ML20043C043
| ML20043C043 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1988 |
| From: | Spangler M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20042C963 | List:
|
| References | |
| FRN-53FR49886, RULE-PR-CHP1 NUDOCS 9006010234 | |
| Download: ML20043C043 (12) | |
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Safety regulation I
L De minimis risk concepts in the US Nuclear Regulatory Commission, Part 2: Implicit j
uses in waste management and regulating uranium mines and mills L
3 Miller B Spangler a
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l Technological and regulatory solutions arrd to be ASTES, GARBAGE, DUMPING - these are developed to improve distributive Justice in nuclear the pejorative terms used in enouonal express-waste management. It is imperative that a balance be ions ofdandaan or resistance to the disposal of the achievedbetween over regulation and under regulation.
unintended and unwanted byproducts of technological The historical treatment of safety usues is considered proc #ses.Moreover, issues of distributive jusdce, and with reference to potential doses to a public residing at even of social stigma, anse whenever the adverse etfects of variable distancesfrom a uranium mill or mill tailings waste disposal are borne by a few and the technology's bene 6ts are reaped by many (Rawis,1971 and Menandorfer, 8 j
1986). In these situations, the not in my backyard, or Since 1986. M, C decisions as so whether to grant NIMBY, syndrome is a common place reacdon that petitions for disposal of low level radioactive waste elevates the conaict between the values or interests of intolte phrases that relate closely to de minimis r6k amaller groups ofindividuals and the common good of concepts. Establishing a high level waste repository u society (Spangier,1980).
more problematical. although is should be possible to Technological and regulatory solutions ceed to be set up de minimus risk standards. Some of the salient developed to improve distribudve iusdce in waste manage-regulatory issues have been described.
ment.even though the perfection ofiusdce is often beyond This paper is Part II of a three parr series. Part til society's reach. It is imperative that an appropriate
. examines the setting vfsafetygoals and treating the risk balance is achseved in waste management between the
- k'*I"*?*'d
- **d b** *I**'"I"I*0**: In the post 4 orlfer *11 era of rapid industnal expansion management hsues of severe nuclear accidents.
there were numerous inadences ofindisenmmate ocean dumping and disposal ofwastes in riven and landfills that Keywords: nsk assessment; safety reguladon; de minimis nsk; nuclear power planu; rediologxal,nmecuan; facihty Pued small to senous health liazards and ecological decommission
- dianspdoes.
Unquestionably, the most dramatic episode due to the under regulation of waste disposal in the USA was that involving landfill disposal of chemical wastes at the Love Canal near Niagara Falls, New York. The seepage of over 300 chemicals in the soil caused the abandonment of 235 houses, cleanup costs estimated at US$30 milhon,lswsuits totalling over US$2 billion, and acute suffenng and mental anguish (Maugh,1979 and Helden,1980). This and other spuodes of under regulation and masmanagement c(wastes have spurred legisladvs. rdministrative and court acuens to reduce the hazards of waste disposal. Also, large investments are being made in pub'ic and pnvete research
.W!!r
- Spang!cr u Spenal Assistant for Folicy Development, to improve waste managemen* rechnologies and the Offh. af Nuclear Reactor Regulauon. US Nuclear Regulatory science ofnsk assessment essenu. e the sound regulauon Comeinion, Was'rungtoe. DC 20355, US A.This ankle,and the of wastes.
othe u o paru (in our last and our nert issues), are an updated The avoidance of under regulau:n in waste manage-venia of Chapter 12 as published by the author m De Muumu ment will pmve to be a long and conunumg process.
Ruk. C sns \\thpple (ed tor). Plenum Preu.
However, the development of a de trunmus nsk standard Proieet Appraisa! M. arch 1988 c26s ase7/as/otoo43-12 ussos oo 43 9006010234 891130 PDR-PR CHP1 53FR49886 PDC
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c e regulatory tbolin waste management is more directly pes'at afvie26 that,ife mandardif6 minimis risk were to' eencerned with the svoadance ofover regulaten. As noted be etabbshed and pmund esclusively fram as tdvidual i
b Pan 1 (Meyser 4p'unel, volume 2, gwebu 4, December risk perspoenve, then ngulatory considereuen dpublic i
1987), the detenminanon that a nsk is equal to or less than risk in egens beyond a few miles distance tem the sites of a de minimus risk standard - and hence is teed frees wannan mines and mills would be moot.3 Asnher regulation - would serve to release funds and it is hir to any there is a sipu6 cent renonale for both ngulatory resourses is be used for a more efective treet.
sides of such an argument. Fl=h== of the UK's ment of the non truly sagadcaat ruks deserving
'ty National PP M Fretecdoe Board, provides a logic fankson,p for social managessent. Dus, in ilus for both the le&vidual and soewtauy agregate nok sitenuo e de minimis nak standard could accelerou perspecuves (Flestuaan, IMS)-
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"[Tjhere has ed debate as to whether i
I che aminus na concepts in au h Mu manag, mat.
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background radiaties in the calculsion and use of he controung ethical principle is that pubbc agencies hve due mN his how hm M 1
is a e
lo those as tia&
eensiderable impanance (a the 6 eld of redmacuve
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use of equivalest hands that could purtbase an even ahd wou 4symalh dahed at mylow Wual
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d"_"'"; A feelang has meged wittun greeter esems o(lives is alternative nine for lifc
" ' y> "g,Pnmuse omununity es seveg(Graham and Youpel,IMI and dall,1981).The 08 I
purpose of this arucle Comaussion s (NRC,is to caenune US Nuclear Regulatory M
,,3,,
- ) histoncal etices regarding de muurais nok concepts, or cut o levels of regulatory undue pubhc msnm a h wuu mm -
l concern, in the tneunent of these kmds of regulatory amt preench ruuh im0d>
issues in several concrete examples, such as the manage.
druk. As an almum h hu km suged een snent of nsk to the public from uranium miU todaags, and level of individual dose or risk should b: estabhahed from weste management precuce aan broaQ Aleough below which em ad h w f& W k NR de muumas twk ngulatory concern. Such dam irveh or Was pob,C,s reguistory philosopb cies a stiu evolvmg, the sanon reguistoryinsa leveh dM de W 'Mn'm h m its deemoo-making on wy small rids to the public ever, there an two features which cause diEculty Dom waste managemaet could yield insights of general with this approach. One is ths hbhk=I est a value to other 6 elds of waste management.
War ia&whaal wiu be apud to many nes, i
each of which any 1.sve been esaussed as of no 1
t eencern, and doe second is that one source, which Uranium mill sites mpn ben h m anin,&W bash,nu a fact espose many individuma.
