sturgis (barge)
Contract
Purchase Agree-
ment
B-80
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TABLE B-8 (Continued)
INTERAGENCY IMPLEMENTATION
Information Required
Radiation Data and Reports
State Contracts
Source of
Information
States
local agencies
Federal agencies
Universities
Private industry
International
State agencies
Existing
Arrangements
Contract
B-81
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In specific areas for all of the needs discussed above. The value
of the information varies from only a part of the data needed for a
radiation pollution index to baseline data that can be used to correct
source monitoring data that is acquired for establishing emission
guidelines. In general, for a specific problem, the data from these
networks are frequently inadequate because the radionuclides of
interest are not monitored, the radionuclides of interest are present
in quantities below minimum detectable levels, the sample acquisition
sites are not designed for the problem, or a combination of these
inadequacies.
Nuclear Facility Surveillance Reports
This source of data is a collation of the data obtained by all
of those agencies that acquire discharge or environmental data
related to nuclear facilities. The effluent data is obtained by
the facility or its contractor and reported to the AEC. The environ-
mental data includes data obtained by the facility, by the State, or
by contractors. The primary purpose of collating this data is to
assess the portion of the population dose that is attributable to
the operation of nuclear facilities. Although this information may
be of value to all of the needs discussed above, the primary needs
currently satisfied by this monitoring activity are for current and
future control of abatement of radiation pollution, effectiveness
of guidelines, benchmark data for models, and program planning. The
shortcomings of this activity, which is just being implemented, are
B-82
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that the information lacks the uniformity provided by quality
assurance and that the specific requirements for the use of this
data have not been thoroughly defined with the potential result
that too much data may be acquired.
EPA Monitoring Programs Not Conducted by ORP
Office of Air Programs (OAP) . The GAP manages the Radiation
Alert Network (RAN), which monitors gross beta radioactivity daily
of airborn particulates on a nationwide basis. At this time, the
primary value of this network to ORP needs is to provide early
warning of wide-spread radioactive contamination from nuclear deton-
ation. This network also measures the status of airborne radioactive
contamination by the method of operation, which requires that samples
with abnormal beta activities by analyzed isotopically. Furthermore,
Pu-239 and Pu-238 activities are routinely determined for selected
stations. Because the value of this network is primarily related to
ORP activities at this time, management of this network may be trans-
ferred to ORP during FY-74.
Office of Water Programs (OWP). The OWP manages the Interstate
Carrier Drinking Water Analysis Program, which samples the water from
interstate public drinking water supplies. The water samples are
analyzed for gross alpha and beta radioactivity and if they exceed
specified limits they are also analyzed for Sr-90 and Ra-226. The
purpose of this network is for the enforcement of Drinking Water
Standards.
B-83
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The OWF also conducts the Radium Monitoring Network, which
monitors gross alpha, gross beta, thorium, Pb-210, Po-210, and
Sr-90 in the surface waters of the Colorado River Basin. The
purpose of this network is to monitor the ambient trends of
radiation pollution from the operation of uranium mills and mines
that discharge their wastes into the Colorado River Basin.
Office of Enforcement and General Counsel (OEGC). The OEGC
includes levels of discharges of radioactive materials in the appli-
cations for discharge permits under the Water Refuse Act Permit
Program. Under current legislation, the OEGC may enforce levels
specified in the Drinking Water Standards.
Other Sources of Monitoring Data
In addition to the above activities, data related to a source
of radiation pollution or to radiation pollution in the environment
are acquired by other agencies. This can be compiled by ORP if it
is of value to ORP problems. Examples include cosmic ray intensities
from the IGSY program, worldwide distribution of specific airborne
radionuclides by the HASL 80th meridian network, State operated
networks, etc. In general, these programs are designed to meet
specific objectives that usually are not the same as ORP objectives
and consequently, this information is not as useful as it could be.
The specific ORP needs that could be satisfied by data taken by
other agencies needs to be specified.
Nonionizing Radiation
The ORP programs in the area of nonionizing radiation are
being developed and parts of the programs are expected to
B-84
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include monitoring activities to determine the status of the ambient
nonionizing radiation environment. These monitoring activities,
which are expected to be developed in FY-73 and implemented in FY-74,
will include:
• Special ORP field studies at selected locations, and
• Assistance to Regional offices in response to specific
regional problems.
Environmental Radiation Monitoring Data
Figure B-3 shows the types of monitoring activities providing
data to ORP, and the automatic data processing system which will
be used to compile, analyze, report the data, and calculate dose.
The output of the data system and the intended uses for the output
show that ORP will be compiling ambient and source monitoring data
which will be used in support of all ORP program areas. The listed
uses for output data lead to the ultimate goal of reduced risks from
population exposure to radiation.
The input data are of two types. The first type is ambient
and source monitoring data generated by national surveillance net-
works and source monitoring programs, both of which are operated in
accordance with EPA/ORP surveillance guides and analytical quality
control programs. The second type of data is the emissions and
auxiliary data which will be used to calculate concentrations of
radionuclides in environmental media needed to predict population
dose and environmental impact.
J-85
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Data sources Include Federal Government agencies and laboratories,
States, industry, and other countries. Ultimately the monitoring pro-
gram will cover the total spectrum of ORP problems, providing source
related radiation exposure data which will support case preparation
and enforcement activities of EPA.
The data management system will process monitoring data and
provide information concerning environmental radiation levels in
air, water, milk, food and other items of interest. The data manage-
ment system will have the capability to selectively retrieve infor-
mation for publication of reports and summaries, determine trends and
long-term buildup, and provide statistics to support analyses.
Selective retrieval will include information for user specified
sites, states and regions. National and worlwide summaries can
also be provided.
Dose models using emissions data and quality controlled
environmental monitoring data will be required to calculate population
dose. The environmental monitoring data will be used to assist in
validating predictions of population dose calculated from emission
data.
The program managers for radiation within EPA will have a firm
technical base for:
• Environmental standards - National and International.
• Environmental impact determination and technology assessment.
In addition current and accurate data on environmental radiation
levels will assist in:
B-86
-------
• Credible public and scientific reporting.
• Alerting to needed population protective action and/or
abatement programs at the State, local and federal level.
Data Management System
The proposed data management system will consist of the contin-
uation of data management computer processing for existing networks
plus the addition of data collection and information retrieval computer
programs for source monitoring data. It is proposed that source moni-
toring and ambient monitoring (Network) data be processed at either
the Bureau of Radiological Health computer facility or processed
within the Water Quality Office's STORE! data management system.
In addition to management of monitoring data, some work in the
area of modeling can be undertaken in FY-73. It is recommended that
specifications for a pathway/exposure model be prepared for Model F
(Table B-9). Because of limitations on funding, actual development
and use of the model must be deferred until FY-74. Concurrently,
the development of a health effects model should be investigated.
Since a model for this purpose probably does not exist in a form
usable by ORP, a program to define the requirements of such a model
for ORP should be established. This program would identify ORP
requirements, establish any R&D requirements, and finally develop
the model specifications. Such a program might be completed in
FY-74 depending upon research requirements. In order to provide
ORP with a pathway/exposure modeling capability, it is recommended
that Model B (Table B-9) be developed in FY-73.
B-87
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TABLE B-9
MODEL SUMMARY
MODEL DESCRIPTION
FACILITY
PRODUCT
PARAMETERS HOWLED
A. RclaClvcly Simple
Single Site Model
BWR
&
PWR
Estimatesdose to critical popu-
lations near oltc from Inhala-
tion & immersion from air path-
way.
Source term, air pnrticulatc. and noble
Kases, site meteorology, and popul.ition
geographic density to calculate concen-
trations and dose.
B. Improved Single Site
Model
I
C. Predictive Single
Site Model
D. Upgraded Predictive
or Nonprcdlctlvc
Single Site Model
E. Large Single Site
Model
F. Large Scale Multi-
Site or Regional
Model
BWR
&
PWR
BWR
&
PWR
BWR
&
PWR
BWR
&
PWR
PWR
&
BUR
Estimates djsc to critical popu-
lations near sice from Inhala-
tion & immersion and direct
radiation from air pathway.
Same as Improved Single Site
Model but modified to include
capability to predict future
buildup and trends.
Same as Improved or Predictive
Site Model but includes water
pathways.
Same as Upgi.ided Predictive
hut ouptit will include con-
centrations resulting from
uptake by crops & animals.
Provides exposure and dose
ciiLinutcs which can be used to
study environmental effects
resulting from more th.m one
facility on a regional basis
such as a river basin in which
more then one facility dis-
clurfM'a. Included would hp a
predictive c.ip.-ibLlity which
would allow ebtinuLio:i of future
cnvironrentul im[UcU. 'lased upon
plans for new facilities. By
aggregating regional effects a
n.itional do:.e estimate would be
ol) talned.
Considers source term air p.trtlculate &
noble gases, 'neteorology, population
geographic density, cloud depletion duo
.to decay, wet and dry deposition, and
direct radiation from clouJ, to calcu-
late concentrations and dose.
Same as Improved Single Site Model with
addition of plant activation products
and terrain effects.
Same as Improved & Predictive Models but
includes consideration of water pathways.
Sciir.e as Upgraded Predictive Model with
addition oi t.ins I deration of food pro-
duction and a.'.rai.iiltur.il methods in
area influenced by the facility.
Model would luve the capability to con-
sider all patiw.iys as required to esti-
mate exposure diid dosr. Meteorology,
hydrology, soiree Urmdata, demographic
data (& inclule living patterns and diets)
agricultural irocmclion methods and food
distribution ;ouid be Included lit models
data base as required to calculate
rciulLs.
-------
In summary, the FY-73 data management program should represent
a continuation of data processing of network data and be expanded to
include source monitoring data. The specifications for a pathway/
exposure model should be developed in FY-73, a program established
to determine ORP requirements for a health effects model, and a
limited pathway/exposure/dose model be developed.
Milestones
The milestone chart for the Proposed Program is presented in
Figure B-12. Proposed Program is based on Programming/Budgetary
Proposals and is developed around the following accomplishment plans:
Date of
Completion
continuing
monthly
continuing
Jan. 1973
April 1973
Plan
1. Conduct ambient monitoring program
including networks to provide data on
environmental radiation levels in air,
milk, water, and food.
2. Publish Radiation Data and Reports
to provide a public record and document
changes- in the environmental radiation
levels.
3. Provide quality assurance
to EPA regional laboratories, States,
utility companies and other licensees
to assure accuracy and reliability of
environmental radiation measurements.
4. Develop and test a nationwide data
system for processing, storing, and
retrieving environmental surveillance
and radiation source data.
5. Prepare technical specifications for
a contract for the development of specific
source nodels for determining population
dose for geographical regions and for tr.e
total United States.
B-89
-------
DIGITALLY
-------
For these five accomplishment plans, the full-time personnel resources
available are:
Networks NERC-LV - 9
Networks EERF - 7
Networks Hqts - 2
Quality Assurance
Program - 7
Reports Branch - 8
Surveillance
Branch - 6
39 - Total
The budget for these plans is shown in Table B-10.
B-92
-------
FY 1973 RESOURCES
Field Operations Division
Title of Organization
Program Element/Protect No.
E.M. Radiation - Hots.
Operation Anal
Surveillance
••••••••••••
Surveillance - EERE
••n^—»
NERC
IMMIMMMB
Total - Monit
1661.9 1150.9
TABLE B-10
MONITORING BUDGET
-------
Text Deleted
B-93
-------
Pages B-95 to
B-100 (inclusive)
have been deleted.
B-95
-------
Optimum and Proposed Data Management Program Differences
The purpose of this section is to describe computer applications
which would support the Office of Radiation Programs activities for
the Optimum Program and the Proposed Program and to indicate the
differences between these applications.
Computer applications for both the optimum and proposed programs
are in a general sense similar. Both include a data management capability
for the storage and retrieval of monitoring and auxiliary data (demo-
graphic data, meteorology, hydrology, site and facility description,
source term, etc.) and environmental modeling programs. The major
differences lie in the capabilities which each would offer to ORP. The
Optimum Program is envisioned as a fully integrated system in which a
generalized data management system would be used as the foundation of a
integrated technical data management and modeling system. The generalized
system with its inherent flexability to retireve information and organized
data files would be used to store and retrieve monitoring and auxiliary
data.
The generalized system would allow users to specify the data they
wish to retrieve, the time period covered, the type of statistics they
might desire for trend type of analysis, and other parameters such as
site and facility information associated with the data retrieval.
Additionally the generalized system would manage the data bases required
for modeling, the storage and output of model results, and the verifica-
tion of model results with field measurements.
In the Proposed Program a generalized data management system would
not be available. Monitoring data would be managed by a series of
-------
relatively simple application programs specifically written for each
ambient or source network. The outputs of these application programs
would be predefined. Only through new computer programming efforts
could they be changed. Thus, the data management of ambient and source
monitoring data would not be integrated nor would the flexibility in
retrieval of data offered by the generalized system be available.
Because of the lack of a generalized system which would integrate
all data, manual processing of outputs of the proposed system would
in many cases be required to arrive at trend data, to correlate data
among the networks and sources, and to arrive at information needed for
problem solution.
In the proposed system the modeling capability would be reduced.
Because of personnel and funding restrictions the models that would
be developed for exposure and dose calculation would be oriented to
single site assessments and less comprehensive in the detail considered
e.g., some pathways which are not critical would not be modeled. A
regional or national level model would not be developed. No data
management system would be available to correlate model results with
monitoring data or manage the data base for the models. These activities
would be done by hand. Figure B-13 shows pictorally the difference in
the concepts of the Optimum Program and the Proposed Program.
Table B-9 shows varying degrees of models that might be developed.
The level of model complexity starts at what might be considered at
almost a zero point and progressively increases in complexity to a
B-102
-------
Ambient (, tw i e
1)J l .1
Aux 1 1 1 ;i i s- r> i t.i ^,
OPTIMUM
PROGRAM
^xfi.it.i :;. in •"!•._ in s\->nii
/ -jf- — y / ~^~~>\
r >i !. .iy \,, ,. •. ui i j
lliu'c 1 /.
P..-.I
. ^ J:uli- ) J
P^l
Lffic Ib ._|
ModM
/
2.
^ ".ii!'i;ii.r ] lift* i i L n»ii
^ T: riid .
!)»>:.*• , 1 , r« HIP, Cf i' ' i
^ t r -it . .
Coi rr l.i ! > il ! f fr c l ' .
(.01 T i ' - 1 • r1 'I, • 1 /
SJL.IIJ f iciint poiiit:., imi.- of c'.itj i.an !j;ci-c .it S/'.LC^I IIIHL- }.•• s niiiuil
data pi c^nrJl i c n, pro.,ici r.in,; et'l'oiLii, |-ii 1>J 1 i L> ctir-
rc'l.ites cuiLpnls; uodi-li arc- cor.iplcs and t lir>roui;u.
KttworV- fita
( V .11 1 1; n t )
Kc-troik
^ftwork >'.^:nlor r..>
I> it .• , (f. i.-. l : t:i
(Ai.nn-
ikoriii,; CIIL.I, prcfl^.-i r-ili tl.n -Icn r -..- *«' J.-i-d : i I'Vts-. :i, - •• il
pr"par.Tt iv •• f»f i .ic't 1 cl.if.i h.iii- : r. L"«U- 't icm p .•'.r.ol^ trn.irin f t r
eacti r.o'Jclit.r; it,n.
FIGURE B-13
COMPARISON OF METHODS IN OPTIMUM AND PROPOSED PROGRAMS
B-103
-------
regional or national environmental model. The intermediate levels are
arbitrarily chosen to illustrate different capabilities. The Optimum
Program would include the national or regional type model and a lesser
modeling capability to study specific problems in detail. In terms of
resources available to SID, model B could be developed during 1973
and placed in operation.
For the Optimum Program model F, the Large Scale Multi-site and
Regional Model and Model D, the Upgraded Prediction or Nonprediction
Sample Site Model are recommended. The development of these models
would require approximately two years at an estimated cost of $400,000.
About $160,000 of the $400,000 would be required for data collection
and reduction. )
Figure B-14 depicts the estimated costs to achieve various data
handling and modeling capabilities for ORP. The abscissa represents
capabilities that could be achieved and the ordinate the estimated cost
to acquire the different capabilities. Also shown for comparative
purposes are the costs if all data handling and modeling were done by
hand.
The Proposed Program, unless supported in FY 1974 with additional
funds, will provide only minimum support to the Systematic Radiation
Strategy. Adequate models to calculate pathway dispersion, calculate
environmental concentrations, and calculate exposure and dose will not
be available. Similarly, no model for health effects will be available;
hence, the effectiveness of control programs, measurement of progress
of attainment of ORP goals, and a comprehensive assessment of the radio-
.logical environmental status will be difficult. Because there will be
-------
400
350
300
250
-? 200
•o
e
150
100
50
I I I II II I MANUAL PROCESSING
PROCESSING BY COMPUTER
19 or more additional
personnel
a'a
III
E . o
i>
16 Additional personnel
14 Additional personnel
\ - . I I I I I
I I I It-
I I I li'
12 Additional personnel
8 Additional personnel
N. @ $10k ea.
4 Additional personnel--
@ $10kaa-v | I I I I
ONE TIME MODEL DEVELOPMENT COSTS
CAPABILITIES
Present Capability
Proposed Data Management & Model A
Proposed Data Management & Model B
Proposed Data Management & Model C
5) Proposed Da,ta Management & Model D
>r
6) Proposed Data Management & Model E
s<
7) Proposed Data Management & Model F
FIGURE. B-14
COST VERSUS CAPABILITY FOR DATA MANAGEMENT AND ANALYSIS
B-105
-------
no generalized data management system in the proposed program, data
selection and retrieval capabilities will be limited. Additionally, the
correlation of monitoring data and modeling results must be accomplished
by hand.
In order to support the systematic strategy, the Proposed Program
will require additional funding in FY 1974 and possibly additional data
processing personnel.
MEASURES OF GOAL ATTAINMENT
The goal of monitoring is to provide sufficiently comprehensive and
quality data to calculate population radiation dose in support of environ-
mental impact reviews, standards development, health risk assessment,
program policy decisions and to provide a technical basis for assessing
the 18 problem areas defined for the Office of Radiation Programs. A
measurement of the goal attainment will be determined by the adequacy of
monitoring data to support all of these functions.
Monitoring data will provide a measure of goal attainment for other
ORP problem areas and generic functions. Figure B-15 summarizes the esti-
mated annual average whole body radiation dose to individuals in the United
States from the major sources of exposure. The estimated dose curves in
this figure were developed by the ORP Special Studies Group based primarily
on literature research. Monitoring data will permit refinement and pro-
jection of these curves to determine areas where population dose can be
controlled or reduced most effectively. Goal attainment will also be
B-106
-------
100-
Total
Natural
Medical
10-
Global Fallout
Miscellaneous
Occupational
Other
Environmental
0.1 .
1960
1970
1980
1990
2000
FIGURE B-15
FORECAST AVERAGE WHOLE BODY RADIATION DOSE IN THE U. S,
'B-107
-------
measured by the availability of monitoring data to make those projections
and determinations.
The following is a discussion from the Special Studies Report of
the data presented in Figure B-15.
Environmental Radiation
A major source of radiation doses in the United States is natural
radiation. The total estimated annual whole-body dose increases from
23.8 million man-rem in 1960 to 41.7 million man-rem in the year 2000 from
cosmic and natural terrestrial sources. The increase is due exclusively
to increases in population size. Global fallout from nuclear explosives
tests contributed about 1 million man-rem (whole-body) in 1960, a high
of 2.4 million man-rem in 1963, and 0.8 million man-rem in 1970. Future
doses from fallout for 1980 are predicted to be 1.1 million man-rem,
increasing to 1.6 man-rem in 2000, the increase again being due to popula-
tion growth. The total dose contributed by all other environmental sources
increases from 0.015 million man-rem in 1960 to 0.15 million man-rem in
2000.
Medical Radiation
By far the greatest portion of the dose, to the United States popula-
tion from the use of radiation in the healing arts is due to medical
radiography, dental radiography contributing a negligible quantity. The
whole-body man-rem dose from diagnostic medical radiography in 1970 is
estimated to be 21.1 million man-rem, while that from dental radiography
is less than 0.05 million man-rem. It is assumed that the magnitude of
the gonad dose is the best presently available measure of the magnitude
B-108
-------
of the whole-body dose. In addition, the diagnostic use of radiopharma-
ceuticals is estimated to have contributed a somatic dose of 0.4 million
man-rem in 1970.
Occupational Radiation
The contribution of occupational exposures to total United States
per capita dose is estimated to be less than 1 man-rem/year. The major
portion of this dose during 1960 and 1970 was incurred through the use
of ionizing radiation in the practice of medicine and dentistry.
Increased industrial use of ionizing radiation, particularly the
projected increase in nuclear power production, will increase the per
capita dose by approximately 0.1 man-rem/year by 1990. During the 1990's
the population dose from industrial sources and the practice of medicine
and dentistry will probably be about the same. The total dose from
occupational exposure to the United States population is estimated to
have been 0.14 million man-rem in 1960 and is projected to reach 0.28
million man-rem in the year 2000.
