Text

Informs of Comments on EPA Science Advisory Board Rept on Proposed EPA Std for Mgt & Disposal of Spent Nuclear Fuel, High Level & Transuranic Radwaste (40CFR191)
	ML20127B969
Person / Time
Issue date:	08/09/1984
From:	Dircks W; NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	;
References
	TASK-PII, TASK-SE SECY-84-320, NUDOCS 8408220402
	Download: ML20127B969 (103)
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SECY-84-320 August 9, 1984 For: The Commissioners j l From: William J. Dircks Executive Director for Operations l

Subject:

NRC STAFF C0994ENTS TO ENVIRONMENTAL PROTECTION AGENCY (EPA) ON THE SCIENCE ADVISORY BOARD REPORT ON PROPOSED EPA STANDARD FOR MANAGEMENT AND DISPOSAL OF f*ENT NUCLEAR FUEL, HIGH-LEVEL AND TRANSURANIC WASTE (40 CFR PART 191)

Purpose:

To inform the Commission of comments of the NRC staff on the EPA Science Advisory Board's Report. Discussion: In January 1983, the Environmental Protection Agency (EPA) formed a subcommittee of its Science Advisory Board to review the technical basis for the proposed 40 CFR Part 191, Environmental Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes. The Subcommittee prepared a report that contains a number of findings and recommendations i which the EPA is considering incorporating into the final version of 40 CFR Part 191. On May 8, 1984, the EPA published in the Federal Register a notice of availability of the report, and encouraged the public to comment on it (49 FR 19604, Enclosure 1). Since the report contains -\\ recommendations affecting the Commission's ability to implement the standard, and other matters on which the Commission and staff had previously commented, the staff commented to EPA on these matters. A copy of the staff comments is contained in Enclosure 2.

Contact:

D. Fehringer/J. Linehan, WMRP 427-4177 seaba m

M M 146 pp.

O The Commissioners On July 19, 1984,' Acting Chairman Roberts wrote to Administrator Ruckelshaus, suggesting a possible resolution of the jurisdictional issue regarding the procedural and assurance requirements contained in EPA's proposed HLW standard. If the recommendations of Acting Chairman Roberts' memorandum and of the staff's comments on the Science Advisory Board report are adopted by EPA, the staff considers that all of its concerns with the EPA HLW standard would be resolved. )d' \\0 v~ N liiam J. Dirck E cutive Director for Operations

Enclosures:

1. 49 FR 19604 - Commissioners, SECY, OGC and OPE only. ~ 2. Staff Comments O m 4 O

O 8 ENCLOSURE 1* ' O t l

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WM 5/F 3R i 3.3 WMRP r/f l NMSS r/f l I JUL GEM CF REBrowning JWCIf MJBell l 406.3.3/0JF/84/06/15/0 PComella 1 JBunting KGO'II'" i PAltomare 0Fehringer & r MRKnapp JLinehan L8arrett l Econti Central Docket Section (LE.130) LBHigginbotham PComeH a U. S. Environmental Protection Agency HJMiller PCR ATTN: Docket No. R.82-3 RR8oyle Washington, DC 20460 SCoplan JKennedy The Nuclear Regulatory Comission (NRC) staff is pleased to respond to the request by the Environmental Protection Agency (EPA) for coments on its Science Advisory Board's review of the proposed EPA standards for management and disposal of spent nuclear fuel, high-level and transuranic radioactive wastes (40 CFR Part 191). The NRC staff shares the concerns of the Science Advisory Board (SAB) regarding the implementability of the proposed standards, l and several of our comments address this concern. Our specific coments are listed below. In each case the SAB's reconnendation is first presented, followed by the NRC staff's comment. EXECUTIVE

SUMMARY

RECOMMENDATIONS A. The Standard 1. The Subcomittee recommends that the release limits specified in Table 2 O of the proposeo standards be increasec by a factor of ten, thereby causing a relateo ten fold relaxation of the proposed societal objective 4popu.lation risk of cancer). The NRC staff considers that the proposed release limits can be achieved provided that the implementation concerns expressed in the NRC's formal coments on the proposed standards (comment letters dated May 10 and 11,1983) are resolved. (Specific issues of concern are discussed below.) Thus, from the point of view of implementation of the standards, the NRC staff would not l consider it necessary to increase the proposed release limits. l B. Uncertainty and the Standard 1. We recomend that the probabilistic release criteria in the draft standard be modified to reac " analysis of repository performance shall demonstrate that there is less than a 50% chance of exceeding the Table 2 limits, modified I as is appropriate. Events whose median frequency is less than one in g one-thousand in 10,000 years need not be considered." 2. We recomend that use of a quantitative probabilistic condition on the modif1ed Table Z release limits be made depencent on EPA's ability to provide evidence that such a condition is practical to meet and will not lead to serious impediments, legal or otherwise, to the licensing of high-level waste w MRP:ejc

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406.3.3/DJF/84/06/15/0 m geologic repositories. If such evidence cannot be provided, we recommend that EPA adopt qualitative criteria, such as those suggested by the NRC. { The NRC staff believes it is important to recognize a distinction between a standard of performance and the quality of evidence that the standard has been met. A quantitative probabilistic standard of perfonnance can be applied in noministrative proceedings. However, when it comes to determining the evidence that should be admitted, or in evaluating the probative force of that evidence, different considerations come into play. These matters involve judgments which i are qualitative. We would regard it as arbitrary and inappropriate to rule, as an absolute principle, that a certain median frequency of occurrence should always be the basis for considering particular events. And while we could apply a preponderance.of-evidence standard of proof (in place of the suggested 50%), we regard the reasonable assurance standard as being more restrictive and better suited to protection of public health and safety. Accordingly, the NRC staff would take exception to the above recomendations. Moreover, it is noted that the reconsnendations are more matters of implementation than environmental standards as such. It may nevertheless be possible to meet the intent of the SAB recomendation in an appropriate manner that would be implementable in a ~ license review. The NRC staff considers that the revised wording of the O containment requirements set out on page three of this letter would achieve this goal. C. The Time Frame - 10,000 Years and Beyond 1. We recommend that epa retain the 10,000-year time period as the basis for determining the adecuacy of repository performance. We believe that use of formal numerical criteria limiteo to this approximate time perico is a scientifically acceptable regulatory approach. l 2. We reconsnend that the process of selection of sites for disposal systems also take into account potential releases of radioactivity somewnat beyonc 10,000 years. Particular attention should be focused on potential releases of long-lived alpha-emitting radionuclides and their decay products. The NRC staff agrees, in principle, with these recommendations. We note, however, that-the process of site selection is assigned by the Nuclear Waste i Policy Act (NWPA) to the Department of Energy (DOE), and that DOE's siting guidelines include a criterion requiring comparative evaluations of the perfonnance of alternative sites for 100,000 years, fully satisfying the SA8 recomendation. Since criteria for site selection are not " environmental standards" as envisioned by the NWPA or by Reorganization Plan No. 3, EPA should not add such a requirement to its standards. 3MRP:ejc

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( O 406.3.3/0JF/84/06/15/0 O 3-JUi-G15 t MAIN REPORT RECOMMENDATIONS A. Uncertainty and the Standard 2. We believe that repository designers will find it quite difficult and perhaps excessively s'.yensive to comonstrate with reasonable or high assurance that the levels of prob'ction sought by EPA in the draft standaro have been met. The following wording has been suggested, in recent discussions with the EPA 1 staff, for the containment requirements: 191.13 Containment Requirements (a) Disposal systems for spent nuclear fuel or high-level.or transuranic wastes shall be designed to provide a reasonable expectation, based upon performance assessments, that the cumulative releases of waste to the accessible environment for 10,000 years after disposal from all significant processes and events that may affect the disposal system shall: (1) have a likelihood of less than one chance in 10 of exceeding the quantities calculated, according to Table 1 (Appendix A), and (2) have a likelihood of less than one / chance in 1,000 of exceeding ten times the quantities calculated according to Table 1 (Appendix A). (b) Performance assessments need not provide complete assurance that the requirements of 191.13(a) will be met. Because of the long time period involved and the nature of the events and processes of interest, there will inevitably be substantial uncertainties in projecting disposal system performance. Proof of the future performance of a disposal system is not to be had in the ordinary, more short term, sense of the word. Instead, what is required is a reasonable expectation, on the basis of the record before the implementing agency, tnat compliance with 191.13(a) will be achieved. The NRC staff considers that this revised wording of the containment requirements will alleviate the concerns of tne SAB, and will be implementable in a licensing review. 7. We find that an approach to the EPA standard employing " individual dose limits" (cons 16ering some " maximally exposec individual," or alternatively some " average exposec individual") woulo in practice make the standard difficult to meet with high assurance for very long times for any repository concept currently under active consideration. However, we recommend that for tie first 500 years, the EPA standara embody an extremely low 11kelinood that increases in radioactivity approaching the limits allowed by the EPA drinking water standarcs will occur in potable well water drawn from any 'IWMRP:ejc

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406.3.3/DJF/84/06/15/0 4 s C _,M well adjacent to the site of the repository. For longer time periods, we reconnend that EPA rely on the assumption that standaros similar to the i J present orinking water standaros will exist to protect groups of Individuals. The NRC staff agrees with this reconnendation. We particularly note the SAB's use of the phrase " adjacent to the site of the repository". We think it is clear that the SAS intends that groundwater protection requirements be applied only to groundwaters beyona the geologic barrier which serves as part cf an overall repository system (e.g., groundwaters beyond the " controlled area" as defined in 10 CFR Part 60). We believe that any groundwater protection requirement adopted by EPA should be applied as intended by the SAB. E. Assurance Requirements 1 j 1. We reconnend that the assurance requirements, as amended by this report, be submitted as a Federal Radiation Guidance document in support of the EPA rule package. The NRC staff agrees with this reconnendation, and notes that the NRC's forinal - connents on the proposed standards identified the assurance requirements as being inappropriate for an environmental standard and reconnended that they be deleted. The NRC staff also agrees with the recommended specific changes (Reconnendations E.2-E.7, not listed here) if these provisions are to be published as Federal Radiation Protection Guidance. Recognition of the similarity between several of the proposed assurance requirements and the corresponding provisions of the NRC's regulation, 10 CFR Part 60, suggests a possible alternative solution. This would take the fann of l modification of Part 60 if and as appropriate so as to incorporate the principles of EPA's proposed assurance requirements. In view of these changes, EPA would delete the assurance requirements from the stancard. Thus, problems of overlapping jurisdiction between the two agencies (and potentially conflicting requirements) could be avoided. The NRC staff will continue discussions with the EPA staff to explore the feasibility of this approach. L. Limit Standard to Mined Geologic Repositories 1. We recommend that the ap)licability of Subpart B of the proposed standards be explicitly restricted by EPA to disposal in mined geologic repositories. The NRC agrees with this reconnendation for the reasons cited by the SAB and because of the direction in NWPA to develop standards for disposal in mined geologic repositories. tMRP:ejc

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406.3.3/DJF/84/06/15/0 O 5-JUL C 1534 N. High. Level Radioactive and-Transuranic Wastes Definitions 1. We reconsnend that EPA's definition of high-level radioactive wastes be consistent with that set forth in the Nuclear Weste Policy Act (NWPA) ano ~ coordinated with the definition used by the Nuclear Regulatory Consnission (NRC). l The NRC staff agrees with this reconsnendation and notes that recent working l drafts of the EPA standards have contained an appropriate definition. 1 We appreciate the opportunity to consnent on the SAB report and will be pleased to consult with the EPA staff on these consnents or other matters that will assist in publication of the final standards. Sincerely,. 5i..cN ..h'gM J. M ' 1 i Robert E. Drowning, Director Division of Waste Management l Office cf Nuclear Material Safety and Safeguards I i i

See previous concurrence page.

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HIGH-LEVEL RADIOACTIVE WASTE DISPOSAL, EPA PROPOSED RULE, 40 CFR PART 191 9APrI as COMPARISON OF CHANGES AND RECOMMENDATIONS p FEDERAL REGISTER NOTICE,29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT, JAN.1981 [ NUCLEAR WASTE; POLICY ACT'0F, j 19821!

SUBPART A - ENVIRONMENTAL STANDARDS FOR MANAGEMENT AND STORAGE

's 191.01 APPLICABILITY COVERS WASTE'MGT. & STORAGE,0PERAT!pNS NOT. COVERSBOTH.NRCAND,AGREEMENTSTATELICENqED f { SUBJECT To 40 CFR PApT 190.> FACILITIES NOT SUBJECT TO 110CFRPART190,;AND f DOE FACILITIES NOT PEGULATED BY NRC OR BYl l l j j l l AGREEMENT STATES. l l 1 I l i l l t 's 191.02 DEFINITIONS l f ', EXCEPT AS DEFINED, TERMS HAVE SAME NINGl EXCEPT AS DEFINED, TERMS HAVE SAME: MEANING ECOMMEtjDED CONSISTENCY WITH N}iFA AS IN SUBPART A 0F 40 CFR PART 190 AS 11 SUBPA T A 0F 0 CFR PART 190. AND COORDINATIO WITH RC (HLW) 1 } AND OTHER AGENCIES (TRU). I l i ) i l l t t i I i i I 'l " SPENT NUCLEAR FUEL"r IRRAD{ ATED FUEL SAMEDEFINITIONWITpADDEDfSPECIFICATION [ CONFORMED TO NHPA3 REMOV D FROM A NUCLE R REACTOR. " CONSTITUENT ELEMENTS OF WHICH HAV NOT B EN I SLPAfATEDByREPROCESSING.} { { ~{ j i ~~ I r i l I I l i "HI LEVEL RADIOACTIVE WAS E" DEFINED IN DEFINEDAS:l l l RECOMMEyDED CONSISTENCY AND CO-TERMS OF > TABLE 1 CONCENTRATIONS FOR: -LIQUIDWASTEPRODUCEDyIRECTLY;INREPq0-3RDINATj0NWITHNRCDEFINITION. j - FIRST CYQLE LIQUID WASTE FROM REPRO. [ESSINGlANDANYSOLIDMATERIALl DERIVE!) [ CONFORMED TO NWPAl l r I - CONC. WASTES FROM SUBSEQUENT EXTRACTION. FROM SUCH LIO. WASTE THAT CONTAINS FI SiON ~. - SOLIDS FQRMED FROM SUCH, LIQ. WASTES. PRODUCTS IN SUFFICIENT ; CONCENTRATIONS. l - SPENT NUCLEAR FUEL IF D SPOSED OF WITH -OTHERH{GHLYRAD10ACTI}EMATERIALDETR-I l CUT REPROCESSING. l MINED By NRC BY. RULE TO REQUIRE PERMANENT i 1 ISOLATION. l l 1 I i " TRANSURANIC WASTES" DEFINED IN TERMS OF DEFINED AS ? WASTES > 100 NC1/G, Tg > 20 yR, RECOMMENDED EQUIVALENCY IN LIEU a-EMITTING TRANSURANICS WITH >100 NCI/G, EXCEPT FOR HIGH-LEVEL RADI0 ACTIVE WASTE; WASTES OF MTHM CONCEPT FOR DOE WASTES Tg > 1 YR DETERMINED BY DOE NOT TO REQUIRE DEGREE OF ISO-AND FOR SOME KINDS OF COMMERCIAL LATION REQUIRED BY 40 'CFR PART 191, EPA CON-RADIDACTIVE WASTES. CURRING, OR WASTES APPROVED FOR DISPOSAL BY NRC ON CASE-BY-CASE BASIS UNDER 10 CFR PART 61.

