ECONOMIC IMPACT ANALYSIS FOR THE PROPOSED
REPORTABLE QUANTITY ADJUSTMENTS FOR RADIONUCLIDES UNDER
SECTION 102 OF THE COMPREHENSIVE ENVIRONMENTAL
RESPONSE, COMPENSATION, AND LIABILITY ACT
A Report to the
EMERGENCY RESPONSE DIVISION
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Prepared by
ICF INCORPORATED
under subcontract to
Combustion Engineering, Inc.
EPA Contract 68-03-3182
December 1986
ICF INCORPORATED International Square
1850 K Street, Northwest, Washington, D. C. 20006
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D C. 20460
APR _ 8 BUT
OFFICE OF
SOLID WASTE AND EMERGENCY
MEMORANDUM
SUBJECT: Publication of Proposed Reportable Quantity (RQ) Adjustment
Regulations for CERCLA Potential^Earcino|Jen^andb ftadioiiuclides
FROM: Timothy Fields, Jr., Di rector
Emergency Response Division (WH-548/B)^ IT
TO: EPA Regional Libraries
On March 16, 1987, the Agency published two regulations proposing RQ
adjustments for potential carcinogens and radionuclides in accordance with
section 102 of the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended (see 52 FR 8140-8186). Attached
for your information are copies of the Federal Register notice and the
technical and economic background documents for each proposed rulemaking.
The public comment period for both proposed rules is scheduled to end
on May 15, 1987. Please make the £R Notice and technical and economic
background documents available to the interested public upon request. If
infortion, P^ase contact Dr. K. Jack Kooyoomjian at
no 1,5; : (carcinogen regulation) or Ms. Barbara Hostage at (202)
382-2198 (radionuclides regulation).
Attachments
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ECONOMIC IMPACT ANALYSIS FOR THE PROPOSED
REPORTABLE QUANTITY ADJUSTMENTS FOR RADIONUCLIDES UNDER
SECTION 102 OF THE COMPREHENSIVE ENVIRONMENTAL
RESPONSE, COMPENSATION, AND LIABILITY ACT
A Report to the
EMERGENCY RESPONSE DIVISION
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Prepared by
ICF INCORPORATED
under subcontract to
Combustion Engineering, Inc.
EPA Contract 68-03-3182
December 1986
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TABLE OF CONTENTS
Page
CHAPTER 1: BACKGROUND AND INTRODUCTION 1-1
1.1 Background on CERCLA and RQ Notification Requirements l-l
1.2 RQ Adjustments for Radionuclides 1-2
1.3 Organization of This Report 1-4
CHAPTER 2: ALTERNATIVE APPROACHES CONSIDERED FOR ADJUSTING
RADIONUCLIDE REPORTABLE QUANTITIES 2-1
2.1 Establishment of a Dose-Equivalent Level as the
Radionuclide RQ 2-2
2.2 The Selected Approach -- Setting RQs in Terms of Activity
Levels 2-3
CHAPTER 3: BASELINE REPORTABLE RELEASES 3-1
3.1 Baseline Definition 3-1
3.2 Availability Data Sets for Estimating Radionuclide Releases... 3-3
3.3 Estimation of Historical Radionuclide Releases 3-5
3.3.1 Total Number of Annual Releases of Radionuclides 3-7
3.3.2 Frequency of Release for a Particular Radionuclide .... 3-14
3.3.3 Size Distribution of Releases 3-14
3.4 Baseline Reportable Release Estimation 3-17
CHAPTER 4: VALUATION OF THE EFFECTS OF THE PROPOSED RQ ADJUSTMENTS ... 4-1
4.1 Actions Taken With a Reportable Release 4-1
4.1.1 Actions Undertaken By the Regulated Community 4-1
4.1.2 Actions Undertaken by the Government 4-2
4.1.3 Incremental Actions Attributable to the Radionuclide
RQ Adjustments 4-3
4.2 Valuation of Costs 4-4
4.2.1 Value of Actions Performed by Regulated Parties 4-4
4.2.2 Value of Actions Performed by the Government 4-7
4.3 Valuation of Benefits 4-10
CHAPTER 5: ESTIMATED ANNUAL COSTS OF THE PROPOSED RQ ADJUSTMENTS 5-1
5.1 Estimated Change in the Number of Reportable Releases 5-1
5.2 Estimated Costs of the Proposed RQ Adjustments 5-2
5.3 Firm-Level Economic Effects 5-5
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TABLE OF CONTENTS (continued)
Page
CHAPTER 6: ESTIMATED BENEFITS OF THE PROPOSED RQ ADJUSTMENTS 6-1
CHAPTER 7: SENSITIVITY ANALYSIS 7-1
7.1 Concepts and Key Variables 7-1
7.2 Results of the Sensitivity Analysis 7-3
7.3 Statistical Analysis of Radionuclide Data Base 7-5
7.4 Summary 7-6
APPENDIX A: PROFILES OF FACILITIES THAT RELEASE RADIONUCLIDES A-l
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LIST OF EXHIBITS
Page
3-1 Radionuclide Data Base Characteristics 3-6
3-2 Profile of Releases in Nuclear Regulatory Commission AEOD
Data Set 3-9
3-3 Frequency of Release for Radionuclides in Data Base 3-15
3-4 Size Distribution of Radionuclide Releases in Data Base 3-18
4-1 Release Scenarios 4-8
5-1 Calculations of Annual Costs of RQ Adjustments Under the
Proposed Regulation 5-3
6-1 Radionuclides With Proposed RQ Greater Than One Pound 6-2
7-1 Sensitivity Analysis Results 7-4
A-1 Facilities using or Producing Radionuclides A-ll
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CHAPTER 1
BACKGROUND AND INTRODUCTION
The purpose of an Economic Impact Analysis (EIA) is to estimate the
incremental costs and benefits resulting from a regulatory action. Any
regulation requiring behavior changes will usually result in some elements of
society which will benefit from the regulation and some elements of society
which will incur costs. An EIA analyzes those benefits and costs and
estimates the net gain or net loss under the proposed regulation.
This chapter describes the general reporting requirements under Sections
103(a) and (b) of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) and describes the reporting requirements for
radionuclides m particular. It explains the purpose of the proposed
regulation and introduces this report to the reader. Section 1.1 describes
CERCLA reporting requirements and the ranges of potential response activities
triggered by CERCLA reporting; Section 1.2 describes the statutory authority
for and the intended purpose of the RQ adjustment for radionuclides; and
Section 1.3 describes the remaining chapters of this report.
1.1 BACKGROUND ON CERCLA AND RQ NOTIFICATION REQUIREMENTS
The Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (CERCLA) establishes broad federal authority to respond to releases or
threats of releases of hazardous substances from vessels and facilities. The
Act requires immediate notification to the National Response Center when a
hazardous substance designated under CERCLA is released into the environment
in an amount equal to or greater than the reportable quantity (RQ) for that
substance.
Section 101(14) of CERCLA defines as a CERCLA hazardous substance any
substance designated under:
Sections 307 and 311 of the Clean Water Act;
Section 3001 of the Resource Conservation and
Recovery Act;
Section 112 of the Clean Air Act; and
Section 7 of the Toxic Substances Control Act.
In addition, the Environmental Protection Agency (EPA) has the authority under
Section 102 of CERCLA to designate additional hazardous substances.
Currently, there are 717 CERCLA hazardous substances. Section 102(b) of the
statute establishes a one-pound RQ for each of these substances, except those
for which an RQ was established pursuant to Section 311 of the Clean Water
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Act. Section 102(a) of CERCLA authorizes EPA to adjust statutory RQs by
regulation.1
Under regulations implementing the general reporting requirements of
Sections 103(a) and (b) of CERCLA, a person in charge of a vessel or facility
is required to notify the National Response Center immediately when there is a
release of a designated hazardous substance in an amount equal to or exceeding
the reportable quantity (RQ) for that substance (40 CFR Section 302.6(a)).
Those persons required to notify but who fail to report immediately to the
National Response Center are subject to criminal penalties under CERCLA
Section 103(b). Releases that are federally permitted are exempt from the
Section 103 notification requirements.
The purpose of RQ notification is to alert the federal government to
releases of hazardous substances that may require rapid response to protect
public health and welfare and the environment. Under Section 104 of CERCLA,
the federal government may take response action whenever there is a release or
a substantial threat of a release of a hazardous substance or of any pollutant
or contaminant which may present an imminent and substantial danger to public
health or welfare.2 Notification based on RQs serves to inform the
government of a release, thereby enabling an evaluation of the incident and a
timely field response should one be deemed necessary. Notification does not
necessarily mean that a federal field response will occur, nor does it
eliminate liability or responsibility for response costs or natural resource
damages associated with the release.
1.2 RQ ADJUSTMENTS FOR RADIONUCLIDES
There are approximately 1800 radionuclides. A radionuclide is an element
with an unstable combination of protons and neutrons in its nucleus.
Instability is the net effect of forces between these two types of nuclear
particles. To achieve a more stable configuration, the nucleus releases
energy in the form of particles or rays by a process of decay called
radioactivity. Each radionuclide decays at a different rate and, as a result,
a pound of two different radionuclides could represent significantly different
levels of radioactivity.
1 The RQs for 340 hazardous substances were adjusted by EPA on April 4,
1985 (50 FR 13456). RQ adjustments for an additional 102 substances were
established in a final rule published September 29, 1986 (51 FR 34534).
2 Notification to the National Response Center pursuant to CERCLA
Section 103 is limited to releases of designated hazardous substances in
amounts that equal or exceed the applicable RQ. Releases consisting solely of
pollutants or contaminants that are not designated as hazardous substances
under CERCLA need not be reported to the National Response Center.
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Radionuclides are designated as hazardous air pollutants under Section 112
of the Clean Air Act and, as such, are designated CERCLA hazardous substances.
Section 102 of CERCLA establishes a one-pound RQ for radionuclides, as a
generic class of substances, but authorizes EPA to adjust the RQ by regulation
if appropriate. EPA recognizes that an RQ of one pound for radionuclides is
not appropriate in most cases because releases of less than one pound may
present a substantial hazard to public health and welfare and to the
environment. In addition, "pound" units for measuring radionuclides are not
commonly used for the purpose of radiation protection.
All other CERCLA hazardous substances have RQs in units of pounds, ranging
from one pound to 5000 pounds. For these substances, the principal health
concerns are chemical toxicity, ignitability, reactivity, or potential
carcinogenicity, which may be related to some number of pounds released of the
hazardous substance. Radionuclides are different in this respect from other
CERCLA hazardous substances. The principal health hazard associated with
exposure to radionuclides is carcinogenicity, but the hazard is related more
closely to the radioactivity emitted rather than the mass of the substance.
Although the level of radioactivity is directly proportional to the mass
(i.e., the number of pounds) of the radionuclide released, activity levels are
generally used as indicators of radiation hazard. The quantity of
radioactivity is measured in units of curies3 (Ci) and, for each
radionuclide, the same number of pounds translates into a different number of
curies. Thus, the statutory one-pound RQ translates into a wide range of
curies for different radionuclides, covering twenty orders of magnitude.
Besides curies, another widely used radiation measurement is the Roentgen
Equivalent Man (rem).k The rem is a unit measure of radiation dose and is
often expressed as some number of rem to a specific organ such as the lungs,
thyroid, or whole body. The difference between curies and rem is that the
latter considers the routes of exposure and biological effects and, therefore,
directly reflects the levels of tissue damage. Curies can be converted into
rem by identifying the radionuclide, mode and duration of exposure, quantity
of intake, tissues most acutely affected, and other factors.
The nuclear industry generally works with units of curies and rem and, in
fact, most existing reporting triggers for radionuclide releases are expressed
in terms of one of these two units. In addition, essentially all existing
regulations and controls established by the Nuclear Regulatory Commission and
the Department of Energy, which govern a major portion of the nuclear industry,
are based in units of curies or rem. Therefore, in order for the RQ under
CERCLA to be consistent and meaningful, and to ensure that the radionuclide RQ
3 The curie is a measure of the rate of radioactive decay, with one
curie equal to 3.7 x 1010 disintegrations per second.
"Radiation measurements can also be expressed in international metric
units of becquerels or sieverts, however, these terms are less common in the
United States.
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allows for timely reporting and timely field response, if necessary, the
statutory one-pound RQ is being adjusted in a proposed regulation.
The proposed RQs are in units of curies and are not uniform across all
radionuclides. The Agency is proposing to divide radionuclides into seven RQ
groups: 0.001 curie, 0.01 curie, 0 1 curie, 1 curie, 10 curies, 100 curies,
and 1000 curies. The Agency is proposing RQs for 757 individual radionuclides
for which there are metabolic data presented in the International Commission
on Radiation Protection (ICRP) Report Number 30. The Agency is also proposing
an RQ for all radionuclides not listed by the ICRP. These other radionuclides
have a proposed RQ of 1 curie for the entire class.
For most radionuclides, the proposed RQ adjustments would require
reporting releases that are considerably smaller than one pound. The proposed
regulation, therefore, will impose additional reporting and report processing
costs on the regulated community and the government respectively. This
analysis discusses and quantifies, to the extent possible, the costs and
benefits that will result from the proposed RQ adjustments.
1.3 ORGANIZATION OF THIS REPORT
This report analyzes the economic effects of the proposed RQ adjustments
for radionuclides. It analyzes the costs and benefits and estimates the net
gain or net loss under the proposed regulation. The remainder of this report
is organized as follows:
Chapter 2 -- Alternative Approaches Considered for
Adjusting Radionuclide RQs -- a discussion of the
regulatory options considered during the proposed rulemaking
development process;
Chapter 3 -- Baseline Reportable Releases -- an analysis
of baseline (pre-regulatory) reportable releases, including
a discussion of available release data, size distribution of
releases, and the estimated number of baseline reportable
releases;
Chapter 4 -- Valuation of the Effects of the Proposed RQ
Adjustments -- an explanation of the unit values used in
estimating the incremental costs and benefits of the
proposed regulation;
Chapter 5 -- Estimated Annual Costs of the Proposed RQ
Adjustments -- an analysis of the additional costs that
would be incurred by both the regulated community and
government as a result of the proposed regulation;
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Chapter 6 -- Estimated Benefits of the Proposed RQ
Adjustments -- a qualitative assessment of the additional
benefits under the proposed regulation;
Chapter 7 -- Sensitivity Analysis -- a test of the
assumptions used throughout this report to determine
sensitivity of the results to various assumptions; and
Appendix A -- Profiles of Facilities that Release
Radionuclides -- a general discussion of the types and
number of facilities that potentially release radionuclides.
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CHAPTER 2
ALTERNATIVE APPROACHES CONSIDERED FOR ADJUSTING
RADIONUCLIDE REPORTABLE QUANTITIES
Radionuclide production and use in the United States is presently
regulated and controlled by the Nuclear Regulatory Commission and the
Departments of Energy and Transportation. These agencies were asked by EPA to
participate actively in an interagency work group1 whose purpose was to
explore the relative advantages and disadvantages of alternative approaches
for adjusting the radionuclide RQ. The work group carefully considered
numerous RQ adjustment options including:
Option 1: Allowing the radionuclide RQ to remain at
one pound;
Option 2: Assigning no RQ to radionuclides;
Option 3: Establishing a dose-equivalent level (i.e.,
units of rem) as the radionuclide RQ;
Option 4: Establishing a single level of activity as
an RQ for all radionuclides;
Option 5: Grouping radionuclides into categories and
assigning an RQ in terms of activity to each category;
and
Option 6: Establishing an RQ for individual
radionuclides based on activity levels (i.e., units of
curies).
The option of leaving the RQ at one pound was rejected because pound units
are not meaningful for radiation protection and a quantity of one pound often
represents potentially high levels of radiation contamination. The second
option, establishing no RQ for radionuclides, was rejected because it would
have to be supported by a finding that existing reporting requirements
adequately cover releases of all radionuclides, and, at present, EPA could not
make such a finding. In particular, many releases of naturally occurring and
accelerator produced radionuclides (NARM) are not required to be reported
under existing federal regulations, and many existing reporting requirements
do not require immediate telephone notification.
Option 3 was seriously considered as it is presently the basis of existing
reporting requirements by the Department of Energy and the Nuclear Regulatory
lWork group membership also included representatives from the U.S. Coast
Guard and several offices within EPA.
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Commission. It was determined, however, that this reporting option required
too much judgment on the part of the person in charge of the facility or
vessel and, for purposes of CERCLA reporting, may not produce timely reports.
Option 4, establishing a single level of activity for all radionuclides, and
Option 5, grouping radionuclides using specific criteria and assigning
activity-level RQs to each group, were determined to be inappropriate because
neither option accounted for the varying degrees of hazard posed by the same
activity level of different radionuclides. These options would not have
required radionuclide by radionuclide evaluation to develop an RQ, but rather
would have required analysis of large groups of radionuclides based on a
single characteristic. Because of the lack of homogeneity among
radionuclides, grouping the radionuclides into meaningful categories for
purposes of RQ development became difficult.