Miscellaneous Radiation
Miscellaneous radiation sources (e.g., television, consumer products,
and air transport) contribute to the radiation dose of the population of
the United.States. Estimated annual average whole-body doses to the
population are 2.0 and 2.6 man-rem (0.36 million and 0.55 million man-
rem) for 1960 and 1970, respectively. Projected annual doses are 2.1
man-rem (0.51 million man-rem) for 1980 and 1.1 man-rem (0.32 million
and 0.36 million man-rem) for 1990 and 2000.
B-109
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Page Deleted.
B-110
-------
TAB 1
INTERACTION WITH THE OCF
Introduction
The Office of Categorical Programs (OCP) will provide planning and
program guidance for monitoring the toxic and hazardous pollutants
(including radiation and pesticides) for which it is responsible, except
for monitoring which can be done by air or water ambient/source monitor-
ing. In the latter.case, OCP will submit its requirements to GAP and OWP
for incorporation in the consolidated guidance.
Within ORP, monitoring programs are organized and coordinated
primarily in the Field Operations Division (formerly the Surveillance
and Inspection Division) whose functions are stated below:
Field Operations Division
The Field Operations Division, under the supervision of a Director:
is responsible for a national program for obtaining baseline data on the
levels of existing environmental radiation; determines any change occurring
in the radiological quality of the environment, the magnitude of this
change, and the nature and probable source of the contaminant; provides
data for estimating population exposure to ionizing and nonionizlng
radiation; determines if environmental levels are within established
radiological guidelines and standards; assists in evaluation of the
effectiveness of existing control programs; publishes environmental
radiological quality data from Federal, State, and facility surveillance
programs; establishes requirements for analytical quality control services
to assure compatibility and reliability of the data from the various
participating laboratories, provides consultation and technical assistance
on surveillance activities to State and other Federal agencies.
B-lll
-------
Surveillance Branch
The Surveillance Branch conducts continuing systematic studies of
the environment to determine if changes of public health significance
have occurred in its radiological characteristics, and ascertains the
magnitude of the change and the specific nature of the contaminant and
operates surveillance networks to provide information for the assess-
ment of population radiation exposure. The Surveillance Branch also:
(a) coordinates surveillance to detect environmental radioactivity
resulting from device tests or other peaceful uses of nuclear energy;
(b) develops surveillance methodology oriented towards improvement of
surveillance operations to provide better data for assessment of
population exposure; (c) conducts and coordinates special studies in
the general area of the measurement and distribution of environmental
radioactivity; and (d) provides technical assistance to State and Federal
agencies and the public and private organizations which plan and develop
protection action to reduce or prevent environmental contamination and
radiation exposure of people.
Field Studies Branch
The Field Studies Branch conducts field studies at operating nuclear
facilities to investigate the mechanisms for production, release, and
disposal of radionuclides in the environment. The Field Studies Branch:
(a) measures the movement of radionuclides through environmental media
to determine the concentration factors and effects of chemical state;
(b) develops and tests radiation detection equipment to identify and
quantify radionuclide discharges from nuclear facilities; (c) conducts
B-112
-------
special studies at selected nuclear facilities to obtain data to evaluate
the facility's operational performance to determine if it meets the
discharge criteria and environmental radiation protection guides;
(d) provides Analytical Quality Control Services to Federal and State
agencies and to nuclear facility operators.
Operations Analysis Branch
The Operations Analysis Branch plans and conducts technical evalua-
tions and field studies to determine if discharges of radioactive material
from operating nuclear facilities are within ORP's environmental radiation
protection standards. The Operations Analysis Branch also; (a) evaluates
the effluent discharges by operating nuclear facilities and users of
radioactive materials; (b) obtains environmental samples from critical
exposure pathways, and analyses them for biologically significant radio-
nuclides; (c) provides program management for projects to obtain indepen-
dent data as an input into the National Environmental Radiation Monitoring
Program, thus assuring validity and compatibility of surveillance and
monitoring information; and (d) evaluates potential consequences of
various radiation accidents and recommends protective actions.
Electromagnetic Radiation Analysis Branch
This branch is responsible for developing and implementing the
nonionizing radiation program within ORP. The Branch identifies problem
areas resulting from nonionizing radiation sources in the environment
and assesses the impact of these sources on human health and the environ-
ment. The Branch also: (a) conducts studies to determine and evaluate
B-113
-------
environmental levels of nonionizing electromagnetic radiation sources;
(b) develops and maintains the capability to monitor nonionizing electro-
magnetic radiation sources; (c) provides information for standards
development; and (d) provides direct technical support for other functions
of ORP's Divisions as related to nonionizing electromagnetic radiation.
From information collected and analyzed, the Branch recommends priority
areas and goals for continuing nonionizing radiation program emphasis
so that appropriate resources may be allocated to ensure adequate
protection of human health and the environment.
Reports Branch
The Reports Branch publishes monthly Radiation Data and Reports;
reviews Field Operation abstracts and manuscripts; prepares special
radiation reports as required; and maintains a national data bank of
information on environmental radiation levels from all sources.
B-114
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TAB 2
VALUE AND COST OF MONITORING
Description of Monitoring Activites
Monitoring Components
• Ambient Trend Monitoring
• Protective Action Capability
• Special Studies (model development, in-depth studies of
problems, in-depth studies of discharges four setting
effluent standards, supplementary information for
evaluation of Environmental Impact Statements)
• Field Studies (problem definition, effectiveness of
specific standards)
• Supporting Functions (AQCS, publication of Radiation Data
and Reports, IRAP, coordination of development of emergency
plans).
Requirements for Monitoring
Management Needs
• Program planning and policy guidance,
• Radiation Pollution Indices for a measure of goal
attainment,
• Control of pollution abatement (feedback), and
• Effectiveness of standards or guidelines.
Management needs for monitoring can be met by a combination of
monitoring source data, which provides information (activity, population
dose rate, and risk) as a function of class of sources, and pathway or
environmental data monitoring which provides information (activity,
population dose rate, and risk) as a function of class of source, and
monitoring pathway or environmental data, which provides information
(activity, population dose rate, and risk) as a function of radionuclides,
B-115
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Ambient trend monitoring provides the past, current, and with the help
of technical forecasting, future status of radiation pollution in the
environment. Monitoring of pathway data is required in addition to
monitoring source discharges because (a) the risks from radiation pollu-
tants are synergistic (the total risk is greater than the sum of the
risks of each pollutant) and (b) monitoring source discharge data alone
cannot address all of the sources of radiation in the environment
(notable exceptions include natural background, accelerator produced
isotopes, natural sources of radiation, and miscellaneous sources).
Protective Action. EPA/ORP is responsible for maintaining a
capability to evaluate the need and to provide early warning of the
need for protective action following large scale episodes such as
fallout, particularly from foreign weapons testing, which is not under
control of the Federal government.
Environmental Radiation Standards and International Agreements.
Ambient trend monitoring also provides data and information that is of
use for establishing Environmental Radiation Standards and of use for
negotiating and implementing international agreements.
Multiple Sources and Synergistic Effects. Source and ambient trend
monitoring is useful for identifying areas in the environment that may
be the point of impact of multiple sources of radiation plus other
pollutants.
Congressional and Public Information. The aggregation of all moni-
toring activities will be of interest to Congress and the public, however,
monitoring efforts should not be designed to cope with all potential
requests for information.
B-116
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Table B-ll shows the requirements for monitoring, the weight of
each requirements and the type of monitoring that fulfills the require-
ment.
Information Derived from Monitoring Data
Figures B-16 and B-17 show the transformation of monitoring data
from sources and pathways to information. Figure B-18 is a generalized
illustration of the information that is derivable from the ambient
trend monitoring program.
Scope
The dimensions of monitoring include geographical scope, range of
sources, range of radionuclides, and range of media or pathways.
1. Present
The present scope of ambient trend monitoring is shown in
Table B-12.
2. Future
The future scope will be the present scope plus increased
emphasis on noble gases, long-lived radionuclides, and
radionuclides from the use of plutonium, also increased of
sources in monitoring specific ionizing radiation problem
i
areas (waste disposal, Pu-fabrication and operation, accidents,
and transportation).
Alternative Approaches
Sample Analysis and Acquisition Alternatives
Although some of the monitoring requirements must be defined after
development of requirements relative to ORP problem areas, there are
B-ll 7
-------
TABLE B-ll
REQUIREMENTS FOR MONITORING DATA
Type of
Monitoring
Data
Weight of
Requirement
a. Management
1. Program Planning
Ambient Trend
Monitoring derived
from:
a. pathway of
environmental
data
b. source effluent
data
plus models.
2.0
b. Protective
Action
Early warning of
large scale
incidents (RAN
Network)
Capability for
ambient monitor-
ing after inci-
dent.
1.0
c. Environmental
Radiation
Standards
d. International
Agreements
Ambient Trend
Monitoring
0.8
e. Multiple
Source Impact
f. Synergistic
Effects
Identification by
analysis of Ambient
Trend Monitoring
Information.
0.7
g. Other
1. Effluent stds.
2. EIS Evaluation
3. Model Develop-
ment
Special Studies
1.5
00
-------
SOURCES
.DISCHARGES
ENVIRONMENT
PATHWAYS
(critical)
MAN
vo
Specific
Identified •
Sources
F.I 1 lout
B-ickground
Accelerator
Prod. Isotopes
Njtural1
K-idioactive
Sources
Miscellaneous
Radiant
Source
Monitoring
Data
EXPOSURE
EFFECTS
Environmental Pathway
Monitoring Monitoring
Data Data
Residual
Monitoring
Data
FIGURE B-16
IONIZING RADIATION POLLUTION FLOW CHART
-------
DATA
(current
stalus)
COMPUTi-.R
MODELS
SOURCE
MONITORING
DATA
AUXILLAK
DATA
ENVIRON.
MON.
DATA
TRANSPORT MODEL
(source to environment}
M
o
FOREC.'-STS
(futui «.•
AUXILIARY
DATA
PATHWAY
MON.
DATA
PATHWAY MODEL
(environ, to
man)
AUX,
DMA
ESIDUAL
MON.'
DATA
POPULATION
EXPOSURE
MODEL
SOURCE
FORECASTS
(future
trends)
UJXILLARY
DATA
EFFECTS
MODEL
(impact)
RISK
ANALYSIS
FORECASTS
TREND ANALYSIS.
INFOR: \TSON
a.
b. r.tJionuclide
c. ft.; ion
d. p.iLhways
c. a; j i (.gates
TRENDS OF
RADIATION
POLLUTION
KRENDS OF
POPULATION
• EXPOSURE
TRENDS OF
RISKS
FIGURE B-17
IONIZING RADIATION - AMBIENT TREND MONITORING INFORMATION FLOW CHART
-------
I
I-
Ni
III!
§:.
*•'
[Natijorial;
1
•[Pathw£
l Pathways') * [All -
| . i - . . •
. ::•}.,;::
Radionuclides J :«-i — [Sour<^esj-p— --7—r~ •
I
;:< NOTE:
IL Pr«dlcted Trend =
|!i Extrapolated Trend
;'; + Adjustments for growth
r - Adjustments for improved control ;
:.- Sources ]H[N
111:
ational- Moderj
FIGURE B-18
TEMPORAL STATUS OF RADIATION POLLUTION - GENERAL ILLUSTRATION
-------
TABLE B-12
PRESENT SCOPE OF AMBIENT TREND MONITORING ACTIVITIES
f
H
to
Type of
Monitoring
Data
Pathway or
Environmental
Data
Source Data
i
SCOPE
licograpnica i
or
Source class
National
Regiona 1
*Problem
Areas
(ion. rad.)
Background
Other
«.
Pathway or Media
AIR
RAN
Pu (RAN)
Nuclear
facility
rep's.
WATER
3H, f.p.
Pu
Nuclear
facility
rep's.
JH, Ra
MILK
f.p.
X
•
K
FOOD
f.p.
X
Ra, K
-------
presently several sets of alternatives that can be considered and that
are generally applicable to the design of the future QRP monitoring
system.
The quality of the,data obtained versus the cost can be examined
for various alternatives of sample acquisition and sample analysis.
Alternatives for sample acquisition include contractors, EPA regional
offices, ORP Support Facilities, or non-ORP facilities (States, other
Federal agencies, other EPA program offices, etc.). Alternatives for
sample analysis are the same as for sample acquisition.
Table B-13 shows the total cost of sample acquisition and analysis
as a function of these alternatives for a specific network. The maximum
cost of data acquisition is assumed to be "a" dollars/sample (written
$a/sample) for acquisition by contract and an estimate of the fraction
of this cost has been made for the alternatives for sample acquisition.
Similarly, a maximum cost of "b" dollars/ sample (written $b/sample) is
assumed for analysis by contract. In adjusting the scaling factors,
some consideration was given to changes in the cost of data management.
Averaged over a large program, the cost of sample acquisition is
usually about equal to the cost of sample analysis (this is generally
not true for a specific network). Consequently, in Table B-13, "a" can
be set equal to "b" and a/20 can be neglected in the first column of
Table B-13. In order to obtain a quality to cost ratio for the alter-
natives of sample acquisition and analysis, the quality of the analyses
by ORP support facilities has been assigned a value of "q" and an arbitrary
B-123
-------
TABLE B-13
COST OF SAMPLE ACQUISITION
(in Multiples of $a/sample)
PLUS COST OF SAMPLE ANALYSIS
(in Multiples of $b/analysis) versus FACILITY
Sample
Analysis
(Cost)
Non-ORP
($0)
EPA labs/
ORP Sup. Fac.
($3b/4)
EPA Reg.
Labs*
($b)
Contractors
($b)
Sample Acquisition (Cos
Non-ORP
($a/20)
$aV20
3b/4
+a/20
b+a/20
b+a/20
ORP Sup.
Fac.($3a/4)
N/A**
(a+b)3/4
b+3a/4
b+3a/4
EPA Reg.
Off.($3a/4)
N/A
(a+b)3/4
b+3a/4
b+3a/4
)
Contractors
($a)
N/A
a+3b/4
a+b
a+b
**
Assuming that each regional laboratory has a need for radionuclide
analysis from non-ORP programs that supports equipment and at least
1-FTP. Otherwise, the analysis costs for ORP programs alone are
too high for analysis by regional laboratories.
,k
NA - Not applicable because samples acquired by EPA are not likely
to be analyzed by a state or local agency.
B-124
-------
quality scaling factor has been assigned to the other alternatives. The
resulting quality/cost ratio as a multiple of the ratio q/a is shown in
Table B-14 for the various alternatives.
Although the scaling factors are arbitrary, some general conclu-
sions can be derived from Table B-14. The highest quality/cost ratio is
for those networks that are conducted by others with no direct costs
to ORP, consequently if they are effective relative to the monitoring
requirements, they should be used when possible. Presumably, networks
that are designed by ORP will be effective in meeting the ORP monitoring
requirements; consequently, the values in Table B-14 except for the
first line (analysis by non-ORP) , can be regarded as a measure of cost-
effectiveness. In general, the best network is one in which the samples
are acquired at no cost by non-ORP agencies with sample analysis by
ORP support facilities under tight quality control. Other alternatives
are less cost-effective primarily because of either greater direct cost
or greater indirect.- costs because of more cost for quality control and/or
data management.
Other Alternatives
The costs versus the estimated values of current monitoring activities
that are related to specific problem areas are listed in Table B-15. The
estimated values are estimated relative to the value of the problem weight.
The estimated costs and values of adnustments to the current (FY 1973) level
of activity are also shown in Table B-15. The results for each problem
area are plotted in Figure B-19. The sum of these curves are plotted in
Figure B-20. The value of current monitoring activities are indicated on
each figure.
B-125
-------
TABLE B-14
QUALITY/COST RATIO*
(in Multiples of q/a=quality/$cost)
VERSUS SAMPLE ACQUISITION AND SAMPLE ANALYSIS FACILITY
Sample
Analysis
(Quality)
Non-ORP
(q/4)
EPA labs/
ORP Sup.
Fac. (q)
EPA Reg.
Labs.
(3 q/4)
Contractors
(3 q/4)
SAMPLE ACQUISITION
Non-ORP
5 q/a
1.33 q/a
.75 q/a
.75 q/a
ORP Sup. Fac.
N/A
.67 q/a
.43 q/a
.43 q/a
EPA Reg. Off.
N/A
.67 q/a
.43 q/a
.43 q/a
Contractors
N/A
.57 q/a
.375 q/a
.375 q/a
The costs are taken from Table B-13 and the cost of analysis is
assumed to be equal to cost of sample acquisition (i.e., a=b) which
is about true for a set of networks but is not usually true for a
specific network.
B-126
-------
TABLE B-15
NETWORK MONITORING VALUE VS. COST (FY 1973 - FY 1974)
COST/VALUE OF CURRENT MONITORING OF SOURCES
Problem Area
Fallout Mon.
Oper-U
Mining & Mill
Tailings
3
H - Thermo.
Pu - Fab. +
Pu - Oper.
TOTAL
PROGRAM
Network Level
FY 1973
RAN + others +
Milk (capability
- $100)
Nuc. Fac. Rep's.
only above + H +
Bone=FY-73
FY-73 + state contracts
Water (Ra) = FY-73
External to all men
3H (oper-U) = FY-73
Expanded H
RAN (Pu) _ 7.
Bone (Pu)
above + reports
above soil
Value
V max.
v
V2
V
max.
V3
V,
V5
V
ins Y
ilia A •
V6
V7
V
max.
V8
V9
max.
V10
V12
V
max.
Vn
= 5
= 4
= 3.5
= 3.6
= 2.2
= 2.7
= 3.2
= 1.2
= .8
= 1.0
= 6
= 2
= 4
= 8.05
= 2.5
= 3.0
= 5.0
= 23.85
= 11.5
Cost
yn a v
UlCfc A •
D2
C3
C4
C5
C6
C7
C8
C9
C10
4
C
max.
C
—
= $430K
= $330K
= $110K
= 160K
= 360K
= $ 20K
= 60K
= $ 25K
= 80K
= $ 65K
80K
= $180K
=
= $700K
B-127
-------
L_3_.j:. ;r- Ju ' '' "'" ; "
E ElEEEElt
Mining and. Mill Tailings
100
200
300
400
500
600
700
FIGURE B-19
COST-VALUE ANALYSIS OF RADIATION PROGRAMS
B-128
-------
321~-.
,. .. I . __ -_
!_-,.»[
[— .-r-^-., .....
..; .___..•-..._.,
!
' r"-I% L"~'..J
.... : . ...
IT . 1 ..:. ,
•-.::.:-:::.•:.:•
. . -,
... :... |. .
-_ ,
1
•-•_--(-;; I - r -
•-;-;-
..!......_„
. __.. _|
X"
>. ^
• . - .-
*
--:-:^^--^:
:>"• j
Current program_^TFY-:73
M
: _
i , • • i , , ; .
.. — .-H _
r.
— 1 1
:; . 1 ;|
i 1 1
grr
1
| j j —
i . i i_
400
800
1,200 1,600 2,000 2,400
FIGURE B-20
COST-VALUE ANALYSIS OF OPTIMUM PROGRAMS
B-129
-------
A curve to illustrate the cost/value relation for current monitoring
activities plus additional activities in those problem areas that
currently are not being monitored is shown as a dashed line in Figure
B-21.
The following adjustments could lead to a more cost-effective
monitoring program:
a. adjust effort in networks directed towards fallout to maintain
capability level,
b. increase effort in other networks, and
c. add additional monitoring activities for problem areas not
currently monitored.
B-130
-------
TAB 3
NATIONAL QUALITY CONTROL PROGRAM
Current Programs
The Analytical Quality Control Program provides radiochemical
standards and quality control for analytical and radiation measurements
to the EPA laboratories and State radiological health programs in
connection with measurement of radioactivity in environmental samples
as a result of radioactive fallout. Because of the increased use of
power reactors, this program has been redirected to provide services
to evaluate the quality of the environmental radiation surveillance
data obtained by Federal and State agencies and utility companies and/
or their contractors in the vicinity of operating nuclear facilities.
It has also been extended to assure that the data resulting from the
reporting requirements under the AEC Safety Guide 21 are of sufficient
quality so that they may be used for estimating population dose.
Participation in these programs by the nuclear facilities or their
contractors is expected to increase significantly in the future. In
order to perform this program the Analytical Quality Control Serivce
(AQCS) operates several types of cross-check programs for the analysis
of radionuclides in environmental media such as milk, food, water, air,
and soil. The purpose of these cross-check programs is to enable these
laboratories in the field of radiation to assure the quality of their
data.
B-131
-------
Water Program
The water program was originally designed to crosscheck water samples
received from the interstate carrier water program. The nuclides of
interest at that time were gross alpha and beta measurements, strontium-90,
and radium-226. With the advent of the nuclear reactors, tritium was
added to the nuclides. This program has expanded rapidly during the
past year in that participants, such as States, nuclear facility operators,
9
national radiation laboratories, and so forth, need to assure themselves
that their data meet the established criteria. The samples are submitted
on a bi-monthly basis and reported immediately to the laboratories upon
receipt of their data so that they may make corrections when necessary.