,7 ,/~. N,/ iv 9 April 1985 Page 2 FEDERAL REGISTER NOTICE, 29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN.1984 INUCLEAR WASTE POLICY ACT OF 19821 " RADIOACTIVE WASTE" IS DEFINED AS THE HIGH-LEVEL, AND TRANSURANIC RADIOACTIVE WASTE COVERED BY l l 40 CFR PART 191. i " MANAGEMENT AND STORAGE" DE INED TO INCLUDE " STORAGE" MEANS RETENTION OF SPENT, NUCLEAR FUEL PREPARATIONFORSTORAGEORDISPOSALhOR OR RADIDACTIVE WASTES WITH' INTENT AND CAPABILITY l i } ACTIVITIES ASSOCIATED WITH DISPOSAL; TO READILY RETRIEVE SUCH FUEL OR WASTE FOR SUB-i i l l i l l l SEQUENT USE,' PROCESSING, OR DISPOSAL. l " MANAGEMENT"MEANSkNYACTION(EXCEPTFORTRANS- ] j ( l PORTATION) CONDUCTED TO PREPARE SUCH FUEL,0R { i RADICACTIVE WASTE FOR STORAGE OR DlSPOSAL,I OR l I i THEACTIVITIESASS0plATEDHITHTHEDISPOSLOF 4 i i i I SUCH WASTE. "{ l I 1 i i I 100 HEM /YRDOSEEQUIVALENT l i AND AN INFREQUENT E OSURE OF > MREM /YR DOSE l l l EQUIVALENT FROM ALLjSOURCES. l ! i t e I t I ( i "5 191.05 EFFECTIVE DATE l t i 4 J 'f EFFECTIVE 12 MONTHS AFTER PEOMULGAT10N EFFE{TIVE 30 DAYS AFTER PUBLICATION IN FEI)ERAL j 'l f,' "l OF RUkE. REGISTER. a I r l "* 'StRPART B - EMVIgnasaermTAL STaunAQD$ FOR D{$pntAl { 5 191.11 APPLICABILITY 1 I i

