NATIONAL  RADIATION PROTECTION
            PR06RAM
      APPENDIX C -  PROBLEM AREAS
      OFFICE OF RADIATION PROGRAMS

    ENVIRONMENTAL PROTECTION AGENCY
            OCTOBER 1972

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                              APPENDIX C

                             PROBLEM AREAS

                            TABLE  OF CONTENTS
  PROBLEM AREAS                                                    C-l
• ACCIDENTS                                                        C-l
  PROBLEM DESCRIPTION                                              C-l
  Introduction                                                     C-l
  Background                                                       C-2
  Scope                                                            C-8
  LEGISLATIVE STATUS                                                C-ll
  COORDINATION                                                     C-12
  Interagency                                                      C-12
  Intragency                                                       C-l3
  ALTERNATIVE APPROACHES                                            C-13
  OPTIMUM PROGRAM                                                  C-13
  Knowledge                                                        C-13
  Research and Development                                         C-15
  Enforcement and Control                                           C-16
  Expected Accomplishments and Measures                            C-16
  PROPOSED PROGRAM                                                 C-16
  Knowledge                                                        C-20
  Research and Development                                         C-21
  Expected Accomplishments and  Measures                            C-21
  COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS                      C-21
  MEASURES OF GOAL ATTAINMENT                                      C-25
• RADIOACTIVE-WASTE DISPOSAL                                       C-31
  PROBLEM DESCRIPTION                                              C-31
  Component Problems                                               C-31
  Background                                                       C-31
  LEGISLATIVE STATUS                                               C-35
  COORDINATION                                                    C-36
  Intra-Agency                                                     C-36
  Inter-Agency                                                     C-37
  EPA-State                                                        C-37
  EPA-Industry                                                     C-38
  ALTERNATIVE APPROACHES                                           C-38
  OPTIMUM PROGRAM                                                  C-39
  External Needs                                                   C-40
  internal Needs                                                   C-41
  PROPOSED PROGRAM                                                 C-41
  External Needs                                                   C-42
  Internal Needs                                                   C-43
  Comparison of Optimum and Proposed Programs                      C-43
  MEASURES OF GOAL ATTAINMENT                                      C-44
  Fiscal Year 1973                                                 C-44
  Fiscal Year 1974                                                 C-45
                                  C-i

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                             APPENDIX C

                          TABLE OF CONTENTS
                            (Continued)
Fiscal Year 1975                                                 C-45
Fiscal Year 1976                                                 C-45
Fiscal Year 1977-1979                                            C-45
NUCLEAR FUEL REPROCESSING                                        C-46
PROBLEM DESCRIPTION                                              C-46'
Background                                                       C-46
Component Problems                                               C-48
Scope                                                            C-51
LEGISLATIVE STATUS                                               C-55
COORDINATION                                                     C-55
Interagency                                                      C-55
Intragency                                                       C-56
ALTERNATIVE APPROACHES                                           C-57
OPTIMUM PROGRAM                                                  C-58
External Needs                                                   C-59
Internal (ORP) Needs                                             C-61
Milestone Chart                                                  C-62
PROPOSED PROGRAM AND COMPARISON WITH OPTIMUM PROGRAM             C-64
MEASURES OF GOAL ATTAINMENT                                      C-64
THERMONUCLEAR                                                    C-65
PROBLEM DESCRIPTION                                              C-65
Technical Background                                             C-65
LEGISLATIVE STATUS                                               C-73
COORDINATION                                                     C-74
Interagency                                                      C-74
Intragency                                                       C-74
ALTERNATIVE APPROACHES                                           C-76
PROPOSED PROGRAM                                                 C-77
EPA Responses to Progress in TNP Implementation                  C-80
External Needs                                                   C-85
Internal Needs                                                   C-88
MEASURES AND GOAL ATTAINMENT                                     C-89
FABRICATION PLUTONIUM                                            C-91
PROBLEM DESCRIPTION                                              C-91
Component Problems                                               C-91
Background                                                       C-91
Scope                                                            C-95
LEGISLATIVE STATUS                                               C-98
COORDINATION                                                     C-98
Interagency                                                      C-98
Intragency                                                       C-99
ALTERNATIVE APPROACHES                                           C-100
Identification of Alternatives                                   C-100
OPTIMUM PROGRAM                                                  C-100

                               C-ii

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                             APPENDIX C

                           TABLE OF  CONTENTS
                             (Continued)
 External Needs                                                  C-101
 Internal Needs                                                  C-104
 PROPOSED PROGRAM                                                C-105
 External Needs                                                  C-105
 Internal Needs                                                  C-107
 COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS                     C-107
 MEASURES OF GOAL ATTAINMENT                                     C-107
 OPERATIONS - PLUTONIUM                                          C-109
 PROBLEM DESCRIPTION                                             C-109
 Component Problems                                              C-109
 Background                                                      C-109
 Scope                                                           C-113
 LEGISLATIVE STATUS                                              C-113
 COORDINATION                                                    C-114
 ORP Internal Coordination                                       C-114
 Interagency Coordination                                        C-116
 External Coordination                                           C-116
 ALTERNATIVE APPROACHES                                          C-117
 Description of Alternatives                                     C-117
 Compromise Alternatives                                         C-119
 OPTIMUM AND PROPOSED PROGRAMS                                   C-120
 External Needs                                                  C-120
 Internal Needs                                                  C-130
 Proposed Program Milestones                                     C-131
 COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS                     C-135
 MEASURES OF GOAL ATTAINMENT                                     C-137
 OPERATIONS - URANIUM                                            C-139
 PROBLEM DESCRIPTION                                             C-139
 Problem                                                         C-139
 Background                                                      C-141
 Scope                                                           C-145
 LEGISLATIVE STATUS                                              C-147
 COORDINATION                                                    C-148
 Interagency                                                     C-148
 ALTERNATIVE APPROACHES                                          C-150
 Description of Alternatives                                     C-150
 Cost Effectiveness                                              C-157
 External Needs                                                  C-163
 Internal Requirements                                           C-166
 PROPOSED PROGRAM                                                C-167
 COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS                     C-170
 MEASURES OF GOAL ATTAINMENT                                     C-171
»FABRICATION-URANIUM                                             C-172
 PROBLEM DESCRIPTION                                             C-172

                                 C-iii

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                             APPENDIX C

                          TABLE OF CONTENTS
                            (Continued)
Component Problems                                              C-172
Background                                                      C-173
Scope                                                           C-174
LEGISLATIVE STATUS                                              C-177
COORDINATION                                                    C-177
Interagency                                                     C-177
Intra-agency                                                    C-178
ALTERNATIVE APPROACHES                                          C-178
External Needs                                                  C-182
Internal Needs                                                  C-183
OPTIMUM PROGRAM                                                 C-1B3
MEASURES OF GOAL ATTAINMENT                                     C-183
TRANSPORTATION                                                  C-185
PROBLEM DESCRIPTION                                             C-185
Component Problems                                              C-185
Background                                                      C-185
Scope                                                           C-186
COORDINATION                                                    C-187
Interagency                                                     C-187
Intragency                                                      C-189
ALTERNATIVE APPROACHES                                          C-189
Reduced Efforts                                                 C-189
Expanded Efforts                                                C-189
OPTIMUM PROGRAM                                                 C-190
External Needs                                                  C-190
Internal Needs                                                  C-192
PROPOSED PROGRAM                                                C-192
COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS                     C-192
MEASURES OF GOAL ATTAINMENT                                     C-194
CONSTRUCTION MATERIALS                                          C-195
PROBLEM DESCRIPTION                                             C-195
Component Problems                                              C-195
Background                                                      C-196
Scope                                                           C-199
LEGISLATIVE STATUS                                              C-199
COORDINATION                                                    C-200
ALTERNATIVE APPROACHES                                          C-200
First Alternative                                               C-200
Second Alternative                                              C-201
Third Alternative                                               C-201
Fourth Alternative                                              C-201
OPTIMUM PROGRAM                                                 C-201
PROPOSED PROGRAM                                                C-203
                                C-iv

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                             APPENDIX C

                          TABLE OF CONTENTS
                            (Continued)
COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS                     C-205
MEASURES OF GOAL ATTAINMENT                                     C-205
MINING AND MILL TAILINGS                                        C-206
PROBLEM DESCRIPTION                                             C-206
Component Problems                                              C-206
Background                                                      C-206
Scope                                                           C—208
LEGISLATIVE STATUS                                              C-209
COORDINATION                                                    C-210
Interagency                                                     C-210
Intragency                                                      C-210
ALTERNATIVE APPROACHES                                          C-211
Uranium Mining                                                  C-211
Uranium Mill Tailings                                           C-211
OPTIMUM PROGRAM                                                 C-211
External Needs                                                  C-211
Internal Needs                                                  C-213
PROPOSED PROGRAM                                                C-213
Uranium Mining                                                  C-213
Uranium Mill Tailings                                           C-213
Milestone Chart                                                 C-214
COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS                     C-214
MEASURES OF GOAL ATTAINMENT                                     C-214
Uranium Mining                                                  C-214
Uranium Mill Tailings                                           C-217
RADIOFREQUENCY AND MICROWAVE                                    C-218
PROBLEM DESCRIPTION                                             C-218
Introduction                                                    C-218
Component Problems                                              C-218
Background                                                      C-222
Scope                                                           C-223
LEGISLATIVE STATUS                                              C-224
COORDINATION                                                    C-225
Interagency                                                     C-225
States                                                          C-229
ALTERNATIVE APPROACHES                                          C-229
Determination of the Status of the Environment                  C-229
Evaluation of Electromagnetic Radiation Effects                 C-231
Development Guidelines                                          C-232
Development of Control Program for EM Radiation Pollution       C-233
OPTIMUM PROGRAM                                                 C-234
Introduction                                                    C-234
Determination of the Status of the Environment                  C-239
Determination and Evaluation of Effects                         C-240

                                C-v

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                              APPENDIX C

                           TABLE OF CONTENTS
                             (Continued)
 Development  of Guidelines                                        C-241
 Emergency Response  Capability                                    C-242
 Response to  Requests  to Technical Assistance                    C-242
 Review of Environmental Impact  Statements                        C-242
 Research                                                        C-243
 Field  Support  Facility Development                               C-243
 Technical Publications                                           C-243
 Program for  Control of Environmental  Electromagnetic
   Radiation  Pollution                                           C-244
 Information  Inventory Development                                C-244
 Liaison Activity                                                 C-245
 Internal Needs                                                  C-248
 PROPOSED PROGRAM                                                 C-253
 External Needs                                                  C-253
 Internal Needs                                                  C-253
 COMPARISON OF  OPTIMUM AND  PROPOSED  PROGRAMS                      C-353
 MEASURES OF  GOAL  ATTAINMENT                                      C-259
 Authorization  to  Monitor                                         C-259
 Access to ECAC and  OT Source Data Bank                          C-268
 Emergency Response  Capability                                    C-268
 Synthesis of Current  Effects Knowledge                          C-269
 Development  of Instrumentation  for  EM Measurements              C-269
 Characterization  of Urban  EM Spectra                             C-269
 Headquarters Instrumentation Support  Facility                   C-269
 EM Ambient Level  Determination                                   C-270
 Specific Source Monitoring Data                                 C-270
 Analytical Procedures for  EM Radiation Analysis and
   Software Requirements                                          C-270
 Rate of Growth Determination                                     C-271
 Interim Guidelines                                               C-271
 Decision on  Proposed  Standards                                   C-271
 Write  and Enact Standards                                        C-271
 Annual Report                                                    C-272
 LASER  RADIATION                                                 C-273
 PROBLEM DESCRIPTION                                             C-273
 Background                                                      C-273
 LEGISLATIVE  STATUS  AND COORDINATION                             C-274
 Proposed Program                                                 C-275
i MEDICAL ISOTOPES                                                 C-277
 PROBLEM DESCRIPTION                                             C-277
 Component Problems                                               C-277
 Background                                                      C-278
 Scope                                                            C-279
 LEGISLATIVE  STATUS                                               C-280

                                C-vi

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                              NOTICE


     Since this document contains budgetary information, it is

privileged information until such time as it i's approved by the

Assistant Administrator for Categorical Programs.

     The documents are serially numbered for accountability and

to insure that recipients receive changes as they  are i&sued.

     Recommended changes or corrections should be  submitted to

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

-------
                             APPENDIX C

                           TABLE OF CONTENTS
                            (Continued)
COORDINATION                                                    C-281
Interagency                                                     C-281
ALTERNATIVE APPROACHES                                          C-282
OPTIMUM PROGRAM                                                 C-283
External Needs                                                  C-283
Internal Needs                                                  C-285
PROPOSED PROGRAM                                                C-285
COMPARISON OF THE OPTIMUM AND PROPOSED PROGRAMS                 C-286
MEASURES OF GOAL ATTAINMENT                                     C-286
OCCUPATIONAL EXPOSURE                                           C-287
PROBLEM DESCRIPTION                                             C-287
Component Problems                                              C-287
Background                                                      C-288
Scope                                                           C-290
LEGISLATIVE STATUS                                              C-294
INTERAGENCY COORDINATION                                        C-295
ALTERNATIVE APPROACHES                                          C-295
Description of Alternatives                                     C-295
Comparison of Alternatives                                      C-298
External Needs                                                  C-299
Internal Needs                                                  C-301
MEASURES OF GOAL ATTAINMENT                                     C-302
MEDICAL X-RAY                                                   C-303
PROBLEM DESCRIPTION                                             C-303
Component Problems                                              C-303
Background                                                      C-303
Scope                                                           C-304
LEGISLATIVE STATUS                                              C-305
EPA                                                             C-305
Department of Health, Education, and Welfare (DHEW)             C-305
States                                                          C-306
Voluntary Standards                                             C-306
COORDINATION                                                    C-306
Interagency                                                     C-306
Intragency                                                      C-308
ALTERNATIVE APPROACHES                                          C-308
First Alternative                                               C-309
Second Alternative                                              C-309
OPTIMUM PROGRAM                                                 C-309
External Needs                                                  C-311
Internal Needs                                                  C-312
Implementation                                                  C-313
Milestone Chart                                                 C-313
PROPOSED PROGRAM                                                C-315

                               C-vii

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                             APPENDIX C

                           TABLE OF CONTENTS
                             (Continued)
External Needs                                                  C-315
Internal Needs                                                  C-315
Milestone Chart                                                 C-315
Comparison of Optimum and Proposed Programs                     C-315
MEASURES OF GOAL ATTAINMENT                                     C-317
Goals                                                           C-317
Measures of Goal Attainments                                    C-317
DEVICE TESTING                                                  C-318
PROBLEM DESCRIPTION                                             C-318
Component Problems                                              C-318
Background                                                      C-320
Scope                                                           C-323
LEGISLATIVE STATUS                                              C-329
COORDINATION                                                    C-330
Interagency                                                     C-330
Intragency                                                      C-331
ALTERNATE APPROACHES                                            C-332
OPTIMUM PROGRAM                                                 C-333
External Needs                                                  C-333
Internal Needs                                                  C-334
PROPOSED PROGRAM                                                C-335
External Needs                                                  C-335
Internal Needs                                                  C-339
Detailed Program for FY 1973                                    C-339
COMPARISON OF THE OPTIMUM AND PROPOSED PROGRAMS                 C-342
MEASURES OF GOAL ATTAINMENT                                     C-342
PLOWSHARE                                                       C-345
PROBLEM DESCRIPTION                                             C-345
Summary                                                         C-345
Component Problems                                              C-345
Background                                                      C-347
Scope of Program                                                C-352
LEGISLATIVE STATUS                                              C-357
COORDINATION                                                    C-358
Interagency                                                     C-358
Intra-Agency                                                    C-360
ALTERNATIVE APPROACHES                                          C-361
OPTIMUM PROGRAM                                                 C-363
Introduction                                                    C-363
External Needs                                                  C-366
Internal Needs                                                  C-369
PROPOSED PROGRAM                                                C-370
Introduction                                                    C-370


                               C-viii

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                             APPENDIX C

                           TABLE OF CONTENTS
                             (Continued)
                                                                Page
                                                                C-372
External Needs                                                  c-374
Internal Needs                                                   ~
COMPARISON OF THE OPTIMUM AND PROPOSED PROGRAMS
MEASURES OF GOAL ATTAINMENTS                                    C-J7b
                           LIST OF TABLES


TABLE NUMBER                                                    Page
    C-l          CONTRACTOR SKILL REQUIREMENTS                  C-24

    C-2          PRODUCTION RATES OF THE MAIN FISSION
                 PRODUCTS IN A LWR                              C-50

    C-3          TRITIUM IMPACT FOR ONE GIGAWATT YEAR
                 ELECTRIC                                       C-70

    C-4          SHORT RANGE COORDINATION                       C-75

    C-5          A HYPOTHETICAL CHRONOLOGY FOR TNP
                 DEVELOPMENT                                    C-79

    C-6          TIME SCALE FOR ORP/EPA ACTIONS                 C-81

    C-7          TNP REVIEW AND EVALUATION FY 73-FY 75          C-84

    C-8          ESTIMATED PRODUCTION OF LONG-LIVED RADIO-
                 NUCLIDES BY NUCLEAR POWER REACTORS             C-lll

    C-9          RESEARCH AND DEVELOPMENT ACTIVITIES CON-
                 DUCTED UNDER THE OPTIMUM PROGRAM WHICH ARE
                 NOT IN THE PROPOSED PROGRAM                    C-121

    C-10         EXTERNAL INFORMATION NEEDS                     C-125

    C-ll         RESEARCH PROJECTS UNDER PROPOSED AND
                 OPTIMUM PROGRAMS                               C-l 28

    C-12         COMPARISON OF OPTIMUM, PROPOSED, AND
                 MINIMUM FUNCTIONAL PROGRAMS                    C-l36

                              C-ix

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TABLE NUMBER

    C-13


    C-14

    C-15

    C-16


    C-17

    C-18

    C-19

    C-20

    C-21

    C-22

    C-23

    C-24

    C-25
            APPENDIX C

     LIST OF TABLES (Continued)


                                               Page

FUNCTIONS PERFORMED UNDER ALTERNATIVE
APPROACHES                                     C-151

COST-EFFECTIVENESS OF ALTERNATIVE APPROACHES   C-158

URANIUM PROCESSING FACILITIES IN THE U.S.      C-175

SUMMARY CHART FOR TRANSPORTATION REQUIREMENTS
OF NUCLEAR POWER INDUSTRY                      C-188

REQUIREMENTS - OPTIMUM PROGRAM                 C-249

REQUIREMENTS - PROPOSED PROGRAM                C-255

COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS    C-260

ESTIMATED U.S. OCCUPATIONAL DOSE               C-291

U.S. NUCLEAR DETONATION SUMMARY                C-321

ANALYSIS OF OPERATING EXPENSES BY PROGRAM      C-326

ANALYSIS OF YEAR-END EMPLOYMENT BY PROGRAM     C-327

WERL PROJECTS RELATED TO ORP PROBLEM AREAS     C-343

PLOWSHARE EXPERIMENTS                          C-353
FIGURE NUMBER

    C-l


    C-2

    C-3

    C-4

    C-5
MILESTONE CHART - LIGHT WATER REACTOR
ACCIDENTS - PROPOSED PROGRAM

MILESTONE CHART - LMFBR ACCIDENTS

MILESTONE CHART - HTGR ACCIDENTS

ACCIDENT PROGRAM

PROPOSED PROGRAM - ACCIDENTS
                                               Page
C-17

C-18

C-19

C-22

C-26
                                    C-x

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                             APPENDIX C

                     LIST OF TABLES (Continued)


FIGURE NUMBER                                                   Page

    C-6          CLASSES OF INITIATING EVENTS                   C-27

    C-7          CONSEQUENCES OF INITIATING EVENTS              C-28

    C-8          CONSEQUENCES OF VARIOUS CLASSES OF ACCIDENTS   C-29

    C-9          ACCIDENT CONSEQUENCE ANALYSIS                  C-30

    C-10         RADIOACTIVE WASTE DISPOSAL - MILESTONE
                 CHART FOR THE PROPOSED AND OPTIMUM PROGRAMS    C-32

    C-ll         U.S. FUEL DISCHARGES BY FUEL TYPE              C-53

    C-12         PROGRAM FLOW LOGIC - FUEL REPROCESSING         C-60

    C-13         MILESTONE CHART FOR THE PROPOSED PROGRAM -
                 FUEL REPROCESSING         "                     C-63

    C-14         MILESTONE CHART - THERMO-NUCLEAR POWER -
                 PROPOSED PROGRAM                               C-78

    C-15         CUMULATIVE PLUTONIUM PRODUCTION WITHOUT Pu
                 RECYCLE                                        C-93

    C-16         PLUTONIUM PRODUCTION AND USE WITHOUT Pu
                 RECYCLE                                        C-94

    C-17         KILOGRAMS OF PLUTONIUM                         C-96

    C-18         MILESTONE CHART - FABRICATION PLUTONIUM -
                 OPTIMUM PROGRAM                                C-102

    C-19         MILESTONE CHART - FABRICATION PLUTONIUM -
                 PROPOSED PROGRAM                               C-106

    C-20         PROBLEM AREA COORDINATION REQUIRED FOR
                 PLUTONIUM FUEL CYCLE                           C-115

    C-21         OPERATIONS-PLUTONIUM:  MINIMUM FUNCTIONAL
                 PROGRAM MILESTONES                             C-118

    C-22         INTRAGENCY INFORMATION NEEDS                   C-123
                                   C-xi

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                             APPENDIX C

                     LIST OF TABLES (Continued)


FIGURE NUMBER                                                   Page

    C-23         MILESTONE CHART - OPERATIONS-PLUTONIUM
                 OPTIMUM AND PROPOSED PROGRAM                   C-132

    C-24         OPERATIONS - URANIUM, AGENCY COORDINATION      C-149

    C-25         OPERATIONS-URANIUM - MILESTONE  CHART FOR
                 THE OPTIMUM PROGRAM                            C-161

    C-26         OPERATIONS-URANIUM - MILESTONE  CHART FOR
                 THE PROPOSED PROGRAM                           C-168

    C-27         MILESTONE CHART - FABRICATION:   URANIUM -
                 PROPOSED PROGRAM                               C-180

    C-28         PROPOSED PROGRAM - TRANSPORTATION               C-193

    C-29         MILESTONE CHART - CONSTRUCTION  MATERIALS -
                 PROPOSED PROGRAM                               C-204

    C-30         MILESTONE CHART - URANIUM MINING               C-215

    C-31         MILESTONE CHART - URANIUM MILL  TAILINGS        C-216

    C-32         ELEMENTS OF ORP FY 1973 & FY 1974  RADIO-
                 FREQUENCY AND MICROWAVE PROGRAM                C-236

    C-33         OPTIMUM RADIOFREQUENCY - MICROWAVE PROGRAM     C-238

    C-34         PROPOSED RADIOFREQUENCY - MICROWAVE PROGRAM    C-254

    C-35         ESTIMATED NUCLEAR GENERATING CAPACITY IN THE
                 U.S. THROUGH THE YEAR 2000                     C-293

    C-36         LEGISLATIVE STATUS FOR OCCUPATIONAL
                 RADIATION EXPOSURE                             C-296

    C-37         INTEHAGENCY COORDINATION - OCCUPATIONAL
                 EXPOSURE                                       C-297

    C-38         OCCUPATIONAL EXPOSURE MILESTONE CHART -
                 OPTIMUM PROGRAM                                C-300

    C-39         MILESTONE CHART - MEDICAL X-RAY -  OPTIMUM      C-314
                                  C-xii

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FIGURE NUMBER




    C-40




    C-41




    C-42




    C-43




    C-44
            APPENDIX C




    LIST OF TABLES (Continued)











MILESTONE CHART - MEDICAL X-RAY - PROPOSED




ORGANIZATION CHART NERC - LAS VEGAS




NUCLEAR DEVICE TESTING MILESTONE CHART




MILESTONE CHART - PLOWSHARE - OPTIMUM




MILESTONE CHART - PLOWSHARE - PROPOSED
Page




C-316




C-325




C-336




C-365




C-371
    GLOSSARY
                                                C-xiv
                                C-xiii

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                             GLOSSARY
AEC
ANSI
AQCS
BRH
BWR
CAB
CEQ
CRF
CIA
COMM
CSD
CW
C2
DCPA
DEPA
DHEW
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 end 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 Inpact 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 Tc'inperature 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
                                C-xiv

-------
                             GLOSSARY (Cont'd)
Acronyms

   ITDSN
   ITS
   JCAE
   I1IFBR
   LORAN
   LWR
   LV
   MLON
   MFC
   NAS
   NASA
   NBS
   NCRP
   NEPA
   NERC
   NEXT
   NGS
   NIOSH
   NOAA
   NRDS
   NSF
   NTS
   OAP
   OCP
   OEGC
   OEP
   OFA
   OGC
   OMB
   OPE
   0PM
   OKNL
   ORP
   OSHA
   OSW
   OT
   OTM
   OTP
   OWP
   PAG
   PAHO
   PMN
   PUR
   RAN
   RGB
   RFC
   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 o£ Standards, CQMM
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, D11EW
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
                                 C-xv

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                          GLOSSARY (Concluded)

Acronyms

   SAR          Safety Analysis Report
   SID          Surveillance and Inspection Division, ORP
   SNAP         Systems for Nuclear Auxilliary Power
   STORET       Storage and Retrieval of Water Quality and Hydrologic Data
   TAD          Technology Assessment Division, ORP
   TLD          Thermo-luninescent Dosimeter
   TNP          Thermonuclear Power
   TSS          Tritium Surveillance Survey
   USBM         U. S. Bureau of Mines
   USD1         U. S. Department of the Interior
   USGS         U. S. Geological Survey
   USIA         U. S. Information Agency
   USPHS        U. S. Public Health Service, DHEW
   UERL         Western Environmental Research Laboratory
   WHO          World Health Organization
   WLM          Working Level Month
                                   C-xvi

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                                            REVISION MARCH 197-3




                               APPENDIX C




                              PROBLEM AREAS



                                ACCIDENTS




PROBLEM DESCRIPTION




Introduction



     The potential impact on the environment from accidents associated




with the fission fuel cycle is of particular concern to EPA's Office of




Radiation Programs because of the extreme toxicity of the radioactive




by-products produced during the fission process.  The problem is




intensified since the toxicity of these by-products would not be




significantly reduced through natural processes once introduced into




the biosphere.  While the amount of radioactivity would decrease with




time, as a consequence of the natural radioactive decay process, a




significant amount of the radioactivity could remain for many years.



     It is the potential for uncontrolled, accidental releases of




biologically hazardous radionuclides to the environment which dictates




special emphasis on the probability and consequences of accidents as-




sociated with fission fuels.  The remainder of this problem area



description will focus on the question of accidents in nuclear reactors,




since the potential risks from these facilities are higher than those




associated with other portions of the fission fuel cycle.  Similar




methodology, however, will be applied to accidents associated with




other aspects of the fission fuel cycle  (e.g., waste  disposal, fuel




reprocessing, and spent fuel transportation, etc.).   Accordingly, much




of  the work described herein will contribute to resolving accident-




related issues of the facilities, systems, and processes associated




with other problem areas.
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                                            REVISION MARCH 1973
Component Problems



     Accidents and subsequent release of radioactive material from



nuclear facilities are important considerations for environmental




radiation protection because they represent a finite potential and




a significant risk to the public health and the environment if they




should occur.  The AEG has the authority and responsibility for as-




suring that nuclear plants are designed, constructed, and operated so




as to prevent accidents and mitigate their consequences.  Under the




National Environmental Policy Act of 1969, the AEC must describe the




environmental consequences of its licensing actions, including the




risks from accidents.



     The output from the program for this problem area to meet the




responsibilities of the EPA consists of the following:




        Development of criteria and standards relating to risks




        and consequences from radiation accidents.



        Development of methods for the quantitative evaluation of




        accident risks suitable for use in environmental statements




        and environmental statement reviews.



        Accident risks evaluated for risk/cost/benefit analyses.




        Review of Reactor Siting Criteria, and, if needed, issuance




        of guidance for development of improved criteria.




        Development and refinement of protective measures, including




        the  evaluation of experience on evacuation from natural




        disasters.



        Development and refinement of Protective Action Guides.
                                    C-2

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                                             REVISION MARCH  1973






        Establishment of Emergency Monitoring Systems.




        Assistance to state and local officials  in the  area of




        radiological emergency preparedness.




Background



     The potential significant consequences of hypothesized reactor




accidents were realized at the inception of the  development of



reactors.  Major efforts were employed at the outset to help assure



reactor safety by factoring safety into the reactor design process




and by setting up a stringent licensing process  to help assure  that




reactor operation would result in no undue risks to public health and




safety.  As might be expected, the approach and  criteria on which



reactor safety and siting judgments are based have evolved over the




years as new information was developed, plant designs improved, and




operating experience obtained.



     The initial concept was to design reactors  to assure that  even



the worst possible accident that could happen would not result  in




doses to the offsite population greater than prescribed levels.  In



essence this concept attempted to avoid the requirement of establishing




the probability of accidents in a quantitative way.  This was to be




accomplished by the "safety-in-depth" approach,  in which fuel Cand




fission products which are produced during operation) is contained in




a pressure tube Cfuel pin cladding), the fuel pins were contained in




reactor primary system (pressure vessel and associated piping designed




and built to the highest standards available), and the primary system




housed in a very low-leakage high strength building  (containment building)
                                   C-3

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                                             REVISION MARCH  1973









In addition, redundant and emergency systems were incorporated




into the reactor, to minimize the potential of a single failure in




any critical component (e.g., the nuclear control system) from




initiating an accident.



     By 1962, sufficient advances were made so that a Technical In-




formation Document was issued by the AEG (TID-14844 "Calculation




of Distance Factors' for Power Test Reactors") which is referenced in




the AEC's regulations.  TID-14844 provided a sample calculation which




could be used as a guide t'o help assess the suitability of a given



site for a power reactor in terms of distance from a populated area.



In essence, it embodied the ideas noted above in great detail.  The




TID-14844 Guide focused'on the concept of the "maximum credible ae»-




cident" (MCA) which is defined as a nuclear accident "which would




result in a potential hazard that would not be exceeded by any other




accident considered credible during the lifetime of the facility".




TID-14844 went on to detail a potential maximum credible accident for




pressurized light-water reactors, namely the loss-of—coolant accident




CLOCA) initiated by.an instantaneous double-ended  (i.e., complete




offset) rupture of a main coolant line.  One of the basic assumptions




in TID-14844 was that the LOCA resulted in the release from the fuel




elements of 100% of the noble gases, 50% of the halogens, (including




iodine) and 1% of the solids fission product inventory in the  core.




Such an extensive release would be consistent with an accident involving



a major meltdown of the core.  In addition, it was assumed that' half




of the iodine (which generally controls the overall hazard for hypothesized




large accidents in light ^water reactors) plated out instantaneously on
                                  C-4

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                                              REVISION MARCH 1973







surfaces inside the reactor and containment building, making 25%




of the iodine inventory in the core available for release from the




containment building.  While not Included in the calculational




example, TID-14844 indicated that engineered safeguards such as




washdown features (e.g., containment sprays and filtering networks)




could provide additional reduction factors 
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                                              REVISION MARCH 1973





     The preceding discussion has dealt largely with the framework




by which reactor accidents are judged;  it should be noted, however,




that during the last few years the AEC  has been placing an ever in-




creasing emphasis on quality assurance  in the design, construction,




maintenance, and operation of nuclear reactors.  This extremely en-




couraging development stems from the rationale that the objective of



safe, economic nuclear power cannot be  met unless the reactor systems




are reliable.  Proponents of this concept suggest that safety stems




from an excellence of engineering and that safety is better assured




by precluding accidents or stopping them early rather than attempting




to accommodate severe accidents late in the accident sequence.  Others




argue, on the other hand, that errors or natural disasters will still




occur and that insufficient knowlege of potential accident chains




exist.  This thought suggests use of an "envelope" approach with an




emphasis on assuring safety by use of consequence mitigating engineered




safeguards which are suitable for a variety of accidents.  Both ap-




proaches have merits and drawbacks, and while not mutually exclusive,




do, at times, conflict with each other.  (Unfortunately,  it appears  that




the methodology necessary to make objective, cost-effective judgments




concerning the optimum mix of engineered  safeguards, quality assurance



programs, and operating limits  (Technical Specifications) has  not yet




been developed.] All of the approaches employed  have directed  effort




toward reducing the risk of accidents.  Little has been done  to quantita-




tively evaluate the risk because of the difficulties involved  in




determination of the very small probabilities  involved  with accidents




which have severe  consequences.
                                  C-6

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                                                 REVISION MARCH  1973





     However, the August,  1972 "Comment Issue" of the "Guide  to




the Preparation of Environmental Reports for Nuclear Power Plants




notes that "In the consideration of the environmental risks associated



with postulated accidents, the probabilities of their occurrence and




their consequences must both be taken into account."  It is most




encouraging that the AEC is moving in the direction of more quantita-




tively assessing accident  probabilities and consequences.  A  new AEC




program to assess the environmental risk of reactor accidents (accident




probabilities and consequences) is underway.



     Efforts to date in the area of developing a capability for




responding to emergencies  as the result of reactor accidents  have




been somewhat fragmentary, with various state organizations, and Federal




agencies (including federally-controlled laboratories) all involved.




Improvements in this situation should be forthcoming as the result




of agreements reached among participating organizations under the



overall coordination of OEP.  These efforts will include the  develop-




ment and issuing of improved Protective Action Guides, protective



measures, Emergency'Monitoring Systems, Emergency Plans and emergency




response capabilities, and as such form another major element of the




proposed program.




Scope of Problem




     In the nuclear power industry, there are about 27 operational plants,




about 180 plants operating, being built, planned or on order, and about




1000 plants expected by the year 2000.  Facilities for the remainder of




the fuel cycle must be expanded accordingly.  The expected potential
                                  C-7

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                                               REVISION MARCH 1973



for accidents is such that,  while  a catastrophic event may never


occur, minor accidental releases may increase to a frequency of one


or more per year.


     Because of the great similarity of reactor components and sub-


systems among different plants,  a  number of plants have similar


possible chains of failure leading to radioactivity releases and


therefore assessment of accidents  can be largely generic in nature.


Unique plant designs will have both common and unique possibilities


for accidents and thus will require more effort in accident assessment.


Further, specifics associated with each reactor site must also be


factored in.  For example, the probability of an accident initiated


by an earthquake will vary from site to site, and the consequences


of an accident on a site with a larger nearby population would be


more severe than one which is well removed from high population areas.


Therefore, a treatment of accidents will require not only generic

                                      ff+-
assessments but will have to acccount jaf site variables.  The probability


of a given accident being initiated is, of course, a function of many


variables.  For example, accident initiation could result from some


combination of design error, faulty construction, operator error, poor


maintenance and natural disaster.   Similarly the consequences of the


spectrum of possible accidents varies from nil to catastrophic depending


on such variables as the event which initiates the accident, reactor
                        \

size and location, efficacy of engineered safeguards which are intended


to control the accident or minimize consequences, the weather  and  the


action of reactors operators, of disaster team specialists, and of


public officials subsequent to the accident.
                                  C-8

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                                                   REVISION MARCH 1973





LEGISLATIVE STATUS




     EPA and other Federal agencies have sufficient authority to carry




out the program proposed herein.   Some of the existing legislation,




however, requires that interfaces be appropriately defined by partici-




pating agencies if the total program is to be performed in a timely




and efficient manner.




     The statutory authority of EPA to advise the President on radia-



tion matters affecting public health is derived through the transferred




authority from the former Federal Radiation Council (FRC) T42 U.S.




Code 2021(h)]. Reorganization Plan No. 3 of 1970 gives EPA the re-




sponsibilities for setting generally applicable environmental standards,




which were formerly held by the Division of Radiation Protection




Standards of the Atomic Energy Commission.  Authority to protect the



public health is derived by EPA from the Public Health Service Act.




     The National Environmental Policy Act of 1969 requires that EPA




review Environmental Impact Statements, to assess the adequacy of




environmental protection associated with major Federal actions.  Addi-



tional authority for EPA activities in this area can be derived through




implementation of the Clean Air Act and the Federal Water Pollution




Control Act Amendments of 1972.



     While no additional legislation appears necessary at this time,




it is possible that,proposed legislation such as "The Administration




Siting Bill" could relieve any potential misunderstandings as to re-




sponsibilities and authority in matters related to this problem area.
                                   C-9

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                                                 REVISION  MARCH  1973







COORDINATION




Interagency



     The coordination required  to assure success in the resolution  of




this problem area is extensive  and complex.   Furthermore,  the plan




envisions that a major portion  of the program will be performed by




others (largely the AEC).   In general, the approach calls  for AEC




efforts to concentrate on  the reactor aspect of reactor accidents




and EPA to concentrate on  the environmental and health implications




of those accidents.  As such, a major near-term goal is to set up




the appropriate coordinating links and to assess whether the degree



and timing of effort contemplated for others is achievable.   This



section will summarize general  responsibilities, and efforts of various




organizations from which coordination links can Be inferred.



     In general, the AEC will be responsible for all activities which




relate to implementation and enforcement of policies to assure adequate




environmental protection from nuclear power plant accidents including




the efforts which relate to the detailed assessment of the adequacy




of the engineering, design, construction, maintenance and operation




of the reactor plant safety systems and for the development of methods




needed to quantitatively assess risks from such reactor accidents.




EPA will provide comments  to the AEC for use in its enforcement role




through the EIS review process.  In general,(the proposed program



contemplates EPA activities concentrating on the development of standards



and criteria which will provide a basis for Judgment concerning accident




risks to be used in the EIS review process. ) The EPA will also develop
                                  C-10

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                                                 REVISION  MARCH  1973







and refine methods for assessing the environmental and health




impact of potential accident induced radiation pollution needed




to a) better define potential protective measures which, can be




taken in the event of an accident, and b) provide additional in-




formation needed to assess the need for refinement of the AEG




Reactor Siting Criteria.  All of the above EFA-developed information




will be inputs to the AEC enforcement procedures and Siting Criteria.




The latter must also be coordinated with, the Federal Power Commission.




Major efforts by both AEC and EPA are contemplated in the area of



radiological emergency preparedness.  In addition to the work on pro-




tective measures noted above, EPA will prepare and refine Protective




Action Guides (PAGs) and, Jointly with AEC, assure the establishment




of emergency monitoring systems. /EPA Regions will utilize the PAGs




and an AEC-issued Guide for the Preparation of Radiological Emergency




Plans to assist regional compacts, and state and local officials in




their emergency preparedness efforts.  Input to the AEC's Guide for




the Preparation of Radiological Emergency Plans will be provided by




DCPA, EPA, HEW, and




     In addition, coordination may be required with the insurance




industry and the JCAE in connection with Price-Anderson indemnification




legislation.



Intraeency



     Coordination of the accident problem area with other problem areas




within EPA-ORP is also required.  Specifically, the accident area ad-




dresses the question of reactor accidents.  The overall approach.,
                                   C-ll

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                                               REVISION  MARCH  1973







however, will be utilized for addressing accidents In other areas




of the fission fuel cycle (e.g. fuel reprocessing and fabrication




plants, transportation, waste disposal, and uranium mining).  For




example, much of the input developed for assuring appropriate




emergency response capability, such as Protection Action Guides,




will be used directly in other problem areas.



     Additional coordination with other EPA offices such as OEM




will be required to initiate specific research programs related to



the accident area.



ALTERNATIVE APPROACHES




     There are many possible alternative approaches to a program for




this problem area, each satisfying the requirements and providing




benefits to a different degree.




     Each suggested alternative is understood to include the effort




to develop adequate emergency response capabilities, as has already




been agreed to among Federal agencies.




     Alternative 1;•  To leave discretion with regard to accidents



to the AEC by




     1.  Deferring to their judgment on the subject of accidents and




         their environmental consequences, or




     2.  Refusing to become involved in the issue due to EPA lack



         of expertise and resources.




     Alternative 2;  To develop a comprehensive ORP program independent




of the AEC to arrive at independent judgments.  This would include




efforts related to quantitatively defining the risk of accidents Cac^-




cident probabilities and consequences), to set standards and criteria






                                   C-12

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                                                REVISION MARCH 1973







including model siting criteria to assure that the risk level from




accidents is consistent with general societal values,  and to develop




methods for application in EIS reviews to assure further reduction of




risk on a cost-effective basis.



     Alternative 3;  To develop an ORP program which recognizes on-going




and potential AEC activities, but which (at least initially) can be




performed largely independently of the AEC.  The ORP efforts would




include sufficient independent effort in the areas where comprehensive




AEC efforts are anticipated or underway so that a meaningful assessment




of the AEC results could be performed in the EIS review process.  Such




relatively small, independent efforts would also provide ORP with the




leverage needed to help assure that the AEC efforts are adequately




performed in a timely manner.  In essence, the AEC would provide the




detailed methods for a) quantitative risk determination  (accident




probabilities and consequences), and b) application of the cost-




effective principle to reduce  the.risk of accidents, as well as the




development of improved Reactor Siting Criteria.  The ORP program



would develop a sufficient capability to assess the AEC  results to




provide a basis for independent judgment needed in EIS reviews.  In




addition, a comprehensive effort  to assess the accident  risk level




which is  consistent with general  societal values would be undertaken




by EPA to provide  an independent  basis for reaching judgments  concerning




risks.  Further, ORP efforts  in the area of  assessing  the environmental




and public health impact of  accidents would  be performed to provide a




partial basis  for  EPA  input  to Reactor Siting criteria.
                                    C-13

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                                                REVISION MARCH 1973




     Alternative 4;  To develop a cooperative (i.e. non-independent)




program with the AEC in the area of quantitative risk determination,




risk assessment, and the development of improved Siting Criteria.




This alternative would call for the AEC to provide a definition of




the possible radioactivity source terms along with the probabilities




of such releases.  ORP would calculate the environmental and public




health impact of such' releases.  ORP and AEC would work jointly in




developing methods for risk reduction using a cost-effective principle




and in an assessment of what risk level is consistent with general




societal values.  Finally, ORP would provide input to AEC on Improved




Reactor Siting Criteria based on the above information.




     The proposed program on which this plan is based is consistent



with Alternative 3.  The rationale used in its selection is as follows:




Alternative 1 would not allow EPA to discharge its responsibility in




this area as currently defined.  Alternative 2 would not be a cost-




effective program in that it would duplicate  major efforts being




performed by the AEC.  In addition, the manpower and resources required




for Alternative 2 significantly exceed those available to ORP.  Alter-




native 4 appears undesirable since it would not likely provide EPA




with the capability to make independent judgments.  Further it is




possible that failure of the AEC to meet ORP expectations in quality




or timing could impair ORP efforts.  It is also possible that untoward




events affecting the performance of ORP (e.g. funding limitations, hiring




freezes) could place EPA in a position of hindering another agency




through faulty performance.  Alternative 3, however, appears to be
                                   C-14

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                                               REVISION  MARCH 1973







consistent with projected EPA resources and with meeting EPA




responsibilities in the accident  area.   It also  would provide the



technical basis for applying leverage on the AEC to  help assure that




the requisite level of environmental protection  will be achieved.




RECOMMENDED OPTIMUM PROGRAM



    No recommended optimum program will be described in detail here




since the elements would be similar to  that of the proposed program.




However, the recommended optimum program can be  readily inferred from




the section "Impact of Proposed Program Compared to  Optimum".




Proposed Program Scope



    It should be emphasized that the scope of the program noted herein



requires major efforts on the part of EPA, AEC,  and  state and local




governments.



     The general goal is to assure adequate environmental protection




from potential reactor accidents.  This goal requires:



     1.  Determination of the environmental risk of  accidents Caccident




consequences as a function of accident  probability).




     2.  Development and application of criteria for judgments concerning




risks in terms of costs, benefits and general societal values.




     3.  Assessment of adequacy of Reactor Siting Criteria and providing




guidance for improvements, if needed,  (based on 1 and 2 above).




     A.  Adequate emergency preparedness to help minimize the environ-




mental and health consequences of reactor accidents, if they should occur.



     While Initial work in each, of these areas can proceed on an essen-



tially Independent basis, some iteration and feedback among  these areas




will be required to assure optimum results.  Definitive objectives include
                                   C-15

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                                               REVISION MARCH 1973







the development of Improved Protective Action Guides, Emergency




Monitoring Systems, State Emergency Flans, and guidance for improved




Siting Criteria, and the development of objective methods for factoring




the environmental risk of accidents into the decision making process




based on a risk/cost/benefit rationale.




1.  Quantitative Risk Determination




    The methodology for defining the expected risk requires a quantifi-




cation of the probability of teaching various damage levels for the



complete spectrum of accidents, including those which, may result in




more severe consequences than the currently defined maximum credible




accident.  Since sufficient statistical data may not be available to




allow a straightforward probability assessment for all possible accidents,



a variety of approaches will be required to assess the probabilities of



both initiating events and the possible responses of the plant, operators,




and public officials.  Since an estimate of the true environmental risk




is required, the developed methods should predict realistic rather than




conservative damage levels.



     The AEC is required under the National Environmental Policy Act




of 1969 to describe in its environmental statements  the risk of accidents




Imposed by its licensing action.  The  EPA has requested that this include




information on the probabilities of accident occurrences,  the probable




consequences, and other risk, cost, and benefit information.  This plan




assumes that the needed methods and information will be made available




by the AEC in a timely manner.  However,  the plan calls for ORP to




assess the suitability of the methods  employed.  This effort will  include

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                                                    REVISION MARCH 1973
 an assessment of the adequacy of the data base,  assumptions,  judgments,




 and completeness of the methods, along with an assessment of  the ade-




 quacy of the accuracy and confidence limits of the results.




 2.  Development of Methods for Reaching Judgments Concerning  Risks




      In the preparation of environmental statements under the




 National Environmental Policy Act of 1969, any agency of the  Federal



 Government (e.g., the AEC), is required to articulate the reasons for




altering   the environment by its actions (including imposing  accident



 risks on society such as the licensing of nuclear power plants).  Thus



 a major input relating to the problem area is the development of a




 methodology for reaching objective judgments on what risk due to



 radiation accidents may be considered acceptable by society.   It should




 be emphasized that there is no absolute "justifiable risk" in a technical




 sense good for all time and place.  Indeed a decision on what constitutes




 a justifiable risk is basically a societal - political decision since




 it involves value judgments on which people would be expected to




 differ.  Thus, while this problem is difficult in that there  is no




 "answer" which will satisfy everyone,/it is clear that a more objective
                                  C-17

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                                                     REVISION MARCH 1973






basis for reaching judgments than currently available can and shall be




developed. ) In essence, it requires a method for reaching an a priori




decision on what risk/cost/benefit balance society would ultimately




select if all subsequent information (e.g., reactor risks and risks of




alternatives) were available to it.  Three complementary risk/cost/




benefit approaches will be utilized to develop justifiable risk




criteria:



     1) comparison of risks associated with the fission fuel cycle




     (including the risks of reactor accidents) with the risks of not




     obtaining the additional power.




     2) comparison of risks of the fission fuel cycle with the risks




     of other fuel cycles (including the risks of accidents)




     3) comparison of risks of the fission fuel cycle with other




     "acceptable" non-voluntary risks (e.g., some forms of travel).




     While the "risk" term has been emphasized in the above description




for clarity, the actual purpose will be to derive "socially acceptable"




(i.e., justifiable) cost/risk/benefit balances.  The first and second




approaches are internal to the energy production framework and will




therefore lead to a cost-effective approach to reducing environmental




and public-health risks associated with the production of electricity;




the latter effort will examine general societal values to enable




decisions to be made on whether other alternatives (not previously




considered seriously, such as underground siting of nuclear plants)




should be considered.






                                   C-18

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                                                  REVISI Ota MARCH 1973




     Once the total justifiable risk is  defined,  a portion  of that risk

will be considered justifiable for the power  plant itself.   Using this

level of risk for a nominal plant, one may then look at each reactor

individually to determine how it's expected risk over the  life of the

plant (including the risk of accidents)  compares to the justifiable

level.  Within the overall envelope of justifiable risk for the reactor

plant, the risk level should be further  optimized on a cost-effective

basis.  In essence, a balance should be  made  of the cost of combinations

of various engineered safeguards,  quality assurance programs, and operating

limits (technical specifications)  and the expected cost saving of prevent-

ing accident consequences.  Such cost-effectiveness optimizations

for Individual reactors should be  possible once the methods for

quantitative risk determination are completed.

     It should be recognized that  definition  of an overall justifiable

risk will require significant development efforts and public debate,

and as such, will not be finalized in the near term.  The plan calls

for major efforts by both EPA/ORP  and EPA/ORM in this area.

     In the near-term (through early f is caj^ year 1974) ORP will develop
             '       v          -   ~
a preliminary quantitative assessment of the  benefits of the uranium

fuel cycle (under the risk/cost/benefit  generic area), and develop the

mathematical framework for application of the risk justification efforts.

The latter efforts will allow parametric studies of health effects

(including both acute and chronic  mortality), accident consequences,

and accident probabilities.  In essence, the  probability of occurrence

of the various classes of accidents required  to produce a fixed number


                                C-19

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                                                 REVISION  MARCH 1973










of health effects will be determined.   Based on this near-term effort,




the maximum justifiable probability for each class of accidents will




be readily calculable once the overall risk justification is determined.




3.  Improved Siting Criteria



     The knowledge gained from the quantitative risk determination and




the basis developed for judgments concerning risks may ultimately lead




to issuing guidance for improved Reactor Siting Criteria.  As a first




step, a comparison of the relative risks of all existing and firmly




planned reactors will be prepared by ORP, assuming an arbitrary but




equal probability of accidents resulting in various levels of radio-




activity release.  Developing such comparisons requires  the development




of individual risk estimates for each plant on the basis of the local




meteorological (and perhaps hydrological) conditions, biological toxicity




of the individual radionuclides, and local population patterns.  Once




the transport analyses define the information on concentrations and loca-




tions of the various isotopes involves, the resultant risk to the public




health and environment will be calculated to give a true picture of the




relative risk of actual sites.  Such information will provide a firm




base for subsequent rapid assessments when actual accident probabilities




are defined.



     Therefore,  the quantitative determination of the probabilities of




various release  levels,  transport models, and health-effects  and  land

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                                      REVISION MARCH 1973

damage models are all required before one can determine the risk
of each individual reactor.   It is only then that one can determine
whether these risks and the judged benefits as weighed against the
existing Siting Criteria result in an adequate situation or whether
improved Siting Criteria and/or improved nuclear plant safety are
required.
    It should also be noted that the Siting Criteria will have to re-
flect multi-station sites,  regional siting patterns, and the differences
among various types of reactors CBWRs, HTGRs, LMFBRs, and FVRs) .
4.  Emergency Response Capability
    In addition to assessing the risks with regard to acceptability
and deciding how to reduce risks if necessary through improved Siting
Criteria and/or cost-effective improvements in plant safety, it is
necessary to prepare for effective response to emergencies, in order
to reduce the consequences of accidents should they occur.  Preparedness
for such emergencies Involves considerable planning, coordination, and
the development of response capability, and should be done on a cost-
effective basis, consistent with the expected risk and consequences.
The effort Involved, is large, involving several Federal organizations
and many lower-level governments.  The responsibilities of the EPA In-
volve issuing Protective Action Guides, and assisting other organizations
in emergency planning, development and assessment of protective measures,
and cooperation in the establishment of radiation detection and emergency
monitoring systems.  These efforts will be applied not only to radio-
logical emergencies arising from reactor accidents but all other
radiological emergencies arising from the insertion of radioactive
materials to the Biosphere.
                                   C-21

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                                          REVISION MARC H  1973




    An example of one Protective Action Guide (FAG)  which requires


near-term effort is related to the development of guidance which


would weigh the risks due to the evacuation  of various population


groups and costs of action prescribed against reductions in exposure.


There Is a real need for guidance to the states on anticipated risks


due to evacuations.  Through the cooperation of OEP, AEC, and DCFA,


ORF will develop a report on the history of  the risk due to evacuation.


Considered in such a study will be the various population groups and


different weather conditions in different parts of the country.  ORP


will then issue a PAG which indicates at what expected reduction in
                       -          t

radiation exposure evacuation of various population groups would be


warranted.  As a very practical matter, it will take several months


to gather this information.  Continuing from that point on, ORP, with


the cooperation of the other Federal agencies, will develop guidance


to the states for the evacuation and/or alternate remedial action in


the event of an anticipated exposure, such as the benefit of shelter.


    It should be noted that additional PAGs for radlonuclldes not now


considered may be desirable, depending on the outcome of studies of


the realistic probabilities and consequences of accidents of current


systems, and upon the large-scale introduction of other reactor types


(HTGRs, LHFBRs).


    With regard to emergency radiological monitoring, agreements among


AEC, OEP, DCPA, HEW, and EPA call for the establishment of radiation


detection and measurement systems by EPA in cooperation with AEC.  It


appears that the major effort required in this area is_ng_t_the invention


of basic new monitoring techniques but rather the identification and



                                    C-22

-------
                                              REVISION MARCH  1973


development of practical fsyatS8SB''~ suitable for emergency  use in

the field including consideration of existing national radiation

monitoring networks.  Both AEC and EPA work in this area is contemplated,

although the detailed coordination required to assure an optimum

effort has yet to be carried out.  A major input required to adequately

define emergency monitoring systems is a better definition of the

potential consequences and probabilities of accidents.  Such definition

will be provided by the quantitative risk determination study as

noted above.

     Finally, EPA-Regions will provide assistance to regional compacts,

and state and local officials in developing a.sufficient emergency

preparedness capability.  The major effort will be aid to lower level

governments in developing Emergency Plans, consistent with an AEC-issued

Guide.  ORP input to this Guide is planned.   The EPA-Regions will

utilize information developed by this program (e.g., PAGs) in their

efforts and will be aided by EPA laboratories  in promoting the

training  of emergency teams and  testing of the  Emergency Plans.

      In order to meet the schedule  for  the proposed  program  as  shown

in the Milestone Charts,  the near-term  ORP manpower,  contract funding

and ORM support levels  are estimated  to be:

      1.   Quantitative Risk Assessment:   2 MY  + $15K from  3/73  to  6/73

                                         2.5 MY +  $60K from 6/73 to 6/74

      2.   Basis  for  Judgment:             1.0 MY from 3/73  to  6/73
                                        + equiv.  of 2 MY  from ORM

                                         3.0 MY +  $65K from 6/73 to 6/74
                                         + equiv.  of 6 MY  from ORM
                                   C-23

-------
                                      REVISION MARCH  1973







     3.   Improved  Siting Criteria:     2.0 MY  from  3/73  to 6/73



                                      4.0 MY  +  $50K from 6/73 to 6/74




     4.   Emergency Preparedness        5.5 MY  from  3/73  to 6/73



                                      7.5 MY  +  $100K from 6/73  to 6/74




     Total                            10.5 MY  +  $15K from 3/73 to 6/73




                                      17.0 MY  +  $275K from 6/73  to 6/74




     It is difficult to estimate manpower and  contract funding require-




ments accurately beyond fiscal year  1974. While efforts related to




defining a basis for judgment could  likely be  decreased in FY 1974,



efforts in other areas would increase [e.g.  quantitative risk assessment




of HTGRs and PAGs  for other radionuclides Ce.g.  plutonium)].  It is




roughly estimated  that 20 technical  man  years  and $300K for  contracts




will be required each year from fiscal years 1975 and 1976.