His subject h treated in two parts; a review ofthe relanon Ahhough the regulatory analysis leading to an NRC ofde sainimis nsk concepts to NRC's historical regulatory decision se the treatment of the radiolopcol nsks from treatment of safety imuss involves potendal doses to e aniu tahags foBowas decomaussioning did not explicitly public residing at variable dista ices from a uranium mill
&acuss not establish a de sumans entanon, the discussion or mill talungs site; and second, a bnef emploration of to follow reveals the sort of issues and data analysis philosophical usues as to whether a standard ofde aununas provuled by the stasand licensing boards that would be nsk should deal with nsk levels regarded as insigmfuant most relevant to any future developanent of this kind.
esclusively from an adadualperspecuve, or whether a
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- t of mill tashngs aAer adhng operations i
sometalpenpoetive ofagregme ruk should ad&donaUy be esass, involving about 400,000 tons / year dmatenal with considered, low re&onuclide concentrwiens,is the maior canadersoon ne re&sson dosse to slw public et distance o(several in decomunimening of these facilities. ne maior poblem miles or snore from e uranium aniu and min tadance site an monuntered in post milling operations is the management i
su5cietly low as in invite coanderenen of using de ef tediap generated by the miuang ivocess. Although the
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annimis nsk concepts in their regulation, or et least the concentreuen of redioecnvity in the tailings is relsuvely 1 arem/yr caos conospt in te poPulanon does low, control anessures am necessary because of the large calculadons, as curready in the revmces to quantitim involved and because of the long half hfe of the document 10 CFR Fan 3D (see part 1 of my series) for parent rodeauchdas that are present.
other types ofnuclear fuel cycle incihnes. Accordagly,one he management of miU tadings has received incross-ing attennon and interest in recent years from involved Although the concentration of radio.
Fahmi md sma asmos and fmm evimammtal amusm anon groups. His interest has resulted from stu&es setivity in anill tallings is low, control e.rned oui dE"ihe inst decade which h.ve in&ca measures and associated issues are dat ur*'d=
ilinga if M PNPaly cannaged and i
controued, could present a potennal public health haaard.
called for by the tonnages involved ne most vivid saampic h the situ. tion thei occurnd in and the long half lives of sonne of their Grand Junction, Colorado. The remedial actions deter-parent radionu 11 des mined necessary to correct the misuse of rs&olopcaDy contanunsted min taiungi in the onstnicnan orbocas, schools, and other pubbe structures are continuing at 44 Proleet APPralealMe441988
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s:bstantial cost to the Federal Govemment and the State Euclides (which are regulated under 40 CFR Pan 192).
of Colorsds.
Total exposures t) the individuals and populanons also discussed include doses resulting from the redon com-ponent and health risks associated with these total V,
Need for change esposura.
Under NRC's regulations, the EPA's 40 CFR Pan 190 The inves and alternative for providing acceptable haits are to be snet at permanent reandence locanons near
- sdiological protecnon to the public were examined in uranium mius. Domes received by the nearby individual detail by the NRC OfEce of Nuclear Material Safety and substantially escoeded 25 inrem per year; bone and lung Safeguards. The Final Genenc Environmental Impact doses are 45 and M mrom, respecuvely. Analysis indicates Statement (G EIS) on Ursnium Milling prendes a benefu.
the haut could not be met withm about three ben downoind cost analysis of both radiological ans non-radiological froen the mill. The e5act on the nearty residents of a impacts (NRC,1980). The key objectives of the G EIS are:
potential worst cow concentration of mi
- activity, e to sueu the nature and extent of the environmental where a clusterof!2 millsis tulatedin year
,would be toincrease 40 CFR 190 to bone andlungby about impacu of conventional uranium milhng in the US from local, reponal, and nadonal perspecuves on both 15% to 20%. Although not a large fracnonalincmau,this abows that the coninbunon from a mins could shon and long term benes to deterame what regulatory be imponent in eitueuons when amting 40 FR M was if y,dto vide information on which to o&wwise a bordwhne cau, e
re determine what r story requiremenu for manage-ment and disposal of miU tailinp and mill decommiu-Public risk from rados ioning should be; and e to support any regulation changes that may be deter.
truned to be neceuary, According to the GE!S, total esposure estimates (which include redon and daughters)in&cate that redon emanet.
Specific regulatory changes found to be needed as a resul*
ing from mill tailmps is the greatest smgle contnbutor to of the analvsa performed were issued simultaneously 4th mk. When total esposures are considered, the chances the GEIS.ln ad& tion,the regulauons incorporate requ.re-that the nearby individual would prematurely die from ments of the Uraruum MiB Tailings Radiation Control Act cancer as a result ofliving near the "model miU" (see of 1978, as amerded. Reqmrernents in the regulauons below) for 20 years (a penod assumed to include the full afecung emasions dunng operation ws!! assure tant operation and decommissioning cycle of the miU) would be exposures to individuals are within ensting public health about 380 in a million, hus, at a rate of 19 (380 + 20) s:.andards. Furthermore, requirements of regulations will cancer fetc.lities in a million per year of espasure, this is have the efect of assunng that miU operations are sabotar4tanUy above the tai 4n-a-mdban to one in a-tmlbon performed in a manner that redsecs populauon tiposures annual fatahty nak leveis commonly suggested as standards and risks to the maminum ntent reasonably achievable, for individual de minunis risk.
With respect to overall health impacu, the cnucal mill-Because of the considerable uncertainties that exist in nicased rs&onuebdes and their pnmary sources are,5 the health nsk estimaton used (ruks could be one half to descendmg order ofimportance: Rn 222 (radon) from the two times those estimated), compenson with risks posed taihnp pde; Ra 226 (rs&um) and Pb 210 (lead) from the by background radiation provides valuable penpective.
tailinp pile; and D238 and U 234 (uromum) from The asumated risks to the nearby individual would be an yellowcake operauons. Health impacts from Rn 222 result increase of about 25% above nsks from background from inhalation ofm grown dau6hters and ingestion of the rs&ation caposures.' Exposures and ruks to an average ground depenited long lived daughter Pb 210. Because individualin the region over a similar time span would be a Kn 222 is released in gaseous form, it is transported long smau fraction (less than 1%) of those for the nearby datences, exposing large populebons, albeit at entremely indmdual.
small and dimmahing levels above background.
De efect of concentrated milling activity would be to The iApacts of Ra 226 and Pb 210, released in par-increase raks to the nearby individual by about 50%.The ticulate form from the tailing pile, result pnmarily milling cluster would have a more dramatic efect on nsks through ingestion pathways. (Diapersed Ra 226 also con-for the average indindual, raising them by a factor of about sututes a secondary source of Ra 222 releanc.) Emincions ten, from thr:e to about 30 chances in one million of from impounded taihngs materials have an enhanced premature cancer death. This risk would be about 2% of importaace due to their persistence beyond the operst-that faced due to natural radiation exposures, ional hfetime of the mill itself Youowcake emissions result De risk to an average individual Imns in a repon of in sigm6 cant amh=d impacta, pnmarily via inhaladori, mammum muung and milling acuvity in the year 2000 is t
but essentially terminate when the mill shuu down.
very roughly estimated to be double those desenbed above The amended NRC regulations require changes in for milhng alone his estimate is based on recent todon current milhng practices and taeasures to reduce long-measurementa around open pit and underground mines, term societai nsk from mili tailings,so as to conform to the which indieete that releases from acuve mining will be r CJired Environ. ental Protection Agency (EPA) radio-roughly equivalent to those which would occur from lopeal protection standards in 40 CFR Part 192 and those tanhngs under tbc base case.
m 40 CFR Part 190 which NRC chose to adopt and impement. These standards require that exposures of mle body or any orfan to any indindual in the general Model mill risk assessment ptlic not caceed 25 mrem per year. Because the limits app!y only to exposure to nuclides other than redon and its A useful penpecuve on radiological impacts on workers da:hten, the hrst exposures daeussed (referred to as 40 and nearby individuals of the general pubbe from radio-CF R 190 doses) do not tnclude contnbutions from these acuve airbome emissions for the G EIS (Generic Enytron-Pre!eet Appealsal MccA 198f 43 q
Airlear cane menetemrar mental Impact Statement) base. case model mill is shown interat. As of1976, mills employing the acid 4esch process b Table I (NRC,1930). Radionopcal impacu will depend represented g29 of the total U,0, prodvedon capacity of N
on the tumber of mills in a repon and on the mill site and the conventional milling industry; mills with alkahne-other vanable charactenstics of mill design and operanon.