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l ' i t i 6 6 i i a INTO THE ACCESSIBLE ENV! NT. DOCS NOT -JHEACCESSIBLEENVIRON NT,ANp APPLYToDISgSALDIRECTLYINTOOCEANS -{ERTAINSOURCESOFGROUNDNATERINTHE VI- .J OR OCEAN SEDIMENTS. CINITY OF DISPO AL SYSTEMS. f i DOES NOT APPLY TO DISPOSAL ;DIRECTLJ INTO CCEANS i i j OR OCEAN SEDIMENTS,l0R TO WASTES D SPOSED OF I i i a BEFORE PROMULGATION OF THIS RULE. { l l 4 i i i ^5 191.12 errimrTin=< j l) "DISPbSAL"IEANSISOLATIONOFRADIDACTIVE (DElIETED ?) l 1 DISPO L"MEANSEMPqCEMENTIN ^ i t t A REPOSl; TORY WITH NO FORESEEABLE WASTES WITH NO INTENT TO RECOVER THEM. ) i i f f .;NTENT OF RECOVERY.3 i a i i t i 1
N 9 April iv Page 4 FEOERAL REGISTE.R NOTICE, 29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 (NUCLEAR WASTE POLICY ACT OF 119823 " DISPOSAL SYSTEM" MEANS ANY COPE! NATION OF EN " DISPOSAL SYSTEM" MEANS ANY COMBINATION OF i GINEERED AMD NATURAL BARRIERS THAT CONTAINS ENGINEERED AND NATURAL BARRIERS THAT ISOLATE 1 i SPENT NUCLEAR FUEL OR RADIOACTIVE WASTE AFTER RADIOACTIVE WASTES AFTER DISPOSAL., l l j l i i f f DISPOSAL. i-l i i i f " WASTE" MEANS ANY $ PENT NUCLEAR FUEL OR RADIO- { f l ACTlVEWASTEISOLAEDINADISPOSALSYSTEM. i I l I i i "NASTEFORN"MEANSfTHEMATERIALSh0MPRISINGTHE I i i i i i { j l RADIOACTIVE COMPONENTS OF SPENT NUCLEAR FUEL OR i RAD {0ACTIVEWASTEANDANYENCAPSUhTINGOk '0 i STABILIZING MATRIX { l I " ACCESSIBLE ENVIRONMENT" INCLUDES:( ) THE " ACCESSIBLE ENVIRONMENT" 4 ANS:(1 THE ATNOS-RECOMMEN,DED EPA EXTEND iTHE DEF le i i ) i a i ATMOSPHERE,...(ETC.) THAT ARE MORE HAN PHERE,...(ETC.) THAT ARE BEYOND THE CONTROLLED ION TO INCLUDE MAJOR SOURCES F i AREA. OTABLE ROUNDNATERTHATAREB{- i i 10 KM; INANKDIRECTlONFROqTHEORIGINAL 7 LOCATION OF ANY OF THE RADlQACTIVE WASTES T "" '" c "'" "'" ^"E^'(^S {lNEDI,10CFR PART 60) aan l IN A ISPOSAL SYSTEM ARE MOR THAN 2 KM. IN A HORI- ~ ZONTAL DIRECTION FROM THE ORIG,- 1 I i MAL LOCATION, E"C. l ~ "COETROLLED AREA" MEANS A SURFACE, LOCATION, - ]' i 6 6 i IDENTIFIED BY PASS VE INSTITUTIONAL CONTROLS, EXTkNDINGHORIZONTALLYNO MORETHkN2Km.FROM ^ THE OUTER BOUNDARY OF THE WASTES'lORIGI f LOC TION, AND THE StBSURFACE UNDERLYING SUCH l ASURFACELbCATIJN g {
$O) V) / 3 a \\ / v 9 April 7 985 Page 5 FELERAL REGISTER NOTICE. 29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 (NUCLEAR WASTE POLICY ACT OF .19823 " BARRIERS" MEANS ANY MATERIALS OR STRUCTURES " BARRIER" ME7NS ANY MATERIAL OR STRUCTURE (" ENGINEERED BARRIERS" MEANS MAN-l THAT PREVENT OR SUBSTANTIALLY! DELAY MOVEMENT THATPREVENTSORSUBSTANT(ALLYDELAYSM0}EMENT MADE COMPONENTS OF A DISPOSAL OF RADIOACTIVE WASTES TOWARD THE ACCESSIBLE OF WATER OR RADIONUCLIDES TOWARD 1HE ACC SS!- SYSTEM DESIGNED TO PREVENT THE RELEASE!OFRADIONUCLIDESINTO BLE' ENVIRONMENT. l ' ENVIRONMENT. i t ) s THEGE01.0GICMEDIUMINOLVED.j I j i " PASSIVE INSTITUTIONAL CONTROLS"MEANS:(1) "PASSIVEItiSTITUTIONALCONTROL"EANS:(1) l ",PERMANENTMARKERSPLACEDATADISTOSALSITE;f PERMANENTNARKERS LACEDdTASITh;(2)PUBLIC ',(2) PuBLIC RECORDS OR ARCHIVE $2(3) FEDERAL I RECORDSANDA* CHIVES;(3)60VERNMEfTOWNERSHIP l 1 i l i i ",60VERMENT OWNERSHIP OR CONTROL OF LAND USE; l AND REGULAJIONS REGARDING LAND OR RESOUR E USE; ICR(4)OTHERMETHODSOFPRESEkVINGKNDWLEDGE AND (4) OTHER METHODS OF PRESERVING KNOWLEDGE " ABOUT k DISPOS L SYSTEft. ABOUTAGEhLOGICREPOSITORY. l i "I I ] t i f I l i l 1 "["ACTIVEINSTITUT!CNALCONTROL}"MEANS:(1) "ACTIVEINSTITUTIONALCONTROL"MEANSANYl MEA- " GUARDING A DISPOSAL SITE, OR C2) PERFORMING SURE OTHER!THAN A' PASSIVE - INSTITUTIONAL CONTROL r i t t ' MAINTEMANCE OPERATIONS OR REMEDIAL ACTIONS PERFORMEDJ0:(1)CONTROLjcCESSTfASITI:,(2) PERFORM MAINTENANCE OPERA IONS OR REMEDIAL " { AT A DISPOSAL SITE, OR (3) CONTROLLING Og .A SITE, (3) CONTROL OR; CLEAN UP RE-ACTIONS AT ]CLEANINGUPRELEASESFROMADSPOSALSITE. LEASES AT A SITE, OR (4) NITOR{ARAMETjRS l g i l REl.ATED TO GEOLOGIC REPOS{ TORY PEfFORMANCE. i l i "AQUlFER* ANS AN UNDERGkOUND GE LOGICAli FOR-i l f MATION,ETC.,CAPABLEOF}!ELDING'ASIGN) FICANT ~'l [ 1 1 I t + j j { AMOUNT OF WATER TO A WELL OR SPRING. i ~ I l i l l l l l i } "TRANSMISS}VITY" EANS THE HYDRAULIC CONDUCTI-l i a t 8 i VITY INTEGRATED OVER THE $TRURATED THICKNESS l OF AN UNDERGROUND FORMATION. THE TRANSMI$SIVITY l t t i i i t, i 1 i l i i j j OF SER!8SOFFORMATIONSISTHESUMOF}HE i l INDIVIDUAL'TRANSMISSIVITIES OF EACH FOntiATION. f I
9 April 1985 Page 6 FECERAL REGISTER NOTICE, 29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 [ NUCLEAR WASTE POLICY ACT OF i1982.] "COPMUNITY WATER SYSTEM' MEAMS A SYSTEM FOR PROVIDING PIPED WATER FOR PUBLIC CONSUMPTION, WITH AT LEAST 15 SERVICE CONNECTIONS USED BY j i YEAR-ROUND RESIDENTS, OR REGULARLY SERVES 25 i j YEAR-ROUND RESIDENTS l i i j 7 I "SIGNIFICANT SOURCES OF GR,OUND WATER" MEANS:(1) l j j AN AQUIFER,'THAT: f l 4 - IS SATURATED W'ITH WAT R WITH < 10 Mc/L "i j j TOTAL DISSOLVED SOLIDS; I f ,IS WITHIN 2,500 FT. OF LAND SURFACE; ] l - HAS TRANSMIISSIVITY >200 GAL / PAY /FT.s PRO-i VIDED EACH FORMATION R PART THEREOF HAS + I INDIVIDUAL HYDRAULIC CONDUCTIVITY >2 GAL / + i DAY /FT ; f f [ f y 4 l -CAPABLyOFCONTINUOUSYlELD110 GA/ DAY I TO A P ED OR FLOWIN WELL FOR A PERIOD 0F AT LEAST A YEAR; 04 I (2)7 PROVI S THE PRIMARY OURCE OF WATER FOR j. ] l ACOPMUNITJWATERSYSTEMASOFTHfEFFECTIVE { DATE OF THHS RULE.' l 1 l l "SPECIALSOURCESOFGROUNyWATER"lMEANS} HOSE l: CLASS I GROUND WATERS IDENTIFIED BY EPA AS i i f l { IRREPLACEABLE, IN THAT NO REAC LE ALT R- ~ NATIVE SGURCE OF DRINKING WATER IS AVAILABLE '{ _l l l l TO SUBSTANJIAL POPULATIONS. [l i 1 t i l i i i i s I { l l } I i I 6 t i i t i
p / 9 April 1985 Page 7 FELERAL REGISTER NOTICE, 29 DEC. 1932 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JfN. 1984 [ NUCLEAR WASTE POLICY ACT OF
~~19821~~
" UNDISTURBED PERFORMANCE" MEANS THE PREDICTED BEHAVIOR OF A DISPOSAL SYSTEM, INCLUDINGiCON-SIDERATIONS OF UNCERTAINTIES IN EXPECTED BEHAV ; IOR, IF UNDISTRUBED BY HUMAN INTRUSION Of( THE I l i { OCCURENCE OF UNLIKELY NATURAL EVENTS. l i i l l + I ' REASONABLY FORESEEABLE RELEASES" MEANS THE fSEE 5 191.13) l l ECOMMENDATION THAT ANALYSIS OF fEPOSITORYPERFORMANCEfSHA CUMULATIVE RELEASES OF RADIOACTIVE WASTES.... i ',THAT ARE ESTIMATED TO HAVE McRE THAN 1 CHANCE f0NSTRATELESSTHAN50% CHANCE, .la100CFCCCURR1hGWITHIN10iYRS. f i DF EXCE DING TABLE 2 LIMITS, f i j DIFIEhASAPPf0PRIATy,ON 'l'VERY Lf4LIKELY, RELEASES" MEANS THE CtitutATIVE f (SEE 5 191.13) puRIESqELEASEDTOENVRONMEN .RELEASESBEESTIMATEDTOHAVElBETWEEN1CHANQE f IN 10 } EARS; EVENTS WHOSE MED,IM4 l {REQUENCYISLESSTHANl1 "l1a 100 AND ABOUT 1 CHANCE IN 10,000 OF OCCUR: l 1N10$EARSNEEDNOTBECONSI-l 4 4 l l l j '.RlhS IN 10 yrs. I l EREDJ A SO THA USE OF QUANTI i f TATIVE PlROBABILISTIC l I f l 6 i l t, ! l t i l j { j j S PRAC}ICAL TO MEET
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~~4 QUALITA}!VECRITERIARECOMMENDED. I i i } l ) i 1 i l l I I I i~~
~~RE-I l'PERFORt*ANCEASSESSMENT"MEAN$ANANALYSIS ALSOREQUIRESESTipTES0{THECUMULATIVI I~~
'.THAT IT NTIFIES EVENTS AND PROCESSES kHICH l LEASES OF RADIONUCLIDES, CONSIDERING THE ASSO-I l I i i e MIGHT AFFECT THE DISPOSAL SYSTEM, THEIR CIATED UNCERTAINTIES, CAUSED BY ALL SIGN {FICANT l { t i ' EFFECTS ON BARRIERS, AND THE PROBABILITIES PROCESSES AND EVENTS, AND REQUIRES THE A SEMBLY .AND CCMSEGUENCES OF THE EVENT $. j OFfHESEESTIMATESINTOANOVERALLPROBASILITY j j f DISTRIBUTIONOFCUMULATIV(RELEASETOTH EXTENT-PRACTICABLE. (SEE PPENDIX B, FOLLOWING). i l i j l I i
() 9 P.pril'1985 Page 8 FECERAL REGISTER NOTICE, 29 CEC.1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 (NUCLEAR WASTE POLICY ACT OF .1982] 4 "!MPLEMENTING AGENCY" MEANS THE NRC FOR SPENT i l NUCLEAR FUEL OR HIGH-LEVEL OR TRANSURANIC l WASTESTOBEDISPOSEDOFqNNRC-LICENSED;FACIL-i l ITIES, AND DOE FOR ALL OTHER RADIDACTIVE WASTES.i j j i [5191.13 CCNTAIMMENT REQUIRE NTS l 4
~~DISPOSAL SYSTEttS SHALL.BE DES GNED TO PROVIDE DISPOSALSYSTEMSSHALLBE{LESIGNEDTOPRVIDE (SEE DEFINITIONS, PREV OUS PAGE).~~
~~S '. REASONABLE EXPECTATION THAT FOR 10 YEARS AREASONAELEEXPECTATION,{BASEDONPERF04MANCE fECOMMEyDATIONTHATANALYSISO,F " AFTER DISPOSAL~~
~~ASSESSMENTy,THATfHECgLATIVEfELEASEjOF REPOSITQRY PERFORMANCE SHALL DE-~~
- REASONABLY FORESEEABLE RELEASES BE l RADIONUCLIDESTOTpEACCESIBLEENVIRONMENTFOR %NSTRATE LESS THAN 50% CHANCE ABLE2QUANTITjES,AND l1CHANCEIN FEXCEDINGTyLE2LjMITS, 10 YEARS AFTER DISPOSAL! "l LESS THAN DIFIEyASAPPf0PRIATj,ON l "j - VERY UNLIKELY RELEASES BElLESS THAn 10 ;
~~HAVE A;LIKELlHOOD OF LESS THAf "j~~
T!ttiS TABLE 2 QUANTITIES. ! l l10OFExCEEDINGTABLE1 QUANTITIES;AND URIE RELEASEqTOENVjRONMENT 'l f l l HAVEAjLIKELIH00DOF ESSTHAf 1CHAKEIN IN 10 } EARS; EVENTS WHOSE MEDIfN I i H i l i1,000 0F EXCEEDING 10 TIMES T E LE 1 OUANTI-FREQUENCY IS LESS THAN l IN 1030 l TIES. N 104 YEARS NE D NOT E CONSip-I l PERf0RMANCyASSESSpENTSNgEDNOT{ROVIDECOM-FRED;AhSOTHATjuSEOF{ QUANTI- ? ANCETHATAbOVqREQUIRfMENTSBE {ATIVEPROBABIL]STICCONDITION "j i PLETE ASS METjDUETOlSUBSTANTIALUNgERTAINTIESINPRO-pEDEPEqDENTONEPASHOWINGITg f S PRAC}! CAL T0 MEET 10THERWISE, } l JECTINGDISPOSALSYSTEMP(RFORMANpE; WHA}IS g REQUIRED IS A REASONABLE SXPECTATION, BAS.ED ON UALITATIVE CRITERIA R COMMENDED. 'i i l l }l RECORDBEFORETHEIMPLEMEqTINGAGENCY. j i j { ( (SE E APPENhiX B, FQLLOWINC).
~~s 191.lts As--JAT*~ RFCDIREMENTS~~
'jDISPOSA SHAtt BE CONDUCTED 1 ACCORDANCE SAME REQUlijEMENT, EXCEPT }HESE PROVISIONS DO NOT} APPLY 10FACIL'TIESREGULATEDBYNRC (SEE j ' CITH THE FOLLO(ING PROVIS10MS I INSTEAD 10.CrR PART S0). I i l i ^ t i l (DELETED) PELETIO RECOMMENDED. ! l ', - WASTES SHALL BE DISPOSED OF PROMPTLY j ,t t i I I i i l j i
f. p 10 April 1985 Page 9 FECERAL REGISTER NOTICE,29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 198fi (NUCLEAR WASTE POLICY ACT '0F i l19823 -- DISPOSAL SYSTEMS SHALL BE; SELECTED AND (DELETED) USE OF ALARA CONCEPT RECOMMENDED l i f, S.OLELY FOR CONSIDERATION OF THE ~ DESIGNEDTOKEEPRELEASESfTOTHEACCESSISLE + ENVIRONMENT AS SMALL AS REASONABLY ACHIEV-GEOLOGIC CHARACTERISTICS OF t i i j 1 ABLE-l ( } SITES. l l I I l l 1 I i 1 1 1 l l } l '. t - DISPOSAL SYSTEMS SHALL USE SEVERAL DIFFERENT SAME, EXCEPT LAST REQUIREMENT ON DESIGN OF RECOMMENDED USE OF MULTIPLE BAR-4 l s-t r i s t o TYPES OF BARRIEN,70 ISOLATE THE ASTES FROM EACHSEPARATEBARRIERHA{BEENDELETED. f!ERSBEREVISEDTOGIIEMORE THE ACCESSIBLE EMYIRONMEN". BOTH ENGINEERED (SEE APPENDIX B, FOLLOWillG). EMPHASlyTOTH SYSTEMfASA 1 WHOLE; SARRIERS SHOULDf BE DE-AND MATURAL, BARRIERS SHA!J. BE INCLUDED. EACH t ,,1 i i i SU31 BARRIER SHALL BE DES}GNED SEPARATEL" TO { f!GNED$0THATfHEYCOMPLEMENTj EACH OTHER AND ELP TO{COMPENSA PROVIDE SUSSTANTIAL ISOLA'10N. N l FOR UNEXPECTED FAILURES. "I I J l } l l l -DISPOSALSYSTEMSSHALLNOJRELYONACT!YE ACTIVEINSJITUTIONALCONTROLSSHOULDBEMAIN-RECOMMENDEDATIMELIMlTOF1E I INSTITUTICEAL CON OLS BE"0ND A REASONABLE TAINED FOR AS LON A PERIOD OF TIME AS IS YEARS AND THAT UITABL{SUR-PERIOD OF 'i!E,E.G. A FEW HUNDRED YEARS. R OMABLE AFTER DISPOSALJ CREDIT FORSUyH _ VEILLANCE DE REQUIRED DURING THAI ION OF WASTES SHALL NOT PERIOD. C0qTROLSFpRISO BE TAKEN FOR MORE HAN l @ YEARS AFTER D:.SPOSAL. i i (SEEAPPENylXB, LLOWING). i i t DIS-DISPOSALSJSTEMSSHALLBEMONIT0yDAFTEl
~~MENTAL POSAL TO DETECT Ay SUBSTANTIAL yD DETR:~~
ERFOR E. TH :S DEVIATIONS FROMEfECTED MONITORING SHALL BE DONE HITH TE NIQUES THAT THE ISOLATION OF THE STES TJEO{ARDIZE DO IMPLEMENTING ANgSHALLSECONDUCTEDUNJILTHE SIGN ;FICANT AGENCYDET{RMINESTHATTHfREARE CONCERNS TO BE ADQRESSED HY FURTHER MONI'r0 RING. e l i i l 1 1 i
O O O 10 April 1985 Page 10 FEDERAL REGISTER NOTICE, 29 DEC.1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCi.,ffi. REPORT,JAN. 1984 fNUCLEARWASTEPOLICYACTOF l19823 - D:!*0 SAL SYSTEMS SHALL BE IDENTIFIED BY THE SAME, EXCEPT OTHER PASSIVE INSTITUTIONAL, BROADENING OF THE DEFINITION OF MOST PERMANENT MARKERS AND RECORDS PRACTI-CONTROLS ARE ADDED. 1 j PASSIVE INSTITUTIONAL CONTROLS; I RECOMMENDED BY THE ASSURANCE CABLETOINDICATEJHEDANGERSOFJHEWASTES itEQUIREMENTS SUSGROUP. ! I I AMD, THEIR LOCATION, l' l l I l l 1 1 l i i - DISFOSAL SYSTEMS SHALL NOT BE LOCATED PLACES WHERE THEREiHAS BEEN MININ6 FOR RE- {0NSIDERAT10NOFAPOTENTIAL 'l l t WHERETHEREjHASBEENMININGFORRESOURCES SOURCES, Oq WHERE JHERE IS A REASONABLE ElX-EPOSITORY SITE SHOULD NOT BE 9 ORJHEREISAREASONABLEEXPECTATf0NOF PRECLUDED BECAUSE NATURAL RESOUR-1 PECJATION OF EXPLORATION FOR RESOURCES.. i j SH0yLDBEqVOIDED.RESOURCESTOBECONSIDERED CESARElATORN{ARASITE,BUTl l t e i OF XPLORATION FOR RESOURCES, ETC, l INCLUDE (AMONGOTHERS)GROUNDWATERSTHATjARE RATHER,THEIRPRESENCEjSHOULD BE I EITHER 1RREPLACEABLE....OR ARE VITAL TO T'HE "AKEN AS A HIGHLY UNFAVORABLE i i i I i PRESERVATIONOFUNlQUEANESENSITIVEECOSYSTEMS. FACTOR.. N i I I I I l 1 ASSURANCE REQUIREMENT ON RE-f REQUIREMENT.f l -DIS {0SALSY,STEMSSHALLBESELECTEpSOTgT S 7RIEVABILITY OF WASTE SHOULD Bk l REMOVAL OF MOST OF THE WASTES IS NOT PRE-DELETED.l, f I I l it CLUDED FOR A REASONABLE PERIOD OF TIME AFTkRDISPOSAL. l i ~ i
~~s 191.15 PROCFDURAL REQUIREMENTS APPINDIX B - GUIDAldCF FOR IMPLEMEllTATION OF i~~
t i i I 6 i (PROCED L REQUIREMEN S ARE SPECIFIED, APPL - SUBPART B (PROCEDURA REQUIREMENTSARESPEClFIEDASGUID-CABLETOPERFORMANCEASSESSMEqTSTODETERMINE ANCJNOTASANINT{GRALPyTOF CFRPyT191. i '" COMPLIAfE WITy THE CONTAINMENT REQUIREMENTS 0F s 191.13, AB0vE.) IMPpEMENT! O D BY ThiS GUIDANCE.)qGAGENCIESARENOTBUN ~~ j l 4 THIfGUIDAyEINDI{ATESEP,AINTENJREGARDING ISE WHEN IMPLE ENTING CERJAINISSUESTHAJMAYA}1 ^ ss 191.13 AND 191.15 (NEW. SOME APPLIES.ONLY I l f I m. TO DISPOSAL,IN MINED GEOLOGIC REPOSITORIES AND ; 4 i i 6 g l i WOULD BE INAPPROPRIATE FOR OTHER TYPES OF SYSTEMS.
10 April 1985 Page 11 FEDERAL REGISTER MOTICE, 29 DEC.1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 l (NUCt' EAR WASTE POLL'CY ACT OF '~ j (19823 : . - ASSESSMENTS SHALL CONSIDEq REALISTIC PRO-GUIDANCE SAME, PLUS EXCEPTION FOR' PORTIONS OF I JECTIONS OF THE PROTECTION PROVIDED BY SYSTEMTHATMAKENEGLIGIBLECONTRIBUTION%TO i f { ALL OF THE ENGINEERED AND NATURAL! BARRIERS OVERALL ISQLATION PROVIDED BY THE, DISPOSAL i OF A. DISPOSAL SYSTEM. SYSTEM. I .t i i I I I i I - ASSE. SSMENTS SHALL NOT ASSUE THAT ACTIVE: IMPLEMENTING AGENCY WILL ASSUME THAT NONE,OF RECOMMENDED A TIME LIMIT OF 100 JEARSFORACTIVEINSTITU i i r i ENT INSTITUTiOMAL CONTROLS CAN PREVENT OR THE. ACTIVE; INSTITUTIONAL CONTROLS CAN PR CONTROLS'. REDUCE RELEASES TO:THE ACC,ESSIBLE ENVIRON-ORREDUCERADIONUCLIDEREL,EASESFORMORE{THAN i i NENTBEYONQAREASCNABLEPERIOD,{.G., 100,,YEARSAFTERDIPOSAL.THEFED{RALGOVERN- { A FEW HUNDRED YEARS. IT SHOULD BE ASSUMED MENT IS C009t!TTED JO RETAINING OWNERSHIP 'OF THEfFEDEGOVERNMENT WI RETA! ALLDISPOSALSITESAMDWILESTABplSHAPPRO-PASSIVE INSTITUTIONAL CONTROL OF DISPOSAL PRIATE MARKERS ANDg RECORDS. EPA BELIEVES SUCH SITES IN PERPETUIT7. SUCh PASSIVE INST!- MARKERS,RECORDSANDOTHEqPASSIVEINSTIT,U-TUTf0NALCONTROLS SHOULD fE ASSUED TO T!ONAL CONTROLS S ULD BE EFFECTI'/E IN ER-INADVE}TENTHUMANIN-ING{EXPLOITATIONO{THESEflSPOSAI SITES) AND E OF KEE{THEC f TRUSION VERY SMALL AS LON AS THE FEDERAt. THATTHEYCANStBSJANTIA YREDUC{THECHANCE GOVERNMENT RETAINS SUCH P SSIVE CONTROL OF INADVERTENT HUMAN INTRtJSIOM; EfA BELIE 3/ES OVER DISPOSAL SITE ls.(SEE 191.14!,ABOVE). THA{PASSIVEINST!JUTIONA CONTRO S CA T BE ASSfDTOCOMPLET{LYELI]!NATET{ECHAN OF HUMANINTRUSIONINTOTHESqDISPOSALSITES'. t i f i - ASSESSENTS SHALL USE INFORMATION,ABOUT INADVERTENT INTRUSION BY EXPLORATORY DRIt, LING INTR ION AND ALL FOR RESOURCES (OTH R THAN HOSEIhTHEDISPOSAL LIKfLIHOODOFHUMA SYSTEM) SHQULD BE HE MOST SEVERE INTRUSI,0N OTHERUMPLAhMEDEVENTSTgTMAYCAUSE NT SENARIO TO,BE CONS IDERED qY IMPLEMENTING AGENCIEl s.- RELEASESTOTHEACfESSIBLqENVIR AGENCY IMP MENT!yAGENC.lES SHOULD ASSUME PASSIVE '} AS fTERMINED BY THE IMPLEMENTING FOR; EACH Dl_SPOSAL :stTE. INSJITUTIONALCONTROLSORTHEINTRUDERS',0WN f EXPLORATORYPROCEDh.ESSUFFICETOINFORM,INTRU-I k l l l DERS OF THE INCOMPATIBILITY OF THE AREA WITH l .i l THEIR ACTIVITIES. l l f
