ML19297A393
| ML19297A393 | |
| Person / Time | |
|---|---|
| Issue date: | 10/10/1980 |
| From: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML19284C733 | List: |
| References | |
| FOIA-81-69, TASK-IR, TASK-SE SECY-80-467, NUDOCS 8010300570 | |
| Download: ML19297A393 (12) | |
Text
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UNITED STATES October 10, 1980 NUCLEAR REGULATORY COMMISSION SECY-80-467 WASHINGTON, D. C. 20555 INFORMATION REPORT For:
The Comissioners From:
John G. Davis, Director Office of Nuclear Material Safety and S feguards Thru:
Executive Director for Operations c4
Subject:
EXTENSION OF INDEMNITY COVERAGE TO MATERIALS LICENSEES OTHER THAN THOSE POSSESSING AND USING PLUTONIUM
Purpose:
To report to the Comission on the status of the feasibility of extending indemnity coverage to licensees involved in highly enriched uranium processing and fabrication, spent fuel storage, radioisotope source preparation, and other materials activities.
Issue:
This paper covers an information matter.
Discussion:
Background -
When the Price Anderson Act was amended and extended in 1975, the Congress directed that the Comission re-examine the feasibility of extending indemnity coverage to plutonium licensees.
This was done; and in early 1977 10 CFR Part 140 was amended to require financial protection and provide indemnity coverage for persons authorized to possess five kilograms or more of pl.utonium and to use one kilogram or more of plutonium (both excluding sealed sources and fuel rods ).
In the course of its deliberations (SECY-76-444) the Comission asked that the staff report back on the feasibility of extending indemnity coverage to other materials licensees -- specifically those processing and fabricating highly enriched uranium, those preparing large radioisotope sources, and those handling and storing spent fuel.
The Comission also requested that the threshold values selected for plutonium processing and fuel fabrication plant licensees be examined in the same context to verify that they are reasonable.
Contact:
Peter Loysen, NMSS 42-74205 801030057b
The Commissioners The staff contracted with Oak Ridge National Laboratr,ry (ORNL) to perform a study to determine the radiolog: cal consequences and costs resulting from releases of the different types of radioactive materials.
It was planned that the results from the study would be used in conjunction with other information reported in the literature and available to the Office of Nuclear Material Safety and Safeguards (NMSS) to determine if damage costs might exceed the limit of privately-available nuclear liability insurance coverage ($140 million at the time of the study) and hence represent a potential requirement for indemnity protection. ORNL had performed a study in 1964 (0RNL-3441) for a somewhat similar purpose.
The ORNL report (NUREG/CR-0222) was published in 1979 and it is included as Enclosure 1.
Drafts of this report have been subjected to considerable scrutiny by the staff, but the subject matter is controversial and can be analyzed in different, reasonable ways.
Especially significant are the impacts of the many assumptions that had to be made in arriving at damage costs which are basically a combination of the public radiation exposure expense from an accident and the subsequent decontamination expense.
Important factors affecting the results inc_lude population density, meteorology, release fractions, resus~ pension factors, decontamination levels and unit (per capita) costs.
We be'feve that the report deals appropriately with a*1 of these factors with the possible exception of the choice of decontamination level. Additionally, the effect of sabutage of shipments was not thoroughly studied. The former is considered in Adjustments to Results, which is included as Enclosure 2 and the latter in two published documents -- NUREG/CR-0743
" Transportation of Radionuclides in Urban Environs:
Draft Environmental Assessment" and NUREG-0170, "FES on Transportation of Radioactive Material by Air and Other Modes."
Of particular concern in the area of shipment sabotage has been that of spent fuel sabotage.
Both of the referenced documents cover spent fuel sabotage and use extremely conservative source tems for the release of radioactive material. In an effort to determine more realistic source tems, the staff has contracted with Battelle Columbus Laboratories to conduct simulated scaled tests using actual spent fuel in a program entitled Shipping Cask Sabotage Source Term Investigation.
The Commissioners Results from this investigation are expected in late 1980.
In addition, proposals are being evaluated for a companion project to address source terms from possible indirect violations (" blow-out") of shipping casks. These source terms can be used in the staff's long-planned Modal Study to assess the effects of accidents and sabotage of shipments in various modes.
In NUREG/CR-0222, no attempt was made to examine every radionuclide or the detailed activities of individual licensees. However, a follow-up study was perfomed by the staff to determine potential release quantities of the full spectrum of byproduct materials handled by licensees and to assess the relationship between radioactive material quantities authorized and quantities actually possessed, quantities processed and stored, material form and dispersibility, types of operations perfomed and other factors.