The Water Program also includes a sample for the analysis of gamma
emitters usually found from reactor effluents. The radionuclides presently
included in this program are cesium-134, cesium-137, cobalt-58, cobalt-60,
and zinc-65. Other nuclides such as chromium-51, ruthenium-103 or 106,
and cerium-141 and others will be added in the near future. Mock reactor
solutions containing these nuclides plus others, such as manganese-54,
iron-59, and yttrium-88, will also be submitted. These mock solutions
will be submitted to the participants in a routine program and as possible
technical experiments.
A tritium technical experiment is normally conducted annually. In
addition to the routine participants, other agencies, such as hospitals,
private laboratories, and so forth, participate. This technical experi-
ment enables the participants to evaluate the methods and instrumentation
used in their analyses. It normally carries a critical level of radio-
activity and includes a biological sample.
B-132
-------
Milk Cross-Check Program
The milk cross-check program provides quality assurance for results
obtained from the National Environmental Radiation Monitoring Program.
The samples are submitted on a monthly, bi-monthly, or quarterly basis
depending upon the needs of the participating laboratories. The analyses
requested for this program are cesium-137, barium-140, iodine-131,
strontium-89, and strontium-90. These are the nuclides normally found
in milk from fallout or from reactors. In addition, a technical experi-
ment is conducted annually in order to provide assurance to those labor-
atories not normally participating on a routine basis so that their data
may also be evaluated. This technical experiment also provides further
input into the operation of each laboratory by allowing them to assess
the operational condition of their equipment and their methology.
Food Cross-Check Program
The food cross-check program was designed to augment the nationwide
institutional diet network program. The samples are sent out on a
quarterly basis and consists of synthetic foods made up and spiked
similar to the milk samples. While it still serves this purpose, it
also enables the States and utility companies to assess the environmental
media in a form of foodstuffs which are obtained from surveillance
points around these nuclear facilities. The nuclides of interest are
similar to milk with the addition of manganese-54, zinc-65, and zirconium-
niobium-95. These are normally found in fallout also.
B-133
-------
Soil Samples
Soil samples are distributed on a triannual basis. The radionuclides
of interest are similar to those of the water gamma sample. In addition
these samples contain naturally occurring radium and thorium; however,
we normally send out background samples so that these two interfering
nuclides may be eliminated in the analysis.
Plutonium Environmental Samples
The plutonium environmental samples are sent out to the EPA labora-
tories and selected State and Federal laboratories. The plutonium samples
consist of a synthetic sea water sample, a soil sample in which the
plutonium has been oxidized, and an air filter sample. These are distri-
buted on a bi-monthly basis with each environmental media being distri-
buted three times a year.
New and Projected Programs
Gaseous Analyses
The first cross-check krypton-85 sample was sent out in January
1972. This sample served a dual purpose. It was a krypton-85 standard
carried on natural krypton gas containing environmental levels of krypton.
This sample served as both a krypton-85 gas standard and cross-check
sample. The sample was sent to the Western Environmental Research
Laboratory, Eastern Environmental Radiation Laboratory, Radiochemistry
and Nuclear Engineering Laboratory, New York State Health Department,
and the SID Field Operations Branch at Winchester.
Presently an economically feasible container is being developed for
distribution to the utility companies and State Health Departments that
B-134
-------
have requirements for measurement of krypton-85. This program will
consist of environmental krypton-85 and krypton-85 effluent from nuclear
reactors. The former type will be for those laboratories having the
capability of handling the krypton-85 for either liquid scintillation
or gaseous counting. The latter type will permit tha utility companies
and other participating laboratories to perform gamma analyses for
krypton-85.
The cross-check sample for xenon-133 gases is in the preliminary
stages. The sample has been obtained and standardized. It is being
distributed to selected participants prior to being submitted as a
cross-check sample. The container used for krypton-85 cross-check
program will also be employed for the xenon gas cross-check program.
w«rlP.ar Facilities Discharge Effluent Cross-Check Program
The levels for the offsite nuclear facilities surveillance programs
present no problem since they are in the same range as the previous fall-
out samples. The discharge effluent type samples within the nuclear
facilities are at a much higher level. A study of this problem is being
undertaken and is being integrated into the Quality Assurance Program.
Radionuclide Distribution and Calibration Program
Radionuclide Distributions
The Quality Assurance Program distributes low-level radioactive
standards in order to augment its cross-check program. These levels
are in a magnitude of 25,000 - 100,000 dpm per gram solution with
an accuracy of 1 to 2 percent at a 2-sigma level. Since these low-
level nuclides are not commercially available, the QAP has been providing
B-135
-------
these standards to the participants of its cross-check programs in order
that they may be able to calibrate their equipment prior to receiving
samples for analysis. The utility companies and/or their contractors
are also supplied these nuclides so that they may also meet the criteria
established by the QAP for cross-check samples. The standards that are
available commercially are of a magnitude of 10 or higher and it has
been found that many mistakes have been made through dilutions of these
higher level standards resulting in poor calibration of equipment and
poor standardization of their methodology.
The EPA laboratories are provided with certain nuclides which are
short-lived and are not normally carried in their stock.
Calibration Services
The calibration services are maintained in order to assure the
accuracy and precision of dilutions made from the higher level standards
received from commercial suppliers. In addition, short-lived nuclides,
which are not available commercially, may also be standardized.
Reference calibration of gamma standards by sodium iodide detectors
is made by QAP to insure the integrity of the dilutions and the accuracy
of the purchased standards. Standards are gamma scanned for radiochemical
impurities either on sodium iodide or on germanium-lithium drifted crystal
detectors. Primary standardization is performed on 4-pi alpha and beta
counters for alpha and beta standards, respectively. Secondary standard-
ization or comparative counting is also performed on sodium iodide crystals
by QAP on short-lived radionuclides, such as iodine-131 and barium-140.
The QAP has recognized that the National Bureau of Standards is the
B-136
-------
Federal agency with the responsibility for providing primary standards
•
to users for a reasonable fee. As a result, QAF will use the NBS as
its source for radionuclides when they are available, and it is also
in the process of establishing traceability to NBS.
State Participants
Relation with States
Presently there are 27 States participating in the QAP cross-check
programs. A total of 39 are also included in the radionuclide distribu-
tion program. They are also provided upon request with technical assist-
ance in the area of quality control. The cross-check programs are designed
to fit the needs of the State laboratories in that the range of environ-
mental media covered and radionuclides found are suited for analyses
from surveillance around nuclear facilities and from fallout where back-
ground levels are determined prior to the operation of proposed nuclear
facilities.
Technical Assistance
The QAP offers a followup service to the States participating in
the cross-check program or in a technical experiment. Whenever a
laboratory exceeds the prescribed control limits, the QAP will contact
them. If the laboratory feels that it needs technical assistance either
in calibration, radiochemistry, or methodology, it should contact the
EPA Regional Radiation Representative. The EPA Regional Radiation
Representative will consult the QAP or one of the EPA area laboratories
to obtain assistance for the State laboratory.
B-137
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Utility Companies
The QAP maintains liaison with the utility companies in the operation
of their environmental radiation programs around reactors either with
the company itself or with their designated contractors. Four utility
companies take part in the QAP cross-check program. Presently there are
eight contractors taking part in the nuclear cross-check program. Between
the four utility companies and the eight contractors, all of the operating
reactors now take part in one or more of the programs. In addition, we
have provided 16 utility companies with standards for internal calibration.
It is proposed to eventually conduct a program to assure the data from
within the plant.
Collaborative Studies
In order for the QAP to properly carry out its mission and to remain
in the forefront of radiation quality control, it is necessary for the
program to assist in the development and promulgation of standard
methods. The QAP assists the societies in this area by conducting
round-robin testing of methods for the acceptance by the societies. The
QAP assists the following societies: American Society for Testing
Materials, American Public Health Association, and Association of
Official Analytical Chemists. Through these societies, the QAP maintains
contacts with other private laboratories, universities, and other Federal
agencies. The Office of Monitoring has recently recognized QAP as the
primary program to carry out method standardization for the EPA in
radiation.
B-138
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TAB 4
RELATIVE COST OF RADIATION MONITORING
Total annual gross national product of approximately $1,000 billion
is seven orders of magnitude higher than the $200,000, which approximately
represents the minimum probable costs of care or claims for one radiation
related injury or death. The prevention of a claim or a delay in the
occurence of a radiation related illness, injury or death on no more than
three occasions would equal the cost of the current monitoring networks
and the radiation data and reporting activities of the Office of Radiation
Programs. The cost of surveillance for 25 power reactors in accordance
with the minimum program recommended in current guidance of the Environ-
mental Protection Agency's Office of Radiation Programs is approximately
$1.25 million. The approximate current annual cost for State environmen-
tal activities is $4.5 million. These are activities within the health
departments and within environmental agencies in the States. Whereas
this cost may not be evenly distributed at this time, it does represent
the total costs in these areas for the States that are actively involved
in environmental radiation protection programs.
A proposed program to modernize and standardize the State radiation
data reporting systems would cost $20 million. It represents the first
proposal beyond the current system of monitoring. This would involve
improved instrumentation and data handling equipment for 50 States. This
would allow ORP to complement the existing Federally operated networks
and data reporting systems with source related monitoring data through the
B-139
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regional offices from the States on a national basis and subject to
quality requirements established by the Office of Radiation Programs.
The annual operating costs for a full EPA data collation and moni-
toring coordination program are approximately $50 million. This would
include provisions for the collection of existing data subject to quality
control requirements. Federal and State agencies would utilize the
data in the dose model along with emission and modeling data to calculate
the status of environmental radiation exposure in the United States.
This would be the stopping point for planning purposes before we would
move to the Total Radiation Monitoring and Control Systems (TRMCS) at
the capital cost of $6 billion and TKMCS operating at a level of $600
million annually. This would be the ideal and complete system embodying
a totally representative picture of the emissions from all sources,
real-time estimates of emissions from sources with provision for control
of resources if standards were exceeded. The system would include a
totally representative ambient monitoring system for air, water, food,
streams, diet, soil, capable of providing a long-term and continuing
indication of the impact of radiation sources on the environment with
no further "controls" required. The system would also provide a totally
representative indication of human dose on a real-time basis by location
of the individual and distribution of individuals in terms of the source
of dose to the individual and the character of the dose (i.e., whether
it is a krypton or inhalation exposure or radium-bone-dose exposure or
X-ray exposure). Finally, the system would read out to States, regions,
B-140
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and at headquarters the current radiation exposure situation nationally
and internationally with all of the basic technical information required
for the use of radiation sources safely and in accordance with standards
nationally. As an indication of the output from the ultimate monitoring
system, Figure B-21 is indicative of what could be produced by the systems
planned. The monitoring guide for plutonium will be produced by the
systems and would report on the current worldwide inventory for such
things as the amount of plutonium in space, or lunar plutonium. The
environmental pathways would be registered as air, water, sediments,
soils, the amount of plutonium in storage scheduled for ultimate dis-
posal or for power applications, as well as in transit by ship, rail,
motor vehicle or air would be easily available from the system and
would be reported on request. Other applications such as research,
medical uses in humans (e.g., heart pacers) and that used in commerce
for thermal heating would also be compiled and reported. All applica-
tions would be within the system in registry form.
B-141
-------
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FIGURE B-21
MONITORING GUIDE FOR PLUTONIUM
A WORLDWIDE INVENTORY
IMG-94-239-USEPA, Dated 12-22-73
(Arrows indicate 10 year rates)
-------
ENVIRONMENTAL IMPACT STATEMENT
PROBLEM DESCRIPTION
Component Problems
The problem, briefly stated, is to develop and maintain a capability
for the independent evaluation of the potential impact of activities
which involve radiation, both ionizing and nonionizing. The capability
is required by the responsibilities and workload imposed on EPA by
NEPA and Reorganization Plan Number 3 of 1970.
The problem has three separable components:
• The technical (radiological review of nuclear power plant
environmental statements).
• The management function associated with the agency-wide
review of nuclear power plant environmental statements.
• The review of nonpower environmental statements involving
radiation.
Background and Legislative History
Section 102 of the National Environmental Policy Act of 1970
states that "...all agencies of the Federal Government shall... include
in every recommendation or report on proposals for legislation and
other major Federal actions significantly affecting the quality of the
human environment, a detailed statement by the responsible official on:
• "the environmental Impact of the proposed action,"
• "any adverse environmental effects which cannot be avoided
should the proposal be Implemented,"
• "alternatives to the proposed action,"
B-143
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• "the relationship between local short-term issues of man's
environment and the maintenance and enhancement of long-term
productivity," and
• "any irreversible and irretrievable commitments of resources
which would be involved in the proposed action should it be
implemented."
Section 102 further states that prior to making any detailed
statement, the responsible Federal official shall consult with and
obtain the comments of any Federal agency which has jurisdiction by
law or special expertise with respect to any environmental impact
involved.
Revised guidelines for the preparation and review of environmental
statements were published by the Council on Environmental Quality on
January 28, 1971. The guidelines listed the Federal agencies which
should be consulted in connection with the preparation of environmental
statements. The list includes the Environmental Protection Agency.
Appendix II of the guidelines specified the jurisdiction by law or
special expertise of various agencies. The Water Quality and Air
Pollution Control Office of EPA are listed as having special expertise
in the environmental aspect of electric power generation. EPA is also
listed as having special expertise in the transportation and handling
of hazardous substances.
In July 1971, the U.S. Court of Appeals for the District of Columbia
Circuit and Calvert Cliffs Coordinating Committee vs. AEG, provided a
decision of a Federal appellate court construing section 102 of NEPA.
B-144
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The court's decision meant that expanded environmental impact state-
ments had to be prepared for all nuclear power stations except the
four that had already received full power operating licenses.
One possible consequence of the Calvert Cliffs decision could
have been a delay in the construction and operation of nuclear power
generating stations. Therefore, the ATomic Energy Commission and the
Federal Power Commission identified nuclear power units that were
critical to the nation's power needs and which should be given highest
priority. A ninety-day period for the review of a draft environmental
statement^ preparation of final statement, and review of that final
statement was adopted by the AEC. A thirty-day period was scheduled
for review of the draft statement.
By memorandum dated October 20, 1971, the Deputy Administrator
established certain procedures to be followed in the review of nuclear
plant environmental statements. The review process that has evolved
is comprised of five phases: (1) notification and distribution by
the sponsor agency; (2) receipt and internal distribution within EPA;
(3) technical review and comment; (4) consolidation of comments; and
(5) approval of comments and transmittal to sponsor agency. These
phases are displayed graphically in Figure B-22.
In order to analyze and program the review process it is necessary
to separate the technical review and management functions. The principal
requirement of the technical review is a sufficient number of technical
personnel specially trained to evaluate nuclear facilities, while the
management function requires procedures by which agency-wide comments
B-145
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/IMPACT
I STATUMLKT
I RECLULO ORP
j 'INFO COPY I
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ORM
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-TECHNICAL REVIEW
Cui be repeated once.
DEPUTY \
ADMINISTRATOR I
EPA /
FIGURE B-22
REVIEW PROCEDURE FOR A NUCLEAR POWER PLANT ENVIRONMENTAL IMPACT STATEMENT
B-146
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on controversial projects can be consolidated and prepared in the form
of an agency position to meet a very short and critical deadline.
The Deputy Administrator's memorandum of October 20, 1971, also
designated the Office of Radiation Programs as the principal reviewer of
draft environmental impact statements for nuclear power plants. The
role of principal reviewer in these cases is described as performing
both the radiation review and the management function.
The possibility of transfering the management function and/or
radiological review to the regional office has received increasing
attention within EPA. It was determined that during fiscal year 1973:
(1) the management function would be transferred to at least two
regional offices, and (2) the technical (radiation) review would con-
tinue to be performed by ORP and would not be transferred until a
regional office is fully staffed, the personnel trained in the review
process, and provided with review guidelines.
Detailed environmental statements involving radiation, both ionizing
and nonionizing, are prepared for a wide variety of Federal or federally
licensed activities other than nuclear power plants. The principal
responsibility for the review of these nonpower statements has been
assigned to ORP by OFA, but this practice has never been formalized.
The nonpower Federal projects are often more complex than power plant
statements and often require development of new policy which is of
national interest and significance, such, as the development of a Liquid
Metal Fast Breeder Reactor (LMFBR) and the establishment of a Federal
-------
high level waste repository. In some cases the nonpower projects also
have a strong regional bias, such as uranium mining and milling.
ALTERNATIVE APPROACHES
Nuclear Power EIS's
Three possible approaches to EPA's review of nuclear power plant
environmental statements are available, viz.:
e The review can be conducted according to guidelines for
which technical bases have been developed and the use of
which assures a thorough, complete and consistent evaluation
of potential impact.
• In the absence of guidelines the review can, as a minimum,
determine whether a plant can comply with "as low as prac-
ticable" release limits, and that all environmental pathways
have been considered.
• The review can be limited to the information provided in the
environmental statement.
The first two approaches are not incompatible and, in fact, are
complementary. They will be described as one in the next section.
The third, or alternative approach, i.e., restricting the review
to the information contained in the environmental impact statement, has
the advantage of requiring minimum manpower but also has several serious
disadvantages. Experience has shown that the information contained in
the EIS is usually not sufficient for EPA to make an independent evalua-
tion of the potential Impact of a plant. Thus, in each review, EPA
would comment that insufficient information had been provided in the
B-148.
-------
statement. If sufficient evidence were to be provided in the environ-
mental statement, it would approach or exceed in size the applicant's
environmental report. Since all recipients of the environmental state-
ment do not need as much information as does EPA, it would seem to be
that the wisest use of resources for EPA reviewers to use the environ-
mental report than to require it to be reproduced in the environmental
statement. If sufficient evidence were to be provided in the environ-
mental statement, it would approach or exceed in size the applicant's
environmental report. Since all recipients of the environmental state-
ment do not need as much information as does EPA, it would seem to be
that the wisest use of resources for EPA reviewers to use the environ-
mental report than to require it to be reproduced in the environmental
statement.
It should also be noted that the third approach is not amenable to
regionalization because consistency in EPA comments would be virtually
impossible. Also, the need to interface with ten regional offices would
place a considerable burden on the sponsor agency. These two later
disadvantages could be overcome if back-up were provided by ORP but
the total Agency manpower requirements would approximate those required
for all the original review.
In terms of manpower, the third alternative approach is estimated
to require 20 man-days of technical review. The management function
would be the same for all approaches, which is 22 man-days per statement
exclusive of supervision. The anticipated schedule of impact statements
for Fiscal Year 1973 would require an estimated seven man-years of tech-
nical review effort and seven man-years of management function.
B-149
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Nonpower EIS's
The wide range and diversity of the nonpower EIS's preclude the
establishment of technical guidelines for their review. Therefore,
their review depends on the expertise of the staff. That expertise
within EPA will exist primarily in ORP's problem areas. Consequently,
the nonpower statements will be referred to the appropriate problem
areas for review. The scope and depth of the review will depend on
the expertise of the reviewer and will normally include, as in the case
of nuclear power statements, a determination that:
• The discharge of radioactive materials is kept to the lowest
level practicable, and
• all exposure pathways have been considered.
OPTIMUM: PROGRAM
Nuclear Energy EIS's
The recommended program continues the currently employed review
procedure, which is the second approach described in the previous section
"Alternate Approaches," with concurrent development of guidelines. The
currently employed review process begins with the issuance of the safety
analyses report (SAR) and the environmental report (ER) by the applicant
and stretches over a twelve to eighteen month period. The SAR and ER
are reviewed, and the ORP staff develops its analyses based on the
information in these documents. When the draft environmental impact
statement is issued by the sponsor agency (about 7-10 months after the
review begins), the ORP staff reviews the environmental effects given in
B-150
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the draft statements, based on the independent ORP assessment. The EPA
emphasis is directed toward determining whether (1) the releases of
radioactive waste can be considered "as low as practicable," and (2) all
significant environmental exposure pathways have been adequately considered.
The current review approach for nuclear power plant EIS's, as in
the case of nonpower plant review depends heavily upon individual staff
expertise. Consistency is achieved through supervisory guidance of the
reviewers and management review of draft material. Only in limited
instances has the technical bases been adequately developed for the
issues raised. The development of guidelines for the review, each of
which has a documented technical basis, will (1) ensure consistency
among reviews and reviewers, (2) enable the sponsor agency to under-
stand and respond to the need of the reviewers, (3) assure that important
issues had not been overlooked, and (4) improve the quality of the review.
The guideline development will be completed by June 30, 1973, for
those guidelines for which sufficient information exists. The need for
additional information will be referred to the appropriate problem areas.
The first major milestone following completion of the guidelines
will be the decision of whether or not to regionalize the technical
(radiation) review. If it is decided to regionalize, regional office
personnel. An estimate of two years for this activity seems reasonable.
Two man-years per year of effort is estimated for guideline development
and training.