    The schedules  noted in the Milestone Charts  are based on the




projected manpower levels noted above and were developed on the  basis




of assigning highest priority to BWRs and PWRs,  second priority  to  HTGRs,




and third priority to LMFBRs.  This  priority rating is based on  the



relative numbers of such plants  which are anticipated in the near  term.
                                     C-24

-------
                                                                     REVISION MARCH  1973
PROGRAM FUNCTION
                             FY-73
                                                        FY-74
                                                                                    FY-75
                                                                                                                    FY-76
                                                                                                                                         FY-77
ENFORCEMENT
LEGISLATION
RESEARCH &
DEVELOPMENT
MONITORING
INFORMATION
CRITERIA
AND
STANDARDS
TECHNOLOGY
ASSESSMENT
OTHER
FEDERAL
AGENCIES
                                   Contractor assistance In assessing QRA methods for reactor accidents
       Initial eval. of approaches
       & accuracy requirements for
       QRA methods for LWR
       accidents (6/73)
             Assess, of adequacy
             of ABC QRA methods
             for LWR accidents
             for use In EISs*
               (9/74)	
QRA for LWR accidents
(generic) ,AEC(9/73)
QRA methods for LWR
accidents suited for
case-by-case evalua-
tlon In EISs,AEC(9/74)
                                                                                           NOTE: QRA methods & generic  results  also
                                                                                                 assessed  for adequacy  as  Input to efforts
                                                                                                 In accident work areas 2,3, 44:
                                                                                                 2:  Effectiveness of QA,  tech  specs &
                                                                                                 engineered safeguards in  reducing
                                                                                                 accident  risks.
                                                                                                 3:  Input to refined siting criteria
                                                                                                      (generic)
                                                                                                 4:  Accident definition for emergency
                                                                                                 plans, emergency monitoring systems, &
                                                                                                 possibly additional PAGs.
Assess, of adequacy for AEC QRA
methods for LMFBR accidents for use
in EISs* (9/76)
                                                                      Asses, of adequacy of AEC QRA methods
                                                                      for HTGR accidents for use In EISs* 9/75
                                                                            QRA methods  for  LMFBR  accidents
                                                                            (both generic study  &  suitable for
                                                                            case-by-case review).AEC   (6/76)
                                                                QRA methods for HTGR accidents both generic
                                                                study & suitable for case-by-case review),
                                                                AEC (9/75)	
                                        MILESTONE CHART FOR ACCIDENT WORK AREA 1, QUANTITATIVE RISK ASSESSMENT   tt}RA)'OF REACTOR ACCIDENTS
                                                                          FIGURE C-l
                                                                                        C-25

-------
                                                                                            REVISION March 1973
PROGRAM FUNCTION
                                       FY-73
                                                                                  FY-74
                                                                                                                                FY-75
  ENFORCEMENT
  RESEARCH ADD
  DEVELOPMENT
  MONITORING
  INFOftMATTOM
                                 Risk Justification based on general societal
                                 values (CBN & review by special, public advisory
                                 panel), (generic area study)	
                                                                             Contractor assistance on costs of
                                                                             QA, Tech Specs, Engrd Safeguards
                                                                                 Justifiable risk foe total fuel cycle
                                                                                 (Input from generic area)*l/75	
  CRITERIA AND
  STANDARDS
 Initial stud; on
, total benefits of fuel
! cycle*(lnput froa
! generic area) 5/73
Parametric studies of
healft effects of accident
source terms as function
of arbitrarily selected
accident probabilities •
(12/73)**
                                                                                           1
                                        Develop mathematical
                                        framework  suitable  for
                                        subsequent application
                                        of a justifiable  risk
                                        criterion  when it is
                                        developed  (7/73)
                              J
  TECHNOLOGY
  ASSESSMENT
Apportionment of justifiable risk to LWR reactor
accidents (requires coordination with other clak
components)* **	3/75
                                                                  Input from work area 1, QRA for LWR's to assess effectiveness
                                                                  of risk reduction via QA. tech specs, and engrd  safeguards* ** 1/75
                                                                  Assess cost of risk reduction iron 1MB accidents (QA,  tech specs,
                                                                  and engrd safeguards) for use In cost-effectiveness study* 1/75
                                                                                                        Methods  to  form basis
                                                                                                        for  judgments  concerning
                                                                                                        LWR  accident risks  In
                                                                                                        EIS  reviews*    6/75
  TECHNICAL
  SUPPORT
                                         Compilation of Information
                                         from TVA and AEC on cost
                                         of QA, tech specs, & engrd
                                         safeguards	
  SIATES & REGION	
  OTHER FEDERAL AGENCIES
                                                                           FIGURE C-2
                                                             MILESTONE CHART FOR ACCIDENT WORK AREA 2
                                                  BASIS FOR JUDGMENT CONCERNING RADIOLOGICAL RISKS FROM ACCIDENTS
                                                              *SioHar vork geared  to HTGRe  and
                                                               IMFBRs paced by input  from work
                                                            .   area  I, QRA methods, or  benefit
                                                            .   study of  other  fuel  cycles (input
                                                            _  from  generic areas) .
                                                             **InpuC to  work area  3,  improved
                                                               siting criteria
                                                                                                       C-26

-------
                                                       RLVIMON MARCH  1973
PROGRAM FUNCTION FY-73
ENFORCEMENT
RESEARCH
DEVELOPMENT
MONITORING
INFORMATION
CRITERIA
AND
STANDARDS
TECHNOLOGY
ASSESSMENT
STATES
REGION
OTHER






—

f


Calculate dose as
""^ hydrology) for all
10 X DBA & DBA with
,(1/7^1
Ff-74 FY-75 pv-76

^ Propose new siting
te criteria (AECHl/74)





f (local meteorology,
LWR sites for DBA,
containment failure

1^ Calculate damage potential as 	
f (population) for each LWR 1
site (3/74) 1

1
Mathematical frame*
suitable for aubseq
application of a Ju
risk criterion when
developed (7/73)

Input on accident
approach to be
considered(4/73)



i



on siting

FEDERAL AEC-contraccor siting
AGENCIES criteria study
T
Rank LWR sites & asse
adequacy of proposed
siting criteria to pr
additional Input to A
(6/74)
	 '""'
Input from generic ORM i
risk justification task ,
(see accld. work area) 3/7,'3
t
	 i
t
\
\
i <

^ Issue ;Euid.
ovlde ™Si?ln5
EC (EPA acanda
i . i '.
ork 1
uent T j
stlflable ,
It is
.,..„ 	 	 ]....
In;
fol
(sc
are
ut from QRA I
LWR accidents " — •
e accident work j
a 1M9/74) .
Adopt final siting criteria
for LWRs (AECH9/75)

NOTE:
l)Non-reactor accident considera-
tions for siting criteria
handled by other portions of plan.
2) Efforts noted here keyed to LWB.
studies In accident work areas
1&2; ' 'mllar efforts for HTGRs
& LMFBRs paced by work area
162 outputs for such systems.
ance for
:rlterla
rd)(6/75)





MILESTONE CHART FOR ACCIDENT  WORK  AREA  3,  INPUT TO ,IMPROVED SITING CRITERIA (ACCIDENT CONSIDERATIONS)

                                            FIGURE C-3
                                                          C-27

-------
PROGRAM FUNCTION
                                FY-73
                                  FY-74
                      R2VISION MARC II  197J

                       1                FY-75
                                                                                                                                     FY-76
  ENFORCEMENT
  LEGISLATION
  RESEARCH AND
  DEVELOPMENT
  MONITORING
  INFORMATION
  CRITERIA AND
  STANDARDS
  TECHNOLOGY
  ASSESSMENT
                            a sue  Guide tor
                           Emergency Plans  (AEC)
                       Implement Emergency
                      Monitoring System (AEC)
       Develop program with AEC
       for Emergency Monitoring 9/73
                          I Determine Risk of Evacuation  8/731
            Demonstration of
            Emergency Monitoring
              System	6/74
  FIELD OPERATIONS AND
  TECHNICAL SUPPORT
  STATES AND
  REGIONS
                               [Determine Benefit of  Shelter 10 /73|
               Issue PAG for
               Evacuation 11/73
                                                      Issue  PAG
                                                      for Shelter  1/74
            Initial Assessment of
            Accident Level to be
            Considered in Emergency
            Preparedness
        Final Assessment of *
        Accident Level to be
        Considered in Emergency
        Preparedness      1/74
Evaluation of
Protective Measures
Emergency Monitoring
  Development	
                            Determine Protective *
                            Measures (e.g. Pu, Ru)
i
              Continuous input  from Regions  to States  in  development of Emergency Plans
              and training of Emergency Teams based  on AEC and EPA Accident Program Input
  OTHER FEDERAL AGENCIES	
              ^Similar work geared  to HTGR's  and LMFBR's
               paced by input from Work Area  1,  QRA  Methods
                                                                         FIGURE C-4
                                                MILESTONE CHART FOR ACCIDENT WORK AREA 4:  EMERGENCY PREPAREDNESS
                                                                                                  C-28

-------
                                                                                    RCVlhlUN  MARCH  197J
        FIIWTTfltf FT—71
                                                               FY-7A
ENFORCEMENT
LEGISLATION
RESEARCH AND
DEVELOPMENT
MONITORING
MFORMATIOH
CRITERIA AND
STANDARDS
                    Develop mathematical
                    framework suitable for
                    subsequent application
                    of a Justifiable risk
                    criterion when It is
                    developed (7773)
                             Her

                            ±
                                                        opose new siting  i
                                                      criteria  (AEC)(1/74)1
                                   Monitoring System(AEC)

                              Msk justification -baaed cm general societal
                              values (OEM & review by special, public advisory
                              panel), (generic area study)     (9/74)
                                 Development and Deoonstration of Emergency
                                 Monitoring System  (6/74)
I       I
             for LWRs (AZC)(9/75)
                                                                                                    ^•••••••••••••••qf •*••••••••*
                                                          Determine  Protective
                                                          Measures (e.g.,Pu,Ru)
TECHNOLOGY
ASSESSMENT
TECHNICAL
 SUPPORT
STATES AND
REGIONS
                Issue PAG for
                Evacuation
                (U/73)
                                                  Apportionment of Justifiable risk  to LVR  reactor
                                                  accidents  (requires coordination with  other  risk
                                                  conmonenGB)  (3/751
Rank safety of. IMS. sites i
assess adequacy of proposed
new siting criteria to pro-
vide additional input to
AZC  (6/74)	
I                                                Issue FAG          I
                                                for Shelter  (1/74)1
Issue PAS's
                                                                                            Issue guidance for
                                                                                            LMR siting criteria
                                                                                            (EPA standard)(6/75)
                                                 Assess,  coat  of  risk- reduction  from LVR accidents (QA,  tech specs,
                                                 and, engrd safeguards)  for  use In cost-effectiveness  study (1/75)
                                       Final assessment of
                                       Accident Level  to he
                                       Considered in Emergency
                                       Preparedness (1/74)
OTHER FEDERAL
AGENCIES
                                                 Assess, of adequacy of AEC
                                                 QRA methods  for LVR acci-
                                                 dents  Cor use in EIS's
                                                 Emergency Prep., Dev. of
                                                 Siting Criteria (9/74)
                                                                                   Methods  to  form basts
                                                                                   far Judgments  concerning
                                                                                   LWU accident risks  In
                                                                                   £IS reviews (6/75)
                                                                                                                                              1%*«»
                            Continuous inpur from Regions to States in development of Emergency Plans
                            and training of Emergency leaas based en. AEC and EPA Accident Program  Input
QRA for LWR accidenta
(generic) .AEC (9/J1)
                                                                    QRA methods  for LVR. accidents  suited for
                                                                    ease-by-easa evaluation in Eli's,  AEC (9/74)
                                                                          C-5    SUMMARY JULESTOWE CHART FOR  U.Tt ACCIDENTS

-------
                                         REVISION MARCH 1973
IMPACT OF PROPOSED PROGRAM COMPARED TO OPTIMUM



     The optimum program would be similar to that of the proposed




program except for two factors.  First, the optimum program would




apply significantly greater manpower (by a factor of ^1.5) in order




to speed up the program.  Hence the optimum program would allow review




of the safety of reactors on a risk/cost/benefit basis at an earlier




time.  In view of the many plants to be licensed over the next few



years and the fact that each plant has an expected operating life of




30 years, a more rapid completion of the program could have a major




impact on environmental protection if it turns out that currently




designed systems are not adequate.  If, on the other hand, quantitative




risk assessment indicates that the current protective features




used are unduely restrictive, presumably major cost savings could be




provided by reducing conservatism in design.  Of particular concern




are the relatively late dates for developing methods for assessing



HTGRs which are beginning to be introduced in a rapid manner in the U.S.




In addition, the optimum program would speed up the efforts related to




the adequacy of reactor siting criteria.  In view of the long lead




times required for site selection, increased near term efforts would




be expected to influence the siting of plants which would be operating




well into the next century.  In addition, the increased effort would



result in a significantly more rapid upgrading of radiological emergency




response capability.  In view of the current state of response capability




and the rapid increase in the number of reactors and related facilities




which is taking place, such upgrading is urgently needed.
                                    C-30

-------
                                        REVISION MARCH  1973






     Second,  the optimum program would apply yet  another factor




of 1.5 In manpower (or equivalent In contract help)  to assess the



validity of AEC efforts noted in the proposed program.  In addition




such manpower could provide ORP with information  for those areas




in which AEC efforts are not as timely or  complete as desired.






EXPECTED ACCOMPLISHMENT AND MEASUREMENT OF THESE  GOAL ATTAINMENTS



     The ultimate goal of this area is to  preclude any accidental




radionuclide release which would adversely affect the public, and




to assure adequate emergency preparedness  in the  event of such an




accident.  As such, ultimate "success" will be difficult to measure,




while "failure" will be obvious.  Since some accidents or incidents



will happen, however, limiting the extent  of radioactivity releases




to the environment and significantly reducing the impact of any



major release would provide some indication of a successful program.




     A more visible measure of program accomplishment will be to




assess the degree to which the schedules noted on the milestone



charts are met, and the degree to which ORP philosophy and impact



are utilized in enforcement actions by the AEC. The program  accomplish-




ment  can be  "measured" by assessing the reduction in  public  health and




environmental  risks from reactor accidents  (i.e. by quantifying the




reduction of reactor  accident probabilities  and  associated consequences)




resulting from the program.  It  should be recognized, however,  that since




the major portion of  the program is "preventive" rather 'than "cleanup"




In nature, the risk reductions will be calculated averages rather  than




physically measured values.







                                     -C-30A

-------
                     RADIOACTIVE-WASTE DISPOSAL





PROBLEM DESCRIPTION




Component Problems



     The disposal of radioactive wastes is common to every aspect of




nuclear energy use.  Areas of concern for the Environmental Protection




Agency include (1) the projected amounts of wastes that will be pro-




duced from operations of light-water and fast-breeder power reactors,




and the high-level and low-level wastes that will be produced from




fabricating and reprocessing fuels for these reactors; (2) the commer-




cially produced low-level wastes from reactor operations, research,




medical, and other sources that are currently being disposed in




State-licensed commercial burial grounds; (3) the AEC-generated low-




level solid, liquid, and gaseous wastes currently being disposed at




AEC facilities and laboratories; and (4) the AEC-generated high-level




and transuranic-contaminated wastes currently being stored at AEC




facilities and laboratories.  These areas of concern constitute the



four sub-activities of the proposed radioactive-waste disposal program




of the Office of Radiation Programs.  (See Figure C-10).




Background



     Radioactive wastes are currently being produced in a bewildering




variety of solid, liquid, and gaseous forms, are being treated in




complex ways, and are currently being stored or are disposed by a




variety of methods 'to ground, air, and water.  Decisions related to




disposal and storage of these wastes are complex because of the great




ranges in concentrations of various radionuclides in various wastes and
                              C-31

-------
 PAGE NOT
AVAILABLE
DIGITALLY

-------
the consequent ranges of their biological hazard potentials.  The



decisions are complicated further by the long-lived hazards of the



highly concentrated constituents of some of the wastes, that range



from a few years from some fission products, to as much as 200 years



for potential future concentrations of tritium, hundreds to a thousand



years for strontium-90 and cesium-137, and more than 100,000 years



for plutonium and iodine-129.



     The general nature of radioactive waste management and disposal



problems can be viewed in present-day terms as related to public-health,



technologic, and economic decisions concerning:



     •  the shallow land burial and the release to the environment



        of large volumes of low-level solid, liquid, and gaseous



        wastes versus segregation and concentration of these wastes



        for storage or for disposal in earth materials isolated



        from the biosphere; and



     •  the surface and near-surface storage in retrievable form



        of relatively small volumes of concentrated, high-level solid



        or liquid wastes versus the storage or ultimate disposal



        of these wastes in earth materials isolated from the biosphere.



     Decisions on all aspects  of radioactive-waste disposal should



be based on an orderly assessment of the public-health, technologic,



and economic factors of present practices and future conceputal methods.



Without such assessments it will not be possible for formulate criteria,



standards, and regulations that are appropriately conservative in



radiologic terms, but are not  unnecessarily restrictive in economic






                              C-33

-------
terms.  The responsibilities of the Office of Radiation Programs



relevant to radioactive-waste disposal are immediate because of the



necessity for technically based decisions on the radiological-health



aspects of Environmental Impact Statements, the responsibility for



assessing technology related to radiation matters, the responsibility



for developing radiological-health criteria and standards, and the



necessity for providing technical assistance and consultation to State




agencies.



     The field and scope of problems of radioactive-waste management



and disposal are such that the Office of Radiation Programs cannot



embark on an overall program of research and development, which seems to



be the responsibility of the nuclear industry and the Atomic Energy



Commission.  Nevertheless, a comprehensive program of evaluational and



conceptual studies is necessary to provide the data base and back-up



for EPA decisions, to identify and sponsor topical research in neglected



areas, and to provide a consistent national approach to public-health



and safety concerns related to management and disposal of radioactive



wastes.  Such a program, properly coordinated with AEC and other Federal



agencies, State agencies, and industry, would provide EPA leadership



to the currently fragmented and inconsistent approaches to disposal



practices for existing wastes.  The program would also address the



longer ranging EPA responsibilities related to the development of



nuclear energy and would provide the basis for developing and sub-



stantiating adequate criteria, standards, and regulations for commercial
                               C-34

-------
power-reactor wastes and for determining the ultimate fate of the



storage or disposal sites for these wastes.






LEGISLATIVE STATUS



     The Resource Recovery Act of 1970 CP.L. 91-512) specified, in



Sec. 212, that the Secretary of the Department of Health, Education,



and Welfare will supply to Congress a comprehensive report and plan



for the creation of a system of national disposal sites for the storage



and disposal of hazardous wastes, including radioactive wastes, which



may endanger public health or welfare.  The authority for this work



has been transferred to EPA, with the Office of Solid Wastes as the



lead organization.  The problems of radioactive wastes require special-



ized technical competence and are critical to the mission and ongoing



work of the Office of Radiation Programs; therefore, it is desirable



that ORP assume the lead for the portions of P.L. 91-512 that apply to




radiation matters.



     From the wording of P.L. 91-512, the intent of Congress seems



clear that the Federal responsibility for the disposal of hazardous



wastes, specifically including radioactive wastes, will reside with



the Environmental Protection Agency.  This is consistent with the more



limited authority of the Atomic Energy Commission which exercises



control only on those who actually possess radioactive materials.



This authority and its accompanying regulations apply to radioactive



materials on the ground surface at disposal sites.  However, according



to prevailing philosophy of the Regulatory portion  of AEC  concerning
                                 C-35

-------
commercial waste-disposal facilities, when the radioactive materials



are buried in the ground, and thereby are no longer in the possession



of the user, AEG licensing is no longer required.  The responsibility



for the buried wastes is then transferred by legal agreements to the



States which issue licenses and establish regulations for the sites.



     The transfer of the functions of the Federal Radiation Council



to the Office of Radiation Programs provides the general authroity to



issue Federal guidance in radiation matters.  Further, there is an



implied responsibility, in terms of those responsibilities transferred



to ORP from AEG, to assure that the controls exercised over the licensees



possessing radioactive materials will include proper disposal procedures.






COORDINATION



Intra-Agency



     The Office of Solid Wastes is currently proceeding with general



contract studies covering the management and disposal of all hazardous



wastes, as required by the Resource Recovery Act of 1970.  A comprehen-



sive report to Congress on these studies is required by the law in



mid 1973.  Liaison between ORP and OSW has been established, but



additional consultation and cooperation will be required to assure a



coordinated EPA approach to the portion of the OSW effort devoted to



radioactive-waste disposal.



     The Office of Radiation Programs is the lead organization in EPA



for radiation aspects of environmental protection including reactor



operations, nuclear fuel fabrication and reprocessing, and disposal of
                                C-36

-------
radioactive wastes.   Therefore, the ORP needs are immediate for com-




prehensive and detailed data and analysis on critical aspects of



radioactive-waste disposal.   The ongoing activities of ORP provide the



basis for the continuing development of this program.  The ORP program



will be coordinated to provide evaluations and policy guidance on



radioactive-waste disposal which will augment the general OSW studies




of hazardous wastes.



     OR? has established a coordinated team effort with NERC^WESL to



operate with appropriate EPA Regional offjLces_in review of radiation



aspects of AEC operations and disposal practices.  Continuing coordin-




ation will be necessary for 2 to 3 years.



Inter-Agency



     A considerable Federal effort, including work in other parts of



EPA, the AEC, the Department of Interior, and the Department of Defense,



is underway on the overall field of waste disposal.  Therefore, it will



be necessary to establish liaison and coordination between ORP and these



agencies to keep abreast of current developments.  It will be desirable




to solicit consultation and advice from other agencies by establishment



of an inter-agency task force or working group.



EPA-State



     Under ORP sponsorsorship the Conference of State Radiation Control



Program Directors has established a Task Force on Radioactive Waste



Disposal which will be advisory to ORP.



     ORP is currently providing financial assistance to States having



commercial waste-disposal sites for the purposes of inventorying and
                                  C-37

-------
analyzing the existing commercial wastes.   OEP anticipates continuing



technical assistance and coordination as part of the on-going State




programs.



EPA-Industry



     It will be desirable to continue EPA-Industry liaison through



appropriate committees of the American National Standards Institute,




and to establish consultation through the Atomic Industrial Forum and



other groups.






ALTERNATIVE APPROACHES



     Several alternative approaches to radioactive waste disposal



problems are possible for ORP.  Briefly, these are as follows:



1.  Maintain general cognizance sufficient for review of Environmental



    Impact Statements.  Maintain general liaison with other parts of



    EPA and provide advice and consultation as requested.



2.  Develop the recommended optimum 4-year ORP program on the four



    areas of concern (described below) that will accommodate the



    overall needs and mission of EPA, and also will permit EPA



    leadership in a timely and nationally consistent program of



    radioactive-waste management and disposal related to the develop-



    ment of nuclear power.




3.  Develop an alternative ORP program (described below) to provide



    a data base adequate for defining problem areas and potential



    environmental hazards.  Develop conservative radiation-health
                                  C-38

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    criteria and, ultimately, conservative general policy, criteria,
    and standards for storage and disposal of radioactive wastes to
    provide guidance for other EPA activities and state consultation.
    The program would involve some cooperation between ORF, Regions,
    NERC, and AEG in acquisition and analysis of the data base.


OPTIMUM PROGRAM
     An optimum ORP program would address the four component problem
areas, or subactivities (above), in sufficient depth to accomplish
the ORP missions connected with Environmental Impact Statements,
radiological-health criteria and standards, assistance and consultation
to States, and the Resource Recovery Act of 1970.  The program would
provide a consistent national approach to the immediate public-health
and safety concerns related to existing AEG and commercial radio-active
wastes.  Additionally, the program would comprehensively utilize the
remaining lead time (about 5 years) before the fuel-reprocessing and
reactor-operational wastes from the nuclear-power industry will begin
to require major decisions concerning storage and disposal.
     The program would consist mainly of conceptual and evaluational
studies, augmented by Federal-State-Industry consultation, to assess
current knowledge, technology, operational experience, and planning.
Gaps in knowledge will be identified for research or will be treated
in appropriate manner during development of the criteria, standards,
and regulations which would be the major goals of the program.  EPA-
Industry consultation is vital on all phases of technologic assessment,
                               C-39

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economic and geographic evaluations,  and in the development of regula-




tions.  This can be accomplished through liaison and participation with




the American National Standards Institute, the Atomic Industrial Forum,




and by other means such as Government-Industry advisory task forces.




     The Optimum Program would consist of three phases and would extend




from FY 1973 to FY 1976, with a possible extension through FY 1979.




(See milestone chart for Optimum Program.)  The phases would consist



of (1) establishing a comprehensive data base, (2) analyzing and




evaluating existing disposal practices and conceptual methods to develop




EPA radiation-health criteria and interim positions, and  C3) developing




EPA general policy, criteria, standards, regulations, and overall




recommendations to Congress which would lead, potentially, to establish-




ment of carefully selected, evaluated, and regulated national repositories




for various kinds of radioactive wastes.




External Needs



     Parts of the needed information for beginning the program are being




obtained from existing literature and documents as part of current ORP




activities.  Because of manpower limitations within ORP it will be




necessary to obtain other information, state-of-the-art assessments,




and needed research through contracts with consultants, industrial




firms, and other Federal agencies in specific technical fields.  QRP-




State program elements underway include obtaining inventories, of wastes




and reviewing management practices at existing commercial burial grounds.




Additional efforts in reviewing hydrogeology and other environmental




factors, monitoring procedures, needed additional site investigations,






                               C-40

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and applied research will require a continuing joint ORP-State program.




Acquisition of similar information about AEG sites will require cooper-




ative action with AEG.  Reviews of sites and operations will require




ORP coordination of teams from NERC-WERL that will include representa-




tives from various Regional Offices.  ORP sponsorship will be required




for the Task Force on Radioactive-Waste Disposal of the Conference of




State Radiation Control Program Directors and Federal interagency Task




Forces (yet to be established).




Internal Needs




     Much of the necessary administrative, supervisory, and technical




competence, as well as the necessary overview for the Optimum program




currently resides in ORP.  The full-time assignment of 5 professional




personnel will be necessary to manage and coordinate activities, to




sponsor and monitor research, to analyze data and prepare reports, and




to provide liaison and coordination with other Federal, State, and




Industry organizations.  An additional 5 professional personnel will




be required for topical investigations and preparation of reports in




specific areas of competence.





PROPOSED PROGRAM




     The Proposed Program also would address the four component problem




areas (subactivities) in sufficient depth to accomplish the ORP missions




connected with Environmental Impact Statements, radiological-health




criteria, assistance and consultation to States, and the Resource
                                 C-41

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Recovery Act of 1970.  The main objectives would be completed  in FY 1973-



1976.   (See milestone chart  for Proposed Program.)



     The Proposed Program would consist of establishing essentially



the same data base (Phase 1) as the optimum program.  However* the scope



of evaluational studies (Phase II) would be reduced considerably in



the Proposed Program.  In connection with existing wastes at commercial



burial  grounds and AEG sites, the Proposed Program would concentrate



mainly  on determining and defining potential problem areas and developing



EPA positions and recommendations concerning the problem areas.  In



connection with future commercial fuel-cycle wastes, the Proposed Program



would concentrate mainly on developing radiation-health criteria for



disposition of various radionuclides; on assessment of proposed con-



ceptual methods such as engineered surface storage or subsurface disposal



in optimum earth materials; and on development of EPA general policy,




criteria, standards, and regulations concerning these methods. /Poten-



tially, the alternative program also would lead to the establishment



of national_reppsitories for radioactive wastes.  /



External Needs




     As with the optimum program, parts of the needed information for



beginning the program and establishing the data base (Phase I) will be



obtained from existing literature and documents, through existing State




programs, through ORP-NERC-Region teams, and through cooperative action



with AEG.  ORP sponsorship will be required for the State Task Force on



Radioactive Waste Disposal and for Federal interagency task forces.
                                 C-42

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     Because of the lesser scope of the Proposed Program, the Phase II



contractual needs for research, state-of-the-art assessments, and site




Investigations by private, State, or Federal organizations outside ORP



would be minimal.



Internal Needs



     The Proposed Program will require the assignment of 5 professional



personnel in ORP to manage and coordinate activities, to analyze data



and prepare reports, and to provide liaison and coordination with other



parts of EPA and other Federal, State, and industry organizations.  An




additional 5 personnel will be required for about half-time efforts



for topical investigations and preparation of reports in specific areas



of competence.



Comparison of Optimum and Proposed Programs



     The recommended Optimum Program and the Proposed Program would both



consist of conceptual and evaluational studies to provide the data base



and essentially the same preliminary definitions of potential problem



areas•and environmental or radiation hazards.



     In Phase II the general approaches and depths of consideration of



the two programs diverge.  The Optimum Program would develop and apply



EPA radiation-health criteria to assessments of actual situations



associated with current methods of disposal of commercial and AEC-




generated wastes to determine environmental limits of current practices



and sites, and also would apply the criteria to various conceptual




methods for disposal and storage of various projected nuclear power



wastes.  This would assure effective assistance to States, authoritative



recommendations concerning AEG wastes, and positive, well-founded





                             C-43

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radiation-health leadership in the waste-disposal aspects of nuclear-


power development.  As further steps, the Optimum Program would assess


the technologic feasibility of various methods of storage and disposal


and the economic, geogrpahic, and geologic-hydrologic aspects of waste-


disposal siting in order to assure a practical approach, consistent


with public-health, to the development of general EPA policy, criteria,


and regulations.


     Phase II of the alternative program would concentrate mainly on


applying radiation-health criteria to analyses of the defined problem
  i

areas and potential hazards of existing wastes and making recommendations


to States and AEG toward solving these problems.  In connection with


future wastes from the development of nuclear power, the alternative


program would concentrate on developing necessarily conservative general


EPA policy, criteria, standards, and regulations concerned with public-


health aspects of ideal or optimum methods of storage and disposal.


     With the alternative program the general mission and responsibili-


ties of EPA can be accomplished in terms of critical review, problem


identification, and development of guidance, criteria,  standards, and


regulations.  However, the alternative program will not permit the EPA


to exert strong leadership in developing radiologically safe and


economically practicable management and disposal practices.


MEASURES OF GOAL ATTAINMENT


Fiscal Year 1973


     -  Complete evaluations of Federal and State criteria  and


        regulations for radioactive-waste disposal.
                                C-44

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Fiscal Year 1974



     -  Complete inventories of existing waste-disposal facilities.



     -  Complete definitions of potential problems and hazards of



        existing sites.



     -  Complete EPA radiation-health criteria for various radionuclides,



Fiscal Year 1975



     -  Complete evaluations of the necessity for continuing interim



        storage for radioactive wastes.



     -  Develop EPA positions and recommendations for disposal at



        existing commercial sites and storage and disposal at AEC sites.



Fiscal Year 1976




     -  Complete EPA general policy, criteria, standards, and regula-



        tions concerning storage and disposal of radioactive wastes.



     -  Complete overall summary report  and recommendations to Congress.



Fiscal Years 1977-1979



     -  Complete national repositories and determine ultimate fates



        of wastes and repositories.
                                 C-45

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                      NUCLEAR FUEL REPROCESSING






PROBLEM DESCRIPTION



     The objective of this program is to fulfill the obligations of



ORP/EPA set forth in Public Law 91-190 that is:  (1) to mitigate the



impact of the environmental radiation challenge by consideration of



environmental, ecological, and social costs associated with nuclear



fuel reprocessing plants; (2) to assist decision makers by indication



of the costs and benefits of the various alternatives available for



controlling any projected adverse impact associated with such plants.




Background



     Uranium-235 is the only fissile material found in nature in



sufficient quantities to be of practicable use.  Naturally occurring



uranium contains about 0.7% U-235 and approximately 99.2% U-238, a



fertile material.  Under neutron irradiation U-238 Is transmuted to



U-239 which subsequently decays by beta emission to Pu-239t a fission-



able material.  A second fertile material which is readily converted



to a fissile material by neutron irradiation and beta decay is Th-232



from which U-233 is obtained.



     A typical light water reactor is loaded with about 100 tonnes (long



ton) of slightly enriched (2 to 4%) UO-.  Subsequent to long-term reactor



operations, fissile materials are Intimately mixed with the fission



products; and must be chemically separated before they can be recycled.



This separation process is known as fuel reprocessing.




     Both U-233 and Pu-239 are candidates for breeder reactor fuels.



Since they are not found naturally (their half-lives are relatively
                             C-46

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short compared to U-235), they must be produced by transmutation.



Because they also fission under neutron irradiation, the reprocessing




of spent nuclear fuel (or blanket material) is a necessary step in a




breeder program.



         A variety of processes were used in the past most of which



performed satisfactorily for plutonium recovery.  However, the fission



product wastes were often left in a state unsuitable for solidification



or other processing to facilitate waste management.  The Purex process



is currently used at all operating AEG and commercial facilities.  The



high level wastes are left in an acid solution and thus are amendable




to solidification.



         Three processing plants are currently operated by contractors




for the AEC at Hanford, Idaho, and Savannah River.  The commercial



plant owned by Nuclear Fuel Services has operated since 1966.  The



Midwest Plant owned by G.E. and located near the Dresden nuclear power



site is essentially completed and is in the final stages of the



licensing process.  A large commercial plant is under construction in



Barnwell County, S.C. adjacent to the Savannah River Plant.  A fourth



commercial facility was originally planned for South Carolina and



preliminary designs were completed.  However, this  plant was canceled



due to lack of  contracts with utilities.  On the basis of projections




of power requirements  (nuclear-electric),  it appears that the three



commercial facilities in use or under construction  will provide



sufficient capacity for the next ten years.



         Development work  for reprocessing nuclear  fuels  is being



conducted primarily at ORNL.  Most of this work is  oriented to the






                             C-47

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development of methods for High Temperature Gas Reactor (i.e., U-Th




cycle) fuels.  Idaho is also participating in this developmental work.




Preliminary investigations for LMPBR spent fuel characteristics are




also being conducted at ORNL.  It appears that the LMFBR fuel can be




processed using the same technology as is used in processing LWR fuels.




The three fuel cycles have differing criticality problems, however,




which mitigates against using identical processing operations and




facilities.




Component Problems




     The development and implementation of a publically acceptable




administrative method for controlling any projected adverse impact




associated with nuclear fuel reprocessing plants (present and future)




constitutes a major problem to be solved by EPA.




     Much public concern exists regarding the use of nuclear energy




for public in general and opponents of nuclear power in particular, to




believe any pronouncements of the AEC relative to the adequacy of their




regulatory activities to prevent adverse environmental impacts.  Since




nuclear fuel reprocessing represents a major component of this endeavor,




any policy which can provide control that will alleviate the concern




will in turn contribute to avoidance of the projected energy shortage.




     Fuel reprocessing plants are the main source of waste which comes




from the nuclear industry.  The quantity of radioactivity in the waste




material represents 99.9% of the fission products which were in the




spent fuel.  Approximately 1 - 1/5% of the plutonium produced is found




in the waste stream also, although it is expected that this level will
                               C-48

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be reduced to 0.5%.   An example of the specific activities of the main




fission products in LWR spent fuel elements for 90 and 150 days is




presented in Table C-2.




     Individual fuel reprocessing plants are being designed to process




as much as 1500 metric tons/year with a total capacity of 1200, 3100




and 6700 metric tons per year projected as being required for the




years 1975, 1980 and 1985 respectively.




     This quantity of radioactivity greatly exceeds the total in




the waste produced from all other sources.  In view of these consider-




ations and the relatively few number of plants that have been projected




as being required to provide reprocessing capability, special waste




management techniques are mandatory for such facilities in order to




avoid adverse environmental impacts.




         The radioactive pollutants that can be released from nuclear




fuel reprocessing plants can be distributed both locally and worldwide.




Although the worldwide health impact may be small relative to background;




permitting the worldwide distribution of radioactive material can have




impact on our foreign policy — in much the same manner as atmospheric




testing of nuclear explosives.  This problem is compounded by the fact




that the benefits associated with any planned releases accrue directly




to the local and national population groups and only indirectly  (or




possibly not at all)  to  the worldwide  population  group.




         The problem  defined must be resolved for establishment  of




policy regarding siting, normal operation, and decommissioning.  The




parameters requiring  consideration  include the following:
                                C-49

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                        TABLE C-2
    PRODUCTION RATES OF THE MAIN FISSION PRODUCTS
                        IN A LWR*

Isotope


Tritium
Krypton 85
Strontium 89
Strontium 90
Yttrium 90
Zirconium 95
Niobium 95
Ruthenium 103
Ruthenium 106
Antimony 125
Iodine 131
Xenon 133
Caesium 136
Caesium 137
Barium 140
Lanthanum 140
Cerium 141
Cerium 144
Promethium 14]

Half-life


12.3 years
10.76 years
51 days
28 years
2.60 days
65 days
35 dyas
40 days
1 year
2 years
8 days
5.2 days
13 days
30 years
12.8 days
1.6 days
32.5 days
285 days
2.6 years
Radioactivity 90
days after dis-
charge from LWR
curies per tonne
of fuel
6.98 x 10?
1.13 x 10?
2.14 x 10^
7.69 x 107
7.69 x 10:
5.24 x 10^
8.69 x 10^
2.55 x 10^
4.59 x 10,
8.48 x 10,
3.81 x 10Z
2
5.10 x 10^
1.07 x 10^
1.11 x 107
1.28 x 10*
2.05 x 10^
8.92 x 10^
1.04 x 103
Radioactivity 150
days after dis-
charge from LWR
curies per tonne
of fuel
6.92 x 10?
A
1.12 x 10?
9.6 x 107
7.66 x 10*
~ c
2.76 x 10J
5.18 x 10^
8.9 x 10:
A.I x 10*
8.1 x ID"*
2.1
1
2.08 x 10r
1.06 x 10,
3.23 x 10*
j.
5.67 x 10?
7.7 x 10T
9.9 x 10*
*LWR of about 1100 MWe;  fuel 90 tonnes of enriched uranium;
 Burn-up 33,000 Hvd/t;   specific power 30 Megawatts per
 tonne.
                     C-50

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     Accidents



     Disposal



     Occupational



     Transp ortation



     With the advent of the LMFBR and associated "energy parks,"




additional problem areas will include:



     Fabrication - Plutonium




     Operation - Plutonium



     Operation - Uranium



     Should the "energy park" concept be applied to LWR and HRGR fuel



cycles, additional problem areas will include:



     Fabrication - Uranium (includes Thorium cycle)



Scope



     Present.  The present situation may be described as one of slow



but deliberate growth with a transfer of technology from the government



to the private sector.  The technology base is extensive and the docu-



mentation prolific, the latter peaking recently with the publication




of ORNL-4451 (Siting of Fuel Reprocessing Plants and Waste Management



Facilities) which address virtually all associated problem areas, but



essentially begs the basic question of need for reprocessing in an



absolute sense.




     To date, only one commercial fuel reprocessing plant has been in



operation and its experience has been limited to reprocessing of highly



decayed spent fuel.
                                  C-51

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     Based upon operating experience to date, two major categories may




be delineated - effluents and facility operations.  Regarding effluents



the following is the norm at present:



     •  Uncontrolled release of long half-lived Kr-85 and H-3.




     •  Controlled release of long half-lived Co-60, Cs-134, Cs-137,



        and Sr-90, short half-lived Ru-106, and very long half-lived



        1-129 and actinides.



     •  Controlled release of other isotopes in virtually negligible



        amounts by comparison.



     Because of the long cooling times of spent LWR fuel reprocessed



commercially to date, little experience with relatively short half-




lived 1-131 effluent has been attained commercially.  Thus, 1-129



control technology has also suffered.



     The major facility problems are associated with waste storage



(not significant to date), accidents (none serious to date) and trans-



portation (some significatn operational experience has been gained).



     Future.  Projections of the extent of future problems are weighted



heavily by the LMFBR program.  The LWR spent fuel reprocessing load is



expected to peak throughout the 1990's, with a rapid decay after the



introduction of the LMFBR.  Many projections, however, appear to have



underestimated the growth being experienced by the H.TGR (U-Th cycle),



the impetus for which comes primarily from private industry.  Thorium




processing poses somewhat different operational requirements and problems•



An estimate of the total quantity requiring processing for the various



cycles is presented in Figure C-ll.






                                  C-52

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100,000
 80,000
 60,000

 40,000 -
  10,000
  8.000
  6,000
     .10
YEAR  1970
1980
2000
             1990

           FIGURE C-ll

U.S. FUEL DISCHARGES BY FUEL TYPE
2010
                                                                   -0.05
2020
                                C-53

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     In their proper time frame,  then LWR (U)  reprocessing problems



will be most significant during the 1980-1995 period, HTGR (Th-U)



during 1983-2000 and LMFBR (Pu) beginning in 1990 and continuing



indefinitely.



     Because of the 30 day recycling period projected (by economic



considerations) for the Pu cycle, with higher burn-up fuel, the advent



of the "energy park" will impose a several order of magnitude increase



in all problems associated with this problem area.  In particular,



gaseous holdup tanks, presently the norm at PWR facilities, will be



required in energy parks; the amount of radioactivity contained



therein (about 1,000 times greater than at present) requiring under-



ground tanks and posing a potential accident problem.



     Certain general predictions regarding management of hazardous



waste can be made as follows:



     •  In general, by 1985 the off-site "disperse and dilute"



        disposal method will be virtually obsolete and on-site



        "contain and control" will reign.



     •  Solid and liquid wastes will probably be stored above ground,



        awaiting a solution to the problem of ultimate disposal.



     •  Decontamination factors for iodine will still not be quite


                                   —8
        satisfactory to purists (10   is rather small).



     •  Energy parks, "criticality," fire, siting, transportation,



        fuel cycle (Pu, Th, fusion, solar) tradeoffs, off-shore



        reprocessing and deep-sea burial, and "accidents" will reign



        as.-the major problems.
                                 C-54

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LEGISLATIVE STATUS



     EPA has authority primarily to provide guidance, or set standards,




but not enforcement authority.  The statutory authority of EPA to




advise the President on radiation matters affecting public health is




derived through the transferred authority from the former Federal




Radiation Council (FRC) (42 U.S. Code 2021h).  In addition, the




Reorganization Plan No. 3 of 1970 provided for EPA to assume the




responsibilities for setting generally applicable environmental




standards, which were formerly held by the Division of Radiation




Protection Standards of the Atomic Energy Commission.  Authority to




protect the public health is derived by EPA from the Public Health




Service Act.  Possible authority to regulate radioactive materials




may be derived through the implementation of the Clean Air Act or the




Federal Water Pollution Control Act, although the legislative history




of these acts casts some doubt upon the applicability of them to AEC




regulated licensees and materials.  Although EPA has no specific




authority to set uranium mining radon daughter limits, the setting




of these standards on the request of the Department of the Interior




(Bureau of Mines) is an example of the general EPA policy of advising




other Federal agencies with regard to radiation safety.






COORDINATION




Interagency




     Since all fuel reprocessing plants, commercial and governmental,




are regulated by the AEC, a majority of interagency activity will be
                                  C-55

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with that particular agency.  It is anticipated that interactions with




other governmental agencies will be required to a lesser extent with



regard to specific topics as follows:



     •  Federal Power Commission - Energy Requirements and Projections.



     •  Department of Commerce - Fuel Cycle and Waste Control Economics,



        industrial standards, etc.



     •  Department of Labor - Occupational Safety.



     •  Department of Defense - Safeguards and security.



     •  Department of Transportation - Transportation of Hazardous



        materials.



     •  Department of State - International implications of Kr and



        H-3 dispersal.



     •  Health, Education, and Welfare - Biological risk assessment



        methodology, demographic data.



     •  NOAA - Air transport and dispersal mechanisms and meteorological



        information.



     •  Department of the Interior - Geological, seismologies and



        natural resource information.



     •  CEQ - Environmental Impact Statements.



Intrageney



     The tasks outlined previously will require intragency interactions



as follows:



     •  OKM - Technique development, model development and data



        accumulation re-multiobjective decision making procedures,
                                 C-56

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        transport and dispersal mechanisms, reduction in uncertainties



        in risk assessment, compliance assessment instrumentation,




        determination of value Judgment for different target groups.




     •  OCP/OSW - Hazardous materials disposal sites.



     •  OPM/OPE - Promulgation of rules, economic analyses guidelines.




     •  OAW — Constraints for non-radiological pollutants.




     •  OGC - Legislative authority requirements.






ALTERNATIVE APPROACHES




     Two major alternative approaches are available for EPA to achieve




its obligations with respect to control of adverse environmental impact




from radiation facilities — specifically in this case from nuclear




fuel reprocessing plants.



     EPA/ORP may assume a passive role in which its programs in the




subject area are dictated essentially by inquiries from governmental




agencies, the public, intervenors and other institutions.  This approach




suffers from the fact that the priorities are essentially established




from without the office; the office is continually under pressure to




supply answers to inquiries, and there is no overall strategy.  This




inefficient approach is rejected in favor of the other major approach.




This second alternative to generate an overall program, such that those




technical and administrative problem which are common elements in the




overall list of problems may receive sufficient emphasis to be resolved




effectively.  In this case the overall program is active, the problems



are self-initiated in advance of external inquiry.  In this case,






                                  C-57

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priorities can be more easily controlled and resources used more




effectively.






OPTIMUM PROGRAM



     Any program to resolve the problems associated with, nuclear fuel




reprocessing is necessarily cyclic in that it must incorporate a method




which allows for introduction of technological advances and an updating




of management techniques.



     The Optimum Program should address the following questions:




     •  What are the electrical energy (power) requirements for both



        the short-term and long-term and what fraction of these




        requirements will be met through nuclear (fission) systems?




     •  For each of the fuel cycles under consideration, under what




        conditions can fuel reprocessing be justified when viewed




        with respect to the overall environmental impact?



     •  What are the protective action guides (levels and methods)




        for both normal and abnormal operations for each of the fuel



        cycles as a function of time?




     •  What are the appropriate criteria for siting, operation,



        and decommissioning for each fuel cycle?




     •  What is the most appropriate control technique and compliance




        assessment procedure for each fuel cycle?




     The program can be divided into the following functional elements:



     •  Criteria development.




     •  Procedures (Techniques) development.
                                  C-58

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     •  Data accumulation.




     •  Technology Assessment (Evaluation).



     •  Multiobjactive decision making CPolicy).




     •  Decision Implementation (Rulemaking  activity and




        Compliance assessment).



     •  Program management  (Planning,  Interfacing, Reports, etc.)*




     A program flow logic for the major decisions regarding siting,




operations, and decommissioning is displayed in Figure C-12.




External Needs



     Legislative Needs



     Some form of legislation is required to provide EPA with either




the authority to license and regulate  specific facilities which may




give rise to adverse environmental Impacts or the authority to regulate




other agencies and institutions which  control the specific facilities.




     Knowledge Needs



     Knowledge, including a mechanism  for its timely provision, is




required from various agencies external to ORP.   The needs include:




     •  A definitive listing of the independent objectives of EPA




        and the value functions for each of  the stated objectives.




     •  Power projections for specific nuclear fuel cycles.




     •  The status of development of new separation- technology for




        LMFBR and HTGR systems.




     •  The status of the development  of new effluent control tech-




        nology for iodine,  volatiles,  tritium, and the noble gases.
                                  C-59

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     (Criteria
      Devt.
9
o>
o
Initial  Conditions
Site 6 Facility
Charac ter is tics
  Size
  Location
  Fuel Cycle
  Controls
                                    UJ
[Release Mechanisms I
Operations L
Accidents P
Malevolent Acts |
4r
Transportation
Storage
Separation
Haste Management
Product Management
                             Impact Criteria

                               Health
                               Ecological
                               Economic
                               Political
                                   Inventory,  Release
                                   Rates,  Env. Trans-
                                   port, Media Concen-
                                   trations, Target
                                   transfer, Response
                                   functions
                                                                               zards  Analysis
                                                                                                          Adequacy Criteria
                                                                                                            Procedures
                                                                                                            Data
                                                Analytical Procedures
                  Control Methods Develop-
                  ment
                   Administrative
                   Engineered
                                                                            Decision making
                                                                             Procedures
                                                                                              commission,
                                                                                            Operation and
                                                                                              Siting
Economic
Analysis
Analysis Methods Develop-
 ment
  Dose Modeling
  Risk Modeling
  Benefit Modeling
  Multlobjective Deci-
   sion Making
                                                Analytical Procedures
     Program
      Devt.
                                                                             Political
                                                                              Analysis
               Data Accumulation
                                                Analytical Procedures
                                                                Objectives Redefined
                                                                Goals Redefined
                                                                  FIGURE  C-12

                                                 PROGRAM FLOW  LOGIC -  FUEL  REPROCESSING

-------
     •  The status of the development  of  waste disposal technology.



     •  The status of radiological health effects studies specifically



        for long-term low level exposures.



     •  Operational characteristics and release rate data for specific



        facilities of interest (both governmental and commercial).



     Research and Development Needs



     EPA Research and Development program needs include:



     •  Development of a decision making  methodology (risk/cost/benefit



        analysis).



     •  Determination of value judgments  regarding public health,



        ecology, and economics as viewed  by public, industrial and



        governmental population groups to provide basis for impact



        criteria.



     •  Development of an understanding of multiple stress health



        effects.



     •  Development of environmental transport parameters, media



        concentration factors, and intake/exposure parameters.



     Enforcement Needs



     Enforcement needs requires the development of enforcement methodo-



logy consistent with authority.



Internal (OKP) Heeds



     The knowledge methodologies and data required within the office



in order to fulfill the objectives of  the ideal program include the



following:
                                    C-61

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     •  Analysis models to assess risks/costs/benefits, ike., inventories,




        environmental transport, media-target interactions, target




        response models.




     •  Monitoring surveillance methodology.




     •  Acceptable impact criteria for health., economics, ecology, and




        policy for populations and individuals.




     •  Detailed fuel cycle economics.




     e  Details of engineered controls regarding decontamination




        factors (release rates), reliability and costs.




     •  Sensitivity of siting criteria to size, operations, accidents,




        transportation, configuration (i.e., energy park concept).




     •  Spent fuel projections and inventories for the various fuel




        cycles.




     e  Isotope specific risk indices with emphasis on I, H-3, Kr,




        alpha emitters and volatiles.




     •  Site specific demography.




     •  Influence of ultimate waste disposal strategy and techniques




        on fuel reprocessing facilities.




Milestone Chart




     The milestone chart for the Optimum Program is displayed in




Figure C-13. The dates for deliverable items is predicted on the assump-




tion that the siting criteria for facilities which process LMFBR fuel




should be available at least 10 years before the facility becomes




operational.  This assumption presumes that the energy park concept
                                C-62

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 PAGE NOT
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DIGITALLY

-------
will be applied to such facilities.   For facilities not utilizing the




energy park concept, a 5-year lead time is assumed to be sufficient.






PROPOSED PROGRAM AND COMPARISON WITH OPTIMUM PROGRAM




     The Proposed Program differs from the Optimum Program in that the




method proposed to administratively control the adverse environmental




impact is through:  (1) constant review and critique regarding the




adequacy of the licensing and regulating agency's specific administra-




tive control methods through FRG authority by comparison to EPA




criteria, guidance, and/or standards; (2) the use of the critique of



environmental impact statements; and (3) providing technical capability



to evaluate objectively a point of contention that may arise between




opponents and proponents of a given endeavor.



     In this case, there is no longer a need for further legislation




nor increase in enforcement capability.  The interagency agreements




are still required as are all of the knowledge and R&D efforts described




previously, however.






MEASURES OF GOAL ATTAINMENT



     The anticipated accomplishment is that EPA will influence the




control methods (both administrative and engineered) for nuclear fuel




reprocessing plants while simultaneously building credibility for



objectivity in the view of both the proponents and opponents.  Goal




attainment can be measured by the frequency and lapse time with which




EPA policy recommendations are incorporated into the positions regulating



agency and the intervenors.
                                 C-64

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                            THERMONUCLEAR





PROBLEM DESCRIPTION




     It is possible that towards the end of the 20th century thermonuclear




power (TNP) will be in use as a source of electrical energy.  The purpose




of this program is to develop a system for estimating the environmental




impact of TNP so that meaningful decisions can be made regarding its




introduction into the energy economy.




     The program presented below has two main objectives:




     •  to establish a time frame for EPA actions in this area of




        environmental protection responsibility, and




     o  to establish a means of monitoring present TNP safety and




        health risk evaluation programs so that potential problem




        areas can be identified in a timely manner.




Technical Background



     A nuclear reaction which combines atoms of low atomic number, such




as hydrogen isotopes, to yield atoms of higher atomic number like helium




is known as nuclear fusion.  Many such reactions have been identified




and several are highly exothermic.  For various technical reasons the




particular process most likely to be used initially for the production




of TNP is the deuterium-tritium reaction.





                2^ + 3T __^4He (3.5 MeV) + ln (14.1) MeV.





     Because tritium is needed as fuel, all proposed thermonuclear systems




are tritium breeders utilizing 14.1 MeV neutrons; the most promising




breeding reaction being






                *n + 3T _* 4He + V
                                C-65

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Predicted tritium breeding ratios are high (1.3) and  fuel doubling times




may be as low as one-tenth of a year.  Consequently the radiological




hazards associated with TNP are centered around accidental and routine




losses of the tritium inventory within a large fusion reactor and with




the activation products produced in reactor components by the fast




neutrons.




     Choice of the particular fusion reaction chosen  for TNP is limited




by plasma density, the temperature and confinement times needed to start




an exothermic process; the D— T reaction having the most favorable con-




ditions for initiation.  Other possible reactions such as the D-D and




the D- He reactions are much further from practical application but are




of environmental interest in that not only is neutron activation con-




siderably reduced but also most of the energy is available as charged




particles.  This latter feature could lead to direct  conversion to




electrical energy at very high thermal efficiencies and a reduction in




the thermal load to the environment.  It seems likely, however, that if




TNP is introduced as an energy source at least one generation of D-T




reactors will be built.  The problem analysis presented here is directed




at the expected environmental impact from first generation plants using




a D —T cycle.  Other fuel cycles which may be used in the future will




occur much later and present lesser problems.




     Present Problems




     Not only is there no present environmental problem from TNP, it is




even conceivable that there never will be.  Exothermic steady-state




fusion has not been demonstrated and the costs of TNP as a competitive
                            C-66

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energy resource have not been established.  Indeed there is a school of




thought that TNP implementation much later than the year 2000 will never




be economically feasible because of predicted technological improvements




in fission breeders.  It is probable, however, that a decision to use




INF will depend in part on environmental considerations.  A plan for




developing the necessary information on a timely basis if presented




below.




     Notwithstanding the possibility that fusion power may never be an




important energy resource, it would seem prudent for EPA to assume that




TNP is a likely option for fulfilling the national energy needs and to




prepare plans that will allow the environmental impact to TNP to be




explored before final commitments for large scale utilization are made.




It is noted that such a before the fact consideration of environmental




impact is a rather unique opportunity for EPA.  Hopefully, it can also




be a prototype problem for developing skills in preventing detrimental




environmental impacts rather than cleaning up after them.