For compatability, the methodology of NUREG/CR-0222 was used in this follow-up study also. The study results entitled, "A Staff Analysis Re: Feasibility of Applying Price-Anderscn Indemnification to Byproduct Material Licensees, is presented as Enclosure 3."
Results to Date -
The several reports published in the last few years have provided considerable information related to damage costs from radioactive material releases.
Since they were prepared by different organizations and sometimes for different purposes, it is difficult to compare directly the results or even to use them supportively.
Nevertheless, the two most significant factors influencing any of the results are:
- 1) the magnitude and quality of the source tem used and,
- 2) the allowable level of residual radioactivity following decontamination. Neither of these factors has been firmly established.
In NUREG/CR-0?, releases in dispersible and respirable form equivalenc to $140 million were detemined and assumed to be capable of occurring.
This was a useful simplifying assumption because, even after adjusting the results to account for a lower allowable level of residual radioactivity along the lines of
The Commissioners current staff thinking and proposed EPA guidance for nonnal releases and decommissioning activities, certain conclusions can be reached.
(This lower level of 1/100 of 10 CFR Part 20, Appendix B, Table II equates to derived values of about 5 mrem /yr to the whole body or 15 mram/yr to most organs '
l.
Releases of highly enriched uranium in dispersible and respirable form would have to exceed the working quantities of any fuel fabrication and processing licensee to result in damage costs exceeding $140 million. This release quantity is about 230 kilograms of highly enriched uranium.
By analogy, the quantity of natural uranium or yellowcake would have to be about ~00 times greater, or 23 tonnes.
By reference to a previously-performed calculation, it was shown that damage costs resulting from a criticality accident would have little off-site significance and that they would be very much less than $140 million.
2.
The calculated quantity of plutonium fuel material that would have to be released to cause
$140 million in damages is three grams.
While this is far less than the now-indemnified quantities of five kilograms (storage) and one kilogram (use), the dispersible and respirable release fraction of these quantities is probably no greater than.002, suggesting that the choices of values for indemnification purposes were reasonable.
It is useful to note here that, as a result of the Administration's indefinite deferral of reprocessing and the Commission's termination of GESMO, plutonium licensees have reduced the quantities of material they possess and use, and most are in various stages of decommissioning their facilities.
The Commissioners 3.
In the case of spent fuel, either in away-from-reactor storaga or during transportation, accident release scenarios were specified by the staff and damage costs determined by ORNL. The costs resulting from a storage related accident are insignificant; those from a transportation related accident cr sabotage could exceed $140 million in a suburban area. NUREG/CR-0743 suggests damage costs as high as $1 billion in a hyperurban area.
There are a significant number of NRC and Agreement State licensees who are authorized to possess several of the radionuclides analyzed by ORNL, principally for source preparation.
If released in dispersible and respirable form, the damage costs could exceed the amount of privately-available nuclear liability insurance coverage.
However, the ORNL study was not designed to examine the activities of individual licensees, and so the factor of release fraction is important in judging whether or not damage costs could exceed $140 million.
In the follow-up study thirteen licensees who might qualify for coverage were selected for in-depth analysis by systematically reviewing the various parameters of radionuclide use.
Of these, only one might be in a situation where damage costs could exceed
$140 million.
Of course, modifications to licensees' operations, as well as specific residual radioactivity levels, or future changes in the use of othar radio-nuclides in different quantities and fonns, could alter potential indemnification requirements.
It should be pointed out that these findings were based on the 10 CFR Part 20, Appendix B, Table II values and not some fraction thereof.
Additional in-depth analyses would be required to evaluate the damage cost potential for reduced conditions of allowable levels of residual radioactivity.
As noted earlier, one of the two most important factors influencing the outcome of damage cost estimations is the source term used in the selected accident or sabotage scenario. This is particularly important in the case of spent fuel, where the radionuclide inventories are large and where even a very small release fraction can be significant.
For example, in NUREG-0170 and the original
The Commissioners working draft of NUREG/CR-0743, a respirable release fraction of one percent of solids was assumed for the maximum release.
The revised version of NUREG/CR-0743 used 0.07% as a most likely value.
The range considered is 0.02% - 0.2%.
NUREG/CR-0222 used 0.01%, as had been assumed in Supplement II to WASH-1238 (at least as far as accidental release of semi-volatile cesium is concerned, not for sabotage reasons).
It is for these very differences that the current work at Battelle Columbus Laboratories on Shipping Cask Sabotage Source Term Investigation and the proposed work on the Modal Study and indirect violations of shipping casks (" blow-out" study) were sponsored.
In addition, research on graded safeguards for the spectrum of nuclear materials, which is being considered by NMSS, may provide useful information on source terms from several sabotage events.