As indicated earlier, the decision has already been made to transfer
the management function to selected regions during FY 1973. A decision
B-151
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concerning the transfer of the function to other regional offices will
be made in early FY 1974.
A major factor in deciding whether or not to regionalize the tech-
nical review and management function is the comparative man-power require-
ments. The options available are listed below.
• Option I - All of the technical review, management
functions are performed by ORP.
• Option II - All technical review and management functions
performed by ORP, plus the development of
guidelines.
• Option III* - Primary management function is carried out by
the regional offices. ORP assists in the initial
management function, performs the technical
review and assists in the final coordination
and management approval.
• Option IV* - Regional offices perform both the technical
review and the management function. ORP
reviews the technical comments made by the
regional offices.
Estimates of the staff time required for one complete EIS action
for each of the four options are presented in Figures B-23, to B-26. The
two principal conclusions from these analyses would appear to be that
• the management functions can be transferred to the regional
offices without any increase in personnel, and
*
(In both Option III and IV, ORP would develop and make available the
review guidelines.)
B-152
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i
Months 0"
CO
g
4-
.4 5 6-
co
M
U
Q
-7-
eo
H
M
-10-
-11
-12
TOTALS
(man-days)
TECHNICAL REVIEW
(man-days)
Headquarters
Ui
w
MANAGEMENT FUNCTION
Headquarters
SAR ER
Review Review
i—i •-« I— -
10 7k
Review
Amendments
1
Type Comments, Schedules, etc.
Draft
EIS Review Final
& EIS
Briefings Review
Consolidate Comments
Docket Distribution
Typing
Proof Reading, etc.
-I I - — — »
18
32
22
ADMINISTRATION
Headquarters
File Amendments
-f
FIGURE B-23
EIS TIMELINE (OPTION I)
56 Man Days
-------
3
Months 0-
-1-/-2 —
gj g
w fc
8. ...9
10 - 11 ---- 12
TOTALS
(man-days)
TECHNICAL REVIEW
(man-days)
Headquarters
MANAGEMENT FUNCTION
Headquarters
SAR ER
Review Review
i—* H-» I—-
9 7
Review
Amandments
Type Comments, Schedules, etc.
Draft
EIS Review Final
& EIS
Briefings Review
Consolidate Comments
Docket Distribution
Typing
Proof Reading Etc.
I I 1
18
26*
22
ADMINISTRATION
Headquarters
File Amendments
GUIDELINE DEVELOPMENT
2 Man-Years
FIGURE B-24
EIS TIMELINE (OPTION II)
50 Man Days
-------
g
S
CO
M
U
Months 0
1 12
61 7
CO
H
w
t*
9
10 11 12
TOTALS
(man-days)
TECHNICAL REVIEW
(man days)
Headquarters
SAR ER
Review Review
Review
Amendments
Draft
EIS Review Final
& EIS
Briefings Review
26.
Ui
MANAGEMENT FUNCTION
Headquarters
Region
ADMINISTRATION
Headquarters
Typing, Scheduling, etc.
-I
4 Consolidate Comments
Docket Distribution,Typing
Type Comments, Schedules, etc. Proof Reading, etc.
I -» I 1
File Amendments
16
4
18"
Region
File Amendments
FIGURE B-25
EIS TIMELINE (OPTION III)
52 Man Days
-------
TECHNICAL REVIEW
(man-days)
.Headquarters
Region
i
Months 0
SAR
Review
• i
5
SAR
Review
i — i
ENV. REPORT
1 /2
ER
Review
L_ J 1
7
ER
Review
i— 11—
C/l
345
Review
Amendments
1
Review
Amendments
CO
H
H
H
0
6^7 8
Draft EIS 1
Review & ]
Briefing / \
i . •» ii •
6 4
Draft EIS Review
and Briefing
j i_i
(A
M
W
9
Pre
Re\
Res
Fi
t-
10
11
12
TOTALS
(man-days)
Provide Technical Assistance
Review Regions Comments &
Resolve Differences 01
Review
f.
26
? MANAGEMENT FUNCTION
K Headquarters
Region
Typing, Scheduling, etc.
4 Consolidate Comments
Docket Distribution,Typing
Typing, Scheduling, etc. Proof Reading, etc.
16
18
ADMINISTRATION
Headquarters
File Amendments
Region
File Amendments
FIGURE B-26
EIS TIMELINE (OPTION IV)
75 Man Days
-------
• transfer of the technical review function to the regional
offices, with ORP review and approval of comments, nearly
doubles the technical staff time required.
Nonenergy EIS Review
The technical review and a minor portion of-"the management function
for nonenergy EIS reviews will be performed as an integral part of the
activities of the ORP Problem Areas. The personnel assigned the review
responsibility within the appropriate problem areas will be working
daily on these topics with counterparts in the issuing agency. They
will, therefore, be the individuals in ORP most qualified to perform
the review.
The majority of the management functions and all of the adminis-
trative duties will continue to be carried out by personnel assigned
to the EIS review.
It is currently estimated that a total of approximately thirty-five
nonenergy EIS's will be received in FY 1973 from the AEC (General Manager),
NASA, and the Department of Defense. There has also been an indication
that as many as sixty additional draft EIS's may be issued by the FCC
for communications/navigation systems. The management and administrative
workload for each nonenergy EIS action is estimated to be eighteen man-
days as compared to the twenty-four man-days for a power plant EIS.
The principal difference is that a nonenergy EIS is not as widely
distributed for comment throughout EPA and, therefore, fewer comments
need to be consolidated. The management and administrative support
associated with this effort is estimated to be about two and a half
B-157
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man-years. This estimate is necessarily crude due to the great vari-
ability in the effort required by different statements, and the uncer-
tainty in the number and complexity of the FCC statements.
B-158
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TRAINING
PROBLEM DESCRIPTION
Component Problems
The problem of providing or assisting in meeting the radiation
protection training needs of the country is two-fold because of two
distinct types of training needs. These two types of needs can be
classified as program related training needs and problem related train-
ing needs. Program related training needs are a result of the overall
mission and goals of the radiation protection program in question.
These needs are usually met by acquiring personnel with adequate long-
term training, i.e., hiring either employees with Associate, Bachelors,
Masters, or Doctorate degrees. Problem related training needs are a
result of individual problems or groups of problems encountered by the
radiation protection program in fulfilling its mission and goals. These
are usually met by sending current employees to some type of short-term
training activity to obtain some specific skills related to the prob-
lems at hand.
Background
Radiation protection related training has been either sponsored
or conducted by EPA and its predecessors in the U.S. Public Health
Service for a long time.
Short-term courses were begun in the late 1940's by NIOSH and
later continued in the U.S.PHS at Cincinnati and then expanded to
include facilities at Las Vegas, Nevada; Winchester, Massachusetts;
B-159
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Montgomery, Alabama; and Rockville, Maryland. The direct-course train-
ing program was initiated because of the need for State and local health
department officials to have increased capabilities in the area of
environmental monitoring and occupational safety.
As the use of atmospheric testing subsided after the nuclear test
ban treaty was signed in 1963, increased emphasis was placed on radia-
tion protection from medical sources, primarily X-ray equipment. There-
fore, the direct training program increased their course emphasis in
that area.
The passage of the "Radiation Control for Health and Safety Act
of 1968" required that "the Secretary of HEW shall establish and carry
out an electronic product radiation control program designed to protect
the public health and safety from electronic product radiation. As a
part of such program, we shall plan, conduct, coordinate, and support
research, development, training, and operational activities to minimize
the emissions of and the exposure of people to, unnecessary electronic
product radiation." As a result of this requirement, the Bureau of
Radiological Health training branches developed courses regarding the
safe use of lasers, microwaves, and other radiations from electronic
products.
The creation of the Environmental Protection Agency by Reorgani-
zation Plan No. 3 of 1970, transferred part of the radiation training
activities of DHEW to EPA. All courses that are principally concerned
with some aspect of environmental training were determined to be the
B-160
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responsibility of EPA, and therefore, transferred to EPA. Courses
that dealt primarily with medical or X-ray exposures were determined
to be primarily HEW's responsibility and remained with HEW. A number of
courses that were multidisciplinary, such as the Basic Radiological
Protection Course, were maintained by both EPA and BRH. At the time
of the organization of EPA, the training branches at the Western
Environmental Research Laboratory (WERL) in Las Vegas, Nevada, and
the Eastern Environmental Radiation Laboratory (EERL) in Montgomery,
Alabama, were transferred to EPA, the others remained with DHEW.
Each EPA radiation training branch at the two laboratories has
training facilities which include a classroom, laboratories, radiation
detection equipment, radiation sources, nonionizing sources, and audio-
visual support equipment, worth approximately $100,000 at EERL and
$83,000 at WERL. In addition, the training branches have access to
the equipment and facilities of each laboratory. The total budget for
the radiation training programs at both EERL and WERL for FY 1972 was
$210,000. The two training branches trained a total of 678 trainees
in radiation short-courses in calendar year 1971. Statistics for
previous years are included in Tab 1.
The training grant program was created in 1961 by the Division
of Radiological Health, Bureau of State Services (Environmental Health),
U.S. Public Health Service, DHEW, to meet the national need for radio-
logical health specialists and technicians for use in State and local
radiation control programs, Federal radiation control programs, and
B-161
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other organizations which required knowledgeable radiation protection
personnel to provide for the public health. Training grant funds were
used to strengthen and extend programs of basic instruction, to add
to the faculty and its supporting staff, to secure equipment, and to
encourage greater enrollment by providing financial assistance to
qualified students preparing for careers in radiological health. The
projects operated at two academic levels, Radiological Health Specialists
(graduate) and Radiological Health Technicians (undergraduate). Train-
ing included study in radiobiology, atomic and nuclear physics, hazards
evaluation, epidemiology, biostatistics, and other areas of radiation
science and public health. The curriculums were designed to prepare
radiological health specialists and technicians for professional and
para-professional positions in radiation protection programs.
Funding for training grants during fiscal years 1962 through 1971
ranged from $1,000,000 to $2,500,000 covering grants to 20-45 institu-
tions yearly. Table B-21 Tab 2 lists the number of graduates as a
direct result of the training grants. Table B-22 in Tab 2 indicates
the number of specialist (graduate) and technician (undergraduate)
grants that were active each year, and the total dollars appropriated
for training grants.
At the creation of EPA, 17 training grants were transferred from
the Bureau of Radiological Health, DHEW, to ORP. The decisions con-
cerning which grants should remain with DHEW and which should be trans-
ferred to EPA were affected by guidance from the Office of Management
and Budget. The $2,000,000 appropriated funds for training grants were
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to be split 60% to DREW and 40% to EPA. A team of officers having
in-depth knowledge of individual grants (Ronald E. Blaes, Benjamin
H. Bruckner, and Thelma J. O'Connell) was appointed to recommend the
apportionment of active and pending training grants.
The OMB guidance for splitting training grants 60/40 between
DHEW/BRH and EPA/ORP meant that EFA/ORP would have a base of $800,000
for budget purposes. In FY 1971, $856,350 was paid out for the train-
ing grants shown in Tab 2, Table B-23 $209,626 by the Bureau of Radio-
logical Health, DREW, and $653,724 by ORP.
Five new grants which had been approved pending availability of
funds were not funded. (See Table B-23, Tab 2.)
The training grant program for FY 1972 by ORP was essentially a
continuation of the FY 1971 program, except that funding for most
schools was decreased. (See Table B-24, Tab 2.) No new grants and
no renewals were awarded in compliance with a freeze in January 1972
by the Office of Planning and Management. The likelihood of further
decreases in grant awards was communicated informally to recipients,
who were already aware of the generally austere financial climate.
At the beginning of FY 1973 the outlook for the entire training
grants program of EPA is one of tight financial control. In size,
the Radiation Training Grants Program is small. Both the Air and Water
Programs are more than three times as large. Only the Solid Waste
Program is smaller, although an exploratory contract for $500,000 by
Solid Waste to determine the need for training in that Program has
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been funded. Pesticides has no training grant program. Comparative
funding (preliminary data from Grants Administration) is shown in
Table 16.
TABLE B-16
TRAINING GRANTS -FY 1972
Program
Air
Pesticides
Radiation
Solid Waste
Water
FY 72 Funds Awarded
in $ millions
$2,477,133
751,258
229,631
2,608.723
$ of Total
Program
41
12
4
43
TOTAL
$6,066,745
100
OMB questioned the need for EPA's training grants program in
FY 1972, with a view toward reducing the program in FY 1972. As a
result, funding of renewal or new grants was frozen, and a working
group met and drafted an implementation plan for a $3 million cut in
the FY 1973 program. To date, the freeze has not been lifted, and no
decision has been made for action.
Scope
It is the goal of the Office of Radiation Programs to conduct a
program of activities that will ensure that there is sufficient capable
manpower to meet the country's radiation protection needs. The full
assurance of this capability cannot be done solely by EPA's Office of
Radiation Programs, but must be done on a cooperative basis among all
agencies involved.
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Training to provide adequate radiation protection personnel is
most frequently divided into two categories which relate to program
related training needs and problem related training needs. For the
purpose of simplicity these are usually considered as short-term and
long-term training. While these two activities must be coherently
coordinated to provide for adequate training, for clarification they
will be separated in this discussion.
A grant supported program in radiation protection at a university
or college is conducted by an agency for many reasons, but the most
important goals from our perspective are the following: .
• To provide a means for solving the Agency's program
problems.
• To provide staff development training for personnel
currently in the radiation protection programs.
• To ensure a supply of qualified radiation protection
personnel for future leadership and productivity in the
field.
• To provide visibility, public relations, academia contacts
for the Agency.
There are a number of granting mechanisms that can be established
at universities and colleges to meet these goals. While each mechanism
can accomplish some or all of the above goals, the mechanism chosen by
the Agency will be a function of its program priorities.
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Types of Grant
Training Grants - Under this type of support, funds (currently
about 38%) are provided to the institution to supplement equipment,
salaries, etc., and funds (currently about 62%) are also provided for
payment of student tuition and stipends. The major goals of this type
of support include the latter two goals shown above. However,the
second goal above is also partially accomplished through stipend incen-
tives to experienced students and through State agencies and other
support (approximately 50% of enrolled students in all schools offering
radiation health and safety training are committed to employers, i.e.,
only 50% of graduates are new to the field.)
Research Grants - Under this type of support, funds are provided
to the institution to supplement equipment, salaries, etc., and funds
are also provided for students who work on the specific research prob-
lems that the grant is supporting.
Problem Solution - Training Grants - Under this type of support,
funds are provided to the institution to supplement equipment, salaries,
etc., and funds are also provided for students who work on specific
problem related projects being supported by the grant.
Financing Levels
The financial support for long-term training, like short-term
training, must be directly proportional to the demonstrated needs if
the program is to be effective. However, as with short-term training,
the definition and assessment of the radiation protection training
needs is currently quite sketchy and needs improvement.
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However, regardless of data proving or disproving the need, there
is a current trend to decrease support to training grants. This decision
does not appear to be founded on the premise that the supply of trained
personnel in radiation protection is overabundant, but rather appears
to be at least partially founded on the opposite rationale. The ratio-
nale. The rationale appears to be that the decrease in training grant
support to training grants including radiation protection is warranted
because: (1) all persons graduated in radiation protection can get
a job, therefore there is incentive for a student to enroll in the
program; (2) salaries for persons working in radiation protection are
average to above-average for those in fields requiring comparable
training; and (3) job security in radiation protection appears to be
excellent. Therefore, since students pay to go to schools in other
areas, offering less incentive than radiation protection, why shouldn't
they pay to go to school in radiation protection and, therefore, why
should agencies like EPA support these programs.
These arguments may be true, but there is no readily available
data to fully support these assumptions. In fact, the following argu-
ments can be made as to why it would be to the agency's and the radia-
tion protection field's advantage to support the long-term training
program. These reasons are the following: (1) radiation protection
training is very specific and universities would eliminate the radia-
tion protection training program if it was not supported by the users
of the trained personnel who are in many cases Federal agencies;
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(2) a good program in radiation protection requires a great deal of
expensive laboratory and radiation detection equipment; (3) by support-
ing the institutions, the agency has the opportunity to directly parti-
cipate in what courses and philosophies will be taught; (4) in general,
student tuition pays only about 1/3 of the cost of a student's educa-
tion, therefore, even if the student paid his own way, unless there
were additional funds specifically available for the overhead of radia-
tion protection training, the school could not afford to educate the
student; and (5) radiation protection is not a basic field such as
physics, biology, or others, but is rather a combination of many basic
fields and, therefore, is somewhat less attractive to universities
for their own support.
The Office of Research and Monitoring is the EPA research arm
and, therefore, all research grants are handled through that Office.
Any decision by ORP to encourage research grants would have to be done
through ORM. Of the two mechanisms remaining to ORP, training grants
and problem solution-training grants, on first observation it would
appear that the problem solution-training grant would be superior to
the conventional training grant. The main reason for this observation
is that with the problem solution-training grant the agency can accom-
plish all four goals, while only three are possible with the conventio-
al training geant. If the highest priority was to solve program prob-
lems with training of future radiation protection leaders, current
staff development and academia and public relations much farther down
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in priority, then for effective accomplishment of its objectives, the
agency should very definitely gravitate toward problem solution-training
grants. However, if solutions to program problems, training of future
radiation protection leaders, current staff development, and academia
and public relations are of equal or near equal importance, then the
decision whether to choose the conventional training grant or the
problem solution-training grant is much more difficult. This difficulty
arises primarily because, while the problem solution-training grant may
allow for the accomplishment of all four goals rather than the three
of the training grant, the accomplishment of the additional goal is at
the expense of the other three. The point is that in order to solve
the problem, funds and student's time must be diverted from his degree
requirements. Therefore, it may take him 50% to 100% longer to finish
his degree while working on the project than if his entire time could
be devoted to his studies. This would affect the agency because,
while the problem may be partially or fully solved, they might have paid
as much or more to the student than if he was on a stipend. Secondly,
the university program being supported by the agency might turn out a
significantly fewer number of students in radiation protection. If
the supply of trained personnel in the field is critically short, this
could have a significantly damaging affect. However, if the current
'supply was near demand, then this reduction in graduating volume might
indicate that problem solution-training grants are definitely the course
to pursue.
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Unfortunately, accumulated and analyzed data regarding radiation
protection personnel supply and demand, effect of stipend curtailment
on student enrollment, and effect of reduction in financial support
on nationwide radiation protection training capabilities is very
sketchy. Therefore, at this time, any major decision to plot a defi-
nite agency course for the next five to 10 years would be an impru-
dent and unjustified move. The first major activity that must be
undertaken is to acquire and assess the specific data that will allow
a meaningful long-term commitment to one course of action.
In regard to grants, the purpose of this report is to detail a
program that will compile necessary data and evaluate it to allow a
meaningful decision among various alternatives available.
Special Courses
Short-term training has historically been treated by EPA and its
predecessors by primarily conducting short-courses of one to two weeks
in some aspect of radiation protection and on-the-job training conducted
at the laboratories to meet some specific technical training need. As
previously stated, the reason for initiating the short-term training
programs was that the State and local control agencies were composed
primarily of sanitarians, civil engineers, and sanitary engineers that
badly needed training in radiation protection. The Federal government
undertook the task of establishing program to train the personnel
because the training was not readily'available from other sources and
the Federal government wanted to continue the spirit of Federal-State
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cooperation by providing technical assistance and training in radia-
tion protection under the authorization of the FHS Act, as amended.
Therefore, initially the courses conducted by the PHS were almost
entirely comprised of State and local control agency personnel. How-
ever, in recent years this has not been the case. The trend is that
State and local control agency enrollment has diminished and the course
applicants now come from other employer categories, primarily the
Federal government and industry. This shift in employee categories
of the trainees may be due to a combination of many factors which
include:
1. The training programs were effective in their goal and all
those requiring radiation training in State and local control agencies
have been reached.
2. Today the State and local control agencies have a core of quali-
fied radiation protection personnel and only need additional short-
term training fro staff development, when a new employee is hired, and
when a new radiation problem is encountered.
J
3. Travel and per diem authorization and for funds for out-of-
State travel is severely restricted in many States and local control
agencies.
4. The training courses were not fully relevant to the problem
and training needs of the State and local control agencies.
5. Industry and the Federal government have expanded so greatly
in radiation protection as compared to State and local agencies so
that they comprise the bulk of the work force.
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Therefore, if our goal is still the same as it was in the origin
of the program, then new mechanisms need to be employed to ensure that
the bulk of the short-term trainees are from State and local control
agencies. However, before this statement is hastily accepted, we need
a more comprehensive analysis of EFA's responsibilities in radiation
training along with a view of the responsibilities of other agencies.
In general, EPA's mission in regard to radiation protection is
to protect public health and the environment from adverse effects due
to radiation exposure. This mission is extremely broad and included
in it is the protection of the public from unnecessary medical exposure,
the protection of the public and the environment from controllable
natural sources, the protection of workers from unnecessary occupational
sources, and the protection of the public and the environment from all
man-made sources of both ionizing and nonionizing radiation. Needless
to say, if EPA or any other single agency attempted to develop a train-
ing program that would provide short-term training for all persons
included in controlling exposures from all these sources, it would
require a training program with total resources exceeding or at least
comparable to EPA's entire radiation budget. Therefore, at this time,
a totally encompassing training program is neither feasible nor reason-
able. An argument could be made for total consolidation of radiation
protection programs currently dispersed throughout the Federal govern-
ment were consolidated in one agency.