leech circuits accounted for the remaisung 18%. In view of e
Accordagly, the GEIS developed a generic description the preponderance of acid-leach milla, the model mill of a 'model mall' based on feetures typical o(uranium mills employed the acid 4ench
. However, the meior in operation in the early 1970s. The charactenstics, impacu from the alkahne h process are not espected operating procedures, processes, and eHluents of the to be significantly diferent from thoes of the acid 4each model trull were denved from data for existing mills as proces.
desenbed in techmont literature and various environ-The basic assumpdons in the model mill mental reports and statements.
charactenatics are showninTable 2.
features ofthis The model mill concept serves two basic functions:
gemene approach in ddnas the snodel mill and related First,it provides a sneans of assenems the environmental source term and other assumptions important to radio-impact of the model region and the model site. Second,it lopcal impact assessment are found in the Gels (NRC, serves as a base case for evaluating the environmental 1930).
isnpacu of allemative methods of efluent control and in comparing the does comminnents leadanpo health tailms management.
efects impacts (ie latent cancer fatality risks)in Table I for The model mill features a relatively low level of total done including redon with those escluding redon, it is environmental control, which in some respects represents seen that a maior diSerence esists for hang dose and to a a lower level ofcontml than that currently used at US mills.
lesser essent for whole body does. The estimated lung Dependmg on the chemical charactenstics of the ore, does,includingredonfora ' le mill,is 220 mrom,or 7.3 convenuonal uraruum mills employ either the acid leach tunes the level escluding to
. The whole body dose process coupled with solvent extraction, of the alkshne.
including redon (at 9.7 mrem)is about 3.2 times the dose lasch process coupled with causuc precipitation for the escluding redon. In contrast, the bone dose commitment concentration and punfication ofleached ursnium.These includmg redon is only IM higher than that escluding processes are most common in the industry at present, and redon.
this situation is espected to contmue for the penod of The integrated risk assessment for an ossite nearby Table 1.
Radiologicalimpacts from reeleective altheme emir 56ene for the base case model mill
~
~
Dees sommitmente Reek from miti (mtem) esseeeentose
.. --, gg gg g g gg gg la&ckereund F4ceptor Whele body Gene Luag (ents
- Nearby individuaN Annual 40 CFR 190 cost tescludmg recon) i mill 3
45 30 Mil cluster 4
51 3t Total ocae tinctuomg recon) 1 mill 97 51 220 25 i
Mill cluster 13 61 340 38 Average individuat' 1 mill 0 061 0 50 1.6 019 Mill cluster 0 66 6.8 16 1.9 Average worker' Annual 450 2000 7100 400 Career
- 2.1 a 108 9 3 x 108 3.3 a los 600
Background
143 250 704 l
I-Notes -
e All doses shown are total a nnuet 16th year dose commitmente eacept where noted as bems those covered by 40 CFR 160 limetes e The range in noks due to uncertainties 6n health effects models outends from about one halv to two times the contral value (App. G 7). This range does not melude l
uncertainties in other areas (eg. source term estimates and does sesessment modelst e Risk comoansons are presseted for exposure recorved during entire milllife; that is.16 years of esposure cunng operation of the mill,and S years of poetoperation esposure while tailmgs are drymg out are consecored. This value is greater than that f rom annual esposures presented because tailmga dual releases increased m the pened when tailmes are crying.
- The " nearby motvidual" occupies a permanent residence at a reference location about 2 km downwed of the tailings pile.
- The " average individual" exposure is cetermmed by dividing total population esposure m the model region by its population total.
The " average worker" e aposure is determmed by a veragmg suposure s eapected at the vanous locations m tne typical mill.
r The career dose is based on a person who has worked 47 years m the milkng mdustry (that is. from ages 18 to 65).
Source-NUREG 0706 (NRC.1960).
l l
46 Project Appealsal March 1988 l
l
1 N uinerene n m l
Tatie 3.
Summary cf principal cperating chorector.
appreciably 6eleer the US annual rete of 187. It b bar.
tot 6es of the model mill anung to note that four of these states (New Memoo, j
W Utah, and Colorado) have many acnve uranium
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t,,
Poremeter value and mBis, and am endmMed collectively to possess Oro process rate 1600 MT/o 70% of the probable uraniusa resources of the US (NRC, Avera0e or* Orsoe (% Us n) "'
1980, page ).15).
o Oea'iu....an.each' nasson =**n =ishi susai *= io do=
caughter m secuia, of radia6on could be beneScial to one's health (Luckey, ecumonum to10% Us p aso oci/o 1980). However, a inom widely acceptable explanation is o
l Ore transport Naviage from mme to mitt by that this negative correlanon a donunantly isopected by
(
truck 23 MT averape lose the sneslung efects ddir snore important causal counbu.
Ore haulme oistance 15 o 80 km ($o km everspo) tions to cancer fatality reten. neae include demographic Oro ano area normany m use o S he and socio economic factors, dieten habita, smoking and Oro storage '.rre tio.esy other 1sfestyle diferences, and environmental chemical supply en nanot
~12 e and radiation carcinogens of attainctual or natural onpn Operstmo sors per year 310
($p,,;,, gpg3),
Manpower reovirements
~160 employees ano other ggg g ggg g
uranium recovery teatraction A bomb survivors of n=a and Nagasaki, as well as eHaciency) 93%
gmauer sub.populadens ofindustrial workers or snedscal Procu:t punty 90%upojfET ye oweake that a done of10 rem is still suf5ciently smau that dete cuon l
patients esposed to substandal dose dredimion, suggmu 1
(E*u""o*F s
wioweeke transport shipment m ss.oanon erums of an increase above the normal background incidence of by truck;each orum contam.
cancer cannot genersuy be demonstrated with statistical mg a manimum of 430 kg of pyggiaign, even in a large esposed populadon (Peterson, g,iowea,ke. ao oruma carnea g 984, and Kato and Schull,1982). hus, the jury is still out Dry sono waste generateo on whether the levels of rediation doses estimated for the t
ttaiimost isoo MT/o nearby individual in the model mill cases in Table 1 might l
Taihr es censity isturry) t e g/cm2 ultimately be accepted as de minimis risk accordmg to Gr water flow to taihngs Cominon use concepts EIindividual exposure.
Taihngs srand water recycloJ 30%
Net water consumotion for
'rihngs alurry 1260 IA!/o Future generations 1.rea of mitng facihty ArIs"Ni!inNno*rn'd Ne D' P'tentf ally most useful, and possibly contrewersial, cat a unuseo inne too he appbcation of a de ramhnts ruk standard would be as a Tutsi area ownea by minmg eutoff concept for law levels of ruk posed by rnin tailmss operatien 300ha for futurs generations as weU as for long distances fro n l
Source NUREG.0706 (NaC 1980) ci e, the relevant ethicalissues are not wht;ljy dinimuar han h anociated wMr mu%nusuonal individual m Table I for cancer fatabtY rates usi"8 model efecu oflong-term storage of high level westes from the mill anumpoons is pven as 25% of background nsk for a spent fuel of nuclear power plants that have been widely single null, and 38% for a mill cluster. It should be noted discussed (MacLAan and Brown,198)i SPansler,1984).
that about half of the health effects from tailinp radon However, amce the tonnage of mill tailings produced is releases are from very small doses distnbuted over the about 10,000 times as large as the t fuelin genersting contiguous 48 states.
electncity, the spent fuel can bly be buned at Moreover, there is a sign,incent basis for the view that a depths in the earth that would ment less concem for one third or so mcrease in radiation dose relative to cumuladve effects on future generations than can mt!!