EPA ultimately selected in the proposed regulation the last option,
establishing a proposed RQ based on activity levels for selected
radionuclides. This final option involved an analysis of individual
radionuclides, evaluating their individual characteristics to determine
appropriate proposed RQs. Ultimately, all radionuclides were grouped into one
of seven RQ categories, but only after completion of the individual
radionuclide evaluations.
This chapter discusses briefly options 3 and 6, the two adjustment options
considered most seriously for determining radionuclide RQs. The chapter
begins with a discussion of the relative advantages and disadvantages of
establishing dose-equivalent levels as the radionuclide RQ. The chapter then
discusses the selected option, assigning proposed RQs based on the activity
levels of individual radionuclides.2
2.1 Establishment of a Dose-Equivalent Level as the Radionuclide RQ
EPA explored the option of establishing a radionuclide proposed RQ based
on a single dose-equivalent level or a set of dose-equivalent levels assigned
to all radionuclides. A dose equivalent is a direct measure of the amount of
biological damage resulting from exposure to ionizing radiation. Dose
equivalent is measured generally in terms of rem or sieverts. A
dose-equivalent level is not a measure of emitted radiation, but is a method
of normalizing the effect of an absorbed dose of radiation in tissue,
regardless of the type of radiation. It is therefore useful from a health and
environmental protection perspective because the number of rem can be related
directly to the amount of damage likely to be incurred. The Agency seriously
considered establishing a proposed RQ for radionuclides in terms of rem
because most reporting requirements of the Nuclear Regulatory Commission and
the Department of Energy are in terms of rem.
2The other adjustment alternatives not specifically presented in this
chapter are discussed in depth in: ICF, Incorporated and Environmental
Monitoring & Services, Inc., Technical Background Document to Support
Rulemaking Pursuant to CERCLA Section 102: Radionuclides, Report to the
Environmental Protection Agency, Office of Solid Waste and Emergency Response,
October 1986.
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To assign proposed RQs in terms of dose equivalent or rem, the Agency
first had to determine which dose-equivalent level is most appropriate for a
radionuclide RQ. Several agencies of the U.S. Government and other national
and international organizations have developed different estimates of the
appropriate dose-equivalent level. Many of these dose-equivalent levels vary
substantially. For example, the Federal Radiation Protection Guidance
recommends a limiting exposure of 500 millirem per year for the general public
and the ICRP recommends a limit of 5 rem per year for employees of nuclear
facilities. EPA established an annual dose-equivalent level of 4 millirero per
year in 40 CFR Part 141 (promulgated under the Safe Drinking Water Act).
Therefore, there did not appear to be a universally accepted dose-equivalent
reporting trigger for use under CERCLA.
A second major issue faced by the Agency when considering this alternative
involved the development of a standardized methodology for estimating
dose-equivalent levels. A standardized methodology was considered desirable
because a dose equivalent is not measurable directly. For a given release,
different judgments regarding exposure pathways, intake quantity, and other
factors could lead to different dose-equivalent estimates and, thus, different
determinations of whether the release is reportable to the National Response
Center under CERCLA.
The advantages of establishing radionuclide RQs based on dose-equivalent
levels are twofold. First, a dose-equivalent value can be related directly to
potential health effects without having to make further assumptions or
performing additional calculations. Second, a dose-equivalent level RQ could
be established for all radionuclides, including mixtures, because one RQ level
would suffice for all radionuclide releases.
The disadvantages of the option, however, were perceived to be
substantial. Among the primary disadvantages was that estimating a
dose-equivalent level can be quite complicated and its magnitude may vary
substantially for different circumstances involving the release of the same
amount of the same radionuclide. For example, different exposure pathways,
periods of exposure, and bodily organs exposed may yield order-of-magnitude
differences in dose-equivalent estimates for the same release quantity.
Moreover, dose-equivalent levels would be more difficult than an activity
level to estimate quickly during an actual release event.
For these reasons, the Agency decided to remove the dose-equivalent
alternative from further consideration, favoring instead the determination of
proposed RQs for individual radionuclides based on activity levels.
2.2 The Selected Approach -- Setting RQs in Terms of Activity Levels
The Agency ultimately decided to propose radionuclide RQ adjustments based
on levels of activity. A level of activity, in units of curies (or
becquerels), is a measure of the rate of radioactive decay and thus the amount
of radiation given off by a substance.
There are several advantages to basing radionuclide RQs on activity
levels. For example, a level of radioactivity is much easier to measure than
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a dose equivalent. A common survey instrument such as a Geiger counter can be
used to measure directly the ionizing radiation. The Agency believes setting
RQs in terms of activity would, therefore, provide more timely reporting than
an RQ expressed in terms of dose equivalent.
A second advantage of using activity levels is that establishing RQs for
radionuclides individually would allow consideration of individual
radionuclide characteristics (e.g., nuclide forms and the potential to migrate
through the environment). An RQ in terms of dose equivalent (rem) would also
(by definition) have considered nuclide form and migration but would have left
much greater judgment to the person in charge of the vessel or facility.
Activity level RQs (curies) also consider each radionuclide individually but
minimizes judgments by the person in charge of the vessel or facility. The
option to establish RQs in terms of curies, therefore, was considered
advantageous.
The nuclide-specific RQ approach also has disadvantages however.
Primarily, unlike a dose-equivalent value, a level of activity by itself does
not necessarily reflect a level of danger to human health. As is presently
the case for RQs for non-radioactive substances, a case-by-case evaluation by
the On-Scene Coordinator will be necessary to estimate the health and welfare
and environmental hazards associated with a radionuclide release, and to
determine if a federal response is required.
The general methodology used by the Agency to develop proposed RQs began
with the ALIs listed in ICRP's Publication 30. These values are annual intake
limits, in units of curies, that would result in radiation exposure of 5 rem.
The ALIs were adjusted by EPA to reflect (1) the difference between intake
levels and release levels and (2) a lower dose equivalent of 500 millirem (0.5
rem), a more protective release level. Using conservative assumptions
regarding different releases to air and water, and analyzing exposure through
inhalation, ingestion, and direct exposure, EPA estimated the smallest number
of curies for each radionuclide which, if released to the environment, could
result in a person being exposed to a dose equivalent of 500 millirem.
The inhalation equation derives a Release Value by dividing the ALI for
inhalation developed by the ICRP by the product of the following factors:
° The release fraction that describes the portion of
radioactive materials that could become airborne in a
release;
° The Atmospheric Relative Concentration Value
corresponding to a ground-level relative concentration
at 30 meters from a ground-level release under stable
meteorological conditions;
° The breathing rate of "Reference Man"; and
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Several numerical factors to account for a 500
millirem dose limit for members of the general public
and the conversion from microcuries to curies.
The ingestion equation is based on a ground-water release scenario using
an advection-dispersion model combined with conservative estimates for such
parameters as ground-water flow velocities, retardation factors, and
transverse and longitudinal dispersion. The resulting equation, like the one
for inhalation, derives a Release Value by dividing the ALI for ingestion by
the product of an assumed dilution factor, contact time, and water
consumption, as well as the same numerical factors as the inhalation equation.
A set of equations were also developed to calculate Release Values for a
third route of exposure, direct exposure to a release of a radionuclide. One
direct exposure equation derives the quantity of material intercepted by
Reference Man at a distance 30 meters from a point source release, assuming
an exposure of 500 millirem. Release Values are derived by dividing the
product of the squared distance and the absorbed dose by the duration of
exposure and the product of photon energy emitted and the fraction of the
encountered radiation absorbed.
A second direct exposure equation was derived for releases of noble gases
which result in exposure by submersion in a cloud of radioactive material.
This second equation uses air concentration values rather than ALIs and,
therefore, also incorporates the Atmospheric Relative Concentration Value
mentioned above.
For each radionuclide, three Release Values were derived: inhalation,
ingestion, and direct exposure.3 To simplify the administration and
implementation of RQ reporting, the radionuclides were then assigned to seven
groups based on the lowest Release Values:
6 radionuclides (0.8%) have a proposed RQ of 0.001
curie;
25 radionuclides (3.3%) have a proposed RQ of 0.01
curie;
24 radionuclides (3.2%) have a proposed RQ of 0.1
curie;
35 radionuclides (4.6%) have a proposed RQ of 1 curie;
JFor further detail on the methodology used in developing the
radionuclide proposed RQs, see ICF Incorporated and Environmental Monitoring
and Services, Inc., Technical Background Document to Support Rulemaking
Pursuant to CERCLA Section 102: Radionuclides, Report to the Environmental
Protection Agency, Office of Solid Waste and Emergency Response.
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342 radionuclides (45.2%) have a proposed RQ of 10
curies;
242 radionuclides (31 2%) have a proposed RQ of 100
curies; and
89 radionuclides (11.8%) have a proposed RQ of 1000
curies.
In addition, radionuclides not listed by the ICRP have a proposed RQ of 1
curie. For all but 30 of the radionuclides with a specific proposed RQ
adjustment, the proposed RQ is smaller than one pound. It is expected that
the number of reportable releases for these radionuclides will increase,
resulting in notification, recordkeeping, and response costs for the affected
community and notification processing and other response costs for the
government. Increased benefits of more efficient and timely responses are
also to be expected.
For the 30 radionuclides whose proposed RQ is greater than one pound, the
number of reportable releases are expected to decrease. This should result in
lower costs to both the affected community and the government, and incremental
threats to public health and welfare and the environment. Chapter 3 begins by
discussing the baseline (pre-regulatory) reporting requirements and lays the
foundation for estimating the incremental costs and benefits resulting from
changes in the number of reportable releases under the proposed regulation.
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CHAPTER 3
BASELINE REPORTABLE RELEASES
A regulatory baseline is the starting point for any economic analysis.
The baseline provides a measurement of the estimated costs and benefits that
the affected community would incur if the proposed regulation were not to take
effect. Once the baseline has been estimated, we can then model the effects
of the proposed regulation and estimate the post-regulatory costs and benefits
incurred by society. The difference between the post-regulation costs and
benefits and the baseline represents the incremental costs and benefits of the
proposed regulation.
Baseline costs and benefits are related directly to the number of
reportable radionuclide releases with a radionuclide reportable quantity (RQ)
of one pound. The baseline costs are the values placed on actions resulting
from a reportable release and the benefits are the values placed on cleanup of
reportable releases. This chapter describes the methodology used to estimate
baseline reportable releases and presents the baseline release estimates.
Section 3.1 defines the regulatory baseline for the proposed regulation;
Section 3,2 describes the data sets available for estimating baseline releases
of radionuclides; Section 3.3 estimates the number of historical radionuclide
releases; and Section 3.4 estimates the baseline number of reportable releases
of radionuclides.
3.1 BASELINE DEFINITION
The baseline is an estimate of the costs and benefits the affected
community would incur if the proposed regulation were not to take effect. It
is related directly to the number of reportable releases under current
reporting requirements.
Many facilities that produce and use radionuclides are regulated already
by a number of different federal agencies. The Nuclear Regulatory Commission,
the Department of Energy, the Department of Transportation, and the
Environmental Protection Agency all impose reporting requirements and/or
release limitations on facilities under their auspices. In addition, local
and state license and registration programs also control the regulated
community. Each agency's reporting requirements are different, frequently
involving different time frames for reporting.
An important consideration in analyzing baseline reporting is that Section
103(a) of CERCLA requires immediate notification to the National Response
Center by the person in charge of a facility or vessel if a release equals or
exceeds an RQ. Therefore, reports to other agencies are not a substitute for
directly telephoning the National Response Center.
For purposes of this analysis, therefore, the regulatory baseline is
defined as the costs and benefits associated with reporting releases of
radionuclides to the National Response Center prior to the proposed
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regulation. Releases of radionuclides need to be reported immediately to the
National Response Center under (1) Department of Transportation regulations
(49 CFR Parts 171-177), and (2) Sections 103(a) and (b) of CERCLA.
The Department of Transportation (DOT) requires that all transportation
incidents "involving the shipment of radioactive material in which fire,
breakage, spillage, or suspected radioactive contamination occurs" shall be
reported by telephone to the National Response Center "at the earliest
practicable moment." (49 CFR Section 171.51(a))
Sections 103(a) and (b) of CERCLA require immediate notification to the
National Response Center of all releases of radionuclides (and other CERCLA
hazardous substances) in an amount that equals or exceeds the applicable RQ.
The present statutory RQ for radionuclides is one pound. Section 102(a)
authorizes EPA to adjust the statutory RQs for all CERCLA hazardous
substances, including radionuclides.
There are two important exclusions to CERCLA notification requirements
that pertain to radionuclides:
(1) Section 101(22)(C) of CERCLA excludes from the
definition of release, any release of "... source,
byproduct, or special nuclear material from a nuclear
incident, as those terms are defined in the Atomic
Energy Act of 1954, if such release is subject to
requirements with respect to financial protection
established by the Nuclear Regulatory Commission under
Section 170 of such Act..."
(2) Section 101(10)(K) of CERCLA defines a federally
permitted release (such releases need not be reported
to the National Response Center) to include "any
release of source, special nuclear, or byproduct
material, as those terms are defined in the Atomic
Energy Act of 1954, in compliance with a legally
enforceable license, permit, regulation, or order
issued pursuant to the Atomic Energy Act of 1954."
The first exclusion refers primarily to reactor incidents. The second
exclusion has been interpreted by the Agency to mean any release that is in
compliance with a regulation, license, or order from EPA, the Nuclear
Regulatory Commission, an agreement state, or the Department of Energy.
EPA has issued a proposed regulation defining the scope of the federally
permitted release reporting exemption (48 FR 23552, May 25, 1983) This
regulation is scheduled to be reproposed in the near future. The draft
reproposal states that any release of a CERCLA hazardous substance must be
reported immediately to the National Response Center if the release exceeds
federally permitted levels by an RQ or more. If the release is less than an
RQ above permitted levels, the release is not considered federally permitted
but nonetheless need not be reported to the National Response Center under
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Sections 103(a) and (b) of CERCLA. Releases in compliance with EPA
regulations, Nuclear Regulatory Commission licenses, agreement state licenses,
and Department of Energy Orders are considered federally permitted under
Section 101(10)(K) of CERCLA, and therefore do not need to be reported to the
National Response Center.
Given these baseline reporting requirements, the following radionuclide
releases would be, strictly speaking, baseline reportable releases:
All reportable transportation incidents;
All federally permitted releases that equal or exceed
permitted levels by the statutory one-pound RQ; and
All non-federally permitted releases that equal or
exceed the statutory one-pound RQ.
However, we focus the analysis on non-transportation releases because all
transportation incidents are already required to be reported to the National
Response Center and, thus, the proposed regulation should not generate any
increased reporting of transportation incidents. Adjustment of the
radionuclide RQ, however, could affect the number of reports from facilities
with and without federal permits because the reporting trigger is being
adjusted in the proposed regulation.
3.2 AVAILABLE DATA SETS FOR ESTIMATING RADIONUCLIDE RELEASES
A radionuclide release data base was created for this analysis. The data
base contains information describing radionuclide releases in the United
States. Included in the information assembled in the data base are the date
of each release and, when available, the radionuclide and quantity (in curies)
released. These data were used to develop size and frequency distributions
for radionuclide releases. We estimated the expected number and size of
future radionuclide releases using data on the number and size of past
radionuclide releases.
In developing the radionuclide release data base, release reports were
incorporated from six sources:
Reports maintained by the Nuclear Regulatory
Commission's Office for Analysis and Evaluation of
Operational Data (AEOD), 1981 through 1985;
Reports maintained by the Transportation Technology
Center (TTC) of Sandia National Laboratory in
Albuquerque, New Mexico, 1971 through 1985;
Data provided by the Department of Energy's Office of
Environment and Health, Emergency Operations Center
(EOC), March 1983 through April 1986;
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3-4
Reports to the National Response Center, 1982 through
1985;
Reports to the Environmental Protection Agency's
Office of Radiation Programs (ORP), October 1981 through
September 1983; and
Reports to the Nuclear Regulatory Commission's
Operations Center, January 1983 through January 1986.
Of these six sources, the Nuclear Regulatory Commission's Office of
Analysis and Evaluation of Operational Data (AEOD) incident reports were the
most complete for our purposes, both in terms of release descriptions and the
population of release events included in the data. These reports usually
contained details on the quantity and identity of the radionuclide released.
The AEOD reporting population includes all Nuclear Regulatory Commission
licensees and some reports from agreement state licensees.