The question is, then, what is an acceptable and rational role
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for EPA in providing or supporting short-term training. To answer
this question, the following factors must be thoroughly investigated:
1. Who needs short-term radiation protection training?
2. What areas do they need it in?
3. To what types of functions would the training be applied in
reducing population and environmental exposures?
4. Who is involved in providing any short-term radiation protec-
tion training?
5. In what areas do they provide the training?
These questions are discussed in detail in Tab 3 where a priority
rating has been established for the radiation protection training needs
of various organizations as they relate to EPA.
Analysis of Tab 3 indicates that, in general, EPA should directly
involve itself in conducting significant training activities for indus-
try participants. This conclusion was reached because: (1) sufficient
training in most radiation protection areas is available from the pri-
vate sector; (2) courses or other training activities with abundant
industrial participation could be considered as governmental inter-
vention into private enterprise; (3) particular industrial or other
private sector uses such as nuclear power plants, X-ray technicians,
and others can obtain training from governmental sources such as the
AEC or BRH, respectively, in addition to private sector training pro-
grams; and (4) with our limited resources, EPA could only hope to train
an insignificant fraction of the total industry and private sector
personnal and, therefore, our efforts would be insignificant in reducing
total population exposure.
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Analysis of Tab 3 indicates that, in general, EPA should not con-
duct significant training activities for Federal government partici-
pants other than EPA employees. This conclusion is reached because:
(1) in general, Federal agencies with significant radiation protection
responsibilities either hire only qualified personnel, conduct their
own training programs, or send their personnel to outside of govern-
ment training when necessary; (2) there are sufficient training pro-
grams in most radiation protection areas available from the private
sector; and (3) the turn-over in some government agencies, such as
DOD, is so great that in many cases the training is not effectively
put to long-range practical use.
The computed ORP priority for each organizational category requir-
ing radiation protection training is listed in Table B-17. The priori-
ties were computed according to the procedure in Tab 3.
From this priority listing, the following two significant con-
clusions can be drawn: (1) the number of people that require some
form of radiation protection training is so great that our resources
can be effective only if the majority of our training activities deal
only with the highest priority groups; (2) for the remainder of the
groups needing training, the most effective EPA/ORP role must be one
of a catalyst interacting between the various groups needing radiation
protection training and those providing radiation protection training.
This interaction can and must take many forms, including accumulating
an inventory of resources available to groups needing training and
ensuring that they know what is available, assisting in interagency
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TABLE B-17
RANKED ORF TRAINING PRIORITIES BY ORGANIZATION
ORP Training
Organization Priority
Environmental Protection Agencies (State & local) 171.0
Health Departments (State & local) 96.9
Academia 37.5
Research & Development Organizations 32.1
AEC 31.8
Medical Facilities 30.1
Radiation Protection Consultants 29.3
Department of Labor 24.8
National Institute for Occupational Safety & Health 24.8
Firemen and Police 20.8
Civil Defense (State & local) 20.8
Tennessee Valley Authority 17.1
Reactor Vendors 15.3
National Institutes of Health 15.1
Department of Defense 14.8
National Aeronautics and Space Administration 14.6
Bureau of Radiological Health 13.6
Radioisotope Producers 13.4
Department of Commerce 9.8
Utilities 8.5
Department of Housing & Urban Development 6.7
Department of the Interior 6.1
Department of Transportation 1.8
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training planning sessions, and influencing the types of training
courses and materials prepared by various agencies and other groups.
This report is designed to detail the functions of the EPA role
in short-term radiation protection training and to establish a program
for effective implementation of this role.
LEGISLATIVE STATUS
The legislative basis for the conduct of the Office of Radiation
Programs training activities originates in the Public Health Service
Act, as amended. Section 301(c) of the Act authorizes EPA to "estab-
lish and maintain research fellowships in the Service with such stipends
and allowances, including traveling and subsistence expenses, as may
be deemed necessary to procure the assistance of the most brilliant
and promising research fellows from the United States and abroad."
Section 301(d) of the Act authorizes EPA to "make grants-in-aid to
universities, hospitals, laboratories, and other public or private
institutions, and to individuals for such research or research training
projects as are recommended by the National Advisory Health Council."
Section 311(b) of the Act authorizes EPA "to train personnel for State
and local health work."
These authorities are reflected in the EPA Organization Order
Number 1110.21 of August 12, 1971, which states that "The Deputy
Assistant Administrator for Radiation Programs is responsible for
providing assistance in the training of personnel for radiation pro-
tection programs in the States and for other purposes." Therefore,
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the Office of Radiation Programs, through the Office of Categorical
Programs, has the authority to provide or assist in short-term train-
ing such as short-courses, on-the-job training, seminar, workshop, or
other techniques as required to meet the radiation protection needs.
COORDINATION
Interagency
The easiest way to discuss current interagency coordination is to
divide training activities into its two component parts: long-term
training and short-term training.
Interagency coordination regarding training grants has been minor,
with most of the coordination being between EPA and BRH.
Interagency coordination regarding short-term training has also
been relatively minor. Most of the coordination has either been with
BRH or AEC. This coordination has been regarding planning, course
content, and guest lecturers.
Intraagency
Again, the easiest way to discuss intraagency coordination is to
divide the training activities into long-term and short-term training.
One of the first attempts at coordination among EPA's training
grant programs was the Report of the Grants Procedural Task Group which
submitted its report on March 29, 1971. In regard to training grants
within the agency, the Task Group submitted a number of recommendations
which are detailed in Tab 4.
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To date, only a few of the Task Group's recommendations have been
Implemented. It should be noted that the Research Grants Task Group
recommended that all training grants be totally administered from one
office. However, while EPA decided to place all research grants under
ORM, all training grants were not transferred to one office, primarily
because the other training activities, that is the short-term training
programs, were not centralized. It was believed that it would be more
effective for both long-term and short-term training activities if
they remained with their respective technical programs. However, the
Office of Training and Manpower in the Office of Planning and Manage-
ment has undertaken a cohesive role among the various EPA training
grant programs regarding policies and appropriations. The Office of
Radiation Programs has been working with the Office of Training and
Manpower on various issues relating to training grants.
Intraagency coordination regarding short-term training has
taken a number of forms. From time to time, meetings have taken place
with representatives of each training program to discuss items of
mutual relevance. These items have included consolidation of EPA
training catalogs, and discussion of the EPA decision to charge a fee
for training courses. The Office of Training and Manpower, 0PM, has
recently initiated an EPA Training and Manpower Steering Committee on
which ORP has a representative. One of the first purposes of the
Steering Committee is to resolve the user fee issue.
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ALTERNATIVE APPROACHES
In the discussion of alternative approaches in determining the
ORP role in radiation protection training, the first issue to determine
whether ORP should adopt a strategy of total separation of long-term
training activities from short-term training activities. Historically,
this has been the accepted approach. However, if we examine the current
status of training, we find that with this separation there is very
little exchange between the users of training, for example, the State
and local control agencies, and the providers of long-term training,
the academia. EPA and its predecessors were the only ones who could
bridge the gap since they dealt with each group, but this interaction
was not fully achieved because of the theory of separation of long-
term and short-term training activities.
It appears that significant benefit could be derived from increas-
ing exchange between the academia and the short-term training users.
For example, as a part of a training grant, the grantee might be required
to put on a short-term course once a year specifically designed for the
high priority short-term user. And conversely, before a training grant
is awarded, the proposal could be circulated to a training user, such
as a State radiation control program, to determine if the program is
relevant to current and projected training needs. Therefore, a major
part of the EPA training role is to remove the short- and long-term
training blockade and increase coordination between these areas.
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It is emphasized that short-term training and long-term training
are considered separately in this report only for the purpose of reduc-
ing confusion and not because they are or should be separated in the
ORP training role.
The Environmental Protection Agency's program regarding long-term
radiation protection training could take three forms: (1) training
grant, (2) research grant, or (3) problem solution-training grant. The
individual meaning of each of these three alternatives has been pre-
viously discussed. It should be noted that the research grant would
be administered by ORM, the training grant by ORP, and the problem
solution-training grant by ORP if it was given as a training grant with
the problem solution stipulations in the grant.
The ORP short-term radiation training program could be aligned
along one of the three significant alternatives which are explained
as follows:
1. A program which would provide a complete training capability.
This alternative would require that ORP have a training facility. This
facility would require a staff of instructors, technical equipment,
and other supporting resources. Courses would be given in various
areas by this training staff, both at the facility and in the field.
Provision would have to be made for maintenance of the support equip-
ment and generation of training resources. ORP would also have to
*\
supply a training needs assessment function to ensure that all train-
ing is relevant and fully reflects the needs of the priority groups.
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It should be emphasized that the primary purpose of this alternative
is to provide a special problem solving capability, that is the staff
would analyze the various radiation problems presented, determine
which ones could be fully or partially relieved by the proper applica-
tion of training, and establish means such as courses, seminars, work-
shops, and packaged materials to meet the needs.
2. A program which would provide a coordination role. This alter-
native would require that EPA retain a minimum staff totally devoted
to training. The one or two man staff would coordinate the available
EPA radiation training resources with the Regions, States, and academia.
This role would include assisting the States in their development of
training needs, and informing the States and others as to what resources
are available from EPA, including personnel, equipment, and literature.
In this role, ORP would also act as a liaison to ensure that adequate
resources get to the States and others to help them meet their needs.
3. A program in which EPA would only be a user of radiation
training and not provide or support any .radiation training. By taking
this alternative, EPA would not need to maintain any personnel totally
devoted to radiation training. If EPA required some form of radiation
training for its personnel, it would either obtain it from other Federal
agencies or from the private sector.
OPTIMUM PROGRAM
The goal of the Environmental Protection Agency is to ensure that
adequately trained and staffed radiation protection programs are on hand
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and will continue in the future. To accomplish this goal requires a
program designed to assist in providing manpower and training for
organizations with radiation protection needs. To ensure that out
resources are being effectively utilized, the program is directed to
place the greatest emphasis on the highest priority organization
requiring manpower and training in radiation protection.
The two major factors that are involved in the successfulness of
this program are: (1) a meaningful assessment of the supply and demand
of radiation protection manpower and objective assessment of the problem-
related training needs; and (2) effective coordination among all the
agencies involved, including the States, EPA, BRH, AEC, and NIOSH, to
minimize duplication and promote cooperative training activities.
Within EPA, this program will also require a significant amount of
coordination among the Regions, the Office of Radiation Programs, and
The Office of Research and Monitoring.
It is difficult to divide the optimum program into categories of
external and internal needs, so the program will be discussed in rela-
tion to the following six divisions:
• headquarters,
• regions,
• States, .
• other EPA coordination,
• other Agency coordination,
• private sector coordination.
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Headquarters
To provide the optimum headquarters role requires that a Training
and Special Problems Branch be established. The Branch would provide
the following functions:
• A continuing assessment of the radiation protection man-
power supply and demand.
• Direct the Office of Radiation Programs activities in
relation to academia grants.
• Provide liaison between the States, Regions, and Headquarters
to provide technical assistance to States in their training
efforts.
• Participate as EPA coordinator to the Conference of Radiation
Control Program Directors' Task Force on Training.
• Inventory and maintain responsibility for ORP rediation equip-
ment and other resources relative to training.
• Develop materials, training packages, and other resources as
needed to solve special problems related to training needs.
• Coordinate and/or conduct training events, such as seminars,
workshops, or courses, to meet training needs identified by
the Office of Radiation Programs' goals and objectives.
• Establish liaison to all Regional Training Committees for the
purpose of assisting in meeting State and local program train-
ing needs.
• Coordinate ORP training objectives with other Federal agencies,
such as the Bureau of Radiological Health, the Atomic Energy
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Commission, the Department of Labor, and the National Institute
of Occupational Safety and Health.
• Establish and/or coordinate joint training activities with
other interested Federal, State, and local agencies.
• Establish liaison with the academia for the mutual benefit
of short-term'and long-term training needs.
The training and Special Problems Branch would be the focal
point for all EPA radiation training activities.
Personnel
For optimum operation, the Training and Special Problems Branch
would require four professionals and a secretary. The personnel
requirements are based upon nees up to FY 75. At that time, reassess-
ment would determine if staff expansion or reduction is warranted.
Operation Researcher/ Program direction, GS-14
Health Physicist evaluation
Biophysicist/Engineer Academia relations & grant 6S-13
evaluation
Physicist/Engineer Special problem solution de- GS-13
velopment & RTC & other agency
liaison
Biophysicist/Engineer Special problem solution 6S-12
development & RTC & other
agency liaison
Secretary 6S-6/7
Total Annual Salary - $82,000
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Equipment and Materials
It will be necessary for the Training and Special Problems Branch
to maintain radiation detection equipment, training aids, and other
materials necessary for effective training. These materials would be
utilized by the Branch and lent to States and Regions for their use in
training activities. The following annual funds are necessary for
these needs:
Training materials development $4,000
Equipment acquisition & amintenance $4,OOP
Total Cost $8,000
Assessment of Manpower Supply and Demand
As previously indicated, the current assessment of the radiation
protection personnel supply and demand is quite sketchy. The AEC has
recently embarked on a program to determine the supply of personnel
in the radiation protection field. To complete the information
required to make meaningful decisions regarding grants to the academla
in support of radiation protection training, the following questions
have to be answered:
• What is the present and future national demand for radia-
tion protection personnel?
• Can the present and future demand be met by the current and
projected availability of personnel?
• Would the supply of radiation protection personnel be signifi-
cantly affected by reductions in Federal support to academia
programs?
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• Would the quality of the radiation protection personnel be
significantly affected by reductions in Federal support to
academia programs?
These are a few of the important questions that must be addressed.
In this program, the Training and Special Problems Branch will take
each individual question and determine if there is adequate data cur-
rently available to draw reasonable conclusions. If data is lacking,
the Branch will analyze each question and develop a questionnaire or
some other mechanism that can be successfully used to obtain the
necessary data. Completion of this entire analysis will provide infor-
mation for input into the decision concerning the establishment of
new training grants, problem solution-training grants, both, or neither.
This assessment must continue throughout the overall training program
to ensure that we always have a relevant and useful data base on which
to make decisions regarding academia grants.
Assistance to Regional Training Committees
To meet the short-term training needs of the State and local radia-
tion control programs, it will be necessary to provide a large amount
of assistance to the Regional Training Committees, particularly in their
early stages. The functions of the Regional Training Committees will
be discussed later. This assistance will be in the form of providing
expert technical personnel from EPA to present lectures or conduct
other activities, and by providing resources including training materials
and equipment for use during training events.
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The headquarters assistance to the States through the Regional
Training Committees will be directed by the Training and Special
Problems Branch. The Branch will oversee all materials supplied to
the Regional Training Committees by headquarters, will assist the
Regional Training Committees in planning training events and materials,
and will contact the ORP divisions to obtain expert technical personnel
to provide lectures. The Branch will provide liaison to other agencies
for the purpose of obtaining experts to present lectures, and will
oversee the allocation of resources to the Regional Training Committees.
To accomplish this each of the ten Regional Training Committees will
require approximately $5,000.
It should be noted that these resources can be used to pay travel
and per diem for EPA personnel assisting the Regional Training Com-
mittees, travel and per diem for members of the Regional Training
Committees for the purpose of attending Regional Training Committee
meetings, expenses of consultants, purchase necessary training materials,
and pay expenses in shipping ORP provided training materials and radia-
tion detection equipment to the site of training events. Since the
Regional Training Committees have not yet met, it is difficult to get
an accurate picture of the total cost. However, it is estimated that
the above funds would be necessary. In subsequent years, it would be
anticipated that each Regional Training Committee would submit a request
that would detail their estimated resource needs for the following year.
B-187
-------
Regions
In the optimum program, It will be necessary for the Regions
to play a very large role. It will be their prime responsibility to
provide close liaison with the States in order to ensure that ORP
utilizes its resources effectively in meeting the training needs.
Regional Training Committees
It will be necessary for one representative of each Regional
Office to be an ex-officio member on the Regional Training Committee
in his Region. In most cases, this representative should be the
Regional Radiation Representative. The reason for this is that he
would have the best idea of the radiation related problems in the
Region and, therefore, be able to be a very reliable contributor to
the solutions developed by the Regional Training Committee. His role
to the Regional Training Committee would include:
• Assist in the assessment of the training needs.
• Assist in the development of mechanisms to meet the needs.
• Inform the Regional Training Committee as to what resources
are available from EPA.
• Act as liaison between the Regional Training Committee and
the Office of Radiation Programs, and act as liaison between
the Regional Training Committee and the Research Office, partic-
ularly the Regional Training and Manpower Office.
• Provide technical assistance to the Regional Training Committee.
B-188
-------
States
The States play a very active role in the optimum program. The
States have much of the responsibility for adequate assessment of
training needs in this program.
Training Task Force
As a result of the Fourth Annual Conference of Radiation Control
Program Directors in May 1972, a task force was established to develop
mechanisms that would enable the accurate determination of training
needs and means to meet these needs in a timely and effective manner.
The Task Force is co-supported by ORF/EPA and BRH/FDA. Because
of the priority of the training issue, the Task Force held its first
meeting July 26-28, 1972, in Rockville, Maryland. The Task Force
recommended that Regional Training Committees be established to
determine and meet the radiation protection training needs.
It will be necessary for ORP to co-support the Training Task
Force with BRH/FDA. The total annual cost to ORP will be approximately
$2,000.
Regional Training Committees
The purpose of the Regional Training Committee in this program is
to objectively determine the radiation protection training needs in
the States within each Region and the Region as a whole. Secondly,
the Regional Training Committees are to develop and plan appropriate
mechanisms to meet the demonstrated training needs.
B-189
-------
As recommended by the Training Task Force, each Regional Train-
ing Committee would have the following responsibilities:
• To identify, quantitate, and place priorities on specific
training needs within the Region.
• To establish training activities, such as seminars, work-
shops, short courses, and training materials, for use within
the Region in meeting training needs.
• To coordinate with Federal, State, and local agencies,
industry, universities, and others to ensure that the State
radiation control program training needs are being met.
• To report to the Conference's Training Task Force on their
findings for the purpose of improving effective training
nationwide;
• To report to the Conference of Radiation Control Program
Directors annually on their findings, activities, and recom-
mendations regarding training.
The training Task Force would have the responsibility to monitor
the effectiveness of the Regional Training Committees and recommend
any necessary modifications to their operation.
The Regional Training Committees should be composed of a repre-
sentative from each State, territory, and local program in the Region.
The chairman of the Regional Training Committees should be initially
designated by the chairmanship of the Conference and serve for one
year. Thereafter, the chairmanship should rotate alphabetically by
B-190
-------
State, territory and local program in the Region. Ex-officio members
shall be Regional EPA and BRH/FDA representatives, Training Grant
Program Directors in the Region, as selected by the Regional Training
Committees, and any other representatives the Regional Training Com-
mittee believes appropriate. The chairman of the Regional Training
Committee shall call the meetings of the Committee and prepare an
agenda for each meeting. If additional resources are needed to meet
the Regional training needs, a request for assistance shall be pre-
pared according to the format shown in Table B-18, and forwarded to
EPA and/or BRH/FDA.
TABLE B-18
EXAMPLE FORMAT
REQUEST FOR TRAINING ASSISTANCE
Clearly state the problem.
Briefly state priority.
State training plan of the Regional Training Committee to meet
the problem.
State what assistance is requested from EPA and/or BRH/FDA.
Include budget if monetary assistance is requested, and time
schedule if formalized.
State anticipated benefit that will accrue if assistance is
granted.
B-191
-------
Other EPA Coordination
It will be necessary to coordinate all of the ORP training
activities with the Office of Training and Manpower in the Office of
Planning and Management. This coordination is necessary to ensure that
ORP makes effective use of the planning and overview capabilities of
0PM. Also, since the Office of Training and Manpower in 0PM is to be
the focal point for EPA training and manpower activities, this coordi-
nation will provide ORP input to them for dissemination throughout the
other EPA training activities.
It will also be necessary to coordinate the ORP training activi-
ties with the Office of Research and Monitoring since they will
maintain the research capability for the Agency. This coordination
will be used to obtain technical experts from ORM to participate in
training events and also to arrange for on-the-Job training at ORM lab-
oratories for State and Icoal control agency personnel.
Other Agency Coordination
ORP will have to maintain close coordination with the Bureau of
Radiological Health, the Atomic Energy Commission, the Department of
Labor, the National Institute of Occupational Safety and Health,
and a number of other Federal agencies. The purpose of this coordi-
nation is to ensure that there is no unnecessary duplication of train-
ing efforts and that the resources of the agencies can be effectively
used to accomplish mutual training objectives.