     Future Problems




     The most likely sources of pollution from TNP are very large




electrical power plants.  (The possibility of distributed sources is




less likely and will be considered in a separate section.)  Present




thinking is that, to be economically viable, a TNP plant would need to




produce 2000 MWe in a single unit.  The possible impacts considered




below are based on a plant of this projected capacity.  Such a plant




would contain about ten kilograms of tritium of which only a few grams at




most would be in the plasma state, the rest would be circulating in the
                               C-67

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tritium recovery apparatus or be held up in the walls of the various

                                                             g
components.  Ten kilograms of tritium corresponds to about 10  curies.


The OBNL is currently predicting (for planning purposes), a tritium


inventory loss of one part per million per day (100 Ci/day) but this


projection is based on environmental considerations rather than available


technology.  At heavy water reactors where there is a large economic


incentive to conserve D20, the inventory losses are about 60 times


larger (60 x 10   parts per day) but it is best not to put too fine a


point on this difference since in actuality, tritium confinement will


depend in part on the configuration of fusion reactor and tritium


recovery systems not yet invented.


     A secondary source of possible radiological hazard from TNP is


from the induced radioactivity in reactor components due to 14.1 MeV


neutrons.  Metallurgical problems due to the anticipated flux of fast


neutrons are quite severe and it is anticipated many highly radioactive


components will need to be replaced throughout the lifetime of a fusion


reactor.  Indeed, selection of component materials will probably be


determined by their lattice stability under neutron bombardment.  In


any event, there will be a waste disposal problem associated with reactor


parts.  The magnitude of this problem will depend on the final selection


of reactor materials.  Niobium and vanadium are materials presently being


considered but these choices are too tentative to warrant a discussion


at this time of any specific health implications.


     Tritium production figures for a TNF powered world can be pretty

                                                 4
impressive since fusion does produce about 2 x 10  more tritium atoms than
                           C-68

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 fission  (for an equal energy increment).  However,  fusion also  consumes

 tritium  atoms so that a proper measure or its environmental  impact is

 the amount of tritium liberated into the environment.  Long-term storage

 of high  level T-O need not be a problem because if  the breeding ratio

 of a fusion reactor is reduced to less than 1, the  fusion process can

 be used  as a tritium waste disposal mechanism.   It will probably be

 necessary, at first, to breed tritium in fission reactors to provide

 the tritium for fusion reactor start up.  If an economically viable

means of concentrating tritiated wastes can be found, these wastes

 could be an alternate source of the needed tritium.  Any plans  for

 tritium recovery in fission fuel reprocessing should consider the possible

 economic incentives offered by a future TNF program.

     Tritium produced by a fission power plant enters the environment

 at two locations, near the reactor site and, with presently approved

practices, in the vicinity of the furl reprocessing plant.  While a FUR

plant releases more tritium at the reactor site than a comparable

boiling water reactor, in either case most of the tritium is released

at the fuel reprocessing site, as shown in Table C-3.  Fast fission of

Plutonium (in breeder reactors)  has a higher tritium yield than the thermal

fission of uranium as presently used in light-water reactors.  Indeed,

per Gigawatt-year of energy,  fusion and fast fission breeder reactors

could release about the same  amount of tritium into the environment if
*
 Because fusion reactors are such a copious source of fast neutrons they
 have been considered as a means of converting some long half life fission
 wastes to short half life isotopes by transmutation (ANS Trans. Vol. 15,
 //I).  The projected economic/power costs are rather severe but it is
 something ORP/EPA could bear in mind.


                               C-69

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                          TABLE C-3


          TRITIUM IMPACT FOR ONE GIGAWATT YEAR ELECTRIC
Slow Fission




     PWR


     LWR


   Fuel Reprocessing
    5.0 Ci
    0.5 Ci
18.0 x 10J Ci
at reactor site


at reactor site


at reprocessing site
Fast Fission




     LMFBR


   Fuel Reprocessing
Fusion
      2,3
 29 x 10J Ci
 18 x 10J Ci
at reactor site


at reprocessing site



at reactor site
 Assumed thermal efficiency 0.3.
2
 Assumed thermal efficiency 0.4.

 Assumed T release fraction 10 /day
                         C-70

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tritium containment in fusion reactors is held to 10   as predicted by


ORNL, Table C-3.


     Future power needs on the time scale of interest in a discussion of


TNP are not well known and may be subject to more societal control than


presently predicted by exponential growth curves.  There is some agree-


ment that if TNP is introduced t-he earliest this could occur is sometime


around the year 2000.  Taking 2000 as a starting point for a discussion


of possible levels of tritium contamination in the Earth's hydrosphere,


the total tritium inventory at that time will be about 700 MCi.  About


300 MCi of this tritium radioactivity is due to past weapons tests and


cosmic ray production 'and (assuming no tritium recovery in fuel repro-


cessing) about 400 MCi from fission generated electrical power, (2 x 10


Gwatts per year).  If this amount of fission generated electrical power


were replaced by TNP the amount of tritium generated and consumed by


fusion reactors would be 8 x 10  MCi per year.  The tritium inventory in

                                                    4
these fusion reactors might be something like 4 x 10 .MCi, of which


about 150 MCi per year will be added to the environment.  Any future


growth in generating capacity using TNP will increase environmental


tritium inventories by 75 MCi for each 1000 Gwatt years.


     Though fusion reactors are usually thought of as some sort of "plasma"


machine containing an ionized gas of reacting atoms, there is some dis-


cussion of a fusion reactor which depends on a sharply focused laser


beam to "ignite" a solid pellet of deuterium and hydrogen.  Perfection


of such a process might make it possible to reduce the scale of TNP


plants by several orders of magnitude if the explosion containment problems
                               C-71

-------
 are  also adequately solved.  Laser  "fired"  fusion plants utilizing such



 technology might be as small as 20  M Watt;  i.e.,  about one-third the



 size of a pre-1945 fossil fuel plant.  Development of small TNP sources



 would have both good and bad environmental  effects.   Though the control



 problem for tritium release would no doubt  be more difficult,  the total



 environmental impact from electrical power  generation might be reduced



 greatly.  It is often mistakenly assumed  that the thermal pollution pro-



 blems associated with electrical energy production started with fission.



 Rather, fission made the introduction of very large scale fission and



 fossil plants economically advantageous.  The net result is we are faced



 with meeting future energy needs with large point sources of thermal



 pollution where formerly the thermal impact of "old  fashioned" fossil



 plant was comparatively minor.  Introduction of small TNP reactors



 might allow the heat load on the environment to be spread out.   If



 siting problems can be solved it would also allow on-site production of



 electrical energy and heat with a resultant saving in energy transmission



 losses.



     Though the possibilities outlined above are  intriguing, it  would



 seem advisable to limit Cat this time) exploration of the environmental



 problems from a distributed source power  system utilizing small  TNP



 reactors.  A first generation of large TNP  breeders  will be needed to



 produce the tritium fuel for smaller TNP  sources.  We can also assume



 that any early fusion plants will be costly because  of developmental and



 safety costs; and consequently rather large so as  to reduce the  invest-



ment per unit of electrical production.   Finally,  the widespread applica-



 tion of small TNP units is an improbable  development, perhaps  two  orders
                              C-72

-------
of magnitude less likely than INP per se.  In any event, many of the radio-



logical studies for large plants would be directly applicable to small



plants as well; only the size of the source term changes.



     The predicted tritium inventory and rate of tritium release from



possible fusion reactors given above are certainly no better than order



of magnitude estimates at this early stage of hazard analysis.  They do



serve, however, to give a scale to the problem which perhaps allows a



tentative opinion.  The environmental impact from tritium due to an



energy economy based on TNP would be of the same order of magnitude as



that from one using nuclear fission.  Other radiological impacts would,



of course, be much less.  There would be no fission products.  There



would be no waste storage problem of plutonium and other long half life



biologically important isotopes, such as 1-129.



     Perhaps most important of all, the catastrophic accident problem is



largely removed by the use of TNP.  Not only is the potential energy in



the amount of the fuel (2 grams) being "burned" at any one time in a


                                     12
fusion reactor rather small, about 10   joules compared to that in an


         19
LMFBR (10   joules) but also the physical requirements for fusion to



occur are difficult to maintain.  Accidents in a fusion reactor which



perturb the carefully maintained physical conditions within the plasma



will terminate the fusion process.  The control problem is not how to shut



the thing off but how to keep it going.  Fast breeders have a different



set of problems.





LEGISLATIVE STATUS



     TNP would effect the general environmental levels of radioactivity



and therefore are under the general guidance and standard setting
                             C-73

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responsibilities of EPA.  Considering the time frame for TNF implementation




it is perhaps unrealistic to discuss any specific legal implications of




TNP in terms of the agency's present legislative status.  Rather in the




program plans presented below, suggestions are offered on how new




legislative actions might be coordinated with programmatic requirements.






COORDINATION




Interagency



     Interagency requirements for an effective coordination of the pro-




posed TNP hazard evaluation plan are listed in Table C-4.  The laser-




fusion program is currently budgeted under the AEC weapons development




programs and coordination with DOD is indicated.  However, the expecta-




tion is that if this line of research shows potential for TNP development,




part of it will be split out of the weapons program.  Currently the




proposed AEC budget (FY 1973) for fusion research and development is




$39 million for magnetic confinement studies with an additional $20




million in the weapons budget for laser related fusion studies.  Direct




DOD financing of high powered laser research, an unknown fraction of




which is related to fusion problems, was $100 million in FY 1972.




Intragency



     Intragency coordination requirements are two-fold.  Within ORP, the




problem areas associated with Plowshare, fuel reprocessing and to a




certain extent waste disposal, are related to the evaluation of possible




TNP hazards.  The Plowshare evaluation program, where tritium dose models




and health risk from environmental tritium must be considered in detail,
                              C-74

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                  TABLE C-4

           SHORT RANGE COORDINATION
INTERAGENCY

AEC HQ

DOD LASER TNP

AEC LABS

  ORNL

  LIVERMORE

  LOS ALAMOS

  PRINCETON
ORP/EPA INTRAGENCY

ORP PROBLEM AREAS

   PLOWSHARE - TRITIUM DOSE
               MODELS AND
               HEALTH RISK

   WASTE DISPOSAL
   FUEL REPROCESSING
EPA
   OFFICE OF RESEARCH AND
   MONITORING WATER QUALITY
   OFFICE
               C-75

-------
is particularly relevant.  It is assumed that the various ORP divisions




will contribute to an ievaluation of TNP environmental studies via the




problem area route rather than by means of specific line responsibilities.




     Eventually any large TNP operations will have impact on water quality




and ORP efforts in preserving water quality will be coordinated with that




EPA office.  Of more immediate interest are any ORM studies, present and




future, that are concerned with tritium distribution in the environment,




its possible reconcentration, and health impact.  Such studies must be




coordinated with TNP requirements as outlined in Table C-4.






ALTERNATIVE APPROACHES




     In terms of alternative approaches to potential TNP environmental




problems, EPA/ORP has two options.  One is to wait five or ten years to




see if exothermic fusion is demonstrated in the laboratory.  The other is




the establishment of a program now that will monitor ongoing health and




safety studies of TNP being performed by other agencies and, most important,




prepare plans that will allow the timely implementation of EPA directed




studies and regulations as TNP research progresses.  A plan outlining




the second approach is given in the next section.  At first glance a




"wait and see" policy has at least cheapness to recommend it.  However,




it is likely that this cost advantage would be wiped out in any rapid




start-up of a TNP program by staff personnel not familiar with TNP




problems.  The approach outlined below will insure that EPA/ORP will




have at least some expertise on TNP health implications on call at any




time.
                                 C-76

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     A "wait and see" approach also nullifies the impact a study of TNP




will have on other problem areas.  As pointed out in the section on




coordination, study of the potential release of tritium into the environ-




ment is common to a number of problem areas..   The information on the




health risk from tritium and the devleopment of good tritium pathways and




distribution models obtained in this study can be invaluable inputs to




a number of identified environmental problems.




     It should be noted that no optimum program is proposed.  The proposed




program is also the optimum program at this early stage of TNP develop-




ment.  The proposed program has built into it a means of reappraising




the scope of EPA/ OKP needs as research on TNP progresses.






PROPOSED PROGRAM




     A study of environmental TNP problems must be future oriented which




leads to the attendent difficulty that technological innovations cannot




be predicted with much precision.  Therefore, a plan for the study of




TNP environmental problems needs a degree of flexibility not typilfied




by other ORP problem areas.  Rather than just describing work areas and




needs in this problem area, a time frame for EPA actions is presented



in Table G-5, and then more specific needs are discussed in the context




of the milestone charts. Figure C-l4.




     A time scale for the study of thermonuclear power helps establish




priorities for EPA/ORP reactions to this environmental challenge.  The




dates presented in Table C-5 are neither projections nor speculations of




when actual events might occur.  Rather they have been postulated to
                                C-77

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 PAGE NOT
AVAILABLE
DIGITALLY

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                            TABLE C-5

         A HYPOTHETICAL CHRONOLOGY FOR TNP DEVELOPMENT
 TIME SCALE
(Fiscal Years)

  1973 - 1975

  1976 - 1980

  1981 - 1985

  1986 - 1990

  1991 - 1995


  1996 - 2000
TECHNOLOGICAL EVENTS OCCURRING IN THIS INTERVAL

Plasma Confinement Research

Laboratory Fusion

Fusion Reactor Development

Prototype Reactors are Built and Tested

First Generation Full Scale Reactors are
Planned and Constructed

Thermonuclear Electric Power on a Commercial
Scale
                              C-79

-------
provide some idea of the sequence of events and what the interval



between subsequent events might be.  The listed dates should be regarded



as gates.  When a significant event occurs in TNF technology this will



initiate certain actions and activities within EPA/ORP so that progress



in the solution of TNP environmental problems will coincide with the



implementation of TNP into the national energy economy.  The sequence of



events shown in Table C-5 represents an "optimistic" chronology in that



these events are unlikely to be earlier and may occur as much as 5 to



10 years later.  A long-range milestone chart showing how these events



trigger EPA/ORP responses is given in Table C-6.



EPA Responses to Progress in TNP Implementation



     The responses shown in the milestone chart, Table C-6, are triggered



by the events shown in the technology row.  Demonstration that sustained



fusion is possible will start the development of prototype reactor



systems.  However, before such a program develops its own momentum, a



decision on the applicability of TNP to national needs should be made.



It is outside the bounds of this study to define what the national



policy on energy regulation will be at that time.  There may be a single



Federal agency regulating all large energy sources or the multiple control



system now used may be in force.  Hopefully, some agency or group of



agencies will be in a governing postiion to consider whether a TNP



program should be initiated at all in view of the national energy needs,



types of energy resources available, and the expected environmental impact



of alternative energy sources.  It can be expected that the "costing"



of environmental detriments will be highly developed by the time TNP is
                              C-80

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                                                        TABLE C-6

                                              TIME SCALE FOR ORP/EPA ACTIONS
                              FY 73-75
               ENDING
               FY 80
FY 85
FY 90
FY 95
FY 2000
              TECHNOLOGY
              DEVELOPMENT
PLASMA
RESEARCH
FUSION IN
LAB
PROTOTYPE PILOT PLANT BUILD FIRST
REACTOR OPERATIONS GENERATION
DEVELOPMENT FULL SCALE
REACTORS
                                      THERMONUCLEAR
                                      POWER
              EPA RESPONSES   SEE TABLE
                                C-7
n
oo
              APPROVAL AS ENERGY SOURCE
              AFTER COMPARISON WITH
              ALTERNATIVE SOURCES

              WRITE ENVIRONMENTAL STANDARDS
              FOR DEVELOPMENTAL AND LATER
              REACTOR TYPES

              ESTABLISH SITING CRITERIA
              REACTOR

              SEE IF LEGISLATIVE MANDATE IS
              NEEDED
                                                                     SET FINAL
                                                                     1) CRITERIA FOR SITING
                                                                     2) REGULATIONS
                                                                     3) WASTE STORAGE
                                                                   MONITOR AND INSPECT
                                                                   TNP INSTALLATIONS
                                                                   PLAN FISION PLANT
                                                                   DECONTAMINATION AND
                                                                   DECOMMISSIONING

-------
considered and that such hidden costs will be given full weight in any




decision involving a choice between energy sources or the switch from




one source of energy to another.  It is mandatory that EPA/ORP be in




a position to provide the necessary environmental impact information




as needed as soon as a successful fusion system has been defined by the




engineering community.




     Assuming a TNP development program is initiated after due consider-




ation of the EPA/ORP recommendations, it will be necessary to provide




environmental standards for prototype TNP reactors.  Rather than the




piecemeal implementation being followed in the consideration of environ-




mental impacts from LMFBR systems, a more global approach should be




used for TNP.  This should include setting interim guidelines for all




future reactor developments such as permissible tritium losses, waste




disposal regulations and siting criteria so that the development of




TNP can take place within a framework that minimizes environmental



problems.  Consideration of legislative problems that may follow such




an approach is outlined in a separate section.




     After the monitoring of TNP pilot plant operations have established



the relationship between predicted and actual releases and any unexpected




problems have been recognized and evaluated, final criteria and regula-




tions for TNP environmental effects should be set, as shown in Table C-6.




This should occur before the full scale systems are designed and in the




construction phase.   Finally, EPA/ORP should consider the set of problems




associated with the decommissioning of fission plants as they are replaced



by TNP units.
                             C-82

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     A shorter range view of needed ORP/EPA actions  is shown in Table C-7.




The  immediate need is for an information monitoring  program to provide




inputs into ORP/EPA judgments of the potential  environmental effects from




TNP.   (It is contemplated that other ORP problem areas will be a position




to furnish an evalution of fission power when the  desirability of using




fusion as national energy resource is considered.)




     This short range plan has four major areas of effort.   The most




important at this time is to establish technical liaison with other




researchers and safety groups working on TNP problems.  Quite frankly




it is more practical at this time for ORP to depend  on other organizations




for information, particularly the AEC, than  to  expend  ORP resources on




original research.  Not only will such a passive approach economize on




ORP resources but it is likely that the best information will  come from




these groups working directly with people responsible  for the technical



development of TNP.




     Other activities in this time frame (Table C-7) include a review of




presently available tritium dose models and biological  effects informa-




tion.  Under dose models are included models for predicting the  distri-




bution of tritium in the environment from its point  of  release,  pathways




for human uptake, physical deposition of energy, and the calculation of




total body and organ doses.   Timely review of this material will allow




ORP to project its research and information needs to ORM by the  start



of the FY 1974 planning  cycle,  Jan-Feb 1974.




     The identification  of  problem areas will depend on the  results




obtained by monitoring other TNP safety programs.   Several  possible areas
                             C-83

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                                                            TABLE C-7

                                               TNP REVIEW AND EVALUATION FY 73-FY 75
n
oo

Identify Safety Groups and
Establish Working Relationship
Review Tritium Dose Models
Review Tritium Bio-Effects
Suggest Research to ORM
Update Plan and Review Fusion
Progress
Identify Likely Problems
Tritium Leadage in Normal Operations
Heat Load to the Environment
Component Activation
Siting
Accidents
Fission-Fusion Hybrids
FY 73
by Dec. 72
Draft Jan. 73
Draft Jan. 73
Feb. 73

machine dependent
FY 74

continuous
continuous
Jan. 74
Aug. 73

FY 75
continue
update
update
Jan. 75
S/lB^.
Aug. 74^plan stillVlfes
^XvalidX^
No
Review need for study.
If needed start new plan
based on newer estimates
of TNP time frame.
               "Dose Models"  to  include dispersion, possible reconcentration,
               pathways, uptake  models, etc.

-------
have been recognized. Table C-7.  The magnitude of all these problems




is more machine dependent than generic and it is likely that most of the




meaningful safety work in these areas, such as practical countermeasures,




will be developed after the demonstration of practical TOP systems.




     Included in the plan is a schedule for updating the plan and




reviewing fusion research progress so that the "gates" identified in




Table C-6 will be implemented as soon as possible.




External Needs




     Legislative Meeds




     Any legislative needs can be deferred until sustained thermonuclear




fusion is demonstrated.  The suceeding 5 to 10 year interval for fusion




reactor development is long enough to consider any new needs, such as




regulatory authority in terms of the Agency's legislative mandate in




the 1980's.



     Information Needs




     ORF/EPA needs to establish,in a formal manner, technical liaison




with all TNF safety groups so that all copies of relevant reports are




forwarded to this office and the problem area leader.  Besides formal




communication, some direct personal contact between team members and




other persons working in this area should be established.  The end




point of this communications effort is to have ORP/EPA fully aware




of new potential problem areas in TNF safety as they devleop, and




access to current thinking on how the problems identified in Table C-7




may be solved.
                                C-85

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     Research & Development Needs




     The basic and applied research required for an adequate assessment




of the radiological hazards from thermonuclear power relate to the large




postulated tritium inventories and the evaluation of potential releases




of this radionuclide.   The neutron activation products induced in plant



construction materials will present a waste disposal problem but, as




these products will generally be fixed in the materials and mainly




consist of short-lived radionuclides (such as niobium-95), their poten-




tial introduction into the general environment has a low probability.




Technology to shield against the high energy neutrons emitted by fusion




process (D—T reaction) is already developed.




     Tritium as a potentially serious environment contaminant is not




unique to fusion power sources.  It is produced in appreciable quantities




by both fast and thermal fission of uranium and plutonium.  Many of




the general research requirements related to tritium dosimetry and




environmental transport will also arise from consideration of nuclear



gas stimulation (Plowshare) and fission power (both light-water and




fast breeder operation, fuel reprocessing, and waste disposal).  Within




this framework, the general research needs relative to tritium transport,



control technology, and dosimetry are:




     •  Development of models to predict world-wide mixing of tritium




        in the atmosphere and oceans, in particular the determination




        of the dilution capacity (effective mixing depth) of the oceans.




     •  Determination  of the reaction kinetics for the exchange of




        tritium between the gaseous elemental form (HT), water, and




        biologically significant molecules.
                               C-86

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     •  Validation of models for predicting the washout of atmospheric




        tritium (as HI or ECO)  into surface waters.




     •  Development of compartmental models for predicting the intake,




        turnover, retention, and distribution of tritiated molecules




        in living organisms with particular reference to humans.




     •  Determination of applicable concentration factors for tritium




        uptake by aquatic and marine organisms.




     •  Determination of unique biological effects resulting from the




        incorporation of tritium into biologically active molecules




        such as proteins, carbohydrates and, most importantly, genetic




        materials such as deoxyribonucleic acid (DNA).




     •  Development of microdosimetric models to predict the effects




        of low-energy beta particle emission at cellular level and




        particularly sub-cellular levels.




     •  Development of tritium  control technologies capable of removing




        tritium from gaseous hydrogen and  from large quantities of




        water having low tritium concentrations (low specific activity




        wastes) without excessive economic penalties.




     •  Development of long-term storage and ultimate disposal techniques




        which will keep either  tritiated gas or water excluded from




        interaction with the biosphere and concomitant research on




        ground water transport  related to  the safety of such methods.




     The time scale for the research indicated above will for the most




part be determined by needs in  other problem areas (Plowshare, etc.).  An




area which requires further investigation  and is not particularly germane
                               C-87

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to either fission power production or gas stimulation is tritium con-




finement and retention technology, particularly the diffusion of




tritium through metals.  Tritium in the gaseous form (HT or T^) can




diffuse quite readily through many metals.  Because of the large tritium




inventories in fusion reactor plants this phenomenon is of considerable




importance.  It is questionable whether EPA needs to pursue this research




topic now, since it is being investigated by the AEG as part of the TNP




development program.   The AEG research program should be monitored to




determine whether sufficient containment will be insured prior to the




construction of any TNP demonstration plants.




Internal Needs



     The program as outlined above places only modest requirements on




ORP resources.  For this very reason care should be taken that adminis-




tration of the proposed program is delegated at a level high enough




to insure that the fusion study is not lost in the press for time and




resources to study more immediate problems.




     About one man year of professional effort will be required to




start the projected study.  Effective technical liaison, and not just




report collecting, will require 0.2 to 0.3 man-years.  Evaluation of




dose models, health risks and relevant EPA/ORM research will require




an additional 0.5 man years.  Some of this effort will of course be




applicable to other problem areas such as Plowshare.




     At least two and preferably three professionals should share the




responsibility for this study.  While this may be less efficient than




centralizing the effort in one person, it insures that a single personnel




transfer will not wipe out ORP capability.  Some of this capability may
                            C-88

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be of more immediate-use to EPA than outlined in the milestone charts.




Inquiries, Congressional and otherwise, concerning potential TNP




environmental problems can be expected at any time.  ORP must, of course,




be in a position to prepare adequate replies.




     Divisional responsibility for this problem area does not present




any difficulties.  Either CSD or TAD could be the lead organization.




More important is the active participation of each of these divisions




in the implementation of an approved plan.  The Field Operations



Division will provide information on the applicability and adequacy of




any tritium monitoring operations proposed for TNP assessments.





MEASURES OF GOAL ATTAINMENT



     This program will accomplish the following:




     •  Provide a long range guide for EPA actions as various technolo-




        gical goals in the national TNP program are accomplished as




        shown in milestone chart - Figure C-14.




     •  Keep ORP/EPA on top of the progress made by other agencies in




        the identification and solution of TNP safety and environmental




        problems.



     •  Identify EPA research needs for ORM and other research groups.




     •  Familiarize the ORP/EPA staff with TNP and its related environ-




        mental impacts.



     Identifiable indicators of goal attainment are of two types.  The




most important of these in the short run will be how well EPA/ORP will




be prepared when the -laboratory demonstration of sustained fusion initiates




a national debate on the usefulness of rapidly introducing TNP.  The
                              C-89

-------
environmental consequences of plutonium breeder energy economy are so




great EPA should be able to lead such a debate.  If it can't, this




program has failed.



     A more objective measure of goal attainment will be the degree of




change in the amount of tritium in the environment if TNP is eventually




introduced.  It is anticipated that the concentration of tritium in the




local environment around TNP installations will be energetically




monitored.  This will allow an objective evaluation of the effectiveness




of equipment and control methods at specific installations.  It will also




test the adequacy of the models used to predict tritium release rates




and transport coefficients.  In the final analysis the degree to which




environmental tritium problems are controlled will be the final measure




of program success.
                               C-90

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                           FABRICATION PLUTONIUM



PROBLEM DESCRIPTION


Component Problems


     •  Fuel Fabrication - the manufacture of plutonium reactor fuels


        for the LMFBR and LWR plutonium recycle reactors.


     •  Radioisotope Generators - the fabrication and use of plutonium


        radioisotope generators for space and terrestial heat sources.


     •  Nuclear Weapons and Use - the fabrication of nuclear weapons


        and their use for war or as nuclear explosives in Plowshare


        activities.


     •  Plutonium Recovery - plutonium scrap recovery facilities,


        waste treatment facilities for reclaiming, or storing plutonium


     •  Inventory Control - the identification and inventory of


        uncontrolled quantities of plutonium in small sources.


Background


     Environmental Problems


     The fabrication of plutonium fuels for reactors, in addition to


operation of Pu fueled reactors and fuel reprocessing plants, is expected


to be a potential source of population and environmental radiation


exposure.  Long-term accumulation in the environment from small, contin-


uous, or accidental releases is the likely source for inhaled, resuspended


and inhaled, or ingested plutonium in people.  For plutonium and other


transuranic elements, the contamination will cause an indefinite commit-


ment for the future because of the long half-life involved.  Radiobioeffects
*
 Use and recovery of plutonium in nuclear fuels are discussed in problem
 areas Operation-Plutonium and Fuel Reprocessing.



                                C-91

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from plutonium inhalation are controversial.  The long-term accumulation




and incorporation into other living organisms has been sparsely studied




with little indication of the environmental insult within an ecosystem.




As the uses of plutonium for reactor fuel and radioisotope generator




heat source increase, the need for determining long-term health and




environmental effects will become critical.




     Potential Sources



     The increased use of plutonium for reactor fuel will follow the




development of Fu recycle in light-water reactors and development of the




Liquid Metal Fast Breeder Reactor.  The fabrication of plutonium fuels




is mixed with fabrication of uranium fuels in most facilities.  The




source of Pu for the LMFBR and Fu recycle fuels is the conversion of




U-238 in present light-water reactors.  (See Figure C-15 and C-16).



During fuel reprocessing the Fu is recovered along with uranium.  The




Fu as a nitrate or fluoride is converted to PuO_, the powder pressed




into pellets, sintered, milled, and the pellets loaded into fuel



cladding tubes.  The total time between discharge of spent fuel and




use of the recovered plutonium and uranium in commercial operation of




the reactor is estimated as two years.




     Other Sources



     Other potential sources of plutonium in the environment are




plutonium scrap recovery plants, nuclear explosives and weapons manu-




facture, Pu-238 radioisotope generator fuel fabrication, and application




of Pu-238 radioisotope generators as space and terrestial electric




sources.  The present levels of plutonium in the environment are from
                             C-92

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   200*-
                                     FIGUKE C-15
               CUMULATIVE PLUTONIUM PRODUCTION WITHOUT Pu RECYCLE
                Cumulative Pu recovered  from domestic power fuels
         «K*.M» Cumulative Pu used  for  major AEC programs
   175
   150
   125
   100
 o

 60
 «
 U-4
 o

 CO
 (0
 n
 O
75
    50
4J
fl
i-<


.1
O
    2.5
                72
 t
73
                      1
                      74
 I
75
76   77  78


   Years
 I
79
80
I
81
I    T
82  83
 I
84
 I
85
                                      C-93

-------
  40
  35
  30
w 25
04
t*4
O

60
20
O

en
CO
1
  15
  10
                  Pu recovered annually from domestic power fuels
        •----• Pu used annually for major AEC programs
                              LMFBR Demo Plant Core
    70  71  72  73  74  75  76  77  78  79  80  81  82  83  84  85
                               YEAR
                               FIGURE C-16


             PLUTONIUM PRODUCTION AND USE WITHOUT Pu RECYCLE
                              C-94

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accidental or routine releases from the above applications rather than




from nuclear power plants.  Nuclear device testing has deposited Pu-239




as fallout.  In addition, an accidental burnup of a Pu-238 radioisotope




generator has added Pu-238 to the ambient levels of radioactivity present



in the environment.  Pu-239 has also been released from the AEC's




Rocky Flats Plant.  (See Figure C-17.)




     Relation to Other Program Areas




     Present experience at plutonium facilities indicates accidents




are a major source of environmental contamination.  Other ORP plutonium




problem areas in addition to accidents are waste disposal, fuel repro-




cessing, operation-plutonium operation-uranium, medical isotope (Pu-238




powered heart pacers), occupational radiation, device testing,




fabrication of uranium, and transportation.




     Inventory Control




     Small sources of plutonium that are sold to AEC and Agreement




State licensees and the small quantities that are not recovered in




processing materials will be placed in radioactive wastes.  A lower




limit for handling the wastes as long half-life alpha emitting trans-




uranic elements will be required.




Scope




     Present




     The following table is a summary of data from The Nuclear Industry




1971 for plutonium reactor fuels capability.
                             C-95

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                           FIGURE C-17


                     KILOGRAMS OF PLUTONIUM

                    (NOT COMPLETELY TO SCALE)
              SPACE
o
M
f
                  ENVIRONMENT
    SEALED SOURCES

    NUCLEAR EXPLOSIVES.MISSILES
P
o
M
W
                                    STORAGE
   en 0 £
   M M >
   H eo w
   W TJ H
   CO O W
ULTIMATE DISPOSAL
     POWER REACTORS
§
i
     THERMAL-BREEDER
     FABRICATION
     REPROCESSING
                                    POWER

                                    APPLICATIONS
                                 CONVERSION

                                 (RECYCLE)
         05*

         PI
                                IN TRANSPORT
               OTHER APPLICATIONS
                          C-96

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                      U.S. Commercial Capability

    Type of Facility            No. of Facilities        EPA Regions

    Pu Fuels Fabrication               8            II, III, IV. VI, IX, X

    Pu Fuel R&D                        9            I, II, III, IV, V, VI,
                                                    IX, X

    Cold Pu Scrap Recovery             3            III, IV, VI


In addition to the above facilities AEC contractor plutonium facilities

at National laboratories are involved in handling plutonium for research,

device manufacture, and radioisotope generator assembly.

     The present level of environmental contamination by plutonium

operations at Rocky Flats, Colorado has received a great deal of public

attention.  Because of disagreement between "experts," assessing the

magnitude of the hazard to public health from environmental plutonium

is difficult for Rocky Flats or other plutonium facilities.

     Future

     The future plutonium fabrication facilities in the U.S. would be

expected to parallel the growth of the LMFBR and Pu recycle in light-

water reactors.  Expansion of existing uranium fabrication facilities

to handle plutonium fuels and new plutonium facilities will be the

means for meeting increased fabrication capacity.  The anticipated

plutonium requirements for the Fast Flux Test Facility (FFTF) and the

first LMFBR are not expected to use the total Pu produced in the light-

water reactors..  In 1976, the plutonium requirements for the FFTF,

LMFBR fuels research, and the LMFBR demonstration plant fuel total

2,450 Kg of plutonium.  Without Pu recycle the plutonium recovered from
                             C-97

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domestic power reactor fuels for 1976 Is projected as 6,400 Kg.  The




remaining plutonium would be expected to be used for Pu recycle in




light-water reactors.




     Other plutonium facilities for utilization of Pu-238 for radio-




isotope generators for space and medical applications will be expanded,




but will be smaller in number.






LEGISLATIVE STATUS




     ORP has no specific legislative authroity at present, but has




general authority from transfer of the Federal Radiation Council




functions and environmental radiation level standard setting function




transferred from the AEC.  General functions assumed from DHEW allow




research monitoring, data interpretation, data publication, assistance




to states, training, and public information activities.






COORDINATION




Interagency




     Since all plutonium facilities, commercial and governmental, are




regulated by the AEC, a majority of interagency activity will be with




that particular agency.  It is anticipated that interactions with




other governmental agencies will be required to a lesser extent with




regard to specific topics as follows:




     •  Federal Power Commission - Energy Requirements and Projections.




     •  Department of Commerce - Fuel Cycle and Waste Control Economics,




        industrial standards, etc.
                             C-9S

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     •  Department of Labor - Occupational Safety.




     e  Department of Defense - Safeguards, Security, and devices.



        Example:   Air Force - Broken Arrow emergency assistance.




     e  Department of Transportation - Transportation of hazardous




        materials.



     •  Department of State - International implications of Pu dispersal




        from accidents,  (device dispersal in plane crash.)




     •  Health, Education,  and Welfare - Biological risk assessment




        methodology - demographic data.



     •  National Oceanic and Atmospheric Administration - Air transport




        and dispersal mechanisms and meteorologial information.




     •  Department of the Interior - Geological, seismologies, and




        natural resource information.



     e  Council on Environmental Quality - Environmental Impact State-




        ments .




Intragency



     The tasks  outlined  previously will require intragency interactions




as follows:



     •  OEM - Technique  development, transport and dispersal mechanisms,



        reduction in uncertainties in risk assessment, environmental




        radiation assessment instrumentation, determination of value




        judgment for indifferent target groups.



     •  OCP/OSW - Hazardous materials disposal sites.




     •  OCP/OTS - Associated Toxic materials.
                            C-99

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      •  0PM/OPE - Promulgation of rules, economic  analyses  guidelines.






ALTERNATIVE APPROACHES




Identification of Alternatives




      First Alternative




      A minimum EPA program which monitors AEC work and  suggests additions




without active participation except approval.



      Second Alternative




      A maximum EPA program which is completely independent  of AEC.




      Third Alternative




      A carefully coordinated program in which EPA  and AEC work together




for optimum information development, exchange and  minimize  duplication




of effort.




      The third alternative is the optimum from the standpoint of the




development of ORP and EPA expertise and needed information.  Since the




primary responsibility of the EPA and the AEC differ, the types of




information development required do not parallel.  However, the overlap




between the agencies very easily leads to duplication of effort.  Thus,




close coordination between EPA and AEC on any aspect of plutonium is




necessary.






OPTIMUM PROGRAM




     Major emphasis is placed on a research program and ORP paper studies




which provide the documentation evidence needed for dose assessment




models.   Environmental criteria for the maximum safe levels of plutonium




are derived from experimental evidence, reducing the uncertainties
                            C-100

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of radiobiological effects and critical pathways.  The Milestone Chart




for the Optimum Program is presented in Figure C-18.




External Needs




     Legislative Needs




     None.




     Knowledge and Information




     Much of the preliminary knowledge and information needs for the




program exist within AEC documents and the open literature.  This body




of information should be drawn together by data summaries that would




be of use to EPA, AEC, its contractors and licensees.  AEC plans for




present and future research programs should be considered in develop-




ment of EPA sponsored research protocol.




     Some monitoring data presently exists for plutonium in the environ-




ment.  Analyses of the data are needed to indicate the present levels




of plutonium in the environment and serve as baseline data for future




assessments of plutonium in the environment.




     Research and Development Needs




     Research programs to identify the mechanisms and importance of




environmental pathways for transport of plutonium are used as a base




of information for criteria and standards development.  Research is to




be defined to provide a data base and parameters for dose assessment




models.




     A great amount of effort has been expended by the AEC for research




in all areas of plutonium technology.  Despite the many projects invest-




igating the biological and environmental hazards of plutonium, several
                             C-101

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aspects of the hazards associated with the element have not been




investigated.  Environmental studies presently conducted under AEC or




EPA sponsorship are limited to the western U.S. in desert or high plains




ecosystems.  Long-term accumulation, resuspension, and redistribution




is expected to be an important mechanism for transport of plutonium




to man.  Present planning for the LMFBR and Pu recycle in LWRs indicates




the majority of these reactor and an equal number of plutonium fuel




service facilities will be in the midwestern or eastern seaboard states.




The mechanisms of resuspension and the importance of each should be




determined for the midwestern and eastern ecosystem.



     Food chain transport of plutonium has been studied on a small




scale.  Present literature sources only offer small bits of information




for plutonium and essentially no information for other transuranic




elements.  Further research in the area of plant, milk, and meat as media



for transport of transuranic elements to the human should be studied.




While a given food type may be very small as a source of ingested




plutonium, the integrated amount from air, water, and all foods may




be important.



     A systematic means for integrating all sources of plutonium and




other transuranic elements reaching man would be the development of a



regional radionuclide transport model.  The pathways identified for




transport of other radionuclides can serve as the basis for such a




model.  As information from present and future plutonium research




becomes available, the data base and parameters for the exposure path-




ways can be added to the model.
                           C-103

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      Enforcement  and  Control Requirements




      Since the AEC and  the EPA can regulate  through the rule-making




 activities,  enforcement would be through this means.   Control would




 be implemented through  the AEC licensing and compliance process.




      Interagency  Implementation




      The major external agency implementation of plutonium criteria



 and standards would be  through the AEC regulation,  licensing, and



 compliance programs.




 Internal Needs




      ORP requirements to implement the optimum program must be con-




 sidered with the  operations plutonium problem area.  Also,  the fuel




 reprocessing problem area is considering the environmental  hazards of




 plutonium  and other transuranic elements.  Efforts  in  all  three problem




 areas are  thus related.  Fabrication-plutonium is unique as a plutonium



 and  transuranic element problem area only because plutonium is present




 in much larger quantities and without the concurrent large  quantities



 of  fission and activation products.




     The major internal ORP needs would be addition of personnel




 needed for monitoring research programs, development of dose assessment




 models, and adequate computer facilities for model development.  Moni-




 toring for plutonium in the environment would require  additional




 laboratory analyses and additional data analyses.




     Plutonium as an environmental pollutant fits into  many of the




modeling efforts for fission products released to the  biosphere.  The




major deficiencies are the lack of identified pathways  and associated
                               C-10A

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parameters.  These variable are required for development of criteria




and acquisition of proper monitoring data that describe the plutonium




and transuranic element radiation insult to man and the environment.




One would foresee standards and criteria for media (air, water, and




soil) as well as worldwide limits.






PROPOSED PROGRAM




     The milestone chart for the Proposed Program is presented in




Figure C-19.



External Needs




     Legislative Needs




     None.




     Knowledge and Information




     The knowledge and information needs for the Proposed Program




are the same as the Optimum Program.  However, the information is used




to write research protocol appropriate to early issuance of provisional




radiation protection guides and environmental plutonium criteria.




     Research and Development Needs




     Research programs would be reduced to short-term laboratory studies




with the goal of criteria for plutonium accumulation in the environment




being issued the end of FY 1974.  A long-term resuspension study would




be started to provide the needed data for evaluation of the adequacy of




the criteria by FY 1979.




     Enforcement and Control




     Same as Optimum Program.
                               C-105

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DIGITALLY

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     Interagency Implementation




     Same as Optimum Program.




Internal Needs



     Through summary papers of existing literature and results of AEG




sponsored research, the present staff would issue provisional environ-




mental plutonium criteria.  Added personnel would be required for follow-



on studies needed for evaluation of the provisional criteria and




validation by monitoring.






COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS




     The proposed program results in early issuance of environmental




plutonium criteria based on present knowledge of the behavior and




effects of the element in biological systems.  Issued as provisional




criteria the influence of research findings can be used to change the




criteria at a later date.  The uncertainties of this program would be




off-set by the Optimum Program which relies on sound data from experi-




ments designed for determining parameters needed to predict plutonium




movement in the environment.  The proposed program would be less costly



and set criteria prior to development of siting and effluent standards.




The Optimum Program results would be delayed by the long time period




required to complete appropriate research projects.






MEASURES OF GOAL ATTAINMENT




     The goal of the program is to minimize the health and environmental




risks associated with utilization of plutonium.  The first measure of




this goal would be setting environmental criteria for plutonium and the
                             C-107

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subsequent use of the criteria for setting siting and effluent criteria




for plutonium.  The second measure of goal attainment would be decreasing




or negligible plutonium detected in the environment after implementing




the criteria and standards.
                                  C-108

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                       OPERATIONS - PLUTONIUM





PROBLEM DESCRIPTION




Component Problems




     This problem area has the problems of assessing the potential




radioactive effluents from the routine operations of the proposed




liquid-metal-cooled fast breeder reactors (LMFBR's) and the light-water-




cooled reactors (LWR's) which employ plutonium fuel, of determining




significant exposure pathways and dose to the population, of issuing




guidance and/or standards adequate for the protection of the population




from these effluents, and of verifying the sufficiency of this procedure




by environmental monitoring.  The major emphasis of this problem area




will be related to the radiation dose to adjacent population groups




from the operation of these facilities.  In addition, the information




developed on effluents will be an input to the overall assessment of the




total radiation hazard from all sources.




Background



     The development of a LMFBR has been assigned a national priority




in President Nixon's Energy Message to Congress on June 4, 1971.  The




LMFBR can produce more fissile material than it consumes and its develop-




ment could alleviate the depletion of fossil-fuel (coal, oil, and natural




gas), and uranium reserves that would be required to meet projected




increased demand for electricity.  As a result of this impetus, the AEC




has initated an LMFBR Development Program to construct large (500-1,000




Mwe) demonstration plants.  If these demonstration plants show that the
                                0109

-------
LMFBR. is both technically and economically feasible, a program  for the


large-scale commercial utilization of LMFBR1s for electrical power


generation will commence.


     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 contaminat-


ing the environment for hundreds or thousands of years with concomitant


long-term radiation exposure to succeeding generations.  The radionuclides


released to the biosphere from the large scale utilization of plutonium-


fueled reactors could add to existing radiation exposure from naturally


occurring radioactivity, medical X-ray and other health related sources,


industrial radiation applications, uranium fueled nuclear reactors and


associated operations, and other portions of the plutonium fuel cycle.


The total radiation exposure of population groups must be controlled if


radiation induced deleterious health effects are to be minimized.  These


factors indicate that releases of radionuclides from LMFBR operations


to the environment should be severely restricted, and, if feasible,

4
/fuidance should be established to prohibit the release of plutonium and


other highly toxic radionuclides to the environment.  The estimated


accumulated production of the more important long-lived radionuclides


are shown in Table C-8 as an indication of the potential magnitude of


this aspect of the radiation problem from the increasing utilization of


nuclear energy.
                                C-110

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                                          TABLE C-8

                      ESTIMATED PRODUCTION OF LONG-LIVED RADIONUCLIDES
                                 BY NUCLEAR POWER REACTORS
Radionuclide
H-3 (tritium)
Krypton-85
Iodine-^29
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
L2000
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+
Curies
321,250
1,958,200
7,600
13,897,800
1,296,300
103,146,000
5,065,000
Percent of
1970 Values
800,
3,300
380,000
1,985,400
1,440,300
1,146,100
3,900
*Source:  USAEG Report ORNL-4451 July 1970 Table 2.1 p 2-9.
•f-Assuming no production after the year 2000.

-------
     The utilization of nuclear power for electrical generation pre-




sently provides only a small fraction of the nation's power requirements.




In 1970, only 3 gigawatt-years were generated by nuclear reactors com-




pared to a total generation of 205 GWe-years; nuclear generation com-




prising 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.  Although large scale




UIFBR plants will not be operable until the late 1980*s, they are expected




to provide approximately 31% of all electrical power by the year 2000.




     The Atomic Energy Commission's proposed fast-reactor development




program will incorporate requirements 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 than the normal operation




of plutonium-fueled reactors.  It must be clearly recognized, however,




that any long-lived radionuclides which are emitted from these plants




will add to releases from other portions of the plutonium fuel cycle




and similar releases from the uranium fuel cycle components.  These




long-lived radionuclides may also accumulate in the environment as a




consequence of their slow removal rate due to radioactive decay.  Thus,




radionuclides discharged from plutonium-fueled reactors, unless strictly
                              C-112

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controlled or for the most toxic radionuclides prohibited, would have




both additive and cumulative impacts on environmental radiation levels.




Scope



     The problem area is restricted to the radiation exposures to the




public resulting from effluents that may be released during routine




operation and those inadvertent minor radioactivity releases resulting




from waste treatment system malfunctions, in-plant spills, or operator




error.  Specifically excluded from consideration in this problem area




are potential major accidents in these plants and other portions of the




plutonium fuel cycle.  The use of plutonium in aerospace or other non-




reactor applications is not contained within this area but will be




included in the Fabrication-Plutonium problem area.






LEGISLATIVE STATUS



     There are no authorities granted to ORP that relate specifically to




this problem area.  The general authority derived from the Federal




Radiation Council function allows EPA to issue general guidance to




Federal agencies on all types of radiation exposure including plutonium-




fueled reactors.  The environmental radiation level standard setting




function transferred to EPA from the AEG provides a direct means of




limiting radiation exposure from these facilities.  EPA comments on




plutonium-fueled reactors provide a powerful means of effecting changes




in waste treatment system designs, effluent releases, and facility




operations.  The general functions assumed from DHEW provide EPA autho-




rity for research, monitoring, data interpretation and dissemination,
                               0113

-------
standards development support, aid to states and other governmental




bodies, training, and public information activities related to environ-




mental radiation exposure.  These combined authorities provide an




umbrella under which all of the porposed radiation programs can be




justified and, therefore, no new legislation for additional authority




is required.






COORDINATION




ORP Internal Coordination



     The problem area Operations-Plutonium comprises only one component




of the total radiation problem and, as such, both the input requirements




(information needs) and outputs (radiation hazard evaluations and




control requirements) generated within its scope must be combined with




those from other problem areas to provide a unified strategy.  This




unification is accomplished under the generic areas of monitoring, risk-




benefit analysis, and strategic studies.




     The strategic area sub-element "fuel-cycles" will be of primary




importance in developing the ORP policy on plutonium-fueled reactors.




The total radiological impact of the plutonium fuel cycle must be the




primary consideration in this regard and, therefore, becomes the




radiation leverage point for EPA policy formulation.  Operations-Plu-




tonium and other ORP problem areas that intersect with the plutonium




fuel cycle are depicted in Figure C-20 in order to provide a concise




summary of their relationships.
                              C-114

-------
                                  GYRATION:
                                  UJtANIUM
              ACCIDENTS
Oi
I
                                       TRANSPORTATIO:
                               OPEFATION:
                               PLUTONIUM
                                                 FUEL
                                                REPROCESSING
                                                U Cycle
FABRICATION:
PLUTONIUM
                                             FUEL
                                             REPROCESSING
                                             Pu Cycle
                                                                       WASTE
                                                                       DISPOSAL
                                                          FIGURE  C-20

                                 PROBLEM AREA COORDINATION REQUIRED FOR PLUTONIUM FUEL CYCLL

-------
Interagency Coordination



     In order to implement the proposed systemic radiation strategy,



the ORP will have to draw upon the expertise and capabilities present



in the other offices of EPA.   The principal scientific areas where



coordination is required are related to health effects research,



monitoring, environmental system simulation, and pollutant dispersion



modeling.  In addition to these technical support functions, guidance



and administrative support will be required from the Office of Planning



and Evaluation (cost-benefit analytical techniques and economic analyses),



Office.of the General Council (legal guidance), Office of Administration



(contract management support), and the Office of Categorical Programs



(policy guidance).  Thus, coordination with all of the operating offices



of EPA will be required to implement the programs described below.



Many of the required areas of coordination will generally follow from



the systemic strategy and the requirements of this approach.  Specific



coordination for this problem area will be required in the development



and execution of plutonium research programs, the conduct of field



studies around LMFBRs and in the development of environmental monitoring



programs.



External Coordination



     The majority of the research effort on reactor technology, ionizing



radiation bioeffects, and the environmental movement of radionuclides


                                                                       
-------
data, extensive liaison must exist between ORP and AEG components.



Several other agencies are also involved in power demand forecasting,



environmental system modeling, and radioecological research, and coor-



dination with these agencies must also exist, both nationally and inter-



nationally.  A third area of EPA coordination is required with national



and international bodies which provide guidance on radiation protection



so that this guidance may be reflected in EPA radiation protection efforts.




ALTERNATIVE APPROACHES



Description of Alternatives



     There are three possible approaches for the conduct of a program



for plutonium-fueled reactors.



     First Alternative



    /The minimum functional program for plutonium-fueled reactors is
   .£—


predicated on continuing only those essential radiation functions of   ^



EPA which cannot be delegated to the AEG, or the states, or otherwise



dispense with. /These functions are primarily nationwide monitoring and



environmental impact statement response.  The milestones for such a



program are shown in Figure C-21. 'This program completely relegates



all research to the AEC and minimizes the standard setting and radiation



guidance roles which EPA could assume./The problem contains only a small



number of support functions required by the monitoring programs and for



EIS technical backup.   The principal technology assessment functions are



required to support the EIS responses which would become the principal



promulgation mechanism for EPA's radiation positions.
                                 C-117

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DIGITALLY

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     Second Alternative




     Develop a systematized approach to assess the magnitude of poten-



tial health risks and environmental effects from plutonium-fueled




reactor operation and formulate radiation standards and environmental




criteria to minimize these risks.   The development of control technology




to meet the EPA requirements would be relegated to the AEG and industry.




     Third Alternative



     Undertake an active research  program in control technology




development, in addition to performing the assessment and guidance




functions specified above in the second alternative.  These three




alternative approaches are designated, respectively, the minimum func-




tional, proposed, and optimum programs and are described below.




Compromise Alternatives



     Because of the great difference between the proposed and minimum




functional programs, there is a wide variety of options which could




result in compromises between these two programs.  The first paring of



the proposed program would be to minimize direct EPA radiation research




functions related to plutonium-fueled reactors.  Leverage could be




exerted on the AEC to perform these reserach functions by virtue of its




substantially greater environmental and radiation bio-effects research




budgets.  A second reason for cutting the research functions would be




the cost-effectiveness of research programs which require long lead times




and large fund expenditures before yielding results which can be employed




by program offices.  The second level of cut-backs would be to eliminate




facility-oriented radiation exposure standard development which the AEC

-------
could undertake, leaving EPA to develop the environmental criteria for

long-lived radionuclides.  Thus, ORF could still employ a systemic

strategy although much reduced in scope.



OPTIMUM AND PROPOSED PROGRAMS

     The Optimum and Proposes Programs are generally similar and major

differences occur only in two areas:  (1) the conduct of monitoring

operations and (2) the degree of involvement with waste treatment system

development.  Under the Proposed Program, ORP would concentrate on

environmental aspects and leave control technology development and a

detailed study of in-plant radionuclide transport to the industry and

the AEG.  Under the Optimum Program, EPA would have, an active research

input into these areas via the programs shown in Table C-9./Monitoring

would be performed directly by EPA labs and coordinated through regional

offices in the Optimum Program."/The Proposed Program would require a
                              J
smaller commitment from EPA and a greater involvement of state health

and environmental protection agencies and of utility companies in the

actual conduct of monitoring operations. /EPA would conduct field

studies for effluent data verification and pathway model validation./'

Because of the similarity of the remaining portions of both programs, a

common program plan can be developed for both.  Differences between the

two programs will be indicated where they occur.

External Needs

     Legislative Needs

     ORP has available sufficient authorities for conducting either the

proposed or optimum programs and additional legislation is not required.
                                C-120

-------
                                                          TABLE C-9

                             RESEARCH AND DEVELOPMENT ACTIVITIES CONDUCTED UNDER THE OPTIMUM
                                      PROGRAM WHICH ARE NOT IN THE .PROPOSED PROGRAM
I
to
Period
FY74-FY82
FY73-FY76
FY75-FY78
FY77-FY80
FY79-FY82
Task
Longrterm Rcsuspension study from soil to air
(interim report FY 78 far plutonium standard
development - final report in FY82)
Evaluate Noble Gas Recovery Systems
Evaluate Gas Disposal nnJ Storage Techniques
Develop tritium removal technique
Evaluate tritium disposal methods
Evaluate effectiveness of sodium cold-traps
Evaluate techniques for disposal of contaminated
sodium
Method of
Performance

ORM
Contract
Contract
ORM
Contract
ORM
Contract,
ORM
Contract
ORP TOTAL
PROGRAM TOTAL
Total Resource
Requirements
man-years
20
3
3
16
3
6
3
9
3
15
66
$1000' s
BOO
160
400
1600
160
260
160
240
160
1040
3920
Allocation to Operation
Plutonium
Fraction
1/4
1/4
1/8
1/4
1/8
1/8
I
1/2
1/2


man-year.; |$ 1000 's
5
.75
.4
4
.4
.75
3
4.5
1.5
6
20.3
200
40
50
400
20
30
160
120
80
350
1100

-------
      Knowledge Needs




      The development of a systemic radiation strategy  for  plutonium-




 fueled reactors requires the following information:




      •  Estimates of the magnitude and composition of  effluents;




      •  A means for determining radionuclide movement  and  accumulation




        in the environment, particularly in the food chains leading



        to man;




      •  Techniques for converting environmental radionuclide concen-




        trations into external dose rates;




      •  Methods for predicting the distribution of and dose rates from




        radionuclides in the human body;




      •  Assessment of the potential biological hazard, both genetic and




        somatic, from the accrued radiation doses;




      •  Methods for comparing the risks from the plutonium fuel cycle




        with those from alternate energy sources and from  the lack of



        power;




      •  Monitoring programs and techniques for forecasting the potential




        risk magnitudes to insure that excessive risks may be identified




        within sufficient time to institute control measures.