,a J 10 Aprit 1985 Page 12 FELERAL REGISTER NOTICE, 29 DEC.1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 [ NUCLEAR WASTE FOLICY ACT OF 1982] IMPLEMENTING AGENCIES SHOULD CONSIDER THE LIKEllH00D AND CONSEQUENCES OF INADVERTENT EX-f PLORATORY DRILLING. THEL {KELIHOODOFSUCHIN-ADVERTENT DRILLING SH3ULD NOT BE ASSUMEDjTO BE l l l 4 i > 30 BOREHOLES/KM OF REPOSITORY AREA PER 10 i I i l i YEARSFORREPOSITORIESIN,PROXIMITYToSEglMEN-l l l l l 9 TARY ROCK F,ORMATIONS; OR !, 3 BOREHOLES/KM, FOR l [ i i i REPOSITORIES IN OTHER GEOLOGIC FORMATION $. THE f l 9 l CONSEQUENCES OF SUCH INADyERTENT DRILLING j SHOULD NOT;BE ASSUMED TO BE MORE, SEVERE THAN: l - DIRECT RELEASE TO THE LAND SURF, ACE OF ALL { { [ THEGROUNDWATEqINTHEREPOSITORYHOR{ZONTHAT { l ChulD PROMPTLY FLOW INTO THE NEWLY CREATED OFfROUND 3 kOREHOLE OR 200 M TER, WHICHEVER i IS GREATER; AND i 1 1 i t 1 ( - CREATION}OF A GROUND WAJER FLON 'l j j PATH W TH A PERMEABl(ITYTYICALOFABORHOLEFILL{DBY j l SOILORG,RAVELTHATWOULDNORMALLYSET}LEINTO i AN OPEN HOLE OVER TIME,,;NOT THE' PERMEABILITY j 3 i i j } j OF A CAREFULLY SEALED BOREHOLE i c,. i j, j r i 1 IMPLEMENTING AGENCIES ARE:lREE T DEVELOP LESS i t e I l t i i l SEVERE ASSUMPTIONS THAN THE ABOV, AS APPROPRIATE ~,e TO THE PARTICULAR DISPOSA SYSTE i j I J l l I (SCOPE OF PERFORMANCE ASSESSMENTS AS BEQUIRED l I l I l l l i 5 191,J:12.) l l l BY)5 191.13' AND DEFINED IN i i SUCH PERFORMANCE $.SSESSMENTS NEED NOT CONSIDER l l I I { l CATEGORIES;0F EVEt(TS OR PROCESSES THAT ARE ESTl] j i NATED TO HAVE < 1 CHANCE IN 10,000 0F OCCURRING! ) [ [ OVER 10 YEARS. ALSO, EVENTS AND' PROCESSES MAY ! I i 4
,/, .j 10 April 1985 Page 13 FELERAL REGISTER NOTICE, 29 CEC. 1982 EPA h0RKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 (huCLEAR WASTE POLICY ACT OF BE OMITTED FROM THE PERFORMANCE ASSESSMENTS IF ;19823 THE REMAINING PROBABILITY DISTRIBUTION OF CUMU-LATIVE RELEASES WOULD NOT BE SIGNIFICANTLY CHANGED. } } l (COMPLI ANCE WITH s.191.13.) WHENEVER PRACTICABLE, IMPLEMENTING AGENCY SHOULD ASSEMBLE AS RESULTS OF PESFORMANCf ASSESqMENTS l l 3 INTO A " COMPLEMENTARY CUMULATIVE DISTRIBUTION FUNCTION" THAT INDICATES THE PROBABILITY OF i EXCEEDINGYARIOUSLEVELSqFCUMUyTIVERELEASE. WHEN UNCERTAINTIES INPARAMETERSfRECONSIDEREDIN l l } t A PERFORMANCE ASSESSMENT, iTHE EFFECTS OF :THE UN-{' 4 1 I i l l i i CERTAINTIES CAN BE. INCORPORATED INTO A SINGLE SUCH i i i I I I i UlSTRIBUTION FUNCTION FOR;EACH DISPOSAL SYSTEM l l l i i i i i CONSIDERED, EPA CONSIDERS A DISPOSAL SYSTEM MAYl l l i i i t i BE CONSIDERED TO BE IN COMPLIANCE IF THIS SINGLE i i i i l l DISTRIBUTION FUNCTION MEE}S THE REQUIREMENTS OF s191.13.l' l ~ i i t (CCt<PLIANCE WITH s' 191.15 (NEW)). 1 WHENTHEUNCERTAINTIESINlUNDISTURBEDPERFORMANCE I a 3 i l 1 1 OFADISPOSALSYSTEMARECONSIDER.ED,IMPhEMENTING l j i i l AGENCIES NEED NOT REOUIRE A VERY 1ARGE PERCENTAGE j i l I f j j OF THE RANGE OF ESTIMATED l RADIONUCLIDES F} ALL BELDW i i 4 l i + + i l THE'LIMITSIESTABLISHEDINl5191.15. EPA SELIEVES; j t COMPLIANCE {MAYBE ASED UPON THE BEST E T! MATE" l PREDICTIONS (E.G.,,THE MEAN OR THE MEDIAN OF THE j l l 1 i, i i I l { l APPf0PRIATE DISTRIBUTION, WHICHEVER IS HIGHER). i l i t j t 4 l t k
10 April 1985 Page 14 FECERAL FEGISTER NOTit.E, 29 CEC.1982 EPA WORKING DRAFT NO. 5, 21.' ARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 (NUCLEAR WASTE POLICY ACT OF s 191.15 CROU'4D WATER PROTECTION REQUIREMENTS 19821 (hCT IN OnlGINAL NOTICE) - DISPOSAL SYSTEMS SHALL BE DESIGNED TO PROVIDE RECOMMENDATION THAT FOR FIRST SW THAT, FOR FIRST 1000 YEARS AFTER DISPOSAL, UN-.THE STANDARD EMBODY AN EXTREMELY DISTURBED PERFORMANCE OF THE DISPOSAL SYSTEM LOW LIKEllH00D THAT INCREASES IN SHALL NOT CAUSE AVERAGE ANNUAL RADIONUCLIDE RADIOACTIVE CONTENT IN POTABLE CONCENTRATIONS WITHIN ANY SIGNIFICANT SOURCE WELL WATER APPROACH PRESENT EPA 0F GROUND WATER OUTSIDE THE CONTROLLED AREA DRINKING WATER' LIMITS. TO EXCEED: l l - 5 PCI/L OF RA-226 AND RA-228; i -15PC1/tOFa-EMITTERS (INCLUDINGRAp226 j l l , AND RA-228); oR j i -COMBINEDSY-EMITTERSTHATWOLDPRODpCE l l MNUAL. DOSE EQUIVALENT TO WB,0R ANY INTERNAh j ORGAN > 4 MREM /YR IF AN INDIVIDUAL CONTINU- , OUSLY CONSUMED 2 L/ DAY OF DRINKING WATER f i ~ {FROMSUCHASOURCEOFGROUNDWATER. I l l I - DISPOSAL SYSTEMS SHALL AL 0 BE D SIGNED 0 THAT, i F0a 1000 YEARS AFTER DISPOSAL, UNDISTURBED PER-I ,F0$".ANCE OF THE DISPOSAL pYSTEM SHALL NOT CAUSE ~ j THE AVERAGf ANNUAL RADION;JCLIDE CONCENTRATIONS i IN WATER WITHDRAWN FROM ANY PORTION OF A SPECIAL i l I e j SOURCEOFGROUNDWATERTO. EXCEED!THECONCENTRA-} TIONS IN 5 191.15 (AS GIVEN ABOVE). l i t t j i t j -IF;ANYOFTHEAVEqAGEANNUALRADIONUCLID{CONCEb-TRATIONS IN WATERS CONSIDERED ABOVE ALREADY l j f EXCEED THE ABOVE LIMITS BEFORE CONSTRUCTION OF I { i THE DISPOSAL SYSTEM, THE DISPOSAL SYSTEM SHALL i BE DESIGNED TO PP.QVIDE A REASONABLE EXPECTATION l i THAT, FOR 1000 FEARS AFTER DISPOSAL, UNDISTURBED
___= _ ) 10 ApriI 1985 Page 15 FEDERAL REGISTER h0TICE, 29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT, JAN.1984 (NUCLEAR WASTE POLICY ACT'OF PERFORMANCE OF THE DISPOSAL SYSTEM SHALL NOT I 19823. INCREASE THOSE AVERAGE ANNUAL RADIONUCLIDE CON-; l CENTRATIONS BY MORE THAM 10% OF THE CONCENTRA-i t i TIONS EXISTING BEFORE DISPOSAL SYSTEM CONSTRUC-1 i l 1 TION. HOWEVER, IF;THE 10% POTENTIAL INCREASE l l i WILL EXCEED THE ABOVE NUMERICAL LIMITS, THE l [ j INCREASESHALLBELIMITED,TOTHEVALUEOfTHE l I I NUMERICAL LIMITS.; l l l 5 l l '5 191.16 ALTERhATIVE PROVISIONS FOR bfSPOSA1 OF FYISTING HIGH-t_EVF AND TRANStRANIC RADIQLCTIVE MASTES i l i ,/ i j { j
~~(NOT Im ORIGINAL NOTICE)~~
~~- THE ADMINISTRATOR jMAY BY fulE SUjSTITUTE ALTERNJ I Tl PROVISIONS F DISPOSAL OF LPECIFIC WASTES { i I THAT: l - EXIST ON THE EFFECTIVE DATE OF THIS SUBPARTj l t i i l l .)l [ I l k~~
~~HAVE BEEN STORED IN SUCH A MANNER THAT RE-~~
} t e t i j 6 i j TRIEVAL AND RELOCATION OF T WASTES WOULD f l BE UNUSUALLY DIFFICULT OR WOULD PRESENT SUB-e i e i t i i g STANTIAL RISK $ TO HUMAN HEALTH AND T1E EM-u, 3 j j i l VIRONENT; AND -dl l -CANBkISOLATEDFROM HEENVjRONMENTlSOTHAT I f f t I l THE RISKS WOULD BE MORE TNAN RISKS FROM l 4 a i ~_- t RETRIEVALAND;RELOACTIONTOjDISPOSALSYS-l ~ TEM MEETING SUBPART B; REQUIREMENTS. i i i l .i il -TH{ADMINISTRATORjSHALLPf0MULGATESUCHALTERNA" Tl PROVISIONS ONLY AFT : - DOE HAS PROVIDED EPA HITH INFORMATION ON j COSTS,, RISKS, BENEFITS OF DI$POSAL LEdDER THE i i t l t i i t st i i ALTERNATIVE PROVISIONS AND REASONS WHY 6 j I ? e i 1 l 3 -9 + l ( l SUBPART B PROYISIONS WOULD BE IMPRACTICAL; 1 i + ALTERNATIVE PROVISIONS HAVE SEEN PROPOSED j j l .a y j j y I I i FOR PtBLIC COM9ENT IN THE FEDERAL REGISTER; i 6 i
.. ~ _. ~ _. ~ - --.. - - - -- -~. _.- 10 April 1 45 Page 16 FEDERAI. REGISTER NOTICE, 29 DEC. 1982 EPA NORKING DRAFT NO. 5, 21 nARCH 1985 EPA SAB SuBCOM. REPORT,JAN.1984 (NUCLEAR NASTE POLICY ACT OF - A PLSLIC ColWEENT PERIOD OF AT LEAST 90 i1982] 4 , DAYS HAS BEEN COMPLETED, INCLUDING OPPOR-i i 6 ' TUNITY FOR PuBLIC HEARINGS; AND - PUBLIC C009 TENTS RECEIVED HAVE BEEN FULLY r i l t } l CONSIDERED IN DEVELOPING THE, FINAL VERSION i j j i i ! I OFTHE$ALTERN$TIVEPROVISIONS. j 4 4 i i t i r l l I j l l l 4 5 141.17 EFFECTIVE MTE l f j ]5141.16 EFFECTIVE DATE l EFFECTtvE If9ENATELY UPON PROMULGATION OF f EFFECTIVE WITHIN E DAYS kFTER PLSLICATifM6 IN RULE. FEDERALREIISTER. l 1 i f ? ..k I ?APPF':nf Y. Tam!r I f APPENDIX 5 l' 1 l l f l 1 l CONCENTRATIONS IDENTIFY!IBG HIGH-LEVEL g(DELETED) i RADIDACTIVE WASTES i i I APPENDIX, TABLE 2, RELEASE LIMITS FOR CON-APPENDIX A, TABLE 1, RELEASE LIMITS FOR CON-([1}1n00 M #0 !ll TAIMBEE T armatbMEETS (Ct/Ini 1 MTISD TAingEENT DFmaIItf MTS AMERIClun-241 OR 2243 I 300 RECOMME D FA TOR OF 10 INCREA!E AstRICiun-241' 10 A8tRIClun-243 [4 IN TABLH VALUES. )00 14 2g0 CAsp0N-14 CEstun-135 20q0 CE41un-135 OR -137 1000 ' < CESIUn-137 500 { 100INE-129, J00 j siEPTuMIun-237 p NETUNIUn-f37 f 400 PLuTONIun-238, -239, -240., OR -242 100 ^jPtuTONIun-238 i 5 PLUTON!un-239 l 100 PLUTOstUn-28@ 1@ 1('O t i ^fPLUT0ellu,-242 I l I I ".RADlun-226 j
~~3 RADlun-226, j~~
100 g j 30 STRoNTIuh-90 l j 100 ' STRONTrun-90 l TEdHNETlun-99 i j j 10000 l I. ITECHNETIun-99 i 10 M l i i___._.,. -
O O bo 11 April 1985 Page 17. FEDERAL REGISTER NOTICE, 29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 (NUCLEAR WASTE POLICY ACT'0F ', Aper e fX,T m F 2(CONT *D) (CI/lD00 ElfD' APPFMDIY A.T m F 1(ComT'Dh (C1/1000 MD80 i 19823 i I i THORIUM-230 OR -232 10 i TI 3-126 E TIN-126 l IM l I t URAN!uM-233,-234,i -235, a236 OR.-238 100 i [ANY OTHER a-EMITTER j ANk OTHER #-EMITTER, Tg > 20 YRS.! 100 l i
~~lANYOTHERNON-*-EMITTER Sm ANY OTl!ER p0N-4-EPlITTER,Tg > 20 YRS. 1@0 f~~
~~I. i i*!APPFuniv. MOTE ~l 1 i APPFhDIY A. NOTE 1 I j I I l l l I~~
~~RELEASELIMITS;INTABLE2 APP [YTo:~~
REthASE LittlTS IN TABLE 1 APPLY}O: RECOMMEpDASUI,TABLEEQUIVALEqCY f -AMOUNTOFpiGH-LEVELMASTlESGENEEATED - Jyq0UNT Of SPENT NUCLEAR, FUEL CONTAININp gTOTHEfTHMCOqCEPT(SfHASQNE "l FROM 1. E MTHM, p 3,M MTHM, BURDUP BETWEEN 25 M AND 40,@0 jBASED Of NUPSEq OF FISSIONS) qE y T OF [RU WASTES CONTp!NING 10 Cl yn/MTHM) l 6 ESTABLIEHED F DEFENSEWASTE}, g AND FOR SOME KINDS OF COMMERCTAL OF a-EMITTING TRAISURANICE. TOfHIGH-VELWAfTESGEqERATED{ ROM j },000 MTP, bur 90P BETWEEN 25,[00 AND 40,000 WASTES. "i l pD/MTHM; 9 C1 cF v On 8-EMITTERS, 20 YRS'<T <10( I - EACH 10 i i t 6 I i I % YRS., l l IDENTIFIfDBY C AS HIfLEVEg{ RADI0 ACTIVE W STEJ 6 l qACH10 Cl0FqTHERR IONUCLIDES (Y-OR ( j-EMITTEfS,Tg}100 YRS.; ora'-EMITTEfS,Tg>20 YRS) IDENTIFIED BY NqC AS HIf-LEVEg RADIDACTIVE WASTEJ OR 6 y T of TRU q STES C091TAININg 10 Cl 0F a-EpilTTING TRANSURAMICS, Ty > 20 YltS. APpFunIY A. MOTE 2 [ t l QUANTITIES IN TABLE 2[SHALL BE ADJUSTED TO SAFEREQUlfEENT. DE RELEASE LIMITS FOR A SPECIFIC DISPOSAL SYSTEM ( LESGIV{N). I s hi i 'P i [ l l l i, l, i t 4 i i i 1
) i s 11 April ,J5 Page 18 FEDERAL REGISTER NOTICE, 29 DEC. 1982 EPA WORKING DRAFT NO. 5, 21 MARCH 1985 EPA SAB SUBCOMM. REPORT,JAN. 1984 (NUCLEAR WASTE POLICY ACT OF APPENDIX, NOTE l (CONT'D) APPFMDIX A. NOTE 3 1982] FOR REACTOR FUELS EXPOSED TO BURNUPS OF l < 25,000 MND/MTHM,' OR > 40,000 MHD/MTHM,! UNITS OFWASTEDEFINEDINNOTE1,(FIRSTTWOUNJTS) i i f. f l F i I SHALL BE ADJUSTED: 1 t { { .lF BURNUP KNOWy, THEN: l i i i . ADJUSTED UNIT 3 I l(FUEL'Sl ACTUAL BURNUP,fD/MTHN) I l I l l l jlFBURNUPNOTkNOWN,THEN: i l l I J i .it j s j (NOTE l MIT)(i.5 X 10g Ci) l j i t i i ..l l l { ADJUSTEpUNIT*TTOTALfR-90AiDCS-137INWANTE I, t OR SPENT FUEL.- 10 YRf. AFTEF i ,, { { f I l DISCHARGEFR0qREACTOR) i i l N APPFMDIX A. NOTF 4 t F HIGH-LEVEL WA TE STRE p THA} HAVE BEEN SEPARATED f STINED OR DIFFERENT D SPOSAL SYS-INTOCOMPpMTS TEMS, OR MO LONGER ASSOCIATED WITH THE QUANTITY!AND i' 'i I t i 6 EXPOSUREOfTHEOqlGINALfEACTORFUEL,FfRSTTWg AND LAST TWO UNITS UNITSOFMpTE1AqENOTRpLEVANTg l } OF MOTE 1 HALL B USED. 1 I t 'l l l2 APPFMDIX A'. NOTE 5 l lAPPFMDIX. h0 IE: r i t !IF A MIXTURE OF RADIONUCLIDES,.IS PROJECTED SAME REQulREMENT, ENCOMPAiSING TABLE 1 AND I T3 BE RELEASED THE LIMITING ALUE WILL j NOTES 1THpOUGH4. ll BE DETERMINED 5 FOLLOWS: FOR EACft RADIO-MUCLI INTHEjMIXTURE,DETE INE T RATIO j ' ; BETWEEN THE CtJMULATIVE RELEASE QUANTITY OVER, l t s i s + ',10 YEARS AND THE TABLE 2 AND MOTE 1 LIMIT. THE l I j y I I ! Sun OF Att SuCu RATIOS MAY NOT EXCEED 1. l I f 3 t in u-
u O objectives in High-Level Wastes / Spent Fuel Disposal by F. E. Culler R. J. Catlin R. F. Williams paper for presentation at the Twenty-First Annual Meeting of NCRP i 4 l April 3-4, 1985 i Washington, D.C. I l i ) I l Electric Power Research Institute 3412 Hillview Avenue l Palo Alto, California 94303 i !O i
Objectives of High-Level Wastes / Spent Fuel Disposal F. L. Culler, R. J.
~~Catlin, R.~~
F. Williams l Introd uction l l l i My purpose today is to review the objectives of the disposal of high-level radioactive wastes and spent reactor fuel elements, and, in the light of recent experience, suggest some potential areas where we can improve the process of implementation. l To a considerable extent, the challenge we face is much like that, of the highway engineer who must devisc a way to keep traf fic moving on an expressway while performing major construction on l e the road. For the highway engineer it is sometimes possible to l set up a detour, sozthat traf fic can be" routed around the area of construction. Betours generally produce delay. In the case of ~ ~ the high-level wsste disposal program, a detour into more s. . studies, legislative review, or a search for new concepts is not need ed or appropriath.. We have, thr ough a painful but deliberate process over the past thirty yAars, d eveloped the technology, a regulatory structure, ano a lengthy process for public and agency l participation to build' repositories for high-level waste. There l t is much that we can do to improve the structure as we proceed l down the path of. program implementation. ' O I 1 l u 4 - - " - - ~ - - - -,, v
( Objectives In defining the objectives of high-level waste disposal, four functional areas of interest must be addressed : o Safety - the establishment of goals, standard s and criteria for the protection of health and safety. o Technology - the identification, development, and selection of a technology from a spectrum of choices. Regulation - the acquisition of scientific and o experimental evidence to specify the level and to () demonstrate the ef fectiveness of the technology to meet the criteria for safe permanent disposal. l o Process - the implementation of the selected technology within an agreed-upon framework that defines the responsibilities of the involved parties within the l l society, the process by which they interact, and the time frame for such action. The objectives of high-level waste / spent fuel disposal are njgt stated with varying emphasis and level of complexity, depending on how explicitly the underlying requirements are stated. t O 2