The release data obtained from the Transportation Technology Center (TTC)
and DOE's Emergency Operations Center (EOC) are equally complete in terms of
information provided. These sources, however, provide information on a much
smaller subset of release events than does AEOD. The TTC data are limited to
transportation accidents/incidents involving radioactive material; the EOC
data are limited to the past three years (1983-1986) and include only
reportable events under DOE Order 5484.1. Other events are not included in
the EOC data set.
The release data from the National Response Center did not contain
detailed quantity information and were, for the most part, not included in our
data base. Reports examined from the Nuclear Regulatory Commission's
Operation Center included only "release events" as defined by the Nuclear
Regulatory Commission. The Commission's definition is narrower than CERCLA's
definition of release.
Incident report duplication between the six sources appears to be
relatively limited. In developing the radionuclide release data base, we
tried to avoid double counting of releases by cross-checking the details about
particular release events. Incompleteness of the reports in some of the sets
and inconsistencies in dates of the events, however, complicated this effort.
Duplicates, therefore, have probably not been totally eliminated.
The radionuclide release data base developed for this analysis includes
1,139 events. These events range in size over many orders of magnitude, from
-9
5.0 x 10 curies to 56,892 curies. Of the 1,139 events in the data base,
there are 455 events with no quantity information or for which units of curies
could not be determined from available information. These 455 release events
were used only in the estimation procedure to determine the frequency of
release for particular radionuclides but could not be used to estimate the
size distribution of radionuclide releases. There are also 23 events included
in the data base that do not identify the radionuclide released but do have
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3-5
information on the quantities released. These events were used in the
estimation procedure to determine the size distribution of radionuclide
releases but could not be used to estimate the frequency of release for
particular radionuclides. In cases where neither the radionuclide nor the
quantity information was available in a data set, the event was not included
in the data base of 1,139 events. Exhibit 3-1 summarizes the characteristics
of the data base.
3.3 ESTIMATION OF HISTORICAL RADIONUCLIDE RELEASES
Baseline reportable releases are the number of releases that would need to
be reported to the National Response Center if the proposed radionuclide RQ
adjustments were not to take effect and the radionuclide RQ remained at one
pound. Because it is not possible to predict the future with certainty, we
rely on historical release events to characterize the likelihood of future
releases of radionuclides. The number of historical radionuclide releases
(both reportable and non-reportable) is the starting point m the estimation
process for determining baseline annual reportable releases. We estimate
baseline annual reportable releases to be a function of three factors:
(A) total number of annual releases of radionuclides;
(B) frequency of release for a particular radionuclide; and
(C) probability that a release equals or exceeds the
reportable quantity of a particular radionuclide (i.e.,
the equivalent, in curies, of one pound or one pound
above permitted or licensed levels).
In particular, the total number of baseline reportable releases can be
represented as follows:
Total Baseline Releases = (A)*I[ (B . )-(C .) ]
The product of Bi and represents the product of B., the probability
of a release of a particular radionuclide, and C , the probability that any
radionuclide will be equal to or above reportable levels, as that is defined
for each radionuclide.
Therefore, the product [B^-C^] represents the probability that a
release of a particular radionuclide will be equal to or above reportable
levels. The summation of this product represents the probability that any
release will be equal to or above reportable levels. When we multiply this
latter probability by (A), the total number of annual radionuclide releases at
any level, we are able to derive the total number of annual radionuclide
releases equal to or greater than the baseline RQ. Each of these factors is
discussed in more detail below.
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3-6
EXHIBIT 3-1
RADIONUCLIDE DATA BASE CHARACTERISTICS
Total number of release events in data base 1,139
Number of release events without quantity
information 455^
I
Number of release events with quantity |1,139
information (used to estimate size distri- j
bution of radionuclide releases) 684 1
Number of release events with radionuclide
unidentified 23 1
Number of release events with radionuclide |1,139
identified (used to estimate the probability j
of release for a particular radionuclide) 1,116J
Number of radionuclides identified in data
base 63
Source: ICF analysis.
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3-7
3.3.1 Total Number of Annual Releases of Radionuclides
The available data sets discussed in Section 3.2 above do not cover
releases from all facilities that handle and are therefore likely to release
radionuclides.1 The data base established for this analysis is used
primarily to develop the estimated frequency of release for particular
radionuclides (factor B above) and the estimated size distribution of releases
(factor C above). It is not used to estimate the total number of releases
(reportable and non-reportable) of radionuclides by the affected community
because a large portion of the releases by the affected community is not
included in the data base (e.g., releases from facilities in agreement states
are not included generally in the data base).
To estimate the total number of annual radionuclide releases, we focus the
analysis on non-transportation releases because all transportation incidents
are already required to be reported to the National Response Center. Thus,
the proposed regulation should not generate any increased reporting of
transportation incidents; the incremental increase in reportable radionuclide
releases consist only of non-transportation releases.
We assume that the number of non-transportation releases is proportional
to the number of facilities producing and using radionuclides in any
appreciable quantity. We realize this assumption is an over-simplification
and, thus, is not entirely accurate. The probability of a release event
occurring at a facility is probably correlated with use levels and types and
forms of radionuclides used at a facility. If a facility uses a small
quantity of radionuclides in a sealed form, the likelihood of a release from
that facility would be less than at a facility that uses a large quantity of
radionuclides in an unsealed form. Unfortunately, facility-specific data on
radionuclide production and use levels are unavailable.
To derive the number of annual non-transportation radionuclide releases,
therefore, we rely on the Nuclear Regulatory Commission AEOD data. We use
these data because the number of facilities required to report releases to the
Nuclear Regulatory Commission is well defined and we can thus establish the
relationship between the number of releases and the number of facilities
required to report. The AEOD data set includes most release events from
Nuclear Regulatory Commission licensees and some small fraction of the release
events from agreement state licensees. Only Commission licensees are required
to notify the Nuclear Regulatory Commission when there is a radionuclide
release. However, some states and some facilities licensed by agreement
Appendix A of this report describes the major types of facilities that
produce and use radionuclides. Releases from facilities in agreement states
would not be expected to be represented in the Nuclear Regulatory Commission
data sets, the Sandia National Laboratory's data set, the Department of Energy
data set, or the EPA's Office of Radiation Programs data set. It is possible
that releases from these facilities could be represented in the data set from
the National Response Center, but the data from this source are mostly
qualitative and were, for the most part, not included in our data base.
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3-8
states notify the Commission of a release even though they are not strictly
obligated to do so.
It would not be appropriate simply to use the average number of events
reported annually in the AEOD data set to represent average annual reportable
releases in the baseline from Commission licensees. Because reporting an
incident is relatively simple and because the nuclear industry is closely
monitored and highly sensitive to public concerns, there is a tendency for the
regulated community to report any incident, regardless of the quantity
involved and regardless of whether the event actually results in a release to
the environment. On the other hand, it is likely that some facilities may not
be reporting all reportable release events. In addition, the AEOD data set
does include some transportation incidents that must be elminated before we
can use the data in our analysis.
A release is defined as an event where radionuclides are released into the
environment. Strict determinations of releases in the AEOD data are difficult
to make because the reports generally lack detail. It is difficult to
determine, for example, whether a radionuclide release was contained by a
structure or whether the radionuclides escaped to the environment. To promote
consistency, we established criteria for categorizing the various events.
These criteria are conservative to develop an upperbound estimate of the
number of release events per year. These release events are not necessarily
large nor do they pose a danger to public health or welfare or the
environment; they are simply release events reported to the Nuclear Regulatory
Commission over the last five years.
For the years 1981 through 1985, the release profile for the AEOD data set
is shown in Exhibit 3-2. About 25 percent of all reports classified in this
analysis as release events are clearly events involving releases to the
environment. The remaining events were classified as releases to the
environment in the following manner:
Reports of loss, theft, or burial of radioactive
equipment or sources (approximately 40 percent of the
reports) -- Reports of lost radioactive seeds, stolen
machinery, and burials of radioactive machinery or waste
in landfills were classified as releases to the
environment. The most commonly reported event
throughout the AEOD data is the abandonment of sources
in drilling holes. Because the sources are not
recoverable, the Agency considers all such events to be
releases to the environment, even if the sources are
encapsulated with cement or slurry.
Reports of contamination of shipped products or
equipment (approximately 15 percent of all releases) --
Reports of contaminated or leaking equipment involved in
shipping are considered events involving releases to the
environment. They are, however, classified only as
transportation releases when escape or leakage of
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3-9
EXHIBIT 3-2
PROFILE OF RELEASES IN NUCLEAR REGULATORY COMMISSION
AEOD DATA SET
Total
Number of
Non-Transportation Releases
Total
Total Number of
from:
Number of
Transportation
Agreement
Commission
Year
Release Events-
Releases
States
Licensees
1981
103
7
2
94
1982
82
5
1
76
1983
103
8
8
87
1984
92
3
3
86
1985
83
9
15
59
Annual
Average:
93
6
6
80
*A release event is defined as an event where radionuclides are released
into the environment. It was often difficult to determine from the
information in the reports whether a release to the environment actually
occurred. When in doubt, for purposes of this analysis, we assumed the event
did result in a release to the environment. In addition, many of the releases
were exceedingly small, posing no danger to public health or welfare or the
environment. The number of releases represented in this table are not
necessarily reportable under either the one-pound RQ or the proposed RQs. The
table simply presents the maximum number of events in the AEOD data that could
be considered releases to the environment. The AEOD data sets also include
additional events that were not considered to be releases. These events
include, for example, reports of failure to submit monitoring data and
incorrect labels on containers.
Source: ICF estimates.
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3-10
radioactive materials is evident to shipping personnel
and reported by them. A spill of material on a highway,
for example, is considered a reportable transportation
release. Damage, loss, or contamination of a package
during shipping that was not clearly evident to shipping
personnel, however, is assumed to be a non-transportation
release. For example, if a package was received
damaged, and the report does not clarify that the
shipping agent was aware of the damage and had actually
reported the incident, for purposes of this analysis,
the report is considered a non-transportation release.
Reports of high stack concentrations and radiation in
unrestricted areas (approximately 15 percent of all
reports) -- Citations of high concentrations of
radioactive material in exhaust stacks and airborne
radiation in unrestricted areas are both classified as
releases to the environment. That is, if reports do not
specify the location of airborne radioactive materials,
we assume the event involved a release to the
environment.
Reports of allegations of releases (about 2 percent
of all reports) -- Although not officially confirmed,
allegations by personnel of release events (e.g., the
burial of radioactive waste in a landfill) are
considered releases to the environment.
Report of fire (about 2 percent of all reports) --
Citation of a fire is considered evidence of a release
except where a report indicates specifically no
contamination.
The following events were not classified as releases to the environment:
Reports of a leaking source -- Although it was not
always possible to determine whether the leak occurred
in a secure enclosure, we did not classify these events
as releases to the environment.
Reports of positive radioactivity test results --
Reports citing test results that found "removable"
radiation on lab and industrial equipment were not
classified as releases to the environment.
Reports of exposure of badges or personnel -- Where
badges worn by personnel reflect exposure to
radioactivity, this analysis assumes exposure occurred
in a contained structure. Badge exposure therefore was
not classified as a release to the environment.
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3-11
Report of loose packaging -- Reports of loose or
improper packaging used for purposes of transport were
not considered evidence of a release. However, the
observed escape of liquid or solid material from
packaging was considered evidence of a release.
As shown in Exhibit 3-2, there are an estimated 80 annual non-transporta-
ti°n release events reported by Commission licensees in the AEOD data set. If
we assume that 80 percent of all releases are actually reported to the Nuclear
Regulatory Commission,2 then the number of non-transportation radionuclide
releases by Commission licensees is estimated to be 100 releases annually.
As discussed in Appendix A of this report, there are approximately 75,000
facilities that could potentially release radionuclides, including facilities
in the following categories:
Nuclear Regulatory Commission licensees (8,900);
Agreement state licensees (13,000);
DOE facilities (78); and
Unlicensed facilities (53,475):
Laboratories (700)
Coal-fired utility and industrial boilers (52,500),
Uranium mines (181 -- 21 active),
Aluminum smelters (32),
Copper smelters (15),
Zinc smelters (5),
Lead smelters (5),
Phosphate rock plants (31), and
Elemental phosphorous plants (6).
These industries are heterogeneous and, therefore, have very different
probabilities of releasing radionuclides at levels that equal or exceed an
RQ. Several of these industries are unlikely to be affected by the proposed
RQ adjustments because they release radionuclides in very small quantities and
only as part of their normal operations. Examples of these industries
include: coal-fired boilers, aluminum, copper, zinc, and lead smelters, and
phosphate rock plants. Radionuclide release cannot occur due to a spill at
these facilities, but only due to the burning of the coal or ores during the
production processes. The radionuclide releases may occur into water, into
2We have no data on the amount of under-reporting that occurs, but
because Commission licensees are highly regulated and very sensitive to public
concerns regarding radiation, we believe the assumption that 80 percent of
releases are reported is reasonable. This figure is not assumed to be higher
because there will always be some releases that the releaser will not report.
Thus, under-reporting is taken into account here. We test the effect of this
assumption in Chapter 7 of this report.
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3-12
air, or through disposal of the sludge. Air releases from the facilities were
examined closely by the Agency because radionuclides are a hazardous air
pollutant under Section 112 of the Clean Air Act. The following discussion
presents the general results of the Agency's analysis of the air releases from
each of the different facilities.
Coal-fired boilers release radionuclides to the air only when they burn
coal. The radionuclide quantities released during the coal-burning process
are smaller than the proposed RQ levels. Radionuclides released from a large
utility boiler, for example, are in the uranium and thorium series and are
released at levels generally close to 0.0001 curies per day, except for
radon-220 which is released at levels of close to 0.001 curie per day. These
levels are below the proposed RQs for the affected radionuclides, and well
below the proposed RQ of 100 curies for radon-220. For industrial boilers,
which have relatively smaller thermal capacity and coal consumption, emission
levels are closer to 10 ^ curie per day,3 well below the proposed RQs.
Similarly, aluminum, copper, zinc, and lead smelters release radionuclides
to the air only when they process their respective ores. The radionuclide
quantities released to air from a typical smelter vary by the type of ore
processed, but range generally from close to 10 7 curie to 10~^ curie per
day, well below the lowest proposed RQ of 0.001 curie per day.u Therefore,
air releases from these industries will not be affected by the proposed RQ
adjustments.
Phosphate rock plants are also not expected to be affected by the proposed
RQ adjustments due to releases to air. Phosphate rock plants release
radionuclides to the air during grinding and drying processes at levels no
higher than 10 6 curie per day.5 This is well below the lowest proposed
-3
RQ of 10 curie.
The coal-fired boilers, smelters, and phosphate rock plant air emissions
have been analyzed thoroughly by EPA when the Agency was considering
regulating radionuclide emissions under Section 112 of the Clean Air Act. The
Agency concluded that "good reasons exist to propose not to regulate the
following categories of facilities: (1) coal-fired boilers, (2) the phosphate
industry, (3) other extraction industries..." (48 FR 15076, April 6, 1983).
Radionuclide air emissions from these facilities do not present a potential
threat to public health or welfare or the environment and will not be affected
by this proposed regulation because air releases from these facilities are
expected to be the result of plant operations only and to be well below the
3ICF analysis based on emissions data in U.S. Environmental Protection
Agency, Radionuclides Background Information Document for Final Rule, Volume
2, EPA 520/1-84-022-2, Office of Radiation Programs, October 1984, p. 4.2-7.
"Ibid., pp. 7.1-8, 7.2-6, 7.3-4.
5Ibid., p. 6.1-11.
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proposed RQs. Radionuclide releases due to contamination of sludge may be
reportable under CERCLA, however, if the release is equal to or above an RQ.
Regarding releases to water, the Supreme Court rules in Train vs. Colorado
Public Interest Research Group, 426 U.S. 1 (1976) that "source," "special
nuclear," and "byproduct" materials are not pollutants within the meaning of
the Clean Water Act. As such, specific releases of radionuclides were not
considered in developing effluent limitations under the Act. However, NARM
(naturally occurring and accelerator produced radioactive materials) can be
limited specifically in water discharge permits, and regulation of certain key
indicator pollutants can result in the control of other pollutants, including
radionuclides. Therefore, water releases of radionuclides may or may not be
considered federally permitted under Section 101(10) of CERCLA.
In a similar manner, unlicensed laboratories are not licensed by the
Nuclear Regulatory Commission because they do not handle radionuclides in
sufficient quantities to warrant concern. In particular, unlicensed
laboratories do not handle radionuclides in quantities close to the proposed
RQs. It would be virtually impossible, therefore, for these facilities to
release radionuclides at reportable levels. Therefore, for purposes of this
analysis, we assume the universe of affected facilities does not include
coal-fired boilers, aluminum, copper, zinc, and lead smelters, phosphate rock
plants, or small, unlicensed laboratories.