The majority of the information required to develop the system models




will be obtained from extensive review of the past and current technical




literature and close monitoring of existing research programs of other




agencies,  primarily those of the AEC, its National laboratories, and




contractors.   Specific knowledge needs and the external coordination




points required to obtain them are shown in Figure C-22 for EPA offices
                               C-122

-------
               OFFICE OF RESEARCH & MONITORING
               OFFICE OF RADIATION PROGRAMS
               OFFICE OF WATER PROGRAMS
I
ro
               OFFICE OF AIR PROGRAMS
               OFFICE OF PESTICIDE PROGRAMS
EPA
jMonltorJrv;
Stratc'-j.
Global
Pollutant
DispersIon
      Develoi'
                                                                FIGURE C-22

                                                    IN1RAAGENCY INFORMATION  NEEDS

-------
and in Table C-10 for other agencies.  This coordination is required




on a continuing basis and is not shown on the program milestone charts.




     Research and Development Needs




     The principal research on plutonium-fueled reactors and their




radiation hazards will be conducted by the AEG, its National laboratories,




and contractors.  EPA research efforts to supplement this research could




fall into two areas:  (1) evaluating waste treatment systems and radio-




active waste disposal techniques; (2) determining the health risks from




Plutonium and other actinides and the significant food-chain pathways




for these elements in man's diet.  One of the principal differences




between the Proposed and Optimum Programs is the limitation of EPA's




reserach efforts under the Proposed Program.  Under the Optimum Program,




research on the development of improved radioactive waste treatment




systems and disposal methods would form a large portion of the total




research effort.  The Proposed Program would concentrate primarily on the




environmental aspects of radionuclide transport and on bio-effects




research and leave research on in-plant parameters governing effluents




and waste treatment system development to industry and the AEC.




     The resuspension in air of plutonium and other long-lived actinides




which have been deposited on the ground may be a principal determinant



of the long-term hazard from these elements as the usual forms of these




elements do not readily enter into food-chains leading to man.  The




degree to which resuspension can occur over a long duration may determine



whether the accumulated ground deposit constitutes a hazard or whether




only recent airborne releases contribute significantly to the dose to man.
                                •0124

-------
                                                             TABLE  C-10

                                               EXTERNAL INFORMATION NEEDS
ACEtiClr
                                                 XHFOKMTION "R SERVICES PROVIDED
                                                                                                        EPA APPUCATIOJl
  . 5. Atonic Energy Co-snlssion (USAEO

    Division of Reactor Development
    and Technology
    Division of Biology and Medicine


    Division of Planning and Analysis

    Division of Environrcntal Affairs



    Division of Compliance



    AEC I.atloMl Laboratories (ORNL.
    A-.fL, BSL, PNWL.  SRL.  and NRTS)

Federal fever Coratsston

Council en Envtronnental  Quality


       jl Cri**cil t
T-;tr-atleral Coralsslon on Radiological
rr:tjction (-CP
T-irrrrt £c"jl  Co-nissto** en Radiological
Irtir-Jtio-al Atoale Energy Agerey





D;?art-xnt of Cetaerce


!.qtton.'il  Oceanic  and Atmospheric
Pepart-rint of Interior

    Fish and Wildlife Service

Office ef Budget  and Manare-.ent



Rational Acodeay  of Selyee

^Jtlc•'Jl Aeadery  of En;lngeriP8
Katlenal Research Council

T>e Co-Treis oi  the United States

    Co\'cmacnt Accounting Office (CAO)

    Covomnent Printing Office (GPO)

State Ufa1th and Environmental
Trvtsctl^n
Breeder Developocnt Prograa Status

Vaste Treatncnt System Design*                <

Sodlua Chemistry &.Fission-Product Retention*!

Radiation Bio-effects Data*


Nuclear Power Growth Forecast*

Radloccolqgy Research Data*

Environmental Effect Data*

Operating Experience and Effluent Data*

Field Studies Protocol

Items Marked (*) Above


Power Growth Forecasts

Policy
                                                 Radiation Protection Guidance
Foreign Blo-Effccti. Research Data


Foreign Reactor Dcvelopcent and
Operating Experience

Econoolc Data


Environmental Data


Commercial Fishing Industry Data

Consultation



Radloccologlcal Research Results

Budget Analyse»-and Policy Direction

Standards Review



Consultation



Budget Review

Prograa Review

Printing Services


Monitoring
                                                                                                        Prograa Timetable and Planning


                                                                                                        Effluent Estimates


                                                                                                        Risk Allotment snd Icse-Effect
                                                                                                        Kodels

                                                                                                        Problem Magnitude Assessment

                                                                                                        Radlonucllde Transport Kodels

                                                                                                        Envtronnental Impact Aisessment

                                                                                                        Effluent Estimates

                                                                                                        Coordination of Effort!

                                                                                                        See  Above


                                                                                                        Problem Magnitude Assessment

                                                                                                        Policy  Guidance
                                                       Standards and Advisory (FRO
                                                       Policy Ferruletirr.
                                                                                                       Risk Assessment and Doit-Effect
                                                                                                       Models
                                                                                                       Effluent Estimates and
                                                                                                       Treatment Technology

                                                                                                       Risk-Benefit and Cost Effective-
                                                                                                       ness Analysaa

                                                                                                       Padlonuclide Dispersion Model
                                                                                                       Ihputs

                                                                                                       Food Intake Model

                                                                                                       Environmental Systems y_-iellng
                                                                                                       Rndlonuellde Trar'^-'t •.-••els

                                                                                                       Funding and Policy Format ion

                                                                                                       Standards Development



                                                                                                       Program Guidance



                                                                                                       Prograa Funding

                                                                                                       Management Guidance

                                                                                                       Public Information


                                                                                                       Monltorlnu  Data
                                                        C-125

-------
The AEC has research programs to study this phenomenon in desert soils




such as the Nevada test site of the Rocky Plats area.  Present planning




for the LMFBR and Pu recycle in LWR's indicates the majority of these




reactor and an equal number of Pu fuel service facilities will be in the




midwestern or eastern seaboard states.  Thus, the mechanisms of resus-




pension and their importance should be determined for midwestern and




eastern soil types.  Under the Optimum Program this research would be




performed directly by EPA research facilities, either as part of the OHM




research program or partially funded by ORP.  Because none of the eastern




EPA laboratories currently occupies a large enough site for such a study,




additional facilities would be required in an isolated area, adding to




the proposed cost.  Although this research is on an important environ-




mental factor, the proposed program would use EPA influence to induce




the AEC to undertake such a study at one of its National laboratories.




     The Optimum Program would provide contract funds for evaluating




sodium clean-up (cold-trap) systems and noble gas removal techniques,




both of which are important factors in determining LMFBR effluents.  A




tritium removal technique would also be developed to limit the discharge




of this radionuclide to the environment.  Both krypton and tritium are




also produced in uranium-fueled reactors and the principal release points




are the fuel reprocessing plants so that the costs of these programs




should be allocated between the problem areas Operations-Plutonium,



Operations-Uranium, and Fuel Reprocessing (the assumed allocation of




resources for both of these tasks is 1/4, 1/2, respectively).
                                0126

-------
     The Optimum Program would also entail direct EPA participation in




the development and evaluation of disposal techniques for tritium*




krypton, and contaminated sodium.  The costs of the first two programs




would be divided between the problem areas Operation Plutonium, Operation




Uranium, Fuel Reprocessing, and Waste Disposal as 1/8, 1/8, 1/4, and




1/2.  The programs costs for sodium disposal would be shared equally




between Operations-Plutonium and Waste Disposal.




     Estimates of the total costs of these programs and those costs




assignable to Operations-Plutonium are shown in Table C-9.  Under the




Proposed Program these efforts would be relegated to the AEC with EPA-




ORP monitoring their progress and only health-effects research and food-




chain transport studies would be conducted.  The OEM budgets for these




programs are provided in Table C-ll.




     Interagency Implementation and Enforcement Requirements




     The principal external outputs from the proposed program will be




environmental radionuclide criteria and a radiation exposure standard



for the LMFBR and Pu-recycle LWR's.  These differ in their applicability




and enforcement requirements.




     The criteria would be independent of the facility type and hence




not only applicable to plutonium reactors but also to fuel reprocessing,




waste disposal, fuel fabrication operations, and the corresponding




uranium fuel-cycle operations.  These criteria would specify the maximum




concentration of each nuclide that could exist in the general environment




with special regard to potential long-term buildup from multiple sources
                               0127

-------
                                                             TABLE C-ll

                                          RESEARCH PROJECTS UNDER PROPOSED AND OPTIMUM PROGRAMS
N)
CO
             Project Title (WERL Projec . #)
Pulmonary Carcinogenic Effect:, of
  Radioactive Particles (21-A--T)

  Inhalation Health Effects Research
   OPERATION PLUTONIUM Alloca* ion
   of above (25%)
          Transport Processes of Selected
            Radionuclides in the Environment
            (21-AMI- sub-tasks 17,18,19,20
                and 23 only)

            Food-chain Transport Studiec
             OPERATION PLUTONIUM Allocation
             of above (25%)

man-years
$1000's
L man-years
$1000's
man-years
$1000's
man-years
$1000's
FY
2.
52.
0.
13.
6.
143
1.
36
73 FY 74
4 2.4
8 52.8
6 0.6
2 13.2
5 -6
132
6 U5
33
Resource
FY 75
--
--
5.5
121
1.4
30.5
Total Research Costs
OPERATION PLUTONIUM
Allocated costs
Requirements
FY 76 FY 77
__
-.
6.5 7.5
143 165
1.6 2
36 41.5
man-years
$1000's
man-years
$1000's
FY 78
«
--
7.5
165
2
41.5
44.3
974.6
11.3
244.9
Project
Total
3.8
105.6
1.2
26.4
39.5
869.0
10. 0
217.5



-------
and forecasted power demands.  In order to meet these criteria, the



regulatory agency (AEG) may have to impose effluent limitations (in terms




of release rate, not concentration) on each facility type in order that




the total nuclear industry release rate (summed over all sources and




facility types) would not exceed the criteria.  Compliance with these




criteria would be demonstrated by calculating the long-term buildup from




measured effluents at present power demand growth rates and comparing




this with environmental monitoring program data designed to assess long-



term buildup trends.  At periodic (five or ten year) intervals, or in




the event of an extreme upward deviation of power demand forecasts, the




EFA guidance and applicable AEC effluent regulations would be reassessed




with regard to changes in projected power demands and the observed




buildup trend.



     The exposure standard would be more conventional, be expressed as




the maximum acceptable individual and total population dose rates, and



be applicable only to the LMFBR and Pu-recycle reactors.  Compliance




with the standard could be confirmed by (1) local radiation surveillance




programs conducted by state agencies with EPA validation studies in the



proposed program and by EPA in the optimum program, and (2) compliance




with AEC effluent regulations which were developed to meet the limits




specified by the standard.



     Enforcement of the exposure standards and applicable AEC effluent




regulations would be solely the function of the AEC.  Review of the




adequacy of the AEC effluent regulations in meeting the exposure standards




and the criteria would be an ORP responsibility.
                               C-129

-------
Internal Needs




     The systemic approach will require new talents to be added to




existing ORP capabilities.  A large systems analysis operation involving




systems analysts, computer programmers, radioecologists, meteorologists,




hydrologists, and geologists would be required in order to model environ-




ment radionuclide transport processes.  Capabilities in economic analysis,




nuclear-chemical engineering, and power systems analysis would be




required for cost-effectiveness and risk benefit evaluations.  Additional




expertise in statistical trend analysis would be required to evaluate




monitoring data.




     The information inputs to the systemic models require a well-




equipped technical library and the development of an information storage




and retireval system.  A large computer system with adequate data storage




capacity and multiple output modes (alpha—numeric, graphic, and graphic




display) will also be required.




     Few of the necessary tasks are unique to the problem area Operations-




Plutonium; considerable overlap will exist with other problem areas




concerned with the plutonium fuel cycle.  For this reason, it is




necessary to allocate manpower and budgetary resources for common tasks




between the problem areas involved. ' For Operations-Plutonium the total




ORP effort expended in the next ten-year period (FY 1973 - FY 1982) will




be 69 man-years and $2,229,000 for an average of 7 man-years and $223,000




per year.  The level of effort is not constant but varies with the proposed




program milestone schedule.  The maximum efforts are exerted in FY 1977




(9 man-years and $244,000) and FY 1980 (13 man-years and $365,000).  Of
                                C-130

-------
the total effort, external contracts expenditures would be $132,500




and field support studies would require 23 man-years and $555,000.




     The total Proposed Program requirements (including research efforts)



would be 80 man-years and $2,474,000.  The Optimum Program would require




114 man-years and $4,146,000.  Of this, resources directly allotted to




ORP's efforts in Operations-Plutonium would be 75 man-years and $2,579,000,




the remainder being additional research study support.




Proposed Program Milestones




     The program milestones for the Proposed Program are shown in




Figure C-23.




     Technology Assessment



     During FY-1973, preliminary estimates of actinide production will




be prepared to aid problem assessment and guide program development.




These preliminary estimates will be supplemented by a complete review of



actinide production and control technology in FY 1978-FY 1979 prior to




the issuance of environmental criteria for plutonium and other alpha-




emitting transuranium elements.  The second review will also contribute




to an assessment of the total radiological impact of the Pu fuel cycle.




The latter study will provide the primary basis of EPA's EIS comments on




large commercial LMFBR's and the development of an LMFBR radiation




exposure standatd.  A preliminary review of existing soidum reactor




effluents and waste treatment systems will also be undertaken in FY 1973.




This will serve to provide background information on sodium-cooled




reactors and will be supplemented by a field study performed at the FFTF




site and a special study at a large demonstration plant.
                               0131

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AVAILABLE
DIGITALLY

-------
     The proposed monitoring program may be subdivided into:



     e  Network monitoring which determines the status of the environ-




        ment and provides baseline data .




     •  Special studies at nuclear installations and in unique environ-




        ments, to provide data for radionuclide transport modeling.




     •  Field studies to verify effluent data.



At present monitoring around existing facilities is performed by the




operators, and in some cases, by state agencies.  Nationwide monitoring




for plutonium is limited to analysis of selected air network samples.



     A realistic assessment of the impact of radionuclides added to the




environment by plutonium-fueled reactors will require, in addition to




information from the AEC, facility operators, and state agencies, special



studies in the environs of selected facilities such as Fermi #1 and the




FFTF to determine effluents.



     In order to assess the long-term accumulation of plutonium and




other radionuclides, the analysis of additional media such as soils



will probably be useful, and may be achievable with a minimum of addi-




tional effort through combined monitoring programs with other EPA




offices (such as the analysis for plutonium in soil samples acquired by



the Office of Pesticide Programs) in the course of ORP monitoring




programs.   Similar indications for aquatic ecosystems may be provided




by the analysis of sediments in regional watersheds.  Indication of human




exposure to plutonium and other bone-seeking actinides would be provided



by a bone sampling and analysis program.  Monitroing programs to assess
                                0133

-------
the long-term environmental accumulation of tritium and krypton-85




would also be required.  These programs are already in effect on a




limited basis and do not appear on the milestone chart as their




scheduling would be governed primarily by the fuel reprocessing program




requirements.



     By the time the first LMFBR demonstration plant has experienced




a year of normal operation, i.e., about 1981, the state of the art



of evaluating the environmental impact of nuclear operations should




be considerably advanced, and a special study of the LMFBR demonstra-




tion plant should provide good supporting data for the reassessment of




the plutonium-fueled reactor program and review of the large LMFBR



EIS which may be expected at that time.  This information will also




be used in the development of the LMFBR exposure standard and over-all




review of the plutonium fuel cycle.



     Criteria and Standards Development



     In order to provide bases for specific radionuclide criteria and




facility exposure standards, the basic ORP philosophy for its radiation




protection guidance must be establihsed at an early stage.  This should




be undertaken in FY 1973 with the issuance of provisional radiation




protection guidance for this activity.



     At least four environmental concentration criteria would be




required for the principal long-lived radionuclides:  iodine-129,




plutonium, tritium, and krypton-85.  The iodine-129 criteria are intro-




duced first because of the need for developing techniques of assessing
                                 C-134

-------
the hazard from very long-lived radionuclides and the large existing




body of information on iodine retention systems and environmental trans-




port pathways for iodine.  Krypton-85 criteria are developed secondly




because of the relatively simple exposure pathways (it does not enter




food-chains to any significant extent), the need for early control




because of greater potential dose levels than from tritium, and the




growing body of information on noble gas retention technology which will




permit control.  Tritium criteria development is delayed until FY-1977 in




order to permit the development of feasible control techniques which do




not presently exist.  In addition, this timetable will permit more




sophisticated environmental transport models to be employed to predict




potential environmental accumulation.  The delay of plutonium nad actinide




criteria until FY 1978 is not advisible from a programmatic viewpoint



as substantial plutonium inventories will be accumulated from light-




water reactor operation.  However, this delay is necessary to incorporate




a complete review of actinide production, the interim results of the long-




term resuspension-migration studies, and bio-effects research results.




     The LMFBR exposure standard is also delayed beyond a programmatic




optimum time frame.  This is necessary  if large LMFBR plant operating




experience, the complete Fu fuel-cycle  assessment, and data from special




studies around the demonstration plants are to be incorporated.  These




factors will provide a more informed and factual basis for the standard




development.






COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS




     A comparison of the major alternative programs is shown in Table




C-12.  The Impact of the Proposed Program is similar to that of the
                                0135

-------
                                                          TABLE C-12
                                              COMPARISON OF OPTIMUM. PROPOSED. AND MINIMUM
                                                           FUNCTIONAL PROGRAMS
Systonlc Radiation Strategy?

Enforcement Capability?

CulJance Expression Options?




Control Techulogy Development?

Active EPA Research Input?

Perr-lts Rlsk-Jer.eflt Assessment?
Requires Addi~lor.al Expertise and Staffing
to Present CdjabllltlesI
Degree of EPA Leadership Exercised



Perclts Completely  Independent Assessments?



 Budget Changes



 Change In Siroort  Function!


 External Visibility



 Execution of Monitoring Program





 Scope of Monl:orlng Program



 Execution of £IS Reviews
Optima
Prog ran
Tei
Ito
Tes:
Proposed
Program
Yes
No
Yes:
Radiation Protection
Guides. Radiation
Criteria and Standards, and EIS Contents
Yes
Ye*
Yes
Yes:
Economic
Chenica 1
No
Yes
Yes
Yes:
Analysis, Radlobiology, Nuclear-
Engineering. Radloecology, and
Minima
Functional
Proojraa
Ho
No
No
EIS Cosnente Only
Ho
No
No -
Risk Assessment
Only
Ho
Reprogramnlng of
Functions
                                                          Environmental System Modeling
Strong
Yes
 Requires
 40-601
 Increase
                                                                                       Strong
Yes
With Exception of
In-plant Parameters

 Requires
 15-25%
 Increase
 Require  Large Technical Library and Computer
 Facilities
 Strong!
                              Strong;
 Technical  Reports and Papers
 Meeting  Presentations, and EIS Comments
 EPA Directly                         4.    _
 through Labs and             Utility  CO .
 Regional Offices             with  EPA
                             validation
                             studies.
 Regional and National, Supplemented by Local
 Field Studies
 By Regions  with Policy Guidance and Technical
 Simnorf fw  Hn*dni»trrftr9
Weak
Primarily Response
to AEC Lead '

No , Leans Strongly
on' AEC Supplied Data
 Permits
 20-301
 Decrease

 No
                             Weak;	
                             EIS Cements
                             Primarily

                             States with
                             Financial
                             Assistance
                             National and
                             Field Studies
                             Only

                             Principally by
                                                    C-136

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Optimum Program except that greater reliance is placed upon  the AEC




for waste treatment system development and research on in-plant radio-




nuclide transport and upon the states for the conduct of monitoring




programs.  These changes result in some loss of independence for EPA




and a greater need for coordination with other agencies but  with a




corresponding reduction in the financial and manpower requirements to




carry out these programs.




     The minimum functional program provides for a response  rather than




a leadership role for ORP and consequently diminishes the influence which




can be applied to the AEC.  This program provides only minimal external




visibility and does not permit a systemic radiation strategy to be




developed.  Under the minimum functional program ORP's technical capa-




bilities would be severely limited and there would be little flexibility




in the choice of guidance expression options.  The ability to react to




unforeseen problems (and even to foresee problems) would also be reudced




under this extreme option.






MEASURES OF GOAL ATTAINMENT




     The principal goal of the Proposed Program described above is to




assess and minimize the radiological impact of plutonium-fueled reactors




on the environment and on public health.  Subsidiary goals are to provide




adequate knowledge resources and technical competence to achieve the




primary goal and to insure that the development of plutonium-fueled




reactors is carried out with adequate consideration of potential environ-




mental consequences.
                               C-137

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     The planned accomplishments of the proposed program are manifold.




The primary accomplishments are the development of adequate criteria for




limiting the accumulation of long-lived radionuclides in the biosphere




and the development of a radiation standard for reducing the radiation




exposure of the population groups adjacent to plutonium-fueled reactors




to the lowest practicable level.  The secondary accomplishments are:




     1.  Providing an integrated monitoring system capable of detecting




trends in environmental radiation levels early enough so that potential




hazards may be controlled before they have a significant impact;




     2.  Conducting research programs to increase existing knowledge




of radiation effects and the environmental movement of long-lived radio-



nuclides;




     3.  The development of an adequate information resource upon which




intelligent decisions can be based;




     4.  The implementation of a comprehensive systemic strategy for




controlling radiation exposure to the population from all sources.




     The attainment of the goals may be verified by the degree of




incorporation of environmental factors in the development of the LMFBR




development program, the lack of a significant buildup of long-lived




radionuclides in the environment as determined by radiation monitoring




data,  and the minimization of radiation exposure to people from the




operation of these facilities as shown by surveillance data.
                                C-138

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                        OPERATION - URANIUM




                        PROGRAM  DESCRIPTION






I.  Problem Description




     A.  Problem




          A major area of concern about risk to  the environment from




radiation is that of the generation and utilization of energy through




nuclear power.  Because the fuel cycle that is necessary for nuclear




power has several activities which are distinguished by their functions,




geographical locations, and potential impacts, it has been divided




into several problem areas—mining and mill tailings, fuel fabrication




and associated activities, transportation, fuel  reprocessing, and




disposal.  Fuel cycle steps involving large amounts of polutonium




have been separated from those involving principally uranium, and




accidents are treated in a problem area separated from routine




operations, because their characteristics and potential radiological




impacts are distinctly different.




          The problem area OPERATION - URANIUM for the reasons stated




above is limited to (1) an assessment of the radioactivity added to




the environment at the facility site in~ the course of routine




operations, (2) computation of the population dose within 50 miles,




with adequate critical exposure pathway transport models, from the




subsequent distribution of the added radioactivity in the environment,




and (3) validation of all dose predictive models through field studies.




A computerized data management and processing system is essential




for effective implementation of these activities.  Due to frequently






                               C-139

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 changing technology and variations in facility design and operations,




 an assessment of the environmental impact will be made to determine




 the effectiveness of the new technology in reducing population dose.




           The output from t*° -i	---s for OPERATION - URANIUM, the




 impact in terms cf ra
-------
 standards of these groups, of course,  are  compatible.   They have been




 used by the Commission as the basis  for regulations and safety




 requirements in the AEC's regulatory program.




          Recently, the AEG announced  the  publication  for public




 comment of proposed-nunicrita.!..^::.'^.' -v;o-;7Jesign  objectives and




 limiting conditions for operation  for  light-water-cooled nuclear




 power reactors to keep radioactivity in effluents  "as  low as practicable",




 These proposed changes to the reactor  licensing  regulations were in the




 form of an additional Appendix I to  10 CFR 50.   The term "as low as




 practicable" as used in the proposed amendments  to Part 50 means




 "as low as is practicably achievable talcing  into account the state




 of technology and the economics of improvement in  relation to benefits




 to the public health and safety and  in relation  to the  utilization  of




 atomic energy in the public interest".




          In testimony at the AEG hearings on these proposed amendments,




 the EPA indicated that it would accept the proposed amendments as




 generally representative of guidance that  the EPA  would issue if it




had set environmental standards for  light-water-cooled  reactors.




In accepting the dose guidance in the proposed changes  to 10 CFR 50,




 the EPA made the following stipulation:  "... if actual practice under




 these guides should result in maximum individual doses  over what can




be expected under careful operation  with the technology implied by




 the guidelines, EPA will reexamine this decision."
                              C-141

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          It was further stated that "... we anticipate that timely




reports and cooperation will be available from the AEG concerning




the performance of its licensees.  Individual facilities need not




exceed the guides; indeed, in most cases they will probably




operate at levels consiJera!-0  .'alow the guides.  EPA will




continue to review the environmental impact of .individual facilities




with these considerations in mind."  In making this public declaration,




the EPA has committed itself to a minimum of an assessment of the




current operations of the industry.




          The Office of Radiation Programs and its predecessor




organizations have had an active and continuing program related to




nuclear power reactors.  The two primary endeavors have been




assessment of current operations through review of reactor operating




and environmental surveillance reports and the assessment of




technology through engineering evaluations and special studies.




          The assessment of current operations has included the




following specific activities:




          1.  Compilation and publication of analyses relating




effluent trends to power production and discharge limits.




          2.  Assessment of the effectiveness of surveillance




programs in providing data necessary for estimation of population




doses.




          3.  Assessment of the adequacy of data in facility




operating reports for evaluation of population risk.
                             C-142

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          4.  Preparation of a guide for environmental radioactivity




surveillance around light-water-cooled nuclear power facilities.




          The assessment of technology has included the following




specific activities:




          1.  A CGTrLTact: to TBO.!-: .-r-;xf--i,^v?l cost effectiveness




evaluation of waste treatment systems.




          2.  A contract to perform a literature search on data




relative to waste treatment systems.




          3.  An evaluation of gaseous holdup systems.




          4.  An evaluation of PWR primary to secondary leakage.




          5.  A compilation of PWR and BWR operational parameters.




          6.  Indepth studies at two BWRs and two PWRs (Dresden I,




Oyster Creek, Yankee Rowe, and Connecticut Yankee).




          7.  An evaluation of effluent tritium, iodine-131, and




krypton as environmental problems.




          Although the area of review of Environmental Impact




Statements is to be presented as a separate generic program area it




will have an operational relationship with the OPERATION - URANIUM




program.  This will provide a. continuing awareness and analysis




of current technology and new issues for assistance to this program




and vice versa.




     C.  Scope




          The determination of dose to the population from operating




plants is expected to become a routine data processing function after
                             C-143

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the computer program for calculating environmental pathway doses




becomes operational.  The development of this program will be the




first step in establishing a national dose model which  is one of




the major overall objectives of ORP.




          Initially, fi<_ld j-_uli-•.-.:••>«• validate the environmental




pathway dose models will be necessary.  However, once the models




have been verified, it is anticipated that further field studies




will not be required.  This accomplishment is not expected to




require more than a few selected field studies over  the next few




years.  Maximum use of the data available from Strategic Studies




for new generation plants will be made.




          1.  Present




               In 1972, there are approximately 29 operating light-




water-cooled nuclear power plants and one gas-cooled reactor in the




United States.  The present radioactivity releases from these plants




appear to have no significant effects on the environment or the




general population based upon assessments of these releases.




However, a continuing assessment of critical exposure pathways,




specifically for radionuclides that build up or concentrate, is




necessary to identify trends which may ultimately lead  to significant




effects.  This continuing assessment will permit remedial actions




to be taken early enough to prevent the effects from becoming




significant.  Concurrently the discharges of radioactive material




from nuclear generating stations should continue to  be  evaluated




in terms of population dose.
                            C-144

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          2.  Future




               By 1975, the number of operating nuclear power plants




in the United States is anticipated to increase to about 80.  It may




be stated with reasonable certainty that the environmental impact




of the operating light-water-cooled reactors has been minimum on an




individual basis but may chau.-0_'• '.•v~i. '. »\'if?wer levels increase and




more reactors become operational at a single site.




               Since the environmental impact of a nuclear power




plant is related to the reactor site and reactor operating practices,




reactor sites must be evaluated on a individual basis.  However, as




acceptable reactor sites become more scarce, utilities will tend




to locate multiple units on already existing sites.  Signs of this




trend are already apparent.  These sites will undoubtedly be in




close proximity to one another.  We must, therefore, begin to




evaluate the accumulative environmental effects of multiple unit




reactor sites which have overlapping spheres of influence.  This




must be done not only on a regional basis but also on a nationwide




scale if the true total environmental impact from the production of




nuclear power is to be determined.




               The same cannot be said with equal certainty for




high-temperature-gas-cooled reactors which are just coming on line.




The HTGRs, because of their design and method of operation, are




anticipated to be less of an environmental problem than light-water-




cooled reactors; however, this must be verified by analysis of




operational data and through field studies.
                              C-145

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               New generation reactors with perhaps significantly




different environmental considerations (e.g., the floating barge




concept) than the current light-water-cooled reactors may pose




different and previously uninvestieated environmental problems.




These new generatio-L.'rc.aci-1--^ -'.-Z~-A••>:?>• to be monitored closely,




at least initially, until their environmental impact can be




accurately and adequately evaluated.






II.  Legislative Status




     The statutory authority of EPA to advise the President on




radiation matters affecting public health is derived through the




transferred authority from the former Federal Radiation Council




(FRC) (42 U.S. Code 2021h).  Reorganization Plan No. 3 of 1970




gives EPA the responsibilities for setting generally applicable




environmental standards, which were formerly held by the Division




of Radiation Protection Standards of the Atomic Energy Commission.




Authority to protect the public health is derived by EPA from  the




Public Health Service Act.  Possible authority to regulate radio-




active materials may be derived through the implementation of  the




Clean Air Act, the Federal Water Pollution Control Act or the




Refuse Act of 1899, although the legislative history of these




acts casts some doubt upon their applicability to AEC regulated




licensees and radioactive materials.  This is because the Atomic




Energy Act of 1954 has been interpreted to have  preemptive authority




in the establishment of radioactivity emission standards.
                              C-146

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III.  Coordination




     A.  Interagency Coordination




          Coordination is required between the Environmental




Protection Agency, the National Bureau of Standards, the states, and




the Atomic Energy Go—.ii —'-..„. , ^-he^EC licensees and AEG operating




facilities which include operating reactors, are required to report




their discharge, operating, and surveillance data to the AEC Division




of Compliance or the AEC Division of Operational Safety.  The AEC




in some instances, interprets and summarizes reports from facilities




under its jurisdiction.  The EPA/ORP should receive both facility




operators reports and the AEC interpretive and summary reports.




State radiation control agencies should also receive these reports.




          Based on surveillance program needs, EPA/ORP will provide




technical assistance and support services (e.g., laboratory and




quality assurance) to state agencies for environmental monitoring.




Quality assurance will also be provided for federal and commercial




contractor monitoring programs.  The sources used for quality




assurance standards will be traceable to the National Bureau of




Standards.  Monitoring reports from states are provided to EPA  to




supplement data provided to EPA from other sources.




          The Office of Research and Monitoring will provide




laboratory services for quality assurance and research, as  required.
                               C-U7

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IV.  Alternative Approaches




     Alternative approaches differ principally in the amount of effort




required of EPA and in the techniques used to estimate the dose to




the population within 50 miles of the operating nuclear power




station.




     Alternative 1:  Dose estimated by others.




          The effort of the EPA under this alternative approach is




limited to obtaining estimates of dose to the population from the




AEG and to evaluating the population dose from each facility in




relation to the EPA's environmental standards.  The dose estimate




for each facility would probably be prepared for the AEG annually




by the utility company.




     Alternative 2:  Dose estimated in-house from data reported by




others.




          In this alternative approach, the effort consists of




preparing estimates of population dose from the routine operation




of nuclear power plants based on operating reports such as those




prepared in accordance with AEG Safety Guide 21, and on reported data




from environmental surveillance reports by the utility company,




the AEC, and others.  This alternative requires the development or




acquisition of critical exposure pathway models for dose computations




and methods for making regional and nationwide dose calculations.




Data for verification of exposure pathway dose models would be derived




from studies performed by others.  A data management system would be
                              C-148

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 developed  to enable  the  storage and use of effluent  data,  transport




 pathway  data, demographic data, and computational  models.




     Alternative 3  - Proposed Program:  Dose  estimated  in-house  from




 data reported by others; methods validated by field  studies.




           The Propubed Ptograri. 'j-j^s-iv 's—1>£ estimation of population




-doses  from operating nucLear power .plants by  the use of validated




 environmental pathway-dose models.  In  this program, the radioactivity




 releases from plants are characterized  by acquisition of effluent




 data from the AEG,  from  the utility companies,  and from state




 authorities if  available.  The  significant exposure  pathways  are




 selected from reported results  of  the in-depth Strategic Studies of




 power  plants conducted by the Radiochemistry  and Nuclear Engineering




 Research Division  of NERC--Cincinnati.  A  limited  number of additional




 field  studies will be conducted at selected,  representative facilities




 to validate pathway-dose models.   Once  a  system for assessing the




 site-vicinity  impact of  individual facilities is  operational, models




 will be  adopted or developed  for calculating the  regional impact




 and the  national impact.




           Development of a  data management system to organize and




 process  the large  amounts of  data  is  required. For each facility




 data are required  on effluent  radioactivity,  on exposure pathways




 including air,  water, and food  pathways,  on the population distribution




 and on meteorology.  The acquisition  of a computer code to calculate




 exposure by the significant pathways  is an important step in the




 assembly of the data management system.  The data management syscem
                              C-149

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will have a section for acquisition, preparation, and storage of data,




a section for calculating the radioactivity distribution and doses




by use of pathway models, and a section for output and storage




of results.




          The output =f t±i_ .?:."•#-.'svi^?M contribute to (1) Environmental




Impact Statement review, (2) evaluation of the effectiveness of "as




low as practicable" technology, (3)  evaluation of the adequacy of




applicable guidelines and standards, and (4) comparison of actual




facility performance with design specifications.




     Alternative 4 - Optimum Program:  Dose estimated in-house from




data reported by others; methods validated by field studies.




Unconstrained resources.




          The Optimum Program 'has the same basic structure as the




Proposed Program; i.e., estimation of site-vicinity population doses




from operating nuclear power plants by validated environmental




pathway-dose models using reported data on the sources, site-specific




pathway characteristics, population and meteorology, followed by




development of regional and nationwide dose estimates, all supported




by a computer-centered data management system.




          While the Optimum Program has nominally the same scope as




the Proposed Program, the Optimum Program could be developed in a




time span little more than the minimum, due to the greater application




of resources to put a concentration of expertise to work on the




program, in particular on the data management.  Once the framework
                               C-150

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of the program is established,  attention can be given to improving the




depth of technical content.   The Optimum Program would thus bring the




program to full operation, i.e., impact reporting for all facilities,




at an earlier date and permit reevaluation and updating of the program




on a shorter time cycle.   Minimum time spans for milestone achievement,




however, do not permit the Optimum Program to be accomplished much




quicker than the Proposed Program.  The minimum time spans are




determined by the speed of obtaining information, by  the speed of




communication and response in-house, and by the degree and timeliness




of necessary cooperation by other organizations, in particular, the




AEG.




     Alternative 5:  Dose estimated in-house from data reported by




others and from data from contracted surveillance of all facilities;




methods validated by field studies.




          This alternative has the features of the Proposed Program




plus continual monitoring under EPA contracts of all nuclear power




plants.  This alternative is not considered practical due to the




amount of time required to bring this program to full operation,  the




large investment of resources it requires, and the loss of versatility




accepted with such an extensive operation.  Furthermore, as effluents




from individual sources become smaller with improved technology,  and




sources become closer together increasing the overlap of their influence,




the data obtained from external monitoring of individual facilities




is likely to become less meaningful.
                              G-151

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V.  Proposed Program




     The program described as alternative 3 in Section IV of this




report is recommended as the proposed program because it is cost




effective and accomplishes the desired goals.




     The solution to'~he \-•-'•.•!*:-<  - 
-------
     The regional offices will continue to be responsible for




coordination with the states in obtaining state surveillance data




for nuclear power plants.




     The technical services facilities (i.e., field laboratories)




are responsible for -J..o -_-. c.-lof,—^' -*>%-f ield and analytical data




to support the development and verification of exposure pathway




dose models and validation of effluent data.  Technical direction




of the field studies effort will be provided by FOD so that




priority program objectives and responsibilities are assigned by a




single group.




     The basic information derived from this optimum program is




assessment of environmental impact of facilities in terms of dose,




validation of exposure pathway dose models and reported effluent




data, input to the data management systems, input to development of




criteria and standards, and input to technology assessment,




     A.  External Needs




          1.  Legislative Needs




               The present authority vested in the EPA by Reorganization




Plan No. 3 appears to provide the necessary flexibility for the EPA




to conduct this program.




          2.  Knowledge




               We are fortunate that the voids in our knowledge




relative to the component problems and their respective solutions are




few in number.  A long history of reactor development, the stringent
                              C-153

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regulatory activities associated with reactor licensing, reactor




operating experience and the information assembled during the last




15  years has  provided an excellent foundation of knowledge.




Information gaps do exist, however, but are not extensive when




compared with our  general ~ie.^ -^f^viitowledge.  They are mostly




.related .to,,refinements  in existing areas of knowledge  concerning




the environmental  effects of nuclear power generation.  With  the




development of new waste treatment and reactor  technologies,  new




knowledge  gaps will become apparent.  These information gaps  can  be




filled  through appropriate technology assessment  programs.




           30   Research  and Development




                A better understanding of  the  environmental  transport




of radionuclides would  permit  a more accurate prediction  of dose  to




man via the various established food chain pathways.   Such  doses




might also be helpful  in defining new  or  previously unconsidered




exposure vectors.  These studies would,  of course, take  into




account any reconcentration  effects  or  long-term buildup  of




activity.



                There  are inherent errors associated with the current




 methods used  for  estimating  dose to  man from various exposure




 pathways.  These  errors are  due largely to uncertainties in some




 of the assumptions that are  necessary to estimate doses.   An




 attempt should be made to  refine these uncertainties in an effort




 to improve the accuracy with which dose estimates can be estimated.




 This is not  intended to imply that the errors associated with
                               C-154

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present dose computation techniques are outside an acceptable range




but rather is a suggestion that current techniques can be refined.




This is particularly important since the present design basis dose




guidance for operating reactors i^ becoming increasingly smaller.




               It i» sugg^-o.-\2~ 'JlisL'-'exposure pathway dose models




based on .the more refined assumptions be developed into a computer




program which will permit translation of environmental radioactivity




concentrations into dose to man from any significant exposure pathway.




               Developmental efforts to standardize sample collection




techniques, analytical techniques, and data reporting formats would




assure uniformity in the determination of environmental impact.




               Additional developmental work is required to  increase




the sensitivity of direct radiation measuring devices such as




thermoluminescent dosimeters to within the dose range of interest.




          4.  Interagency Implementation




               A close working relationship between AEG and  EPA  is




necessary to avoid duplication of effort where this duplication  is




undesirable from a cost-effectiveness standpoint.




               AEG participation in the program should be  limited




to  (1) a review function for planned and completed activities,




(2) an exchange of technical information, and  (3)  an  interface




between the EPA and AEG licensees.
                              C-155

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     B.  Internal Requirements




          The effective resolution of this problem area is contingent




upon the following internal requirements:




          1.  An inventory of the critical exposure pathways available




for each type of reictoi' ^vJ \-i^i_i:v-> r jactor sites is the first step




in the development of critical exposure pathway dose models.  These




exposure pathways should include a consideration of any long-term




buildup or concentrating mechanisms within the food chain.  This




information is a generic issue and should be factored into Strategic




Studies.




          2.  Critical exposure pathways must be considered on an




individual basis for the development of dose computation models which




translate environment radioactivity levels in any exposure pathway




into dose to man.  This model development should be directed only




at those exposure pathways which are anticipated to significantly




contribute to man's total dose.




          3.  Field studies must be developed and implemented  that




will verify the critical exposure pathway dose models discussed




above.  These studies should attempt to refine any subjective




assumptions inherent in the development of the pathway dose models.




          4.  Computer applications for the general problem area of




OPERATION - URANIUM include both a data management capability  for




the storage and retrieval of modeling data (demographic data,




meteorology, hydrology, source terms, etc.) and  the translation of




these data, through dose modeling programs, into dose  to  man.
                              C-156

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     C.  Milestones




          The significant milestones for the proposed program are




shown in Table 1.




VI.  Optimum Program




     The problems relat.. ' t  .—-"yvrr^ _ URANIUM remain the same




regardless of the amount of funds and resources that are available.




Therefore, the scope of the Proposed and Optimum Programs is




essentially the same.  They differ only in the fact that additional




funds and resources would permit the Optimum Program to be




implemented in greater technical depth and in a quicker time frame




relative to milestone accomplishments.




     Because of the similarity in the basic problem the component




problems of the Proposed Program and this Optimum Program; other




considerations, such as, legislation, knowledge, research and




development needs as discussed in the Proposed Program above will




remain the same.  The internal requirements and milestones are  also




the same.




VII.  Impact of Proposed Program Compared to Optimum




     Within the above context  the variation between  the Optimum and




Proposed Programs will  be related to the technical depth and  time  frame




in which milestones can be completed.  The Proposed  and Optimum




Programs outline an approach for keeping EPA continuously aware on an




annual basis, of the performance of each uranium  fueled nuclear power




plant relative to  its potential radiation impact  on  the environment




as well  as carry out those activities necessary  to evaluate  new




innovations and problems.




                               C-157

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VIII.  Expected Accomplishments and Measures of These Goal Attainments




     The expected accomplishments and measures of goal attainments




in terms of measurable health effects will be indeterminant at the




projected dose levels because of the magnitude of the epidemological




study required to determrufe i'l ^' i.l:."<-/..T.~a causative biological effect




relationship.  However, it is not altogether unreasonable to expect




to find an overall reduction in the health effects (dose to the general




population) from nuclear power generation in the future as reactor




technology improves.  The continued assessment of the population




doses from nuclear plants will provide an indication and a measure




of this dose reduction factor.




     The other major goals are somewhat more tangible and can be




considered accomplished when:




     1.  All critical exposure pathways have been identified for




various environmental media, different types of  reactors, and reactor




sites.



     2.  Dose computational models  considering all of  the above have




been developed and validated through  field measurement  programs.




     3.  A data management system capable of processing the  dose




computational models derived above.




     4.  The capability for evaluating  the  dose  from all nuclear




power plants is available and  used  in such  a manner  that we  not  only




have a  cumulative  library of doses  from a given  facility but also




have the capability  of evaluating any facility  at  any time.   Each of




the  above  represents  the attainment of  a  goal.
                              C-158

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     The fifth alternative is considered the Optimum Program.  It pro-




vides monitoring of all facilities by state agencies under contract.




Technical support and quality control by EPA assure quality equal to




that obtained in the fourth alternative.  By involving more local forces




in the effort, better insight is obtained into purely local influences




on the impact.  The costs of administering the large and complex system




involved plus the funding of the monitoring contracts limit the cost-




effectiveness of this program.



OPTIMUM PROGRAM



     The following Optimum Program is premised on the basic assumptions




that the necessary resources and technical expertise are available in




the regional offices and withing the states Involved and that there




are no .constraints on grants or contracts to states or other contractors.




Other commercial contractors would only be considered in those cases




where states were either unable or unwilling to participate in the pro-




gram.



     The solution to the problem of determining the environmental impact




of operating nuclear power plants in terms of dose to the population




is relatively simple in concept.  It involves a continuous assessment




of the radioactivity releases from each plant and a determination of the



environmental radioactivity levels in the immediate site environs around




each plant.  The previous information can be translated into resulting




population dose by the use of appropriate dose models and computer pro-




grams.  The computer program approach to the assessment of dose should




not only consider individual plants but also the cumulative effects of




multiple sources within a given region.
                                    C-159

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     Under the generous guidelines for Implementation of this problem




area, the most worthwhile way to approach the problem on a nationwide




basis would be to provide grants or contracts to states for reviewing




plant operating data and performing environmental surveillance activities




around nuclear power plants.   It is not suggested here that these acti-




vities be conducted without consideration of what the AEC is presently




doing in both of these areas.  For, it is the purpose of this program




to arrive at a solution to the problem through a combination of inde-




pendent EPA assessments and field studies in conjunction with information




available from other sources such as the AEC.  There is no explicit or




implied intent to duplicate the work that is presently being performed




by the AEC.



     The state data will be collated and evaluated by EPA regional




offices on a regional basis according to guidelines established by ORP.




The  final analysis of the impact of each operating nuclear power plant




would be made annually by the headquarters staff based on information




received from the states through the regions.  The Milestone Chart for




the  Optimum Program is presented in Figure C-25.



     Program planning and technical direction would be provided by the




FOD.  The states and regions would be basically responsible for assessing




plant operations in terms of dose and the technical support facilities




through field studies would be responsible primarily for validating  the




dose computational technology used by the states, regions, and head-




quarters.
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     The basic information to be derived from this Optimum Program




would be assessment of environmental impact of facilities in terms of




dose, validation of exposure pathway dose models, input to the data




management systems, input to development of criteria, and standards,




and input to technology assessment.



     The basic program is directed at obtaining the information necessary




to resolve the problem of accurately estimating the doses from nuclear




plants.  This information is available from a number of sources.  To a




limited extent the necessary information is available wholly within the




EPA.  That is, headquarters could direct a program utilizing the technical




and analytical resources of the laboratories and other groups within EPA




to arrive at an assessment of the environmental impact of nuclear power




plants.  However, because of the relatively limited resources within




EPA, such a program would not be as productive as a program that addi-




tionally utilized the resources available with states and/or commercial




contractors.  Therefore, the Optimum Program takes advantage of all these




resources on a grant or contract basis with overall technical direction




of the program provided by the Operations Analysis Branch within the




Field Operations Division.  This, of course, will require a large




coordination effort.



     Under this program structure the regional offices would, through




state or other contractor participation, be assigned the responsibility




for the collection, collation, evaluation, and interpretation of data




for plants within their region within uniform guides from the Field




Operations Division.  This information would be forwarded to headquarters
                                  C-162

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for final analysis of the total impact of nuclear pover plants and for




evaluation of those data which are directed toward validating dose




computation models.  In the latter regard, field studies (which could




also be used in assessing total impact) which use the analytical re-




sources of the field laboratories would be primarily directed at deter-




mining critical exposure pathways, validating pathway dose models, and




satisfying the requirements for field measurements as specified by the




Technology Assessment Division in their continuing effort to keep abreast




of changing or advanced reactor technology.




External Needs




     Legislative Needs




     The present authority vested in the EPA by Reorganization Flan No. 3




appears to provide the necessary flexibility for the EPA to conduct this




program.  It appears taht what would be more desirable than legislation




at this point is a memorandum of understanding between the AEC and the




EPA regarding the guidance of activities discussed in this problem area.



     Knowledge




     We are fortunate that the voids in our knowledge relative to the




component problems and their respective solutions are few in number.




A long history of reactor development, the stringent regulatory activi-




ties associated with reactor licensing, reactor operating experience




and the information assembled during the last -15 years has provided an




excellent foundation of knowledge.  Information gaps do exist, however,




but are not extensive when compared with out general level of knowledge.




They are mostly related to refinements in existing areas of knowledge







                                   C-163

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concerning the environmental effects of nuclear power generation.  With




the development of new waste treatment and reactor technologies, new




knowledge gaps will become apparent.  These information gaps can be filled




through appropriate technology assessment programs.




     Research and Development




     The biological effects of chronic exposure to low-level radiation




in the range of doses that one might expect from power reactor operations




on an individual and cumulative basis are still uncertain and will probably




continue.  Therefore, studies directed at determining these effects




should continue in an effort to verify with greater certainty that the




linear dose effect hypothesis which is presently assumed for low doses




is valid.




     A better understanding of the environmental transport of radionu-




clides would be instrumental in permitting a more accurate prediction




of dose to man via the various established food chain pathways.  Such




doses might also be helpful in defining new or previously unconsidered




exposure vectors.  These studies would, of course, take into account




any reconcentration effects which occur in the various media in each



food chain pathway.




     There are inherent errors associated with the current methods used




for estimating dose to man from various exposure pathways.  These errors




are due largely to uncertainties in some of the assumptions that are




necessary to estimate doses.  An attempt should be made to refine these




uncertainties in an effort to improve the accuracy with which dose esti-




mates can be made.  This is not intended to imply that the errors
                               C-164

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associated with present dose computation techniques are outside an




acceptable range but rather is a suggestion that current techniques




can be refined.  This is particularly important since the present design




basis dose guidance for operating reactors is becoming increasingly




smaller.




     It is suggested that exposure pathway dose models based on the more




refined assumptions be developed into a computer program which will per-




mit translation of environmental radioactivity concentrations into dose




to man from any significant exposure pathway.




     Developmental efforts to standardize the collection of environmental




samples, analytical techniques and reporting formats would be very useful




in assuring uniformity in the determination of environmental impact.




     Additional developmental work is required to increase the sensitivity




°f direct radiation measuring devices such as thermoluminescent dosimeters



to within the dose range of interest.




     Interagency Implementation




     The largest single obstacle facing the implementation of this opti-




mum program or any other program sponsored by the EPA which attempts to




evaluate the environmental effects of AEC lincensed facilities is the




interface between the EPA and the AEC.  Recently, this interface has been




the subject of a great deal of controversy between the EPA and the AEC.




The EPA still does not have a satisfactory resolution of the position




of the AEC relative to our programs directed at evaluating the environ-




mental impact of operating reactors.   Without a memorandum of understanding




concerning the AEC's position and a resolution of the AEC policy issues
                                 Cil65

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created by EFA's program efforts in this area, it will be difficult, if




not impossible, to proceed with this program.




Internal Requirements




     The effective resolution of this problem is contingent upon the




following internal requirements:




     1.  An inventory or library of the critical exposure pathways




available for each type of reactor and various reactor sites and other




considerations is the first step in the development of critical exposure




pathway dose models.  These exposure pathways should include a considera-




tion of any reconcentrating mechanisms within the food chain.  This




information is a generic issue and should be factored into the generic




issue of monitoring.




     2.  Critical exposure pathway must be considered on an individual




basis for the development of dose computation models which translate




environment radioactivity levels in any exposure pathway into ultimate




dose to man.  This model development should be directed only at those




exposure pathways which are anticipated to significantly contribute to




man's total dose.  Pathways of lesser significance, although of impor-




tance from an academic standpoint, are not necessary from the standpoint



of determining dose to man.




     3.  Adequate field studies must be developed and implemented that




will validate the critical exposure pathway dose models discussed above.




These studies should attempt to refine any subjective assumptions inher-




ent in the development of the pathway dose models.
                                C-166

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     4.  Computer applications for the general problem area of Operations-




Uranium include both a data management capability for the storage and




retrieval of modeling data (demographic data, meterorology, hydrology




source terms, etc.) and the translation of these data into environmental




dose modeling programs.




PROPOSED PROGRAM




     The third alternative program described in the previous section,




is recommended as the Proposed Program, because it is cost effective




and accomplishes the desired goals.  The Milestone Chart for the Pro-




posed Program is presented in Figure C-26.




     The Proposed Program considers the present guidance on staffing and




budget.  It is identical in scope with the Optimum Program because the




problems are the same for each program.  It differs from the Optimum




Program only in its method of implementation and the rate of accomplish-




ments and attainment of goals.  The Proposed Program, because of con-




straints on resources, would compromise the number and frequency with




which the environmental impact of nuclear power plants could be deter-




mined.  It will not, however, compromise the scope of the functional




elements necessary to resolve the problem.  It is doubtful that the




Proposed Program would permit all operating reactors to be evaluated



annually.




     The proposed low-cost program is implemented by the Field Operations




Division.  FOB will provide program development, technical direction,




and will perform the final analyses to determine the total impact of
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nuclear power plants based upon information received from the regions,




the technical service facilities,  AEG, states,  and licensees.  FOD will




also provide technical direction of field studies directed at validating




exposure pathway dose models and effluent data.  The regional offices




will continue to he responsible for coordination with the states in ob-




taining state surveillance data for nuclear power plants.



     The technical services facilities (i.e., field laboratories) will be




responsible for the development of field and analytical data to support




the development and verification of exposure pathway dose models and




validation of effluent data.  Technical direction of the field studies




effort will be provided by FOD so that priority program objectives and




responsibilities will be assigned by a single group.



     Because of the similarity in the basic problem the component pro-




blems of the optimum program and this proposed program are identical;




other considerations, such as, legislation, knowledge, research and




development needs, as discussed in the optimum program above, will remain




the same.  The internal requirements are also the same.




     The only difference between the two program with regard to inter-



agency implementation is the elimination of many of the state's respon-




sibilities as previously defined and assumption of those responsibilities




by FOD.  The states would continue to participate in this program by  pro-




viding environmental surveillance data around nuclear power plants which




is sponsored either by the state, ABC, or  the EPA.  The states would




have no further responsibility in this program.
                                 C-169

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COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS




     The problem area of Operations - Uranium encompasses the ORP acti-




vities related to the-uranium-fueled reactors which for decades to




come will constitute the public's most common interface with the nuclear




fuel cycle.  Most radiation impact problems from routine operation




associated with these facilities are considered soluable of the BIS




review, this effort is basically one of maintenance, evaluation of per-




formance, and examination of new innovations.  Some notable exceptions




to this basic premise will need to be considered such as decommissioning,




multiple facility siting, and evaluation of the new generation HTGR.




     Within the above context the variance between the Optimum and Pro-




posed Programs will be related to the degree of thoroughness and timeli-




ness of the effort.  The Optimum Program outlines an approach for keeping




EPA continuously aware on an annual basis, of the performance of each




uranium-fueled nuclear power plant relative to its potential radiation




impact on  the environment as well as carry out those activities necessary




to evaluate new innovations and problems.  The Proposed Program would




not allow  the EPA to maintain its cognizance of the industries routine




performance on a current basis.  Although, as long as the AEC is main-




taining its current activities, this in itself would not have a major




deleterious effect on the environment and health of the nation, it would




have two significant secondary effects.  First, this Agency would need




to be content with a second place position in the eyes of industry and




the public due to its lack of current information.  Secondly, other por-




tions of the ORP program, such as EIS review and Strategic Studies would




suffer from lack of the insight that current operation analysis should give



them.                            c_170

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MEASURES OF GOAL ATTAINMENT




     The expected accomplishments and measures of goal attainments In




terms of measurable health effects will be indeterminant at the pro-




jected dose levels because human biological effects at these low doses




are not measurable with existing techniques.  However, it is not alto-




gether unreasonable to expect to find an overall reduction in the health




effects (dose to the general population) from nuclear power generation




in the future as reactor technology improves.  The continued assessment




of the population doses from nuclear plants will provide an indication




and a measure of this dose reduction factor.




     The other major goals are somewhat more tangible and can be con-




sidered accomplished when:




     •  All critical exposure pathways have been identified for various




        environmental media, different types of reactors, and reactor sites.




     •  Dose computational models considering all of the above have been




        developed and validated through field measurement programs.




     e  A data management system capable of processing the dose compu-



        tational models derived above.




     •  Data and techniques are available for the immediate evaluation



        of any nuclear power plant proposal.
                                 0171

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                        FABRICATION-URANIUM






PROBLEM DESCRIPTION



     The problem is to determine, assess and mitigate the environmental




impact of normal operations of nuclear fuel processing, enriching and




fabrication facilities in terms of dose to the population.