=. For example, such objectives may be presented in the form of primary and secondary functional goals. Table 1 presents one such summary in a form which highlights some of the present issues in implementation. An alternate approach would be to define the objectives in terms of progressive activities and operations, such as: " Site, design, license, construct, operate, and close a repository for the safe permanent disposal l of radioactive waste." A more complex statement making visible more of the implicit budgetary and institutional requirements would be: Os " Site, d e sign, license, construct, operate, and close a repository for the safe permanent disposal of radioactive waste, at a reasonable or acceptable cost, and within a process affording reasonable opportunity for participation and i comment by interested or involved individuals, organizations and governmental entities." l An even more complex approach escapes presentation in a single paragraph or paragraphs. The objectives are expressed in terms of "34 sources of goals" which specify a mixture of activity () requirements in three time frames of interest, as shown in Table 3
. _ ~ 2. This table, taken from NUREG-0300E13, is an example of a very (} complete and explicit spectrum of actions. In this formulation, the conflicts between certain factors and the need for tradeof fs is evident. 1 From the previous discussion of objectives several observations l can be made. If the overall objectives are stated only in a complete and theoretical sense, it will be dif ficult to appreciate the degree to which the objectives in the real world have been modified over the past 30 yaars, particularly by choices and decisions in the technical, regulatory, and political arenas. () The major area of progress in the past several years has been to resolve some of the conflicts in goals by reduction in the number of technology options, by further embellishment of the regulatory process and by establishment of a complex procedural approach to institutional interaction. Given the confusion and overlap between objectives, goals, parameters, functions and responsibilities, it is not surprising that the primary objective of establishing an adequate and appropriate level of safety may be seemingly ignored. Resolution of Goals
~~O Let us briefly highlight some of the tradeof fs in goals which 4~~
= -. -.
have been made during the past several years. The technological base has changed little since the late 1960's when most technical options an$ failure modes were understood and reasonably eval uat ed. The analytic capabilities have undergone extensive expansion ard improvements, however. Some new experimental data have been added. Changes and additions have occurred, hopefully to satisfy the greater public concern about nuclear wastes by the regulatory process. For examples o The selection of mined geologic repositories over other options, such as deep space disposal, or burial under the polar ice caps, accomplished by the GEIS for Commercial High Level Waste Disposal [2], was a major (] programmatic technical decision. However, this U selection should not foreclose research on other options of excellence, o The issuance by EPA of its environmental standard s for the management an$ disposal of spent nuclear fuel, high-level and transuranic radioactive wastes is a key element in the definition of regulatory requirements. It is now in draft form for public comment [33 The definition by NRC of the procedural requirements for repository licensing and the technical criteria for HLW disposalE43 are also part of the procedures and published in final. lO s L
The Nuclear Waste Policy Act[5] established the major o procedural elements for the institutional process by which the repositories are to be licensed, built and monitored. Tasks and sched ules have been established i that are heavily weighted for additional development and multiple levels of proof. Thus, I would propose the following concise statement of waste disposal objectives, in light of the mixture of safety goals, technology, political process and the licensing and regulatory processes: "Try to build and operate a geologic repository by 1998 under the schedule, cost, and procedural ( requirements of the NWPA, meeting the safety, proc ed ural, regulatory, and technical requirements of the EPA, the NRC, the DOE, the DOT (and 20 or so other federal, state, and local agencies)." l Because of the series of tradeoffs and compromises, a real question of feasibility remains. To use the phrase coined by Fred Singer in an informal talk at EPRI, Can the schedule and mandate of the NWPA be met, or do the process, proced ures, and milestones constitute " pre-programmed grid -lock"? !O 6
Singer's question is certainly justified, because the approval i I \\/ mechanism enacted in Sections 114 and 115 of the Nuclear Waste Policy Act provides a Catch 22 for the actual location of a repository site some 5-10 years from now. Some of the elements that set the catch ares o The approval structure for site selection, with two major feedback loops, as shown in Figure 1[6] that provides the potential for successive delays. o Overlapping review and approval authorities of the Pres id e nt, the Congress, Federal and State agencies, Governors, local governments and Indian tribes. ,o 1 (',) l Further, there is an increasing overlap among the several responsible Federal agencies involved in high-level waste disposal. It should be noted that the regulatory agencies operate almost as a fourth branch of the Government, one not %r contemplated by or subject to the Constitution, each with its own rules, compliance (trial) processes, decision-making, and enforcement actions and penalties. e I y t Also, the courts have to a degree become extensions of the regulatory arm by ruling more frequently on issues of substantive technical judgment rather than of legal merit. The extent to which such actions may constitute a legal grid-lock in high-level [G waste disposal is yet conjectural. 7
i A very real potential exists for grid-lock. However, a number of specific steps can be taken that might help to avoid paralysis, and some which might improve the present process. A few specific 4 suggestions related to the topic of regulatory criteria and radiation protection are of fered. Improving the Regulatory Process d uring the Preparation Period Prior to 1998. A major fraction of the expen$itures in a $25 to $35 billion E73 is directed to collecting dollar waste management program sufficient data for repository performance assessment, and to () demonstrate compliance with regulatory criteria. Perhaps 20 to 30% of the program expend itures relate directly, and another 30 to 40% of the program expenditures indirectly to the process of demonstrating regulatory compliance with ad equate or reasonable assurance. In on$ er to simplify the selection, nomination and licensing of 1 the initial repositories, we should ask: does the process, the design, or the criteria need modification? If so, can the change be made without major detrimental side ef fects? There are topics i or areas in the regulatory process and the implementation of radiation protection criteria which of fer the possibility for simp 11 fication, cost containment and other improvements, and d eserve review. The topic is too broad to be treated 8
comprehensively in this paper, but let us consider a few examples: o Societal goals and radiological health protection criteria. o Numerical standard s and redundancy requirements for engineered barriers. o Treatment of uncertainty in performance evaluation. o Use of the collective dose concept. I t O Societal Goals and Radiological Health Protection Criteria l l Societal goals must be established for waste disposal in order to keep potential health detriments to present populations and future generations unlikely to exceed low, acceptable levels of risk. From these goals, secondary standards must be estWblished to define performance criteria and design parameters. Such criteria may be evaluated against analyses of expected behavior of the repository in the geochemical environment, from which l i analyses of future risk may be projected. 1 i EPA, in its proposed ruleE33, enumerated such a societal goal in terms of not more than 1,000 possible additional cancer cases t 9 l
() during the first 10,000 years following closure of a repository in mined geological media, for each 100,000 metric tons of heavy metal (MTHM). As shown in Table 3 taken from the January 1984 report of the High-level Radioactive Waste Disposal Subcommittee of the EPA Science Advisory Board E03, the proposed standard s lead to levels of protection that were considered by the Subcommittee to be much more stringent than levels of protection generally required or adopted in today's society and, moreover, far more stringent than the levels imposed on the disposal of chemical wastes. Even so, EPA now proposes to make its release limits more stringent by reducing the diffusion zone from the wastes to the accessible environment from 10 to 2 kilometers horizontal rad iusE93 ~ O In developing this societal goal, EPA staff gave considered weight to the projected performance of model repositories in various geologic media, as well as to possibly analagous risks to health from unmined uranium ore bodies. In so doing, EPA staff chose not to extrapolate risks to individuals from population health impact projections, contrary to the current practice used by NCRP, ICRP, and proposed in the report of the Waste Isolation Systems Panel of the NAS/NRC[10] to specify goals and standard s i at an individ ual risk level. 1 j Nevertheless, it is illuminating to compare safety goals and standards with experience and expectations of the individual 1 i cancer risks, as shown in Figure 2[1.',123 In terms of annual 10 .. ~ -.
4 l cancer risk to an average individ ual, the EPA high-level radioactive waste disposal limit is shown to be three orders of magnitude below the nuclear power plant limits of 10 CFR Part 50, Appendix I[133, and almost five orders of magnitude below the cancer risk associated with exposure of the U.S. population from natural background radiation. Moreover, the cancer risk from probable performance of waste repositories established in accordance with the draft EPA rule is projected to be several orders of magnitude lower than that derived from the rule, due to conservatisms inherent in regulatory risk assessment and design practices. Such perspectives contributed in large measure to recommendations by () the EPA Subcommittee that the societal objective and the release limits in the EPA draft rule each be relaxed by a factor of 10. I In examining the possible outcomes of regulatory criteria, as set forth in Table 3[83, the preceding discussion shows that although the levels of the EPA draft rule may be taken at face value to i i assure public health and safety, the proposed standards do not appear to have a direct relationship to real levels of potential harm. Nor are the relationships to other hazards or tradeoffs in cost-benefit or cost-effectiveness readily apparent. Consid ering the billions of dollars cost projections for the high-level l radioactive waste disposal programs in the United States, i l together with other multi-billion dollar waste management programs, such as Superfund, placing demand s on the public 11
4 monies, the societal goals and release criteria would appear for review in terms of risk / cost tradeoffs and O candidates I perspective on acceptable levels of risk. J Numerical Standards for Engineered Barriers In the reference models derived by EPA in its draft population risk reportE143, expected health ef fects over the first 10,000 years were compared for salt, granite and basalt for a series of comparable parameters (geochemistry, ground water flow, waste form, canister performance, etc.). For levels of 100 and 1,000 health ef fects (cancers) over 10,000 years, certain minimum engineering -controls were specified in EPA's Draft Regulatory ( Risk Analysis [15] in terms of leach rate and canister life, for the purposes of estimating performance, as shown in Table 4. E43 its minimum Similarly, NRC has specified in 10 CFR Part 60 performance standards for the engineered barriers (as a whole) and for canister life, also given in Table 4. As the comparison shows, application of the more conservative NRC requirements would lead to the expectation of a ten-fold reduction in societal e f fe ct s, i.e., from 1,000 down to 100 cancer in 10,000 years. The difference appears as a good example of one regulatory agency exercising conservatism on the technical specifications of another agency without due consideration of either the necessity 1 or trade-offs of its actions. The example also represents one of l the inputs to regulatory conservatism exercised on the EPA draft ( standard, as indicated in Figure 2. 12
Approach to Treatment of Uncertainty High-level radioactive waste disposal is a probabilistic process, as note 3 previously. It is a process which the scientific and public communities can characterize in absolute certitude as an uncertain endeavor. Yet, the licensing and operation of a nuclear waste repository will require a detailed analysis built upon treatment of uncertainties to provide reasonable assurance of safety, i.e., that Federal performance requirements will be met. Such analysis of expected performance will involve the construction of probability density functions for all important parameters in the waste disposal system.[3,16], 1 Both risk assessment and risk management actions require an l l l intelligent treatment of uncertainty. Uncertainties are real in many parameter of waste disposal systems, involving: o Dose /ef fect models for predicting health ef fects; o Stochastic and non-stochastic dif fusion an3 dispersion properties; i o Lack of perfect data; and Extrapolation from chort-term phenomena to extended-term o behavior of man and his environment.
~~O 13 l~~
1 ---m..
