NATIONAL RADIATION PROTECTION
PR06RAM
APPENDIX C - PROBLEM AREAS
OFFICE OF RADIATION PROGRAMS
ENVIRONMENTAL PROTECTION AGENCY
OCTOBER 1972
-------
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 C208
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
-------
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
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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.
C-l
-------
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
-------
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)
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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-ofcoolant 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.
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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.,
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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
-------
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.
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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.
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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
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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
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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.
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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
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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 FT71
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
-------
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
-------
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
-------
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
-------
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
-------
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
areasand 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
-------
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
-------
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
-------
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
-------
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
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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:
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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.
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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.
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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
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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.
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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
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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,
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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,
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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.
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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.
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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:
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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
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PAGE NOT
AVAILABLE
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.
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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
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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
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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
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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.
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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
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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
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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
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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
-------
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
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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 (DT 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
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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
-------
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.
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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
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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.
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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.
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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.
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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 (alphanumeric, 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
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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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PAGE NOT
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
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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 areasmining 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
-------
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
-------
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 's1>£ 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
-------
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.
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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
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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
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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 subelements 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.
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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.
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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.
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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
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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.
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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
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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.
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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.
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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
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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
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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
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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.
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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
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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.)
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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
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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.
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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
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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
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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
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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.
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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'
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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
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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
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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,
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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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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.
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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
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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
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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.
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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
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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
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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
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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-\
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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
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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
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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.
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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
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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.
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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-
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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.
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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
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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.
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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
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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
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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.
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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.
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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
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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
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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.
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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
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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
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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
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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
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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
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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)
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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
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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.
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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.
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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.
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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
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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.
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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
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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.
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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.
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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
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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.
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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,
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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.
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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
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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
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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
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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 radioactivityand 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
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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
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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
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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
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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.
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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
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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
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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
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DELETED
C-324 through C-325
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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
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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
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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.
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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.
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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.
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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 beperformed 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.
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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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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.
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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.
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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
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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).
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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
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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
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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
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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
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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,
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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).
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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
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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.
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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
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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,
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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
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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
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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
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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.
C-364
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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).
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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
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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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