. natural background radiation might eventuaUy be re-mimp (we below).
garded as a de minimis level ofindividual risk (Spangler, p,,,p,,1jy,,, g(estimates in the GE!S provide a he ne followin 1985). For example, the avange available background nsk issues related to mill tailinp-redieu,on dose m Concredo from cosmic and terrestnal t
reistion is 124 mrom/yr.nis is 2.4 times the 52 mrerryr e ne most significant impact from mill operstions under estimated for the lowest state (Florida). Wilson (1984) the base case would occur firom tent redan pcmt: cut that a re:ident in a state with a low level of releases from the tailinp. About 000 premature cosmic background radiation increams his or her risk of deaths are calculated over the pened 1979 to 3000 (not premature fatality by one part m a million dunng a two.
2000) in the US, Canada, and Mexico, from tailinp month visit to Denver, the same as for the increased level which would be generated by the fuu opereLion of mills of dosage from cosmic rsdiauon m a ict flymg for 6,000 in the US through the year 2000.
miles at 35,000 feet altitude, e ne cumulative potentialimpacts constitute a 1.2 10' A companson of state data for annual cancer fatality (ie 0.0012%) fraction of the overs!! US incidence of rates with esumates for natural background suggests,if cancer. This lesel deverage (individual) nsk is almost anythms, an inverse correlation at these low rates of two orders ofmagnitude (80 times) leas than the average radiation doses. For example, the sin highest states in level oflatent cancer fatality nok to the population in l
terms of total cosmic and termtnal radiation (Colorado, the vicinity of a nuclear power plant from a severe Montana, Wyoming, Utah,ldaho, and New M.'.aico), with accident, as stated in NRC's recently approved safety estimates renpng from 88 to 124 mrem'yr, have cancer poal - namely, a 10 '(or 0.1%) fraction of background.
death rates of 91 to 162 per 100,000 population. These are latent cancer fatahties (see Pan III of this senes, m June Project Apprainal March 1988 47
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.w.e w,suem,%,acu 1988 Mojes ApPrenaf).
O ne efects of releases from :rulkng can also be com-Shiuld Ovallable Societal retources i
pand wit eoes occumng from natural and tech 4 v
n iepc.iiy enhanma nource d radon. Spm6cany, be used t3 protect people from redse i
espesem from milhas redon nkma wald be about emanating from tailings when greater 0.3,0.2,3 and 10 % ofesposures occurnng from releases from m.mmi am, buikung inierson, evapotransp,,.
benefits might derive from other mim, and tiling or.oit, a., uy.
uses of those resources? The Generic
- $,*"),D@is 's[naQ"io $"aN*ui$
Environmental Impact Statement year. Das annual rate could be used to deve sought an answer utmeias of besith efects beyond 1000 yeen if this were desired; this would require makmg very uncertam assenpuans on long-terin factors, such as climate, populauan growth, etc (NRC,1980, page $).
knowledge and analysis is of no avail. Perspectives As noted above, the base case for these estimates pertain to on how em quesness swid be answed varied millag opersuons in the 1970s, and do not n6ect current widely among commentators on the drnA GEIS.
protecove measures to reduce these n.oks under the new
% stated est se ta&ngs Wauca pmWan deal should be properly viewed as a shonaerm one when cost bene 6f w
es amant dados controlest abound be men the used mg t
"9 sought to address the following issues (NRC,1980, volume period M
ID, pages U 6, U 7)-
O&er commam 5 em ee fuu dd e Should available societal ruources be committed to toxicity should be considered and, based on this and protecuan from taihngs emanated redon wben greater the large number af potential health efects, virtuauy benc6u might denve from other appbcauons) no redan relenes fmm the tehny should be allowed."
e Should health nate occurnng far in the futun be valued "Notwithstandmg the enormous subsecuvity in-as though they were occurnng now? And af not, how volved with these questens, some might be withng io should future health nsks be valued) make judgments about them and eclect values for the e la it ready worth reducmg naks which, on an mdividual parametere descnbed in Smion 2 and 3 that, for basis, are at least estremely etmall and may even be mampla, lie soonewbere between the estrosasa. ne sero?
optamisation metledology would still break down e Should present generatior.: b primitted to bequesth a for the mee of the urartauen mill tailinea disposal e
3
'egacy of conunums undeserved rad.auon cepsure) ptoblesc, however his is largely d e to the sm-i 8
possibtlity of correlet ng contamment performan&
umquely with mpplicable cos s (that a, nlaung :
Ethics and value complexities to paramet: As as das:vseed ir. Secuoc 3.2)."
he doDar values and ranges of para:neters used it. this Depite em Kcuico, the GE;S did reach certam nsk cost bene 6: ana!vais of alte neuves for irsenamed regulatory coa:Imo is and developed new requirements m&olopeal protecuan are shown i i Tables 3 sad 4 (NRC, I"'"**uns cwung tw w ddAn to arenasc 1980, volume Ul. page U-6). After grapp!zg with the md% cal pmtectm.i Mond keer prs:tica ne 2
detaak M h alternatan maus cwh m se above ethical tasues in the sobemq contest and comples-iues of nsk cost bencSt analysis, the GEIS states (NRC, an4:a and ee imphcanau dee ww nquimmnu for 1980' volume Ill' F*8' U 7)'.
ifennt we d unining and inlung operauons, and enwonmental situations, an beyond the scope of this "These questions are, quite simply, beyond technical arucle. Because of the substantial compleasues and the ruoluuon. Although perunent and important, they evolvmg nature of agencv policies, a discussma of the no mvolve emotional, pohucal, and even religious interacuans hetween the N%C and the US Environmental conudersuons that the gOis.es of purely soenoSc Protecnon Astency (EPA)on mall taihngs and radiolopcal Table 3.
Velves and renpos of parameters used in todon flua opelmisation Peremeter Definition and Unite Centrol value Aante A
health eMects/yr per oCum8 eec of Rn reisaned 0.021 0 0021' to 0 21 i
A methons of 8 per meter of certh cover spoke 0 106 76 to 320 s
A.
redon flun attenuation coeMicient, per meter 13 0 8 to 3.0 A
millions of 8 per heattn etteet 0 48 0.02 to 10 s
t eMoctive number of years of annual heetth effects counted 100 to 100.000*
Notes e An uttomate tower hmot of toro os possible e An uttomate upper kmot of e $ s 100 has been cetermanec Centret retues geven here for other parameters result onrectly from statt anstysis ano are correctly unterpreted as statt "best estimates "The centret velve shown for the cotter worth or a heetth errect merery represents a m:00te ver e un a wree range of vetves appeetong on the open hterature. rt ns not v
otherwese sooored or endorsed by the start Source NUREG 0706 INRC ss00) 48 Project Appraisal Ma cA 1988
~..
e.
Nutheramaneemenepaw,,t s
s Table 4.
meavita obte6ned la reson fixa opt 6miseu:n reclaimed uranium mines would make the impact 100 umas lower.
Celeulated opt t on flus timits.