The remaining unlicensed facilities, uranium mines and elemental
phosphorous plants, could be affected by the proposed regulation. These two
industries were analyzed by EPA to determine the levels of radionuclide air
emissions from these facilities. Unlike the boilers and smelters discussed
above, uranium mines and elemental phosphorous plants were found to emit
radionuclides at controllable levels. These emissions were controlled,
therefore, under Section 112 of the Clean Air Act and these facilities could
be releasing radionuclides in quantities greater than or equal to an RQ.
However, releases in compliance with Section 112 limitations are considered
federally permitted under CERCLA Section 101(10)(H) and would need to be
reported to the National Response Center only if the quantities released
exceed federally permitted levels by an RQ or more.6
Therefore, the facilities that could be affected by the proposed
regulation because they could release radionuclides at levels equalling or
exceeding an RQ make up a universe of approximately 22,000 facilities,
consisting of 8,900 Commission licensees, 13,000 agreement state licensees, 78
DOE facilities, and approximately 25 active uranium mines and elemental
phosphorous plants. Releases from these facilities could be considered
sThe federally permitted release reporting regulation is scheduled to be
reproposed in the near future. This proposed rule requires any federally
permitted release, as defined in Section 101(10) of CERCLA to be reported to
the National Response Center if it equals or exceeds licensed or permitted
levels by an RQ or more.
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3-14
federally permitted either under Section 101(10)(K) for releases from
Commission licensees, agreement state licensees, and DOE facilities, or under
Section 101(10)(H) for releases from uranium mines and elemental phorphorous
plants.
Because there are 8,900 Commission licensees that are responsible for an
estimated 100 radionuclide non-transportation releases annually, the total
number of annual non-transportation releases of radionuclides from all 22,000
regulated facilities is approximately 250 release events per year (assuming
proportionality between the number of releases and the number of regulated
facilities).
It must be emphasized that this is just a gross estimate. Because these
22,000 regulated facilities are not homogeneous, they cannot be expected to
have uniform release patterns. They release different radionuclides, at
different propensities, and at different levels. We believe this estimate is
an upperbound estimate, although not all facilities that could potentially
release radionuclides have been included in this estimation procedure. In
particular, facilities that use naturally occurring and accelerator produced
radioactive material (NARM) are not included in this analysis. We have no
data on these facilities. Nevertheless, we believe the estimate of
approximately 250 release events per year is reasonable. It is based on
several key assumptions:
total releases from regulated facilities are
proportional to the number of regulated facilities using
and producing radionuclides;
total number of releases per Commission licensee as
reported in the AEOD data represents the average number
of releases per facility for all types of regulated
facilities; and
amount of under-reporting for Commission licensees is
20 percent.
We do rely heavily on these assumptions to estimate the number of
non-transportation radionuclide releases from facilities using or producing
radionuclides in any sizable quantity. We believe, however, that the
assumptions used are reasonable for purposes of this analysis. The estimates
include both reportable and non-reportable releases. The large majority of
these releases are expected to be exceedingly small, well below the proposed
RQs, and would not be expected to pose a danger to public health or welfare or
the environment. We test the effect of these assumptions in Chapter 7 of,this
report.
3.3.2 Frequency of Release for a Particular Radionuclide
The data base assembled for this analysis identifies 63 radionuclides in
1,139 release events. We assume that if a release of a particular
radionuclide occurred in the past, it serves as an indication of the
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3-15
likelihood that the radionuclide will be released in the future. For each of
the 63 radionuclides identified in our data base, we assume the probability of
a future release can be derived from the frequency of past reported releases
for that particular radionuclide. For example, uranium-238 (U-238) is
involved in 129 of the 1,116 events with identified radionuclides in our data
base. We assume, therefore, that the probability a radionuclide release is
specifically a release of uranium-238 is 129/1,116 or .116. Iodme-125
(1-125) is involved in 64 events. We assume the probability that a
radionuclide release is specifically a release of iodine-125 is .057
(64/1,116). This calculation is performed for each of the 63 radionuclides
and is shown in Exhibit 3-3. All other radionuclides have been assigned a
zero probability of release because we have no data on past releases for these
radionuclides.
3.3.3 Size Distribution of Releases
The 684 release events in our data base that have quantity information are
used to develop a size distribution of releases for radionuclides. By taking
the logarithms of the release events in the data base, a log normal
distribution develops, with a mean of 0.15 curies and standard deviation of
2.7 curies. The data are skewed, reflecting a much higher probability of a
small release and a small probability of a large release. Exhibit 3-4
displays the size distribution of the releases in the data base. The
frequency distribution shows, for example, that there are 152 release events
m our data base where the quantity released is greater than 1 curie and less
than or equal to 10 curies. There are 110 release events in our data base
where the quantity released is greater than 10 curies and less than or equal
to 100 curies. There are only 7 release events in our data base where the
quantity released is greater than 1000 curies.
3.4 BASELINE REPORTABLE RELEASE ESTIMATION
Baseline non-transportation radionuclide releases include all radionuclide
releases that exceed permitted levels by one pound or more at licensed or
regulated facilities. We have already estimated annual non-transportation
radionuclide releases to be approximately 250 releases per year. We now
determine the fraction of these releases that are required to be reported in
the baseline to the National Response Center.
We estimate in Appendix A that there are about 21,900 Commission and
agreement state licensees, 78 DOE facilities, and approximately 25 active
uranium mines and elemental phosphorous plants. In addition, there are
approximately 53,000 facilities without federal permits that could release
radionuclides but only at extremely low levels. Although we estimate that
there are about 250 annual releases of radionuclides, not all of these
releases are reportable presently under CERCLA; only releases that equal or
exceed one pound for releases that are not federally permitted, and releases
that exceed permit or license levels by one pound or more need be reported to
the National Response Center.
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3-16
EXHIBIT 3-3
FREQUENCY OF RELEASE FOR RADIONUCLIDES
IN DATA BASE
Number of Probability of Release
Radionuclide Events Per Radionuclide Per Radionuclide
AM-241
65
0.0582
AM/BE
74
0 0663
AR-41
1
0.0009
BA-133
6
0.0054
C-14
10
0.0090
CA-45
3
0 0027
CD-109
1
0.0009
CE-141
2
0.0018
CM-244
2
0.0018
CO-57
6
0.0054
CO-58
2
0.0018
C0-60
68
0.0609
CR-51
3
0.0027
CS-131
1
0.0009
CS-134
1
0.0009
CS-137
225
0.2016
EU-152
2
0.0018
EU-154
1
0.0009
F-18
1
0.0009
FE-55
6
0.0054
FE-59
2
0.0018
GA-67
7
0.0063
GE-77
1
0.0009
H-3
41
0.0367
HG-197
2
0.0018
1-123
2
0.0018
1-125
64
0.0573
1-129
1
0.0009
1-131
32
0.0287
IN-111
1
0.0009
IR-192
91
0 0815
K-42
1
0.0009
KR-81
1
0.0009
KR-85
27
0 0242
MO-99
15
0.0134
NA-24
5
0.0045
NI-59
1
0.0009
NI-63
33
0.0296
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3-17
EXHIBIT 3-3
FREQUENCY OF RELEASE FOR RADIONUCLIDES
IN DATA BASE
(Continued)
Number of Probability of Release
Radionuclide Events Per Radionuclide Per Radionuclide
OS-185
2
0.0018
OS-191
1
0.0009
P-32
9
0.0081
PB-210
1
0.0009
PB-212
1
0 0009
PM-147
14
0.0125
P0-210
17
0.0152
PU-238
3
0.0027
PU-239
9
0.0081
RA-226
4
0.0036
RB-88
1
0.0009
RU-106
2
0.0018
S-35
4
0.0036
SB-125
1
0.0009
SR-90
17
0.0152
TA-182
2
0.0018
TC-99
37
0.0332
TH-232
12
0.0108
TH-234
1
0.0009
TL-201
2
0.0018
TL-204
4
0.0036
U-235
18
0.0161
U-238
129
0.1156
XE-133
15
0.0134
ZN-65
3
0.0027
Subtotal
1,116
1
Unknown isotopes
23
TOTAL
1,139
Source: ICF estimates.
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3-18
EXHIBIT 3-4
SIZE DISTRIBUTION OF RADIONUCLIDE RELEASES
IN DATA BASE
Number of Releases
Probability that Release
Quantity
in Data Base
that
Will Equal or Exceed
(Curies)
Equals or Exceeds
Quantity
Quantity 1
0.001
521
0.762
0.01
437
0.639
0.1
337
0.493
1
280
0.409
10
128
0. 187
100
18
0.026
1000
7
0.010
1 Derived by dividing 684 into the number of releases in the data base
that equals or exceeds that quantity. There is a total of 684 releases
with quantity information in the data base.
Source: ICF analysis.
FREQUENCY DISTRIBUTION
RAW DATA
MO -
2S0 -
200 -
180 -
100 -
SO -
o -f=----=r
1E-0 1
9 ^I
0 100 >100
10
20
90
40
SO
0
70
00
QUANTITY (O)
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3-19
Federally permitted releases are assumed to be all releases from
Commission licensees, agreement state licensees, and DOE facilities that are
in compliance with 10 CFR Part 20 limitations and other license or contract
requirements, and releases from uranium mines and elemental phosphorous plants
that are specified in and in compliance with regulations under Section 112 of
the Clean Air Act. As discussed in Chapter 2 of this report, the proposed RQs
were derived from the Annual Limits of Intake (ALI) developed by the ICRP.
These have been adopted by the Nuclear Regulatory Commission in its proposed
revision to 10 CFR Part 20. For purposes of this analysis, therefore, we
assume that the 10 CFR Part 20 limitations are equivalent to the proposed
RQs. Because of the conservative assumptions used in the development of the
proposed RQs, and because the ALIs are based on a dose equivalent of 5 rem,
not 500 millirem, it is expected that, under most circumstances, facilities
can release more than the proposed RQ without exceeding the 500 millirem per
year limit for exposure to the general public (i.e., without exceeding
federally permitted levels for licensees). The assumption that the proposed
RQs equal the federally permitted release levels would, therefore,
over-estimate the number of reportable releases at facilities with federal
licenses in both the baseline and post-regulation situations. The incremental
number of reportable releases should, however, remain unchanged. The
sensitivity of our results to the number of reportable releases is addresssed
in Chapter 7 of this report.
The federally permitted release levels for uranium mines and elemental
phosphorous plants have been established by EPA under Section 112 of the Clean
Air Act. These levels are independent of the ALIs. However, for purposes of
this analysis, we treat all facilities that have federally permitted releases
in the same manner; we assume the propensity to release radionuclides is
uniform and that federally permitted release levels can be represented
reasonably as being equivalent to the proposed RQs. Therefore, because
baseline reportable releases from facilities with federal permits are all
releases from these facilities that equal or exceed permitted or licensed
levels by one pound, and because for any particular radionuclide, the
federally permitted release level is assumed to equal the proposed RQ, a
release of a radionuclide would need to be reported to the National Response
Center if it equals or exeeds the proposed RQ plus one pound.
For each radionuclide in our data base, the frequency of release shown in
Exhibit 3-2 was multiplied by the probability that a release will equal or
exceed the proposed RQ plus one pound for that radionuclide (all expressed in
curies). This probability is derived from the size distribution of releases
shown in Exhibit 3-4. By multiplying the frequency of release for a particular
radionuclide by the probability that any radionuclide release will equal or
exceed the equivalent, in curies, of the proposed RQ plus one pound, we derive
the probability that a release of a particular radionuclide will be reportable.
For example, radium-226 has an estimated frequency of release of 0.0036
because it was reported released in our data base 4 times. Radium-226 has a
proposed RQ of 1 curie and one pound of radium-226 is equivalent to 449
curies. By examining all 684 releases with quantity information in our data
base, we determine that there are 10 radionuclide releases in the data base
that equal or exceed 450 curies, the proposed RQ plus one pound for
radium-226. We estimate, therefore, that there is a 0.0146 (10/684)
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3-20
probability that a release of 450 curies or greater will occur. The estimated
probability that radium-226 will be released at levels that equal or exceed
the proposed RQ plus one pound, therefore, is equal to 0.00005 (0.0036 x
0.0146).
By performing this calculation for each radionuclide and summing, we
derive the probability that a radionuclide will be released at levels
exceeding its federally permitted level by one pound or more. Multiplying
this sum by the number of annual radionuclide releases (250) from facilities
that have federal permits, we estimate the baseline number of reportable
releases to be 19 releases annually.
Once again, we must emphasize that this figure is an estimate. It is
based on a number of key assumptions that are, to some extent,
over-simplifications, and should not be expected to be correct in every
aspect. Chapter 7 of this report demonstrates the sensitivity of our results
to this estimate of reportable radionuclide releases.
Baseline costs and benefits are the estimated value of actions taken by
both the regulated community and the government when baseline reportable
releases occur. The value of these actions are discussed in Chapter 4 of this
report.
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CHAPTER 4
VALUATION OF THE EFFECTS OF THE
PROPOSED RQ ADJUSTMENTS
The purpose of an Economic Impact Analysis is to estimate the incremental
costs and benefits resulting from a regulatory action. Any regulation
requiring behavioral changes will usually lead to some elements of society
benefiting from the regulation and some elements of society incurring costs.
This report analyzes those benefits and costs and estimates the net gain or
net loss resulting from the proposed regulation. Section 4.1 describes
actions that could be taken by both the regulated community and government as
a result of a reportable release and describes the actions that are
attributable to the proposed RQ adjustments for radionuclides; Section 4.2
discusses the valuation of the costs; and Section 4.3 discusses the valuation
of the benefits.
4.1 ACTIONS TAKEN WITH A REPORTABLE RELEASE
For all radionuclides whose RQ adjustment is downward, the proposed
regulation is expected to result in an increased number of releases reported
to the National Response Center. This increased reporting requirement will
impose costs on the regulated community and on the government. It could also
result in benefits for society if reporting radionuclide releases result in
faster and more efficient cleanups of the releases.
For the 30 radionuclides whose RQ adjustment is upward, the proposed
regulation is expected to result in cost savings (benefits) for both the
regulated community and the government, as fewer releases will be reportable
to the National Response Center. It could, however, result in fewer cleanups
which may impose a cost on society due to a lower level of protection of
public health and the environment. These costs and benefits are the result of
actions taken by the regulated community and the government when a release
occurs and is reported by a facility to the National Response Center. The
remainder of this section describes the likely actions by both the regulated
community and the government as a result of a reportable release and describes
the actions that are attributable to the proposed RQ adjustments.
4.1.1 Actions Undertaken By the Regulated Community
When a radionuclide release occurs, three categories of actions are
undertaken by regulated parties. These actions can be classified as
notification, recordkeeping, and response. The notification action is
required by CERCLA in response to a reportable release. Recordkeeping and
response actions, however, occur indirectly and are not required by the
statute.
Notification includes the notification of the National Response Center by
the responsible party if a reportable release occurs, as is required by
Section 103(a) of CERCLA. This action includes activities beyond the time
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4-2
spent by facility managers in a telephone conversation with the National
Response Center. There is often subsequent interaction with the government by
various levels of firm personnel as the government evaluates and determines
the appropriateness of a response action.
Recordkeeping is often associated with notification. Although CERCLA
does not require that records of releases be kept, regulated parties often
maintain logs of calls to the National Response Center. These logs might
include a description of the incident, its cause, a brief account of
conversations with government officials, and a description of the outcome of
the incident, as well as cleanup actions taken.
Response includes actions taken by the responsible party to mitigate the
effects of the release. Typical response actions might include sampling the
air, water, or soil; evaluating the necessity for evacuation and relocation;
directly containing the release; and removing and/or neutralizing the release.
4.1.2 Actions Undertaken by the Government
Actions undertaken by the government in response to a release can be
divided into four categories. They include notification processing, off-scene
monitoring, on-scene monitoring, and direct removal. Each category is
directly caused by the notification of a release.
Notification processing includes the initial communication with the
person who calls in the report to the National Response Center. It also
includes evaluation of the information, determination of an appropriate
government response, and subsequent recordkeeping.
Off-scene monitoring includes supervision and monitoring of the
responsible party's actions through telephone and data monitoring.
On-scene monitoring includes a government official providing advice and
assistance in person to the cleanup team, coordinating communications among
agencies, providing information to the public, and ensuring that the Agency's
concerns are represented in determining the appropriate response.
Direct removal is necessary when the responsible party cannot or will not
adequately clean up the radionuclide release and the release represents a
hazard to public health or welfare or to the environment. Although the
government response agency will normally use a private contractor to clean up
the release, government response teams nevertheless have sampling, monitoring,
containment, and safety equipment to deal with the initial emergency and to
assist the contractors m the cleanup. Direct removals also could require
more than one government agency.1
lFor example, EPA, the Coast Guard, the Nuclear Regulatory Commission,
the Department of Energy, the Federal Emergency Management Agency, state
response agencies, state and local police and highway resources, or local fire
departments could become involved in a release event.