Component Problems



     The problem consists of three basic components:  technology assess-




ment of effluent control practices, assessment of doses due to facility




effluents, and dose apportionment for this part of the nuclear fuel




cycle.  Each component problem has associated sub-elements.




     For an adequate technology assessment, current practices must be




compared to foreseeable alternatives.  Based upon a multidimensional




risk/cost/benefit analysis, justifiable ORF recommendations to the AEC




can be made, reducing risk where desirable.




     In assessing population dose the following sub—elements must be




considered:




     •  characterization of facility effluents by radionuclide,




     •  definition of all significant exposure pathways,




     •  development of exposure pathway (radionuclide transport) models,




     •  development and verification of dose models,




     •  computation and interpretation of doses and




     •  development of an automated data management and analysis system




        to reduce the analysis task to a manageable level.




     Dose apportionment to this part of the fuel cycle will be straight-




forward when these problem sub-elements are all satisfactorily solved.
                                 C-172

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     Uranium




     Uranium displays both chemical and radiological toxicity.  The




maximum permissable concentration (MFC) of transportable natural uranium




in the human is limited by the chemical damage to the kidney rather




than radiation damage.  MFC of non-transportable compounds of natural




uranium in the lung or gastrointestinal tract is limited by the doses




of radiation they deliver.  When natural uranium is enriched twelvefold,




control based on radiation dose from uranium-235 becomes necessary.




     HTGR




     The fuel elements for the HTGR consist of uranium and thorium




carbides or oxides in all graphite matrix.  While the light water reactor




fuels contain U-235 and U-239, the HTGR reactor fuels contain U-233 in




addition to the above mentioned isotopes and thorium.  It is noteworthy




that the ICRP recommends that thorium exposure be kept as low as possible




(vs. practical).




     Enrichment




     Enrichment facilities are all AEC-owned facilities.  One expects




controls and environmental programs to be considerably more advanced




at these facilities.




Background




     The Fabrication-Uranium problem area encompasses those steps in the




fuel cycle from the mill to the power plant (yellow cake to fuel element).




It includes the identical stages of the thorium fuel cycle and is inti-




mately related to the Fabrication-Plutonium problem area.
                               C-173

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     The radionuclides in this problem area are predominantly of




"natural" origin.   The problem exists because of their redistribution




and concentration.  To date the AEG has not imposed upon the facilities




the requirement to report effluent data sufficient for a dose assessment.




An independent indepth study of typical facilities has not been made.




As a result there is inadequate data to support the present estimate




that the dose associated with these facilities is low.



     The AEC is presently taking steps which will partially rectify the




problem.  On March 24, 1972, the AEC requested industry comments on a




draft effluent reporting license requirement similar to that of AEC




Safety Guide 21 for the nuclear power industry.  AEC expects to implement




their license requirements in early 1973.  Effluent data should then be




available by early 1974.  An AEC environmental data licensing requirement




will follow in FY-74.  Such data can be manipulated by the EPA regional




and national automated data management system providing that the pathway




and dose models axe developed and verified in a timely fashion.  Facility




participation in an EPA analytical quality control service (AQCS) program




will assure valid data.




Scope




     Present




     The present status of the number and location of uranium and thorium




materials handling facilities in the U.S. is reported in The Nuclear




Industry 1971. WASH 1174-71.  Table C-15 summarizes the data for uranium




and thorium fuels.  One or several of the stages of uranium processing




leading to fuel fabrication may take place at a given locality.
                                 C-174

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                            Table C-15



             URANIUM PROCESSING FACILITIES IN THE U.S.
Facility



Uranium Mills





Conversion U_0Q to UF,
            Jo      C




Enrichment





UF, to UO.
U02 Pellets
U Fuel Fabrication

(including Special Fuels)
Carbide Fuels
Thorium
                             Number of

                             U.S.  Facilities     EPA Regions



                                  20             VI, VIII, X





                                   2             V, VI





                                   3(AEC Owned)  IV, V
 7





 8





14







 8





 7
                                                 IV, VI, VII, X
                                                 I, III, IV, VI, VII
                                                 I, II, III, IV, VI,(IX
                                                                      V
                                                 II, III, IV, VI, VII, \IX





                                                 I, IV, VI, VII,(IX
                                C-175

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      The uranium mills  listed in  Table C-15  represent 16 companies with




 plants  at 20 locations.  The  other  types  of  uranium or thorium materials




 handling capability are for 20 companies  at  27  different locations.




 Excluding the two UjOg  to UFg conversion  plants,  all other locations




 include multiple capability for uranium and  thorium fuels at a given



 plant location.




      Future




      The requirements for processing and  fabrication services for uranium




 and  thorium  fuels in the future are expected to increase at the rate  of




 increase which commercial nuclear power stations  are constructed and




 placed  in operation.  The Nuclear Industry 1971 indicates future domestic




 needs will be met by construction of new  facilities  at several new loca-




 tions and expansion of  existing fuel fabrication  facilities presently




 operated by  the  major nuclear steam plant suppliers.




      Expansion of uranium conversion facilities is expected to take




 place at the  two  existing plants  and addition of  the process for conver-




 sion  of  slightly  enriched U (less than  5%) to UFg at  fuel reprocessing



 plants.




      Expanded needs  for uranium enrichment are  expected  to  be provided




by commercial domestic development.   One such plant has  been proposed




by Reynolds Aluminum Corporation.   As the LMFBR and light water  recycle




of plutonium are introduced,  enrichment demands by the nuclear industry




decrease.  AEC projections  indicate enrichment demands should peak and




decrease by 1990.  New enrichment  capacity would be required by  1981.
                              C-176

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     The scope of this program is expected to decrease significantly




with time.  Some facilities process only solid materials.  Many process




only uranium.  Doses associated with these facilities are expected to




be relatively low.  Also, the environmental programs and effluent con-




trols of a few facilities are already extensive and their impact is low.




     Related Problem Areas




     Accidents, waste disposal, fuel reprocessing, fabrication-plutonium,




operation-plutonium, operation-uranium, occupational radiation and




transportation are related problem areas.  For the purpose of problem




definition, the accident potential from fire, criticality and chemical




releases to the environment have been excluded.  Waste disposal of




uranium and chemicals has been excluded other than the amounts routinely




released during normal operation.




LEGISLATIVE STATUS




     Sufficient operational latitude presently exists under the broad




authorities transferred to the EPA from the FRC and AEC and from imple-




mentation of the Clean Air Act or the Federal Water Pollution Control



Act.




COORDINATION




Interagency




     •  Since all fuel processing and fabrication facilities are either




        AEC licensed or contractor operated for the AEC, intimate AEC/OBP



        interactions will be the norm.




     •  Since fuel processing effluents are chemical and radioactive




        with respect to toxicity, ORP will interact strongly with state
                                   C-177

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        air and water quality offices as well as state radiation offices.




     •  The expertise of the Bureau of Mines (Department of Interior)




        would be utilized.




     •  Department of Agriculture, ESSA (NOAA), would provide support




        in the areas of air transport, dispersal mechanisms and meteo-




        rological information.




     •  CEQ may become involved if interagency negotiations reach an




        impasse over critical issues.




Intra-agency




     •  Regional offices will play a role in this program.




     •  OCP support facilities will be involved in an AQCS activity.




     •  Because of the bulk chemical wastes involved in this problem




        area, OWP and OAF support will be solicited.




     •  OTS has expressed confidence in ORP to handle this problem




        area; however, because of the chemically toxic nature of the




        wastes, they will be encouraged to participate in at least an



        advisory capacity.




ALTERNATIVE APPROACHES




     Alternative problem solutions were considered within the framework




of NEPA, the President's Reorganization Plan No. 3 and the ORP Programming/




Budgetary Proposals for FY 1973 and FY 1974.  Solutions such as allowing




the states, the AEC or another Federal agency to solve the problem were




dismissed as non-responsive to EPA responsibilities.  Solutions such as




having other EPA offices (such as the Regional Offices, OAP, OWP, or




OTS) solve the problem were dismissed as being non-responsive to ORP



responsibilities.




                                  C-178

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     The OKP problem solution was developed in recognition of present




and future AEC activities, the controllability of the effluents, the




predominantly chemical toxicity of the effluents and the assigned weight




of this problem.




     It was recognized that a small scale program would provide a problem




solution within three years, with major tasks completed within two years.




Because of physical constraints* a larger program would not effect a




solution in proportionately less time.  Thus, only one program (the Pro-




posed Program) was developed.




PROPOSED PROGRAM




     The Proposed Program requires two separate but allied efforts:  a




technology assessment in support of E1S reviews required under NEPA and




a dose assessment of all facilities in this problem area.




     The goal of the technology assessment is to mitigate the environ-




mental impact by requiring the best practicable effluent control tech-




nology for each facility.  For newer facilities, EIS reviews by OKP




would be used as a means to that end.  Older facilities would be up-




graded by the AEC if their effluents produced doses in excess of their



EPA assigned dose apportionment.




     As shown in the milestone chart, Figure C-27, the required tech-




nology base will be established in three steps:  (1) the present state-




of-the-art will be appraised, this includes on-site appraisals, (2) for-




seeable advances in control technology, or alternative processing tech-




niques will be assessed and (3) the relative benefits and costs of (1)
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and (2) can be compared.  From this base the risks ascribed by the dose




assessment activities can be evaluated against the costs and expected




benefits of new technology.  Justifiable positions can be attained




thereby.



     The dose assessment effort begins with a preliminary assessment




of dose potential due to the facilities.  This will be accomplished




by analyses of the gross radioactivity releases presently reported by




them.  Based upon expertise developed within OBP in the past, radio-




nuclide transport (Pathway) and dose models will be developed.  Field




studies will be inaugurated to provide a firm data base to verify these




models.  Once verified, the models will be made a part of the automated




data management and dose calculational computer code being developed




concurrently within a separate ORP generic problem area.




     As shown in the milestone chart, AEC imposed license requirements




will result in a semi-annual influx of facility generated effluent




and environmental data by FY 75.  The facility data will have been




verified by the EPA AQCS program.  Via previous OBP interactions with




the AEC, the data will be in a known fora and format.  The successful




and timely completion of the dose assessment tasks will result in an




OBP capability to automatically analyze this effluent data.  Dose assess-




ments at that time can aid CSD in their dose apportionment activities.




Further, by having successfully exercised the OBP computerized system,




it will be possible to include it as an operational sub-program in the




regional and national automated system in FY 75.
                               C-l&l

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     This Proposed Program utilizes max-itmmi leverage to achieve the




data necessary to perform a continual dose assessment.  All problem




elements will be solved by FY 75; major tasks will be accomplished in




FY 74.  In the sense that it is a timely and cost-effective program,




it is an optimum program.




External Needs




     Legislative Needs




     •  Federal - None



     •  State - State water quality standards for uranium and process




        chemicals may be needed.




     Knowledge and Information



     Knowledge and information for initial study fo the problem exists




within the open literature, AEG, EPA (OWP), and USGS publications.




     R&D Needs




     These needs will be met by collection and correlation of existing




knowledge and information.




     Enforcement and Control Requirements



     AEG must impose new license requirements upon facilities, requiring




semi-annual reports of effluents by radionuclide.




     Interagency Implementation




     By commenting upon AEC license amendment drafts, OHP must be assured




that the licensee effluent reports will provide data adequate for a dose




assessment to be made.  The facilities must participate in the EPA AQCS




program.
                                  C-182

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Internal Needs




     Legislative




     None




     Knowledge



     Although sufficient background information presently exists in the




open literature, such must be accumulated and digested by OKP.




     Research and Development Needs




     Basic research and development activities will not be required.




Assimilation and calibration of state-of-the-art equipment may be




necessary for the EPA AQCS program and for the field studies.




     Enforcement and Control Requirements




     CSD must provide at least a broad population dose guidance and




numerical guides if possible.  CSD through the AEC must require the




facilities to provide site-specific demographic data; a detailed




description of the habits of suitable samples of local populations




are necessary inputs to models for dose calculations.




OPTIMUM PROGRAM




     The Proposed Program is essentially an Optimum Program.



MEASURES OF GOAL ATTAINMENT




     The primary goal of these programs is to effect adequate control




of all facilities.  The control will be effected by the AEC under dose




apportionment guides set by the EPA.




     Progress toward achieving this goal may be measured by the satis-




factory completion of the following activities:




     •  Implementation by the AEC of facility license amendments to
                                 C-183

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   require reporting of radionuclide concentrations in effluents.




•  Delineation of all pathways transporting radionuclide effluents




   through the environment.




o  Development and verification of dose models.




•  Apportionment by EPA of doses to the nuclear energy field and




   establishing dose standards for fuel fabrication.




•  All facilities participating in an EPA AQCS program.




•  Development, verification, implementation of an automated OKP




   data management system which will translate facility effluent




   data into dose and dose commitment.




•  An upgrading of any facility to effect significantly better




   effluent control, reducing risk.
                             C-184

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                              TRANSPORTATION





PROBLEM DESCRIPTION




Component Problems



     •  Nuclear Power Industry




     •  Industrial Users




     •  Medical Users




     •  Other (Plowshare, SNAP, etc.)*




Background



     The AEC has acheived an impressive safety record in the transpor-




tation of nuclear material for their device testing and production




programs, as has the Navy for their nuclear ships.  Industrial and




medical shipments have not presented a major problem since the number




of shipments has been relatively small.  There have been a few instances




of lost sources and of leaking sources.  Several of these instances




have involved radium which has been in wide use for a much longer time




than reactor produced radionuclides.



     Responsibility for the safe shipment of radioactive materials has




been transferred around the Federal and state governments during the




past years.  This situation has produced a complex regulatory system.




Nuclear Assurance Corporation has prepared probably the most digestible




analysis of the situation by breaking the regulators into three




categories:  Carrier Regulators, Safety Regulators, and Commodity




Regulators.  In this breakdown, the Interstate Commerce Commission,




the Civil Aeronautics Board, and the state Public Service Commissions




are the carrier regulators.  Various Administrations within DOT, the
                                C-185

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CAB, and the state Highway Commissions are the safety regulators.




The AEG and various state agencies are the commodity regulators.  For




radioactive material shipments, and in particular nuclear fuel ship-




ments, the responsibility is shared by several of the regulating




authorities.  For example, the AEC and DOT have a memorandum of under-




standing which delineates the responsibilities of their respective




agencies in the shipment of nuclear fuel.




Scope



     The problem is identified readily by projecting the transportation




requirements for the nuclear power industry.  By 1990 the AEC projects




350 to 400 operating nuclear power plants in the U.S.  Each plant will




ship about 100 truckloads of spent fuel (the most hazardous form) per




year an average distance of 500 miles.  Thus, the total mileage for




spent fuel shipments will be about 20 million miles annually.  The



accident rate for large trucks is about 2 accidents per million miles




with about 10% of the accidents classified as serious or causing




considerable damage.  Thus, 40 accidnets per year involving spent nuclear




fuel in shipment from reactors to reprocessing plants can be expected




in 1990.  About 4 serious accidents per year would also be expected.




In addition to potential releases from accidents, the routine exposure




to populations along the route must also be considered.  This exposure




may become significant near reprocessing centers where shipments will




be concentrated on a few routes.




     A second problem is the shipment of recycled plutonium fresh fuel




to LWR's and of U-233:U-235 fresh fuel to HTGR's.  Plutonium and U-233
                              C-186

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require greater shielding for external exposure than enriched uranium




and, of course, present more of a criticality problem under certain




conditions.




     It appears the largest potential problem is the shipment of




spent fuel from LMFBR's to reprocessing plants.  The combination of much




larger quantities and a shorter cooling time C30 day estimate) indicate




that transportation will quite likely be the limiting factor in both




site selection and size of LMFBR's.  Although much work is required,




it is suspected that the economics of transportation may well dictate




the necessity of nuclear energy parks in a breeder power program.  A




summary of the scope of the transportation problem for the nuclear




power industry is presented in Table C-16.




     Most of this discussion deals with the nuclear power industry




because of the growth potential.  However, radioactive shipments to




medical and industrial users are also expected to increase significantly.




In general, the consequences of both routine shipments and accidents




are lower than those for nuclear power.  This problem should also




receive attention to insure protection of health and safety.






COORDINATION




Interagency




     Because of the large number of regulators involved in this area




the interagency coordination could become a rather extensive effort.




However, it can be considerable simplified for purposes of the proposed




program.
                               C-187

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                             Table C-16

                SUMMARY CHART FOR TRANSPORTATION
             REQUIREMENTS OF NUCLEAR POWER INDUSTRY
Media                 Mode


Spent Fuel            Truck

High Level Waste      Rail


Low Level Waste       Air

Pu fuel               Barge

U Fuel


U-233 Fuel

Mixed Fuel

U Ore
Path
Mine to Mill
Form
Solid
Mill to Conversion  Liquid
  /Enrichment
Enrichment to
  Fabricator

Fabricator to
Reactor
Reactor to
  Waste Site

Reactor to
  Reprocess

Reprocess to
  Waste Site

Reprocess to
  Fabricator

Reprocess to
  Conversion/
  Enrichment
                    Gas
Control


AEC

DOT


States

ICC

CAB
                            C-188

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     Headquarters



     Cognizance of AEC and DOT efforts in promoting and regulating




the transportation of nuclear materials and response to EIS's concerning




this topic.




     Regional



     Coordination with state and local jurisdictions and Federal




agencies such as OEP and AEC for the development of emergency response




capabilities.




Intragency



     It is anticipated that ORP coordination within the agency will




fall largely with FOD and the regions in attempting to develop emergency




response capabilities.  Transportation estimates may be required as




input to OSW in their attempts to evaluate the feasibility of Federal




hazardous waste repositories.






ALTERNATIVE APPROACHES




Reduced Efforts



     EPA participation in the development of emergency response




capabilities can be reduced or eliminated.  The technical evaluation of




trasnportation for the nuclear power industry can also be eliminated




and comments on the subject deleted from EIS reviews.  However, a contract




has been awarded for an analysis of transportation accidents.




Expanded Efforts



     EPA could seek the lead role in emergency response through the




currently established National Contingency Plan.  At present the AEC
                              C-189

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has the lead role in the radiation area.  Participation in the technical




development of transportation methodology would require a large effort




in terms of man-years and the establishment of working agreements with



other agencies.






OPTIMUM PROGRAM




External Needs




     Legislative Needs




     Legislation is required to enable the EPA to exert control over




the shipment of hazardous materials which may lead to contamination of




the environment.  Such legislation should be closely tied to any proposed




system of federal hazardous waste repositories which is currently under




study by OSW.  Radioactive material shipments under this legislation




would require recognition and consideration of existing enabling




legislation given to DOT and AEG.




     Knowledge




     •  Nuclear power projections and related transportation requirements




     •  Potential problems related to the multiple regulatory agencies




        involved with the inevitable inconsistencies in regulations




     •  The status of shipping cask development




     •  Accident statistics for hazardous material shipments




     •  The status of various modes of shipment (Air transport will




        be proposed for fresh fuel shipments - Railroads are refusing




        to ship radioactive material - etc.)
                                 C-190

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     •  An analysis  of  the potential consequences of radioactive material




        shipment accidents




     •  An analysis  of  the potential impact of routine radioactive




        material shipments




     •  Costs of shipments especially spent fuel for siting criteria




     •  Capabilities of state and local jurisdictions for emergency




        response




     Research and Development Needs




     •  Develop emergency response models and plans




     •  Develop TID  system for selective monitoring along much




        travelled routes.




     Enforcement and Control Requirements




     Routine enforcement should be performed by the regulating agencies,




i.e., the states, AEC,  and DOT.  Overall indirect control may be effectively




applied by EPA through  siting criteria and guidance or criteria for the




energy park concept.




     Interagency Implementation



     DOT.  Liaison with DOT concerning hazardous material shipments




relative to federal  hazardous waste repositories, and associated legis-




lation.  Emergency response requires coordination with DOT.



     AEC.  Working agreement must be negotiated concerning emergency




response lead agency.  Exchange of technical information is required.




Liaison needed concerning transportation of radioactive material to




Federal hazardous waste repository (this is closely related to the
                              C-191

-------
issue of whether a system of Federal repositories will be established,




who will run them and if radioactive waste will be included).  Conduct




training courses.




     PEP.  Liaison concerning emergency response is needed.  Definition




of lead agency.




     States.  Development of emergency response models and plans.




Cognizance of state regulations concerning radioactive materials ship-




ments .




Internal Needs




     •  Develop technical staff within ORP




     •  Develop legal/liaison staff in coordination with OSW




     •  Generate other information needed for energy park criteria




        (siting, reprocessing, fabrication, sizing, etc.)




     e  Develop model plans at regional levels.






PROPOSED PROGRAM




     This program is the same as the Optimum Program with the exception




of legislative requirements which are deleted here.  The Milestone Chart




for the Proposed Program is presented in Figure C-28.






COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS




     The impact difference between the two programs rests almost entirely




on the decision made concerning the system of Federal hazardous waste




repositories.  If the decision is made to establish such a system and if




radioactive material is to be stored in this system, the transportation




issue would require definition and delineation.
                               C-192

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              73
                                     71"
                                                           75
                                                                         76
c.fcs.
S.&I.
T.A.
R&D
                                                                           Other
                                                                           Input
                                                                       DECISION'  j ^_____^
                                                                      ON EKFRCY  j»|CRr^R. j
         ACCIDENT
         ANALYSIS FOR
         NUCLEAR POWER
         INDUSTRY SHIPMENTS
          COGNIZANCE OF
          ISOTOPIC AND
          OTHER SHIPMENTS
          DEVELOPMENT OF
          TLD MONITORING
          SYSTEM
                                                                    PARK CONCEPT
                                 ANALYSIS OF IMPACT
                                 FOR ROUTINE SHIPMENTS
                                                                    OF
                                                          PROJECTIONS
                                                          FOR TOI
                                                          IMPACT
                               Cont.
States
Regions
Other EPA
Coord .
Other
Agency
Coord .

DEVELOP MODEL
PLAN FOR
EMERGENCY '
RESPONSE


-

COORDINATE
WITH NATIONAL
CONTIGEiCCY PLA!.'

DEVELOP MODEL
PLAN FOR
'1

Ci


EMERGENCY RESPONSE
WITH AEC, OEP, DOT
DEVELOP
EMERGENCY
PLANS

PLANNING
GUIDANCE
ant.'
;ont

i

AGKEKME::TS
— ^ ON EMERGEHC
ACTIO:J
^ I


J
TEST MODEL
PLAN IN -
VARIOUS
STATES
I TEST PLANS
Y — *•* WITH MOCK
ACCIDENTS

1
RECO
fc, REGULA
CRIT
E
I
MMEND
TIONS,
ERIA,
TC.
— •
.Training
          CONDUCT EMERGENCY
          RESPONSE COURSES
          FOR VARIOUS
          PARTICIPAVfS
                           Cont.
                               FIGURE  C-28

                  PROPOSED PROGRAM - TRANSPORTATION
                                   C-193

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MEASURES OF GOAL ATTAINMENT




     •  Emergency Response Model - complete by FY 1974




     •  Emergency Response Plan - completed by first half of FY 1975




     •  Emergency Response Plan Test - completed by second half of FY 1975




     •  Development of TLD Monitoring System - completed by FY 1974




     •  Routine Survillance on Shipment Routes - in effect during FY 1974




     •  Accident Analysis - report completed by FY 1974




     •  Routine Shipment Analysis - report completed by FY 1975.
                               C-194

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                       CONSTRUCTION MATERIALS






PROBLEM DESCRIPTION




Component Problems




     Construction materials account for the largest exposure to the




U. S. population resulting from man-caused radiation sources.  The




problem has not been considered previously by the radiation protection




community due to the consideration of the problem as a component of




natural radiation, a subject which has been generally neglected.




Although construction materials generally attenuate man's exposure to




natural terrestrial radiation sources, the reduction is usually offset




by the contribution from construction materials themselves, so that




there is generally no net change of man's natural radiation exposure




due to living in most dwellings.  This paper focuses on the potential




for exposure through the unknowing and inadvertent use materials bearing




elevated levels of natural radioactivity.




     There are basically two major component problems of the construction




material exposure problem:




     1.  Whole body exposure to the gamma radiation from K-40 and




daughter products of Th-232 and U-238 within the construction material.




     2.  The inhalation of radon daughters which emanate from the




construction materials and result in lung exposures to occupants of




dwellings.




     The first source of exposure generally accounts for 40-100 mrems/




year to the population, or an integral dose equivalent of approximately




8 x 10  man-reins.  Although there is less quantitative information on
                             C-195

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man's exposure due to radon daughter exposure, radon daughter products


have been measured in various types of dwellings and contribute 1-2


rems/year to lung tissues.


     A third component problem of the construction material issue does

                                                        /*
not relate to the construction material exposure per se/but rather to


the difficulty in attracting interest to the subject as a serious issue


for consideration.  Part of this lack of interest may probably be


attributed to the fact that natural radiation exposure does not appear


to hold the same technical challenges which are associated with exposures


to nuclear reactors, fuel reprocessing plants, microwave sources, etc. /


Background


     Little attention has been given to the incorporation of naturally-


occurring radionuclides into our man-made environment, as evidenced


recently by the use of uranium mill tailings in construction.  Recent


studies by EPA of 43,000 structures in 61 communities in western states


showed that natural radiation anomalies existed in 6,400 of the surveyed


dwellings.  The widespread occurence of these anomalies, which were


due to high levels of natural radiation in building materials as well as


landfill, indicates that the problem is considerably larger in scope


than suspected.  In addition, certain areas in Florida and Tennessee have


been found in which the incorporation of high levels of radioactivity into


building materials has increased the exposure of residents.


     Even though man's radiation exposure from natural sources varies


significantly with geology and elevation, it is properly beyond the
                               C-196

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scope of government to dictate where people should live relative to

their natural radiation exposure.  On the other hand, man's propensity

for indoor living can influence his exposure because of the variations

of naturally occurring radioactivity in building materials; therefore,

our concern should be in this area rather than with one's geographical

choice of residence. /If buildings are made mostly of wood, which has

a low natural radioactivity, the overall exposure is reduced because

there is some shielding of terrestrial radiation./ In contrast to this
                                               **s
situation, homes built with masonry, wallboard or stone walls can

increase man's exposure to natural sources.  The degree to which building

trends emphasize use of wood or these other materials will thus influence

the changes in the national exposure from this source of radioactivity.

     There are limited data available on the precise type of materials

used in the construction of dwellings.  In view of the amount of new

construction which will be built in the United States between now and

1978 (approximately 20 million housing units for 60 million people),

it is important to determine the significance of building materials

as a potential source of radiation exposure to man.  The materials which

will be incorporated into these housing units are basically without

government control with the exception of concern for structural and

fire safety.

     The major initial program efforts for materials containing natural

radioactivity should be to increase knowledge of the degree of exposure.

Current EPA activities are twofold:  1) completion of a general survey

of literature pertaining to variations in exposure to natural background
                               C-197

-------
 in  the United States and 2) working with experts in Poland  to  obtain




 more extensive field data on the influence of variations  in natural back-




 ground on population dose.  These information-gathering programs will




 be  followed by studies of means that could be employed to reduce




 current exposures and other means for preventing possible future




 exposures in man-made environments.  In order to pursue any major




 programs to reduce exposure via these routes, it will be  necessary to




 estimate the expected dose savings (in roan-rem) that could  occur.  The




 difficulties of regulating building material industries and construction




 practices would be justified only if substantial man-rems could be




 averted.  If estimates indicate a justifiable effort in this area,




 considerable work will be required to determine the national exposure,




 to  conduct inspections of various high-level sources of basic  construc-




 tion and building materials, and the development of criteria and




 standards governing their use.




     Virtually no attempt has been made to reduce or examine man's




 exposure to natural radiation sources.  The resulting lack  of  informa-




 tion was particularly evident when EPA was invited to participate in the




 review of human exposure in several Western states which  resulted from




 the inadvertent use of uranium tailings in various structures.  Studies




 in Grand Junction, Colorado, and other localities have shown that the




 indoor radon levels resulting from uranium tailings present in building




materials and in land fill account for significant exposure to inhabi-




 tants in buildings which contain tailings.
                                 C-198

-------
     Other than operating experience in Grand Junction, which has not


been documented in the technical literature, there are few papers on

                                                ^-"
the subject of exposure to building materials. ££he paucity of informa-


tion is an interesting contrast to the volumes of materials which


occupy the technical literature on radiation exposure due to relatively


safe sources such as nuclear reactor waste discharges during normal


operation. /


Scope


     The present scope of the problem is nationwide; the anticipated


construction of additional dwellings to relieve a nationwide housing


shortage will add to the problem.


     An increasing use of man-made materials in dwellings suggests


that additional information is required on the nature of these materials


before wide-scale use of new materials is justified.  Such caution could


have prevented the unnecessary exposures which are now occurring to


inhabitants in Grand Junction and other localities.



LEGISLATIVE STATUS


     At present there is no legislation which controls the levels of


radioactivity present in construction materials.  Although construction


materials must pass the Federal, State, and local standards for fire


safety and structural strength, there are no statutes which would allow


the removal of construction materials from the market which might be


determined to contain elevated levels of radioacitivity.  At the Federal


level, it appears tha't-EPA,.HUD _or. the-FDA could undertake the respon-


sibility for implementing enforcement of safe levels of exposure due to
                                 C-199'

-------
construction materials.  However, under the authority transferred to




the EPA by Reorganization Plan No. 3, it is the responsibility of EPA,




under the Federal Radiation Council's guidance authority, to establish




guidelines for use by Federal agencies for exposure to natural radiation




sources.






COORDINATION




     Interagency Coordination would be required with those agencies




having an input into the selection and quality of construction materials




used in the United States.  Therefore, interagency cooperation may be




necessary between HUD, the various branches of the government which




control financing of construction, and various state and local agencies




which establish building codes.  As previously noted, EPA's FRC guidance




function places primary responsibility upon EPA for taking the lead in




providing safe exposure criteria to other Federal agencies.




     Intra-Agency Coordination would be required with the Office of




Legislation to determine the best possible approach for legislating




man's allowable exposure to natural sources in construction materials.
In. addition, the Office of Research_and-Monitoring would be requested




to assist in the nationwide determination of the present level of




radioactivity present in various construction materials, j






ALTERNATIVE APPROACHES




First Alternative




     HUD implements standards which would be binding upon lending agencies




and which would require certain levels of radioactivity in construction
                               C-200

-------
materials.  These standards would be-established as a result of EPA guid-




ance to all federal agencies.  The ORP would act as technical consultant




in determining the extent of the problem and recommending a level for




construction materials, but HUD would carry out the actual exposure




reduction on a nationwide basis.




Second Alternative




     EPA would request the Food and Drug Administration (or new Consumer




Protection Agency) to use their consumer protection authority to remove




potentially unsafe materials from the market.  EPA would provide FRC




guidance for acceptable exposure levels.




Third Alternative




     A third alternative approach would be for EPA to seek legislative




authority to recuce man's  exposure to construction materials.  This




would enable EPA to establish national standards as well as guidance to




other Federal agencies.




Fourth Alternative




     Do nothing.  This approach would not involve any damage to EPA




since there has little public interest in the problem in the past, and




it is not likely that interest will develop in the future if no govern-




ment activity is initiated.






OPTIMUM PROGRAM




     At present there is no legislation concerning the use of building




materials insofar as natural radiation is concerned.  It should be noted




that legislation is required immediately to initiate EPA's effort under
                                C-201

-------
an optimum program.  The legislation is required in order to respond




effectively to HUD, which seeks to establish a limit on exposures



resulting from building material radioactivity.  During FY 1976, it is




likely that legislation would be necessary to permit an enforcement




role for EPA to license building material suppliers.  In addition, it




would be useful to request posting of exposure levels in high dosage




areas where building materials using high levels of natural radioactivity




were once used.  This procedure could be useful in the case of resale of a




residence in the Grand Junction area, for example.



     Virtually no information exists at present on the natural radiation




content of building materials.  In order to fill this knowledge gap, two




approaches are required in order to gain information.



     One is research and development, which would concentrate upon the




correlation of external gamma levels with indoor radon levels and the




effect of inhaled particles on lung tissue.  In addition, it is nec-




essary to study the possible substitution of material bearing low levels




of radioactive material for materials bearing higher levels of natural




radiation, such as certain masonry materials.  At the same time that




research and development in these areas is going on, additional work




is required to develop instrumentation and procedures at technical support




facilities for scanning relatively large areas quickly.  These techniques




may include mobile laboratories and aerial surveys.




     It is likely that enforcement and control requirements will be




necessary within the next year.  As previously mentioned, these measures




will focus upon the EPA's ability to control the use of various materials,
                                  C-202

-------
 perhaps through a license program.  Interagency  implementation  of  these




 requirements may be effected through HUD or perhaps through  the proposed



 Consumer Protection Agency.




     As noted on the attached Milestone Chart, the primary internal




 needs for the Optimum program are directed towards monitoring and  field




 operations in order to establish current state of knowledge  on  the




 subject.  In addition, considerable importance is attached to training




 since radiation protection specialists have received virtually  no




 training in natural radiation and are unfamiliar with  the radlonuclides




 present in the natural environment and the mechanism of buildup  of radon




 in enclosed structures.






 PROPOSED PROGRAM




     The Milestone Chart for the Proposed Program is presented  in




 Figure C-29.  There are two positions and $175,000 (overage  program)




 planned for the construction material program for the next year, and




 therefore, it is likely that efforts in this field will be accomplished



 through contracts, literature surveys of existing information, and




 the use of results from PL 480 research.  Much of the preliminary




 information has already been assembled in an EPA report which will be




published in FY 1973,  and therefore, future work in this area should




consist of performing sufficient background work via contracts so  that




HUD may be persuaded to consider the control of natural radiation  in




its material selection programs.
                                  C-203

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 PAGE NOT
AVAILABLE
DIGITALLY

-------
     Another possible procedure in the future for accomplishing results




with minimum EPA expenditures would be to request the proposed Consumer




Protection Agency to undertake this form of protection of the public.






COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS




     The Optimum and Proposed Programs differ in two significant aspects.




Although the scientific accomplishments of both programs are identical,




the Proposed Program results will be accomplished on a time scale of




approximately 1.5 times the Optimum Program.  The second major difference




is that the Proposed Program will not include EPA legislation or envorce-




ment, unlike the Optimum Program.  The results of the scientific




accomplishments will be given to other agencies along with EPA recommen-




dations for implementing a population exposure control program.






MEASURES OF GOAL ATTAINMENT




     The goal attainment is simply a measure of reduction of man-rams




from what would be projected if present materials were used in the




future.  Since accurate estimates of the present levels of exposure




due to natural radiation and building materials do not exist, an




estimate of the goal attainment is not possible at this time.
                                C-205

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                      URANIUM MINING AND MILL TAILINGS






PROBLEM DESCRIPTION




Component Problems




     Uranium Mining




     The problem is to insure that exposure standard of 4 working  level




months -(-WLM) per -year previously published as Agency guidance is being




implemented and enforced by the U.S. Bureau of Mines (USBM) of the




Department of Interior (DOI).




     Uranium Mill Tailings




     Agency action is required to (1) prohibit the use of mill tailings




in construction and (2) monitor and review the policies practiced  by the




Atomic Energy Commission (AEC), or, alternatively, by Agreement States, in




the regulation of radioactive discharge from uranium mills, including a




review of the operational policies regarding the stabilization and long-term




control of uranium mill tailings.  Such an exercise could culminate in the




development of an EPA land use policy.  The use of uranium tailings in




Grand Junction, Colorado, for construction purposes has resulted in a




radon problem for approximately 2,000 homes.  Legislation has been passed




to authorize funds for a remedial action program in Grand Junction by the




Atomic Energy Commission and the State of Colorado.  The role of EPA in




the remedial action program is that of a consultant and advisor, and to




remain cognizant of the program.




     It is still necessary to develop a passive dosimeter for monitoring




indoor radon daughter levels more effectively than presently in use in






                                   C-206

-------
Grand Junction, Colorado.  Investigation of the possible use of uranium




tailings for construction purposes in nine other western states indicates




that follow up corrective action may also be required in a limited number




of locations.




Background




     Uranium Mining




     In 1967, the Federal-Radiation Council,(FRC) at the request of the




Department of Labor, recommended to the President an exposure standard




for underground uranium miners of 12 working level months per year.  This




standard was to be enforced by the USBM.  Later, the FRC revised its




recommendation downward to 4 WLM, to become effective January 1, 1971.




This effective date was later changed to July 1, 1971.  The recommendation




was published as EPA guidance (nhe EFA hd^ing assumed the responsibilities




of the FRC by Reorganization Plan No. 3 of 1970), with enforcement




responsibility resting with USBM.  Since that time, USBM has published




procedures for variance applications against the 4 WLM t.tandard (Federal




Register, June 27, 1972).  These regulations would allow variances for




concentrations of radioactivity in the mines for periods of no longer than




18 months, but would not allow an individual miner to exceed the 4 WLM




per year exposure standard.




     Uranium Mill Tailings




     Uranium mill tailings are sand-like radioactive waste products resulting




from the milling of uranium ore.  The quantity of tailings generated is




about equal to the quantity of ore processed.  In the past tailings have




been UL,ed as fill under and aro.inu aovies c.-.d other buildings., resulting in






                                   C-207

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increased radiation exposure to occupants of the buildings, both from


gamma radiation and from radioactive radium progeny.  This problem exists


primarily in the Grand Junction, Colorado  area, although other milling


communities in Colorado and nine other western states potentially have a


similar problem of lesser-magnitude.  EPA has completed a preliminary


assessment of other communities in Colorado and the nine other western


states affected.  Assessment of the problem in Grand Junction is almost


completed, and plans are~ underway for~a"remedial action program, which


is the responsibility of the Atomic Energy Commission and the States.


     An associated facet of this problem concerns the environmental impact


of active and inactive uranium mills.  Specifically, this relates to the


discharge of radioactive effluents to the air and water and the long-term


stabilization and control of uranium mill tailings.-  The AEC or an Agreement


State regulates the discharges to the air or water; however, the measures


for control of tailings at inactive sites and the adequacy of the monitoring


of radioactive effluents by the AEC or Agreement States need  further study.


Some states exercise adequate control, while others are highly deficient.


The responsibilities and authorities of the AEC with regard to controlling


tailings are somewhat nebulous at the present time.  An additional dimension


of the problem concerns land use policy and'whether "disposal" of tailings,


by setting aside land areas as a permanent tailings site requiring perpetual


control, is the best land use or the best method of managing this radioactive


solid waste product.  The resolution of this facet appears to be within the

                              /..„. >«..->.>  '< '
purview of the Bureau of Land Reclamation, which should establish a policy


in the face of USBM recommendations for backfilling open-pit uranium mines.




                                   C-2G3

-------
Scope


     Uranium Mining


     Uranium mining activity is regional in nature, being confined to ten


western states.  In the last decade, economic demand for the ore has decreased,


the 1971 estimate for ore production being 13,200 tons U30S, compared to a


peak of 17.,600 tons in 1961.*  A concurrent decrease in the number of mines


and miners was also experienced.  The number of underground mines dropped
                       ——«•  -—-          • ••••*-  -<**

from the peak of 850 in 1958 to only 193 in 1971; miners totalled 4,908 in


1960, compared to 1,567 in 1971.*  The scope of the problem revolves around


the primary cause of mine closures and the impact of enforcing the 4 WLM


per year standard on the closures.


     Uranium Mill Tailings


     Since virtually all the uranium ore processed ends up as tailings,


the 13,200 tons of U30O produced in 1971 represent only a small fraction


of the quantity of raw ore processed.  The volume of these radioactive


solid wastes has created problems with regard to land use.  With uranium


mining on an economic decline, however, the volume of tailings generated


will necessarily decrease.


     Surveys have been made to determine the gamma levels and radon


concentrations in homes in Grand Junction, Colorado.  Both mobile and


house-to-house surveys have identified structures with excessive backgrounds,


presumably due to tailings, in other states.  Remedial action programs are


being implemented in Grand Junction and will have to be developed in the
*Division of Raw Materials, U.S. Atomic Energy Commission.


                                   C-209

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other affected States.






LEGISLATIVE STATUS




     The EPA has functioned in an advisory capacity only in addressing




uranium mining and in both advisory and technical assistance capacities




in milling problems.  Standards for underground uranium miners vere




developed by the Federal Radiation Council at the request of the Department




of Labor; cooperative programs have baen developed with the States under




the FRC mandate transferred to EPA by Reorganization Plan No. 3 of 1970;




advice and technical assistance has been rendered under the transferred




authority for EPA to respond to situations potentially affecting the public




health; and model legislation for the control of uranium mill tailings




has been supplied the States.




     Congress has authorized five-million dollars for corrective actions




in Grand Junction, Colorado.  The Atomic Energy Commission is the lead




Federal agency in this program, although EPA v/ill be involved on a




consultant basis to the State in determining the extent of the problem.






COORDINATION




Interagency




     The Department of Interior has the responsibility for enforcement  of




the radiation standard for miners recommended by EPA.  With regard to mill




tailings, involvement has been in the form of technical assistance and




extensive resources to the States by the EPA and AEC, although the States




bear the primary responsibility for resolving the problem.  The EPA has




developed a draft of model legislation for mill failings control for States




                                  C-21D

-------
to assist them in this matter.  The EPA has served on the State of
Colorado Interagency Indoor Radon Steering Committee.  This committee was
dissolved in September 1972.  A new policy level advisory committee is
to be formed by the AEG and the State to advise them regarding the
corrective action phase of the Grand Junction project.  The EPA is
expected to participate on this advisory committee.
Intragency
     After the determination of the extent of the mill  tailings problem,
there should be more intra-EPA involvement:  the Office of Water  Programs
and the Office of Air Programs should review and determine the implementation
of standards promulgated by Agreement States or by the AEG to regulate
effluents into water and air, respectively; and the Solid Waste Office
should become involved in solving the disposal problems created by mill
operation.  With regard to non-radioactive hazards, the Office of Toxic
Substances should have a role in reviewing the standards  pertaining  to
the release of toxic substances such as sulfates or acids  into the wacer.

ALTERNATIVE APPROACHES
Uranium Mining
     First Alternative
     Continue to apply Agency leverage  to  insure  the  implementation  of
the 4 WLM per year  exposure standard for underground  uranium miners.
     Second Alternative
     Develop new standards  for gamma exposure  in mines,  if necessary.
     Third Alternative
     Conduct -jjuuy  of coni.ro! ritiMourc.-.  1:1  riiiic.i.  to reri-icv.'  •• :poam. :  o~
                                  C-2-.1

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 mine workers.




 Uranium Mill Tailings




      First Alternative




      Providing the States with model EPA regulations,  such as those




 recently presented at the Colorado River Basin Conference, to encourage




 States to adopt legislation to control the use and disposal of tailings.




(Subsequent Agency leverage-fey way of Environmental Impact Statement




 review will be required to assure resolution of the problem.




      Second Alternative




      Studies by EPA to determine the best land use policy with regard




 to the disposal of mill tailings.






 OPTIMUM PROGRAM




 External Needs




      Legislative Needs




      0  Uranium Mining:  Publication by Department of Interior of




         regulations already published as EPA guidance on  exposure limits.




      &  Uranium Mill Tailings:  Appropriate enabling legislation for the




         States to control the tailings problem.




      Knowledge and Research Development




       0 Uranium Mining:  Technical assessment of  the accuracy and




         reliability of personnel monitors and air samplers  used in




         uranium mines.




       6 Uranium Mill Tailings:  Consultant efforts toward the determination
                                    C-212

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        of  biological effects resulting from radiation exposure due to




        proximity of mill  tailings; continue development  of methods of




        stabilizing tailings piles to minimize  or eliminate  the radiation




        exposure associated with them; and  development of the  optimum




        "disposal" methods.




     Enforcement and Control




     6>   Uranium Mining: —Enforcement by^DOI^of  either EPA guidance or of




        their  own regulations.




     o   Uranium Mill Tailings:  Enforcement of  effluent  limits on




        radioactivity release by the AEG  or by  Agreement  States;




        prohibition by  the States  of  the  use of mill  tailings  in




        construction; and  control  of abandoned  piles  of mill tailings.




     Intcrageney Implementation




     p   Uranium Mining:  Cooperative efforts between  EPA  and DOI  to  insure




        the radiation safety required  for uranium miners.




     0  Uranium Mill Tailings:  Cooperation between the  States, EPA,  and




        AEC to provide  for the control of mill  tailings  use.




Internal Needs




     Uranium Mining




     Periodic checking  by  Headquarters and Regional personnel  to  determine




how effectively the  exposure standard  is  being  enforced  by USBM (DOI).




Obtain  from USBM an  annual report  on  the  exposure of uranium miners.




     Uranium Mill Tailings




     Periodic checking  by  NERC-LV  and  Regional  personnel  to determine the
                                  C-213

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adequacy of control of mill effluents and operations, along with the




adequacy of control over mill tailings, including a determination of who




is actually responsible for exercising such control.  The program for




FY 73 is as follows:




     0  Negotiate new contract with Colorado for position to assist in




        Track Etch Study.




     0  Continue the readout- and suppl.y._ofUe-ir sampling equipment until




        completion of Track-Etch field trial.  This includes the make-up,




        readout, and data reporting of the TLD detectors at NERC-LV.  Parts




        for the air sampling equipment will still be supplied by EPA.




     G   Provide computer services including programming data storage, and




        various data printouts for the Uranium Mill Tailings Gamma Survey




        Data Base and Indoor Radon Snudy.




     0  Completion of the Track-Etch evaluation study by October 1973.




     0  Continue work on determining applicable methods for tailings  pile




        stabilization and conduct surveys of existing piles upon request.




     9  Provide the States with model EPA regulations to encourage States




        to adopt legislation to control the use and disposal of tailings.




Estimated Effort




     One-half to one man-year at Headquarters, FY 73; one man-year from




Regional personnel, FY 73; both resource requirements expected to double




in FY 73.  The budget for this project at NERC-LV is shown  in Table C-17.




Approximately 6 man-years of effort are being planned.




Milestone Chart




     The milestone ciinrt for fne Optinu-- Fr^^am :'.s rhoun in }'i",ji c Z-Z'.'.




                                   C-2U

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                                   TABLE C-17
                           REVISED ORP PROJECT BOUGHT
TITLE:

PROJECT MANAGER:

LOCATION:

OUTPUT:



COMPLETION:
            Uranium Mill Tailings Project

            David L. Duncan

            NERC-LV

            Data Collection, Monitoring
            Systems development, reports
            and recommendations

            Continuing
    Project Element/
      Project No:  2F2191

    IY 72 $000:  266.6
    IT 72 Positions:  15
  Original
    IY 73 $000:  262.0
    IY 73 Position:  17
  Revised
    IY 73 $000:  192.7
    IY 73 Positions:  5
Man
Item Years
" Estiaated
EJcpenditures
through October
Projected
Expenditures
IY 1973
Colorado
   (l)  Instruments            (2 da/mon)

   (2)  TLD Heads              0.6
   (3)  Sampler -parts            0*
   (4)  Ambient Ra Study       0.3**
   (5)  Colorado Contract

   (6)  Computer Services      0.2
   (7)  Consultation & Advice  0.1
   Track Etch                  1
Other
   Project Officer
   Asst. Project Officer
   Staff Officer
   Laboratory Technician
   Secretary
   Mobile Scanner
   Vitro
   Riverton
   Mexican Hat
   Other
   Temporary Employees
      Through July  (2)
      Through Sept  (2)
      Through Oct (l)
                         1
                         1,
                         1
                         1
                         1
                         1
                         0.05
                         0.05
                         0.1
                         0.1

                         0.3
                         0.3
                         0.3
                                              $450

                                            $3,800
                                            $2,800
                                              $400
                                                 0

                                            $1,200
                                              $600
                                                 0
 $5,000
 $4,000
 $3,000
 $3,350
$21,000****
      0
      0
 $1,000
      0

 $4,900
 $6,600
 $4,600
                                                 $69,100
*
*»
#**
                          $450 (Discon-
                                tinue)
                       $11,650
                        $8,400
                        $7,920
                      Renegotiate
                      for (7)
                        $3,600
                          $600
                       $20,^50***
$32,500
$19,000
$20,000
$15,000
$10,000
$21,000
 $1,000
 $1,000
 $1,000
 $3,000

 $4,900
 $6,600
 $4,600
                                                                 $192,670
Cost of labor provided by AEC
0.3 man years contributed by State of Colorado
Includes $10,000 for readout of 1000 badges and $10,200 for Colorado  Contract
               -. j t     —  •**£••       ..  J* t ti-\
                                  C-215

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PROPOSED PROGRAM
Uranium Mining
     The proposed program consists of EPA encouragement for the
publication by DOI of exposure standards for underground uranium miners;
or, alternatively, assurance of the implementation by USBM (DOI) of
EPA guidance in this area.
Uranium Mill Tailings
     The EPA should provide model regulations to the States to encourage
their legislating against the uncontrolled use of uranium mill tailings
in construction.  A study should be initiated to determine the adequacy
of control of mill effluents and tailings by the AEG or by Agreement
States.  Research projects to determine the biological consequences of
exposure to the radiation associated with miii tailings, aa v/ell a^
attempts to develop methods of treating tailings to minimize such exposure,
including the determination of the optimum "disposal" method, should be
conducted.
     The recommended proposed program is essentially identical with the
optimum program.  Due to the relatively low priority assigned this problem
area, however, the time frame under which the activity is conducted may
vary from optimum conditions, primarily due to minimal involvement of
EPA resources compared to other problem areas.  These resource requirements
will be fully developed at a later date.
Milestone Chart
     The milestone chart for the Proposed Program is shown in Figure
C-?0.
                                 C-216

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 PAGE NOT
AVAILABLE
DIGITALLY

-------
Figure C-30
     C-217

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COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS




     There should be negligible difference in impact of the proposed




program compared Co the optimum, with the possible exception of the




time frame involved.






MEASURES OF GOAL ATTAINMENT




Uranium Mining




     G  Determination of whether or not miner exposure is kept below




        the four WLM per year standard, by assessing the personnel




        monitoring equipment and monitoring programs for adequacy.




     3  Determination of the philosophy involved in the enforcement




        of the four WLM per year standard by USBM (DOI).




      G Categorization of the actual causes for mine closures in the




        western states involved, with particular attention to mines




        allegedly closed solely due to the implementation of the




        exposure standard.




Uranium Hill Tailin.es




     ©  Determination of whether or not Agreement States or the AEC




        have adequate regulations to control uranium mill effluent




        concentrations of radioactivity and to control the use of mill




        tailings; determination of whether or not these regulations are




        being enforced.




     G  Determination of a method to determine the  radon concentration




        in a short  period of time for homes where uranium  tailings  have




        been used for construction purposes.






                                  C-217A

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G   Development of  a method  or methods to stabilize tailings piles




    to minimise or  eliminate the  potential hazard from the associated




    radon daughter  emanations,




 e  Study will be made of the existing legislation  to determine if




   there are gaps  im the lavs  for control  of uranium mill  tailings.




   From this study a determination will  be made  if new State or




   Federal legislation is necessary-.
                             C-21.71

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                    RADIOFREQUENCY AND MICROWAVE



PROBLEM DESCRIPTION


Introduction


     The pollution of the environment by nonionizing electromagnetic


radiation is rapidly increasing.  There is concern about two types of


exposure, the exposure of the entire population to low levels which


result from the superposition of the fields from multiple sources such


as broadcast and communications systems and the exposure of smaller


groups to potentially higher levels from sources such as radar, micro-


wave ovens, medical diathermy devices, and Industrail heating equipment.


The concern arises because the existence and importance of nonthermal


effects at low levels are uncertain and the criteria for setting an


acceptable level of exposure, either for thermal insult or interference


effects, have not been defined for the population at large.  Ambient


levels already exist which are in the range of uncertainty for the onset

                                       2
of nonthermal effects (10 microwatts/cm ) and which do interfere with


health related devices such as cardian 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.  A careful determination of current


environmental levels, their rate of growth, and a knowledgeable evaluation


of low level effects are needed to assess the present and future impact


of electromagnetic radiation on health and the environment.


Component Problems


     Since radiation effects depend upon the wavelength, or equivalently


the frequency of the radiation, it is convenient to consider the health



                                 C-216

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and environmental problems associated with nonionizing electromagnetic




radiation as three component problem areas which are defined by wave-




length or frequency, namely, microwave, radiofrequency, and extremely




low frequency radiation.   In addition, consideration must be given to




the low-level, so called nonthermal effects, which may occur at all




frequencies.




     Microwave



     Microwaves are very high frequency radiation with wavelengths




between 10 meters and 1 millimeter (30 MHz - 300 GHz).  The principal




applications are in the area of communications, including FM broadcast,




television, microwave point-to-point, and satellite communication; radar




systems; and heat treatment processes including medical diathermy,




industrial drying, and home and commercial food preparation.  Most of




the concern over direct health effects, especially thermal effects, is




focused on the microwave frequency range.  Current occupational exposure




standards apply to the 10 MHz to 100 GHz frequency range.  Other effects




include indirect effects on health through interference with health




related devices such as cardiac pacemakers, hearing aids, and monitoring




equipment in hospitals.  Consideration must also be given to the inad-




vertent detonation of ordinance and ignition of aircraft fuels as




well as interference with communications and TV and FM reception.




     Radiofrequency




     Radlofrequency radiation covers the wavelength region from 10,000




meters to 10 meters (30 KHz - 30 MHz) .  The principal application is for




communications including AM standard broadcast and amateur radio.  Other
                                  C-219

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applications include radionavigation, radiotelephone and some medical




diathermy.  Apart from nonthenna1 effects, the principal problem in




this frequency range is interference with health related devices and




communications.  There are no standards or guidelines in the U.S. for




permissible exposure of the general public or occupationally exposed




groups for frequencies below 10 MHz.




     Extremely Low Frequency




     Wavelengths from direct current up to 10,000 meters (0 - 30 KHz)




are termed extremely low frequency (ELF).  The principal application is



for power transmission at 60 Hz.  Some military communications operate




in this frequency range.  Of particular note is the ELF communications




system termed Sanguine, because of its high power and requirement for




burying an extensive antenna array (100 miles) in a location accessible




to the public.  The principal problem in this frequency range is the




induction of voltages in long conductors such as telephone lines, fences,




and pipelines, and the corresponding problems of electrical shock and




interference.




     Thermal Versus Nonthermal Riological Effects




     Two types of biological effects are distinguished, that due to tissue




heating which is called thermal and that due to some other mechanism




which is called nonthermal.  Exposure intensities high enough and of




duration long enough to generate heat can cause adverse health effects.




In addition to physiologic heat stress, cataract induction, and impaired




testicular function are thought to be important effects.  Permissible




levels of exposure for occupational activities in the U.S., both civilian
                               C-220

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and military, are set solely on the basis of heat generation.  Studies




of effects conducted in the USSR and some Eastern European countries




have been oriented tovard effects on, or mediated by the central nervous




system, and the overall conclusion arrived at through such studies is




that biological systems are more sensitive to central nervous system




effects than to direct thermal effects.  Many other nonthermal effects




have been reported.  There is considerable controversy concerning these




low-level nonthermal effects and whether they can be considered hazardous.




However, in the USSR these effects are given serious weight and the guide-




lines for permissible occupational exposure are 100 to 1000 times less




than those used in the U.S. depending on the exposure conditions.