Private Sector Coordination
Coordination is necessary with the private sector for two reasons.
B-192
-------
An accurate inventory of private sector sources providing radiation
protection training must be maintained to effectively direct organi-
zations and persons needing training to the proper sources. A number
of experts from the private sector must be maintained on the Training
Review and Advisory Committee for the purpose of reviewing potential
academia grants and for advising ORP on its training activities.
The total cost for the optimum program for FY 73 is $142,000.
B-193
-------
PROPOSED PROGRAM
The proposed Office of Radiation Programs role in radiation
protection training has the same objectives as the Optimum Program.
The major differences in the two programs are the following:(l)The
Training and Special Problems Branch is not established in the
proposed program;(2)Regional Training Committees are initially estab-
lished on a pilot basis in three Federal regions rather than ini-
tially starting with all 10 Regions.
Headquarters
State. Regional, and Academia Liaison Office
To direct the ORP role in training activities, the State, Region,
and Academia Liaison Office would be established. The Office would
be composed of the following three personnel. The personnel require-
ments are based on needs up to FY 75. At that time, reassessment
would determine if staff expansion or reduction is warranted.
Operations Researcher Program direction, 6S-14
Regional liaison
Physicist/Engineer RTC, academia, & other GS-13
liaison, training pro-
gram development
Secretary GS-6/7
Total annual salary
cost $40,000
Equipment and Materials
Same as optimum program. Total cost - $8,000.
B-194
-------
Regional Training Committees
The purpose of the Regional Training Committees and the ORP
interface with them is the same as the optimum program. However,
in the proposed program only three Regional Training Committees are
established on a pilot basis to determine if this is a reasonable
and workable solution. Upon evaluation of their effectiveness, the
decision will be made whether or not to expand to all 10 Regions.
For FY 73, the following resources will be necessary:
Region III $5,000
«*
Region V 5,000
Region VI 5.000
Total cost $15,000
These resources can be used for the same purposes as in the
optimum program. The total cost for the proposed program for FY 73
is $63,000.
IMPACT OF PROPOSED PROGRAM COMPARED TO OPTIMUM
Proposed and optimum programs developed for the purposes of
meeting the radiation protection training needs are presented in
Table B-19. All major program elements are specifically designated.
B-195
-------
TABLE B-19
PROGRAM ELEMENTS FOR THE PROPOSED AND OPTIMUM PROGRAMS
Headquarters
Optimum Program
Proposed Program
Impact
6B
VO
Establish Training &
Special Problems Branch
Branch to be opera-
tional by 9/72
Begin assessment of
manpower supply & demand
Provide technical assis-
tance to States & Regions
in meeting training needs
Participate on Training
Task Force
Develop document detail-
ing EPA available
resources for assistance
to State (manuals,equip-
ment, etc.)
Continue current train- Immediate requirement
ing grants
Develop training pack-
age for State & local
authorities regarding
radiation accidents
Necessary by 3/73 for
current needs
No Branch established;
rather establish State,
Regional, & Academia
Liaison Office by 9/72
To be initiated by 11/72 Same
Immediate requirement Same
Immediate requirement Same
To be completed by 10/72 Same
Same
Same
Reduce the ability of
ORP to rapidly respond
to training problems,
also increases responsi-
bilities of ORP Divisions
to participate in train-
ing activities.
None
None
None
None
None
None
-------
\o
TABLE B-19
PROGRAM ELEMENTS FOR THE PROPOSED AND OPTIMUM PROGRAMS (Continued)
Headquarters
Establish Training Review
& Advisory Committee
Evaluate data from man-
power supply & demand
assessment
Radio frequency-
Microwave problem area -
Implement Federal, State
& Regional training
Radio frequency-
Microwave problem area-
implement training for
field facility personnel
Initiate up to 3 pilot
problem solution-
training grants
Optimum Program
Required by 1/73 to
review academia grant
application for FY 74
Required by 6/73 for
input into decision
about grant activities
Provide technical
guidance & instruction
starting 3/73
Technical information
& instruction required
for implementation of
field facility program
starting 10/73
Required by 8/73 to
solve ORP problem areas
& obtain information
on the desirability for
these combination grants
for input into decision
concerning ORP funded
academia grants
Proposed Program
Same
Same
Same
Impact
None
None
None
Same
None
Same
None
-------
TABLE B-19
\D
OD
Headquarters
PROGRAM ELEMENTS FOR THE PROPOSED AND OPTIMUM PROGRAMS (Continued)
Optimum Program Proposed Program Impact
Construction Materials
problem area - establish
newsletter for States &
Regions on problems
(emphasize problem areas,
i.e., mill site develop-
ments)
Construction Material
problem area- Seminar of
State Radiation Control
Program Directors on
Natural Radiation Problem
DECISION: Whether to
continue grants to
academia & in what forms,
training grants on prob-
lems solution-training
grants
Regions:
Provide technical assis-
tance from Regions to
States regarding training
Required by 1/73 to
limit unnecessary
exposures
Same
None
Seminar to take place
7/73
Same
None
Decision required by
2/74 for effect in the
75 school year
Same
None
Required immediately
Same
None
-------
«o
VO
TABLE B-19
PROGRAM ELEMENTS FOR THE PROPOSED AMD OPTIMUM PROGRAMS (Concluded)
Headquarters
Regions & States;
Optimum Program
Establish Regional Train- To be established in
ing Committee
States:
Establish Training Task
Force
each Federal Region
by 1/73
Immediate require-
ment was established
7/72
Other EPA Coordination;
Coordinate with ORM & 0PM Immediate requirement
Other Agency Coordination;
Coordinate with BRH, AEC, Immediate requirement
DOL, NIOSH
Establish joint train- Begin 3/73
ing activities
Private Sector Coordina-
tion;
Inventory private institu- Completed by 2/73
tions providing radiation
protection training
Proposed Program
Impact
To be established on Delay nationwide imple-
a pilot basis in 3 Fed- mentation about 1 year &
eral Regions by 10/73 possibly miss some train-
Regions 3,5, & 6 ing needs in that time
Same
None
Same
Same
Same
None
None
None
Same
None
-------
TAB 1
TABLE B-20
SHORT-TERM TRAINING
Total Number Total Number
Calendar Year of Trainees of Courses
1968 559 26
1969 568 33
1970 860 45
1971 678* 25
189 students were chiropractors participating in a one-day course.
B-200
-------
TAB 2
TABLE B-21
GRADUATE PROJECTS
1968 - 1971 1970 - 1971
Total Students EPA Stipends Total Students EPA Stipends
Masters 309 194 '106 74
Ph.D. 155 69 55 28
Total 465 263 161 102
Technician Projects*
1968-1971 1970-1971
Bachelors 24 8
Associate 214 82
Total 238 90
*For Technician training, EPA funds only tuition fees.
NUMBER OF GRADUATES FROM EPA SPONSORED ACADEMIC TRAINING PROJECTS
B-201
-------
TABLE B-22
HISTORY OF THE TRAINING GRANTS PROGRAM
Year
1962
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
Number of
Specialist
Grants
20
31
35
35
34
32
31
30
35
31
13
Number of
Technician
Grants
0
1
10
10
8
9
9
7
7
7
3
Total
Appropriation
$1,000,000
2,000,000
2,500,000
2,500,000
2,500,000
2,500,000
2,500,000
2,000,000
2,000,000
2,000,000
800,000
9-202
-------
TABLE B-23
INSTITUTIONS RECEIVING GRANTS
Institution
Active Technician Training Grants;
Central Florida Junior College
Oklahoma State University
University of Tennessee
Grant Number
00073-07
00080-06
00081-03
Cumulative Funds
to 12/2/70
174,662
268,411
47,305
Active Specialist Training Grants;
University of Florida (Eng.) 00046-10
Georgia Institute of Technology 00048-10
Harvard University 00049-09
University of Michigan 00054-10
University of Minnesota 00055-10
New York U. Medical Center 00056-11
University of North Carolina 00057-11
Northwestern University 00059-08
University of Oklahoma 00060-08
Rensselaer Polytechnic Institute 00065-10
Rutgers University 00066-10
Texas A&M 00069-03
University of Texas 00070-10
425,126
402,797
374,876
$1,045,432
428,594
743,036
572,810
552,269
591,763
577,156
. 628,275
71,993
343,616
Pending Specialist Training Grants;
University of Kentucky 00083-01A1
Washington State University 00085-01A1
Howard University 00086-01
Yale University 00115-01
Oregon University 00126-01
B-203
-------
TABLE B-24
EPA FUNDING GRADUATE TRAINING GRANTS
Number and Grantee
00046
00048
00049
00054
00055
00056
00057
00059
00060
00065
00066
00069
00070
U of Florida (Eng.)
Georgia Inst. of Tech
Harvard University
Univ of Michigan
Univ of Minnesota
NYU Medical Center
U of North Carolina
Northwestern Univ
Univ of Oklahoma
Rensselaer Poly Inst
Rutgers University
Texas A&M
University of Texas
Awarded
FY 71
$ 37,025
*
76,193
115,818
60,482
*
57,621
79,952
*
0
53,516
43,340
43,511
Awarded
FY 72
$ 42,215
83,256
0
76,069
55,686
69,080
64,233
80,028
83,198
66,719
69,126
16,476
0
Proposed
FY 73
$ o
54,500 '•*
15,000
0
56,000
69,000
52,000
0
24,900
43,000^
50,000
0
18,500
*FY 71 funds were awarded by DHEW/BRH before transfer to EPA, as
follows:
Georgia Institute of Tech - $57,670
NYU Medical Center - $67,568
University of Oklahoma - $84,388
Technician Training Grants
00073 Central Florida Jr. $ 18,194 $ 24,468 $ 24,500
00080 Oklahoma State Univ 42,892 37,017 37,000
00081 Univ of Tennessee 18,180 29,440 0
B-204
-------
TAB 3
COMPUTATION OF ORP'S TRAINING PRIORITIES
To assist in providing an answer to what EPA's involvement should
be in short-term training, it is necessary to generate relative priori-
ties for organizations needing radiation protection manpower and
training. These priorities were developed by answers to the following
questions:
1. Who needs short-term radiation protection training? The
answer to this question is on Figure B-27 in Tab 3, which is a detailed
list of all organizations that require some type of radiation protection
expertise.
2. What are the areas in which the training is needed? To answer
this question, the matrix in Table B-25, Tab 3, was developed. The
columns of the matrix represent the most important organizations needing
radiation protection manpower and training. The rows of the matrix
represent the problem areas in which capabilities are needed. An "X"
in a box indicates that the particular problem area is of significance
to the organization and is or may be an area where training could assist
in solution to their problems.
3. What type of function would the training be applied to in
reducing population and environmental exposures? To evaluate this
factor, all potential radiation protection functions have been gener-
alized into five categories:
• regulatory,
• standards,
• operations,
B-205
-------
ORGANIZATIONS REQUIRING RADIATION PROTECTION KANPOVER'AKD TRAINING
T
to
8
FIGURE B-27
ORGANIZATIONS REQUIRING RADIATION PROTECTION MANPOWER AND TRAINING
-------
TABLE B-25
ORP PtDBLEM AREAS
1-1
Organizations
Dept.ofDef en.
bur. ot Rad.
Health
DoL.& NIOSH
Natl.Inst.of
AEG
DOI
HUD
DOT
DOC
NASA
TVA
Health Dept.
{St. & L\
EPA (St.&Loc;.
Fireman &
Policemen
Academia
ytilities
Reactor Vend.
KSdioTLsotope
Rad. Prot.
Medical Fac.
R&D Organiz.
Civil Defense
ffirl/)
V
4-
C
a
'f
f
X
X
X
Y
x
X
X
x
x
cX
x
x
„
X
x
x
X
x
I
x
x
X
Y
x
X
X
x
X
Fuel Reprocessing
X
x
x| x
x
x
x
x
x
x
X
x
x
x
X
Plowshare
X
x
X
x
Tr i t ium-Thermonuc
X
y
X
x
X
Microwave
X
X
x
X
X
y
X
x
y
X
Const. Materials
X
X
x
Fabrication-
T5 1 11 -l-r^i-» i iim
X
y
I
X
x
x
X
i :
c-
0 I
•H (
4JJ
to :
Hr
OH
a
0
X
x
y
X
X
x
y
x
y
X
Radiofrequency
X
x
x
X
X
y
X
x
x
X
C E
o :
H-r
4J (
(0 r
a"
o
X
y
X
X
x
y
x
y
X
Medical Isotope
X
X
y
y
x
x
x
X
Occunational
X
x
X
y
y
X
X
y
x
...
x
y
x
y
X
Medical X-ray
X
X
y
•
y
y
y
x
x
X
Weanons Testing
X
y
•
x
in
rHD
•HC
•H-r
"Sf-
\
c
•H
c
•H
s
x
y
X
X
x
Fabrication-"
1 TlY-=>n i urn
X
V
X
x
x
x
1 Transportation
X
X
X
X.
x
X
x
X
y
y
y
X
y
y
y
x
r-i
(U
(3
H
EH
H
•H
x
X
x
Laser & Other E-M
X
X
x
X
X
y
X
x
Y
x
.
1
i
i
"
( Organization's* - Requiring Radiation Protection Manpower &
Training vs the ORP Problem Areas in which the manpower and
training are required.
•Excluding the Environmental^Protection Agency.
B-207
-------
• research and development, and
• general information.
The organization-problem area matrix is utilized for evaluation of
this factor by placing the appropriate number in each matrix box that
will correspond to the respective function. It should be noted that
only the highest priority function is denoted by the number, i.e., if
an employer category performs both a regulatory and R&D function, then
only the number 1.25 will be denoted in the matrix. (See Table B-26,
Tab 3).
4. Who is involved in providing short-term radiation protection
training? This question was answered by generating the comprehensive
list in Figure B-28, Tab 3, which identifies the majority of organiza-
tions that can provide some type of radiation protection short-term
training.
5. What areas can they provide training? This question is answered
by creating the matrix in Table B-27, Tab 3, which is similar to the
matrix in Table B-25, Tab 3. The columns and rows of this matrix
denote the same categories as Table B-25, Tab 3. The difference is
that training in certain problem areas which is provided by the organi-
zations on the right are depicted by an "X" in each appropriate box.
The matrices, Tables B-25 and B-27, Tab 3, can be used to correlate
those who need training in specific areas and the function they need
it for to those who can provide training in specific areas.
To establish relative priorities for those who need training from
our standpoint, the matrix is utilized to generate numerical values for
B-208
-------
TABLE B-26
ORGANIZATIONS
-
Accidents
Vasce Disposal
Fuel P.epro
Piovshare
Tri - Tiicrconu
"icrovave
Const "atl
fab - PU
Ops - PJ
.'*.a:io£requcncy
Ops - L'ran
:'.<4 Isotope
Occupational
:'-.i! X-ray
c-.aps Test
•!ir.:::m Tail
Fab - Iran
Trans
Air Travel
Laser t, SI
UKP Priority
8
6
6
6
6
5. 4
4.5
4.5
4.5
4.1
3.6
3
3
3
1.5
1.2
1
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.5
.3
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2
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1.6
1.9
2.3
2. 4
2.2
1.8
2.4
2.3
2.1
1.9
1.7
1.5
1.3
1.9
2.3
2.3
2.3
1.8
2.5
1.8
Prograa Constraints
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ORGANIZATIONS PROVIDING OB SUPPORTING RADIATION PROTECTION TRAINING
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FIGURE B-28
ORGANIZATIONS PROVIDING OR SUPPORTING RADIATION PROTECTION TRAINING
-------
TABLE B-27
ORP PROBLEM AREAS
nnn
BRH
NIOSH
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AEC
Other Federal
Health Dept.
(S&L)
EPA (S&L)
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Academia
Utilities
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Organizations* currently providing Radiation Protection
Training vs the ORP Problem Areas in which the training is
provided.
•Excluding the Environmental Protection Agency.
ORP-EPA
8/15/72
,B-211
-------
the following factors. The product of these factors will then be the
priority.
1. Relevance to EPA/ORP programs and mission. This factor is
equal to the problem area priority rating as established by the ORP
program document. Therefore, depending on applicable problem areas,
the priority rating would range from 8.0 to .25. The rating for each
category and problem area is shown in Table B-26, Tab 3.
2. Training availability from sources other than EPA. This
factor can be derived from Table B-27, Tab 3. For each problem area
in which training is readily available from some source, the priority
is 1; for each problem area where the training is totally unavailable,
the priority is 2.5. Since there are 15 organizations providing
training, the rating is from 1 to 2.5, depending on the number
providing training in a particular area. The numbers of values for
each problem are shown in Table B-26, Tab 3.
3. Potential effectiveness in reducing exposure. The purpose of
this factor is to allow consideration for the eventual result of the
training when it is applied in the organization. The factors relating
to the function to which the training will be applied serve for
numerical values for this factor. The range for this is 0 to 1.25 in
increments of .25. The factor increases in value from general infor-
mation on through regulatory function. These values are shown in Table
B-26, Tab 3.
4. Program constraints in obtaining necessary training. The
purpose of this factor is to consider the problems that a program or
B-212
-------
employer category might have in obtaining needed training. This
value ranges from 0-2 where 0 indicates essentially no constraints,
i.e., sufficient funds are available and necessary authroizations for
training can easily be obtained. A value of 2 would inidcate essen-
tially the opposite. The values of this factor for each organization
are shown in Table B-26, Tab 3.
. The final priority for each employer category is then obtained
by summing the priorities for each problem area. These priorities
are listed in Table B-28, Tab 3.
The organizations are listed in Table B-29, Tab 3, according
to computed priority.
B-213
-------
TABLE B-28
ORGANIZATIONS
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Waste Disposal
Fuel Repro
Plovsharc
Tr - Thcmonu
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Ops - PU
Radlofrequcr.cy
Ops - Uranium
Occupational
Mod X-ray
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Min & Mill Tail
Fab - Uran
Air Travel
Laser & Dl
SUSS
Pro Const
Outcoae
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6
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2.3
2.4
2.2
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2.4
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1.3
1.9
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2.3
2.3
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10.8
9.9
7.3
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2.8
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8.8
11.1
9.7
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1
2.9
3.4
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9.7
1.5
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24.8
8.8
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2.8
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16.5
13.0
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6.6
4.9
3.9
2.8
18.2
.5
9.8
3
8.8
5.8
2.8
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.9
29.3
.5
14.6
8.8
7.1
4.6
2.8
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17.1
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4.1
9.7
4.9
7.1
.7
48.2
2.0
96.9
I
4.1
10.3
10.8
8.1
7.8
7.1
9.7
4.6
3.4
1.7
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85.5
2.0
171
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tu
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-------
TABLE B-29
LIST OF ORGANIZATIONS REQUIRING RADIATION PROTECTION TRAINING
ACCORDING TO COMPUTED PRIORITY
List of Organizations Requiring Radiation Protection Training
According to Computed Priority
ORP Training
Organizations . Priority
Environmental Protection Agencies (State & local) 171
Health Departments (State & local) 96.9
Academia 37.5
Research and Development Organizations 32.1
AEC 31.8
Medical Facilities 30.1
Radiation Protection Consultants 29.3
Department of Labor 24.8
National Institute of Occupational Safety & Health 24.8
Firemen and Police 20.8
Civil Defense (State and local) 20.8
Tennessee Valley Authority 17.1
Reactor Vendors 15.3
National Institutes of Health 15.1
Department of Defense 14.8
National Aeronautics and Space Administration 14.6
Bureau of Radiological Health " 13.6
Radioisotope Producers 13.4
Department of Commerce 9.8
Utilities . 8.5
Department of Housing and Urban Development 6.7
Department of the Interior 6.1
Department of Transportation 1.8
B-215
-------
TAB 4
TRAINING GRANTS AND FELLOWSHIPS
FINDINGS AND RECOMMENDATIONS
Introduction
There are currently within EPA seven grant programs to support the
training of individuals for careers relating to environmental protection.
These programs having a total appropriation of approximately $10 million
are presently administered by four of the five media offices (Pesticides
Office excluded). Four of the programs (Solid Waste Management Training
Grants, Air Pollution Control Manpower Training Grants, Radiation Training
Grants, and Water Quality Training Grants) award project grants to insti-
tutions to support specific training programs and two of the programs
(Water Quality Research Fellowships, and Air Pollution Special Fellowships)
provide fellowships directly to students for advanced study. The seventh
program, Water Hygiene Training, is no longer an active program.
Most of the training grants and all of the fellowships are awarded
to support graduate and post-graduate study. There are also some sub-
professional training programs supported through the grant mechanism. It
should be emphasized that only those training programs supported by grants
were investigated by the Task Group. The investigations did not include
in-house training operations and the recommendations resulting from the
investigation do not necessarily apply to in-house training operations.
Current
The active EPA training grant programs are outlined briefly below.
Detailed program descriptions are presented as appendices J through P to
the report.
B-216
-------
The Water Quality Training Grant Program, with a FY 1971 appropri-
ation of $4,625,000, is the largest of the programs. During FY 1970 the
program supported 88 training projects and provided direct stripend sup-
port to 722 trainees. Both professional and sub-professional training
curricula are supported by this program.