De board concluded that the best means ofcharacter.
N' valve et parameter' ' central iains the ce of redon releaneg attributable to opemtion se facility wm a compen km wis he T, ym verve meneee associated with naturst backpound mdiation and its 460.000 000 0 000022 o00000003teoott 8uctuations. De incremental releases attributable io the ioo ooo o 097 o o0012 to 95 facility were so small as to be completely undetectable.
1oooo o 97 ooot2 to uniimitea hus, the board concluded that their impact could not be M
['
$ t[ug signi5 cant (8 NRC 87 (1978)).
in several other '
cases involving the same Note.
but, the Nuclear Pg 3 ceasesson's Appeal Boards
- vsi.es s*.own are thou ootainea by minimiting or man, referred to the Ucensing Board's deemion as employstig a amiting the optimum fiva witn resceCl to all carameters "de minimis appronCh" (I) NRC 4I7 (1981)).
encept t. by vamo. cars.n,eter, ranges insten m f sole,U1
,,,d,o,,ei,,,,, ecis, ion con,cerni,ng the health efects in a more recent d i
7ne o,i,maie m, nim m.a e o os,emeie,a, m., oe e,0.
,,,,,i,,,,,,d,,,,ertre,,ce
'*UesUo*fth7v'a'i$Of"' Nfrs*me"t rs ' *"*-
to the de minimis rationale, ney retained the compenson b
rega t
Source' NUREG o706 (NRC.1980L to natural background radiation, however, and concluded that "the incremental bealth risk to the population waste management is also beyond the scope of this article.
stemming from the fuel cycle emissions (ifindeed there is It should be noted, however, that the NRC has completed any)is vanishingly small"(16 NRC 1528 (November 19, the following regulatory sedons set relate to EPA's 1982)). De Appeal Boards found that the todon releases standards published on October 7,1983 as Subpart D and attnbutable to a single 1,000 megawatt (electric) nuclear E to 40 CFR Part 192 (48 FR 45946):
reactor would cause an increase in dose to the bronchial eFithehum dfmrnOM ma005 minanmpsvered to the yearais e NRC amendments to the uranium mill taihnp rule to is far below the 480 millitem per year de.
conform to EPA stabibty and redon release standards (October 16,1985; 50 FR 41852); and bronchial e s&olim by typical outdoor redon levels from i
e NRC rule maki on ursnium milltailiny regulation to conform with PA's ground water pretecuen stand-Nuclear Re8"Istorv Comrmssion has ards for ursnium and thorium mill tailiny for bxb aquemly miocted k vgument that Myisks paed by radiological and nonradintoipcal mater.tas (Novem',cr umnim mining an de sunm. ln denying a stay ofits 13,196$,12 FR 43553)'
hcensing mquaraments for uratuum nulling sought by several mill operstars and t% hfate of New Mexico, the it is sigrafaant to note d.st EPA's standards require Commission explainsd:
controlofrediolpor orie thousand yesu, to the extent Radon is the primary source cieg term public cal harards after the mill olosure period to be efective reasonably achievable, and, in any case, for at least 200 esposure to radiadon rewiung imm uramm ralhng.
years. As in the case of NRC s regulatioes for facihty if adequate measures are not taken w control redon decommissiorung (Part 1), the EPA standard: applicable hH tahy pila, the @ vsm at uratuum nuu closing tire ststed in trrms o' radar.uon to the source would csceed its esposure to aU the reka:.e rates (a measure ofheurt)ta;her tSan in terms of other radiadon sources associated with the uraruum smeptable r0 A to the public 4 ddressed W NRC's G EIS. In kl #4" I13 NkC 460 (INI))'
prepar ng these standards. EPA referer.ced and hit upon The Commission recognized that localized as weu as NRC's GE!S (NRC,1980), inercasing by tenfold the generalized erposure would ocetir, but did not dacuss the release rate standard for redon risk.
potential radiation doses that might result. A stas report i
(NUREG 0757)stimates that, si e distance of100 metera i
downwind from a properly stabilized tailinp pile, an Aggregation of de minimis risks individual could receive an incremental dose or 14 milli.
rems per year above the background level. Hus, it is According to Cunningham (1983), recognition of the important to consider not only generalized but localized importance of the de minimis nok concept emerged in a efects in determi whether exposures from an NRC.
senes of licensing decisions concerning the relene of bcensed source be regarded as de minimis.
redon gas attributable to the mining and milhng c(
It is also interesu'n6 to note the potential impact of uranium needed to fuel certain nuclear power reactors.8 applying retroscuvely the de minimis cutosconcept ofone j
ne issue in those cases arose under tbe Nanonal Environ.
millitem in aggregating population doses from miu tailinp mental Policy Act rather than the Atomic Energy Act.
redon releases as per the proposed 10 CFR Part 20 revision Because the decisions concerned small release of radio-dicussed in Part 1 of these hoject Appreual articles. It is active redon gas, they are closely relateo to the issue of a de clear that this cutos application would yield a maior nunurus concept in radiadon protecdon.
reducuon in the 6,000 delayed cancer fatality estimates of in a proceeding to determine whether permission to the Gels (NRC,1980) over the period 2000 to 3000 AD.
construct a nuclear facility should be granted, the Nuclear he range of the efisctive poputadon dcass (reaching to Regulatory Commission's Licensing Board considered the Canada and Mexico) would also be shortened through a sigrufi.;ance of redon gas releases in the contest of an one millitem per year cutes procedure, as well as the envitcamental cost benefit analysis. nc licensing Board period into the future of sigru'ficance to populauon dose found that the calculated health efect that aught result -
estimates.
half s nath per year in a populadon of 300 million - was a In efect, the use of the cutosconcept in this manner trurumalimpact. Properly stabilized miU taihnp piles and provides a hybrid procedure in response to the quesuon of Project c.ppraisal MarcA 1988 49
=
l
\\
Standards f t Nuclear Pr<er Operadons" stablished by Being downwind could increase O dw US EnvimnmanalProweden y is 40 CFR 110.
Person's exposure bya known amount.
M**d's'**Ehr,'Ep"e"r M die Na"id$
y Thus NRC licencees snust consider mahnms per yem to nil mher esass = a rault spimund d "viaaa"at *** "'"i"" A'*1 'Y
d**"8". neu*imle gradiadon *7 "n involv locall ed eft'ects as well as the more acuvitin general effects abm whichihe Nucise Reguiaiory n and d=
EnvironmentProtocuan considstthe rials unaccept-able, or at least under norinal cucumstances.
whether an Individual ruk pe
've should be the sole Akbough licensees am not requind to reduce esposures or focus of a de mmmus tak
, or whetbet agregate mieness below the ALARA level (As Law As Reasonably I
societal ruk should be uonally considered, in the Achievable - ese previous ardcle), the Nuclear Regulatory bybrid approach, some weight,but less than total weight, Conismosan does not canader those esposures or releases would be pven to very small individual doses in con-sidenng the egngste value of societal u' npact, namely,
, harther reducuan would be required ifetrcum-doses above 1 mrom (0.0lmSv) per year of exposure.
mances changed afectag risha, costs, or bene 6ts to make a lower level ' reasonably achievable'. In the absence of an emphcitly established de saanums risk standard, there is no Low-level waste enesaptions level below which further reducnons might not,in pnnespie, he regnared, even though US court demaions state that sero Thus far, attention in the NRC has been principally nok is not regiured in NRC regulatory dommons (Spangler,
. directed to the use of de muninas risk concepu in regulat-1987),
ing low level rather than high level radioactive waste Under The Atonne Energy Act, the NRC has the management. For esample, Cunningham (1983) notes the authority to es apt imm its regulations certain quantaues or recognidon of the need by the Nuclear Regulatory concenirsoons, forms or unsa, of redsonctive matenal.