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4-3
4.1.3 Incremental Actions Attributable to the Radionuclide
RQ Adjustments
Section 103(a) of CERCLA requires any release of an RQ or more of a
hazardous substance to be reported immediately to the National Response
Center. The proposed regulation is adjusting the RQ for radionuclides,
resulting in a change in the number of reportable releases. For those
radionuclides whose RQ decreases, the proposed regulation will result in an
increase in the number of reportable releases to the National Response
Center. For those radionuclides whose RQ increases, the proposed regulation
will result in a decrease in the number of reportable releases to the National
Response Center. This will affect notification costs, recordkeeping, and
response costs incurred by the affected facilities and it will affect
notification processing costs, off-scene and on-scene monitoring costs, and
removal costs incurred by the government.
The production, use, and transportation of radionuclides are already
regulated and controlled. For the most part, facilities already face some
reporting requirements for releases of radionuclides. All transportation
releases, regardless of quantity, must already be reported to the National
Response Center (49 CFR Parts 171-177). Therefore, the proposed regulation
adjusting the radionuclide RQ from one pound to some new level will have no
effect on transporters of radionuclides.
The proposed regulation could increase notification, recordkeeping, and
response activities for facilities handling and releasing radionuclides with a
proposed RQ less than one pound. Similarly, it could decrease notification,
recordkeeping, and response activities for facilities handling and releasing
radionuclides with a proposed RQ exceeding one pound. The additional cost (or
cost savings) any facility will incur is related to the number of reportable
releases from that facility, which is a function of the handling practices at
the facility, the quantity and type of radionuclides handled at the facility,
and the forms of the radionuclides (e.g., sealed sources, solids, liquids, or
gases). It is difficult to predict which facilities will be most affected by
the proposed RQ adjustments, but it is reasonable to expect a change in the
number of releases of radionuclides reported to the National Response Center
as a result of the proposed regulation. The change in the number of
reportable releases will directly affect the costs and benefits that accrue to
both the regulated community and government.
In addition to the direct economic costs and cost savings resulting from
the change in the number of releases reported to the National Response Center,
the proposed RQ adjustments can affect public health and welfare and
environmental quality. If the likelihood of a cleanup response is greater
when notification to the National Response Center is required, then RQ
adjustments could have the following effects:
Raising RQs for particular radionuclides will
decrease the number of reportable releases. Assuming
that some releasers are less likely to clean up releases
of radionuclides below the RQ, more public health and
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4-4
welfare and environmental damages could occur with
higher RQs. These incremental damages are costs of
raising the RQs for some radionuclides.
Lowering RQs for a particular radionuclide will
increase the number of reportable releases for that
substance. If these lower RQs lead to increased and
earlier notifications of releases and to appropriate and
timely response actions that would not otherwise have
occurred, public health and welfare and environmental
damages could be mitigated. These decreased or avoided
damages can be considered to be a benefit of lowering
the RQs for some radionuclides.
Identifying, predicting, and measuring the public health and welfare and
environmental effects of raising or lowering RQs is inherently difficult. An
analysis of these effects is not included in this report because of serious
information constraints. Although this report estimates the change in the
number of reportable releases under the proposed regulation, reliable
information is unavailable on the damages that have been associated with past
radionuclide releases. There is no information regarding the role (if any)
that RQ levels or reporting requirements played in contributing to these
effects. Therefore, little information exists upon which to base a
quantitative analysis of public health and welfare and environmental effects,
and we discuss these changes in qualitative terms only.
4.2 VALUATION OF COSTS
This section describes the method of attaching values to the actions
caused by changes in the RQs. The values associated with one reportable
release are the resources that are consumed during the notification,
recordkeeping, and response activities by both the regulated community and the
government and also include the changes in public health and welfare and
environmental quality that may be produced by a response. In general,
estimates throughout this study of the resources consumed as a result of
performing each action are quantitative, and the estimates of changes in
public health and welfare and environmental quality are qualitative. The
remainder of this section provides estimates of the value of the actions
performed by regulated parties and the government. These estimates are
examined more closely in Chapter 7 of this report, where we test the
sensitivity of our results to each of the frequency estimates discussed below.
4.2.1 Values of Actions Performed by Regulated Parties
We base most of our cost estimates for each action on the estimates
derived in the Regulatory Impact Analysis (RIA) supporting the RQ adjustment
for 340 CERCLA hazardous substances.2
2ICF Incorporated, Regulatory Impact Analysis of Reportable Quantity
Adjustments Under Sections 102 and 103 of the Comprehensive Environmental
Response, Compensation, and Liability Act, Volume I, March 1985.
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4-5
Notification. Section 103(a) of CERCLA places the responsibility for
notification of the National Response Center on the person in charge of the
vessel or facility from which a hazardous substance is released. It is
reasonable to assume, therefore, that a plant manager or representative will
become involved in the notification process soon after a release is reported.
In addition to the plant manager, the time expended and the type of other
people who become involved in notification activities depend on the following
four factors: the amount, identity, and form (solid, liquid, or gas) of
radionuclide released; the location where it is released; the responses of
government officials and the releaser of the radionuclide; and the size and
organizational structure of the responsible party.
The RIA in support of the RQ adjustment for 340 CERCLA hazardous
substances assumed notification costs for releases of less than 55 gallons are
$121, and notification costs for releases over 55 gallons are $323.3 It
would not be appropriate to differentiate notification costs for radionuclide
releases on the basis of whether the releases are above or below 55 gallons.
As discussed earlier, a radionuclide release well below one pound could
generate a great deal of concern and public interest, resulting in relatively
high notification costs. Radionuclide releases in general engender public
concern and scrutiny because of the lack of understanding and general fear
felt by the public at large regarding radiation and radioactive contamination.
The responsible party may have to respond to more calls from state and local
government officials and from the press, for example, than would be the case
for a chemical release. It seems more appropriate, therefore, to assume
notification costs to industry for a radionuclide release are closer to $323,
which includes three hours of managerial time and two hours of technical time,
than it is to $121 which includes one hour of managerial time and one hour of
technical time. We will assume, therefore, that each release notification
costs the regulated community $323 (1983 dollars).
Recordkeeping. The resources required to perform internal recordkeeping
responsibilities were estimated in the RIA supporting the RQ adjustment for
340 CERCLA hazardous substances to be 1 clerical hour per release, and assumes
a ratio of 1 supervisory hour to each 10 hours of clerical time." This
estimate implies a cost of $28.10 per release, assuming $20 per hour for
clerical time and $81 per hour for managerial time. Recordkeeping associated
with a chemical release notification and recordkeeping associated with a
radionuclide release notification should not differ substantially. We adopt
this same unit cost estimate in this analysis of the proposed RQ adjustments
for radionuclides.
3Ibid, p. 3-11. The larger releases are assumed to take 3 hours of
managerial time at $81 an hour and 2 hours of technical time at $40 an hour.
The smaller releases, which are usually less serious, are assumed to take 1
hour of managerial time and 1 hour of technical time. All estimates are
expressed in 1983 dollars.
"Ibid, p. 3-11.
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4-6
Response. No public health and welfare or environmental costs or
benefits are associated with notification and recordkeeping, £er se. The
public health and welfare and environmental effects of the proposed regulation
are caused solely by the cleanup of releases that would not otherwise have
been cleaned up, or which would have been cleaned up improperly, without the
advice given to the releaser by the government because of the notification.
Although accurate data are generally unavailable, Nuclear Regulatory Com-
mission, Department of Energy, and Environmental Protection Agency sources
agree generally that responsible parties currently respond adequately to a
very large percentage of releases. Responsible parties are liable for
response costs and natural resource damages for all releases of radionuclides,
whether these releases are above or below the RQs. It is logical to assume,
however, that a responsible party is more likely to respond to a release that
is above the RQ than it is to a release that is below the RQ simply because
the release is larger and the National Response Center must be notified of the
release. For purposes of this analysis, therefore, we assume that responsible
parties adequately respond to 90 percent of radionuclide releases below the RQ
and adequately respond to 95 percent of radionuclide releases above the RQ.
Hence, if the RQ is lowered, we might expect a 5 percent increase in response
activities for those releases that are now reportable. For those
radionuclides whose proposed RQ is greater than one pound, we would expect a 5
percent decrease in response activities for releases that are greater than one
pound but are no longer reportable under the proposed regulation.
The Regulatory Impact Analysis (RIA) for RQ adjustments of 340 CERCLA
hazardous substances estimated the range of response costs incurred by
regulated parties to be between $185 and $2,093 per release (1983
dollars).5 The costs are a function of the size of the release.
Radionuclide releases are, in general, much smaller than the chemical releases
considered in the RIA, which range from one pound to 5000 pounds.
Radionuclide release responses, however, often require special equipment and
protective clothing, resulting in higher response costs. To estimate
radionuclide response costs, therefore, we did not rely on the RIA estimates.
Instead, we developed three model release scenarios. We based our model
scenarios on release reports in the data sets and tried to select scenarios
which reasonably represented a fair number of the events in the radionuclide
data base. The three scenarios represent a range of response actions and
response costs.
Scenario 1 represents a small radionuclide release resulting from a faulty
valve, for example, at a conversion facility or laboratory. The radionuclide
released could conceivably be uranium-238, tritium, or krypton-85. The
appropriate response for scenario 1 would probably be no more than monitoring
for an 8-hour period. Costs for scenario 1 are used for all releases whose
response costs would be expected to be minimal.
5Ibid, p. 3-13.
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4-7
Scenario 2 represents a laboratory or hospital situation where a
radionuclide is accidently disposed of with the regular garbage. The
radioactive material is then shredded and put in a dumpster. Radionuclide
releases likely to be represented by this model include cobalt-60, iodine-125,
iodine-131, and iridium-192. Scenario 2 costs include monitoring and
decontamination.
Scenario 3 involves a hypothetical release of uranium-238 to surface
water. The release may have resulted from a pipe failure or lagoon overflow
and involves major response actions including monitoring and dredging of
contaminated sediment.
For each scenario, we have estimated the costs of hypothetical responses,
shown in Exhibit 4-1. All costs are in 1986 dollars. Based on the frequency
of occurrence of different types of releases in our data base, we assume
scenario 1 costs are representative costs for 66 percent of response actions;
scenario 2 costs are representative costs for 27 percent of response actions;
and scenario 3 costs are representative costs for 7 percent of response
actions. Using these percents as weights for each of the cost estimates, we
derive an average weighted response cost for radionuclide releases of about
$5,400 per response ((.66 x $160) + (.27 x $5,720) + (.07 x $53,600)). These
estimates were deliberately based on small release scenarios, because large
decontamination actions would occur regardless of the RQs involved and are
therefore expected to be unaffected by the proposed RQ adjustments. We
realize that this estimation process is very imprecise, however, and in
Chapter 7 of this report, we test the sensitivity of our results to the
response cost estimates.
4.2.2 Value of Actions Performed by the Government
Most of the actions performed by the government involve costs which do not
vary with the type of CERCLA hazardous substance released. Notification
processing, off-scene monitoring, and on-scene monitoring costs for
radionuclide releases are assumed to be similar to costs incurred for other
CERCLA hazardous substance releases. The RIA in support of the RQ adjustment
for 340 CERCLA hazardous substances assumed the government actions were valued
at $70 for process notifications, $235 for off-scene monitoring, and $2,761
for on-scene monitoring.6 We adopt these estimates in this analysis of the
effects of the proposed RQ adjustments for radionuclides.
The RIA also assumes that the likelihood of off-scene monitoring and
on-scene monitoring by the government varies with the size of the reported
release. For off-scene monitoring, the RIA assumes government response is
likely between forty percent and seventy percent of the time. For on-scene
monitoring, the RIA assumes government response is likely between five and
twenty percent of the time. Because we believe a government response action
is probably more likely for a radionuclide release than for the average
chemical release simply because of public awareness and concern over radiation
6Ibid, p. 3-17.
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4-8
EXHIBIT 4-1
RELEASE SCENARIO 1
CIRCUMSTANCE: A small radionuclide release from a failed valve at a
conversion facility or laboratory
TYPICAL RADIONUCLIDES: 10 2 curies of Uranium-238, Tritium, or Krypton-85
RESPONSE ACTIVITIES AND COST ESTIMATES:
A response may not be necessary nor appropriate for air releases of this
size. However, we assume the response requires 8 hours of monitoring.
Total estimated cost = $160
RELEASE SCENARIO 2
CIRCUMSTANCE: Radionuclide source accidently disposed of as standard solid
waste, shredded, and put in dumpster.
TYPICAL RADIONUCLIDES: 10 2 curies of Cobalt-60, Iodine-125, Iodine-131,
or Iridium-192
RESPONSE ACTIVITIES AND COST ESTIMATES:
Monitoring and decontamination of bench, trash can, and janitor cart -- $320
Monitoring and decontamination of shredder and dumpster -- $5,400
Total estimated cost = $5,720
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4-9
EXHIBIT 4-1 (continued)
RELEASE SCENARIO 3
CIRCUMSTANCE: Radionuclide release from process discharge pipe to stream
which feeds into a river.
TYPICAL RADIONUCLIDES: 20 curies of Uranium-238
RESPONSE ACTIVITIES AND COST ESTIMATES:
Monitoring (1 wk.) at outfall, ditch, stream, and river -- $1,600
Ground water monitoring well (drilling and sampling) -- $1,000
Treatment of 5,000 gallons of contaminated water ($0.20/gal, including
mobilization for ion-exchange resin) -- $1,000
Dredging and disposal of contaminated sediments (1000 cu ft) -- $50,000
Total estimated cost = $53,600
Source: ICF analysis based on the following sources: U.S. Environmental
Protection Agency, Remedial Response at Hazardous Waste Sites (EPA
540/2-84-002), March 1984; Tawil, J J. et al., Off-Site Consequences
of Radiological Accidents: Methods, Costs, and Schedules for
Decontamination, Battelle Northwest Laboratories, Prepared for U.S.
Nuclear Regulatory Commission, August 1985; ICF 1986.
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contamination, we assume, for purposes of this analysis, that the likelihood
of an off-scene monitoring response by the government is seventy percent and
the likelihood of an on-scene monitoring response by the government is twenty
percent, the high end of the assumed ranges for chemical releases. We test
the sensitivity of our results to these assumptions in Chapter 7 of this
report.
Direct removal cost estimates in the RIA for 340 CERCLA hazardous
substances were assumed to be $39,273.7 We modify this cost estimate in
this analysis because direct response actions for radionuclide releases tend
to be very different from direct response actions for other chemical releases;
for example, decontamination procedures often involve special equipment and
protective clothing.
For purposes of this analysis, therefore, we rely on the model cost
scenarios discussed earlier in the chapter and described in Exhibit 4-1. We
assume the government would get involved in only the most costly scenario and
so assume scenario 3 costs ($53,600) are appropriate for government removal
actions. We further assume that five percent of all radionuclide releases
will involve government response activities.8
The unit cost estimates are not precise, relying on estimates that may not
be totally applicable for radionuclide release actions. We have made very
conservative assumptions regarding likelihood of a response action and have
tried to cost each action conservatively so as to err on the side of higher
cost estimates. We discuss, in Chapter 7 of this report, the sensitivity of
our results to these assumptions.
4.3 VALUATION OF BENEFITS
The economic benefits of adjustments are the decreased industry and
government costs that result from raising RQs for some radionuclides.
Assuming that industry generally reports and responds to a release at or
exceeding the RQ, raising the RQ should decrease industry's and government's
notification, recordkeeping, processing, monitoring, and response costs. The
unit cost savings are the same as the unit cost estimates discussed in Section
4.2 above.
The public health and welfare and environmental benefits of RQ adjustments
are the avoided or decreased damage costs that result from lowering RQs for
most radionuclides. Assuming that a releaser generally reports (or is more
7Ibid, p. 3-17.
8The RIA for the 340 CERCLA hazardous substances assumed the likelihood
of a direct government response action was between one and five percent. We
assume the high end of the range is more appropriate for radionuclide
releases. We test this assumption in Chapter 7 of this report.
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4-11
likely to report) a release at or exceeding the RQ, lowering the RQ should
both increase the number of notifications and provide incentives for earlier
responses to releases.
The public health and welfare and environmental effects of adjusting RQs
for some substances are difficult to identify, predict, and measure for
several reasons.
The only certain effect of lowering RQs is that it
increases the number of reportable releases. The costs
and benefits of RQ adjustments are several steps removed
from changes in the number of reportable releases and
depend upon uncertain regulated party and government
behavior.
Even if it could be established that lowering RQs
generally decreases public health and welfare and
environmental damages, it is difficult to specify the
nature, magnitude, and value of those changes. Almost
no data exist on the damages associated with past
releases of small quantities of radionuclides. There is
even less information on the role (if any) that
reporting levels or notifications play in augmenting
these damages. Therefore, there is hardly any
information upon which to base prediction of effects.