The Air Pollution Control Manpower Training Grant Program has a
FY 1971 appropriation of $3,300,000. In carrying out its purpose to
develop individuals for careers in air pollution control, the grant
program in FY 1970 supported 47 training projects and provided stripend
support to 415 trainees.
The training grant program administered by the Radiation Office is
that part of the Radiological Health Training Grants program which was
assigned to EPA as a result of the reorganization. This program's FY 1971
appropriation is approximately $800,000. The program supports projects
at two academic levels, radiological specialist (graduate) and radiation
technician (undergraduate).
The Solid Waste Management Training Grant program has a FY 1971
appropriation of $490,000 and supports thirteen programs at universities
throughout the country. The programs supported are designed to produce
professionals for solid waste management careers at the graduate or post-
graduate level.
The two fellowship programs (Air Pollution and Water Quality) have
a combined FY 1971 appropriation of $900,000. They are designed primarily
to educate individuals interested in research careers. The Water Quality
B-217
-------
Fellowship Program is currently supporting 105 fellows. The Air Pollu-
tion Control Special Fellowship Program is rather dormant at present
and is not considering new applications for FY 1971.
Although variations do exist, all of these programs are administered
similarly in that outside consultants are utilized for review purposes
and that in-house staffs are maintained within the media offices for
programmatic input and administrative duties. Also, in most of the
programs the awarding of grants and the monitoring of active projects
is the responsibility of headquarters staff as opposed to regional staff.
The policies and regulations governing the administration of these pro-
grams differ considerably between the former DHEW agencies and the Water
Quality Office grant programs.
Assumptions
In developing the recommendations contained in this report, the
Task Group worked under the assumptions outlined in the introduction
and in addition under the following:
• The objective of the various manpower training grant programs
is to increase the number of qualified professionals and para-
professionals in those environmental fields which are most defi-
cient in qualified personnel.
• It is desirable that all training grant regulations and policies
should be standardized throughout EPA.
• It is desirable that the Environmental Protection Agency assume
the visibility necessary to enable it to function as the focal
point for all Federal environmental control activities.
B-218
-------
• The end result of the investigation should be a procedure which
would satisfy the above assumptions, but not sacrifice those
reviews and controls necessary to achieve national manpower and
training objectives.
The task Group believes that EPA must develop a stron professional
training program to provide the individuals needed to carry out broad
environmental protection programs at the local, State and Federal levels
of government. It also believes that implementation of the attached
recommendations will produce a strong program.
Findings and Recommendations
Setting Priorities for Manpower Needs
Finding; The actual manpower needs are not considered by the
agencies in awarding and supporting professional training grants. The
evaluation procedures contain no formal input which is addressed to the
related national need for the personnel to be trained by the proposed
programs. With the exception of the Water Quality Office, no office
has any continuous manpower assessment activity. The Water Quality
Office's program is still in its in.fant stage and has yet to produce
significant quantitative information. The Air Pollution Control Office
recently produced a report on manpower and training needs for national
air pollution control activities. However, this report is the result
of a one-time concentrated effort rather than a continuing activity.
There exists a need for an activity which will develop and maintain
statistics and projections on present and future manpower needs for
the environmental professions and sub-professions and set manpower
training priorities for use by EPA.
B-219
-------
RECOMMENDATION; THESE SHOULD BE ESTABLISHED WITHIN THE OFFICE OF
THE ASSISTANT ADMINISTRATOR FOR PLANNING AND MANAGEMENT A MANPOWER
ASSESSMENT ACTIVITY TO SET PRIORITIES ON MANPOWER TRAINING FOR ENVIRON-
MENTAL PROFESSIONALS AND SUB-PROFESSIONALS.
Provision for Broad Environmental Training Programs
Finding; All training now supported by the Environmental Protec-
tion Agency is related to satisfying legislative requirements of the
categorical offices. These requirements are related to categorical
manpower needs and are not necessarily intended to provide .the personnel
for those areas most deficient in trained manpower as a national priority
need.
Consequently, there currently exists no mechanism to support either
general environmental training programs or specialist training programs
not related to specific environmental categories. Although there is
certainly an existing and increasing need for categorical specialists,
it appears that too much emphasis is currently being given to develop-
ing these categorical specialists as opposed to developing professionals
with a more general background in environmental studies. Several
grantees expressed a need for a grant to support general environmental
studies, or "broad brush" programs, as well as a need for trained pro-
fessionals to fill legal, planning , and administrative positions which
do not require highly specialized technical training but do require a
well founded background in environmental studies.
B-220
-------
RECOMMENDATION; A CENTRAL MECHANISM SHOULD BE ESTABLISHED WITHIN
THE EPA HEADQUARTERS TO SUPPORT BROAD MULTIMEDIA ENVIRONMENTAL TRAINING
PROGRAMS ACCORDING TO THE PRIORITIES DEVELOPED BY THE MANPOWER ASSESS-
MENT ACTIVITY WITHOUT REGARD TO CATEGORICAL REQUIREMENTS.
Standardization of Training Grant Procedures
Finding; The regulations, policies, application processes, forms,
and reporting procedures differ considerably between the former Public
Health Service, DHEW, agencies and the Water Quality Office. For
example, there are minor differences, such as the number of copies of
applications required, as well as more serious differences, such as the
approval authority for trainees. A ma^jor discrepancy between the pro-
grams is the difference in level of student financial support allowed.
The Water Quality Office program provides a base stripend of $2,400 per
year while the former DHEW programs provide a base stripend of $3,000
per year.
The reporting and application requirements of both systems were not
considered burdensome by the grantees contacted. It was found that the
required reporting was looked upon by the grantees as convenient assess-
ment points which could be utilized equally as well by them as by the
funding agencies.
RECOMMENDATION! THE GRANTS ADMINISTRATION DIVISION SHOULD IMMEDI-
ATELY UNDERTAKE TO STANDARDIZE ALL REGULATIONS, POLICIES, FORMS, AND
REPORTING PROCEDURES RELATING TO THE ADMINISTRATION AND MANAGEMENT OF
TRAINING GRANTS SUPPORTED BY THE ENVIRONMENTAL PROTECTION AGENCY.
B-221
-------
Consolidation of Training Grant
Finding; There presently exists no identifiable national program
for training professionals in all the environmental disciplines. This
is not to say that professional training programs do not exist - but
that there is no coordination or central guiding function to achieve
program consistency and national manpower objectives.
There are many similarities in the professional training grant
programs:
• The programs are all administered and managed in branch level
units,within the headquarters of each of the line offices.
• There is a significant degree of commonness in the courses
supported by each of the programs.
• The stated purposes of the programs are very similar in that
all are dedicated to increasing the number of trained environ-
mental professionals.
Implementation of the above recommendation to establish broad
training programs would establish another organizational unit to admini-
ster broad training grants. In this event, the EPA professional training
and manpower programs would be administered by five individual units;
four within the categorical offices and one within the EPA headquarters.
Professional training must be operated from a position which can
minimize duplication and can meet training priorities consistent with
the EPA and national needs. Fulfillment of these needs is basic to
the concept of the establishment of the EPA. Only through a strong
central structure can it be demonstrated that the EPA is the primary
B-222
-------
organization responsible for professional environmental training in the
Federal government.
BE COMMENDATION; THE RESPONSIBILITY FOR AWARDING AND MONITORING
TRAINING GRANT PROGRAMS SHOULD BE VESTED IN A "TRAINING GRANTS DIVISION"
OF SIMILAR ENTITY UNDER THE ASSISTANT ADMINISTRATOR FOR PLANNING AND
MANAGEMENT.
Administration of Training Grants
Finding; Each of the categorical offices maintains a grants admini-
stration operation for its own grant progaam. The groups are similar,
each containing such positions as grants assistants, grants officers,
and clerks responsible for the non-programmatic aspects of training
grant administration. The various offices do vary in their involvement
with procedures. For example, the National Institutes of Health pro-
vide not only receiving and referral activities for all former DHEW
grant programs, but also provides the APCO services necessary to pre-
pare grant awards. This might be contrasted with the Water Quality
Office which has a much more self-contained activity. Regardless of
the individual variation, these activities appear to be unnecessarily
duplicative.
RECOMMENDATION; THE GRANTS ADMINISTRATION DIVISION IN THE OFFICE
OF PLANNING AND MANAGEMENT SHOULD HAVE RESPONSIBILITY FOR THE NON-PRO-
GRAMMATIC ADMINISTRATION OF TRAINING GRANTS.
Grant Review and Approval Procedures
Findings: There presently exists, within the various categorical
offices, a number of approaches to reviewing applications for technical
B-223
-------
merit. In every office, some form of organized consultant review
is utilized. The Solid Waste Management Office routinely visits all
applicants prior to review of proposals by a study section comprised
of qualified professionals from outside the government. The Water
Quality Office subjects all applications to review by in-house
research and development personnel and a panel of consultants.
Applicants are visited only after this initial review. The Air
Pollution Control Office utilizes a subcommittee of its full
advisory committee to determine which applicants should be visited,
and the visit is carried out prior to committee review. The
Radiation Office has a procedure similar to that of the Solid Waste
Management Office, but must subject all of its proposals to a second
review by the National Advisory Council for policy consideration
and approval. This second approval is required by law. The Task
Group recognizes the desirability of training grant application
review by outside consultants. The consultants provide: (1) a
technical input which is usually not available within the EPA; (2) an
external influence on the training grant program which is considered
refreshing and tends to counter stagnation; and (3) an avenue of
maintaining currency with the academic community. Another reason
for consultant review - to provide a convenient crutch for unpleasant
program decisions - is understandable. However, it appears that in
some instances the funding agency has willingly allowed the review
panel to assume decision making responsibility. This practice is
an abrogation of responsibility and must be considered a misuse of
B-22A
-------
the consultant or panel review mechanism.
The Task Group seriously questions the necessity for visiting
training grant applicants as a pre-requisite to approval. It is
recognized that some information might require on-site verification
or that personal interviews might be helpful. It is further recog-
nized that occasionally an institution may be new to the training
grant program and may be unknown to the agency and the consultants.
However, the in-house staff should certainly be well versed enough
to make a determination and if necessary visit the applicant to
provide any information the consultants deem necessary.
RECOMMENDATION. A ROSTER OF CONSULTANTS SHOULD BE ESTABLISHED
TO STAFF TECHNICAL REVIEW PANELS. THE COMPOSITION OF THE PANELS
WOULD BE ROTATED AT EACH MEETING. THE PANELS WOULD REVIEW EACH
APPLICATION FOR TECHNICAL MERIT ONLY, AND NOT BE EMPOWERED TO
MAKE RECOMMENDATION ON APPROVAL/DISAPPROVAL OR FUNDING PRIORITY.
IT IS FURTHER RECOMMENDED THAT THE POSITION OF REVIEW MANAGER BE
ESTABLISHED WITHIN THE TRAINING GRANTS DIVISION TO PROVIDE LIAISON
BETWEEN THE PANELS AND THE AGENCY AND THAT THE POLICY OF ROUTINELY
VISITING APPLICANTS AS PART OF THE REVIEW PROCEDURE BE DE-EMPHASIZED.
IT IS FURTHER RECOMMENDED THAT APPROPRIATE LEGISLATIVE RELIEVE BE
SOUGHT TO ELIMINATE THE LEGAL REQUIREMENT OF COUNCIL APPROVAL AS A
PREREQUISITE TO FUNDING GRANTS IN SOME AREAS.
Training Grant Administration
Finding; Most of the personnel involved with the programmatic
review and monitoring of training grants stated that the removal of
B-.225
-------
the administrative responsibilities from the line office would
harm the quality of the program. This statement was based on the
belief that in order to produce desired results, each grant program
should be administered by program oriented people .rather than
non-technical administrators. Also, it was stated on numerous occasions
that the day-to-day relationship between the training grant activity
and the other activities within the line offices contributed to the
effectiveness of the training program supported by the office. The
Task Group agrees with the statement that individuals knowledgeable
in the program area relating to the training program should be placed
in a position of considerable authority in any organization to
administer the grants. However, the group could not verify the
necessity of the program individuals actually being located in the
line offices. The Task Group could not identify a strong correlation
between the overall objectives of the various offices and the
objectives of their training grant organizations.
V
RECOMMENDATION; THERE SHOULD BE ESTABLISHED WITHIN THE TRAINING
GRANTS DIVISION THE FUNCTION OF PROGRAM MANAGER, TO BE RESPONSIBLE FOR
PRE-APPLICATION ASSISTANCE TO APPLICANTS, REJECTING NON-APPLICABLE
APPLICATIONS, AND RECOMMENDING APPROVAL OR DISAPPROVAL OF APPLICATIONS.
Relationships with Grantees and Trainees
Finding: The Task Group was confronted, on several occasions, by
students claiming that their involvement with the agencies was rather
non-existent. This allegation was confirmed after talking with the
B-226
-------
administering offices which, primarily because of a lack of manpower,
maintained no relationship at all with the trainees. It appears
that the agencies are not realizing the full potential of the training
grant program by not maintaining close relationships with the trainees.
These trainees represent the "cream of the crop" of professionals
interested in environmental careers. The agencies could also serve
as a means of providing information to the trainees regarding employ-
ment opportunities available at various levels of government.
Similarly, several of the training grant directors expressed
feelings of isolation regarding their relationship with the funding
agencies. This, however, was not the dominant view. The agencies
have placed the grantees on mailing lists to receive agency publi-
cations and have attempted through a program of visists to keep the
training directors involved. The Solid Waste Management Office has
initiated a policy of holding an annual meeting of training directors
as a means of improving communication. These meetings have been
extremely well received. The Task Group recognizes the problems
inherent in keeping the directors informed, but also recognizes
the benefits both to the agencies and the training directors which
could be realized by better communications.
RECOMMENDATION; IT IS RECOMMENDED THAT THE PROGRAM MANAGER BE
GIVEN THE ADDED RESPONSIBILITY OF ESTABLISHING AND MAINTAINING
RELATIONSHIPS WITH TRAINEES AND PROGRAM DIRECTORS. IN FULFILLING
THIS FUNCTION, IT IS FURTHER RECOMMENDED THAT THE PROGRAM MANAGER
B-227
-------
VISIT THE TRAINEES AND PROGRAM DIRECTORS ANNUALLY AND INITIATE AN
ANNUAL PROGRAM DIRECTORS MEETING.
Review and Approval of Fellowship Applications
Finding; Fellowship programs to support post-graduate work are
currently supported by two of the Offices within EPA. The program
of the Office of Water Programs is very active, supporting approximately
100 fellowships. The fellowship program administered by the Office
of Air Programs has been de-emphasized. At the time of the Task
Group's interviews with the OAP staff, the Office was not planning
to award any new fellowships during FY 1971.
Applications for fellowships are subjected by OWP to a rather
extensive in-house desk review and to review by a panel of outside
consultants. It was found that OWP usually does not utilize the
results of fellowship research projects. Thus, the policy to submit
applications to such in-depth review seemed questionable. The Task
Group recognized the value of review of the application for technical
merit. However, it feels that equal consideration should be given
to the actual need for the specialty in which the individual is
being trained. The existence of this second consideration was not
obvious in the OWP review procedure.
It seemed to the Task Group that the Agency has received a
better return from its training grant funds than for its fellowship
funds. The program established by the grant funds trained many
individuals not receiving direct support from the Agency in the form
B-228.
-------
of stipends. However, the necessity of a fellowship program as a
supplementary program to train research professionals on an indi-
vidual basis is recognized.
RECOMMENDATION; REVIEW OF FELLOWSHIP APPLICATIONS FOR RESEARCH
CONTENT AND SCIENTIFIC MERIT SHOULD BE ASSIGNED TO THE CENTRAL
RESEARCH GRANT REVIEW PANELS ESTABLISHED UNDER THE ASSISTANT ADMINISTRA-
TOR FOR RESEARCH AND MONITORING. THE FINAL APPROVAL DECISION SHOULD
REST WITH THE DIRECTOR, TRAINING GRANTS DIVISION, BASED UPON RECOMMENDA-
TIONS OF THE APPROPRIATE PROGRAM MANAGER.
Notification of Regional Offices of Training Grants Awarded
Finding; With the exception of the regional Air Pollution Control
Offices, the regional offices have little involvement with the manage-
ment and administration of the training grant programs. The Air Pollu-
tion Control Regional Directors have recently been assigned the
responsibility of approving continuation grant applications. This
responsibility has not been accompanied by increased staff, so this
activity seems to be receiving a rather low priority by the regional
officials. The Task Group could not uncover much excitement either in
the headquarters administrative units or the regional offices concerning
regional participation in the training grant programs. Everyone inter-
viewed identified the training grant program as essentially national
in scope. Several Regional Directors expressed the desire to be
informed of grants approved, but did not think the regional office
should have any role in detailed review or approval of applications.
B-229
-------
The Regional Director and Regional Manpower Officers interviewed
did think that the regional offices could play some role, if
established by policy, in contacting those students who express a
desire to enter Federal service.
RECOMMENDATION; THE REGIONAL ADMINISTRATOR SHOULD BE INFORMED
OF ALL TRAINING GRANTS AWARDED IN THE REGION.
Review and Approval of Continuation Grant Requests
Finding; The procedures for approving non-competing continu-
ations vary considerably from office to office. The Solid Waste
Management Office and the Water Quality Office approve continuations
administratively and without technical review within the respective
headquarters office. The Radiation Office submits all continuation
requests to consultant review. The Air Pollution Control Office has
recently assigned the responsibility for approval of continuations to the
regional offices. Assigning approval of continuation grants to the
regions represents only an illusion of regionalization of authority
and actually imposes upon the regions an administrative chore devoid
of any real responsibility. Technical review of continuation requests
by panels is unnecessary since these grants have already been
evaluated for technical merit. An administrative review is, then, the
most expeditious method of determining disposition of already approved
and ongoing projects. Placement of this review and approval function
in the Program Manager would provide uniformity of review on all
continuation requests, and provide a means of identifying low-quality
B-230
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projects for which continuation should be disapproved.
RECOMMENDATION; THE PROGRAM MANAGER SHOULD HAVE THE RESPONSIBILITY
FOR REVIEWING AND APPROVING TRAINING GRANT CONTINUATIONS; THE DIRECTOR,
TRAINING GRANTS DIVISION, SHOULD HAVE THE RESPONSIBILITY FOR DISAPPROVAL
OF CONTINUATION REQUESTS UPON ADVICE OF THE PROGRAM MANAGER.
Observations
The body of this report, in pointing out deficiencies in the
existing grants administration procedures and recommending changes,
certainly does not give proper credit to the quality of personnel
in the various categorical training grant operations. These indivi-
duals, without exception, impressed the Task Group as extremely
knowledgeable in their respective areas of interest and very concerned
that EPA develop the strongest possible approach to producing the
trained personnel necessary to support the country's environmental
efforts.
In-house training activities were not within the purview of the
Task Group. Therefore, the recommendations included in the report
should not be interpreted as applicable to the in-house training
activities. The Task Group felt that the professional training grant
programs were sufficiently different from the in-house activities to
justify studying them separately. There exists a need for a similar
study of in-house training activities. Another area in the field of
manpower training which should be investigated by EPA is the Manpower
Development and Training Act program administered by the Water Quality
Office. Conceivably, other MDTA funds might be utilized for other
training programs within EPA.
B-231
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The Task Group found that all of the training grant programs are
tending to de-emphasize doctoral-level training in favor of terminal
masters level studies. Although the Task Group agrees with this
X
approach we believe that there is a danger that it is being followed
too far. The Task Group feels that support of the Ph.D. program should
be maintained at a level which will assure that approximately 10% of
the M.S. graduates will seek higher degrees to form the academic
and research core upon which future environmental education will be
based.
The Task Group was confronted on several occasions with the
proposal that the EPA should use its grant program to encourage the
creation of "centers of excellence" throughout the country. These
centers of excellence would consist of several schools in a geo-
graphical area developing combined curricula to exploit the parti-
cular advantages of the respective schools. The Task Group agrees
with this approach to environmental training and believes that a
few of these centers should be established for demonstration purposes.
It seems to the Task Group that such an approach to training pro-
fessionals would be more beneficial than attempting to establish
smaller programs throughout the country.
Several of the university and regional officials indicated that
there was a need for B.S. environmental engineers to fill positions
in communities which could not afford to pay M.S. engineering
salaries. Very few of the training grant programs support this type
B-232
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of study. The Task Group feels that the manpower assessment activity
(Recommendation No. 1) should give attention to this situation and
determine if such a need really exists.
The Task Group could not identify much support in those
universities having three or four training grants for the consolidation
of one grant, into one to ease reporting procedures. Most of these
grants were in different departments of the universities and for all
purposes, might as well have been in different schools. If EPA
adopts a policy of awarding grants based upon something other than
categorical requirements, then attention might be given to combining
the grants. However, consolidation to accomodate possible simplifi-
cation of reporting procedures does not seem to be justified at
this time.