1 In the past, distribution functions for determining probability density f unction (or pd f's) in waste management have, in large measure, been constructed on the basis of expert opinion or mathematical convenience. Popular choices have included normal, log-normal and uniform distributions. Faced with the desire for statistically valid rationales in selecting pdf types, various limiting theorems in probability theory, such as the Central Limit Theorem, have been invoked to justify the choice. But this theorem must be applied with caution because of the great difficulty, generally, in proving that physical situations being modeled satisfy the mathematical prerequisites. When data are sparse, proof of the correctness of a particular type of distribution is difficult, as shown in Figure 3E103 In O this histogram showing the distribution of 1000 samples of the sum of 10 log-normally distributed travel times, the normal distribution (solid line) best fits the histogram, but the log-normal best-fitting distribution would be equally I rea son ab le. In this case, the sum of log-normally distributed travel times approaches a normal distribution, as predicted by the Central Limit Theorem, chiefly because the geologic units were assumed to have identically distributed travel times. If the travel timen differed or the travel time in one layer were to affect the travel time in another, the theorem might not hold. l t Although the Central Limit Theorem does not apply directly to (} give normal distributions When variables are combined in ways i 14 i i
other than by addition, it can be used to show that products do p_ te nd to becona log-normal, as shown in Figure 4[16]. This k) s-histogram shows the result of multiplying four normally distributed variables, each with the same mean and stand ard distribution. The resultant distribution is not normal but very close to log-normal. Thus, under certain circumstances, the Central Limit Theorem predicts that the sum of a large number of random variables will approach a normal distribution, and the pro $uct of a large nunber of random variables will become log-normally distributed. While in many cases these premises will be true, the results will be sensitive to some key parameters and insensitive to others. The identification of pertinent parameters and their distributions is underway, as shown, for example, in Table 5[173 However, one cannot assume a priori that the distribution of combined parameters may autonatically be deduced from the individual pd f ' s. First, the individ ual parameters must be assigned pd f's and the results computed. Then, key parameters must be identified and their pd f's determined with greater precision. Such an approach is needed to ensure that the probability distribution of cumulative releases from. repositories comprising the " complementary cumulative distribution function" of the draft EPA stand ard s is meaningful. I O 15
i s 1 i i I Use of the Collective Dose Concept i Now if safety is the paramount determinant for disposal of high-level radioactive waste, taking the form of a societal limit f for detrimental health ef fects over future generations, the l scientific community must assure that these health ef fects are 1 i proj ected in a meaningful way, particularly at the extremely low i i levels of risk envisaged. I refer to that aspect of collective dose determination commonly characterized as the "minidose/mega-i population" issue. The open literature gives many projections of expected fatal cancerc per year of norraal operati' ns in o 5 populations near facilities that stretch scientific credulity j l for example, rates of projected fatal cancers per year of operation on the order of 10~4 for one facility to 10-13 for from airborne emissions of radio-nuclides[183 Similar
~~another, projections have been integrated in the assessment of performance of high-level radioactive waste repositories.~~
~~Yet, in a recent l l publication by the Nuclear Energy~~
~~AgencyE193, Professor Bo Lind ell, referring to high-level waste repositories in geological i~~
formations where no radioactive material is postulated to reach l l the biosphere for the first 100,000 years, states i i "For such long time periods, estimates of j collective doses are by necessity uncertain and i the result can hardly be used as the basis for l dif ferential cost-benefit analysis. Such analysis i l (:) is ther., ore 3ust not an avai1.,1. methoe,er l l r l 16 l h i i l
's optimization of protection in thoses cases; the O collective dose commitment has ceased to be me aning ful. " Clearly, this is an area where the NCRP can make an important contribution, bearing as it does not only on waste disposal activites but on "de minimis" and ALARA issues as well. Conclusions considering, then, the objectives and current status of the high-level radic at ;ive waste disposal program in the United States, I should like to of fer some observations and conclusions that may prove pertinent to the furtherance of that program. I also suggest that in many of the more important issues an independent body with broad scientific and technical base, such as the National Council on Radiation Protection and Measurements (NCRP), can provide substantial leadership and guidance. Successful disposal of the Nation's high-level radioactive wastes is an absolute necessity, not an achievement to be temporized or foisted off on future generations. The technology, knowledge and skills are at hand. However, a very real danger exists that such disposal may be significantly delayed or may approach a grid-lock ~ unless the system for approval is clarified, and the coordination () of the responsible agencies is improved. We should re-examine 17
whether the present overlapping, yet independent structures can be simplified and unified. The goal of safety must not be lost in developing competing programmatic, regulatory and technological pursuits. It is equally important that this emphasis on safety is not overdone. The pursuit of safety should address an overall goal that is balanced, attainable and demonstrable. Our mechanisms for assuring safety must avoid illogical, cascading requirements, whether in engineering, regulation or public participation. Radioactive waste management and disposal should not create self-perpetuating organizations who never finish their R&DE13 It is important that we recognize this goal to apply not only to the disposers of waste but equally to all participants. Progressive regulatory closure should go hand-in-hand following progressive repository implementation and closure. It is important that the private sector broaden its overview of the high-level radioactive waste disposal program to examine performance in the preparation period, and to constantly look at the issues of risk assessment ard risk management. In so doing, attention should be given to several key areas: o Defining the acceptable level of risk from geologic disposal. 18
Simplifying and accelerating the waste d tsposal program. o Reviewing how waste management criteria are being o developed and applied. Ensuring the documentation, validation and usefulness of o the standards and methodologies applicable to disposal in googlogic repositories. Perhaps the greatest attention should be given first to the determination of the levels of acceptability of risk from geologic disposal. Such determination cannot be made on the basis of first principles, involvng as it does subtle balancing of data, judgments and perceptions. Clearly, a more realistic ~ D s,/ and attainable solution is needed, one to which the NCRP can contribute in an important way. Finally, some balance must be found between investment in debate and protocols, and investment in facilities and operations that accomplish real_ waste disposal and provide real levels of protection. I i l i O 19
_ _ - = - _. = _ - _ _ = 1 l l l References i i ) 1. Bishop, W. P., el al. Proposed Goals for Radioactive Waste Management, NUREG-0300, U.S. Nuclear Regulatory Commission, Washington, D. C. (May 1978). 2. U.S. Department of Energy. Management of Commercially Generated Radioactive Waste, Final Environmental Impact Statement, DOE /EIS-0046F, 3 vols. USDOE, Washington, D.C. l (October 1980). J l 3. U.S. Environmental Protection Agency. Environmental Standards for the Management and Disposal of Spent Nuclear l Fuel, High-Level and Transuranic Radioactive Wastes - 4 Proposed Rule. Federal Register _, Vol. 47, No. 250, pp. 58196-58206 (Decedber 29, 1982). 4. U.S. Nuclear Regulatory Commission. Disposal of High-Level j Radioactive Wastes in Geologic Repositories. Title 10, code of Federal Regulations Part 60. -Licensing Proced ures. Federal Register, Vol. 46, p. 13971 (February 25, 1981) -Technial Criteria. Federal Register, Vol. 48, p. 28194 l (June 21, 1983). l 5. Public Law 97-425. Nuclear Waste Policy Act of 1982. 97th ~ Congress, Stat 2201-2263, PL 97-42 5-Jan. 7, 1983. j Wa shington, D.C. (Jan. 7, 1983). l 6. U.S. Department of Energy. Radioactive Waste Management l System Project Decision Sched ule. DOE /RW-0018 (Preliminary Draft). USDOE, Washington, D.C. (January 1985). I j 7. U.S. Department of Energy. Nuclear Waste Fund Fee Ad equacy: An Assessment. DOE /RW-0020, USDOE office of 1 Civilian Radioactive Waste Management, Washington, D.C. l (February 1985). l 8. Collier, H. E., et al. Report on the Proposed Environmental l Standard s for the Management and Disposal of Spent Nuclear Fuel, High-Level, and Transuranic Radioactive Wastes (40 CFR 191). Report by the High-Level Radioactive Waste Disposal j Subcommittee, USEPA Science Advisory Board, USEPA, i i Washington, D.C. (January 1984). I i 9. - U.S. Environmental Protection Agency. Environmental Standard s for the Management of Disposal of Spent Nuclear l Fuel, High-Level and Transuranic Radioactive Wastes (40 CFR 4 191). Working Draf t No. 5, Final 40 CFR 191.
~~USEPA, I~~
Washington, D.C. (March 21, 1985). i 10. National Research Council. A Study of the Isolation System i i for Geologic Disposal of Radioactive Wastes. Waste Isolation Systems Panel ( Pig fo rd, T. H., et al. ), Boa rd on O Ra$ioactive Waste Management, National Research Council. National Academy Press, Washington, D.C. (1983). l 4 l l 20 l i i. U
11.
~~Catlin, R.~~
J., et. al. Presentation before the High-Level ) Radioactive Waste Disposal Subcommittee, USEPA Science Advisory Board, Public Meeting, San Francisco, CA. (March 24, 1983). 12. Wilson. R. Testimony for American Industrial Health Council, OSHA !!.aarings on Identification, Classification and Regulation of Toxic Substances Posing a Potential Occupational Carcinogenic Risk. U.S. Department of Labor, Occupational Safety and Health Administration Hearings, Washington, D.C. (February 1978). 13. U.S. Nuclear Regulatory Commission. Domestic Licensing of Production and Utili:tation Facilities: Appe nd ix I, Numerical Guides for Design Objectives and Limiting 2 Cond itions for Operation to Meet the Criterion "As Low as is Reasonably Achievable" for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents. Title 10, code of Federal Regulations Part 50, Appendix I.
~~USNRC, Washington, D.C.~~
~~(September 1, 1982, as amended ). 14. U.S. Environmental Protection Agency. Population Risks from Disposal of High-Level Radioactive Wastes in Geologic Repositories. Draft Report. EPA-520/380-006.~~
~~USEPA, Washington, D.C.~~
(December 1982). 15. U.S. Environmental Protection Agency. Draft Regelatory Impact Analysis for 40 CFR 191: Environmental Standards for Management and Disposal of Spent Nuclear Fuel, High-Level 4 and Transuranic Radioactive Wastes. EPA 520/1-82-024. USEPA, Washington, D.C. (December 1982). 16. Sc ott, J. I. and Osten, S. E. Ef fects of Parameter l Probability Distributions in' Performance Assessment i Models. Technical Information Memorandum No. 333379. The l Analytical Sciences Corporation (TASC), Read ing, MA. (July j 2, 1984). 17. Rish, W. R. " Application of risk and uncertainty analysis l results to the development of radionuclide release limits j for HLW repositories." Atomic Industrial Forum Conference l on Radiation Protection, Orlando, FL. (October 9, 1984). 18. U.S. Environmental Protection Agency. Radiological Impact .l Caused by Emissions of Radionuclides into Air in the United l States. Preliminary Report. EPA 520/7-79-006.
~~USEPA, j~~
Washington, D.C. (August 1979). 19. Lind ell, Bo. Concepts of Collective Dose in _ Radiological Protection. A Review for the Committee on Radiation Protection and Public Health of the OECD Nuclear Energy O Agency. OECD (NEA), Paris, France (November 1984). 21
Table 1 O Waste Disposal Objectives Primary objective The primary objective is to achieve the disposal of high-level radioactive waste so thats o Potential detriments to present populations and future generations are unlikely to exceed low, acceptable levels of risk: o Disposal methoJ s are ef ficient, cos t-e f fective, and contain an adequate degree of redundancy in protective measures; and () Active regulatory overview is provided in the first o generation (i.e., up to 100 years) following disposal to ensure overall ef ficacy and safety of the disposal process. Secon3ary objectives The secondary objectives required to assure achievement of the I primary objective includes + o The establishment of societal objectives and related standards and guides to define health protection goals and performance objectives for meeting those goalst o The development of risk assessment methodologies for relating projected technological performance to potential ef fects on the environment and on health; l I 22
Table 1 (Continued ) o The development of appropriate disposal technologies for the preparation and packaging of wastes, the selection and construction of repositories, the emplacement of wastes, and repository closure in a safe, ef ficient and acceptable manner; and e The establishment of institutional, reg ulatory, and administrative relationships and processes to assure estWblishment of disposal facilities and operations in an expeditious manner to achieve the requisite j requirements for safety, technological excellence and management of costs. e t i f O i 23 I
E13 TABIE 2: PRIMARY SOURCES OF GOAIS ( ) (_/ FEIERAL (DNCEINS OF LAW CR PROGRN4 PUBLIC/ CRITICS / CDNVDITIQN GQAL'# - TITLE RB3UIATICN ASSUMPTICNS INDUSTRY WISDCM A.1 The Necessity of Basing Decisions an] Actions on Impet Assessments X X X A,2 The Necessity of Inclu3ing All Aspects X X X A>3 (bnsideration of Nonquantifiable Values (X) X At4 1he Importance of Making thcertainties Explicit (X) X A.5 Making the System Attainable (X) X A6 Involving Society in the Decision Planning Process X X X A.7 Involving State, local ard Regional Governments X X (X) A>8 PLblic Participation in the Decision ~ Process X X X Assigning costs of the System (X) (X) X Bal Providing Organizational Flexibility X B.2 Organizational Response to Changes (X) (X) X B.3 In3epen3ence of the System frcm the Fuel Cycle (X) X X B.4 Ability of Organizations an! Insti-tutions to Detect an! Rectify Errors X X B.5 Assurirg Managerial Chapetence (X) (X) X B.6 Protecting Public Health an3 Safety During System Operation X X X X B,7 Minimizing Effluents X X X B.8 Minimizing the Probability of Untoward Events X X B.9 Reacting to Untoward Events (X) X X B. Minimizing the Interval Between Waste Creation ani Disposal X X (X) 24