If lowering RQs for most radionuclides leads to more or earlier
notifications and more effective response actions, then the following benefits
could occur:
Reductions in the threat of mortality and acute or
chronic morbidity. These include reductions in human
exposure (ingestion, inhalation, or physical contact) to
radiation contamination.
Reductions in the threat of general environmental
damages such as plant and animal damages. These
include reductions in the adverse impact of released
radionuclides on crop yields, non-crop vegetation, fish,
wildlife, and farm and commercial animal production.
Reductions in the threat of public damages. These
include mitigation of property damages, recreational
damages, and lost productivity.
Without data on release damages and the possible relationship of
notification to damages, it is not possible to quantify the public health and
welfare and environmental costs and benefits under the proposed regulation.
However, if greater non-economic benefits result from more reporting, then the
public health and welfare and the environmental benefits provided by the
proposed regulation will probably be positive because 96 percent of all
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4-12
specific radionuclide RQ adjustments are downward, resulting in a net increase
m expected reports to the National Response Center.
The unit costs and cost savings estimates can now be combined with the
estimated number of baseline reportable releases to determining the baseline
and incremental costs and benefits attributable to the proposed regulation.
Chapter 5 presents the cost estimates and Chapter 6 presents the benefits
estimates.
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CHAPTER 5
ESTIMATED ANNUAL COSTS OF THE PROPOSED
RQ ADJUSTMENTS
This chapter discusses the costs of reportable quantity (RQ) adjustments,
including the potential increased economic burden on society that may be
caused by lowering most of the radionuclide RQs, and the potential reduction
in public health and welfare and the environmental quality that may be caused
by raising some radionuclide RQs. The analysis in this chapter combines the
information presented in Chapters 3 and 4 to compute the annual cost of RQ
adjustments.
The costs of RQ adjustments are a result of the change in the number of
releases reportable to the National Response Center. Reporting a release
causes both the regulated community and the government to incur costs for
notification, recordkeeping, and possible response activities; not reporting a
release could affect human health and welfare and environmental quality.
Section 5.1 presents the estimates of the change in reportable releases under
the proposed regulation; Section 5.2 presents the estimate of the incremental
costs of the proposed RQ adjustments; and Section 5.3 presents firm-level
economic effects of the proposed regulation.
5.1 THE ESTIMATED CHANGE IN THE NUMBER OF REPORTABLE RELEASES
The estimated change in the number of reportable releases is equal to the
difference between baseline reportable releases (19) (derived in Chapter 3)
and reportable releases under the proposed regulation. In the baseline, a
radionuclide release at a licensed or regulated facility is reportable to the
National Response Center if it equals or exceeds permitted levels by one
pound. Under the proposed regulation, a radionuclide release is reportable to
the National Response Center if it equals or exceeds permitted levels by the
proposed RQ.
Most licensed or regulated facilities must comply with the Nuclear
Regultory Commission 10 CFR Part 20 release limitations. Because the ALIs in
10 CFR Part 20 are the basis for the derivation of the proposed RQ
adjustments, for purposes of this analysis, federally permitted levels are
assumed to equal the proposed RQs.1 Thus, a reportable radionuclide release
under the proposed regulation from a facility holding a federal permit is
assumed, for purposes of this analysis, to be all radionuclide releases that
1This is a simplification because the 10 CFR Part 20 intake limitations
are based on a dose of 5 rem for nuclear facility workers. EPA based its
proposed RQs on a dose-equivalent of 500 millirem and then made several
conservative assumptions to calculate the release levels for the proposed
RQs. We examine in Chapter 7 of this report the sensitivity of our results to
the number of reportable releases.
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5-2
equal or exceed twice the proposed RQ. Because the proposed RQs are being
used as a proxy for the federally permitted release levels and releases
exceeding these levels by an RQ or more must be reported to the National
Response Center, all releases from facilities holding federal permits that
equal or exceed twice the proposed RQ must be reported to the National
Response Center.
To estimate the expected number of releases above two times the proposed
RQ, we rely on the size distribution of releases in our data base and each
radionuclide's frequency of release shown in Exhibit 3-2 of this report. The
probability that a particular radionuclide release will equal or exceed two
times the proposed RQ is estimated to be the frequency of release of that
radionuclide in our data base, multiplied by the fraction of releases in our
data base that equal or exceed two times the proposed RQ. This calculation is
performed for each of the radionuclides identified in our data base. We then
sum across the radionuclides. Hence, reportable radionuclide releases under
the proposed regulation is estimated to be the number of annual releases
(250), multiplied by the probability that a radionuclide will be released in
quantities equal to or exceeding two times the proposed RQ. Reportable
releases are estimated to be approximately 62 releases annually. Thus, the RQ
adjustments result in 43 (62-19) incremental reportable releases.
Although 30 radionuclides have upward adjustments of their RQs, there is
no change in the number of reportable releases for these radionuclides in our
data base. In both the baseline and with the proposed RQs, we estimate there
will be approximately 18 reportable releases annually of these radionuclides.
We estimate there will be no change in the number of releases that must be
reported to the National Response Center. That is, based on the release
information in our data base, 18 releases would be required to be reported in
the baseline and 18 releases will be required to be reported under the
proposed regulation. Therefore, there is no expected increase in the threat
to public health or welfare or the environment. The remainder of this chapter
will estimate the incremental costs associated with the downward adjustment of
727 radionuclide RQs.
5.2 ESTIMATED COSTS OF THE PROPOSED RQ ADJUSTMENTS
Because we estimate that the 30 radionuclides whose proposed RQ exceeds
one pound have no expected change in the number of reportable releases, all of
the costs under the proposed regulation are due to the reduction in the
proposed radionuclide RQs and economic costs associated with increases in
reportable releases to the National Response Center. The cost calculation is
shown in Exhibit 5-1. Many of the unit costs described in Chapter 3 were
derived from estimates in the RIA supporting the RQ adjustments for 340 CERCLA
hazardous substances. Those cost estimates were in 1983 dollars. For
purposes of this analysis, we have converted all cost estimates to 1986
dollars.
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5-3
EXHIBIT 5-1
CALCULATIONS OF ANNUAL COSTS OF RQ ADJUSTMENTS
UNDER THE PROPOSED REGULATION
COSTS TO BE REGULATED PARTIES
A. Cost of Notification
(43 incremental reports) x $336 =
B. Cost of Recordkeeping
(43 incremental records) x $29.24 =
C. Cost of Response
(43 incremental releases) x (.05) x ($5,400) =
TOTAL COST TO REGULATED PARTIES
COSTS TO GOVERNMENT
D. Cost of Notification Processing
(43 incremental reports) x $73 =
E. Cost of Off-Scene Monitoring
(43 incremental releases) x (.70) x ($245) =
F. Cost of On-Scene Monitoring
(43 incremental releases) x (.20) x (2,873) =
G. Cost of Direct Removal
(43 incremental releases) x ( 05) x ($53,600) =
TOTAL COST TO GOVERNMENT
TOTAL COST OF PROPOSED REGULATION (1986 dollars)*
*The RIA cost estimates supporting the RQ adjustment for 340 CERCLA
hazardous substances are in 1983 dollars. The 1983 dollars were converted to
1986 dollars using the Construction Cost Index. March 1986 dollars equal 4219
and 1983 dollars equal 4055; Engineering News Record, March 1986, p. 107.
Source: ICF estimates.
$ 14,448
$ 1,257
$ 11,610
$ 27,315
$ 3,139
$ 7,375
$ 24,708
$ 115,240
$ 150,462
$ 177,777
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D -<+
The total cost to regulated parties is the sum of notification,
recordkeeping, and response costs. The costs of the proposed
regulation are calculated in the following manner:
A. Notification. There are 43 incremental reportable
radionuclide releases and each report costs an estimated
$336, yielding a total annual cost of about $14,500.
B* Recordkeeping. Multiplying 43 incremental reportable
releases by $29.24, the cost of recordkeeping per
reportable release, yields total annual recordkeeping
costs of about $1,260.
C. Response. It is assumed in this analysis that the
probability of response to a given release is 90 percent
if the release is below the RQ and 95 percent if the
release is above the RQ. Therefore, an extra 5 percent
of incremental reportable releases will be responded to
as a result of lowering RQs. Multiplying the number of
incremental reportable releases (43) by the incremental
probability of response (0.05) and by the weighted
average cost per response ($5,400), equals total annual
response costs of about $11,600.1
The total cost to regulated parties, which is the sum of notification costs,
recordkeeping costs, and response costs, is about $27,300.
The total cost to the government of RQ adjustments is the sum of
notification processing, off-scene monitoring, on-scene monitoring, and direct
removal costs. These costs are calculated in the following manner:
* Notification Processing. A total annual notification
processing cost of approximately $3,140 is calculated by
multiplying 43 incremental reportable releases by $73
(the estimated cost of processing one notification).
* Off-Scene Monitoring. Multiplying 43 incremental
reportable releases by the probability that off-scene
monitoring is required3 (.70), by the cost of
off-scene monitoring per release ($245), yields a total
annual off-scene monitoring cost of about $7,400.
2The sensitivity analysis in Chapter 7 tests the results of assuming
different probabilities of response to releases below and above the RQ.
3The sensitivity analysis in Chapter 7 tests the results of assuming
different probabilities of off-scene monitoring.
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3 -3
On-Scene Monitoring. Multiplying 43 incremental
reportable releases by the probability that on-scene
monitoring is required" (.20), by the cost of on-scene
monitoring per release ($2,873) yields a total annual
on-scene monitoring cost of about $24,700.
Direct Removal. Multiplying 43 incremental
reportable releases by the probability of direct
response by the government (.05) and the estimated cost
of direct removal ($53,600) yields a total annual cost
for direct responses of about $115,000.5
The total cost to the government, which is the sum of notification processing
costs, off-scene monitoring costs, on-scene monitoring costs, and direct
response costs is approximately $150,500.
The sum of the total costs to the government and to regulated parties
equals the total costs of all effects, which is approximately $178,000.
5.3 FIRM-LEVEL ECONOMIC EFFECTS
The estimated costs of the proposed regulation are small relative to the
sales and revenues generated by the industries most likely to be affected by
the proposed regulation. The average facility handling radionuclides is not
expected to experience a radionuclide release above the proposed RQ. We
estimate that there will be about 43 incremental reportable releases annually,
and there are as many as 22,000 facilities potentially affected by the
proposed regulation. The probability that any particular facility will
experience a reportable release is a function of the types, quantities, and
forms of radionuclides used and produced at the facility, and the facility's
handling procedures.
The types of facilities affected by the proposed regulation vary widely,
from laboratories to large uranium mining operations. It is not possible to
predict with any degree of accuracy the facilities most likely to experience
reportable radionuclide releases and, therefore, it is not possible to develop
a financial model of a typical releaser. We can discuss in general terms,
however, the magnitude of costs for a facility experiencing a reportable
release under the proposed regulation. These cost estimates are as follows:
Notification costs $336
Recordkeeping costs $30
Cleanup costs $5,400
""The sensitivity analysis in Chapter 7 tests the results of assuming
different probabilities of on-scene monitoring.
5The sensitivity analysis in Chapter 7 tests the results of assuming
different probabilities of direct response.
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5-6
The total cost to a facility or vessel experiencing a reportable
radionuclide release is, therefore, estimated to be about $5,800. The cost to
the facility will depend directly upon the cleanup costs, estimated to range
between zero and $54,000, with a weighted average cleanup cost of about $5,400.
The total annual burden under the proposed RQ adjustments experienced by
all affected entities depends on the size and number of reportable releases.
The burden imposed by the CERCLA notification requirements on an individual
business depends directly on the number of reportable releases that occur at
that facility. Most of the facilities potentially affected would, in fact,
experience no costs from the notification requirements because they would have
no reportable releases. Even assuming a reportable release occurs at a
facility, the likely costs incurred are so small that we must conclude that
the proposed regulation will not adversely affect any facility, large or small.
The largest costs under the proposed regulation is due to cleanup costs.
Most releases are cleaned up regardless of whether the release is above or
below the RQ. Cleanup of large releases will probably not be affected by the
proposed RQ adjustments because they would be reportable even without the
proposed regulation and cleanup would probably occur regardless of the RQ. To
put the magnitude of the costs attributable to the proposed regulation into
prospective, it is important to consider the benefits of the proposed RQ
adjustments as well. These are discussed in Chapter 6 of this report.
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CHAPTER 6
ESTIMATED BENEFITS OF THE PROPOSED RQ ADJUSTMENTS
This chapter analyzes the benefits of adjusting the reportable quantities
(RQs) for radionuclides. The benefits fall into two categories:
(1) Cost savings to affected parties. Raising RQs for some
radionuclides could decrease the number of reportable
releases. This decrease in turn reduces the costs to
regulated parties and government for notification,
recordkeeping, response, and monitoring.
(2) Public health and welfare and environmental benefits.
Lowering RQs for some radionuclides increases the number
of reportable releases. This increase in turn decreases
the probability of public health or welfare or
environmental damage if earlier or more notifications of
releases are followed by prompt, appropriate response
actions by the responsible party (or in some cases, by
the various local, state, or federal agencies involved).
Benefits of the proposed regulation flow from government and regulated party
responses to changes in the number of reportable releases. If we assume that
industry normally reports and responds to a radionuclide release equal to or
exceeding its RQ, then raising the RQ level should decrease the notification,
recordkeeping, processing, monitoring, and response costs of the regulated
community and government.
Of the 757 radionuclides whose RQs are individually adjusted in the
proposed regulation, only 30 radionuclides have a proposed RQ greater than one
pound. Exhibit 6-1 displays these 30 radionuclides and their proposed RQs.
Six of these 30 radionuclides are represented in our data base. These six
radionuclides with proposed RQs that are greater than the curie equivalent of
one pound were reported released 198 times in the recent past in the data sets
we examined. However, because we estimate there will be no change in the
number of reportable releases of these 30 radionuclides as a result of the
proposed RQ adjustments, there are no cost savings attributable to the
proposed regulation.
The public health and welfare and environmental benefits of RQ adjustments
are, therefore, the avoided or decreased damage costs that result from the
lower RQs for 727 radionuclides. Assuming that a responsible party is more
likely to respond to a release at or exceeding the RQ, lowering reporting
levels for a substance should increase the number of notifications and provide
incentives for earlier responses to releases. These notifications may lead to
more prompt, effective cleanup or containment of releases, thus avoiding or
mitigating damages that would otherwise occur.
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6-2
EXHIBIT 6-1
RADIONUCLIDES WITH PROPOSED RQs
GREATER THAN ONE POUND
Proposed RQ
Radionuclide
Curies
Pounds
Aluminum-26
10
1.2
Cadmium-113
1
905,000,000
Calcium-41
1000
25.3
Cesium-135
100
250
Chlorine-36
100
6.7
Gadolinium-152
0.001
103,000
Hafnium-182
0.1
1
Indium-115
0.1
31,200,000
-Krypton-81
1000
104
Lanthanum-138
1
90,100
Lead-205
100
1,910
Lutetium-176
1
39,000
Manganese-53
1000
1,200
*Nickel-59
1000
32.7
Palladium-107
100
428
Plutonium-244
0.01
1.2
Potassium-40
100
30,800
Rhenium-187
1000
51,900,000
Rubidium-87
1000
26,200,000
Samarium-147
0.01
978
Selenium-79
100
2.9
Tantalum-180
10
111,000,000
Technetium-97
1000
1,550
Technetium-98
10
25.3
-Technetium-99
100
13
Tellurium-123
100
985,000,000
*Thorium-232
0.001
20
"Uranium-235
0.1
103
Uranium-236
0.1
3.4
*Uranium-238
0.1
654
^Radionuclides represented in our data base.
Source: Memorandum from Alan Messing, Environ-
mental Monitoring and Services, Inc. to
Ellen Warhit, ICF, "Radionuclides with
Proposed RQs in Greater Than or Equal to
one pound," October 1986.
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6-3
If lowering RQs for certain radionuclides leads to more or earlier
notifications and more effective response actions, then the following benefits
may occur:
Reductions in the threat of mortality and acute
chronic morbidity;
Reductions in the threat of general environmental
damages such as plant and animal damages; and
Reductions in the threat to public welfare damages
(including property damage, recreational damage, and
lost productivity).
Unfortunately, we have no data on release damages nor on the possible
relationship of the timing of notifications to the extent of damages. It is
not possible, therefore, to quantify the benefits of the proposed regulation.
The direction of all but 30 of the 757 individual proposed RQ adjustments is
downward, however, resulting in an expected increase m the future number of
radionuclide releases reported to the National Response Center. We anticipate
that the earlier notification will result in faster and more appropriate
response actions, yielding benefits to both the regulated community (in terms
of lower response costs) and to society in general (in terms of reduced theats
to human health and welfare and the environment).