Commission for a de minimis appecoch in its regulations Under the Act, NRC regulates matenal classi6ed as governing disposal orlow level radioactive waste. Such an
" source matenal",' byproduct material", or *special nuclear approach would establish minimum levels of radioscuvity instenal". Source matenal is ds6ned as uteruum, thorium that would heve to be present before disposal in the and ther ora in denpisted concentrations, and may include manner prescribed for radioactive waste would be any osbar antanal that la canadered essental to the required.
produene of spenal nuclear notent,l. S nuclear On December 27,1983, the Nucleat Regulutory meteria? means plu aniweguraniuni in uw.nosope Comminion published a Saal rule setting for the bcenairg 2D ur 235, and any oder materal that the Neelear requirerynu for hund dispod r0adioacuve wr.:tedn the Assulatuy Coaummon may densnete, tot dou net melude not.ce of nalomaking (4*r F3 57446), 6e (No mussion suust matenal. Bypoduct metanal meens any radioective endorsed the concept of establir.hing de mir.imia levels for matwial (other than apocal nuclear matenal) yielded in or radioactive wastes, characteriang suca levels as thnee moda milioecuve ry as;pomire to the ned auon incident to tiv "below whica there is no regulatory cor.cern". The p,eceu cl produnng or utiharig special nuclear mate *ul.
uct matunal also includer umnium or thonum mill Costrussion noted that the establichmet of de minimis Fr~
levels wculd reduce the costs of radicactive worte disposa! -
and v.ould con?erve spne in disposal facilhies designed (tw Under Secuan 62 dthe Atcanic Fur Act, the Nuclear westes havng much hi6 er activities.
Rfgulatory Cmmmanww ha the authont) to(sergt from iu h
l Thus, although it used the term "de minimis", the rer lauons unaponani quantities e(source sstenal lt also Nuclear Regu! story Commissioa appeared to have in has authority, under Secuans $7d and si of the Act, to mind the t>pe of cost bene 6t balancing usually employcd esempt qumnticas of nuclear materialand byproduct in the issuance of specific esemptions. It re,terated its matenal, respecove, that would not be irumical to the belief, ardculated in the notice of peoposed rule makiag, conunon defense security and would not consutute an that smarmnmg waste stname on a case-by. case basis unr===anahle ask to the -
health and safety. (This l
would yield quicker and better results than would setting a esernpuon authority is in vanous secdons of the generic limit. It recognised the desirability of a generic regulanons 10 CFR Part 40 for source material 10 CFR hmit, however, and announced its plans to work toward Pens 3045 for byproduct matenal, and 10 CFR Part 70 for this goal over the next few years. Esamples ofNRC's uses spemal nuclear matenals.)
of nsk cost bene 6: analysis in the radiological protection of the public where low levels of radiadon hazards are involved are to be found in the rugulatory procedures for ALARA cutoK concept reaching decisions on regulatory esempuon levels (10 CFR $20.106).
Speci6c esempuans may involve esposures that are withm i
This section requires licensees to assure that radio-the ALARA range, but would not necessarily be de activity in effluenu to unrestricted ereas does not exceed
=mema, depending on the de mamis level chosen. Such certain maximum permissible concentrations above esemptions usually permit use or disposal of esempted natural background in air and water. Esemptions may be products or quantities without regard to their radioacuvity.
spect6cally authorized under that section or under section ney are not properly considered de minimis levels, 20.302, relating to waste disposal, however,because they are not expressly based on a 6nding As noted above, section 20.106 also providce that that the nsk is negligible.
Licensecs engaged in uranium fuel cycle operations shall Rather, exemptions codt6ed in the regulstions are comply with tbc " Environmental Radiation Protection based primarily on a balancing of bene 6: and cost, of 50 Project Appreisal Marc 4 08
1:
Acleer se anew which risk u an important element. There are several
- 2. ne mammum espected efective done equivalent ts
./ l-recent enamples b which NRC amended several secuens an individual member of the public does not onceed a I
of the 10 CFR Part 20 regulations. On March 11.1981 the few millirem per year for nonnel operations and Conwussiun amended Section 30.306 ofits regulations to anticipated evaits.
i permit 6sposal of Equid scintillation media and animal
- 3. De collective doses to the critical population and carcasses containing tracer levels of tridum or carbon 14 seneral population are amau.
(0.05 nuerocunes or less per grass) without regard to their 4.
The pMendal radiological consequences of accidents redsosctivity. It also amended Secuan 20.30)(d) to raise or equivalent mal 6menon involving the wastes and the annual limits for disposal of antium and carbon 14 by intrusion into esposal sites after loss of normal release to the sanitary sewerage system. hat section now insututieinal controls are not sigm6 cant.
provides that each licensee may release into the sanitary
- 5. De esempuen wdl result in a snydacant reduction in sewerage system not more than En ewiss per year of societal sosts.
i intium and one curie per year of carbon 14.
- 6. De weste is compatible with the proposed treatment Dese esempnons do not represent a complete deregul-and disposal opdons.
anon of the disposal ofsuch amounts ofradioacnve wastes,
- 7. De emanpdon is useful on a national scale,ie it is however. Disposal of hquid scmtillation media and ammal likel to be used by a category ofbcensees or at least a carcasses under Section 20.306 must be in accordance with ant poruen of a casesory.
an applicable Federal, State, and local regulations govern-8.
e radiological propernes o'f the waste stream have
(
ing any other some or hasardous property or those been charactenaed on a national besis, the vanability matenals. Tissue may not be disposed ofin a manner that has been projected, and the range ofvariation wiu not would pennit its use as food for either human or animals.
hivalidate supporting analyses.
In addauon, licensees are not relieved of maintaining
- 9. De waste charactenasuon is based on date on real records showing the receipt, transfer and &sposal of wastes.
radioactive materials, as required by Pan 30 of the
- 10. ne disposal fcem ofthe waste has neshgible potential regulations.
for recycle
)
It is not clear what levels of societal risk are involved
- 11. Ucensees can establish efective, licensable, and in-followmg these new permissible procedures or standards.
spectable programs for the waste pnor to transfer to
{
indeed, such calculauons under these circumstances would demonstrste coneliance.
be most dd5 cult, since esposu e of humans to these
- 12. ne ofeite treatment or disposal medium (eg sanitary l
sourers ofhazards is rather tenuous and highly uncertain.
land 611) done not need to be controlled or monitored But it would appear that the risks a e q;ute ses11 and, for radiation peotection purposes, moreover, the esemptions nguire r.c further application
- 13. He methods and procedures used to manage the c,f ALARA to reduce thcst riaks any further.
wastes and to assess theimpacts are no dd'erer.t from i
xheme with upper limiu a(bove which the calculateJDus, notes Cunrirr; ham 1983),we bem a re bee that would be applied to the correspondmg uncontaminated matenals.