     In the U.S., guidelines for permissible exposure of the general




public in nonoccupational situations have not been developed.  Some




argue that the current occupational standard could be used.  However,




exposure to electromagnetic radiation is but one of several sources of




heat input into the body.   Body temperature depends in part on sources--




of heat input such as electromagnetic radiation, physical labor, and




high ambient temperature and on heat dissipation capability as affected




by clothing, humidity, state of health, etc.   In occupational situations




it is presumed that the ambient environment can be controlled or the




exposure level reduced to compensate for additional sources of heat.




This is not the case for nonoccupational situations, and if a guideline




for the public at large is set on the basis of thermal insult, careful




consideration must be given to determining the characteristics of the




population that are most sensitive to heat stress.
                                C-221

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     Serious questions can be raised concerning the philosophy of using




a thermal basis for setting population exposure standards for nonionizing




electromagnetic radiation.  First, there is the possibility that low-level




nonthermal effects have a real impact on health.  Second, interference




with electronic devices which are important to health or the quality of




the environment occurs at levels below those required to heat tissue.




The compatibility of the electromagnetic environment with other sources




and useful devices must be considered in arriving at acceptable levels.




Background



     The biological effects of nonionizing electromagentic radiation




have been studied since their discovery by Hertz in 1888.  During the




period 1930-1940, attention was focused on molecular and chemical effects




and effects on elemental biological systems.  After World War II, the



emphasis in the U.S. was placed on studying whole body irradiation effects




in mammals and man because of exposure of military personnel to levels




intense enough to cause detectable heating of the skin.



     With the proliferation of applications of modern technology to




radar, television, and communications systems, the entire population of




the U.S. is exposed to radiation from these sources at power densities




well below thermal levels.  Because of the lack of definitive scientific




data on the genetic, clinical, physiological, and behavioral effects




at low levels of exposure, a coordinated governmental program for control



of electromagnetic pollution of the environment recommended by the




Electromagnetic Radiation Management Advisory Committee, ERMAC, has been




accepted by the Director of Telecommunications Policy and endorsed by
                                 C-222

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the various governmental agencies concerned.  The recommended program




is estimated to cost $63 million for FY 1974-78.  Spending for current




Federal government programs in this area approximates $4 million/year,




most of which is by DOD, EPA, and DHEW.  In addition to research on




biological effects, the ERMAC program notes the necessity for surveys




of power density levels in urban areas, airports, and military install-




ations to obtain an estimate of the population at risk.




Scope




     Present




     The increase in the number of radiofrequency and microwave sources




since 1940, has been phenomenal and it is generally accepted that environ-



mental levels are rapidly increasing.  Only limited information is avail-




able on actual environmental levels where sources and population are




concentrated.  Exclusive of Federal Government systems, there are over




six million transmitting devices authorized by the Federal Communications




Commission, including in 1971, 892 TV stations and 6,976 broadcast




stations.  There are over 71,000 microwave relay towers and 2,800 fixed




radar sources in the U.S.  As an example of congestion in urban areas,




there are 276 unclassified sources within a 50-mile radius of Washington,




D.C. having a transmitter power equal to or greater than one kilowatt.



     Future




     The number of radiofrequency and microwave sources is estimated to




increase 15% each year.  This rate of growth may increase with new




applications and advances in technology.  Cheaper microwave sources are




becoming available which will increase the use of frequencies above 10 GHz
                                C-223

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for communications.  High power microwave systems have been proposed




for use in agriculture as a substitute for herbicides and for 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 also increase.  Radars are being installed on




some small boats used for recreation and the number will increase as




prices are reduced.  Microwave power transmission of converted solar




energy from satellites to large antennas on the Earth's surface has been




proposed as a significant electrical energy source for the year 2000.






LEGISLATIVE STATUS




     At the present time, there is no legislative_authority for the




specific control of nonionizing electromagnetic radiation pollution of




the environment.  However, as a pollutant, nonionizing radiation comes




under the broad authority of EPA to protect the environment.  In




Reorganization Flan NO. 3 of 1970, EPA is directed to "...by itself




and together with other agencies, monitor the condition of the environ-




ment-biological as well as physical" and "... in concert with the States -




to set and enforce standards for air and water quality and for individual




pollutants."  Leverage to control environmental levels can be exerted




through the National Environmental Policy Act and the required Environmental




Impact Statements.  Guidance to other Federal agencies can be provided




through the authority transferred from the Federal Radiation Council




to EPA, providing EPA can argue convincingly that all radiation, not




just ionizing radiation, is within the FRC authority.




     Civilian broadcast sources are controlled by the FCC but the health




effects of high powered sources are not directly considered in frequency





                               C-224

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 allocation or in the siting of transmitters.  Frequency  assignments for




 government sources are made by the Office of Telecommunications Policy




 based on recommendations of the Interdepartment Radio Advisory Committee




 (IRAC).  The health and environmental effects of government sources




 are given indirect consideration through the Side Effects Working Group




 of IRAC.  This working group is also serving as the interagency coordin-




 ating point for the program recommended by the Electromagnetic Radiation



 Management Advisory Council to OTP.




     The Food and Drug Adminsitration has authority to set performance




 standards for consumer products and has done so for microwave ovens.




 Occupational exposures are controlled by the Department  of Labor using




 a national consensus standard based on the recommendations of the




 American National Standards Institute.  The military services use similar




 guidelines to control occupational exposure.






 COORDINATION




 Interagency




     The Electromagnetic Radiation Management Advisory Council (ERMAC)




 has the responsibility to adivse and recommend to the Executive Office




 of the President through the Director of Telecommunications Policy (DTP)




 on measures to investigate side effects of radiation which arise from




 telecommunications activities to include protection of the general health.




The ERMAC first  met on March 27, 1969, and recognized the problems of




possible health  and ecological hazards of microwave and radiofrequency




radiation exposure.  The Council has recommended a five-year, 63 million
                                 C-225

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dollar program to assist DTP in coordinating the research programs of




the participating federal agencies to accomplish program objectives




and avoid unwarranted duplication.  EPA has two observers on ERMAC and




two representatives on the Side Effects Working Group of the Inter-




department Radio Advisory Committee, the group selected by the Office




of Telecommunications Policy (OTP) to coordinate the ERMAC program.




     Department of Health, Education, and Welfare (DHEW) is charged by




Public Law 90-602, Radiation Control for Health and Safety Act of




1968, with the protection of public health and safety from the dangers




of electronic product radiation.  The control is accomplished through




the issuance of product performance standards by the Bureau of Radio-




logical Health.  The National Institutes of Occupational Safety and




Health evaluates occupational exposure situations and the National




Institutes of Environmental Health Sciences and the Bureau of Radio-




logical Health support biological effects studies.  Direct liaison has




been established between the Office of Radiation Programs, EPA, and the




Bureau of Radiological Health, FDA, in the area of lasers and other




electromagnetic radiation.




     Department of Defense (DOD) activities of the several military




departments with regard to research on health and environmental aspects




of electromagnetic radiation are coordinated by the Director of Research




and Engineering (DDR&E).  Each of the component departments, Army, Navy,




and Air Force, conducts research on frequencies and devices of particular




interest to that service and conducts epidemiological surveys and hazard




assessments for its own personnel and its own environmental situations.
                                C-226

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In addition to OTP coordination, EPA is represented on the Navy's




Biological and Ecological Subcommittee for Project Sanguine and has




an interagency agreement with the Electromagnetic Compatibility Analysis




Center for data and analysis on environmental levels.




     The Department of Commerce offers the services of the National




Bureau of Standards (NBS) and the Institute of Telecommunications




Sciences (ITS) at Washington, D.C. and Boulder, Colorado for guidance




in instrumentation, dosimetric methodologies and primary standardization




of measurement devices.  Coordination with EPA programs is through OTP




and informal staff contacts.




     National Science Foundation (NSF) will make available to the general




reserrch community and particularly to the academic community funds to




elucidate basic mechanisms involved in the interaction of electromagnetic




radiation with biological systems.  Long-range fundamental studies will




be particularly encouraged.  Coordination with EPA programs is through




OTP.  In addition, EPA staff serve as reviewers for research proposals




to NSF on nonionizing electromagnetic effects.




     Federal Communications Commission (FCC) has close contact with and




detailed knowledge of non-government radiation sources which they license.




Their survey and monitoring activities of existing and proposed non-




government communications devices and systems will provide valuable data




on radiation levels.  Principal coordination with EPA is through OTP.




EPA staff also serve on the Radio Technical Commission for Marine Services




Special Committee on Ships Radar which is supported by the FCC.
                                C-227

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     Federal Aviation Administration (FAA)  has primary responsibility




for flight crew health and performance.   Data from the exposure of




airport personnel and flight crews to airport electromagnetic radiation




environments should be applicable to a program for the protection of




ailine and airport personnel as well as to  airline passengers and the




general public.  Principal coordination with EPA programs is through




DTP.



     United States Information Agency (USIA) measures and monitors




radiation intensities for USIA domestic and overseas transmission.




Principal coordination with EPA programs is through OTP.




     The Department of Agriculture (USDA) is concerned with investi-




gating the effects of electromagnetic radiation on crop growth and




development and related ecological aspects.  Principal coordination




with EPA programs is through OTP.



     National Aeronautics and Space Administration (NASA) is responsible




for surveying the electromagnetic environment of launch areas, space-




craft, and tracking radar under their control.  Principal coordination




with EPA programs is through OTP.




     Central Intelligence Agency (CIA) surveys and monitors programs




of foreign countries dealing with health and environmental aspects of




electromagnetic radiation.  Principal coordination with EPA programs




is through OTP.



     Department of Labor (DOL) has responsibility for administration




and enforcement of the Williams-Steiger Occupational Safety and Health




Act of 1970  (PL 91-596) through the Secretary of Labor and the Occupa-




tional Safety and Health Review Board, a quasijudicial board appointed






                                 C-228

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by the President.  Research and related functions are vested in the




Secretary of DHEW.  Principal coordination with EPA programs is




through OTP.



States




     EPA is directed in Reorganization Flan No. 3 to "be able — in




concert with the States — to set and enforce standards for air and



water quality and for individual pollutants."






ALTERNATIVE APPROACHES




     The nonionizing electromagnetic radiation program goals will be




accomplished by implementing four main program elements within ORP:




     •  Determination of the status of the environment through




        measurement of environmental levels and recognition of poten-




        tially adverse situations and sources of radiation.




     •  Evaluation of effects due to nonionizing electromagnetic




        radiation.




     •  Development of guidelines for acceptable environmental




        levels of nonionizing radiation.




     e  Development of a program for control of environmental




        pollution due to electromagnetic radiation.




     Consideration of alternative approaches to the program is based




on possible alternatives to the program components associated with



the four main program elements.




Determination of the Status of the Environment
                               C-229

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     Recommended Approach




     Continue to develop the capabilities, resources, and facilities




to measure environmental electromagnetic radiation (including data




reduction and analytical techniques).




     First Alternative Approach




     Do not implement a measurement program, but attempt to predict,




by mathematical modeling, environmental EM fields using knowledge




of known sources and their characteristics.




     Impact.  Though fields from a single well characterized source




may be predicted mathematically, the general EM radiation environment




cannot be described in this manner.  All significantly contributing




sources and their spatial distributions are not catalogued.  The




required characteristics of catalogued sources are not completely




specified.  The physical geometry at the specified location cannot




easily be described mathematically, if known.




     There will be no emergency response capability and the evaluation




of potentially adverse situations will be impeded.  There will be a




limited capability to provide technical assistance to local and state




agencies.  Requests for assistance will be directed to Federal




agencies with measurement capability.   Evaluation of EIS's, with




respect to effects on the existing EM environmental levels, will be




inaccurate if not impossible.




     Second Alternative Approach




     Implement an environmental EM measurement program by contracting




with private organizations and/or other Federal agencies, with RF and




microwave capabilities and facilities, to perform measurements.






                               C-230

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     Impact.  The contractor will still need to develop techniques




and instrumentation systems applicable to environmental radiation




measurements.  Organizations now possessing RF and microwave capabil-




ities have developed these capabilities with emphasis on communication




and radar applications, where directionality, high antenna gains, and




narrow frequency band characteristics are important.  Environmental




measurements require capabilities involving broad frequency response




and omnidirectional antenna characteristics, and will also include




instrumentation systems having good frequency and time resoltuion




properties.  Development and specification of field measurement




procedures for environmental measurements will need to be defined by




ORP to ensure uniformity in procedure and the quality of measurements




and this is best accomplished through direct experience.  Dependence




on other organizations or agencies will result in reduced ORP compe-




tence and could affect program implementation, ability to evaluate




instrumentation development, application, and quality of data.  Costs




will be high because of private industry overhead.  Emergency response




capacility will be limited with respect to immediate response capability




and proper measurement procedures.  Development of capabilities in




other Federal agencies will essentially transfer ORP responsibility




to that agency.




Evaluation of Electromagnetic Radiation Effects




     Recommended Approach




     Development of an information inventory and synthesis of knowledge.
                               C-231

-------
     Alternative Approach



     There is no alternative to the development of an information




inventory.  This program element must be implemented to provide a




basis for the interpretation of the environmental impact of existing




and projected levels of radiation, evaluation of the impact of




existing and new technology, and identification of gaps in knowledge




to specify the research required to develop guidelines and standards




required for the protection of health and the environment.




Development of Guidelines




     Recommended Approach



     Guidelines for permissible or acceptable environmental levels




must be established to provide a basis for evalutating the total




problem of nonionizing radiation in the environment.  This requires




a knowledge of current levels, the rate of growth of environmental




levels and an evaluation of the research, current and future, on




biological, environmental and interference effects.  The status of




knowledge in this radiation effects area is preliminary and effects




are not yet well defined.  Development of guidelines will proceed




in steps over an undefined period of time as the pertinent information




is generated.



     First Alternative Approach




     No development of guidelines and standards.




     Impact.  There will be no control over electromagnetic radiation




in the environment, the radiation sources, and the impact of  this




radiation on the health and quality of life of the general public




and the responsibility to succeeding generations.
                                C-232

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     Second Alternative Approach




     Accept the USSR standards which exist now and are conservative




as guidelines for acceptable exposure.




     Impact.  The full impact of such a restrictive guideline cannot




be determined at the present time.   However, environmental levels




certainly exceed the USSR standards in some areas and the useful




applications of nonionizing radiation could be severely curtailed




with a yet as undetermined benefit.




Development of Control Program for  EM Radiation Pollution




     Recommended Approach



     Development of a program to control and reduce (where necessary)




environmental EM radiation pollution to include siting and operation




requirements for existing and proposed sources.  This will require




a determination of the best method  of control.  Possible methods



include (1) using influence through the National Environmental Policy




Act, Federal Radiation Council responsibilities, and guidance to




states to maintain levels below those guideline levels recommended




by EPA and (2) establishing radiation pollution.




     Alternative Approach




     To fulfill responsibilities under the National Environmental




Policy Act, there is no alternative to developing a control at least




as it applies to evaluating Environmental Impact Statements.  The




alternatives for direct control need to be determined after a basis




for acceptable levels is established and compared to existing levels




and rates of growth.
                               C-233

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OPTIMUM PROGRAM




Introduction




     The primary objectives of the nonionizing electromagnetic radiation




program are:  1) to identify the effects of electromagnetic radiation




and their Impact on the health of the general population and the




environment, and 2) to develop and implement controls to ensure that




the state of the electromagnetic radiation environment is not detrimen-




tal to health.




     These goals will be accomplished by implementing four program




elements, i.e.,




     •  determination of the status of the environment, monitoring




        and problem source identification




     •  determination and evaluation of effects due to electromag-




        netic radiation




     e  development of guidelines for acceptable environmental levels




        of nonionizing electromagnetic radiation




     •  development of a program for control of pollution due to




        electromagnetic radiation.




     The program also includes other elements which require considerable




effort, but are associated with the more immediate aspects of the problem




and Implementation of the program.  These additional program elements




consist of:




     •  development of an emergency response capability




     •  responses to requests for technical assistance,




     •  review of Environmental Impact Statements
                               C-234

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     •  identification of needed research programs in concert with


        the Office of Research and Monitoring, EPA


     e  development of a field support capability


     •  preparation and publication of the required technical reports.

                            ^
     In addition, certain auxiliary activities are essential to provide


the support necessary to the development and success of the proposed


program.  These include the development of an information inventory,


evaluation of the past and current state of research pertinent to the


problems involved, development of the required analytical procedures,


a liaison activity which ensures that ORP has developed the necessary


working relationships with other organizations, both within and outside


of the Federal government, and continuing program development which


will anticipate program needs on a long- and short-term basis to ensure


that the efforts and resources required are not lacking.


     The program elements and auxiliary activities are generally


described in the text of this paper prior to specification of program


needs.  Figure C-32, Elements of ORP FY 1973 and FY 1974 Radio frequency


and Microwave Program, illustrates the relationships between the major


program elements.


     It is considered imperative that ORP have the capabilities required


to plan and implement all aspects of the program proposed.  Fulfillment


of the responsibilities and goals of the program is dependent upon the


capabilities which exist within ORP.  Dependence upon external sources


for basic technical knowledge and assistance could result in a program


lacking the capability for long-range planning, improper definition
                                 C-235

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           Measure Existing
         Environmental Levels
        Interpret  Environmental
          Impact on Basis  of
          Existing Knowledge
to
                                 Establish  Information
                                      Inventories
                                                 Identify Gaps
Write Interim
 Guidelines
                                                                                                1
  Determine Rates
   of Increase in
Environmental Levels
                                                                           Existing Technology
                                                                                 Anticipate New
                                                  Support for
                                               Required Research
                                                                               1
                                                                Reexamine Interim
                                                                   Guidelines
                      Standards?
        Provide
         Emergency Response
        Technical Assistance
             Review EIS
                                                         FIGURE C-32

                                        ELEMENTS OF ORP FY  1973 & FY 1974 RADIOFREQUENCY
                                                    AND MICROWAVE PROGRAM

-------
and management of technical programs and program elements, inefficient




discharge of technical and program responsibilities, and intolerable




time delays in responding to future demands'-and situations requiring




immediate attention.




     Significant consideration and effort has been given to the problems




associated with electromagnetic radiation as an environmental pollutant




and the approaches to solution of these problems.  The program can be




immediately initiated as is indicated by the time schedule contained




within the milestone charts of the Optimum Program, Figure C-33.




     The environmental nonionizing electromagnetic radiation program




efforts will develop basic techniques and information specifically




required before it is possible to recognize, control, and correct




undesirable environmental EM radiation pollution problems.  Much of




the-basic information and measurement techniques required for an




environmental nonionizing radiation program have not yet been developed




and applied, as opposed to the case of environmental nuclear radiation




sources for which standard measurement techniques exist, effects of




given intensities and energies of specific types of radiation are




relatively well established, and standards have been written and




enacted into law.  Therefore, this program, at least in its initial




development phase, can be considered to be one of technical development,




dependent upon research which is both basic and applied in nature.  This




technical program has been developed with the definition of program




elements such that its goals will be achieved in what appears to be




the most direct manner.  In addition, program direction and development
                                C-237

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appear to be achieved most efficiently through the definition of program




elements in this manner.




Determination of the Status of the Environment




     The determination of the status of the environment requires the




quantitative measurement of those characteristics of the electromag-




netic radiation present in- the environment which are significant in




affecting human health and the environment in which we live.  The




evaluation of the information obtained will be used to characterize




the environment by allowing potentially adverse situations to be




identified and permitting an analysis which recognizes environmental




changes and trends which can be used to predict the future environment.




Evaluation of the environmental impact of existing ambient radiation




is essential, and is required in the development and implementation of




guidelines and standards.




     The means to acquiring the necessary environmental information




involves the adaptation of existing technology to our specific purpose.




The Office of Radiation Programs will in concert with the Office of




Research and Monitoring design, develop, and apply the instrumentation




and data acquisition systems, and the field measurement and analytical




procedures required to quantitatively determine the pertinent environ-




mental EM field characteristics and evaluate the environmental impact.




The development and acquisition of measurement and data handling




capabilities and determination of systems application procedures




requires that a support facility be establsihed.   Sampling of the EM




environment will provide realistic conditions for development of the




required systems.   In addition, simulation of realistic signals for
                                2 39'

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preliminary evaluation of system operation vill also be an essential




feature of system development.




     Measurements will be made so as to determine EM radiation charac-




teristics over extended areas where the existing fields may be due




to the cumulative effect of several individual sources of EM radiation.




In addition, fields due to specific single sources will be investigated, •




possibly requiring a field study of the facility or source involved




in order to develop and validate models so that fields can be estimated.




     The first year of program implementation will allow for a limited




number of field studies due to validate models.  However, as the program




develops further, the selection of sites and sources for measurement




will be carefully made to ensure that the greatest benefit be gained




in defining and evaluating the environment.  The information now




available in existing data banks will be extremely valuable in the




selection process.




     Further program development will determine the need for facilities




in existing EPA field laboratories.




     The implementation of this program element may require establish-




ment of authority to perform environmental measurements, however, the




establishment of relationships with existing Federal, State, and local




agencies should be a valuable asset to the measurement program.



Determination and Evaluation of Effects




     The determination of the impact on health and the environment of




existing ambient electromagnetic radiation and the anticipated application




of developing technology depends upon a synthesis of current knowledge




and the continued generation of information from current and future







                               0-24G

-------
research activity.  The relationships between exposure to EM radiation




and effects is determined through a continual evalaution of available




information in which a correlation is made relating specific effects




to field Intensity and/or power density, frequency, and modulation




characteristics.  Effects, classified as biological, interference, and




environmental in nature, must be identified because of the potential




impact on the present and future quality of life of individuals and




society as a whole.  Immediate and near future impact may be most




obvious, but the identification of less intense, long-term effects which




could influence the lives of future generations are no less important.




Awareness of developing technology and anticipation of future applications




is essential in preparing an effective program which attempts to




determine environmental Impact and provides for long-range planning




which is essential in maintaining and developing the capabilities and




resources needed.  The Office of Radiation Programs in concert with



the Office of Research adn Monitoring (ORM) will identify the research




required to identify hazardous effects.  Intramural and extramural support




for the necessary biological effects research will be implemented



through OEM.




Development of Guidelines




     Guidelines for acceptable or permissible environmental levels




are essential for control of EM environmental pollution and for




correction of potentially adverse and hazardous situations.  The




determination of guidelines is based on cause and effect relation-




ships, particularly in the areas of biological effects, and inter-




ference with the operation of devices and systems in fulfilling the






                             C-241-

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purposes for which they are intended.  The necessity for standards




and the decision concerning when they must be established depends




upon existing and anticipated environmental EM radiation levels and




the degree of the impact on health and the environment.  Continuing




development of information through the information inventory and




research is expected to provide the basis to determine the need for




standards.




Emergency Response Capability




     The capability to respond quickly and competently to emergency




"short notice" situations will be developed.  This necessitates rapid




development of portable and mobile instrumentation systems, establish-




ing the authority and means to test human subjects, authority to




perform measurements wherever and whenever required in emergency




situations, and close liaison with other agencies, particularly State




health departments, DOD, and Regional Offices to establish emergency




procedures and facilitate acquisition of additional equipment if




required.  Determination of impact and decisions with regard to




required corrective action requires establishment of guidelines and




authority to impose whatever corrective measures are required.




Response to Requests for Technical Assistance




     The program includes provision for assistance in the form of




information, technical guidance and direction, equipment loans,




training, and action to States and Regional Offices upon request.




Review of Environmental Impact Statements




     The review of EIS's where effects of EM radiation is concerned




will be a continuing effort.  The demands cannot yet be anticipated,






                             C-242

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but will depend on the number of EIS's and the specific characteristic




of the sources of facilities involved.  The basis for evaluation exists




in the other primary program elements, i.e., determination of environ-




mental status, evaluation of effects, and guidelines and standards.




Criteria for evaluation of EIS's will be developed in a format which




will permit efficient evaluation.  Recommendations and conclusions




will be provided.  Extensive use will be made of the information




inventory, and existing data banks in the Department of Defense and



Office of Telecommunications.




Research




     Research activities in the U.S. will be evaluated with respect




to their potential for providing cause-effect information where gaps



in information exist.  Recommendations for research needed by the program




will be developed for implementation by the Office of Research and




Monitoring and coordinated with other interested government agencies



through OTP.




Field Support Facility Development




     Once the basic development in techniques, systems, and procedures




has been completed and a full scale program of determination of the




status of the environment is outlined, the need for mission support




facilities in existing EPA laboratories will be determined.




     This determination will include the requirements for technical




capabilities, specification of systems and measurement procedures, and




maintenance and calibration of instrumentation and equipment.




Technical Publications




     Publication of technical reports and scientific articles is one




means of providing technical support and allows the best use to be made





                                C-243

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of the acquired data, information,  and analysis.  Further, the goal of




publishing articles in well recognized scientific Journals will assist




the Office of Radiation Programs to develop its capabilities, to



develop and enhance its technical reputation by generating respect in




the scientific community, and to facilitate the process of attaining




its program objectives.



Program for Control of Environmental Electromagnetic Radiation Pollution




     A program will be developed to control and reduce (where necessary)




environmental EM radiation pollution.  The program should ensure that




proposed sources meet EPA requirements prior to siting or operation,




and be able to bring operating sources into compliance with guidelines




for acceptable or permissible exposure.  To be effective it may be




necessary for EPA to establish and enforce standards for environmental




levels of nonionizing radiation.



Information Inventory Development



     An information inventory is being developed which is directed




toward providing the necessary information inputs to all of the EM




radiation program elements.  It would supplement, certainly not




duplicate, certain information and data which is obtainable from




sources such as the Electromagnetic Compatibility Analysis Center and




the Office of Telecommunications.  The information (including classi-




fied information) contained in this inventory cannot be all inclusive,




but must be selectively chosen.



     The kinds of information to be included consist of:  nonionizing




radiation sources and categories of sources, location, source power,




frequency, pulse characteristics, antenna characteristics, facility





                               •6-244-

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operational characteristics, terrain description; environmental EM




radiation field characteristics; correlations of environmental EM




radiation with population distributions; field measurement data




generated; analytical results; and technical literature and reference




material concerning measurement techniques, EM instrumentation and




systems, data handling systems, biological effects, interference effects,




existing and developing technology, and biological, ecological, and




related EM radiation research.




Liaison Activity




     External Needs




     Legislative Needs.  Implementation of the ORP programs may require




establishment of EPA authority in order to fulfill certain program




responsibilities.  Possibilities for required legislation, in view of




the still undefined status of existing legislation, include establishing




authority to:  perform measurements and source inspections wherever




designated and, in the event of emergency situations, whenever necessary;




test humans if necessary due to emergency and unusual situations; permit




access to classified information regarding military EM sources and




facilities, enact into law EPA electromagnetic radiation standards;




and enforce standards and bring sources into compliance.




     Knowledge.  The Electromagnetic Radiation Analysis Branch nonionizing




radition program requires extensive use of existing knowledge in




developing the means and program to determine the status of the environ-




ment, in the evaluation of effects, and development of guidelines




and standards.  All program elements are dependent upon obtaining and
                                •6*245

-------
synthesizing the information required.  The development of the informa-


tion inventory is an essential supporting program activity.


     Research and Development Needs.  The generation of new information


relating to environmental effects, measurement techniques, and develop-


ment of guidelines and standards is dependent upon current and future


research.  Effects of RF and microwave radiations on biological systems


are not well defined and understood.  The USSR and some other Eastern


European countries have reported nonthermal effects which have to


some extent been qualitatively supportec by the limited research


done in the U.S.  On the basis of these effects, standards have been

                                       2
adopted in the USSR which include p-W/cm  thresholds.


     Additional knowledge is required to clearly define and understand


the relationships between electromagnetic radiation and the associated


nonthermal effects.  The research required to provide a basis for


acceptable environmental levels will be identified.  The required


research can then be implemented through the Office of Research and


Monitoring and in coordination with other agencies through the Office


of Telecommunications ERMAC program.


     Enforcement and Control Requirements


     A program will be developed to enforce standards, once they are


enacted into law, to control and reduce (where necessary) environmental


EM radiation pollution.  The program will ensure that proposed sources


meet EPA requirements prior to siting or operation, and will bring


operating sources into compliance with standards, implementing ERAB re-


commendations if necessary.
                                C-246

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     Interagency Implementation.   Coordination of the nonionizing

radiation activities is through the Electromagnetic Radiation Manage-

ment Advisory Council.  The EKMAC was formed in 1968 to advise the

Director, Office of Telecommunications Policy, and to make recommenda-

tions on potential side effects on the environment, biological and

physical, and the adequacy of control of electromagnetic radiation.

EPA has two observers on the EKMAC.

     An interagency working group on biological effects of nonionizing

electromagnetic radiation was recently formed to serve as an intra-

government coordination mechanism for the EKMAC program.  It has been

made a part of the Side Effects Working Group of the recently recon-

stituted Technical Subcommittee of the Interdepartment Radio Advisory

Committee.  This body is comprised of representatives designated by the

heads of agencies with a role in the ERMAC program.  The agencies are:

     Agriculture
     Atomic Energy Commission
     Central Intelligence Agency
     Commerce
     Defense (Director of the Division of Research and Evaluation,
        U.S. Army, U.S. Navy, U.S. Air Force)
     Transportation (Federal Aviation  Administration)
     EPA
     Federal Communications Commission
     Health, Education and Welfare
     Interior
     Labor
     NASA
     National Science Foundation
     Office of Telecommunications Policy
     U.S. Information Agency
     Veterans Administration

     Coordination will be continued through direct participation with

the interagency working group on biological effects of nonionizing

radiation.
                              C-247

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Internal Needs




     The primary objective of the program is to develop  the means




(staff, instrumentation, and procedure) to determine  the status of




the environment by performing measurements of ambient levels of EM




radiation in selected extended areas in the environment  and to con-




duct field studies of specific sources of nonionizing electromagnetic




radaation; to make determinations and evalautions of  effects; to develop




guidelines and standards; and to control environmental pollution due




to electromagnetic radiation by enactment and implementation of




standards.  Manpower and cost requirements for the Optimum Program




are shown in Table C-17.




     The measurement process consists of the quantitative determination




of environmental electromagnetic radiation field characteristics such




as:  field intensity and/or power density, pulsed characteristics,




and variation with time over a given frequency range  (DC to 18 GHz).




These determinations will be made within defined limt^Ls regarding




magnitude, polarization, resolution (with regard to frequency,




intensity, time), and near and far field characteristics.  The infor-




mation acquired must be evaluated and pertinent conclusions reached



where possible.




     This first year of program implementation will allow for only




a limited number of field studies due to the need for development and




acquisition of capabilities and determination of system application




procedures.  However, the selection of sites and sources will be




carefully made to ensure that the greatest advantage be gained in this




development phase.
                               C-248

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                               TABLE C-17

                     REQUIREMENTS - OPTIMUM PROGRAM
PERSONNEL REQUIREMENTS

     The requirements for personnel are based upon a two-year estimate
of needs and costs.   The program provides for inclusion of personnel at
the supporting environmental research laboratories.
(1)  Biophysicist
     or Physicist:

(1)  Physicist:
(1)  Engineering
     Physicist:
(1)  Biophysicist:
(1)  Secretary:

(1)  Engineering
     Physicist

(2)  Physicist or
     Electrical
     Engineer:
(2)
Electrical
Engineer:
(2)  Physicists or
     Biophysicists:
(3)  Electronic and
     Instrumentation
     Technicians:

(1)  Computer Systems
     Specialist:
                     Program direction,
                     evaluation

                     System design & develop-
                     ment, effects evaluation,
                     analysis, measurement
                     protocol
                          (24 mos) GS-14
                                                    (24 mos) GS-12, 13
                     Instrumentation support
                     facility, system design
                     and development, analysis (24 mos) GS-12, 13

                     Effects evaluation, infor-
                     mation inventory, Environ-
                     mental Impact Statements,
                     guidelines and standards  (22 mos) GS-12, 13
Data analysis and data
acquisition systems

Systems development,
development of field
laboratory capability
for EERL, WERL

Field studies and
data analysis

Analysis and Environ-
mental Impact State-
ments

Instrumentation support
facility, field studies
                     Computer systems and
                     software
(24 mos) GS-6, 7


(12 mos) GS-12




(12 mos) GS-12


(10 mos) GS-12



(12 mos) GS-12


(12 mos) GS-9



(12 mos) GS-12, 13
                                C-249

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                            TABLE C-17 (Cont'd)


(1)  Secretary:                                     (12 mos) GS-6

(2)  Electrical           Field studies
     Engineers:           conducted from EEKL
                          and WERL                  (12 mos) GS-11, 12

(2)  Technicians:         EERL and WERL             (12 mos) GS-9

Salary Costs:  $382,800

INSTRUMENTATION SYSTEMS AND SUPPORT FACILITY REQUIREMENTS

Gross survey instrumentation                        $12,000
Field intensity measurement systems                  95,000
Spectrum analysis instrumentation
    (manual and computer controlled)                230,000
Support instrumentation and equipment               150,000
Antenna systems:  Acquisition, development
    calibration                                      50,000
Data acquisition systems                            100,000
Mobile units                                         80,000
Maintenance and calibration                          60,000

Total Costs:                                       $777,000

     The total systems costs include requirements for the Electromagnetic
Radiation Analysis Branch and the field studies support facilities at
EERL and WERL.

INTERAGENCY AGREEMENTS AND SERVICE CONTRACTS

     Interagency agreements and service contracts will provide support
for the information inventory and the analytical program requirements.

Computer use and software                          $100,000
Electromagnetic Compatibility Analysis
    Center Data Bank                                 80,000
Office of Telecommunications Data Bank               60,000
Walter Reed Data Bank                                15,000

Total Cost:                                        $255,000


PROGRAM SUPPORT

     Additional support includes purchases of  reference literature
and support for the information inventory, publication, travel and
transportation, and supplies.
                              C-250

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                            TABLE C-17 (Cont'd)
Information inventory needs
    (books, journals, literature surveys)          $ 5,000
Publication                                          9,000
Travel                                              20,000
Transportation                                      45,000
Supplies                                            30,000

Total Cost:                                       $109,000

TOTAL PROGRAM COST:  Pf 1973 and FY 1974

     The total program cost for the optimum program is summarized for
FY 1973 and FY 1974.

Personnel                                         $382,800
Instrumentation systems and support
    facility requirements                          777,000
Interagency agreements and service contracts       255,000
Program support                                    109,000

Total Optimum Program Cost:                     $1,523,800
                              C-251

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     Additional goals include:   development of the capability required




to respond to emergency (short  notice) situations; development of




requirements for existing laboratories such as the Eastern Environmental




Research Laboratory; preparation to respond with technical assistance




to requests made by other EPA offices, Federal, State, and local agencies;




review of Environmental Impact  Statements; and publication of field




study results and technical accomplishments through reports and articles.




     All of these goals will be accomplished through establishment




within the Office of Radiation  Programs of the following capabilities:




     •  program direction and development;




     •  design, development, acquisition, and application of instru-




        mentation and data handling systems;




     •  information inventory;




     •  analytical procedures and computer application capability; and




     •  liaison with external organizations.




     The needs can be generally described as being included in the




following categories:




     •  personnel;




     •  instrumentation systems and support facilities;




     •  interagency agreements  and service contracts for development




        of analytical support and the information inventory;




     •  program support for publication, travel, transportation,




        and general supplies.
                              C-252

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PROPOSED PROGRAM




External Needs




     The proposed nonionizing electromagnetic radiation program differs




from the optimum program only in the time schedule required  to accom-




plish the program elements.  The same program objectives are intended




for accomplishment, but over a longer period of time.  The Proposed




Program is shown in the Milestone Chart, Figure C-34.  All external




needs are the same as that for the Optimum Program.




Internal Needs




     The program is now in its initial stages of development.  The




internal needs of the program are determined through modification of




Optimum Program internal needs, on the basis of an extended  time




schedule.  Reductions in personnel requirements are made possible by




programming a less intensive effort in the field study program and




in the associated analytical studies required for determination of the




status of the environment.  In addition, development of the  measurement



capability in the field support laboratories will be delayed; the




training effort for personnel will be reduced; the instrumentation




supplied to support groups for FY 1974 will consist only of  gross




electromagnetic radiation survey meters with the additional  field




intensity measurement and spectrum analysis capability delayed until




FY 1975.  Manpower and cost requirements for the Proposed Program are



shown in Table C-18.






COMPARISON OF OPTIMUM AND PROPOSED PROGRAMS




     Proposed and optimum programs developed by the Electromagnetic




Radiation Analysis Branch for purposes of solution of the radio-





                               C-253

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                              TABLE C-18

                     REQUIREMENTS - PROPOSED PROGRAM
FY 1973 REQUIREMENTS

PERSONNEL REQUIREMENTS

(1)  Biophysicist
     or Physicist:

(1)  Physicist:
(1)  Engineering
     Physicist:
Program direction, evaluation    (12 mos) GS-14
(1)  Biophysicist




(1)  Secretary:

Total Salary Cost:    $89,000
System design and development,
effects evaluation, analysis,
measurement protocol

Instrumentation support facil-
ity, system design and devel-
opment, analysis

Effects evaluation, informa-
tion inventory, Environmental
Impact Statements, Guidelines
and Standards
(12 mos)  GS-12,  13



(12 mos)  GS-12,  13




(8 mos)  GS-12,  13

(12 mos)  GS-6,  7
INSTRUMENTATION SYSTEMS AND SUPPORT FACILITY REQUIREMENTS

Gross survey instrumentation                        $ 2,000
Spectrum analysis instrumentation
    (additions to existing systems)                   7,000
Support instrumentation and equipment                22,000
Antenna systems                                      10,000
Data Acquisition systems                             30,000
Mobile unit                                          15,000
Maintenance and calibration                           6,000

Total Cost                                          $92,000

INTERAGENCY AGREEMENTS AND SERVICE CONTRACTS

Computer use and software                           $ 8,000
Electromagnetic Compatibility Analysis Center        20,000

Total Cost                                          $28,000
                              C-255

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                            TABLE C-18 (Cont'd)
PROGRAM SUPPORT
Information inventory needs                         $ 2,000
Publication                                           2,000
Travel                                                4.°°°
Transportation                                        8,000
Supplies                                              5,000

Total Cost                                          $21,000

TOTAL PROPOSED PROGRAM COSTS:  FY 1973

Personnel                                           $89,000
Instrumentation Systems and Support Facility          92,000
Interagency Agreements and Service Contracts          28,000
Program Support                                       21,000

Total Cost                                          $230,000
                                C-256

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                             TABLE C-18  (Cont'd)
FY 1974 REQUIREMENTS

PERSONNEL REQUIREMENTS

(1)  Biophysicist
     or Physicist:

(1)  Physicist:
(1)  Engineering
     Physicist:
(1)  Biophysicist:
 (1) Secretary:

 (1)  Physicist or
     Electrical
     Engineer:
 (1)  Electrical
     Engineer:

 (2)  Physicist or
     Biophysicist:

 (1)  Computer System
     Specialist:

 (2)  Electronic and
     Instrumentation
     Technicians:

 (1)  Secretary:

 (2)  Electrical
     Engineers:

 (2)  Technicians:
Program direction, evaluation    (12 mos) GS-14
System design and development,
effects evaluation, analysis,
measurement protocol

Instrumentation support facil-
ity, system design and devel-
opment, analysis

Effects evaluation, informa-
tion inventory, Environmental
Impact Statements, guidelines
and standards
Systems development, data
analysis, development of field
laboratory capability for
EERL and WERL

Field studies and data
analysis

Effects analysis and Environ-
mental Impact Statements

Computer systems and software
Instrumentation support  and
field studies
From EERL and WERL

From EERL and WERL
(12 mos)  GS-12,  13



(12 mos)  GS-12,  13




(12 mos)  GS-12,  13

(12 mos)  GS-6, 7




(12 mos)  GS-12


(10 mos)  GS-12


(12 mos)  GS-12

(8 mos) GS-12, 13



(10 mos)  GS-9


(12 mos)  GS-6


(4 mos) GS-12

(4 mos) GS-9
Total Salary Cost:  $226,000
                                C-257

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                              TABLE C-18 (Cont'd)
INSTRUMENTATION SYSTEMS AND SUPPORT FACILITY REQUIREMENTS

Gross survey instrumentation                        $ 12,000
Field intensity measurement instrumentation           12,000
Spectrum analysis instrumentation
    computer controlled system                       135,000
Support instrumentation and equipment                 55,000
Antenna systems                                       25,000
Data acquisition systems                              20,000
Mobile unit                                           25,000
Maintenance and calibration                           29,000

Total cost                                          $313,000

INTERAGENCY AGREEMENTS AND SERVICE CONTRACTS

Computer use and software                           $ 40,000
Electromagnetic Compatibility Analysis Center         40,000
Office of Telecommunications                          40,000
Walter Reed data base                                 10,000

Total Cost                                          $130,000

PROGRAM SUPPORT

Information inventory needs                         $  3,000
Publication                                            5,000
Travel                                                12,000
Transportation                                        27,000
Supplies                                              15,000

Total Cost                                          $ 62,000

TOTAL PROPOSED PROGRAM COSTS:  FY 1974

Personnel                                           $226,000
Instrumentation Systems and Support Facility         313,000
Interagency Agreements and Service Contracts         130,000
Program Support                                       62,000

Total Cost                                          $731,000
                                C-258

-------
frequency - microwave problem area are presented in Table C-19.  All




major program elements are specifically designated.






MEASURES OF GOAL ATTAINMENT




     Because of the various effects of nonionizing electromagnetic




radiation are not well defined at this time, the use of any specific




or gross health effect as an indicator of program effectiveness is




not possible, at least initially.  Consequently, the radiofrequency-




microwave program must be evaluated differently as time goes on and as




more biological-effects information is obtained.  Initially, an




evaluation of the various program element achievements is reasonable




with, possible, later evaluation being done on the basis of actual




health effects.




     One possible method of measuring the program's effectiveness, on




other than a health effects basis, would involve the determination




of the general population exposure to RF and microwave energy.  This




could be accomplished by measuring environmental levels and applying




this information to population distribution data.  If, as a function




of time, over the first several years, no detectable increase in average




population exposure occurred, the program could be judged as, at




least, having held the status quo.



     A listing of the expected accomplishments and measures of these




goal attainments in terms of specific program elements follows.




Authorization to Monitor




     Immediate authorization to conduct general environmental monitoring




and perform specific source measurements must be obtained.  This
                              C-259

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                                                                        TABLE C-19

                                                      COMPARISON OF OETIHUM AND PROPOSED PROGRAMS
                                           Optimum Program
                                                             Proposed Program
                            Impact
            EnForcer.'cnr

            Develop  program for  enforce-
            ment of  guidelines and/or
            standards  to  control EM
            pollution  in  environment
                              Program to be in effect by
                              1/76, to:
                              (1) ensure proposed sources
                              meet requirements prior to
                              operation,
                              (2) bring operating sources
                              into compliance with stand1-
                              ards
Program to be in effect by
1/77 to ensure proposed
sources meet requirements
prior to operations
Operating sources will have
increased in number and power
enhancing adverse environ-
uental effects.  Pertains to
introduction of OTK Radar,
automotive control systems,
super power UHF-TV, etc.
n
Ni
o»
o
Le;islai.jvj Requirements

Authority .0 conduct meas-
urements \  :rrever ERAB
designa!.."   nd whenever
r.ccessai  tor emergency
siLuatic ti..

Authorii-,' -o test humans
                       i-.Jear  authori-
            zation  fjr Access to
            classif:cJ information
            regardi:.;;  E!i  sources

            EPA autl.ority to enforce
            standard;,  -ind bring sources
            into  cor p] lance

            Enactment  of  Standards into
            law
                                           Immediate Requirement
                                           Immediate Requirement
                              Immediate Requirement
                              Necessary  for  effective  and
                              immediate  implementation of
                              standards  by 6/75

                              Required by 12/75'  to  imple-
                              ment  standards and allow
Immediate Requirement
No later than 1/73
Immediate Requirement
necessary for effective
implementation of stand-
ards by 6/7$

Required by 12/76 to
implement standards
None
Deliy in responding to cur-
rently existing requests for
assistance and potential
emergency situation

Hone
llumber of sources that could
have been controlled prior  to
operation will have increased

I'ucibcr of sources that could
have been controlled prior  to
operation will have increased

-------
                                          Optimum Program
                                                     TABLE C-19 (CONT'D)
                                                             Proposed Program
                                                           Impact
           Rcsearc'.i  &  Development

           Generation  of  essential
           in forma 11 en through  itnple-
           n.cntatiuu of specified
           research,  nurds
                              EM radiation biological
                              effects information needs
                              and reccnrr.cnded research
                              activities will be speci-
                              fied by ERAB for action
                              by ORiM.  Starting 9/72
                               Same
None
n
M
Mo.iitorrrg Information

Ir.strua* .station systems,
measurer ont techniques
           Field  Support  Program
           Analytical  Procedures
            Environmental Assessment
Emphasis on gross indica-      Same
tors of long-term exposure
at selected sites.
Starting 7/73
                              Monitoring performed by
                              selected field facilities
                              under direction of ER/>B.
                              Data returned to ERAB head-
                              quarters for analysis and
                              evaluation.  Should be
                              started by 7/74
                              Electromagnetic radiation       Same
                              analysis  including monitor-
                              ing data,  ECAC, OT, FCC
                              data, etc.   Includes  pre-
                              paration  of  essential soft-
                              ware.   Starting 7/72

                              Permits trend  analysis         Same
                              required  for long range  plan-
                              ning.   Assists in identify-
                              ing potentially adverse
                              situations.  Starting 9/74
                               Reducted in effort by 50%.
                                                                                                     Hone
Environmental status data
is less comprehensive
                                                                                                     None
                                                                                                     None

-------
                                         Optimum Program
                      TABLE C-19  (CONT'D)

                               Proposed Program
                            Impact
           Criteria ar:d Standards
           Evaluation of effects and
           environn cntal impact
to
o\
to
           Interim Guidelines
           Guidelines & Standards
           Decision c.i Proposed
           Standard >

           Proposer. F>>vtr.onmental
           StJndarc?
Synthesize current knowledge
of effects (e.g., cataract
formation and sterility and
non-thermal hazards), do-
siraetry, and RFI effects on
various equipments.  Fund
research where appropriate.
Starting 7/72

EPA, EM radiation guidelines
necessary to ensure maximum
effectiveness in EM pollu-
tion program by 6/73

Determine implications of
setting standards (e.g.,
health, economics, spectrum
utilization).  Starting 9/72

Necessity for standards
determined by 1/74

Proposed environmental
standards for EM radiation
exposure available by 6/74
Same
None
Delay guidelines to 9/73
Delay one (1) year
Delay decision to 1/75
Delay proposed standards
to 6/75
Diminished program effec-
ivencss and delayed response
to public health EH radiation
needs

Vfill not significantly effect
development of standards
Standards delayed one (1)
year

[•.'umber of sources that could
have been controlled prior to
operation increased
           Technology Assessment
Technology Assessment will
be a continuing program which
naturally evolves from the
efforts being conducted under
information inventory develop-
ment, research effects analy-
sis, development of guidelines
and standards.  Environmental
impact statement reviews con-
stitute a part of tl-iu program.
Limitation in scope
Review of the impact of classes
of developing technology and
potential applications will be
  sduced

-------
                                       Optimum Program
                           TABLE C-19 (CONT'D)
                               Proposed Program
Impact
         Surveillance & Inspection

         EH par.j P.c tors and measure-
         ment techniques
         Instruircncation and data
         acquisition systems
o
fo
Specify meaningful EM          Same
parameters and measure-
ment techniques to char-
acterize status,of
environmental EM pollution

Necessary instrumentation
and data acquisition sys-
tems that will be developed
and acquired are included
in the following categories:

gross measurement instrumea-   Same
tation.  Necessary 7/72
None
                                       improve current state-of-the-
                                       art  for hazard instrumenta-
                                       tion.  Starting 7/72

                                       manually operated  spectrum
                                       .  analysis and precision
                                       .  field intensity  equipment
                                       .  nee cssary  9/72

                                       automated spectrum analysis
                                       .  and  precision field
                                       .  intensity equipment
                                       .  necessary 10/72
                                        associated data acquisition
                                        and processing systems.
                                        Necessary 9/72
                               Reduced effort
                               Same
                               Delayed until 10/73
                               Same
                                                                                                  None
No dramatic effect Initially,
but hazard measurements instru-
mentation development Is slowed

None
Rate of collection of environ-
mental data is reduced result-
ing in less accuracy in describ-
ing the environmental status and
related impact.  Delayed field
support facility involvement
restricts geographic deployment

None

-------
                                                  Optimum Program
                                                      TABLE C-19 (CONT'd)
                                                     	Proposed Program
                                                             Impact
10
Ot
*>
                    Data reduction and analysis
                    techniques
                    Field measurement protocol
Implenc"Lotion of field
measurer'cut capability
                    Site selection
                    Field measurement program
                    Environmental assessment
Develop the required           Same
analytical techniques and
software capabilities
Start 7/72

Specification of procedures    Same
required for efficient
performance of field
measurements. Start 1/73

Adaptation of systems for      Same
mobility and field appli-
cations. Start 2/73

Initial emphasis will be       Same
placed on describing
urban EM environments
and special population
groups. Start 8/72

Ensure efficient and mean-     Same
ingful data acquisition and
optimum use of equipment.
Field support facilities will
be phased into program.
Start 7/73

Evaluation of enyironmen-      Same.
tal quality and identifi-
cation of potentially adverse
situations in terms of health
effects, interference effects,
and general quality of life.
Start 7/73
                                                                                          None
                                                                                          None
                                                                                                               None
                                                                                          None
                                                                                                               None
                                                                                                               None

-------
                                              Optimum Program
                                                                        TABLE C-19 (CONT'D)
                                                                ProDosed Proeram
                                                               Impact
                 Training

                 Field Facility Personnel
                 State & 1'cderal Agencies
                 and Regional Offices
                             Technical information and
                             instruction required for
                             implementation of ERAB field
                             facility program.  Starting
                             10/73

                             Provide technical guidance
                             and instruction. Starting
                             3/73
                                                                    Same
                                                                 None
                                       Same
None
o
i
K)
c*
in
Technical Support

Instrumentation Support
Facility
                 Technical  Publications
                 Review of  Environmental
                 Impact: Statements
                  Data Base Requirements
Required for maintenance,
calibrations, and general
support of monitoring and
surveillance aspects of
program located at ERAB
headquarters.  Must be
available by 9/72

Essential output for demon-
stration of program produc-
tivity and dispersal of
information developed.
Should beain 7/72

Assistance  to Technical
Assessment Division until
adequate internal capa-
bility is developed.
Starting 7/72

Use of ECAC, OT data bank.
Needed 7/72
                                                                                     Same
None
                                                                                              None
                                                                    Same
None
                                                                                     Same
                                                                                                               None

-------
                                                Ontimiiin
                                                                      TABLE C-19 (CONT'D)
                                                                                5'sroDOscd Piroeram
                                                                                                Irnpac t
               States

               Assistance  in  solution  of
               nonionizing radiatlop
               problems
                                Assists states where
                                expertise is lacking and
                                speeds solution to EM
                                problems in environment.
                                Provides technical guidance.
                                Includes instrument loans,
                                measurement and analysis
                                capabilities.  Phased into
                                program but various aspects
                                beginning 7/73
Same
None
to
Regions

Liaison activities
                                                Coordination of activities
                                                involving monitoring,
                                               'surveillance and inspection
                                                and emergency response
                                                facilitates tlie implemen-
                                                tation of these program
                                                aspects.  Provides for
                                                regional awareness of
                                                headquarter activity to
                                                ensure rapid response to
                                                environmental issues.
                                                Begins 8/72
Same
None
                Other EPA Coordination

                OR&M Liaison
                                 Develop need  statements for
                                 OR&M from gaps  identified
                                 in knowledge.  Maintain
                                 liaifjon with  respect to
                                 equipment and technical
                                 capabilities  in event of
                                 possible reciprocal
                                 assistance requirements.
                                 Starts 7/72
Same
None

-------
                                                   TABLE C-19 (CONT'D)
                                       'rogr.-rn                Proposed Program              Impact
Other /cncv Coordination
FCC; FAA, OT, OTP, DOD        Required for efficient         Same                           None
Liaison                       pr >gram implementation.
                              Po .sible fall-back
                              me isurement capability  in
                              caje of emergency or
                              equipment  failure.
                              Sti.rts 7/72

-------
authority is mandatory to develop initial information for purposes of




evaluating current environmental levels of electromagnetic radiation.




Certain aspects of this goal may be attained by working through and




utilizing the established authority of the present Interagency




Radiological Assistance Plan (IRAP) program within SID.  Such a working




relationship will be established by appropriate memoranda between the




programs involved.  Authorization for those aspects not covered within




the context of the IRAP program will be sought through coordination




with other agencies such as the FCC, DOD, and OT.




Access to ECAC and OT Source Data Bank




     Immediate access to the extensive EM source data banks maintained




by ECAC and OT must be obtained.  This information is mandatory in




order to apply appropriate analytical procedures for EM analysis, both




for general environmental population exposure estimates as well as




specific source level calculations.  The attainment of this information




access will be indicated by the signing of necessary interagency




agreements, as soon after the start of FY 1973 as possible.




Emergency Response Capability




     The immediate development of an emergency response capability in




terms of making high level EM measurements is needed.  This capability




is required to make RF exposure assessments about suspected offensive




sources in light of currently used voluntary guidelines.  A primary




indicator of this goal attainment will be the acquisition of broad-




band, handheld survey type meters.
                              C-268

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Synthesis of Current Effects Knowledge




     A synthesis of the current knowledge regarding both biological




and interference effects if required before interim guidelines are




developed.  Attainment of this goal will be indicated by the publica-




tion of an ORP technical report in 8/73.




Development of Instrumentation for EM Measurements




     Development of instrumentation systems is required for meaningful




determination of ambient EM radiation levels.  Though this development




work may be of a continuing nature, well defined systems will be




operational by 6/73 and 6/74, respectively.  These systems will




consitute (1) a manually controlled spectrum analyzer interfaced with




a data acquisition system and a tuneable precision field intensity




meter, and (2) a completely automated spectrum analysis system utilizing




computer control and data processing and storage.




Characterization of Urban EM Spectra




     The first major field effort is a careful spectral characteriza-




tion of various urban EM environments during the summer of 1973.




Indications of this accomplishment will include adaptation of the




required measurement systems for mobility, field deployment of the




mobile surveillance facility, and a final report giving results,




conclusions, and recommendations for similar future work by 11/73.




Headquarters Instrumentation Support Facility




     In order to develop,  calibrate, and properly maintain the required




instrumentation systems and develop appropriate measurement methodology




and techniques for environmental EM measurements, a headquarters based
                              C-269

-------
instrumentation support facility is mandatory.  Initial development




of the facility will be initiated as soon as possible and the success-




ful attainment of this goal will be indicated by the acquisition and




installation of the required maintenance and calibration equipment and




fixed monitoring antennas at the facility.  This facility will be




operational initially by 9/72 and completely outfitted by 6/73.




EM Ambient Level Determination




     Emphasis on meaningfully specifying, from field measurements,




the ambient environmental levels of EM radiation will be stressed




during FY 1974.  Initial indications of this accomplishment will be in




the form of technical reports issued during the Fall of 1974.