Table 2 (Cbntinue3 ) I) FEIRAL CDN RlE OF LM CR PROGRM PUBLIC/ CRITICS / CILVENTIQN GOAL # - TITLE RB3ULATICN ASSUMPTICNS INDUSTRY WISDOM ' C.1 Inmediaut Est&lishment of Ctmplete Wasta Management Program X X C.2 Effects of Present Nea3s on Future (X) X X Systems D1 Bu$getary Cbnsiderations (X) X E.1 Organizations ard Institutions to Detect ard Rectify Errors (X) (X) X X E.2 Specifying the Normal State of the System E.3 Doctmentation for the Future (X) X E.4 Inplementing Organizations Must Not Be self-Perpetuating (X) X E Irdeperdence from the Political System X X l International (bnsiderations X X F.1 Intermediate Hardling ard Storage Not Limiting (X) (X) X F.2 Retrievability of Wastes After X Disposal G.1 Location ard Operation of Disposal Facilities (X) X (X) C.2 Deccmmissioning of Facilities X X G.3 Stability of Social ard Goverrmental Institutions (X) X X G.4 (bnpliance with Ra31ation Stardarda X X X X X = Primary Source (J) = By inplication Id aa Weh tin Task Group fourd ccropellity but Wich ha3 no tientifiable source in the usual ralloactive waste management. f3 v 25 t
Table 3[8] AU 1 M.MBER OF POSSIBIE CANCER CASES DUE 'IO IONIZI!G RADIATION NO. OF
~~10. OF CASES ORIGIN CASES PER YR.2 PER 10,000 YR.2 3~~
High-level Rad. Waste Disposal up to 0.1 up to 1,000 4 Uranium Mill Tailings tkiprotectalt 3 30,000,, Protecte$ (covere$, etc.) 0.03 300 Irdoor Air Pollution 5 Residential Exposure 1,000 10,000,000 to to 20,000 200,000,000* therization 250 2,500,000 Residential y)(Noro Estimate) to to (alded cases 5,000 50,000,000, therization 10,000 100,000,000 Residential y) (alde$ cases to to 20,000 200,000,000, 7 (v Backgrourtl Radiation 3,000 30,000,000 to to 4,000 40,000,000 [ Cancer Deaths (U.S.)8 (all causes) 430,000] Notes: 1 '!hese nunbers are all calculatal on the same basis using a linear non-threshold does response nodel. 'Ibe linear non-threshold nalel involves a high degree of speculation, ard the resulting values have little merit as absolute irrlicators of the nunbers of biological effects that may occur. It has been used here to provide a framework within sich relative risks fran various ra51ation exposure situations can be conparal. Asstrning constant U.S. population art! culture - nunbers with (*) 2 l are extrapolatal fran annual values. 3 IPA proposal rule 40 cm Mrt 191 (Decenber 1982) nunbar per 100,000 MnN high-level ra51oactive wasta repository. 4 tRC (October 1980). "Uranitsu Mill Licensing Requirements: Final Rules," Faleral Register, 45, No.194, 65521-65538. Radon irhalation exposures. l l 26 L_
Table 3 (Cbntinua3) O 222 5 Nero, A. V. "Irdoor Radiation Exposures feczn Rn ari$ Its Daughters: A View of the Issue, " Health Ihysics, 45, No. 2, (August 1983), 277-288. 6 EPA Report EPA 520/4-78-013 (revisa3 printing, July 1979). 7 tRS/tRC, 'Ihe Efflects on Populations of T'xposure to Low Inval of Ionizing Ra$iation (Novenber 1972) - (1972 BEIR Report). 8 American Chneer Society, Chneer Facts ard Figures - 1982, 1981. t Does not incitde health effects from water pathways. f e O l I f l l l 27 \\ ' -I # N Few
h Table 4[4,14,15] U MINIMJM PERFORMANCE SPECIFICATIOtB - EPA AND tRC IEVEL OF HEALTH EFFECTS OVER 10,000 YEARS MEDIA EPA 1RC 100 1,000 1,000 SALT 104 5 1o-2 PW ( 10-5 pg PPY IEAOi RMPE IEJO! RATE LEAOi RATE 10s 'IO 100s YRS. 10s 'IO 100s YRS. 300 'IO 1,000 YRS. CMISTER CMISTER CMISTER 4
~~GRMIIT, (ditto)~~
- 10 PPY (ditto) IEAOi RMPE 10s 'Io 100s YRS. CMISTER ~ BASALT 104 5 104 5 (ditto) PPY IEAO! RATE PPY Of RMTE > 2,000 YRS. > 200 YRS. CANISTER CANISTER I O 28
,_g s 4 E17] Table S UN RfAINIY IN RADIONUCLIDE INDEPEIENT MODEL PARNJ@ TIPES T IDWER UPPER PARATTER DISTRIBUTICN BCUt0 MEDIAN BOWD AIN (VEGETATICN LOCNORMAL 6.0 15.8 42.0 WEMPHERI!G CDEFICIDTF) RESJSPENSION FATCR IDGNCRMAL 1.0E-10 1.0E-9 1.0E-8 WMPER 'IREAINENT INIFOR4 0.2 0.55 0.9 FACrm IRRIGMPICd ERACTION IDGWIFORM 0.02 0.1 0.5 DOSE-RESPONSE. CD T FICIENT6 (EFEECTS/10 PEREE-REM) i o IDW IET SUBJECTIVE O.0 100.0 1000.0 ' o HIGi IEr I/XNORMAL 13.7 100.0 761.6 'i r I i O 29 l
,,i .I ie ,i - nii a ,q , V .ll l ,5, i a r----- lii' ,ijfill 1l t i r--- 1!'l ll-o !gj illl il ('ll { i Il l 1 L_ + p._.... m l 4 l !ll. i. 1 is! + Ell 5 i i u 5 a L __J ilil
~~!!l~~
~~.s ! I i 5 ~ i l1l ,t iggi sii its g ?!j -+ II a y = g, i!I~~
~~li l.~~
~~I e 1l[ E C~~
~~s b~~
~~I di r,~~
~~i i!.~~
l1: -! 1;j ill.: i E I sj"n i s i gg a i + Il'Il Il E i E 2 I i o I i gl8 / !' i \\ l lI 9 - ilI \\g . it e 1 f i g __________a a it ili its I !l n = 1 s 11 i O ,Illh 'il! l.ll! i. 815 51i l i.ll l li sa:Illal. ODo ~ l
.O, \\s, Experience and expectations 10-2 Safety goals and standards Cancer deatn rate U S. population (1981) (Amer. Cancer Soc.) 10-3 Cigarette smoking (cancer only) 10-4 NRC annual dose limit (general public). draft Natural background rad 10 CFR part 20 rev. U.S population
10-5 EPA annual dose limit Medical X-rays (general public) U fuel U.S. population *
~~/ cycle (40 CFR part 190) Nuclear power plants - normal / 10-6 \\ Proposed delayed mortality effluents - 10 mi radius dose~~
~~safety goat (Nureg-0880)~~
~~Consurier products /bidg. NRC nue: ear power plants matenals - rad. dose~~
~~10-7 ettiuent iim,ts 10 CFR 50 app I~~
~~~ One transcontinental flight /yr. 10-8 Nuclear operations - normal avg U S population dose~~
~~10-9 EPA high level rad waste disposallimit (draft) 10-2 4-10-11 EPA limit adjusted for conservatisms in derivation 10-12 Estimated range of e~~
repos: tory performance 10-13 + 1 0-14 Risk / year O sources sii Eeni presentation EPA-SA8 San Francisco March 24.1963 i \\j (2) Wilson. Richard Testimony for O$c4A hearings on toniec suestances. February 1978 BEIA til Figure 2. Individual annual risk of cancer.[11.12] 31
b I "SEST FIT" NORMAL DISTRIBUTION /g\\ SEST FIT" LOG NORMAL 2x10-5. / DISTRIBUTION Y"21+R2+R3+R4 E [ [ l \\ n 15 LOG NORMALLY DISTRIBUTED f WITH MEDIAN = 1600yr 8 s 1 (n o = 1.61 g g j 1 x 10 l \\ I e O i i s ~~_ 0 0.5 x 105 1x105 1.5 = 105 TOTAL TRAVEL TIME. ylyrst Figure 3. Histogram showing the distribution of 1000 samples of the sum of 10 log-normally distributed travel times. 06] From: Scott, J. f. and Oston S. G. Effects of Parameter Probability Distributions in Performance Assessment Models. Technical infon?,ation memorandum no. 3336-9, The Analytical Sciences Corporation, Reading, MA (July 2,1984). f O 32
i e V 4 0.012 s 0.010-l "BEsT-FIT LOG. NORM AL DisTRISuTloN Y " "1 82 "3 84 0.008-a is NORMALLY DISTRIBUTED i r WITH p = 3. G = 1 pm 0.006-0.004- \\_- \\ 0.002- -- 0 ) 0 100 200 300 400 y Figure 4. Histogram showing the distribution of 1000 samples of the product of four normally distributed variables.0s] From: Scott, J. \\. and Oston, S. G. Effe' cts of Parameter Probability Distributions in Performance Assessment Models. Technicalinformation memorandum no. 3336 9, The Analytical Sciences Corporation, Reading, MA (July 2,1984). i O 33 I
I 11 April 1985 R. J.Ca tl in
~~SUMMARY~~
ANALYSIS EPA WORKING DRAFT # 5, 40 CFR PART 191 " Environmental Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes" TECHNICAL FACTORS Sianificant Changes
1. Reduction of the horizontal distance from the original location of wastes in a disposal system to the boundary of the accessible environment from 10 km. to 2 km.

2. Extension of applicability of the standards to two types of ground water in the vicinity of disposal system, in terms of limits on average annual radionuclide concentrations for the first 1,000 years after disposal:
- In ground water outside the controlled area, i.e., in a horizontal direc-tion from the original location of wastes beyond the surface location designated by passive institutional controls (markers, records, etc.) 4 but no more than 2 km. from that original location; such ground water to be characterized as a significant source in terms of quality, depth from surface, transmissivity, capacity and usage; and - In Class I ground waters identified in accordance with EPA's Ground-Water-Protection Strategy that are irreplaceable. lO
3. Assurance requirement to avoid locations where resources have been mined or are likely to be mined has been extended to include locations of ground waters that are irreplaceable or are vital to the preservation of unique and sensitive ecosystems.

4. The likelihood of exceeding specified release limits relative to contain-J ment requirements has been relaxed by a factor of 10.
~~Other Major Channes l S. The definition of high-level radioactive waste has been conformed to that in the Nuclear Waste Policy Act of 1982 (NWPA).~~
6. The definition of barrier has been expanded to include materials or struc-tures that prevent or substantially delay the movement of water toward the accessible environment (as well as the movement of radionuclides).

7. The requirement for disposal system performance assessment has been expanded to include the assembly of cumulative release estimates into overall cumu-lative probability distributions for " compliance" determinations.

8. Detailed puidance on procedurai requirements is given in a new appendix (B) which includes assumptions on inadvertent exploratory drilling to be used by implementing agencies, among other considerations.

9. Alternative definitions of units of waste other than spent fuel and high-level radioactive waste are specified in detail.
O
11 April 1985 RJC . O Page 2 PROCEDURAL FACTORS Significant Changes
10. NRC authority to define high-level radioactive waste is recognized.

11. DOE authority to define transuranic wastes, and NRC authority to define transuranic wastes under 10 CFR Part 61 are recognized.

12. EPA standards are specifically made applicable to DOE disposal facilities not regulated by NRC or Agreement States.

13. Authority to grant variances for unusual operations is moved from the implementing agencies to the EPA Administrator.
~~14 The definition of passive institutional control is expanded to include government ownership and regulations regarding resource use, as well as land use.~~
15. Applicability of EPA assurance requirements is lifted from facilities regulated by NRC in favor of their inclusion in 10 CFR Part 60.

16. Monitoring requirements after disposal have been added, with termination of monitoring effort to be made by implementing agency when need has passed.

17. Provision is made for EPA Administrator to issue alternative provisions for disposal of existing specific wastes conditional on 00E studies and
~ proposals, subject to full public review. l l l l O 1
Table 3[8] 1 MMER OF POSSIBIE CAN R CASES Dt.E 'IO IONIZI!G RADIATIQ4 NO. OF NO. OF CASES ORIGIN CASES PER YR.2 PER 10,000 YR.2 i 3 High-level Rad. Waste Disposal g to 0.1 9 to 1,000 4 Uranim Mill Tailings tkprotecte$t 3 30,000,. Protectal (covera $, etc.) 0.03 300 In5oor Air Pollution 5 Residential Exposure 1,000 10,000,000 2 2 20,000 200,000,000, i therization 250 2,500,000 Residencial y)(Noro Estimate) to to (a$de5 maes 5,000 50,000,000, 10,000 100,000,000 Reside?,LG g) atherization (mida3 cases to to 20,000 200,000,000 7 Backgroun3 Ra$iation 3,000 30,000,000 to to 4,000 40,000,000 [Chnoer Deaths (U.S.)8 (all causes) 430,0003 Notes: 1 'Ihese nunbers are all calculate 5 on the same basis using a linear non-threshold dose response nodel. 'Ihe linear non-threshold m25el 4 involves a high degree of speculation, an5 the resulting values have little merit as absoluta in$icators of the nunbers of biological effects that may occur. It has been usa 3 here to provide a framswork within Wi& relative risks fra various ra91ation exposure situations can be ocuparal. Assming constant U.S. population an5 culture - nunbers with (*) 2 are extrapolatal fra annual values. 3 EPA propose $ rule 40 CER 1%rt 191 (Decenber 1982) nunber per 100,000 MnN high-level ra51oactive wasta repository. 4 tRC (October 1980). "Uranim Mill Licensing Requirements: Final Rules," Fe3eral Registar, 45, No.194, 65521-65538. Radon irhalation exposures. O l 26 9 - --.-w .--_.-,,,.--.--c_ --,,,-,,..,.,.-..--_-,.p., , - ~ - - _,----n-----._--.m_.-
Table 3 IContinued) 222Rn ard Its 5 Hero, A. V. "Irdoor Radiation Exposures from Daughters: A View of the Issue, " Health Physics, 45, No. 2, (August 1983), 777-288. 6 EPA Report EPA 520/4-78-013 (revisa3 printing, July 1979). 7 NAS/lRC, 'Ihe Effects on Populations of Exposure to Iow Invel of Ionizing Radiation (Ncwenber 1972) - (1972 BEIR Report). 8 American Cancer Society, Onneer Facts ard Figures - 1982, 1981. i Does not include health effects feczn wter patNays. O { i o O 1 27 i
Table 4[4,14,153 MINIMJM PERK 2MANG SPECIFICATI0tS - EPA AND tRC IEVEL OF HEALTH EFECTS OVm 10,000 YEARS MEDIA EPA BRC 100 1,000 1,000 SET 104 5 2 FW ( 10-5 pg PW IEAm RMPE IEJO! RATE IEAO! RATE 10s 'IO 100s YRS. 10s '10100s YRS. 300 'IO 1,000 YRS. CMIFra CMISTM CMISTER 4 GUNITE (ditto) - 10 PW (ditto) IZAm RATE 10s '!O 100s YRS. CMISTER i BASALT 104 5 104. 10-5 (ditto) PPY IZAO! RMTE PW IZAO! RXPE O > 2,000 YRS. > 200 YRS. CANISTER CANIST E 5
~~O 28~~
~~(a3 Experience and expectations 10-2 Safety goals and standards Cancer deatn rate U S population (1961)~~
(Amer Cancer Soc.) 10-3 Cigarette smoking (cancer only) 10-4 NRC annual dow limit eral pu lic). drah Natural background rad 10 CFR pan 20 re U S population, 10-5 gpg,nny,, ao,,,m,, Medical X rays (general pubhc) U fuel U S population * / cycle (40 CFR part 190) Nuclear power plants. normal / 10-6 % p,,po,a aer,y,a man niy effluents.10 mi radius dose
~~safety goat (Nureg 0880)~~
~~Consumer products'Didg A NRC nuclear power plants materia!s. red dose~~
~~10-7~~
~~'g e,tiueni simits.10 CFR 50 app I One transcontinental thght/yr 10-8 1 V Nuclear operations. norrnal avg U S population dose~~
~~10-9 EPA high tevoi rad waste disposal limit (drai) 10-10 1 0-11 EPA limit adjusted for conservatisms in derivation 10-12 Estimated range of e~~
repository performance 10-13 + 10-14 Risk / year I bources til EPas preseatation EPA.SAB San Francisco March ta 1943 i A (2) Wilson Reche'd Testimony for O$H A heann08 09 to8'c swestances Feeruary 1974 I ( BEiR til Figure 2. Individual annual risk of cancer.0136 31
E173 Table 5 L23 RTAltf!Y IN RADIOt0CLIDE 4 IICEPDENT EKL PAIUMETERS h rra OF IDER UPPER PAIUNTER DISTRIBUTIW BCDD MEDIMI BOLND i AIN (VEGETXrION 14X3401 MAL 6.0 15.8 42.0 l W.ATHDtI!G ODEFFICIENT) RERJSPENSION FAcrCR IAGtOMAL 1.0F10 1.0E-9 1.0&8 WRrER 'IREADENT WIFOR4 0.2 0.55 0.9 FAcrW IRRIGMrION FRACTICH IDGWIPCRM O.02 0.1 0.5 l ) i DOSE-RESPOMiE ) CDEFFICIENT6 l (EFFECTS /10 j PERION-RIM) o IDW IET SUIL7ICTIVE 0.0 100.0 1000.0 o HIm IEr IXXNORMAL 13.7 100.0 761.6 l I e i i i i i t lO f 29 { ..,___.___,n-,.,,--,,_-_._, , - - - - -. - - - ~... _, -. - - -. _ _...