==
Conclusion:==
With the possible exception of spent fuel storage and its transportation (see related paper, SECY-80-468), the staff has not found compelling reasons to recommend that the Commission exercise its discretionary authority to require financial protection and provide indemnity coverage for licensees not presently protected and covered.
Results from the ongoing and planned studies on spent fuel transportation sabotage and parts of the planned Modal Study should provide additional, useful information related to the matter of indemnity coverage for materials licensees.
The staff notes that if future consideration is given to indemnifying any categories of byproduct material licensees, the NRC only has authority to indemnify its own licensees.
Where the licensee is an Agreement State licensee, new legislation would be needed in order to require that such a licensee be indemnified, m
-t
/-> John G. Davis. Director
[
Office of Nuclear Material Safety and Safeguards
Enclosures:
1.
NUREG/CR-0222 on file in the Office of the Secretary 2.
Adjustments to Results 3.
A Staff Analysis Re:
Feasibility DISTRIBUTION:
of Applying Price-Anderson Commissioners Indemnification to Byproduct Conmission Staff Offices Exec Dir for Operations Material Licensees ACRS
, Adjustment to Results A major part of the methodology used in the ORNL study and the staff follow-up study is relating deposition, through a suspension f actor, to air concentrations and then dose commitments.
For the amount of residual deposition for which no further corrective action would be required, the air concentrations were equated to those listed in Appendix B Table II of 10 CFR Part 20.
This is the'same as Nichols and Guthrie originally used in ORtil-3441.
The concentrations are equivalent, for most nuclides, to annual doses of 500 mrem whole body, 3000 mrsm to the bone and 1500 mrem to most organs.
These doses may be too high or not ALARA for current and future consideration.
As part of the follow-up study, the staff developed a technique to approximate directly damage costs and releases using a few simplifying assumptions.
In this way, additional nuclides could be examined with relative ease and, most importantly, it provided 3'}
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a means to observe the effect of reducing the allowable residual deposition (and therefore dose).
Reduction factors of 1/10 and 1/100 were selected so that releases or costs could be determined using annual doses of 50 mrem whole body (300 mrem bone,150 mrem organs) and 5 mrem whole body (30 mrem bone,15 mrem organs).
Although no allowable dose or residual levels of radio-activity in the environment have been adopted by the Comission or any other agency, current staff opinion is that values close to the lowest of these will be adopted by EPA.
If 1/10 of Part 20 values is used, releases of about 1/5 of those reported in NUREG/CR-0222 would cause
$140 million damage costs.
If 1/100 of Part 20 values is used, releases of abbut 1/50 of those reported in NUREG/CR-0222 would cause $140 million damage costs.
The calculated release reductions vary somewhat from nuclide to nuclide, however, so Tables 1 and 2 have been prepared to show the adjusted release quantities.
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Similarly, damage costs were re-calculated using the lower dose equivalent values for the postulated spent fuel transportation accident.
The costs become $300 million and $3.7 billion respectively, for the 1/10 and 1/100 of Part 20 values (in suburban population density areas of 3000 persons /sqmile).
Costs in less. populated areas would,,of course, be lower.
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TABL'E 1.
QUANTITIES OF RADI0 ACTIVE MATERIALS CAUSING A MONETARY L3SS OF $140 MILLION USING REDUCED DOSE EQUIVALENT VALUES (Modification of Table 4, NUREG/CR-0222)
Quantities Causing a loss of $140 M (Ci) 1 x Part 20 1/10 x Part 20 1/100 x Part 20 Isotope Co-60 15000 2860 306 Sr-90 160 17.4 1.74 55-124 35000 6640 714 I-131 1400 123 12.3 Cs-137 1900 204 20.5 Ce-144 9900 1890 204 Rn-147 81000 25200 3030 Tm-170 41000 9200 1020 Ir-192 42000 8570 918 Po-210 350 67 7.14 Pu-238 2.5 0.63 0.07 Am-241 7.0 1.78 0.20 Cm-242 220 38.4 4.08 Cm-244 11 2.70 0.30
TABLE 2 QUANTITIES OF SPECIAL NUCLEAR MATERIALS CAUSING A MONETARY LOSS OF $140 MILLION USING REDUCED DOSE EQUIVALENT VALUES (Modification of Table 5, NUREG/CR-0222)
Quantities Causing a Loss of $140 M (kg) 1 x Part 20 1/10 x Part 20 1/100 x Part 20 Material U-233 20 4.42 0.49 (500ppmU-232)
U-235 12000 2180 23?
(1.3 w/6 U-234)~
Pu fuel 0.09 0.027 0.0032 O
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