health rssk is genersuy unacceptable Selow these upper
- 14. Dere are no teristory or legal chstaclu to use ofthe limits are varsc..is speci6c provwions and esemptions proposed *,rstment or esposal metho6, invohing calculated nsks that are considered acceptable based an a balancing ofbenents and mts, and need not be Ahhough rtirence to de muurrus concepu is not eglicitiv considered further. Regulawry tequiremea's below the
,,, g, g,,, g,,g,,g,;,,,,
- ,, g7 up hmns are 5ased ott the ALARA pnn
- iple and any de minim. is nsk though the usage of charactenzaaons
,.g incer.t impact on the human evironment ns evolved is Ndged acceptable based not only on the magnitude on the health nsk pc esented, but aho ormnous (itetn 1), the potential for &ccidental consequer:ces are "not social and e:o iomic consideretions.
agm6 cant" (item 4), and "neglagible" potectW for waste A de mirumis level, if adopted, would provide a recycle (itein 10). As noted m Pan i of my senee.,
i regulatory cutof below which any health nsk,if present
.g,;,,g is regudd au pym for de mimmis,
- 'th tnoing
could be considered nelligible. Establishing a lower cutof' Imut for ALARA analyses through a de muumis standard NRC is presently engaged in re enamining its would spare regulatory and other societal resources for rak pesetices and policie regardmg such inter related res-reduction or other goals decrymg pnonty consideration.
ulmory tools as a de muunus nsk standard, below res-ulumy concem, and residual tdemtin release sundvds.
De EPA is also currently developm' s a Below Regulatory uBelow regulatory concern,, - guidelines Concem (BRC) cnterion that would aUow for the unreg.
ulated disposal of certam very low acuvity waste sirsams On January 15,1986, the US Congress enacted the !.ow.
without regard to their radioactive content. h is estimated Level Waste Policy Amendments Act of19g5 (42 USC by the EPA stasthat about 30% to 35% of the commercial 2021b er seg.). One NRC response to this act was to tsaue volume a(low level redsoective wastes genersted between on August 29,1986 a Policy Statement on Radioactive 1985 and 2004 might be tad to qualifyas BRC waste, Waste Below Regulatory Concem (51 FR 30839). His dependmg the le of the BRC criteria that is pohey provides for expeditious handling of petioons for uhunnely c (Foute,1984 rule makmg to esempt speciSc radioacuve waste streams It is genersuy felt that a standard of de minimis risk from disposal in a bcensed iow level waste disposal facility.
should be esublishd pnncipaDyin minion to the ruks of NRC decisions whether to grant such a petition are based
,,,{ living that occasion insigru6 cant concern (Schiage dail 1986). Accordingly, regulatory or other cost savings on the followmg enteria.
resulting from a de mmimis nsk standard should be of no 1.
Disposal and treatment of the wastes as speci6ed in unmediate relevance in etablishing such a standard. On the petition will result in no sigmScant impact on the the other hand, a deterndnation of a source. based level for quahty of the burnan enwronment.
Below Regulatory Concern might well consider such cost Project Appreleal Much 1988 N
w ww mpw
]
savings, and hence support e level of acceEWe ruk above
- m which asht be resarM as a mana r=k
' Natural b:ckground levels' has sonn7 nm 6 e airma quotion whaber the miabinhment sn ccing 13 the genere! p blic, ccd o(a BRC newi mould (agpecne a reguiaiory approach can be related to criteria for BRC -
ggg ""d
- * *y '*k @,"")
Below Regulatory Concern
. ~
he DMR standard.My own is that
khak==
the second af thsee serat is superior to the nrst. All Hsulatory rules and must be prepared to stand Policy Statement of October 9, IMI that favors n-the test of court ruhnss. De concept of de means m
M of spent fuel, and instructed the Secretary of i
hapacts had its on' gin many years ago as a legal pnneiple, k-y to proceed swiAly toward t of a means and a number o(US court decisions regardag radiation d ston'ag and dispoems of high lew! waste and chemscal hasards support the acceptability of de (NRC,1934),
l
====na concepts (Spangler,1937)
De mies of roproosesing and recych'ag o(spent Secondy, a DMR based on a level derind nuclear fuel en believed to be unfavorable for a long i
from the comparative c(everydayliving regarded as period, and there is additional concern over the risle of
'-i---St ara-paa== a key pnnciple of equity and theA of the plutonium produced in reprocesses that could consistency between safety decisions by public agacies be used for proliferauon of nuclear weapons (Carter, and those ofindividuals 1937).
Dus, a base of faamass is stablished that defuses the ne role o(se NRC regenhas policy issues of radio-l question c(whether elitist values or broadly based societal' logical prosecuan from the management of HLW is values are being serwd in regulatory decision-making.
delineated by the Act as it mistes to the roles of the LS Acconhngly,in the complementary approach, the estabhab-Departmentof (DOE)and the US Environmental ment of a DMR standard would provide a vital reference Protection Agency PA). A maior role of the DOEit the level for deciding whether a higher BRC level is needed in analysis and recommendation c(candidate sites for site responding to a petidon for a source based esemption. On characternation through an Environmental Assesunent.
the other hand, if a BRC level is requind, the DMR (An Environmental Assessment is far more limited in its standard would provide a much needed anchor point for empe of analysis than an Environmental Impact State-l l
ngering and aiding the risk. cost beno6: analyris c(
meet.)
l opuanal BRC levels and tory procedures a the A 6rst step in this poosse is the preparatioa of 1
f ruk "i=4 or each source esempdon.
gedehnes (tu be concand in by the NRC) which aball
^
ledeed, the es'ahhah=*nt c(desmon criteria for nde-specify deinikt considrations that shall be making in NRC's Policy Statement on Radioactive Weste pnmary criteri,s kr wiecuan 4 sites in nriom Below Regulatory Cacem (ages) proodes une.'ul ref.
geolope media. Such guidelines shad spee.dy factots ht awces to de minamis fish levels. Dese inc! ale broch-quahry or disquihty any site from devropee.us as a j
i marin for de mirunawk by the Intemational N"*"
repository, including doctors pe teining to die nocsdon of y
on Radaclogical P otecthm (i0 ciithrem ue 0.!rtSv We val.nable natural resources, bydrology, geoph ysics. sesamic l-year), the UK's National Radiological Protection Board (5 activity, and atomic energy defense acuvitis, prommity to i
aullitem per year), and the Canadian Atomic Energy water supplies, pecaimity to components of the National
)
j Control Board (5 millitem per year).'
Part, System, the National Wildhfe Refuge Systo, the i
Another uteful (and much higher) reference point Nanonal Wild and Scenic Rivers System, the Natienal noted by NRC in establishmg de::ision criteria for BRC is WiMerne:,3 Preservation Systeut or National Forest the natur.; teckground doses in the US that typich!!y Lands.