Our analysis of both costs and benefits under the proposed regulation is
based on several key assumptions which, if inaccurate, could cause the
estimates to misrepresent the effects of the proposed regulation. We,
therefore, test the major assumptions to determine the sensitivity of our
results to each assumption. The results of this analysis are presented in
Chapter 7 of this report.
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CHAPTER 7
SENSITIVITY ANALYSIS
Several times in this analysis, data have been used whose margin of error
could have been improved through further research. Similarly, in several
instances, key study assumptions were made which used the best available
information from a very limited data base. Under these circumstances,
therefore, it is important to conduct a sensitivity analysis to test the
impact that changing key study assumptions would have upon the results of the
analysis. The first two sections of this chapter present a sensitivity
analysis on the results of this analysis. The first section discusses the
importance of a sensitivity analysis and establishes the ranges for the key
variables and assumptions that will be tested. The second section presents
the results of the sensitivity analysis using these ranges. The third
section, Section 7.3, describes our statistical analysis of our radionuclide
release data base; and Section 7.4 summarizes our results.
7.1 CONCEPTS AND KEY VARIABLES
In general, a sensitivity analysis indicates how the results of an
analysis might vary if some of the basic building blocks of the study had been
different. If, for example, the analyst is reasonably certain that one of two
particular values for a key variable is correct but does not know which one,
or that two values will bracket the true value, each may be used in the
sensitivity analysis. The result is then presented twice -- once for each
value of the key variable.
In other situations, there may be very little guidance on a particular key
variable. A reasonable guess can be made about the likely value for the
variable; other values may be selected to determine the sensitivity of the
results to this choice. This technique has the virtue of indicating the range
of possible results, although it does not indicate whether the "true" results
are included.
A sensitivity analysis is sometimes thought to add information, and it
does in the sense of bracketing a range. Nonetheless, the range may be too
small or too large, depending on the quality of the values used in the
sensitivity analysis. Thus, the value of the analysis still depends on the
quality of the input data.
This sensitivity analysis tests the impact of changing six basic
assumptions that have been used during this analysis. These assumptions
include: (1) the number of incremental reportable releases; (2) the hours
required and, therefore, the unit cost per release notification; (3) the
frequency of on-scene monitoring; (4) the frequency of direct removal; (5) the
frequency of off-scene monitoring; and (6) the frequency of cleanups by
responsible parties. We test the frequency of actions rather than the unit
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7-2
costs of performing such actions because the cost estimates are considered
reasonable and adjustments in the cost estimates are overwhelmed by the
frequency estimates.
Assumptions regarding each of these key variables are varied in the
following manner in the sensitivity analysis:
1. Number of incremental reportable releases. The number of incremental
reportable releases is perhaps the most important single variable on which
costs are estimated. The analysis in Chapter 5 assumes there will be 43
annual incremental reportable releases of radionuclides. This estimate may
vary because the estimates of under-reporting could be inaccurate, the AEOD
data set may not contain representative facilities, or the number of releases
may not be proportional to the number of facilities. To reflect the
order-of-magnitude changes in costs that would result from large differences
in the numbers of incremental reportable releases, the sensitivity analysis
will estimate the results of halving and doubling this figure. Thus, the
following assumption is tested:
Number of Incremental Releases
Low Estimate Base Case High Estimate
20 43 100
2. Notification hours. The costs associated with notification represent
over 50 percent of total costs to regulated parties. The base case analysis
in Chapter 5 assumes that 3 hours of managerial time and 2 hours of technical
time would be required for each release. To estimate a range of notification
costs that might be experienced by industry and individual firms, the estimate
of hours are halved and doubled for the senstivity analysis, resulting in the
following unit cost estimates:
Managerial and Technical Hours Required for Reporting
Low Estimate Base Case High Estimate
$168 $336 $672
No variation of the hourly cost of managerial and technical time is
available. The average hourly rates used in the base case analysis are
considered to be reasonably accurate. Moreover, potential variations in the
magnitude of these rates is overwhelmed by the potential variation in hours
required for reporting.
3. Frequency of cleanups. The base case analysis assumes that there is
a measurable difference in responses to releases that are above or below the
RQ. If this assumption is inaccurate (i.e., if responsible parties would not
respond differently to releases above or below the RQ), then no costs or
benefits of cleanup can be attributed to regulations that adjust RQs. In the
sensitivity analysis, various assumptions are used relating to this difference
in percentage of releases cleaned up above and below RQs to estimate response
costs.
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7-3
Frequency of Cleanups
Low Estimate Base Case High Estimate
.00 .05 .20
4- Frequency of off-scene monitoring. In Chapter 5, it is assumed that
all releases require notification processing but that some of these releases
require no further action. The three sets of estimates for frequency of
off-scene monitoring that will be used in the sensitivity analysis are as
follows:
Frequency of Off-Scene Monitoring
Low Estimate Base Case High Estimate
.35 .70 .90
5- Frequency of on-scene monitoring. It is also important to examine
the sensitivity of estimates of the frequency with which on-scene monitoring
efforts will be needed (i.e., the percent of incidents that results in federal
government on-scene monitoring) both because the government share of costs is
about 85 percent of total effects, and because on-scene monitoring activities
account for about 16 percent of government effects.
Based on judgments of the likelihood of need for on-scene monitoring and
the availability of resources, the following "low" and "high" estimates have
been formulated.
Frequency of On-Scene Monitoring
Low Estimate Base Case High Estimate
.10 .20 .40
6. Frequency of direct removal. The following estimates of frequency of
direct removal are constructed and used in the sensitivity analysis. Direct
removal costs represent about 77 percent of government costs.
Frequency of Direct Removal
Low Estimate Base Case High Estimate
.025 .05 .20
7.2 RESULTS OF THE SENSITIVITY ANALYSIS
This section presents the results of the sensitivity analysis. The
section includes a description of changes in estimated costs to the government
and regulated parties that occur from reporting and cleanup activities using
the assumptions which were described in Section 7.1. The results of this
analysis are organized in the same manner as the previous section and
presented in Exhibit 7-1.
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7-4
EXHIBIT 7-1
SENSITIVITY ANALYSIS RESULTS
Low Estimate Base Case
1. Number of incremental
Reportable releases
Assumption :
Cost of proposed regulation:
2. Notification hours
Assumption
Notification Costs :
Cost of proposed regulation:
3. Incremental frequency of
cleanups by responsible
parties
Assumptions
Cost of Cleanups
Cost of proposed regulation
4. Frequency of off-scene
monitoring
Assumption
Off-scene monitoring costs
Cost of proposed regulation
5. Frequency of on-scene
monitoring
Assumption
On-scene monitoring costs
Cost of proposed regulation
Frequency of direct govern-
ment removal
20
$ 82,700
168
$ 7,200
$170,700
00
$ 0
$166,200
.35
$ 3,700
$174,300
.10
$ 12,350
$165,400
43
$178,000
336
$ 14,500
$178,000
.05
$ 11,600
$178,000
.70
$ 7,400
$178,000
.20
$ 24,700
$178,000
High Estimate
100
$ 413,400
672
$ 28,900
$ 192,400
.20
46,400
212,800
.90
9,500
180,000
.40
49,400
202,500
Assumption
Direct removal costs
Cost of proposed regulation
Cost of Proposed Regulation
with All assumptions
varied
.025
$ 57,600
$120,200
$ 40,000
.05
$115,240
$178,000
$178,000
.20
461,000
523,500
$1,400,000
Source: ICF estimates.
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7-5
1- Number of incremental reportable releases. Estimates of the number
of reportable releases affect all of the estimates of costs that result from
increased notification, recordkeeping, and response activities on the part of
government and regulated parties. Exhibit 7-1 presents the results of
changing the estimated number of incremental reportable releases and compares
the cost of the proposed regulation to the base case estimate of 43
incremental reportable releases.
2- Notification hours. Varying the estimated number of hours required
to report releases will affect the cost estimates associated with notification
activities. Exhibit 7-1 presents the results of the sensitivity analysis, in
which the base case hours estimates are halved and doubled. Note that this
sensitivity analysis pertains only to effects on regulated parties; the costs
to government do not change with variations in industry hours.
3- Frequency of responsible party cleanups. Varying the assumption
concerning the difference in responsible parties' cleanup efforts for reported
versus unreported releases leads to different response costs for regulated
parties. The difference in industry response to reported releases versus
unreported releases is shown in Exhibit 7-1.
** Frequency of off-scene monitoring. Variations in the assumed
frequency of off-scene monitoring affect the costs associated with government
off-scene monitoring activities. Exhibit 7-1 shows the effect on government
costs.
5. Frequency of on-scene monitoring. Variations in the assumed
frequency of on-scene monitoring for radionuclide releases affect the costs
associated with government on-scene monitoring activities for each
alternative. Exhibit 7-1 shows the effect on on-scene monitoring costs of the
base case frequencies and of lower and higher frequency estimates.
6- Frequency of government direct response. Variations in the assumed
frequency of direct response affect the costs of the proposed regulation.
Exhibit 7-1 shows the effect on direct response costs of the base case
frequencies and of changing the frequency estimates.
By varying all assumptions simultaneously, we estimate that the proposed
regulation will cost between $40,000 and $1,400,000 annually, with a most
likely annual cost of about $178,000.
7.3 STATISTICAL ANALYSIS OF RADIONUCLIDE DATA BASE
The analysis for estimating the number of reportable releases in both the
baseline situation and under the proposed regulation implicitly assumes that
there is no correlation between the size of a release and the identity of the
radionuclide released. We have tested this hypothesis.
An analysis of variance model (ANOVA) was used to test this hypothesis on
a formal basis. The release observations were grouped by isotope and the
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7-6
General Linear Model (GLM) procedure of the Statistical Analysis System (SAS)
was used for the test. The results indicated1 that we could not reject the
hypothesis of no association between isotope and mean release amount.
Therefore, we have assumed that there is no such association.
7.4 SUMMARY
A sensitivity analysis is as enlightening as the data that cause the
estimates to change. The results in this chapter suggest that halving and
doubling many of the effects and altering other key assumptions would not
change the overall conclusions of the analysis that the estimated cost of the
regulation is small. Because data on the health and welfare and environmental
effects of altering RQs are not available, this sensitivity analysis does not
vary these effects.
1The F-statistic was 1.05 (d.f. of 52;632) which was a p-value of 0.39.
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APPENDIX A
PROFILES OF FACILITIES THAT RELEASE RADIONUCLIDES
Radionuclide emissions are most closely identified with the nuclear power
industry, but are commonly released from other activities as well. The
Nuclear Regulatory Commission, agreement states delegated authority by the
Commission, and the Department of Energy (DOE) all license or oversee a
variety of industrial facilities and non-industrial operations that emit
radionuclides. In addition, several industrial categories not licensed by the
Commission or an agreement state could also potentially release radionuclides
at levels equalling or exceeding an RQ. Coal-fired utilities and industrial
boilers, and mineral extraction industries such as uranium, aluminum, zinc,
copper, lead, and phosphorous mining all release certain amounts of
radionuclides during their operations.
The following sections briefly discuss each of the release categories
cited above, describing the source of radionuclide emissions, the number of
facilities within each category, and, where available, general trends in the
industries. Discussion in A.l encompasses most of the Nuclear Regulatory
Commission and agreement state licensees, Section A.2 discusses Department of
Defense facilities; Section A.3 discusses Department of Energy facilities; and
Sections A.4 and A.5 discuss coal-fired utility and industrial boilers, and
the primary mineral extraction industries, respectively.
A. 1 NUCLEAR REGULATORY COMMISSION AND
AGREEMENT STATE LICENSEES
The Nuclear Regulatory Commission has authority under the Atomic Energy
Act to license source, byproduct, and special nuclear materials. Agreement
states have been delegated licensing authority by the Commission to license
source, byproduct, and special nuclear materials for facilities within their
boundaries. As of 1984, there were 8,900 Commission licensees and 13,000
agreement state licensees.1 All licensees are subject to the radioactive
material release limits specified in 10 CFR Part 20, as well as other controls
specified by the license. For purposes of this discussion, licensees have
been divided into five general categories: power reactors, research and test
reactors, radiopharmaceuticals, radiation source manufacturing, and other
licensees. Most Department of Defense facilities are also licensed by the
Commission but are discussed separately in Section A.2 of this report.
A. 1.1 Power Reactors
Power reactors are units which utilize a controlled fission reaction of
uranium fuel to produce heat. The heat converts water to steam, which
1 U.S. Nuclear Regulatory Commission, 1984 Annual Report, p. 73.
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A-2
provides the force to spin a turbine-generator to produce electricity. The
nuclear fission chain reaction is controlled by the reactor's control rods.
The movement of the control rods up or down within the fuel assemblies
sustains the chain reaction at a desired power level. There are over 100
nuclear plants in the United States in operation, generating approximately 13
percent of electricity consumption.
Releases resulting from "nuclear incidents" (see Section 11(q) of the
Atomic Energy Act) at facilities covered by the Price-Anderson Act are exempt
from CERCLA reporting requirements. Releases at these facilities that are an
RQ or more, but do not constitute a nuclear incident, must be reported under
CERCLA to the National Response Center.
A. 1.2 Research and Test Reactors
As of 1983, there were 70 reactors in operation in the United States for
basic and applied research and for teaching purposes. The research conducted
includes testing of reactor designs, components, and safety features, as well
as work in the fields of physics, biology, and chemistry.
A. 1.3 Radiopharmaceuticals
Radiopharmaceuticals are radioactive chemicals used for medical
applications and research. In 1979, there were twenty-six industrial
suppliers of radiopharmaceuticals producing sixty-five generally used
radionuclides. These twenty-six firms exclude firms that purchase
radiopharmaceutical products in bulk and repackage them into smaller
containers (repackagers).
In 1984, there were over 2,800 medical facilities licensed by the
Commission to use radiopharmaceuticals, and approximately another 7,000
facilities licensed by agreement states.2 In 1946, almost 40 years earlier,
only thirty-eight medical facilities were licensed. Medical facilities use
radionuclides in all forms including solids, liquids, and gases; uses include
diagnostic and therapeutic procedures.
A. 1.4 Radiation Source Manufacturing
"Radiation sources" refer to radioactive materials enclosed in sealed
containers. They are found in a number of industrial and consumer products
2 The number of medical facilities that are Commission licensees is
reported on page 73 of the 1984 U.S. Nuclear Regulatory Commission Annual
Report, but the publication does not report the number of medical facilities
that are agreement state licensees. The U.S. EPA estimated the total number
of radiopharmaceutical manufacturers and users to be over 10,000 in 1977 (U.S.
Environmental Protection Agency, Radionuclides Background Information
Document for Final Rules, Volume II, October 1984, p. 3.3-5.). Subtracting
the 2800 Commission licensees from the total estimate of 10,000, yields rougly
7,000 agreement state licensees.
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A-3
such as radioisotope gauges used to measure thickness, static eliminators for
industrial machinery, testing equipment, self-illuminating signs and watch
dials, and smoke detectors.
Manufacturers of radiation sources process bulk quantities of radioactive
materials received from radionuclide production facilities such as accelerators
or reactors. The radiation source manufacturers keep inventories of radio-
active materials in quantities ranging from ten curies to 100,000 curies.
A. 1.5 Other Commission or Agreement State Licensees
Other Nuclear Regulatory Commission or agreement state licensees include
laboratories, low-level waste disposal sites, mineral and metal processing
facilities, fuel cycle facilities, and uranium mills. They are all subject to
the emission requirements of 10 CFR Part 20, Appendix B, Table II.
Laboratories
Approximately 700 laboratories are licensed to handle radioisotopes in
unsealed form, and it is assumed that an equal number of smaller laboratories
that are unlicensed handle unsealed radioisotopes, resulting in an estimated
total of 1400 laboratories that are potential sources of low-level radioactive
emissions.3 These laboratories are established in industry, government
agencies, and academic and research institutions. They perform testing and
research and development, and vary a great deal in size. While some
facilities have only one small, multi-purpose laboratory, others have up to
300 individual laboratories in several buildings.
Small laboratories tend to specialize in a limited use of radionuclides
for a single specific testing purpose. Academic and industrial laboratories
use byproduct materials in research and testing. Medical laboratories conduct
basic chemical and applied radionuclide research related to disease and health
problems. Government laboratory facilities may use radionuclides for purposes
such as food and drug testing or water and air quality monitoring. The most
commonly used radionuclides in laboratory work are tritium, carbon-14,
xenon-133, iodme-125, and iodine-131. Testing and industrial laboratories
tend to use larger quantities of radionuclides than academic or other research
laboratories; conversely, academic and research laboratories tend to use a
wider variety of radionuclides.