Specific Source Monitoring Data




     A detailed measurement procedure must be developed and applied




to a variety of common EM emitters found in the environment.  This




constitutes both short- and long-term measurement projects for the




purpose of defining actual-radiation characteristics of these emitters




for ultimate use in assessing the current status of population exposure




to RF.  A measure of this goal attainment will be the issuance of




various technical reports.




Analytical Procedures for EM Radiation Analysis and Software Requirements




     The development and application of analytical procedures for




modeling and calculation of EM source levels for various geographic




configurations is required.  Also, the development of special software




for data acquisition systems used in .the collection of field data is




necessary.  These goals will be attained with the simultaneous issuance
                               C-270

-------
of documentary memoranda indicating the status of particular mathema-




tical methods and/or computer programs.




Rate of Growth Determination



     To facilitate long-range planning, program effectiveness, and




possible standards development, the rate of growth of nonionizing EM




sources and the associated total ambient EM levels must be assessed.



This goal will be accomplished by both theoretical and field monitoring




methods.  As a minimum, a preliminary report detailing current indica-




tions and yielding projections for the future will be issued by 11/74.




Interim Guidelines



     Effective implementation of the ERAB program to identify and




solve nonionizing electromagnetic radiation problems requires the




development of operating, interim guidelines for RF exposure.  These




interim guidelines will be published in a technical publication, among




other places, by 9/73.  These interim guidelines will be reviewed on a




continuing basis and serve as the primary input for a decision on the




necessity of developing proposed EM standards for the environment.




Decision on Proposed Standards



     It is anticipated that the necessary input data will be  available




for making a decision as to the necessity of proposing environmental




EM standards by 1/75.  The outcome of  the decision process will




represent a preliminary determination  of ORP's responsibility.




Write and Enact Standards



     Dependent upon the outcome of the aforementioned decision process,




standards may, or may not, be written  for  the purposes of protecting




the public health and preservation or  improvement of  the  environment





                               C-271

-------
with respect to EM nonionizing radiation.  This process, should it be




determined necessary, will take place approximately 6/75 for writing




of the proposed standards and approximately 12/76 for enactment of




the proposed standards into law, allowing 18 months for the necessary




legislative aspects.




Annual Report




     As a continuing  aid to evaluation of program effectiveness and




productivity, a comprehensive report describing accomplishments will




be produced annually.  This report will provide an overview of the




RF-microwave problem  area and its solution.
                             C-272

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                            LASER RADIATION






PROBLEM DESCRIPTION




     The potential for irradiation of the general population by the




light emitted by laser systems is small.  Lasers are not generally




used in applications which affect the environment, but are usually




confined in use to areas restricted in accessibility.  A few exceptions




do exist however, where lasers are used in the environment and could




conceivably create hazards to individuals through thoughtless or care-




less application and control of the laser system and area in which it



is used.




     The use of lasers in scientific, industrial, and military applica-




tions is growing.   The potential for application to the communications




industry is great.  However, in these applications unintentional irradia-




tion of individuals is easily avoided with proper precautions being




taken, i.e., by restricting the accessibility to areas in which these




systems are used.   Persons working with laser systems are trained to




avoid direct irradiation, and protective measures must be taken to




avoid hazards due to reflections from surfaces.




     Potential hazards exist primarily because of ignorance or careless-




ness with the most significant possibilities for hazardous exposure to




the general public existing in educational institutions, medical, and




dental facilities, and in the environment due to surveying and ranging




applications.




Background




     The laser can be generally characterized as a source of high




intensity, coherent, monochromatic light with a very small angle of
                                   C-273

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                    —4
beam divergence (=10   radian).  Depending upon the laser material



and purpose, systems may be operated either in a continuous or pulsed



mode.  Laser systems (not a single individual system) can produce



light with wavelengths ranging from the vacuum ultraviolet to the


                                                    9
infrared, and have produced peak powers above 1 x 10  watts.



     Biological damage consists primarily of thermal effects on the



eye and skin; the eye being the most sensitive organ due mostly to



efficient transmission of light in the visible and infrared wave-



lengths (up to =1200 nm), high retinal absorption over these wave-



lengths, and the focusing characteristics of the lens.  The latter



characteristic is responsible for the extremely low level of incident



laser light used as a threshold to avoid retinal damage.  While a




number of exposure guidelines exist,  the  cornea  exposure levels  are


                —6        2                            —7         2
typically 1 x 10   watt/cm  for CW laser systems and 10   joule/cm



for pulsed systems.  The proposed American National Standards Institute



(ANSI) standard recommends a maximum permissible exposure level of


      —3        2
1 x 10   watt/cm  to the cornea.  This level, while three orders of



magnitude higher than the previously mentioned level, is under attack



by representatives of private industry because the vast majority of



some 90,000 low power CW lasers now in use in this country transmit


                                      2

power to the cornea at 2.6 to 13 raw/cm .





LEGISLATIVE STATUS AND COORDINATION



     The U.S. Department of Health, Education, and Welfare (DHEW) , the



U.S. Department of Labor; and the ANSI all have or might have a role



in regulating the manufacture and use of lasers.
                               C-274

-------
     DHEW is obligated by PL 90-602 - known as the "Radiation Control




for Health and Safety Act of 1968" - to develop and promulgate a




standard (now being developed) that will apply to lasers, laser systems,




and laser-containing products intended to produce laser light.  The




purpose of the standard is to ensure that laser products will be




manufactured to meet the appropriate performance requirements which




minimize the possibility of radiation injury.




     The Department of Labor, through PL 91-596 - the "Occupational




Health and Safety Act of 1968" - may adopt any national consensus




standard, such as a standard adopted and promulgated by ANSI.  Any




standard adopted by the Department of Labor for PL 91-596 would apply,




to all lasers used by workers in industry.  At this time, the greatest




prospect of a national consensus standard appears to be the standard




currently being reviewed within ANSI.




     ANSI has established committee Z-136 to develop a laser standard.




The committee's membership is comprised of representatives from approxi-




mately 50 organizations (technical, professional and industry organi-




zations, universities, government agencies, etc.), and several individual



experts.




Proposed Program




     It is recommended that the ORP program for minimization of environ-




mental and biological effects due to use of laser systems be one of




maintaining cognizance in this area because of the minimal risk for




exposure of the general population.  Cognizance will be maintained




through the implementation of the Information Inventory Development





                                C-275

-------
program element of the Radiofrequency and Microwave Radiation Program




within ORP.  Up-to-date awareness of the extent of general population




exposure to applications of laser systems will permit modifications in




the ORP program to be made if required, and in addition, permit




evaluation of Environmental Impact Statements.




     Maintenance of liaison and coordination with other Federal agencies




is made possible by membership in ERMAC as is the case for RF and




microwave radiation.  ERMAC intends to include radiation from lasers




as an area for its consideration.
                                  C-276

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                         MEDICAL ISOTOPES






PROBLEM DESCRIPTION



Component Problems



     When radionuclides are used in medicine, five distinct groups of




people experience radiation exposure:




     •  production, shipment and burial personnel,




     •  patients,



     •  occupational personnel (physicians, technicians, nurses, aids,




        other patients, housekeeping staff, and administrative personnel),




     •  visitors, and




     •  the general population outside the hospital but in the vicinity




        of the nuclear medical center.




     The five groups of people represent five different problems.  This




proposal, however, will not be concerned with the occupational exposure




of personnel involved with production, shipment and official burial of




radionuclides used in nuclear medicine since the AEC, OSHA and another




team within ORP, EPA has this responsibility; nor will it be concerned




with the environmental radiation exposure, contamination and body burdens




of the medical community (internal environmental radiation exposure) and




of the general population outside the hospital (external environmental




radiation exposure).  To date, the general population in the vicinity




of the nuclear medical facility is exposed to an undefined quantity of



radiation.
                                 C-277

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     A special problem in itself, within the internal environment is




 the official record of man-made radionuclides used in medicine.  To




 date, some hospitals produce some of their own radionuclides which




 are thus not controlled by the AEC.




 Background




     According to a document entitled "Survey of the Use of Radionuclides




 in Medicine" prepared by the Stanford Research Institute for the Bureau




 of Radiological Health, the use of radiopharmaceuticals has markedly




 increased from 400,000 administrations in 1959 to 1,575,000 administra-




 tions in 1966.  Only three years later, Glenn T. Seaborg, AEC, reported




 that 3,000,000 radiopharmaceutical administrations were made annually.




 According to Dr. Abraham Goldin of Harvard, patient administrations will




 increase 20 percent annually, yielding 20 million administrations by the




 year 1980.  Within the last decade the percentage of short-term general




 hospitals, equipped with radionuclide facilities increased from 22 per-




 cent to 35 percent, therefore, involving more than 2,000 such hospitals




 by 1970.  To date, the relative importance of the total radiation dose




 received by patients and other members of the medical community from




 radionuclides as compared to X-ray exposures is small (10-15 percent).




However, only eight years ago, radioisotopes contributed only five per-




cent.  In other words,  the problem of environmental medical isotope




exposure is increasing faster than the X-ray exposure problem as indi-




cated in a Houston hospital where the average gonadal radiation dose per




patient increased from 0.06 rads in 1964 to 0.14 rads in 1968.  The radi-




ation dose,  on the other hand, from X-ray examinations, remained the



same for 1964 and 1968  (1.2 rads).




                                C-278

-------
     The external environmental radiation contamination, which occurs




by way of radionuclide release to the air via incineration and to the




water via sewer systems, remains essentially uncontrolled.  Although



the AEC allows only one Curie per year per institution to be released




to the sewer system, this restraint does not include the radioactive




contamination in excrgta_jEroin individuals undergoing medical diagnosis




or therapy with man-made radioactive material.




Scope




     In a recent study of five hospitals in the Boston area, Drs. B.




Shleien and E. LeCroy, Jr. reported that the average 1-125 thyroid




burden in the medical community working with the nuclide was 5-nCi per




individual, the maximum thyroid burden being 20 nCi.  In other words,




the average and maximum thyroid radiation dose from 1-125 was 105 and




420 mrad per year per person.  Other radionuclides accumulate in




various critical organs as well and the whole body does from other




man-made medical isotopes would, of course, be added to these simple




figures.




     Ironic, however, is the fact that the radiation dose from 1-125




alone for the medical community at risk was 10,000 times greater than




that expected for the population at risk in the vicinity of a nuclear




power plant where the man-rem risk from all radionuclides is only




0.0091 mrem/person at risk.  If priority is placed in relation to the




man-rem at risk concept, the environmental medical isotope problem




should be placed higher than nuclear power plant radioactive pollution.







                                 C-279

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Argument for nuclear power studies could be made on the basis of the




rapid growth of such plants, however, the debating point is reduced




when an individual considers also a 20 percent annual increase in




medical isotope administrations.  Argument for nuclear power plant




studies could also be made on the basis of real power needs of our




population.  However, most sick people feel the diagnostic need for




radiopharmaceuticals is equally as important, or even a bit more.






LEGISLATIVE STATUS




     To date, five government bodies have rules and regulations covering




part, but in no case all, of the radiation problems associated with




medical isotopes in the medical community including the patient and




the external environment surrounding the hospital.  These groups by




name include:




     •  Atomic Energy Commission (AEC),




     •  Bureau of Radiological Health (BRH),




     •  National Institute of Occupational Safety and Health  (NIOSH),




     •  Occupational Safety and Health Administration (OSHA),




     •  Criteria and Standards Division, Office of Radiation Programs,




        Environmental Protection Agency (CSD, ORP, EPA).




     The original legislative status of the external environmental




radiation exposure via the sewer system is not adequate even though




the AEC has partial restriction in this area under their rules and




regulations, Title 10, Part 20, Section 303.  The total radioactivity




released to the sewer systems presently is not limited by law.  The
                             C-280

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Environmental Protection Agency should establish the maximum permissible




radiation dose from radioactive contaminants released by a nuclear medi-




cal facility to the external environment in order to fill the present




loophole.  However, the new standard can only be established and enforced




after the proper assessment of the existing and projected problem is




completed scientifically via monitoring and evaluated on a health risk




and dose allowance basis./In other words, no additional legislation is




required since EPA needs only to set the limitation of radiation dose




which must be followed by the correct limitation of radioactive release




set by the AEC. )






COORDINATION




Interagency



     Five different governmental bodies need to coordinate their efforts




towards reducing unnecessary radiation contamination and exposure:




     AEC




     Presently, AEC is only involved in the partial restriction of




radionuclides used in medicine since radiopharmaceuticals produced




within hospitals are not restricted by the commission.  As a result,




the AEC should evaluate and consider the entire radionuclide usage  of




each prospective licensee before awarding the permit and should set




maximum limitations of all radionuclides on hand, regardless of the




method of production.




     BRH




     BRH should continue their radiation epidemiological work  in regards
                                 :-281

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to patient exposure, continue the educational efforts of training and




upgrading techniques of the medical community, and continue their stan-




dards concerned with quality radiation equipment and sources.



     NIOSH




     NIOSH of DHEW should establish their concern with toxicological




research.




     OSHA




     OSHA of the Department of Labor should continue to strengthen




their concern for occupational radiation exposure.




     ORP




     ORP of EPA should assess especially the external environmental




radiation exposure problem from hospitals, monitor and review the




internal environmental radiation exposure as well, establish a new




standard(s), if necessary, and encourage enforcement thereafter.






ALTERNATIVE APPROACHES




     The ORP, EPA could request that the other four governmental bodies,




especially the AEC, assess the external environmental radiation exposure




and other related problems.  A weaker alternative would be to request




directly that state agencies, for example the Environmental Improvement




Agency in New Mexico, provide ORP with data so that CSD could assess



the problem area.
                                  C-282

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OPTIMUM PROGRAM




External Needs



     Legislative Needs




     By the end of 1975 OKP, EPA  should have had qualitative and




quantitative analyses of the internal and external environmental radi-




ation exposure and contamination completed.  Furthermore, CSD, OKP,




EPA should have completed the health risk evaluation associated with




present and projected levels of internal and external environmental




radiation exposures before 1977.  As a result, during 1977, CSD, OBP,




EPA should establish a standard, setting the maximum permissible limits




for nuclear medicine release per year, month and week to the external




environment (vicinity of hospital releasing radiopharmaceuticals).  No




legislation, then, is needed.




     Knowledge




     The radiation exposure and body burdens of the medical community




in the internal environment need to be substantiated by additional data.




More importantly, however, is the unknown amount of radioactive contam-




ination in the environment resulting from releases from hospitals.  The




external environmental radioactive contamination needs to be monitored




and evaluated.




     Research and Development Needs




     Through the use of lithium fluoride thermoluminescent dosimeters,




comparative environmental dose measurements should be made (1) within




the sewer system in the effluent discharge line leading from  the nuclear
                                 C-283

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medicine section, patients section alone,  research section, and the



entire hospital where no additional dilution occurs between the hospital



and the city sewer system; and (2) within the stack of the incinerator.



These dose estimates should be related to the total quantity of discharge



released per time radiation dose is measured, discharge depth, and con-



centration of radionuclides in the actual effluent discharge material.



     Through the use of film badges, comparative dose measurements



should also be made for each type of individual exposed:  physicians,



technicians, nurses, aids, janitors, visitors, etc.



     The Optimum Program requires five different investigations of the



internal environmental radiation exposure and ten different investigations



of the air and water routes of contamination  (external environmental



radiation exposure).  In the Optimum Program, two grants would be awarded



for internal environmental radiation exposure analyses and seven grants



would be awarded for external environmental radiation contamination.
             \


     Enforcement and Control Requirements



     At the present time, AEC, BBH, N10SH, OSHA, and ORP should essen-



tially mark time until the assessment by CSD, ORP, EPA is made and a



need for additional limitations has been shown to be scientifically



sound.  Then, the AEC and associated State agencies must enforce those



limitations or standards established by CSD, ORP, EPA.



     Interagency Implementation



     Within EPA, three laboratories will be requested to monitor both



the internal and external environmental radiation exposure.  In the latter
                                 C-284

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analysis, both air and water radio contamination must be determined.

The three laboratories for this program are:

          Radiological Engineering Laboratory
          National Environmental Research Center
          5555 Ridge-Avenue
          Cincinnati, Ohio   45213

          Eastern Environmental Radiation Laboratory
          P.O. Box 61
          Montgomery, Alabama   36101

          Western Environmental Research Laboratory
          P.O. Box 15027
          Las Vegas, Nevada   89114

     Once a new standard is established, however, regional radiation

representatives of EPA will need to provide guidance to medical communi-

ties and State agencies.

Internal Needs

     Monitoring data in the requested form will be sent to CSD, ORP, EPA

for evaluation.  Health risk analyses will be made and a standard will

be developed if the Director of CSO so seems necessary.  If a new stan-

dard is desired at that time, legal advice and preparation will be

required internally.  ORP manpower will consist of one person in CSD

for FY 73, 74, 77, and 78 and three people in CSD during FY 75 and 76.


PROPOSED PROGRAM

     Exactly the same as the "Optimum Program" with two exceptions:

     (1)  Three groups will be analyzing the internal environmental

          radiation exposure problem instead of five groups.  No grants

          will be awarded since all monitoring will be conducted with ORM.
                                  C-285

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     (2)   Five groups will be analyzing  the external  environmental




          radiation contamination  instead  of  ten groups.   Only two



          grants will be awarded since three  external environmental




          radiation contamination  analyses will  be made by OEM.






COMPARISON OF THE  OPTIMUM AND PROPOSED PROGRAMS



     Only the degree of significance associated  with the assessment of




radiation dose and contamination will be affected.






MEASURES OF GOAL ATTAINMENT



     ORP, EPA will have recognized, assessed and evaluated the problem




concerned with radiation exposure to the medical community.  If the



problem warrants the setting of a standard,  the establishment of such




a limitation will be the second measure of accomplishment.  If such




restraints are established and the enforcement and control measures




are implemented so that the radiation exposure and contamination to




both the internal and external environs are reduced  or stabilized  as




measured by State agencies, the third goal will have been reached.
                                  C-286

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                       OCCUPATIONAL EXPOSURE






PROBLEM DESCRIPTION



     The problem is that personnel are being occupationally exposed




to radiation in an industry that is rapidly expanding and little or




no effort is being expended to prevent exposures from increasing.




The contribution of occupational exposure to the population dose from




radiation is poorly documented in the scientific literature.  Despite




the lack of published information, a vast quantity of data has been




accumulated in various personnel dosimetry programs  throughout the




United States.



      In general, the data  collected by the various reporting  agencies




have  been primarily for verification of  the adequacy of  radiation




protection practice and to preclude, where possible, over-exposure of




the worker.  The retention of  the  data by the  employer  is in  most




instances, for medical-legal purposes.




Component Problems




      Problem 1



      Occupational  exposure regulations are  established  for the purpose




of controlling  individual  exposures.  Under  present  regulations each




 individual is limited  to an average annual  dose of five rem.   However,




 there is no  limit  as  to  the number of persons  that may receive this




 dose for a particular  activity.   Thus the potential  man-rem exposure is




 almost unlimited  and  presents  an unacceptable situation on a national




basis.  Under present  regulations any person who is  18 years of age or




more and  is  not pregnant,  can  be exposed to an average of five rem
                              C-287

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per/yeaz by designating that that person is occupationally exposed.




Further, there are no nuclear facility design requirements limiting




man-rem dose from occupational exposure.




     Problem 2



     There are limited requirements for uniformity in collecting and




reporting of all occupational exposure to radiation and there are no



required standards for accuracy in personnel exposure measurements.




     Problem 3



     In small nuclear installations, the adequacy of definition of




occupational exposure is questionable and the controls for and




measurement of occupational exposure are generally inadequate.




Background




     The statutory authority of EPA to advise the President  on radiation




matters affecting public health is derived  through the transfer of




authority from the former Federal Radiation Council  (FRC)  (42 U.S.




Code 2021 M).  Although EPA has no specific authority to  set occupational




exposure limits, participation in standards setting  for exposure of




uranium miners at the request of the Department of Interior  is an




example of  the general EPA policy of advising other  Federal  agencies



with regard to radiation safety.




     Regulations controlling the occupational exposure are provided by




the AEC and by state health departments  for by-products material and




by state health departments for electronic  devices which  emit radiation.




These regulations define radiation areas in terms of radiation exposure




rate and identify the controls required  for personnel entering or  working
                                 C-288

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in these areas.   General observation indicates that the controls estab-




lished in accordance with these regulations for nuclear facilities of




sufficient magnitude to have full-time personnel devoted to radiation




safety are generally adequate for control of individual exposure to




levels prescribed by the regulations.  However, controls in smaller




facilities are estimated to be generally less adequate with the




definition as to which areas and which personnel are to be controlled




being rather vague.  These situations generally are limited to small




medical facilities, research facilities, and educational institutions.




     Experience with nuclear maintenance operations at major nuclear




facilities indicates a lack of design considerations for maintaining




occupational exposure to a minimum.  A general solution by the facility




operator is to accept the facility design and to attempt to work out



procedures and equipment for performing maintenance in such a fashion




as to keep individual exposures within the required limits.  In cases




where procedures and equipment are inadequate to maintain low exposure,




additional personnel (generally from the local area due to union require-




ments) are brought on the job to spread the exposure, thus reducing




individual exposure but increasing the total man-rem dose.




     No current program exists to correct the above problems and continued




expansion of the nuclear industry could result in unacceptable population




dose due to occupational exposure.  This situation may already exist in




localized areas wherein the genetic exposure could become important due




to continued exposure of the same population over generations.
                                  C-289

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Scope




     Present



     The present scope of the problem is partially defined in Table C-18.




Additional information relative to the causes of occupational exposure




is needed.  This information can only be developed by those present and




involved during maintenance operations to nuclear facilities, or by




observation of practices at nuclear medical, research and educational




facilities.



     The data in Table C-20 generally represent information collected




in 1969 and 1970.  There is considerable uncertainty as to how much the




data varies from one year to the next.  This is particularly true for




occupational exposure from nuclear power facility operations and main-




tenance.  For example, Table C-20 shows the total annual occupational




exposure from all such facilities to be only 497 man-rem.  These data




are from 1969 records.  However, a report from Consolidated Edison




shows the occupational exposure at the Indian Point-1 facility to be




approximately 770 man-rem to approximately 900 persons in a six-month




period in 1970 during which the plant was shut down for refueling and




maintenance.  Extrapolating the Indian Point-1 exposure situation to



the current situation where up to four nuclear facilities with a total




electrical capacity of about 15 time the capacity of Indian Point-1




are constructed on one site, the potential exists for occupational




exposure to increase to a significant level.




     Based on the following assumptions, the somatic risk from occupa-




tional exposure associated with nuclear power facility operations in the
                                  C-290

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             Table C-20
Estimated U. S.  Occupational Dose
Activity
Air Force
Army
Navy
AEC
AEC Licensees
Medical
Major Processor
Waste Disposal
Radiography
Industrial
Academic
Reactors
Fuel Processing
Packing & Transport
Total AEC Licensees . . .
Agreement State
Licensees
Non-federal
Medical x-ray
Non-federal
Dental x-ray
Medical Radium
Approximate
No. employees
included in
study
35.000
7,400
55,000
103,000

20,228
1,789
21
,.1,894
13,331
7,738
2,302
6,637
335
62,090

24,500

194,600

171,200
37,900
Annual
mean
exposure
(mrem)
88
95
200
197

260
276
457
397
160
116
216
328
65
215

273

320

125
540
Man-rem
per year
1,555
708
10,900
20,361

5,260
495
96
752
2,139
903
497
2,177
22
13,365

6,700

62,000

21,400
20,500
                  C-291

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year 2000 can be calculated.


     •  The exposure rate at a plant the size of Indian Point-1 is 1/4


        the average rate for a facility that size or approximately


        385 man-rem/year (arbitrary assumption).


     •  Occupational exposure rate will be directly proportional to


        facility size.


     •  Nuclear power production will grow at the rate indicated in


        Figure C-35.


     •  Risk values in ICEP 8 of 20 leukemia cases, 20 other fatal


        neoplasms and 10-20 thyroid carcinomas per 10  man radiation


        exposures, are realistic estimates.


The above assumptions result in the following calculations:


                  6                               8000 times as much
          2.1 X 10  megawatts in year 2000	 _ nuclear power in year

         2.65 X 102 megawatts at Indian Point-1 " ?°9? as presently at
                                                  Indian Point-1.



     8000 X 190 man rem/year = 1.5 X 106 man rem/year in year 2000.


This represents a risk of 1.5 times the values for risk discussed in


ICRP possibly involving a total population of 7.2 X 106 persons.


     With continued effort to reduce population exposure from emissions


from nuclear facilities causing more in-plant exposures, and considering


increased size and number of plants, and increased age of operating


facilities, occupational exposure from nuclear power facilities may


become one of the major sources of man-made population dose.  Figure C-35


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.
                                  C-292

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                   Figure C-35

ESTIMATED NUCLEAR GENERATING  CAPACITY  IN THE U.S.
               THROUGH THE YEAR 2000
                                           i- 19C2 REPOKT TO
                                              THE PRESIDENT
  1965
           1970
                  1975
                           1930
                                   1935
                                          1WO
                                                  1995
                         C-293

-------
Without additional controls,  occupational exposure from these facilities




will increase at a rate at least equal to the nuclear power growth rate.




     The scope of the problem relative to occupational exposure at




medical, research, and educational facilities in terms of the number




of personnel exposed and the estimated extent of their exposure is




defined in Table C-20.  The first step in solution of the problem is




to determine the causes of exposure, the areas where improvement can




be made and the actions required to effect those improvements.



LEGISLATIVE STATUS



     The basic legislative authority for controlling occupational expo-




sure to radiation from by-prpduct materials  is  contained  in  the




Atomic  Energy Act of  1954.  The Department of Labor has the  authority




to  regulate worker  exposure through the Occupational Safety  and Health




Act of  1970 with DHEW providing research input.



     Based on  the Atomic  Energy Act of 1954, Title 10,  Code  of Federal




Regulations, contains several parts dealing  with  the licensing of by-




product and special nuclear material.  Part  20  of these Regulations,




limits  the occupational exposure of individuals to specified concentra-




tions  of  these products in air and water, as well as  to specified




exposure  rates from external radiation.  These  limits  exceed the limits




for exposure of  population groups  by  a factor  of  30, and  exceed  the




design guide limits for population exposure  of  individuals from opera-




tion of nuclear  power facilities by a factor of 500  to 1,000. No




regulations exist which limit the  total  man-rem of occupational  exposure




related to a specific activity.  Regulations pertaining to nuclear
                                 C-294

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power facilities provide design guidance limiting discharges to levels




as low as practicable.  "Low as practicable" is defined in terms of




population exposure.  No similar regulations exist for occupational




exposure.



     Figure C-36 is a diagram of the process by which occupational




exposure to radiation is controlled.




INTERAGENCY COORDINATION




     Agencies involved for controlling occupational exposure are the




Atomic Energy Commission, the Department of Defense, States, the




Department of Health* Education, and Welfare, FDA/BRH, Department of




Labor, Department of Interior, and the Environmental Protection Agency




Office of Radiation Programs.



     Figure C-37 is a diagram of interagency relationships relative to




the control of occupational exposure.  It is apparent from this chart



there is no formal arrangement for feedback of exposure data to EPA,




the agency responsible for providing guidance and standards.




ALTERNATIVE APPROACHES




Description of Alternatives




     First Alternative




     Take no action and depend on present programs  to control  occupa-




tional exposure.




     Second Alternative




     Point out potential problem to AEC and suggest corrective action.




     Third Alternative




     Perform limited  study to investigate the extent of the problem and
                                   •1-295

-------
                                State
?
\o
   AEC
Agreement
  State
                 Electronic
                 Radiation
                 Equipment
                                Regulations
                                10 CFR~20
                                Regulations
                                State
                                Regulations
                                   Occupational
                                   Exposure from
                                   Production &
                                   Utilization
                                   Facilities &
                                   Source
                                   Material
                                                                                       By-Product
                                                                                       Material
                                   Natural &
                                   Machine
                                   Produced
                                   Radioactive
                                   Material
                                   Electronically
                                   Produced
                                   Radiation
Guidance k
W

DOI
Regulations k
w

Uranium
Mines
                 FIGURE C-36

LEGISLATIVE STATUS FOR OCCUPATIONAL RADIATION EXPOSURE

-------
ICRP
NCRP
guidance
1
EPA
ORP
guidance
and
standards



i
•*
H

AutnodsatiDas
I
AEC
Regulations

' 	 1
AKC
H^UJ! Regulations .

Branch "^
Regulations „
4Exoosure data
\EC
operated

AEC
' licenses

Nuclear
shipyards
Unlicensed
i/j T •{ «- aw
facilities

	 . Worke
?e.pt- of Reculatlons ^ ioniz

Agreement
states
09
ei c
a o
•rt 1-1
O u ctf
•H O 3
C BA
r exposure to s (2
ing & nonionizing
*•*"" » radiation , t
l,r -— hi
4
>
•>
Y
^
Natural & ' Agreement
Machine-made state
radioactive licensee^

NASA Regulations ^ Space


States Regulations

| guidance
FDA-BRH Regulations %.
9

001 Regulations k

Electronic
Radiation
Equipment
users


Electronic
Equipment
Manufacturers

Uranium
Mines

              Figure  C-37




       IKIERAGENCY  COORDINATION




OCCUPATIONAL EXPOSURE (Current  Program)
               C-297

-------
develop a report with suggested actions by government agencies and




industry.




     Fourth Alternative




     Establish a program to:




     •  Perform special studies to investigate the extent of the problem




        as indicated in the third alternative




     •  Perform special studies to determine actions needed to reduce




        exposure potential based on findings of special studies




     •  Advise Federal, and state agencies concerning regulations or




        other actions needed to reduce occupational exposure




     •  Monitor corrective action and determining the effectiveness of



        the revised programs.




     Fifth Alternative




     Perform the first three items above, and also establish an occupa-




tional exposure registry.  This registry would be computerized and all




occupational exposure would be compiled into the registry for analysis




and for prediction of situations requiring corrective action.



Comparison of Alternatives




     The fourth alternative is chosen as the Optimum Program.  The




first and second alternatives would provide little or no information




not already available, and would provide no solution to the problem.




The third alternative could be performed with minimal funding, but pro-




vides no assurance of corrective action.  The fifth alternative which




includes a registry of occupational exposure would probably meet with




objection from industry due to the increased effort required to provide
                                C-298

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data for the registry.  Further, there is no assurance that such a




registry and data analysis program would be required to solve the problem.




If coaputerized data management is required, details of such a program




can better be defined after initial studies are complete.




OPTIMUM PROGRAM




     The Optimum Program would include the steps defined under the




fourth alternative, above.  The extent of the program will be dependent



on the findings in the initial studies.  Initially arrangements must




be made for AEC, DOD, DDL, and States to provide ORP with information




on occupational exposures that have occurred and studies that have




been made relative to the causes of these exposures.  Agreements must




also be negotiated with the AEC and AEC agreement states for special




studies of exposures resulting from licensee operations.  The Milestone




Chart for the Optimum Program is presented in Figure C-38.



External Needs




     Legislation Needs




     Legislation already exists for controlling occupational exposure.



     Knowledge Needs




     Information on occupational exposure will be needed as a function




of type of facility, trade, and type of job in order to determine the




extent of the problem, the potential for continued increases in exposure




rates and the corrective actions necessary.  Acquisition of this infor-



mation is the first step in the proposed program.




     Research and Development Needs




     Additional information is needed to determine the dose risk relation-



ship.




                                C-299

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 PAGE NOT
AVAILABLE
DIGITALLY

-------
     Enforcement and Control Requirements



     It is anticipated that EPA will not be directly involved in the



enforcement of occupational exposure regulations.  The enforcement



should be exercised by the AEC or other agencies having regulatory



authority over sources of radiation.  EPA should be involved in the



establishment of standards and control requirements.  EPA should also



have some type of program to assure through data review that the stan-



dards are being enforced by the agencies involved and possibly some



degree of independent validation of results.



     Interagency Implementation



     Operation of this program by EPA will require the cooperation of



the AEC, DOD, FDA-BRH, and the States.  These are the agencies currently



in control of occupational exposure.



Internal Needs



     Internal needs outside the Office of Radiation Programs will be



limited and will be defined after the initial studies.  It is anticipated



that regional offices will provide coordination with States in the acqui-



sition of information for the initial and followup studies.



     Two personnel should be assigned in ORP during the initial year



of the program, to determine the extent of the problem and to establish



detailed plans for solutions to the problem.  At least one of these



should be experienced in occupational exposure control and in methods



used for exposure prevention.  This person will need assistance in data




compilation and analyses and secretarial assistance.  Further personnel




assignment needs will be determined as part of the initial studies.
                                 C-301

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MEASURES OF GOAL ATTAINMENT




     Under the current program in a particular industry, occupational




exposure is expected to grow at a rate at least equal to the rate of




growth of that industry.  An effective control program should be capable




of reducing the rate of increase from the major contributors by at




least 25 percent.  Monitoring of these programs should be established




such that occupational exposure for a particular industry can be related




to the operating level of that industry.




     The degree of goal attainment should be determined by comparing




the rate of growth of an industry to the rate of growth of occupational




radiation exposure resulting from that industry.
                                  C-302

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                           MEDICAL X-RAY






PROBLEM DESCRIPTION




     Medical diagnostic X-ray exposure is now recognized as the major




source of man-caused radiation dose to the U.S. population.  The purpose




of this paper is to outline the Office of Radiation Programs' (ORP)



plan of involvement with this problem.




Component problems




     Since this problem is only in the cognizance and recognition stage,




as far as ORP is concerned, the first task is to assess the parameters




of the problem to determine its magnitude and scope.  This involves




risk/benefit methodology and dose and technology assessments.




     Secondly, dose reduction goals need to be set and decisions made




on how these goals are to be achieved.  This involves determining ORP's




authority to act in this area and how best to interact with other




agencies in meeting the goals.  After this second step, further problems




will arise.  They cannot be defined at this time.




     Throughout the whole program a component problem is to work out




sufficient coordination and cooperation with other Federal and State




agencies in the various programs, i.e., in acquiring new legislation



or carrying out a training program.




Background




     Although the medical use of radiation has long been recognized




as a major source of human exposure, past radiation exposure guidance




has excluded this source from being covered under the recommended




limits.  The difficulty of controlling this source as well as the
                                 C-303

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undesirability of restricting the physician's ability to treat his




patients have led to this exclusion.



     However, it is now recognized that some medical radiation exposure




may be unnecessary and that research and development activities could



produce better equipment and techniques to reduce radiation exposure.



Therefore, some control may be indicated.  Also, much money is being



spent to reduce small exposures from other sources, i.e., reactor



effluents, whereas, a smaller amount of money may reduce medical X-ray




exposure by a greater amount.



Scope



     Medical radiation use constitutes the largest source of man-made



radiation exposure of the population of the United States.  The Special



Studies Group report indicates that in 1970 medical diagnostic X-ray



radiation contributed about 90% of all man-made radiation exposure.



This percentage will decrease in the future as radiopharmaceuticals



increase in use, but the magnitude of the exposure from medical X-ray



sources is expected to remain about the same.



     The characterization of medical X-radiation exposure is difficult




since it depends on the age of individuals exposed,  the area of the



body exposed, the type of procedure involved, exposed people vs.



unexposed people, and high dose rates for short periods of "time.



     The use  of medical diagnostic X-radiation  involves the exposure



of  three groups of people:  patients, workers involved  in making  the



X-ray exposure, and people working or located near  the  exposure area.
                                  C-304

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The latter two groups are covered by the occupational radiation problem




paper.  Thus, this problem paper is limited to only considering patient



exposure (including dental exposure).






LEGISLATIVE STATUS



EPA



     The functions of the Federal Radiation Council were transferred



to EPA by Reorganization Plan No. 3 of 1970.  These functions include



advising "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 establish-



ment and execution of programs of cooperation with States."



Department of Health, Education, and Welfare (PHEW)



     The Public Health Service Act as amended by the Radiation Control



for Health and Safety Act of 1968 (PL 90-602) provides for the establish-



ment "of an electronic product radiation control program which shall



include the development and administration of performance standards to



control the emission of electronic product radiation from electronic



products."  This is administered by the Bureau of Radiological Health



(BRH) of the Food and Drug Administration of DHEW.  Under this authority



BRH will soon publish, in the Federal Register, performance standards




for diagnostic X-ray systems and their major components.  These go



into effect one year after publication.

-------
States



     Some States have developed their own regulations for the use of



radiation.  The Council of State Governments in cooperation with BRH



and AEG has developed model legislation for use by the States and a



model for State regulations is being revised with assistance from the




Conference of Radiation Control Program Directors.  Performance aspects



of State regulations must be identical to the same performance aspects



of Federal regulations in the areas where Federal regulations have



been established.  In other areas the States are free to establish



their own regulations.  There is no requirement for States to develop



regulations for the use of radiation and about 20 of them have not



done so.



Voluntary Standards



     Several groups develop voluntary standards for users of medical



X-radiation.  These groups include the International Commission on



Radiological Protection, the International Commission on Radiation




Units and Measurements, the National Council on Radiation Protection



and Measurements, Committee N-44 of the American National Standards



Institute, the American College of Radiology, and the American College



of Chest Physicians.  Compliance with standards issued by these groups




is not mandatory unless they are incorporated by rule-making bodies.






COORDINATION




Interagency



     Since this problem is limited to patient exposure from medical



X-radiation and since BRH has authority in this area, the major





                                 C-306

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 interagency  coordination would be with BRH.  This  coordination should



 occur  at  every point in  the program since BRH will actually be doing



 much of the  work  in program implementation.  Some  of  the sections  of



 BRH  that  should be included in the coordination are:



     • Program Office (XES and other special projects)



     • Office of Criteria and Standards



     • N.E. Radiological Health Lab (Division of  Medical Radiation



        Surveillance)




     • Division of Training and Medical Activities



     • Division of Bio-Effects




     • X-ray Exposure Control Lab (Division of Electronic Products)



 This coordination can probably best be Implemented through one contact



 point  with BRH.  A few sections of other Federal agencies  may  be



 involved  in  the implementation of a program to lower medical X-ray



 exposure, e.g., the Medicare program and the Veteran's Administration.



     Coordination with the states in regulations and monitoring will be



 required.  The Criteria and Standards Division (CSD) or  ORP is admin-



 istering a contract recently negotiated with the State of  Illinois.



The contract is for Phases I and II of a three-phase study.  The first



two phases are to develop models for the inventory and categorization



of all radiation sources and for dose assessment and to  test these




models over an 18 county area in Illinois.   These phases are expected



to last for 12 months at a cost of $88,260.   Phase III would extend



the survey to the entire state at a cost of  about $170,000  over 2 years.
                                 C-307

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     Coordination would also be required with groups and individuals




both inside and outside the government concerning risk-benefit deter-




minations.




Intragency




     The Regional program will be involved with working with the states




in setting up State-run dose assessment programs (such as the Illinois




program) and in assisting them in developing or revising State regula-




tions to reflect EPA guidance.




     Some parts of a proposed program can be carried out in cooperation




with other programs within ORP, e.g., contracts with States to carry




out dose assessment programs.






ALTERNATIVE APPROACHES




     Since this problem is only in Stage 1, all approaches to a solution




will involve three basic components:  (1) assessment of the problem,




(2) setting goals and deciding how to achieve these goals, and




(3) Implementing a program to achieve the goals and to measure goal




achievement.




     A guiding priciple for the entire program will be to attempt to




reduce exposure to a minimum by regulating devices and techniques




used in making medical X-ray examinations and by searching for less




harmful diagnostic techniques, while not reducing diagnostic capability




and not restricting practitioners in the number of examinations




indicated.  Two alternates are suggested and briefly discussed.
                              C-308

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First Alternative




     Do nothing - let BRH and the States handle the problem.  This




essentially involves having no goals and thus no program is needed.




BRH and the States can probably handle the problem, but FRC-type guidance




vould be useful for them.  EPA should assess the problem further to




see if guidance is needed.  This approach is not recommended.




Second Alternative




     All other approaches involve an assessment program and the making




of a decision.  The assessment program involves dose, risk-benefit




methodology, and technology assessment.  This program can be:




(a) minimal, (b) partial, or (c) in great detail, and it could be




done solely by ORF or by direct involvement with BRH and possibly




some other Federal agencies.  The decision could be:




     •  issue findings of the assessment program and let public




        pressure, the medical profession, and other governmental




        agencies determine future courses of action,




     •  issue FRC-type guidance on dose; let BRH implement,




     •  issue FRC-type guidance in more detail  (including techniques




        and equipment); let BRH implement, or




     •  seek further legislation to allow EPA to implement  and




        enforce decision.






OPTIMUM PROGRAM




     The optimum program is to set up a joint program with  BRH to




carry out a partial assessment program and to issue a series of
                                C-309

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FRC-type detailed guidance with BRH implementation with EPA assis-




tance .




     A joint program with BRH is recommended for several reasons.  The




guidance to be issued is of the FRC-type which has been formulated in




the past by joint efforts of the agencies concerned with the guidance.




Much of the information to be used in formulating the guidance will




come from BRH, and BRH will be concerned with implementing much of




the guidance.  Also, it is desired that there be no duplication of




effort by ORP and BRH.




     Partial assessment (maximum use of current data plus a detailed




monitroing contract with one State in each region) is recommended.




Minimum assessment (maximum use of current data plus one or two contracts




with States) would most likely not be enough to reflect the national




situation and wourl not provide enough bases for issuing detailed gui-




dance.  Maximum assessment (monitoring contracts with all States)




would be unnecessarily time consuming and wourl be unnecessary to




describe problem areas.




     FRC-type guidance with BRH implementation is more desirable than




for EPA to seek legislation to allow implementation and enforcement.




BRH has sufficient legislation to act in this area, although it would




be desirable to have legislation requiring States to develop radiation




protection standards.  This problem would also be considered by most




people to be outside the environmental sphere.  Thus, EPA should not




be the lead agency in this area.
                                 C-310

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     Issuing a series of detailed guidance rather than a one-time




guidance of minimum scope would allow certain problem areas to be



addressed first in one manner and then other problem areas could be



addressed in a different manner if necessary.  It will probably be



necessary to speak specifically in the medical area rather than issue



a broad guidance on dose as has been done in other areas in the past.



External Needs



     Legislative Needs




     Work with BRH and the Conference of Radiation Control Program



Directors to obtain legislation requiring States to develop radiation



standards.




     Knowledge




     Use currently available knowledge on dose, risk-benefit methodology,



and technology - obtainable mainly from BRH and the States (the 1964



and 1970 USPHS X-ray Exposure Studies will provide much data).  Supple-



ment this by having regions contract with one State in each region to



carry out a statewide monitoring program for dose, methodlogy and



technology.   This could be followed up by gradually adding more States



to the program.   An alternative to the contract State monitoring program



would be to work through a program soon to be implemented by BRH in



cooperation with the States.  The Nationwide Evaluation of X-ray



Trends (NEXT) program is scheduled to start in October utilizing data




furnished by State inspection programs to monitor trends.  It is



uncertain if the program will be useful for standard setting purposes,
                                 C-311

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but the required information could be requested to be obtained through




this program.



     Risk/benefit information could be obtained by talks with and papers



from outside interested groups.



     Research and Development Needs




     Research and development is needed for good monitoring methods



of medical exposure and for new methodology and technology to reduce



exposure.  This can probably be carried out by BRH.



     Enforcement and Control Requirements




     BRH will carry out enforcement and control within the limits of



its legislation.  A few other Federal agencies may be affected to a



small degree.   The type of guidance issued will suggest the need for



enforcement and control.



     Interagency Implementation



     BRH and the States through BRH will implement the program required



through the FRC-type guides issued by EPA.  Regions will make contract



arrangements with the States.



Internal Meeds



     Legislative Needs




     None.



     Knowledge



     QRP will need to evaluate the information received for all sources




in terms of the usefulness and harmfulness of medical X-ray exposure.



     Research and Development Needs



     Some dose, risk/benefit methodology, and technology evaluation



techniques may need to be developed.





                                C-312

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     Enforcement and Control Requirements



     ORP will have some control over the States monitoring program



through the contract arrangements.  The future legislation may give




ORP more direct control over State regulations.



     Interagency Implementation




     ORP should provide coordination and assistance to BRH and the



States, expecially in research and development, in monitoring for goal



attainment and in providing any required training.



Implementation



     To implement the assessment program it is recommended that several



top-level people from both ORP and BRH have a 2-3 day brainstorming



type conference to discuss the issues and decide on the approach that



will be made to the problem.  From this conference a team of one or



two people from ORP and BRH should be established to see that the



assessment program is carried out.  This would not necessarily be a



working group but would be mainly a coordination group.  They would



provide close coordination between ORP and BRH, good exchange of



information, and coordination of efforts within their own agencies.



They would obtain guidance and assistance from the two agencies in




carrying out the assessment program.  This would not be a full-time



assignment unless they were to function as a working group.



Milestone Chart



     The milestone chart for the Optimum Program is shown in Figure



C-39.  This shows the approximate time scale suggested for the various
                                  C-313

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 PAGE NOT
AVAILABLE
DIGITALLY

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phases of the optimum program.  Figure C-39 shows many parts of the




program that would have to be performed outside ORP.






PROPOSED PROGRAM




     The Proposed Program is to carry out the Optimum Program but with




a longer time scale and with fewer states in the monitoring program.




This lowers the man-rpower and dollar requirements of the Optimum Program.




External Needs




     The external needs are the same as for the Optimum  Program




except that only 2-3 States will be contracted with to set up monitor-




ing programs.  This will mean that less information will be available




on which to base decisions.  Therefore, the FRC-type guidance will be




slower in coming and will be less detailed than in the Optimum Program.




     The NEXT program could be expanded to provide the desired infor-




mation or more States could be added to the monitoring program in the



future.




Internal Needs




     The internal needs are the same as for the optimum program except




that personnel and budget restrictions will slow the process.




Milestone Chart




     The milestone chart for the proposed program showing ORP's functions




is given in Figure C-40.




Comparison of Optimum and Proposed Programs




     The major impact of the'proposed program compared to the optimum




program will be that the doses in 1980 will probably not be as low as
                                C-315

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 PAGE NOT
AVAILABLE
DIGITALLY

-------
they would be if the optimum program was instituted.   This results




because the FRC-type guidance will  not be as detailed as in the optimum




program.  It will not be as detailed because less State data will allow




less assessment of improvement areas.  Less detail will lead to fewer




changes in 'State regulations and fewer items -for BRH to implement and




enforce.




     It is possible that the States' standards in themselves will be




sufficient control, and, that along with training, the proposed program




will lower the doses as much as the optimum program would.  This would




be a plus, but the chances of this  happening are not as great with the




proposed program.






MEASURES OF GOAL ATTAINMENT




Goals



     •  To develop a continuing medical X-ray dose and use assessment




        program.




     •  To eliminate unnecessary radiation exposure due to medical




        X-ray use.




Measures of Goal Attainments




     •  The number of States participating in the monitoring program.




     •  The trend of the data resulting from these monitoring programs.




     •  The numbers of people being trained in the better uses of




        medical X-rays.




     •  The doses measured in about 1980 in State or national studies




        compared to the doses measured in the 1964 and 1970 PHS studies.
                                 0317

-------
                           NUCLEAR DEVICE TESTING






PROBLEM DESCRIPTION




     There exists a potential risk to the health of the general population




from exposure to radiation that may result from the testing of nuclear




devices.  The magnitude of this risk is determined by measuring any increase




in levels of environmental radioactivity—and assessing the exposure to




the general population.




Component Problems




     Sources




     An unusual component of this general problem is the variability and




uncontrollability of the sources of testing, the sites at which tests




are conducted, and the types of tests.  Since the first tests by the




United States in 1945, there have been tests conducted by the U.S.S.R.,




Great Britain, and France.  They have ranged from safety tests of the




equivalent of several pounds of high explosive to tests of the equivalent




of fifty or more megatons.  They have been sited from the Arctic to the




equator and far into the southern hemisphere.  They have been detonated




underground, underwater, on the surface, in the atmosphere, and beyond




the atmosphere.




     Background Levels




     As a result of the atmospheric tests prior to the nuclear test ban




treaty, the natural background radioactivity of the whole planet has been




changed.  During the height of the U.S. testing program during the 1950's,




extensive fallout measurement programs were conducted across this country







                                    C-318

-------
arid selected overseas locations.  These studies make possible the




estimation of the present levels from past testing activities throughout




this country, and the prediction of how these levels will decrease with




time, in the absence of any appreciable new testing.




     Source Related Levels




     Another component to this general problem area, is the measurement




or prediction of environmental radioactivity levels, arising from specific




tests.  There is a response time limitation required to establish field




surveillance/monitoring programs, the time frame in which analysis must




be completed, and the temporal limitations under which protective actions




must be Initiated.




     Of great importance to this component problem is the degree of




credibility which attaches itself to the end product cf these




surveillance/monitoring efforts.  The timeliness of the data gathering




and analysis and the credibility of the finished product, however, only




serves as stepping stones which lead; in cases of difficulty, to the




implementation of corrective actions.  The critical question regarding




corrective actions is of course, the governmental siting of the legal




authority to initiate such actions, the speed with which they can be




instituted, and their public acceptance.




     Finally, with regard to this problem, a major difficulty is the




necessity of maintaining the necessary manpower, equipment, and facilities




in a standby status.  The difficulty is compounded during times, such as




the present, when the testing program is reduced far below the years of




peak activity and the continuation of the eutiie testing program is a






                                    C-319

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matter of public and international discussion.




     Synergistic Aspects




     It must be continually stressed that the environmental radiation




contribution from weapon testing activities must not be viewed alone.




It must be assessed as a part of the total with which the population is




faced.  Another part which is very closely related is that arising from




the nuclear detonations-^which are conducted in the Plowshare Program.




The distinction between nuclear devices used  for weapon development




reasons and those used for peaceful reasons pales into insignificance when




the resulting effects are looked at from an environmental protection




viewpoint.




Background




     The majority of the U.S. nuclear device  tests were carried out




either at the Eniwetok Proving Grounds  (EPG)  in  the South Pacific, or at




the Nevada Test Site (NTS) near Las Vegas, Nevada.  The NTS has been used




primarily for atmospheric, surface, and underground tests with yields




below one megaton.  As a result of  the nuclear test ban treaty, all




nuclear devices tests at NTS are conducted  underground.  A  summary of




the U.S. nuclear detonations as of  July  1,  1972,  is presented  in Table C-21,




      In 1954, the U.S. Public Health Service  (USPHS)  of  the Department




of Health, Education, and Welfare,  signed a memorandum of understanding




with  the Atomic Energy Commission  (AEG)  to  provide  a  comprehensive




offsite radiological surveillance and  safety  program  in areas  adjacent




to the NTS and  other testing locations  as requested.  This  program was




condur.fed by  the IISPHS until December  of 1970 when  tha responsibility  for






                                     C-320 .

-------
                                TABLE C-21
                     U.S.  NUCLEAR DETONATION SUMMARY
                                                        Number of Tests

CY-1945
   Trinity, Alamogordo, New Mexico                             1
   Combat detonations, Japan                                   2
CY-1946
   Crossroads Series, Bikini                                   2
CY-1948
   Sandstone .Series,  Eniwetok                                  3
CY-1951
   Ranger Series, Nevada Test Site                             5
   Greenhouse Series, Eniwetok                                 4
   Buster-Jangle Series, Nevada Test Site                      7
CY-1952
   Tumbler-Snapper Series, Nevada Test Site                    8
   Ivy Series, Eniwetok                                        2
CY-1953
   Upshot-Knothole Series, Nevada Test Site                   11
CY-1954
   Castle Series, Eniwetok and Bikini                          6
CY-1955
   Teapot Series, Nevada Test Site                            14
   Wigwam, Pacific Ocean                                       1
CY-1956
   Redwing Series, Eniwetok                                   13
CY-1957
   Plumbbob Series, Nevada Test Site                          24
CY-1958
   Hardtack I Series, Eniwetok and Bikini                     31
   Hardtack II Series, Nevada Test Site                       18
   Argus Series, South Atlantic                                3
Testing was suspended on October 30, 1958 under a voluntary moratorium
which lasted until September 1, 1961 when the Soviets resumed atmospheric
testing.  The United States resumed testing on September 15, 1961 with
an underground test at the Nevada Test Site.  Since that time statistics
have been recorded on a Fiscal Year Basis.

FY-1962
   Nougat Series, Nevada Test Site                            41
   Project Gnome, Carlsbad, New Mexico (12/10/61)              1
   United Kingdom Test, Nevada Test Site                       1
   Dominic Series, Christmas Island and Eastern Pacific       24
FY-1963
   Storax Series, Nevada Test Site                            30  (d)
   United Kingdom Test, Nevada Test Site                       1
   Dominic Series, Johnston Island area and Christmas
      Island area                                             12
                              C-321

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                                TABLE C-21 (CONT'D)

                                                       Number of Tests

FY-1962/1963 (additional)
   The limited test ban treaty restricting tests to under-
fround emplacements was signed in Moscow on August 5, 1963.
On August 20, 1963, President Kennedy told reporters there
had been 97 tests at NTS between September 15, 1961 and the
treaty signing.  This included 23 tests not previously
announced.  These tests have not been identified as to date
of name.                                                       23

FY-1964
   Niblick Series, Nevada Test Site                            26 (e)
   Project Shoal, Fallen, Nevada (10/26/63)                     1
FY-1965
   Whetstone Series, Nevada Test Site                          31 (e)
   United Kingdom Test, Nevada Test Site                        1
   Project Salmon, Hattiesburg, Mississippi (10/22/64)          1
FY-1966
   Flintlock Series, Nevada Test Site                          38 (c)
   United Kingdom Test, Nevada Test Site                        1
   Project Long Shot, Amchitka, Alaska (10/29/65)               1
FY-1967
   Latchkey Series, Nevada Test Site                           26 (d)
   Project Sterling, Hattiesburg, Mississippi (12/3/66)         1
FY-1968
   Crosstie Series, Nevada Test Site                           28 (a)(d)
   Project Gasbuggy, Farmington, New Mexico (12/10/67)          1
   Faultless, Central Nevada (1/19/68)                          1
FY-1969
   Bowline Series, Nevada Test Site                            26 (c)
FY-1970
   Mandrel Series, Nevada Test Site                            39 (a)(b)
   Project Rulison, Grand Valley, Colorado (9/10/69)            1
   Project Milrow, Amchitka, Alaska (10/2/69)                   1
FY-1971
   Emery Series, Nevada Test Site                               9
FY-1972
   Grommet Series, Nevada Test Site                            10 (a)(b)
   Project Cannikin, Amchitka, Alaska (11/6/71)                 1
TOTAL ANNOUNCED U.S. NUCLEAR DETONATIONS                      532

(a)  Includes 1 Vela Uniform event.
(b)  Includes 1 Plowshare event.
(c)  Includes 2 Plowshare events.
(d)  Includes 3 Plowshare events.
(e)  Includes 4 Plowshare events.
                              C-322

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environmental studies of radioactivity was transferred to the




Environmental Protection. Agency (EPA) under the President's Reorganization




Plan #3.