1
[
range Som 100 to 120 mil'iremr. per year, exclusive of the A secer.d role of the DOS is the prepara9on of an
)
lung doses from redan that add about 200 aulkreme to this Environmental Impact Statement (E:S) wLich shall meet I
reference sent. Natursi boekground radiatioe levels pro-the requiremenu of A Neuonal Environmental Policy vided valuable perspective for public understanding ithe Act (NEPA) of 1969. In this regard, the Nuclear Taste degree of concem mented by radiaden doses received by Policy Act speci6es that the Eis sha!! comply with the
[
many residents of the USSR and other countries from the NEPA by " adequate consideration of the need for a Chernobyl nuclear acculent (Denton,1987).
repository, the time of the initial availability ofa repostory, and mE ahernatives to the isolation of high level radioactive waste and spot nuclear fuelin a spository." The Act also High-level waste and spent fuel speci6ed that the EIS prepared by the DOE for a high-level waste repository shall, to ti.e extent practicable, bc As de6ned by the Nuclear Waste Policy Act (NWPA) of adopted by the ra==i=aa (is the NRC)in consecuon 1982 (PL 97 425), the term "high levelradioactive weste" with the issuance by the ra====aa of a construccon l
trieans the highly radioactive material resulting from the authonsation and license for such repository.
reprocessing of spent nuclear fuel, including liquid waste The NTPA assigned to the EPA (Sec.121) the res-I produced directly in reprocessing, and any solid mateaal ponsibility for prepanag, within one year of the law's L
derived from such liquid waste that contains 6ssion enactment, certam standards and criteria in the form of a products in sufBeient concentrations; and other highly rule that shaB promulgate generally applicable standards radioactive material that the Comoussion, consstent with for protection of the general environment from offsite existmg law, determines by rule requires permanent releases from radioactive material in repositories. In isoladon.
parallel, the act assigned to the NRC the authonty to he immediate focus of regulatory attention under the promulgate, by rule, the technical requirements and 3
NTPA is spent nudear fuel consistent with the Pnedential enteria that it will apply under the atomic Energy Act of
$2 Project Appealeal March D88 l
l i
P m
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& clueese m,=,m
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199 and the Energy Reorganizanon Act cf 1974 in of water used by the populauen at risk tnuld be a appruing or daapproving (i) applicadons for authona-funcnon of datance froen the repository, protective anon 'o construct repositones;(ii) applicauons for licenses
, actions taken, arriain h4 y'p! factors, etc.).
m recesse and possess spent nuclear fuel and high-level e To what estent would uncertannues surrounding risk sehnacuee want in such repositories; and (iii) apphcations estimation methods and ovestable data afecting the use for nothnessessen for closure and decommissionmg ofsuch of DMR eencepss imper their bene 6ts in eqsulatory sepeaitones. The Act also supulated that such require-decision making for HLW epositories) enents and criteria shall not be inconsistent with any e What potential advantages would occur in the technical comparable standards promulgated by the (EPA) Adaun-charactensation c(speci6c repository sites or the use of istrator as noted above.
special metals (eg copper) or other conservansms of in the 6ve years since the passage of the NWPA, the engineerug design in the smalti bsmer approach that DOE, NRC and EPA have produced a massive collection would reduce the uncertainties ofrepository failun and of research reports, policy studies and other background thus initigate conuoversy over the bene 6cial uses of data in implemenung their respective roles. Although a DMR concepts?
pnmery obtective of these regulatory esorts is to achieve a e What would be the special value ofa systems integrated very small ievel ofrak to the public in the region ofa HLW approach in the interlocking policy developments and
{L espostory, nowhere in these docuenents does one and an regulatory analyses regardag risks of opnons in (a)
L esplicit discusanon of de minimis risk (DMR) concepts.
temporary onsite fuel storage, (b) ossite, monitored Perhaps the inattennon to DMR concepts in establishing a regnevable storage (MRS) installations, (c) spent fuel HLW repository is, in part, due to the highly basardous transportanon,and HLW
't siting and design?
nature ofhigh-level wastes and spent fuelin sharp contrast e How would risk cost t
is of the above to the relatively small level of hazard oflow-level radio-opuansimpactthe usefulness of concepts? Should logical wastes, the espected bene 6is of DMR concepts be part ofsuch Preoccupanon with the obvious harards of HLW and analyses even though costs and benetts were to play no spent fuel could certainly obscure the possibility that the role in establishing a de minimis nsk standard for decimauon of probabilities in risk computations due to genenc use?
~
multiple-borner concepts of HLW repositories, along with o How would polincal or equity considerstions afect the careful site selection and other measures, might actually above uses of DMR concepts, and vice versa?
g achieve a de rmnimis nsk standard,ifone were established for this and other regulatory uses. it raight also be due to an Havingnarimeda suhdalbdyof nmd article unde ciation of the potential regulstery and other in deriving the above list ofissues,it wou be tempung to p
bene 6t$ en the application ofDMR concepts as docussed exploit this inforosuon in a discussion of the issues. Quite in Fen 1 and a growing body ofliurature on this sublect.
obviously, an appropriate treatmerit of their complesanes Still another source of mistance to de minimis risk is necesserily beyond tl.e scope of the present article.
7 concepts is the sizable scienufic uncertainty surroanding FF estimstes of rare events and their sneequen: s ud probebibties. Yet, this is also a defvulty in the einmation Notes ot'the mdn1 daunt stants of every day living (eg automebile 1 S'nce the GDS was covetooe6(NRC.1980L the Natenal acenderts ar.d air pollution) under venable biolegical, g
techno og4 cal, and environmental conditions confronting
[ ',",
g$p 3g$f[n'eqYeifa',*sYswts ta 4)e tndmdual in h s or bri daily decisions, meresu ne tetai neturei tmekgroune raciation ecsage o an a vertoe tis nevei of 300 mrom/yr. la'gely owe to the metusion o' redon om.ssons from the eartn Reguletory i$$ues
- 2. m rema.nne of uus escuuen of oc meinus nsk in pie NRC's regulatory treatment of mili taihngs issues and the following section on tow level waste enemotions, are What, then, are some of the salient regulatory issues in the substantetty basee on 4, pnor oncer by Cunn*gham bene 6cial uses and assoosted dif5culues in the applicauon t1963L former NRC Director of the Orfice of the Eaecutive of DMR concepts in estabhshing a HLW repository? A y QD"'Cgg,,n,,,,,,,,,,,,,,,,,,,,,,,,,e n,,,,
g l
number of such issues come readily to mind:
aumoer auch u 1o or 6 miikrem and evice it ey ten to e la view of the radioactive decay ofhigh level wastes and erne at a se mnine nok staneerd, on the grownes pet a {
spent fuel, what are the prospects that a DMR concept person megh,t encounter a,n aggregate cose of ten such,
,,,,,,,,,, i ma in,, iag e oi, +,mee mee ih n.se os i
would limit the time period of signi6 cant risk to the numerous radiological and nonudiological hetares tnst public associated with a HLW repository?
are regarose as magnificant tene, hence. se minimies m o Could, or how could, a DMR concept serve to exclude servosy livmg are many more than ten, and are also certain event related scenarios oflow probability (eg
(*,'
, ng [O R r$ th s nos d g o
earthquakes, meteor stnkes, volcanic erupuons, or aooroach as a conservatism jn the face of large un-glacial sconng) frotn further considersnon in risk certamties. But. of course.the orudency and oovity issues analyses of opuons in repository siting or design? (See of conservatismin accietal occmion making baud on the KoPik er al,1982)-
assessment of the naka. costa, one benefits of teen-l nological options - especially when more tha n one ootion e How would a DMR concept limit the geographical a angued with iarge uncertamties - are much nogiected repon ofsigr66 cant nsk, including its potential shrink-cons.oerations tsoangier.1Dost age with the passage of time?
e How would a DMR cutoffconcept(say,1 mrem'yr as in the proposed Part 20 revision discussed in Project References Approuat. December 1987 afect the long-term estimates g, j e,n,,,.uyci,,,,mp,,,,,ves and ovoke trust nac'o-of cancer fatahues from repository failu e risks? (Even
.et,ve,aste, issues m Science ano reennotogt voe me u
given the failure of a repository,the contaminanonlevel 3 number 2.1g87, pages 46 61.
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