Waste Disposal Sites
Although there are six low-level radioactive waste disposal sites licensed,
only three are operational. These sites accept low-level radioactive wastes
in a stabilized form from three major sources: power-reactor and fuel cycle
3 Corbit C.D., Herrington W.N., Higby D.P., Stout L.A., and Corley J.P.,
Background Information on Sources of Low-Level Radionuclides Emissions to_
Air, PNL-4670, Prepared for EPA under U.S. DOE Contract by Battelle Memorial
Institute, September 1983.
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A-4
operations, laboratory research, and medical facilities. Wastes accepted by
these facilities for disposal by shallow-land burial must meet specific site
acceptance criteria. The disposal sites do not accept special nuclear
materials, transuranics (elements having a higher atomic number than uranium),
or spent reactor fuel. Wastes are buried at the disposal site in the
transport containers in which they arrive.
Mineral and Metal Processing Facilities
Commission and agreement state licensees include facilities which extract
metals from thorium- and uranium-bearing ores. Ten such facilities are
licensed in the following nine states: Alabama, California, Colorado,
Florida, Illinois, New Mexico, Oregon, Pennsylvania, and Tennessee. These
facilities generally process ores for either refractory metals and their
oxides (such as zirconium, columbium/niobium, tantalum, and hafnium), or for
rare earths (such as cerium, praseodymium, neodymium, dysprosium, and
ytterbium). Thorium is also used in some of these facilities to manufacture
welding rods and to cast machine parts.
Fuel Cycle Facilities
The Commission and agreement states also license the use of source,
byproduct, and special nuclear material at facilities engaged in the
production of nuclear fuel. These facilities include operating uranium mills,
uranium hexafluoride conversion plants, and uranium fuel fabrication plants.
There is currently no plutonium fuel fabrication being done in the United
States.
Uranium Milling
Uranium ore is delivered to mills where it is crushed and ground, and
uranium oxide is chemically extracted. The mill product, also called uranium
concentrate or yellow cake, is then sent to conversion facilities, where it is
chemically converted to uranium hexafluoride. Uranium milling activity is a
declining industry. As of November 1985, there were only three active
uranium mills in the U.S. (one of which is expected to go on standby status).
An additional 17 mills are already on standby status. Total uranium oxide
production from mills was about 7,400 tons in 1984, down from a high of 21,800
tons in 1980.''
A.2 DEPARTMENT OF DEFENSE (DOD) FACILITIES
Department of Defense (DOD) facilities are also licensed by the Nuclear
Regulatory Commission and must comply with limits for airborne and liquid
discharges to unrestricted areas under 10 CFR Part 20, Appendix B, Table II.
4 U.S. Environmental Protection Agency, Proposed Standard for Radon-222
Emissions from Licensed Uranium Mill Tailings; Draft Economic Analysis,
Office of Radiation Programs, EPA 520/1-86-002, January 1986.
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A-S
The Armed Forces Radiobiology Research Institute (AFRRI), located at the
National Naval Medical Center in Bethesda, Maryland, operates both a thermal
research reactor and a linear accelerator (linac), mainly in support of
research on the medical effects of nuclear radiation and the effects of
transient radiation on electronics and other equipment. The U.S. Army Test
and Evaluation Command operates two reactors which are similar in design and
are used to support studies 111 the effects of nuclear radiation. Both are
fueled with enriched uranium.
Nine naval shipyards contribute almost all the radionuclide releases from
U.S. Navy facilities. Pressurized water reactors power the nuclear fleet at
the naval shipyards. Standard operations at the shipyards include
construction, startup testing, refueling, and maintenance of the reactors.
Radioactive wastes generated by these operations are processed and sealed,
then shipped to commercial waste disposal sites.
A.3 DEPARTMENT OF ENERGY (DOE) FACILITIES
The U.S. Department of Energy (DOE) is given authority by the Atomic
Energy Act of 1954 (Section 161 of Public Law 83-703) "to protect the public
health and safety" with respect to the operation of so-called "G0C0"
facilities -- facilities which are "government owned, contractor operated."
Major DOE facilities include national laboratories, facilities associated
with the Formerly Utilized Sites Remedial Action Program (FUSRAP), the Uranium
Mill Tailings Remedial Action Program (UMTRAP), the Grand Junction Remedial
Action Program (GJRAP), the Surplus Facilities Management Program (SFMP), and
facilities involved in specific research and development programs.5 DOE is
also responsible for operating uranium enrichment facilities, a step in the
nuclear fuel cycle. Other DOE operations involving radionuclides include
nuclear weapons research, development, and production; medical and biological
research; and industrial applications and development.
As of 1980, 78 G0C0 facilities in 24 states were subject to the health and
safety requirements contained in DOE Order 5484.1. In 1982, there were thirty
"active" DOE complexes, many of which have several operating facilities.
("Active" is defined to mean facilities currently generating radioactive
waste.) Fourteen of these complexes are laboratories operating diversified
programs. The other complexes operate programs including primarily weapons
production and testing, nuclear materials production, and physical research.
A.4 COAL-FIRED UTILITY AND INDUSTRIAL BOILERS
Large coal-fired boilers are used to generate electricity for public and
industrial use and to provide process steam, process hot water, and space
heat. Boilers used in the utility industry are designated as utility boilers,
and those used to generate process steam, process hot water, space heat, or
electricity for in-house use are designated as industrial boilers.
5 Rogers and Associates Engineering Corp., Radioactive Contamination at
Federally Owned Facilities, June 1982, pp. 3-2, 3-3.
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A-6
In 1983, coal-fired steam electric power units accounted for 63 percent of
total capacity and 55 percent of total energy generation by U.S. electric
utility generating units.6 In early 1985, there were 1,281 coal-fired units
on-line with a total generating capacity of 281 gigawatts.7
Coal-fired industrial boilers are used mainly to produce process steam and
hot water, generate electricity (for the producer's own use), and provide
space heat. Major users of industrial boilers include the steel, aluminum,
chemical, and paper industries. There are approximately 51,200 coal-fired
industrial boilers operating in the United States.8
More than 600 million tons of coal are burned each year in utility and
industrial boilers. Coal contains mineral matter including trace quantities
of naturally occurring radionuclides. Uranium-238 and thorium-232 and their
decay products are found in relatively large quantities in coal.9
The emission of radionuclides to the air from coal-fired utility and
industrial boilers is small. In promulgating radionuclide emission standards
under the National Emission Standards for Hazardous Air Pollutants (NESHAP),
EPA did not regulate radionuclide emissions from these boilers (50 FR 5190).
Coal-fired steam electric power generators and industrial boilers are not
considered affected by the proposed RQ adjustments because radionuclide
emissions to the air from these facilities are small. Quantities of all
radionuclides expected to be released are well below the proposed RQ values.
A.5 MINERAL EXTRACTION INDUSTRY
Almost all mineral extraction industries that involve the removal and
processing of ores to recover metal release some radionuclides. EPA has
identified the following mineral extraction industries as having potential for
releases of radionuclides: the uranium mining industry, the aluminum
industry, the copper industry, the zinc industry, the lead industry, and the
phosphate industry. These industries were identified because of the large
quantity of ore mined domestically and because the mining processes used
6 U.S. Department of Commerce, Statistical Abstract of the U S. (1985),
105th Edition. Government Printing Office, Washington, D.C., p. 564.
7 ICF Energy Service, Summer/Fall 1985 Coal and Electric Utilities
Market Assessment, p. 1-2 (1985).
8 U.S. Environmental Protection Agency, The Radiological Impact of
Coal-Fired Industrial Boilers (Draft), Office of Radiation Programs,
Washington, D.C., October 1981.
9 U.S. Environmental Protection Agency, Radionuclides Background
Information Document for Final Rules, Volume II, October 1984, p. 4.0-1.
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A-7
create a likelihood for radionuclide emissions.10 Only underground uranium
mining and elemental phosphorus plants were found to warrant radionuclide
emission standards under the Clean Air Act (50 FR 5190). Each mineral
extraction industry is discussed below.
A.5.1 Uranium Mining
There are several different types of uranium mines and extraction
processes. These include: open pit, underground, and in-situ (solution)
mining operations. In 1982, there were 24 open pit uranium mines, 139
underground uranium mines, and 18 in-situ mines in operation, producing about
86 percent of the total uranium oxide domestic production in that year. Total
uranium oxide production was 13,400 tons.11
Domestic uranium is almost exclusively mined in the western portion of the
United States, mostly in New Mexico, Wyoming, and Texas. As of 1984, uranium
production in these states collectively accounted for approximately 65 percent
of the national total. Several other states (including Arizona, Colorado,
Florida, South Dakota, Utah, and Washington) together accounted for the
remaining 35 percent of the total.12
The majority of the uranium industry is owned by large, publicly held
corporations. During the early and mid-1970's, the industry experienced rapid
growth, spurred by expectations of increasing demand. This demand, however,
did not materialize and, as a result, the industry is presently faced with an
excess of capacity and supply, and the potential for increased competition
from imports.
A.5.2 Aluminum Industry
Several materials are used in the production of aluminum. Bauxite is the
principal aluminum ore found in nature. Bauxite contains elevated levels of
both uranium-238 and thorium-232. The ore is processed at the mine to produce
alumina, the basic feed in the aluminum reduction process. Twelve domestic
firms produce primary aluminum. Almost all of the bauxite ore used in
aluminum production is imported. Only five of the twelve firms that own
primary aluminum plants also own domestic plants that produce alumina. These
five firms own 73 percent of the current U.S. primary aluminum capacity.
Currently, there are 32 operating primary aluminum smelters in the United
States. With one exception, all of the plants are located in rural areas.
10 U.S. Environmental Protection Agency, Radionuclide Background
Information Document for Final Rules, Volume II, October 1984, p. 7.1-1.
11 U.S. Department of Energy, Statistical Data of the Uranium Industry.
GJO-100(83), Grand Junction, Colorado, January 1983, p. 9.
12 Ibid., p. 9.
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A-8
These smelters release radionuclides to the air from the uranium and
thorium series at extremely low levels, however. A typical aluminum smelting
operation releases radionuclides in a range from close to 10"^ curie per day
to nearly 10 curie per day,13 which is well below the lowest proposed RQ
value. Therefore, these facilities are not affected by the proposed RQ
adjustments.
A.5.3 Copper Industry
Most firms in the copper industry perform all production processes from
mining through refining. Copper mills and smelters are located near copper
mines. There are fifteen operating primary smelters in the United States.
All smelters are located in rural areas with low population densities. Ninety
percent of U.S. copper smelter capacity is located in Arizona, Montana,
Nevada, New Mexico, Texas, and Utah. The sites tend to be large and generally
contain associated mining and milling operations. In 1978, 1.5 million metric
tons of primary copper was produced.lfc Copper smelters also release
radionuclides to the air at very small levels. At a typical copper smelter,
radionuclides are released principally from the uranium and thorium series at
levels ranging from 1.4x10 4 to 5.4xl0~6 curies per day.15 These levels
are well below the lowest proposed RQ value of 0.001 curie per day, and
therefore, these facilities are not affected by the proposed RQ adjustments.
A.5.4 Zinc Industry
Zinc is usually found in nature as a sulfide ore called sphalerite. The
ores are processed at the mine to form concentrates typically containing 62
percent zinc and 32 percent sulfur. In the past 10 years, U.S. demand for
zinc metal has grown slowly, but U.S. smelting capacity has declined by more
than 50 percent. Plants closed because they were obsolete, could not meet
environmental standards, or could not obtain sufficient concentrate feed.
Consequently, the metal has replaced concentrate as the major form of import.
This situation is expected to continue. There are five operating primary zinc
production facilities in the United States. Radionuclides in the uranium and
thorium series are released from zinc smelters at extremely low levels, except
for radon-222. Most radionuclides from zinc smelters to the air are released
in levels ranging from 1.1x10 4 curie to 1.5xl0~6 curie per day, all well
below the proposed RQ values. Radon-222 is released at an expected level of
13U.S. Environmental Protection Agency, Radionuclide Background
Information Document for Final Rules, Volume II, October 1984, p. 7 1-8.
111 Schroeder H.J., Mineral Commodity Profiles -- Copper, U.S.
Department of the Interior, Bureau of Mines, Washington, D.C., 1979.
15U.S. Environmental Protection Agency, Radionuclide Background
Information Document for Final Rules, Volume II, October 1984, p. 7.2-6.
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A-9
0.001 curie per day.16 The proposed RQ for radon-222 is 100 curies,
however, so the expected release is well below the proposed RQ. Therefore,
zinc smelters are excluded from the universe of facilities affected by the
proposed regulation.
A.5.5 Lead Industry
Galena is the principle lead-bearing ore found in nature. It contains
small amounts of copper, iron, zinc, and other trace elements (including
radionuclides). Lead smelting involves three processes: sintering,
furnacmg, and drossing. Sintering converts the ore from a sulfide to an
oxide or sulfate form and prepares the feed materials for furnacing.
Furnacing reduces the oxide feed to lead metal. Drossing reduces the copper
content of the lead bullion from the furnace. After drossing, additional
refining steps, which are dictated by the specific impurities present and the
intended end-use of the product, are performed to produce the purified lead
metal.
There are five primary lead smelters in the United States. Three
facilities have integrated smelter/refining complexes; two facilities ship
their drossed lead bullion away for final processing. Three of the smelters
are located in Missouri and process only ores from the Missouri lead belt.
The remaining smelters are located in Texas and Montana. The two western
smelters are custom smelters that are designed to handle larger variations in
ore composition than the Missouri smelters. Both domestic and foreign ores
are smelted at the western plants. In 1979, total production from primary
lead smelters was 594,000 tons.17
Radionuclides expected to be released from lead smelters are from the
uranium and thorium series. Radionuclide releases to the air are expected to
range from 1.2x10 ^ curies per day to 2.7x10 ^ curies per day, which are
well below the proposed RQs.18
A.5.6 Phosphate Industry
The two major components of the phosphate industry which release
radionuclides into the environment are phosphate rock processing plants and
elemental phosphorous production.
16Ibid., p. 7.3-4.
17 U.S. Department of Commerce, U.S. Industrial Outlook for 200
Industries with Projections for 1984, Washington, D.C., 1980.
18U.S. Environmental Protection Agency, Radionuclide Background
Information Document for Final Rules, Volume II, October 1984, p. 7.4-4.
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A-10
Phosphate Rock Processing Plants
Mining of phosphate rock is the fifth largest mining industry in the
United States in terms of quantity of material mined. Total 1978 production
was approximately 57.9 million metric tons. Prior to 1983, twenty firms were
operational, with plants in thirty-one locations. The ten largest producers
control about 84 percent of the capacity, with the two largest firms
controlling over 34 percent.19
Phosphate rock processing plants emit radionuclides into the air in the
uranium series during the drying and grinding of the rock. However, levels of
emissions are not expected to be above 4.5x10 ^ curies per day for any of
the radionuclides.20 These levels are well below the lowest proposed RQ
adjustment, so these facilities will not be affected by the proposed RQ
adjustments.
Elemental Phosphorus Plants
Another type of phosphorus plant produces elemental phosphorus, which is
used primarily in the production of high grade phosphoric acid, phosphate-based
detergents, and organic chemicals. Almost half of the elemental phosphorus
produced domestically is used in the production of detergents. Metal
treatment, foods and beverages, and chemicals are the other major end uses for
elemental phosphorus. Approximately ten percent of the total U.S. marketable
phosphate rock mined is used for elemental phosphorus production. Four major
corporations operate six plants in the U.S. The total amount of elemental
phosphorus produced in 1983 was approximately 366,000 tons.21
A.G SUMMARY OF RADIONUCLIDE INDUSTRY
Exhibit A-l displays the estimated number of facilities that release
radionuclides. These facilities do not necessarily release radionuclides at
levels exceeding the proposed RQs, but they produce or use radionuclides and
are, therefore, likely to release radionuclides at some levels.
19U.S. Environmental Protection Agency, Phosphate Rock Plants,
Background Information for Proposed Standards, EPA 450/3-79-017, Office of
Air Quality Planning and Standards, 1979, p. 7-5.
20U.S. Environmental Protection Agency, Radionuclide Background
Information Document for Final Rules, Volume II, October 1984, p. 6.1-11.
2lIbid., p. 6.3-1.
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A-11
EXHIBIT A-1
FACILITIES USING OR PRODUCING RADIONUCLIDES
Category of Facilities Number of Facilities
Commission Licensees 8,900
Agreement State Licensees 13,000
Department of Energy Facilities 78
UNLICENSED FACILITIES (53,456)
Laboratories 700
Utility Boilers 1,281
Industrial Boilers 51,200
Uranium Mines 181 (21 active)
Aluminum Smelters 32
Copper Smelters 15
Zinc Smelters 5
Lead Smelters 5
Phosphate Rock Processing 31
Elemental Phosphorus Plants 6
TOTAL 75,400
Source: See Appendix A text.
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