     The purpose of the EPA program is to document and evaluate the




radiological situation through comprehensive environmental sampling and




radiation monitoring.  A public contact and information program is




conducted to advise the Tiutrric regarding- safeguards employed to protect




public health and property from radiation hazards.  The EPA performs




necessary investigations of incidents which might be attributed to




radioactivity and which could result in claims against the Government




or create unwarranted public opinion.  Special field investigations are




also performed to determine biological effects or to gather other information




of interest.




Scope




     Present




     The EPA program  in this area  is  conducted by the National




Environmental Research  Center, Las Vegas,  (tfERC-LV),  on  a reimbursable




basis with  the USAEC.   In  addition to the weapon testing program, NERC-LV




also provides support for  the  Nuclear Rocket  Development Station  (NRDS)




program,  the Plowshare  program,  and  work for  other  EPA  programs.




      In FY  72,  the  operating  expenses supported  by  the AEC were $2,364,000




with  138 man-years  of effort.  The weapons testing  program utilized




 $2,254,800  and  133.5  man-years.   Tables  C-22  and C-23 provide a detailed




analysis of the  expenditures  and manpower for the weapons testing program.




The computer expenses are  not  included in this analysis.  The off-continent






                                    C-323

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                                                        TABLE C-22

                                       ANALYSIS OF OPERATING EXPENSES BY PROGRAM
                                                       (In Thousands)
o
u>
10
ENVIRONMENTAL PROTECTION AGENCY

PROGRAM DESCRIPTION

Device Program:
   Rad-Safety Off-Site NTS
   Bio-Environmental
   Bio-Environmentai-Animal Investigation Program
   Rad-Safety Off-Continent
   Supplemental Test Site
                        Total Device Program

NRDS Support
Plowshare Program

Reimbursable Work

Capital Equipment - Weapons
Capital Equipment - Plowshare

                        Total Equipment

                        TOTAL PROGRAM COSTS2


 Includes $156,000 for buildings lease.
2
 Excludes computer facilities costs.
                                                                                 FY 1972    FY 1973
                                                                                    48.0
        FY 1974
$1,552.8
380.0
65.0
30.0
227.0
2,254.8
35.0
16.3
10.5
48.0
0.0
$1,983.21
430.6
75.0
0.0
0.0
2,488.8
30.0
30.0
20.0
75.0
0.0
$2,048.01
410.0
80.0
0.0
0.0
2,538.0
30.0
0.0
20.0
97.3
0.0
75.0
97.3
                                                                                $2,364.6   $2,643.8   $2,685.3

-------
                                                         TABLE C-23

                                        ANALYSIS OF YEAR-END EMPLOYMENT BY PROGRAM
                                                        (Man-Years)
               ENVIRONMENTAL PROTECTION AGENCY
               Device Program:
                  Rad-Safety Off-Site NTS
                  Bio-Environmental
                  Bio-Environmental AIP
                  Rad-Safety Off-Continent
                  Supplemental Test Site

£J              NRDS Support

               Plowshare Program

               Reimbursable Work

                               TOTAL
                                                      FY 1972                  FY 1973                 FY 1974
                                               Direct Indirect Total    Direct Indirect Total   Direct Indirect Total
63.0
17.0
4.0
1.5
6.5
1.5
1.0
0.5
97.0
32.5
6.0
0.0
0.5
2.5
1.0
0.5
0.0
41.0
95.5
23.0
4.0
2.0
> 9.0
2.5
1.5
0.5
138.0
69.5
17.0
4.0
—
~
1.5
1.5
0.5
96.0
36.5
6.0
0.0
—
—
1.0
0.5
0.0
42.0
106.0
23.0
4.0
—
—
2.5
2.0
0.5
138.0
71.0
17.0
4.0
—
—
1.5
—
0.5
96.0
37.0
6.0
0.0
—
—
1.0
—
0.0
42.0
108.0
23.0
4.0
—
—
2.5
—
0.5
138.0

-------
      DELETED
C-324 through C-325

-------
and supplemental test site program will not be funded after FY 72.

     The bio-environmental aspect of this program is more directly

related to the programs of the Office of Research and Monitoring (ORM)

while the remaining program relates directly to programs in the Office

of Radiation Programs (ORP).  A tenant agreement has been established

for an Office of Radiation Programs technical support facility at the

National Environmental Research Centers-Las, Vegas.  Certain organizational

changes and functional relationships have been agreed upon.  The Director,

NERC, Las Vegas, will report to the Assistant Administrator, ORM.  An

Assistant Director for Radiation Operations will be appointed by ORP

and concurred in by ORM and will be responsible for the tenant program

of special studies and AEC offsite monitoring.

     The offsite radiological monitoring function and responsibilities

are as follows:

                  Function                        Responsible Office

     1.  Program definition, objective,     Office  of Categorical Programs
         priorities, and allocation of      (OCP) Headquarters
         resources

     2.  Policy guidelines  for executing    OCP Headquarters
         program

     3.  Evaluation of results              OCP Headquarters

     4.  Execution of defined programs      Director, NERC-LV

     In  support of the offsite program  for  weapons  testing  and  Plowshare

activities, NERC-LV maintains continual radiological  surveillance to

detect and document radioactivity,  regardless  of  its  origin,  particularly

in the areas around NTS.  This surveillance includes  personnel  and

field dosimctry monitoring  with  radiation  measuring instruments  ai a

sampling of air, water,  milk,  soil, vegetation and animal tissue.  An

                                    C-328

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immediate action readiness  posture  is  maintained to assist in protecting




the population from exposure to environmental radiation.  Prior to and




during each event conducted at the  NTS or the Plowshare sites, aerial




tracking and surveillance is initiated to determine cloud trajectory




and gather data to estimate the general magnitude of the release and




the resulting environmental contamination.




     The monitoring and~Burveillance servij&es are oriented toward a




two-part program.  The first phase is directed specifically toward the




individual by employing a dosimetry system to measure individual or




area exposures, and mobile monitors equipped with suitable instruments




to measure exposure rates.  This phase also  incorporates a capability




for rapid response to an emergency radiation situation.




     The second phase is to ascertain the exposure of a  large segment




of the  population by obtaining estimates of  the dose equivalent  from




radiation levels attributable to nuclear detonations, whether underground




tests,  excavation projects  or nuclear rocket engine  tests.  Routine




sampling of  the environment is conducted at  fixed  locations with




established  sampling networks.




     An Office of Dose Assessment  and Systems Analysis  at NERC-LV




evaluates the  impact on  the environment  of nuclear  testing and  other




radiological activities, particularly in  terms  of  the  health  and safety




of the  general  public.   Calculations  are  performed  to  document  exposures




to members  of  the population  based on environmental  sampling  and




monitoring.  A whole-body  counting and  scanning facility is  used to locate.




identify, and measure sarrna-emitting  radioactive materials deposited




                                    C-329

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within the body as a result of inhalation and/or ingestion.




     The NERC-LV conducts extensive field and laboratory experimental




studies into the ecology of specific pollutants and the methods and




effectiveness of the transport to man through the various media.




Research efforts are principally applied to investigations into the causes,




characteristics, and effects of man-made and natural radiation.




     The AEC sponsors atr organization-knowa as the Medical Liaison Officer




Network (MLON) which provides physicians in locations other than Nevada




to  investigate radiation injuries which are reportedly due to nuclear




testing activities.  The coordinator is an EPA medical officer who also




is  responsible for  investigating the medical aspects of alleged offsite




radiation  exposure  around  the NTS in Nevada.  Representing every State,




the District of Columbia,  and Puerto Rico, MLON membership is composed




of  physicians knowledgeable  in the  field of radiation bio-effects and




radiation  injury.




     A veterinary or animal  investigation  program is conducted  to provide




background information  to  answer inquiries -and  resolve complaints or




claims by  livestock raisers, wildlife management  personnel, and other




groups concerned with  the  welfare  of animals.   Wildlife  and a  domestic




herd are  studied  on and adjacent to the  NTS,  in cooperation with other




agencies,  to assess the radionuclide constant of edible  species.




      Future




      The  scope  of the  EPA  program  in this  problem area will  be basically




 the same  and will be conducted  by  NERC-LV  under a memorandum of agreement




with the  AEC.






                                    C-330

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LEGISLATIVE STATUS




     The primary responsibility for conducting the national weapons




testing program is mandated to the AEC.  The principle legislation




relating to _the AEC is the Atomic Energy Act of 1954.






COORDINATION




Interagency




     The primary agency with which EPA coordinates its activities in




this problem area is the AEC.  The AEC operates NTS and conducts, primarily




through its Los Alamos and Livermore Laboratories, the nuclear weapon




development test programs.  In addition, some coordination  is necessary




with the Department of Defense (UOD),  particularly the Defense Nuclear




Agency.  The DOD is primarily involved with weapon effects  testing




programs.   Joint concern for  the health and safety of the  population atso




necessitates some coordination efforts with HEW and  State  and  local health




agencies.   There is a need  for coordination with  the State  Department or




other  executive branch organizations  for testing  involving international




areas  or  the territory of  other nations whenever  venting  occurs  following




a planned  test.




     Cooperation  is maintained by  NERC-LV with  the Nevada Fish and




Wildlife  on their wildlife studies.   The NERC-LV  also maintains  a liaison




with the  Bureau of Sport Fisheries and Wildlife of  the Department of




 Interior  in connection with the  veterinary  program conducted by  NERC-LV




 around the NTS.





                                   C-331

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     The NERC-LV also lias  the responsibility under the AEG memorandum of




understanding to carry out precautionary programs to prevent injuries




to members of the public from rocket firing activities at the Tonopak




Test Range and from the seismic effects of test detonations at any




location.  A cooperative program with the U.S.  Coast and Geodetic




Survey and the U.S. Bureau of Mines is necessary to conduct this program.




Intragency




     Coordination is necessary between the Office of Radiation Programs




(ORP) and the Office of Research and Monitoring (ORM).  The ORM has the




administrative authority for all research activities.  Formal research




requirements are developed by the ORP and submitted to ORM in addition to




those developed by ORM.  The actual radiation surveillance and monitoring




activities are technically managed by ORP.  The ORM is kept informed of




the scope and nature of radiation surveillance and monitoring activities




so that  they can properly carry out their overall functions.




     Within the ORP, coordination is necessary between all Divisions.




The Technology Assessment Division  (TAD) has reviewed Environmental




Impact  Statements related to the testing activities at NTS in the  past




and has  commented on their potential adverse environmental effects.




TAD is  the group within ORP  that is coordinating  all  the  comments  on




Environmental Impact Statements from the various  offices  within  EPA  such




as the  Office of Air Programs and the  Office of Water Programs.   The




Field Operations Division is the primary contact  between  NERC-LV and ORP




and has planned special studies at  the NTS  and has  coordinated  activities




of  the  monitoring rifcrvorks both nationally  and  in the immediate  dr.virors





of NTS.




                                    C-33?

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ALTERNATE APPROACHES




     There are several other approaches which could be employed to




accomplish EPA's objectives in this problem area.  They are as follows:




     6  Some other agency_, such as HEW or the AEG itself could perform




        the work.




     0  The work could be performed under contract by private industry.




     t>  The work could~corrtinue to be—performed  by EPA and be funded




        directly by EPA.




     An action memorandum has been written by ORP to  the Office of




Categorical Programs  (OCP) concerning the possibility  that EPA initiate




action with OMB to  transfer funds  from  the AEC  to EPA for conduct of




the  Offsite Radiological Safety Program  an support of test activities




at NTS.   It has been  recommended by ORP  to OCP  that  the  present reimbursable




arrangement with the  AEC be maintained.






OPTIMUM  PROGRAM




      The  optimum program  is the same  as  the  proposed programs  because




 the  scope of  work  is  defined  by the AEC under the memorandum of  understanding.






PROPOSED  PROGRAM




      The  proposed  program involves basically the continued funding




 support  from AEC  for  the  NTS  related  activities at  NERC-LV and the




 overseeing of these activities  by  the Assistant Director for Radiation




 Operations,  ORP.






                                   C-333

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External Needs




     Legislative




     None




     Knowledge




     It is necessary that NERC-LV continue to be informed by the AEG




of all plans to conduct weapon testing programs.




     Research and Development Needs




     The research program proposed for the Offsite Radiological




Safety Program, the Radiation Effects Program, and the Animal Investigation




Program as submitted by NERC-LV to the AEG are required.  This program




is outlined below.




     Enforcement and Control Requirements




     None




     Interafiency Implementation




     The AEG will fund the required NERC-LV activities and will continue




to keep NERC-LV personnel informed of test plans.




Internal Needs




     In ORP the proposed program requires the  assignment  of  one man-year




effort and the  funds necessary to  support his  personnel costs and  travel




expenses.  At NERC-LV, the necessary funding and  positions are  furnished




on a reimbursable basis by the AEC.




Milestone Chart




     See Figure C-42.




     The program  to be conducted by NERC-LV has been adapted from a




proposal by the NERC-LV  to  the AEC oi:  the  cuntinuing and  new projects






                                   C-334

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 C-335

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 PAGE NOT
AVAILABLE
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that they plan to conduct during FY 1973.   Since this has not been




approved, changes may have to be made in the future.




     Off-Site Radiological Safety Program




     0  The. routine environmental monitoring program will continue




        to document the environmental radioactivity levels around the




        NTS.   As required, methods will be improved and additional




        nuclides measuredr~



    e   After each event an extensive program of sampling various ground




        media aerial tracking and surveillance will be conducted.




        Samples collected on and around the NTS will be analyzed for




        xenon, krypton, and tritium as methane hydrogen gas and water




        vapor.



    c-   Analysis of soil, air filters, urine, vegetation, and animal




        tissue for plutonium samples collected  through the NTS surveillance




        network will continue.




     e  Computer programs will be written  for performing additional




        dose  calculations from the data scored  in  the storage and retrieval




        system.  This  is an extension  of the project  to  tabulate doses




        which might have accrued  to an individual  in  the off-site area




        due  to nuclear testing.   Programs  will  also  be written to provide




        dose contour plotting from surveillance data.




     9  A  complete evaluation and update of the gamma spectral analyses




         computer programs will be conducted.




     ff  A  system utilizing a solid state counting  system will be  developed




         to analyze -samples that  conLoir. cociplex mixtures.






                                   0339

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   programs will also be developed to analyze this data.




   The program to document the radioactivity levels in




   hydrological test wells at various off-NTS test sites such as




   Gnome and Shoal will be continued,




Bio-Environmental Program




e  After the excretion of plutonium studies on goats and rats,




   four different-metabolism studies^n dairy cows will be




   conducted.  This project will encompass oral and intravenous




   intakes, excretion, and tissue distribution studies.




o  A study V7ill be conducted on the in vitro solubility of




   Plutonium compounds using a. simulated rumen.




o  The laboratory studies of plutonium assimilation by micro-




   organisms will be continued.




9  The effect of various fertilizers, soil cations and colloids on




   plant uptake of plutonium will be studied.




e  A study of plutonium movement in various soil types will be




   initiated to determine the influence of soil salinity, cation




   exchange capacity,  texture, and structure of each soil.




*  The mechanisms for  foliar absorption of plutonium in forage




   plants will be studied.




ff  Tissue concentrations of fresh and/or aged fission products




   will be determined  in bovine,  mule deer, and other wildlife which




   range on the NTS  with increased emphasis on plutonium-239 and




   tritium.






                                 C-340

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o  The veterinary or animal investigation program will be




   continued.  Investigations of alleged damage to domestic




   animals from AEG activities will be conducted in addition to the




   routine program of surveillance on the radionuclide content of




   edible species.




e>  The investigation of plutonium concentrations in the tissues of




   beef animals grazing the Roller. Chaster site will continue.




o  A study will be initiated to determine the possible hazards




   of plutonium-239 by grazing pregnant beef animals, pregnant




   goats, and fistulated steers on contaminated range in Area 13 of




   the NTS.




&  A workable study of deer migration patterns on the NTS related




   to the season and preferred area will be developed.  One method




   to be investigated is the use of aerial photography with infrared




   scanning equipment or the use of telemetry devices.




&  Cooperation will be maintained with the Nevada Fish and Wildlife




   on wildlife studies, and the NERC-LV will supply veterinary




   support for the Desert Bighorn Range as part of its liaison with




   the Bureau of Sport Fisheries and Wildlife of the Department of




   Interior.




0  The NTS farm will continue to be utilized to evaluate the




   uptake of low quantities of mixed fission and activation products




   in locally grown truck vegetables.  Dairy cows from the farm




   are used  for various radioisotope ingestion and inhalation studies.
                             C-341

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     o   A project to measure the distribution and biological




        magnification of tritium in animals was initiated.




     0  A final evaluation will be conducted on the high concentration




        of -tritium in urine from volunteers who wore watches with




        tritiated luminous dials.






MEASURES OF GOAL ATTAINMENT




     The expected accomplishments of the proposed program will be




primarily:  (a) monitoring/surveillance reports for specific testing




activities presented to the AEC, (b) technical reports on the research




studies published as EPA documents, and (c) routine monitoring/surveillance




data from the ORP networks and NERC-IV networks published in ORP's




RadlatIon Da ta and Re port s.  The measures of these goal attainments




will be the quantity and quality of these reports, the increase in the?




knowledge of environmental pathways, and the development and dissemination




of improved predictive methods and models applicable  to future weapon




testing operations.




     The proposed program, which is primarily  a continuation of the




past program, will continue to provide documentation  of the radiological




impact of NTS weapon testing activities on  the surrounding area to the




AEC.  It will also continue the  ecological  studies being  performed by




NERC-LV related  to  the evaluation  of  the potential impact of past,




present, and future  on the environment.  The  program  will provide a




focal point within  ORP which can facilitate the incorporate of results




of these NERC-LV/NTS programs  into the  activities of  the  three ORP




division activities  (Table C-24).






                                   0342

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                               TABLE  C-24

                   NERC-LV PROJECTS RELATED TO
                          ORP PROBLEM AREAS
New NERC-LV Procedures
 Possible Utilization
Gas sampler to monitor
       noble gas
Air sampling and researctt
       for Tritium
Plutonium Procedures,  Research
   and Surveillance Program
New developments in Environmental
   Monitoring including
   animdl investigation
   program
Computer Operations

Dose and Body Burden Studies
Plowshare Projects
NRDS
Fuel Reprocessing
Operation - Plutonium
Operation - Uranium
Fabrication - Uranium

Plowshare Projects
NRDS
Fuel Reprocessing
Tritium - Thermonuclear
Operation - Uranium
Operation - Plutonium

Operation - Plutonium
Fabrication - Plutonium
Weapons Testing

Plowshare Projects
Fuel Reprocessing
Operation - Plutonium
Operation - Uranium
Weapons Testing
Fabrication - Uranium

All problem areas

Accidents
Fuel Reprocessing
Plowshare Projects
Tritium - Thermonuclear
Construction Materials
Fabrication - Plutonium
Operation - Plutonium
Operation - Uranium
Weapons Testing
Mining & Mill Tailings
Fabrication - Uranium
                                 C-J43

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                              PLOWSHARE
PROBLEM DESCRIPTION
     The use of nuclear explosives in commercial and public engineering




projects as proposed under the Plowshare program presents hazards of




two kinds.  First, it presents a potentially significant public health




hazard from the radioactive contaminants released by the nuclear explo-




sion or associated with the by-products from it.  Because of the half-




lives of the radionuclides involved and their point of injection, the




hazards presented are both Immediate and long-term.  Second, use of




large numbers of nuclear explosives in a relatively small area as




proposed by Projects Rio Blanco and Wagon Wheel has the possibility of




inflicting severe seismic, physical, and chemical damage to the surface




and subsurface environments and natural resources contained therein.




It is not possible, at this point, to accurately assess the total impact




of these activities due to uncertainties in the development of the Plow-




share program and to critical gaps in basic scientific knowledge.




     The EPA/ORP program outlined here seeks to minimize the impact of




this activity by:  (1) filling scientific and economic voids, (2) develop-




ing guidance based on risk/cost/benefit balances, (3) making accurate




pre-project environmental impact assessments, and (4) insuring compliance




with safety guidelines.




Component Problems




     The components of the EPA/ORP program correspond to the major




program areas of Plowshare.  Plowshare activities can be grouped in three
                               C-345

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broad areas:  excavation, resource recovery, and scientific experimen-

tation.  The major components of the program are listed below together

with an indication of the present activity in the United States.  Soviet

activities are also included, and are so marked in cases where they

are unique.

     Excavation

     Surface

        Canals, dams, harbors (inactive).

        Aggregate production (inactive).

     Subsurface

        Terminal gas storage (inactive).

        Deep disposal of radioactive waste - concept stage (active).

        Deep storage of industrial and municipal waste (inactive).

        Special applications - extinguish gasfield fires (USSR).

     Resource Recovery

     Stimulation (hydrocarbon)

        Natural gas from low permeability formations (active).

        Enhancement of oil well flow (USSR) .

     Mineral recovery

        In situ leaching of ore bodies (inactive).

        Removing overburden from shallow ore bodies (inactive).

     Energy

        Fracturing of dry, hot subsurface formations (with a geothermal
        anomaly) for steam production (inactive).
                                 C-346

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     Scientific



     Basic



        Neutron cross section studies (inactive).



        Fission symmetry studies (inactive).




     Applied



        Isotope production (inactive).



Background



     Surface Excavations



     The use of nuclear explosives in surface excavations has recieved



considerable attention in the United States and abroad.  Shallow nuclear



excavations, such as Cabriolet, Buggy,  Schooner, and the large 100 kt



(kiloton) Sedan crater, have been conducted at NTS to obtain basic



cratering and fallout data.   Specific applications considered include



the excavation of sea-level transisthmian canal and the Ogoturuk Creek



Harbor in Alaska (Project Chariot).  Interest in this area has declined



sharply because of the potential for significant adverse environmental



impact, and the present public reaction in the United States against



uncontained nuclear detonations.




     Subsurface Excavations



     Underground excavation experiements in the United States have



been limited to the AEC's NTS (Nevada Test Site).  The Ketch "experiment,"



proposed by Columbia Gas System Service Corporation for a site in a



State forest near Renovo, Pennsylvania, was dropped.  This "experiment"



was to have produced a cavity for natural gas storage.  Although this



particular site was dropped, the program area seems viable and other
                               C-347

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sites in the Appalachian area may be proposed.  The AEG is currently




considering the underground excavations as possible means of radioactive




waste disposal.  In this technique, a deep subterranean cavity is




created by a nuclear explosive placed in a drill hole.  This cavity is




then filled with high level waste whose energy release of heat when




added to the cavity heat generated by the nuclear explosion will




theoretically seal the cavity and solidify as a stable immobile mass.




     Gas Stimulation




     The use of nuclear explosives to stimulate the production of




reportedly large supplies of natural gas in low-permeability rocks in




Rocky Mountain geologic basins has been under development by the AEG




in cooperation with Industry.  Two previous AEC-Industry experiments in




New Mexico and Colorado have demonstrated that nuclear stimulation of




gas in low-permeability reservoirs is technically feasible.




     The AEG has proposed additional experiments at the Rio Blanco




gas filed in Colorado and the Pinedale field in Wyoming with new types




and configurations of multiple nuclear explosives designed to fracture




thick sequences of low permeability rocks.  If the tests are success-




ful, the AEG contemplates the development of the Rio Blanco field with




about 140 nuclearly stimulated wells, and the Pinedale field with about




300 nuclearly stimulated wells.  Possibly other areas would be susceptible




to large-scale nuclear stimulation also.  The explosives for the two




proposed tests would be detonated as depths greater than 5500 feet at




Rio Blanco and greater than 9220 feet at Pinedale, and it is probable
                                C-348

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that much of the radioactivity from these tests would remain in the




deep rocks.  Nevertheless, the analysis of the potential environmental




effects of the proposed tests is complex and critical because of the




large amounts of radioactivity that will be released by the detonation




of multiple devices in the 30-100 kiloton yeild range.  An analysis of




the effects of developing entire gas fields would be extremely complex




and is not possible with existing information.  The environmental con-




siderations of large-scale nuclear gas stimulation can be assigned to




two major categories:  (1) effects on the local environment resulting




from the nuclear detonations during and after well stimulation and




production operations, and (2) the radiation exposure of the general




public by widespread distribution and use of the proposed gas.  The




effects on the local environment that must be evaluated and judged




include the effects of hundreds of detonations over a period of poss-




ibly 8-10 years.  Potential local effects include seismic damage to




man-made structures and terrain, contamination of large underground




water resources and oil shale, and accidental and purposeful releases




of radioactive gas and fluids to the land surface and air during




testing and operations.  A special problem is the disposal of relatively




large volumes of tritium contaminated water that would be stripped from




the gas during testing and production.  After depletion of the gas




fields significant quantities of radioactive materials would remain




underground providing possible sources of contamination by slow migra-




tion in groundwater for many years.
                                0349

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     Assessments of the environmental consequences to the local environ-



ment will depend not only on the above described geologic, hydrologic,



and radiologic considerations, but also on risk/cost/benefit decisions.



The alternatives to large-scale nuclear stimulation whereby the gas



might be obtained by further development of chemical explosive and



hydrofracturing techniques should be examined.  The actual size of gas



reserves that could realistically be developed by nuclear stimulation



should be determined, and a determination should be made as to whether



the increased production of a dwindling energy source will be signifi-



cant enough, in terms of an overall national energy policy, to justify



the radiation risk involved.



     The question of radiation exposures from transmission and use of



nuclear stimulated gas is central to the acceptability of the gas as



a consumer product.  In order to evaluate exposures of the general



population from actual consumer use, it will be necessary to make



projections of the amounts of gas that will be transmitted and used;



the radioactivity of the gas at various stages of transmission, stroage,



and use; and possible methods of achieving "steady-state" concentrations



of radioactivity by diluting gas from newly stimulated wells with



uncontaminated gas from other sources.  Methods of surveillance and



monitoring must be developed at various points in the production and



distribution systems.  Much of the above is currently being investigated



and developed by AEC:  nevertheless, the responsibility of EPA lies



in examining the problems thoroughly and developing methods and expertise
                                0350

-------
for evaluations, decisions,  and recommendations relative to using



nuclear stimulated gas as an energy source.   The determination of



"acceptable" or "permissible" concentrations of man-made radioactivity



in natural gas for industrial and commercial use is difficult because



this represents only one of  many potential sources of radiation



exposure and a large population is involved.  The responsibility and



needs of EPA relevant to nuclear gas stimulation are immediate because



of the necessity for technically based decisions concerning Environ-



mental Impact Statements, the necessity for providing technical assist-



ance and consultation to State agencies, and risk/cost/benefit decisions



related to the reported natural gas shortage.



     Mineral Recovery



     Several mineral recovery experiments have been proposed by industrial



sponsors.  The Bronco experiment was proposed by CER for oil recovery



from shales, and the Kennecott Copper Corporation's Sloop experiment



was to determine the feasibility of in situ copper leaching.  To date,



neither experiment has been implemented.



     Scientific



     Few scientific components of the Plowshare program have been



carried out.  These have been, in general, conducted as part of device



tests at NTS.  Two such experiments were a neutron cross-section



experiment on the Persimmon Event, and an isotope production experiment



on Hutch.  An exception is the Gnome-Coach experiment, conducted at



Carlsbad, New Mexico.  Gnome-Coach was designed to measure the energy
                                 C-351

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dependence of the neutron-activation cross-sections of several heavy



elements and the resonance-fission characteristics of Uranium-235.



     USSR



     The Soviet Union is actively pursuing a program closely paralleling



the U.S. effort.  The level of Soviet activities is presently several



times that of the U.S. and covers a somewhat broader range of applica-



tions.  They are actively pursuing surface excavation, particularly as



applied to water management.   Experimentation is being conducted on a



technique to stimulate oil flow from spent or low production wells.




Scope of Program



     The major completed Plowshare experiments and their dates and sites



are summarized in Table C-25.



     At present, the only active Plowshare program is the stimulation



of gas-bearing formations.  This program is currently in an experimental



phase in which nuclear stimulation technology, explosives research, and



radiological problems are being investigated.  It is conducted jointly



by the AEC and an industrial sponsor.  To date, the industrial sponsors



have been Austral Oil Company, CER-Geonuclear, £1 Paso Natural Gas



Company, and Equity Oil Company.  As previously noted, two field experi-



ments, Gasbuggy and Rulison, have been completed.  Two additional



experiments, Rio Blanco and Wagon Wheel, are in advanced stages of



preparation.  Rio Blanco now scheduled for early 1973, will test the



capability of multiple C3) explosives, fired simultaneously, to success-



fully stimulate a 1400 foot section of thin, low-permeability gas-



bearing sand.  The Wagon Wheel experiment, tentatively set for 1974,
                                    C-352

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Oi
OJ
                                                      TABLE C-25
                                                PLOWSHARE  EXPERIMENTS
 1.  Gnome, Carlsbad, New Mexico (12/10/61)'
 2.  Sedan, NTS (7/6/S2)2
 3.  Anacostia, NTS (11/27/62)3
 4.  Kaweah, NTS (2/21/63)3
 5.  Tornillo, NTS (10/11/63)3
 6.  Klickitat, NTS (2/20/64)3
 7.  Ace, NTS (6/11/64)3
 8.  Dub, NTS (6/30/64)3
 9.  Par, NTS (10/9/64)3
10.  Hancar, NTS (11/5/64)*
11.  Sulky, NTS (12/18/64)2
12.  Palanquin, NTS (4/14/65)2
13.  Templar, NTS O/24/66)3
14.  Vulcan, NTS (6/25/66)*
15.  Saxon, NTS (7/28/66)A
16.  Simms, NTS (11/5/66)3
17.  Switch, NTS (6/22/67)3
18.  Marvel, NTS (9/21/67)5
19.  Gasbuggy, Farmington, N.M. (12/10/67)
20.  Cabriolet, NTS (1/26/68)2
21.  Buggy, NTS (3/12/68)7
22.  Stoddard, NTS (9/17/68)3
23.  Schooner, NTS (12/8/68)2
24.  Rulison, Grand Valley, Col. (9/10/69)*
25.  Flask, NTS (5/26/70)3
26.  Miniata, NTS (7/8/71)3
                                                                                                                6
                 Contained underground experiment.
                2
                 Cratering experiment.
                3
                 Device development experiment.
                (.
                 Heavy element production experiment.
                 Emplacement  technique experiment.
                 Gas  stimulation experiment (industrial participation).
                 Row  charge cratering experiment with  five simultaneous  detonations.

-------
will involve sequentially firing five (5) nuclear explosives in a



2700 foot section of thin, low-permeability formation.  In addition to



gas stimulation experiments, test detonations involving advanced



concepts are being conducted at the Nevada Test Site.  One such



experiment "Yacht" will test the explosive devices and timing and



firing system to be used at Wagon Wheel.



     The gas generated in Rulison and Gasbuggy (the two stimulation



experiments) has relatively low levels of radioactivity, due primarily



to the nuclides H-3, Kr-85, Ar-39, and C-lA.  Significant fractions of



these nuclides have been released to the atmosphere during post stimu-



lation testing.



     While none of the gas produced in these experiments has been sold



commercially, the Rocky Mountain Natural Gas Company will in early



1973 seek clearance from the AEC to allow the sale of Rulison gas in



Colorado.



     The present EPA/ORP program is devoted primarily to gas stimulation.



This program is conducted primarily by EPA's NERC (National Environmental



Research Center), ORP, and regional offices.  Support is given in the



following areas:



     •  Off-site surveillance of test areas (NERC).



     •  Analyses to determine health impact from radionuclide



        releases (NERC).



     •  Environmental impact statement review (ORP).



     •  Development of monitoring instrumentation (NERC).
                                    C-354

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     •  Basic radiobiological research on tritium transfer  (NERC).




     •  Continuing review of old and new Plowshare concepts and




        programs CORP).




     •  Review and promulgation of radiation standards and protective




        action guides (ORP).




     Activities at NERC are funded by the AEC.  In FY 1972 the program




was funded to 16.3K for a 1.5 man-year effort.  The FY 1973 budget is




for 30.OK with a 2.0 man-year level of effort.  No funds are currently




budgeted for FY 1974.  Activities at ORP have been conducted by personnel




from the Technology and Impact Review Branch without special Plowshare



funding to date.




     If the experimental phase shows the gas stimulation program to



be safe and economically and technically feasible, a full field develop-




ment phase may follow.  This may include development of gas fields




throughout the Rocky Mountain area where it is currently estimated




there are 300 trillion standard cubic feet of potentially recoverable




gas in place.  Assuming full field development is initiated in the 1970's,




stimulation activities could continue through this century with the




stimulated wells producing for 50 or more years.




     It is not possible at this point to accurately assess the impact




of full field development due to uncertainties in its growth rate and




to serious voids in scientific and technological data.  All proposed




uses of the gas, whether in domestic heating or in commercial electric




generators, would result in atmospheric releases of the radionuclides
                                C-355

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 H-3 and Kr-85.   These  releases would not be large  in relation to  the




 total  atmospheric  inventories of  these nuclides.   A program of 1,000




 wells  would, however,  involve the use of hundreds  of megatons of




 nuclear explosives and leave a vast inventory of nonvolatile radio-




 nuclides.   In addition, these same explosives could  cause  serious




 physical and seismic damage to the surface and subsurface  environment.




 The ultimate fate  of these nonvolatile radionuclides is not yet known




 with certainty,  and they represent, because of possible communication




 with overlying aquifers, a potential long-term environmental hazard.




     Other  Plowshare programs could become active  in the future, and




 some would  involve the deep detonation of nuclear  explosives.  In




 particular, activity is anticipated in the areas of  deep well disposal




 of  radioactive waste,  in in situ  oil shale retorting and in in situ




 leaching of ore  bodies.  The environmental impact  of these  activities



 is  as yet undefined.




     It has been estimated that under conditions of  uninhibited growth




 the full Plowshare program would  involve as many as  2000 detonations



 in  the present decade.




     To limit the environmental impact of these activities,  EPA must




 increase its present activities and initiate new activities.  Partic-




ularly prominent in this latter group will be efforts in the  area of




 criteria and standards.  To support these activities, efforts will be




made to fill present voids in technological, scientific, and  economic



data.
                               C-356

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     Efforts will be directed primarily toward providing a basis for




EPA policy and guidance in the area of gas stimulation.  Background for




these judgments must reflect careful consideration of the benefits




and risks of the total stimulation problem, including its relationship




to the U.S. energy policy.






LEGISLATIVE STATUS



     The basic legislation controlling this activity is the Atomic




Energy Act of 1954 (AEA-1954).  It is believed that this Act restricts



the AEG to participate only in research, development, or demonstration




programs.  If this is correct, full commercial use of the stimulation



technique must await an amendment to the 1954 AEC act.  (Hosmer Bill,



HR-12919).  EPA can, in principle, influence the development of the




Plowshare program by taking part in the Hearing on this Bill.



     The gas produced by the stimulation technique is considered a by-




product material by the AEC.  Since present AEC exempt classifications



do not include this product, changes in 10 CFR Fart 30 will be required.




Rocky Mountain Natural Gas Company is expected to file an application




with the AEC by January 1, 1973, for the sale of Rulison gas, and thereby




force a decision regarding this regulation.




     The statutory basis for EPA activity in this area rests with



authority transferred in Reorganization Plan No. 3.  Authority transferred



from the AEC permits EPA to "set generally applicable environmental




standards."  Authority transferred from FRC permits EPA to recommend to




the President guidance for all Federal agencies in the formation of
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 radiation  standards.  Other transferred FRC functions  include  the




 establishment  and  execution of programs of cooperation with States.






 COORDINATION




 Interagency




     State




     The most  basic and possibly most important coordination begins




 at  the state level.  Federal agencies may plan and industry may




 promote, but no Plowshare or nuclear gas stimulation project can be




 conducted  without  the consent of the state's legislature and governor.




 The state  judiciary often reviews such projects to ensure compliance




 with state laws and regulations.  Although significant roles in sur-




 veillance, monitoring, and radiation safety programs may rest with the




 AEG, its safety contractors, and with commercial safety contractors




 engaged by industry, the principle radiation safety programs will in




 many cases remain under state health authroities.  Coordination on




 technical  affairs is often required with many specialized state agencies




 such as the state geological survey, state bureau of mines,  and the



 state office of oil and gas.




     Federal




     Coordination with the federal government on Plowshare  and nuclear




 gas stimulation projects can run the gamut from the President and Congress




 to any one of approximately forty executive departments, independent




agencies, and special offices  and councils of the executive branch.




Decisions by the National Security Council or the Office of  Science and
                                C-358

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Technology can determine whether the nuclear stimulation of gas is in




the national interest.  EPA/ORP's coordination on Plowshare will be




most extensive, however, with the AEG and the Department of the Interior.




     Coordination with the AEC occurs from beginning to end of all




Plowshare projects.  The AEC acts as the official sponsor and technical




expert on nuclear affairs to the public and industry for the federal




government.  From project design to environmental impact statement




preparation to post-shot safety evaluation to sale of gas, EPA/ORP



will be in constant contract with the AEC.




     Coordination with the Department of the Interior may occur at




all levels and can occur from shortly after project design to project




end.  Part of this close interrelationship is based on Interior's




control of land; part is based on the "enviro-technical" agencies within




Interior.  Most of the gas-bearing formations considered suitable for




nuclear stimulation underlie government-owned land in the western United



States which is controlled or administered by the National Park Service,




Bureau of Land Management, Bureau of Reclamation, or Bureau of Indian




Affairs — all of Interior.  Many of the environmental and technical




assessments and studies necessary before any Plowshare project can be




executed may be made by services or bureaus within Interior such as




Bureau of Sport Fisheries and Wildlife, Office of Coal Research,



U.S. Geological Survey, and Bureau of Mines.




     Other External Organizations




     EPA/ORP's coordination and contact with other external organizations




is wide and varied.   The United States, in its "Atoms for Peace" program,
                                  C-359

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has promised to help promote the peaceful uses of nuclear energy.




EPA/ORP's coordination with the International Atomic Energy Agency and




other United Nations organizations will be required in establishing




international radiation release standards, in making benefit/risk




assessments of proposed Plowshare projects, dose assessments, and



environmental and geological impact assessments for Plowshare projects




of international scope or for developing countries.  EPA/ORP may engage




universities, private laboratories, or industrial contractors on a



contractural basis to collect data, assess certain problems, to conduct




surveillance and monitoring, or to make laboratory analyses.  In



addition, EPA/ORP are often contacted by and must react with private



citizens' groups, such as the Sierra Club and Colorado Committee for



Environmental Information, on matters pertaining to safety and environ-



mental impact of certain Plowshare projects.  Coordination with the




industrial sponsor of a Plowshare project is continuing and may include:




furnishing guidance on safety criteria, radiation release standards, and



data which will be required for safety analyses; making impact and



safety reviews; and following project development and data acquisition.




Intra-Agency



     Present EPA Plowshare efforts require intra-agency coordination



between ORP, OKM, and the Regional Offices.  This coordination, to




date, has been related primarily to the review of EIS (Environmental




Impact Statements).  Coordination is required between ORP and ORM/NERC



so that EIS reviews reflect current monitoring data and research results.



ORM personnel have also directly participated in the preparation of EIS's.
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     Future EPA programs will require an expansion of coordination efforts,




and particularly with ORM.   Research and development programs sponsored




by ORP will require close coordination with ORM to insure a timely




development of data.   Coordination in the development of standards will



be treated mainly through the existing mechanism of working groups and



steering committees.   Particular attention in the standards area-must,




however, be given to the coordination of activities with those of Air



and Water Programs.  The development and implementation of an expanded




surveillance and monitoring program will necessitate greater ORP-




Regional coordination.  Regions VIII and IX will be involved most




directly.



     Within ORP, continuing coordination of the Plowshare Program




activities with other Divisional commitments will be required to meet




manpower requirements.






ALTERNATIVE APPROACHES



     Seceral alternatives are available that will permit EPA/ORP to




achieve  (in varying degrees) its objective of limiting the impact of



Plowshare activities.  These alternatives and their consequences are



described briefly in the following paragraphs.  Two of the alternatives




are developed in detail in previous sections of  this document.



     Alternative I (Status Quo) is a continuation of tue present, largely




passive, EPA effort in this area.  The program is confined in scope




to gas stimulation and limited in activity to EIS reviews and in  the



conduct  of an AEC funded site monitoring program.  The program  represents
                                    C-361

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the absolute minimum of effort that EPA can expend and meet its delegated




responsibilities.  The program offers weak control over the impact of




present Plowshare activities.   The program would be incapable of main-




taining control if planned Plowshare expansions take place.




     Alternative II is for EPA/ORP to gain, through an unrestricted




commitment of its resources,  total control over the impact of the entire




Plowshare program.  This alternative implies that all existing voids in




knowledge be filled in the minimum time.   To accomplish this, the bredth,




depth, and schedules of the data base would be controlled by EPA/ORP.




The degree of control sought  here would also require that EPA gain




direct control over compliance assessment and the enforcement of its




radiation standards.  This alternative not only allows the EPA to meet




its delegated responsibilities but to do so through policies based on




a minimum of uncertainties.




     Alternative II is for EPA/ORP to embark on a program to gain




positive control over the impact of Plowshare activities in a way




designed to minimize the commitment of ORP personnel.  As a minimum




this would require EPA to fill existing information voids and control




compliance assessment.  The commitment of EPA personnel would be




minimized by  (1) relaxation of time schedules for accumulation of




the information base and (2)  through the use of outside agencies and




contractors where possible to collect data.




     Alternative IV would be for EPA to gain its objectives through




largely legislative channels.   Specifically, EPA would seek legislative




authority to halt proposed Plowshare programs until all questions
                                 C-362

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regarding justification and impact of a given program were resolved




to the Agency's satisfaction.   This alternative shifts the burden of




proof to the AEC and the industrial sponsors.  Under such an approach




ORP would be required to maintain expertise in the program area to




evaluate programs and to produce radiation guidance for approved




activities.






OPTIMUM PROGRAM




Introduction




     At this time, EPA is actively improving its policy positions,




knowledge, and functional capabilities on Plowshare and the nuclear




stimulation of gas in response to growing development within these




fields.  Having just completed the preliminary program phase, EPA/ORP's




next moves include:  (1) completing a detailed program plan; (2) imple-




menting required operating, legislative, coordinating, and other contin-




uing functions; (3) implementing data acquisition and technical assess-




ment studies required as input for making policy decisions, setting




criteria and standards, and maintaining current levels of knowledge;




and (4) making necessary internal studies and assessments and arriving




at certain policy decisions.




     Clearly defining EPA/ORP's Plowshare program, completing the detailed




program plans, and issuing guidelines should have first priority, whether




the "Optimum" or "Proposed" program is chosen.  Responsibility for




completing guidelines and detailed program plans for each functional




area would be assigned to the  branch, division, or laboratory with the




greatest competence.  On completion, the separate documents would be
                                  C-363

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collated and edited at ORP.   Firm realistic deadlines are essential at




each step, for a timely completion of the plans and guidelines.  Even




so, the date of completion is governed somewhat by the editorial pro-




cesses (higher, lower, and external reviews) arid the post.  Presuming a




beginning date in Second Quarter, FY 1973, a realistic time table would




include completion of, and issuing guidelines by First Quarter, FY 1974,




and all EPA/ORP organizations assigned to the Plowshare program being




operational by the end of FY 1974.  The above would not preclude con-




current development of special studies, development of standards,




legislative needs, coordination, etc., for which the need is already




obvious at this time.




     The elements of EPA/ORP's program for Plowshare and nuclear




stimulation of gas have been generally categorized as continuing data




acquisition, and data analysis/decision making functions.  In several




cases, these general categories overlap.  The program elements which




fall under these three categories are discussed briefly below.  Because




it is necessary to perform the routine functions and often gather data




before arriving at decision-making, these are discussed first.




     The program elements within EPA/ORPfs Plowshare/nuclear gas




stimulation program, the milestones which have been identified for




each element, its general functional category, and the time frame for




each milestone, are shown in Figure C-43.  Several nuclear gas stimulation




projects have been or soon will be fielded and may to some degree




influence any scheduling by EPA/ORP during their program planning.
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     Certain continuing functions are dual in that they are routine




but also involve "data acquistion" or "policy/decision making."  In




example, monitoring is a continuing EPA/ORP function, but it also is




a data gathering function.  Assessment of new Plowshare concepts and




review of EIS's involve "policy/decision making," but EPA/ORP must be




preapred to perform both on a continuing "routine" basis.  The "data




acquisition" and "policy/decision making" functions are relatively




straight forward and need little explanation.  The category(s) of each



function or milestone is given in Figure C-43.




     Because of the importance of the issues, a "shortest practicable"




time table was chosen to complete all major milestones.  The time table



is shown in Figure C-43 and on the accompanying Milestone Chart.  Most




milestones are completed within a two-year time frame - by FY 1975.




However, several milestones cannot be completed so quickly.  Construction,



engineering, and technical problems could prevent completion of the



devitrification study before FY 1979.  Policy decisions on full field




development and benefit/risk analysis require evaluated data from Rio



Blanco and may accordingly be delayed beyond FY 1975.  Several other




milestones require data from Rio Blanco, and their completion dates




will necessarily be delayed if Phases I or II of Rio Blanco are delayed.




External Needs




     Legislative




     Legislative authority will be sought to enable EPA to enforce its




gas standards.  Additional legislation will be required to allow EPA to




indicate Protective Action Guides.  EPA policy with respect to the



Hosmer Amendment (HR-12919).






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     Knowledge




     EPA/ORP will rely on external sources  for  the  following information:




     •  Gas stimulation test  results (AEC-Sponsors).




     •  Device test  results  (AEG).




     •  Geological and Uydrological data CAEC,  USDI,  and States).




     •  Gas Resources  - gas amenable to  stimulation and total reserves




        (USDI, FPC,  States).




     •  Plowshare schedules and  test results  (AEG,  laboratories,




        industrial sponsors).




     •  Plans for new  Plowshare  applications  (AEC,  laboratories,




        industrial sponsors).




     •  Radioactive-waste disposal plans for  tritiated water and




        test results.




     Research and Development




     A number of tasks have been isolated for study by ORM in the




Recommended Optimum  Program.   They are:




     •  Investigate  the devitrification  of resolidified molten rock




        containing nonvolatile radionuclides




     •  The transport  of nonvolatile radionuclides  from veil cavities




        and chimneys to aquifers




     •  An independent assessment of the nuclear stimulation technique




     •  An independent assessment of present  and planned non-nuclear




        stimulation  techniques




     •  Investigation  of gas  to  man exposure  pathways for CH,T and




        dose models  for tritium
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     •  Development of improved  instrumentation for tritium monitoring

     •  Investigate reconcentration mechanisms for tritium

     e  Investigation of the biological half life of C-14.

     Enforcement and Control Requirements

     Enforcement of gas standards  and  initiation of PAG by EPA Office of

General Enforcement.

     Interagency Implementation

     General interagency implementation and coordination will be required

in this program and would include:
        Agency

        Congress

        AEC
        Dept.  of Interior
        Federal Power
        Commission


        Council on Environ-
        mental Quality

        Office of Science
        and Technology

        National Academy
        of Science

        Bureau of Mines
Area of Implemenation or Coordination

House hearing on Hosmer Amendment.

All phases of Plowshare activities.
      New Plowshare programs
      Old Plowshare programs
      EIS review
      Gas standards and gas sale
      Benefit/risk analysis.

Geologic and hydrologic assessment of sites.

      EIS review.

Gas-in-place studies.
Benefit/risk analysis.


EIS review.


Benefit/risk analysis.


Benefit/risk analysis.

Benefit/risk analysis.

Environmental impact  (oil shale).
                                   C-368

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         Agency (Cont'd)         Area of Implementation or Coordination

         Bureau of Sport
         Fisheries and
         Wildlife               Environmental impact criteria.

         States                 Surveillance and monitoring.

                                Geologic and hydrologic data.
                                Environmental data.

      In addition, the following existing programs  also require interagency

 implementation:

      •  The joint AEC/NERC  (interim) off-site monitoring program and,

      •  the on-site surveillance and monitoring activities  associated

         with Plowshare detonations.  Efforts  in both  of  these areas

         are expected  to be  coordinated with  the  ORP program related  to

         Nuclear Explosives  Testing.

 Internal Needs

      The program  requires ORP personnel  for the  following tasks:

      •   benefit risk  rationales  for Plowshare components

      e   expansion of Protection Action Guides

      •   EIS reviews

      •   coordination of research projects

      •   collation of research results

      •   development and management of surveillance program and,

      •   continuing review of technological and scientific base.

      In FY 1974, the required ORP level of effort is estimated to be 16

man-years.   An estimated  10 man-year level of effort is required in

research and study programs.
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PROPOSED PROGRAM




Introduction




     The objectives of the Proposed Program like those of the Optimum




Program are to evaluate and ultimately provide guidance to limit the




adverse impact of Plowshare activities.  This program has as major areas




of emphasis data acquisition and technology assessment, collation and




analysis, standards development, and compliance assessment.  The major




thrust in the areas will be prefaced by a detailed program analysis.




This analysis will provide documented scopes for the research and study




programs, accurate budget estimates and Request for Proposal documents.




During this phase specific task assignments will also be made.  An out-




line of the sequence of these events is shown in Figure C-44.  Work on




this analysis will not preclude activity required to meet such commitments




as the Rulison Gas Problem.




     The Proposed Program differs from the Optimum in the depth to which




certain problems are pursued, the means by which information is gained,




and the approach to compliance assessment and enforcement.




     Voids in scientific and technological data, once isolated, will be




filled primarily through research ana study contracts with outside




agencies or contractors.   Specific problem areas which have been isolated




are indicated in Figure C-44.  In general, these will not be pursued in




the same time frame as in the Optimum program.   The information base




serves the two-fold purpose of providing a basis for policy decisions




and a background for standards.
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     The compliance assessment-enforcement area has two major elements,




(1) a State surveillance and monitoring program and (2) AEC-State




based enforcement.   The State surveillance program will be developed by




EPA/ORP with OEM and regional assistance and will be EPA funded.  On-




site monitoring connected with stimulation detonations will be the




responsibility of the ORP Surveillance Program for Nuclear Explosives




Testing.  The present off-site AEC/WERL program will be examined to




determine if additional doverage with respect to radioisotopes and




pathways is required.  If additional doverage appears to be warranted




an expanded program will be developed and presented to the AEG.




     Paralleling these activities will be the development of benefit-




risk rationales for the Plowshare components.  Of immediate concern




will be the basis for gas standards.  The issue of an interim standard




for Rulison gas will be addressed during FY 1973.  Decisions on this




standard will be based largely on existing data.  Benefit-risk balancing




for full commercial use of the stimulation technique will, however,




reflect inputs from research and study contracts and field experiments.




External Needs




     Legislative




     Apart from having EPA policy reflected in the Hosmer Amendment, no




legislative requirements have been identified.




     Knowledge




     EPA/ORP will require the following external knowledge:




     •  Gas stimulation test results




     •  Device test results
                                C-372

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     •  Geological and hydrological test results




     •  Gas resource data




     •  Plowshare schedules




     •  Plans for new Plowshare applications




     •  Radioactive-waste storage-disposal plans (particularly




        tritiated water) and test results




     Research and Development




     The R&D requirements of this program together with the groups




designated to fill them are as follows:




     •  The devitrification of resolidified molten rock containing




        nonvolatile radionuclides (by contractor)




     •  The transport of nonvolatile radionuclides from well cavities




        and chimneys (by contractor)




     •  An independent assessment of the nuclear stimulation




        technique (by contractor)




     •  An independent assessment of existing and proposed non-




        nuclear stimulation techniques (by contractor)




     •  Investigation of gas to man exposure pathways for CH_T




        and tritium dose models (by ORM)




     •  Investigate reconcentration mechanisms for tritium (by ORM)




     •  The development of improved instrumentation for tritium




        monitoring (ORM)




     Enforcement and Control Requirements




     Enforcement of EPA standards will rest primarily with the AEC




and States.  Detailed programs for enforcement with authority designa-




tions will be required.
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      Interagency Implementation




      In addition to the general implementation noted in  the Optimum




 Program, the Proposed program calls for State implementation of an




 off-site surveillance and monitoring network.  This portion of the pro-




 gram  will be coordinated through Regions VIII and IX.




      On-site surveillance during the detonation will continue to be




 implemented by the AEC.  The interim off-site monitoring program will




 also  be implemented by the AEC.  In both cases these efforts will be




 conducted through interfacing with the ORP Surveillance Program for




 Nuclear Explosives Testing.




 Internal Needs




      The proposed program requires the commitment of ORP personnel for




 the following:




      •  Establishment of benefit rationales for Plowshare components.




      •  The preparation of EIS reviews.




      •  The development and coordination of an ORP/State surveillance




        and monitoring program.




      •  The monitoring of research/study contracts and the collation




        of results.




      •  The development of standards.




      •  A continuing review of Scientific and Engineering literature.




     The Proposed Program requires direct ORP participation in six




 functional areas.  It is estimated that a 10 man-year level of effort




will be required within ORP during FY  1974.  Funding to support a 7-8




man-year reserach and development  effort in FY 1974 will also be
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required.   In FY 1975 the ORP manpower  commitment is expected to remain




at 10 positions although increased research funding will be required.






COMPARISON OF THE OPTIMUM AND PROPOSED  PROGRAMS




     The relative impact of the Proposed  Program is measured in terms




of the depth, timeliness, and EPA control available in the program's




milestones.  The same data base is sought in both programs.  The Proposed




Program will accumulate data more slowly  and will attack certain pro-




blems in less depth.   The Proposed Program will have, therefore, at any




given time a less extensive data base.  The existence of greater




uncertainties resulting from this could lead to more conservative




EPA/ORP positions and standards.  This  will also lead to some decisions




being delayed relative to their schedules in the Optimum Program.  In




particular the policy decision regarding  an interim standard for Rulison




gas will be delayed several months.  This delay will reduce the amount




of time available for EPA/ORP to influence possible 10 CFR 30 changes.




     The relative impact of the State surveillance and monitoring program




can be expected to manifest itself primarily as a loss in the uniformity




of compliance assessment.  The absence of enforcement authority in the




Proposed Program can be expected to lead  to reduced effectiveness in




gaining compliance with EPA standards,  particularly in terms of the time




required.  The relatively low EPA profile in this portion of the program




which interfaces most directly with the public could lead to some loss




of public confidence in whether environmental considerations are being




adequately addressed.
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MEASURES OF GOAL ATTAINMENTS




     The overall objective of the Proposed Program is to control the




environmental impact of Plowshare activities.  Specific milestones that




will be accomplished are:




     1.  An improved model for the gas-man exposure pathway for CH~T.




     2.  Hydrological data regarding the transport and ultimate




         disposition of nonvolatile radionuclides.




     3.  Development of improved instrumentation for monitoring tritium.




     4.  An independent assessment of the nuclear stimulation technique.




     5.  Independent assessment of methods of HTO disposal.




     6.  An EPA/State surveillance and monitoring program.




     7.  EPA guidance for the use of nuclearly stimulated natural gas.




     8.  A technically sound EPA policy regarding gas stimulation.




     9.  EPA policy reflected in modification to 10 CFR 30 and




         amendments to the Atomic Energy Act.




    10.  An expanded data base regarding the effects of Nuclear




         Explosives Testing.




     The accomplishment of the overall objective of the program will be




measured by the degree of compliance with EPA/ORP standards and guidelines




that is achieved.  The accomplishment of the scientific and technological




programs can be measured by their acceptance by the scientific and




engineering communities.
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