B-233
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APPENDIX D
COORDINATION WITH OTHER AGENCIES
TABLE OF CONTENTS
Page
INTRODUCTION D-l
• U.S. BUREAU OF MINES D-l
Background D-l
Status D-l
Planned Action D-2
•NATIONAL ACADEMY OF SCIENCES D-2
Background D-2
Status D-2
Planned Action D-2
•NATIONAL AERONAUTICS AND SPACE ADMINISTRATION D-3
Background D-3
Status D-3
Planned Action D-3
•AEC, COAST GUARD, PUBLIC HEALTH SERVICE, MARITIME
ADMINISTRATION D-3
Background D-3
Status D-4
Planned Action D-4
•AEC, OEP, DCPA D-4
Background D-4
Status D-6
Planned Action D-6
•AEC, BRH, USPHS, U.S. AIR FORCE, ETC. D-6
Background D-6
Status D-7
Planned Actions D-7
• DCPA, DOT, DOD, AEC D-7
Background D-7
Status D-7
Planned Action D-7
•AEC, DOD, DCPA, USDI, COMM, DEPA D-7
Background D-7
Status D-8
Planned Action D-8
• ERMAC D-8
Background D-8
Status D-9
Planned Action D-9
• FCC D-9
Background D-9
Status D-10
Planned Action D-10
• DOD, COMM. D-10
Background D-10
Status D-10
Planned Action D-10
•INFORMAL RELATIONSHIPS D-ll
D-i
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APPENDIX D
COORDINATION WITH OTHER AGENCIES
INTRODUCTION
The nature of the problems involved in a radiation protection
program obviously suggest very close coordination with the Atomic Energy
Commission and the Bureau of Radiological Health. Other Federal agencies
have an interest in radiation and the ORP is involved with these pro-
grams through contracts, agreements( task forces, etc. These programs
are described below in terms of agency(s) involved, background informa-
tion, status, and planned action.
U.S. BUREAU OF MINES
Background
In the May 25, 1971 Federal Register, effective July 1, 1971, the
EPA published a standard of 4 WLM per year for exposure to radon and
its daughter in uranium and other mine atmospheres. The Bureau of Mines
of the Department of the Interior is responsible for enforcement of this
standard.
Status
The Bureau of Mines regulations presently include a 12 WLM per
year standard; however, these regulations specify that this standard
will be replaced by a standard which EPA promulgates. At this time
the Bureau of Mines 12 WLM standard has not been changed to 4 WLM in
their written regulations; thus, confusion exists with some States
which are responsible for day-to-day implementation of the standard.
D-l
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Planned Action
Discussions are continuing with the Bureau of Mines and DHEW in
order to insure that the A WLM figure is published as soon as possible.
It will be necessary for DHEW to provide background information to the
Bureau of Mines Advisory Committee concerning the basis for the 4 WLM
standard before the necessary change in the regulations can be effected.
NATIONAL ACADEMY OF SCIENCES
Background
ORP has a contract with the National Academy of Sciences to review
the adequacy of the basis for radiation risk evaluations utilized in
existing radiation standards. A report of the results of this review
is being prepared by a working group of the Academy.
Status
i
The first draft of the review report has been completed and is
under revision. Some disagreement exists among the members of the
working group concerning the content of the final report. This could
result in minority reports being issued with resulting confusion as to
the official position of the NAS.
Planned Action
CSD is working continuously with the Academy to obtain timely
publication of the report and resolution of possible issues prior to the
report's publication.
D-2
-------
NATIONAL AERONAUTICS AND SPACE ADMINISTRATION
Background
EPA and its predecessor DREW agencies have participated with NASA
and will continue to do so in the areas of safety analyses of proposed
isotopic power sources for space use and for operational safety assist-
ance for specific launches.
Status
At present a memorandum of understanding between NASA and EPA has
been negotiated which provides that EPA will furnish off-site safety
coverage for launches of space vehicles containing isotopic power sources.
It is possible that issues could arise in this regard if EPA adopts a
position indicating that a particular launch does not meet EPA's safety
criteria.
Planned Action
No specific actions other than continued operation under the
memorandum of understanding are anticipated.
AEC, COAST GUARD, PUBLIC HEALTH SERVICE, MARITIME ADMINISTRATION
Background
There is a four-agency agreement between AEC, the Coast Guard,
the Public Health Serivce, and the Maritime Administration in which each
of the agencies agreed to provide certain services in support of the
N.S.SAVANNAH operations. The Public Health Service support, which was
transferred to EPA, reads as follows:
The Public Health Service is responsible for the establishment
of standards, and inspection for conformance thereto, for
sanitary construction and sanitary operation of the SAVANNAH;
D-3
-------
for the review and approval of standards and instructions
pertinent to the control of radiation exposure of the crew
and passengers of the SAVANNAH and the public generally;
for the provision of medical, surgical, and dental care
and hospitalization for officers and crew at established
facilities; and for inspection and enforcement activities
covering the release of air and water-borne contaminants.
This agreement has been used extensively for the items specified.
In addition, emergency health physics services and health physics
training have been provided by USPHS.
Status *
Nuclear fuel has been removed and the N.S. SAVANNAH has recently been
mothballed at Savannah, Georgia. The need for further services on our
part has probably terminated. However, the agreement has not been
terminated.
Planned Action
Allow the agreement to reamin inactive and send the files to
permanent storage.
AEC, OEP, DCPA
Background
A meeting on Federal agency responsibilities for nuclear incident
planning was held with the Office of Management and Budget on June 15,
1972. Representatives from the Atomic Energy Commission (AEC), the
Office of Emergency Preparedness (OEP), the Defense Civil Preparedness
Agency (DCPA) and the Environmental Protection Agency (EPA) were
represented to discuss a proposal that the AEC assume the lead operational
role in nuclear incident planning activities among Federal agencies,
with OEF exercising general monitorship over these activities. An OEP
D-4
-------
draft paper was presented at the meeting as a basis for the discussion.
Mr. Silhanek of the Surveillance and Inspection Division, ORP represented
EPA at this meeting.
The Office of Radiation Programs has been involved with these
agencies in preparing a proposal for developing a model plan for handling
nuclear incidents at fixed facilities. The Office of Emergency
Preparedness was coordinating the Federal agencies involved in emergency
planning and selected Arkansas Nuclear One in Pope County, Arkansas <
as the facility to utilize in developing this prototype plan. Several
meetings have been held on this subject but no definite progress was
made because of a problem with the local Arkansas State agencies. There
was a question as to which State agency has the overall planning in the
State for emergency planning around nuclear facilities. This problem
has recently been resolved by a memorandum of understanding between
the local State agencies involved.
The OEP is now presenting a proposal that the AEC become the lead
agency to coordinate various Federal agencies in this activity. Our
Division does not feel that there is a problem in AEC taking this role
but some of the specific responsibilities delegated to AEC in the OEP
proposal will be in conflict with our planning in the Accident Problem
Area, our number one priority at this time. At the meeting with OMB
it was not felt to be the proper time or place to argue these points.
Hopefully these details can be handled in subsequent meetings or
memorandum with OEP and the other agencies involved.
D-5
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Status
A revised draft of the OEP proposal will be submitted to this
office for formal coordination. Since EPA policy involving possibly
the Director of EPA may be involved, this may become a critical issue.
OEP plans to send a letter outlining the responsibility of each agency
from the Director, OEP to the Director, EPA.
Planned Action
A meeting is being planned between all these agencies to resolve
these differences before a revised draft of responsibilities is sent
to ORP for concurrence.
AEG, BRH, USPHS, U.S. AIR FORCE, ETC.
Background
Under the Interagency Radiological Assistance Emergency Plan (IRAP)
we have agreed to provide rapid and effective radiological assistance
in the event of a radiological incident. The AEC is the coordinating
agency for this plan. Several government agencies are involved in
this plan.
Because of this responsibility ORP and BRH have a cooperative
agreement to provide emergency assistance utilizing five emergency teams
located in Cincinnati, Boston, Rockville, Montgomery and Las Vegas.
Under this plan the Public Health Service fulfills its agreement to
provide radiological assistance to the U.S. Air Force in case of inci-
dents involving nuclear weapons and materials. ORP and BRH by mutual
agreement have assigned the primary responsibility to the ORP for
providing emergency teams to respond to requests for radiological
assistance.
D-6
-------
Status
In cooperation with BRH, upon request, ORP will provide assistance
in the event of a nuclear incident.
Planned Actions
Continue to be prepared to respond to all requests for assistance.
DCPA. DOT. POD, AEG
Background
ORP has agreed to provide a member to the Incident Information
Study Group of the Interagency Committee on Radiological Assistance
(ICRA). The five members are from the Defense Civil Preparedness
Agency, Department of Transportation, DOD, AEG, and ORP. The task of
the study group is to identify organizations that receive reports on
incidents and formulate a method to dessiminate this information to
other agencies and the public.
Status
This task force has not met at this time.
Planned Action
Continue to participate in this study.
A£C. DOD. DCPA. USDI. COMM. DEPA
Background
ORP is involved in making recommendations on safety inspection,
posting and damage surveys of nuclear installations in the event of a
disaster due to an earthquake. The other agencies involved in this
D-7
-------
endeavor are AEG, DOD, Defense Civil Preparedness Agency, Department
of Interior, Department of Commerce, and the Defense Electric Power
Administration.
Status
Several meetings have been held and recommendations have been
submitted to OEP.
Planned Action
Continue to participate in this study.
ERMAC
Background
Coordination of the nonionizing radiation activities is through
the Electromagnetic Radiation Management Advisory Council. The ERMAC
was formed in 1968 to advise the Director, Office of Telecommunications
Policy, and to make recommendations on potential side effects on the
environment, biological and physical, and the adequacy of control of
electromagnetic radiation. In December 1971, after comprehensive
assessment of current knowledge programs, and potential problems, the
Council working with Federal agency observers recommended a "program
for control of electromagnetic pollution of the environment: the
assessment of biological hazards of nonionizing electromagnetic
radiation." The EPA observers on the ERMAC are Dr. William Mills and
Mr. David Janes.
The Agencies involved are: Agriculture, Atomic Energy Commission,
Central Intelligency Agency, Commerce, Defense (Director of the Division
D-8
-------
of Research and Evaluation, U.S. Army, U.S. Navy, U.S. Air Force),
Transportation (Federal Aviation Administration), EPA, Federal Comm-
unications Commission, Health, Education, and Welfare, Interior, Labor,
NASA, National Science Foundation, Office of Telecommunications Policy,
U.S. Information Agency, and Veterans Administration.
Status
Recently, an interagency working group on biological effects of
nonionizing electromagnetic radiation was formed to serve as an intra-
government coordination mechanism for the ERMAC program. It has been
made a part of the Side Effects Working Group of the recently reconsti-
tuted Technical Subcommittee of the Inter-departmental Radio Advisory
Committee. This body is comprised of representatives designated by
the heads of Agencies with a role in the ERMAC program.
Planned Action
Coordination will be continued through direct participation with
the interagency working group on biological effects of nonionizing
radiation.
FCC
Background
In 1971 we were invited by the FCC to participate in the Radio
Technical Commission for Marine Services, Special Committee 65 on Ships
Radar. ORP participation is for the purpose of providing advice on
the hazard potential and biological effects of small boat radars.
D-9
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Status
A preliminary evaluation has been provided to the committee.
Planned Action
OKP is awaiting additional information on sources and source
parameters prior to providing a complete analysis.
POD. COMM.
Background
There are two organizations which have computer data on the location
of the most electromagnetic radiating devices in the United States—
the Electromagnetic Compatibility Analysis Center (ECAC), DOD and the
Office of Telecommunications, COMM. In the past, data from ECAC has
been obtained through the Twinbrook Research Laboratory, Rockville,
Maryland. Since the laboratory is moving to North Carolina, ORP will
need to establish direct contact with ECAC and/or the Office of
Telecommunications.
Status
An interagency agreement with ECAC has been prepared for concurr-
ence by the respective agencies.
Planned Action
Execute the interagency agreement with ECAC when FY 73 funds
become available and develop an interagency agreement with the Office
of Telecommunications.
D-10
-------
INFORMAL RELATIONSHIPS
ORP (CSD) has established close working relationships with a number
of agencies and anticipates similar relationships with additional
agencies as indicated in the following listing. These relationships
do not constitute issues as such but are more in the order of day-to-
day cooperation at the working level:
• DOD - Surveys of radiation exposure in aerial flights using
military aircraft, and participation along with AEC in clean-
up Bikini and Eniwetok and other trust territories.
• NBS - Informal day-to-day contacts concerning dose modeling.
• NCR? - Contractural arrangements plus day-to-day working
relationships concerning development of guidelines and
related information.
• OEP - Coordination of responses to radiation emergencies.
• HUD - We anticipate working closely with HUD concerning the
control of population distribution and density around nuclear
facilities.
D-ll
-------
APPENDIX E
LEGISLATION
TABLE OF CONTENTS
Page
LEGISLATION E-l
LIST OF TABLES
TABLE NUMBER
Pace
E-l SUMMARY OF LEGISLATIVE STATUS E-2
E-i
-------
APPENDIX E
LEGISLATION
The principle federal legislation, that serves to protect the
population from the consequences of radiation, has been assembled
over the last 20 years. Some acts specifically address radiation,
others address general effects that include radiation. The many
acts distribute a complex set of responsibilities between numerous
federal agencies.
The manner in which the various acts distribute this authority
between the various activities of ORP, and between the 18 "problem
areas" is shown in Table E-l.
Under the President's Reorganization Plan //3 of 1970, the
responsibility to advise the President on all matters of radiation
policy was transferred from FRC to EPA. The proper conduct of this
responsibility, during a period of rapid growth in radiation-
generating industries, will require a continuous program of data
acquisition and analysis that is exhaustive in its coverage and
systematic in its formulation. The programs of Monitoring, Strategic
Studies and Risk/Cost/Benefit Analysis are designed to meet this
requirement.
Responsibilities charged to the DHEW under the United States Public
Health Serivce Act (USPHS Act), and transferred to EPA under the National
Environmental Protection Act (NEPA) specifically require environmental
monitoring, collection and analysis of data pertinent to the current
use and future regulation of radiation sources. The responsibilities
include monitoring and analysis in the event of accidents and for
E-l
-------
tfl
to
TABLE E-l
SUMMARY OF LEGISLATIVE STATUS
PROBLEM AREA
Accidents
Disposal
Fuel Reprocessing
Plowshare
Thermonuclear
Microwave & RF
Construction Materials
Fabrication - Plutonium
Operation - Plutonium
Operation - Uranium
Medical Isotope
Occupational
Medical X-ray
Device Testing
Mining & Mill Tailings
Fabrication - Uranium
Transportation
Laser & Other Electro-
magnetic Radiation
EXISTING AUTHORITY
PRESIDENT'S
REORGANIZATION
PLAN *3 of 1970
ATOMIC
ENERGY
ACT OF
1954
G
G
G
G
G
M.G
G
C
EXECUTIVE
ORDER
10831
(FRC)
P
P.M.G
P,G
P,G
.
P
P,G
P,G
P
P.G
P
P
P
P,G
P.G
P,A
P,G
P
P.G
* •**
USPHS
ACT
AND
NEPA
M
G
M
M
M
M
M
M,S
M
M
G
RECOURCE
RECOVERY
ACT
1970
S
P.L.
91-606
(DISAS-
TERS)
A
PROBABLE NEED
FOR
ADDITIONAL
* LEGISLATION
None
None
None
Authorize AEC to
promote commercial
NGS
None
None
Enforcement Authority
Needed
None
None
None
None
None
None
None
None
None
None
None
LEGEND:
M • Monitoring & Evaluation
G ° Guidance & Standards
E « Enforcement
P " Policy Advice
A • Emergency or Technical Assistance
S • Other Specific Duties
-------
the special considerations of transportation.
The Atomic Energy Act of 1954 gave the AEG authority to issue
standards for the safe use of radiation sources at nuclear power
plants and for the use anywhere of specific radioactive products
of power plants. Executive order 10831 of 1959, vested authority in
the FRC, for issuance of guidance and standards for a wide range of
radiation sources outside the power industry. Under the USPHS Act the
DREW was vested with authority to issue standards for certain, nonionizing
radiation sources.
In 1970, the NEPA and Presidents Reorganization Plan No. 3
consolidated this authority (with the exception of the supervision
of sources within nuclear power plants) within EPA.
Under the USPHS act DHEW was responsible for a comprehensive
radiological surveilance and safety program in the offsite areas
adjacent to the Nevada Test Site. NEPA transferred this responsibility
to EPA.
The NEPA requires that federal agencies prepare environmental
impact statements (EIS) for the projects they sponsor. EPA must
review these EISs.
The Recource Recovery Act of 1970 created authority, first
vested in DHEW and later transferred to the Office of Solid Wastes
(OSW), EPA, to develop a comprehensive national plan for the disposal
of solid wastes. ORP will advise OSW on the disposal of radioactive
materials.
E-3
-------
Public Law 91-606 gives the President certain discretionary
powers to deploy the resources of the U.S. Government in order to
aleviate an impending disaster. In the event of a disaster involving
radiation, the recourses of the ORP would be so deployed.
E-4
-------
APPENDIX F
PRIORITY COMPUTATIONS
TABLE OF CONTENTS
Page
DEVELOPMENT OF PROBLEM AREA PRIORITIES F-l
LIST OF TABLES
TABLE NUMBER Page
F-l PRIORITY FORMULA DATA F-2
F-2 PRIORITY RANKING FACTORS F-3
F-i
-------
APPENDIX F
DEVELOPMENT OF PROBLEM AREA PRIORITIES
The four scale factors shown in Table F-l were selected for each
problem area based on the best available Information on population
at risk, exposure conditions, control mechanisms which can be exercised
or influenced by ORP and projected risk as a function of time.
From the ranking factors derived, short-term (Table F-2) and
long-term (Table F-3) priorities were assigned as in Section I of
the main report.
F-l
-------
TABLE F-l
PRIORITY FORMULA DATA
• EXPOSURE CONDITION SF*
An Irreversible potential '
exposure condition results. . 5
An acute (timewise) high '
level, short-tern potential
exposure condition results. 4
A chronic (timewise) low
level j 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
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
Ranking Factor • Exposure z Population x Control x Time function
RISK AS A FUNCTION OF TIME SF*
Significant risk. l
Potential increasing risk.
0.9
Potential future risk. 0.8
Limited risk. 0.7
Potential decreasing risk. 0.5
Risk controlled at acceptable
level. 0.3
7
ro
OS RF S10
SF • Scale Factor
-------
TABLE F-2
PRIORITY RANKING FACTORS
Short Term
Problem Area
Accidents
Disposal
Fuel Reprocessing
Plowshare
Tritium
Microwave
Construction Material
Fabrication Plutonium
Operation Plutonium
Operation Uranium
Medical isotopes
Occupational
Medical X-ray
Device Testing
Mining and Mill Tailings
Fabrication Uranium
Transportation
Laser & Other EM
E
5
5
5
5
3
3
3
3
5
4
3
3
3
3
3
3
1
1
P
2
2
2
2
2
2
2
1.5
1.5
1.5
0.5
0.5
1.5
2
0.5
1.5
1.5
1.5
C
0.8
1
0.8
0.6
0.5
1
1
0.8
0.8
0.8
1
1
1
0.6
0.8
1
1
1
T
1
0.8
0.9
0.3
0.3
0.8
0.7
0.7
0.7
0.9
1
1
1
0.3
1
0.3
0.3
0.3
RF
8
8
7.2
1.8
0.9
4.8
4.2
2.7
4.5
4.3
1.5
1.5
4.5
1.1
1.2
1.4
0.5
0.5
RF
E. x P x C x T
RF - Ranking Factor
E — Exposure Condition
F-3
P - Population at Risk
C - Control Mechanism
T - Risk as a function of time
-------
TABLE F-3
PRIORITY RANKING FACTORS
Long Term
Problem Area
Accidents
Disposal
Fuel Reprocessing
Plowshare
Tritium
Microwave
Construction Material
Fabrication Plutonium
Operation Plutonium
Operation Uranium
Medical Isotopes
Occupational
Medical X-ray
Device Testing
Mining and Mill Tailings
Fabrication Uranium
Transportation
Laser & Other EM
E
5
5
5
5
3
3
3
3
5
4
3
3
3
3
3
3
1
1
P
2
2
2
2
2
2
2
1.5
1.5
1.5
0.5
0.5
1.5
2
0.5
1.5
1.5
1.5
C
0.5
1
1
0.5
1
0.5
0.5
0.8
0.8
0.5
1
1
1
0.6
0.1
0.5
0.5
1
T
1
1
0.9
1
1
1
1
0.9
0.9
0.5
1
1
1
0.3
0.3
0.3
0.3
1
RF
5
10
9
5
6
3
3
3.2
5.3
1.5
1.5
1.5
4.5
1.1
0.5
0.9
0.2
1.5
RF = ExPxCxT
RF - Ranking Factor
E - Exposure Condition
P - Population at Risk
C - Control Mechanism
T - Risk as a function of time.
F-4
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PAGE NOT
AVAILABLE
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