O J Q "SEST. FIT" NORM AL DISTRIBUTION SEST. FIT" LOG. NORM AL 2 = 10
l.
[ DISTRIBUTION 4 E ,c l \\ a IS LOG.NORMALLY DISTRIBUTED f WITH MEDIAN = 1800yr ~ s s _t fn o = 1.61 g g g 1 = 10.s. j g N o i \\ s / l. ~ - -. - - - J I O 0.5=108 1=108 1.5 = 105 TOTAL TRAVEL TIME. ylytel Figure 3. Histogram showing the distribution of 1000 samples of the sum of 10 log normally distributed travel times.00 From: Scott, J. D. and Oston S. G. Effects of Parameter Probability Distributions in Nr/ormance Assessment Models. Technical information memorandum no. l 3336-9, The Analytical Sciences Corporation, Reading, MA (July 2,1984). r P O 32 l
c.012 0.010- "SssT. FIT" LOG NORMAL DisTRisuTION Y = "i "a 's '4 o.cos-a is NORMALLY OtsTRisuTED WITH id = 3. 0 = 1 t l ~ 0.004-O N\\ o.002- -- N A- ~ o / o too 200 soo 400 v Figure 4. Histogram showing the distribution of 1000 samples of the product of four normally distributed variables.06 From: Scott, J. l. and Oston, S. G. Effects of Parameter Probability Distributions in Arrformance Assessment Models. Technicalinformation memorandum no. 3336 9, The Analytical Sciences Corporation, Reading, MA (July 2 '964). 1 O 33 .-----,.,,_.,_.,_,_.____,,__n_, 7__
7 Experience and expectations 30 2 Safety goals and standarcs V Cancer oeatn rate U S peowtat on s19e13 (Amet Cancer Soc I 10 3 Ciga'ette smcaing (cance. oney) 10 d NRC ann ei cose i m : w ' 8 ' * ' ' ' ' D ' D " ' ' ' Natwralea:agrow o ras a 10 CFR paq 20 te, U S poesiat.on. 10 5 g,,,,,,,,,,,, u m,, y,,,,,,,,,,, igenerai outoct U twei U S copsiat om' / cycie lac CFR part 12 Nweies' poner D!a9ts normal / 10 6 \\ Propoleo ottayao mortality e'6weats.10 m racews cose' ,,,,,,g3,,,gg,eg 08901 e ate s as os 10-7 ettiweet I.mits.'10 Ce A $3 a:= ! Cae t'aascomt aemtat fligat yr 10 8 Ns:'es' c:e'at cas norma' a.; U $ c:es.at.cm octe' O 6.I5* g *2 *= ~ ~ E *,, N' h,5"e.? 10 10 E 3 I 1011 1/ /I 10 12 l l [ l [ Estimates range et teposctort verformance y 1 0-14 Risk / year e ARE STANDARDS ljNNECESSARILY STRINGENT? e WILL LACK 0F APPARENT f!ARGlii C0fPLICATE A!!D DELAY LICENSlilG7 EXTEND SITE CHARACTERIZAT10ll?
O O O FIG.1 COMPARISON OF DEVELOPMENTAL BASES - GENERAL CONSIDERATION RADIATION PROTECTION STANDARDS PROBABILITY OF CAUSATION o RADIATION RISKS SOMATIC AND GEETIC SOMATIC STOCHASTIC AND NON-STOCHASTIC STOCHASTIC o OTER RISKS NONE CHEMICAL CARCIN0 GENS AND SM0 KING (WITH KNOWN DOSE-EFFECT RELATIONSHIPS) o RISK RELATIONSHIPS ADDITIVE ADDITIVE AND MULTIPLICATIVE l o RADIATION SOURCES INDUSTRY AND DEFENSE - OCCUPA-INDUSTRY, DEFENSE AND TIONAL AND PUBLIC EXPOSURES EDICAL PROCEDURES i EXPOSURES l o PRIMARY CANCER SITES ALL SITES (EXCEPT CHRONIC 12 SPECIFIED SITES - LY W H0CYTIC LEUKEMIA) lli SITES EXCLUDED l o AGE GROUPS ALL AGE GROUPS AGE GROUPS LIMITED FOR 7 0F TE 12 SPECIFIED SITES o END POINT (S) 0F INTEREST MORBIDITY AND MORTALITY MORBIDITY l )
O O FIG.2 COMPARISON OF DEVELOPMENTAL BASES - MODELING CONSIDERATION RADIATION PROTECTION STANDARDS PROBABILITY OF CAUSATION o RISK PROJECTION MODEL ABSOLUTE RISK PROJECTION MODEL: ABS._ RIS_K_PROJ. MODE 1 (OVER TIME) ALL SITES (WAVE FUNCTION): LEUKEMIA AND B0NE CANCER RELATIVE RISK PROJ. MODEL_: SOLID TUMORS EXCEPT BONE o DOSE-PESPONSE MODEL LINEAR: LOW-OR llIGH-LET: LINEAR _-QU_ADRATIC.: LOW-LET: ALL SITES ALL SITES EXCEPT BREAST AND THYROID. LINEAR: LOW-LET: BREAST AND THYROID; HIGH-LET: ALL SITES o RISK C0EFFICIENTS LINEAR (BEIR REPORT, 1980) LINEAR ADAPTED T0_ LINEAR-00ADRATIC: SOLID TUPORS EXCEPT BREAST AND THYROID. LINEAR: BREAST AND THYROID o LATENT PERIOD BEIR REPORT (1980) VALUES 2 YEAR MINIMUM FOR LEU-KEMIA AND BONE CANCER; SM0OTHED 5-10 YEARS FOR SOLID TUMORS
t e a ] F- .r_ g_ (_) $
~~-8 X~~
~~g Ld E d, U) 1~~
~~1 s9~~
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~~p m~~
~~n s 2 o W / a 4 _o n O <( 0 a a o n Y S f v -) ~y g a9 _J c i i i i i i i i i i i i i 0 m 4 c4 o e m 4 c4 o o 4 c4 o m (4 C4 C4 (4 (4 e r ( u. (%)Od /~~
~~w. p.~~
Inited States Government Department of Energy ^ ~ memorandum FEB 141985 CETLY To ATTN or. NE-24 Guidelines for Residual Radioactivity at FUSRAP and Remote SFMP Sites sus;ter: To; E. L. Keller Director Technical Services Division Oak Ridge Operations Office Clarence Miller, Director Surplus Facilities Management Program Office Richland Operations Office The attached guidelines, "U.S. Department of Energy Guidelines for Residual Radioactivity at Formerly utilized Sites Remedial Action Program and Remote Surplus Facilities Management Program Sites" (January 1985) p) should be implemented in FUSRAP and SFMP to establish authorized limits ( for remedial actions. The guidelines provide specific authorized limits for residual radium and thorium radioisotopes in soil, for airborne radon decay products, for externsi gamma radiation, and for residual surface contamination levels on materials to be released for unrestricted use. These guidelines will be supplemented in April 1985 by a document providing the methodology and guidance to establish authorized limits for residual radioisotopes other than radium and thorium in soil at sites to be certified for unrestricted use. The supplement will provide further guidance on the philosophies, scenarios, and pathways to derive appropriate authorized limits for residual radionuclides and mixtures in soil. These guidelines are based on the International Comission on kadiation Protection (ICRP) philosophies and dose limits in ICRP reports 26 and 30 as interpreted in DOE Order 5480.1A. These dose limits are 500 mrem /yr for an individual member of the public over a short period of time and an average of 100 mrem /yr over a lifetime. The approval of authorized limits differing from the guidelines is described in section D, last sentence of the attached document. If the urgency of field activity makes ORAP concurrence not cost-effective, a copy of the approval and backup analysis should be furnished to ORAP as soon as possible, although not necessarily prior to beginning field activities. As a result of a recent court decision, the Environmental Protection Agency (EPA) has issued airborne radiation standards applicable to DOE f] j facilities. These final standards, issued as revisions to 40 CFR 61, s are:
e 1 a o 25 mrem /yr-whole body o 75 mrem /yr-organ o waiver of these standards will be granted if DOE demonstrates that no individual would receive 100 mrem /yr continuous exposure whole body dose equivalent from all sources within 10 km radius, excluding natural background and medical procedures. i radonandradondaughtersareexcluded(thesestandardsarecovered o in 40 CFR 192). The primary airborne radioisotopes of concern in the FUSRAP are radon and its daughters and inasmuch as they are excluded from the EPA airborne standards, there appears to be minimal, if any, effect on the attached DOE /DRAP guidelines or its supplement. l The attached guidelines have been written to be consistent with the revision of the DOE Order 5480.1A now in draft at Headquarters and have the concurrence of the Public Safety Division. Office of Operational 1 Safety. The guidelines have been prepared with the assistance and review i by PE, DP, OR, RL, ANL, ORNL, PNL, and LASL. We greatly appreciate the l h contributions and coments that all involved organizations have made, C particularly Tom Gilbert, ANL, who did much of the work. S. John E. Baublitz Direct l Division of Remedial Action Projects Office of Teminal Waste Disposal and Remedial Action Office of Nuclear Energy Attachments l CC: See attached distribution list I i
I 1 i O!57Rl8UT!0N LIST i C. Welty, PE-243 W. Beck, BN! A. Kluk, OP-122 J. Berger, ORAU M. Barainca, 10 B. Berven, ORNL J. Clark EG4G !D R. Potter UNC/RL i R. Giordana, Shippingport R. Coy, UNC/RL l J. Schreiber, Shippingport R. Dickson, ID E. Jennrich, EC&G 10 P. Dunnigan, RL C. Smith, Science Applications, Inc. C. Miller, RL i i K. Baker, Jacobs Engineering Group K. Eckerman, ORNL i L. Ball, GJ < Gilbert ANL l W. Bibb, OR W. Hansen, LASL i J. Corley, PNL J. Healy, LASL i J. Duray, GJ M. Hughes, SR Plant l R. Glenn, Bechtel W. Kennedy, PNL J. Handy, UNC/RL
~~5. Lichtman, EPA j~~
~~E. Jascowsky, CH R. Moservey, EG4G-l'~~
~~5. Kaye, ORNL B. Napier, PNL t~~
j C. King, SR Lab. C. Roberts Dames & Moore i C. Littie. ORNL J. Soldat. PNL l l J. Themelis, AL R. Vocke, ANL [ M. Robinet. ANL A. Wallo, Aerospace J. Rodgers, LASL R. Wynveen, ANL i i J. Thiessen ER-71 J. taub11tz, NE-24 l l
~~5. Miller, GC-11 E. DeLaney, NE-24 i~~
M. White. AL G. Turi, NE-24 [ J. Alexander, OR A. Whitman, NE-24 l l E. Keller, OR L. Brarley, NE-24 V. Apple, UNC/RL D. Groelsema. NE-24 M. Hardis. EPA I l i l l 4 I l I i i t llO i i i \\ I'. -.,. -. -,.... -. -. - - - _ - _ -,. -
AV U.S. DEPARTMENT OF ENERGY GUIDELINES FOR RESIOUAL RADI0 ACTIVITY AT FORMERLY UTILIZED SITES REMEDIAL ACTION PROGRAM AND REMOTE SURPLUS FACILITIES MANAGEMENT PROGRAM SITES (February 1985) A. INTRODUCTION This document presents U.S. Department of Energy (DOE) radiological protection guidelines for cleanup of residual radioactive materials and management of the resulting wastes and residues. It is applicable to sites identified by the Formerly utilized Sites Remedial Action Program (FUSRAP) and remote sites identified by the Surplus Facilities Management Program (SFMP)." The topics covered are basic dose limits, guidelines and authorized limits for allowable levels of residual radioactivity, and requirements for control of (,~) the radioactive wastes and residues. %J Protocols for identification, characterization, and designation of FUSRAP sites for remedial action; for implementation of the remedial action; and for certification of a FUSRAP site for release for unrestricted use are given in a separate document (U.S. Dept. Energy 1984). More detailed information on appilcations of the guidelines presented herein, including procedures for deriving site-specific guidelines for allowable levels of residual radio-activity from basic dose limits, is contained in a supplementary document-- referred to herein as the " supplement" (U.S. Dept. Energy 1985). " Residual radioactivity" includes: (1) residual concentrations of radio-nuclides in soil material,"* (2) concentrations of airborne radon decay products, (3) external gamma radiation level, and (4) surface contamination. A " basic dose limit" is a prescribed standard from which limits for quantities that can be monitored and controlled are derived; it is specified in terms of the ef fective dose equivalent as defined by the International Commission on Radiological Protection (ICRP 1977, 1978). Basic dose Ilmits are used explicitly for deriving guidelines for residual concentrations of radio-nuclides in soll material, except for thorium and radium. Guidelines for
~~A remote SFMP site is one that is excess to 00E programmatic needs and is located outside a major operating 00E research and development or production area.~~
V;
~~The term " soil material" refers to all material below grade level after remedial action is completed.~~
1
t O 2 OV residual concentrations of thorium and radium and for the other three quanti-ties (airborne radon decay products, external gamma radiation level, and surface contamination) are based on existing radiological protection standards (U.S. Environ. Prot. Agency 1983; U.S. Nucl. Reg. Comm. 198.7). These standards are assumed to be consistent with basic dose limits within the uncertainty of derivations of levels of residual radioactivity from basic limits. A " guideline" for residual radioactivity is a level of residual radio-activity that is acceptable if the use of the site is to be unrestricted. Guidelines for residual radioactivity presented herein are of two kinds: (1) generic, site-independent guidelines taken from existing radiation protec-tion standards, and (2) site-specific guidelines derived from basic dose limits using site-specific models and data. Generic guideline values are presented in this document. Procedures and data for deriving site-specific guideline values are given in the supplement. An " authorized limit" is a level of residual radioactivity that must not be exceeded if the remedial action is to be considered completed. Under normal circumstances, expected to occur at most sites, authorized limits are set equal to guideline values for residual radioactivity that are acceptable if use of the site is not be restricted. If the authorized limit is set higher than the guideline, restrictions and controls must be established for use of the site. Exceptional circumstances for which authorized limits might differ from guideline values are specified in Sections D and F. The restric-V) tions aad controls that must be placed on the site if authorized limits are g set higher than guidelines are described in Section E. DOE policy requires that all exposures to radiation be limited to levels that are as low as reasonably achievable (ALARA). Implementation of ALARA policy is specified as procedures to be applied after authorized limits have been set. For sites to be released for unrestricted use, the intent is to reduce residual radioactivity to levels that are as far below authorized limits as reasonable considering technical, economic, and social factors. At sites where the residual radioactivity is not reduced to levels that permit release for unrestricted use, ALARA policy is implemented by establishing controls to reduce exposure to ALARA levels. Procedures for implementing ALARA policy are described in the supplement. ALARA policies, procedures, and actions must be documented and filed as a permanent record upon completion of remedial action at a site. B. BASIC DOSE LIMITS The basic limit for the annual radiation dose received by an individual member of the general public is 500 mrem /yr for a period of exposure not to exceed 5 years and an average of 100 mrem /yr over a lifetime. The committed effective dose equivalent, as defined in ICRP Publication 26 (!CRP 1977) and calculated by dosimetry models described in ICRP Publication 30 (ICRP 1978), shall be used for determining the dose. n o I
3 C. GU10ELINES FOR RESIOUAL RAC10 ACTIVITY C.1 Residual Radionuclides in Soil Material Residual concentrations of radionuclides in soil material shall be specified as above-background concentrations averaged over an area of 100 m2, If the concentration in any area is found to exceed the average by a factor greater than 3 guidelines for local concentrations shall also be applicable, These " hot spot" guidelines depend on the extent of the elevated local concen-i l trations and are given in the supplement. The generic guidelines specified below are for concentrations of individual radionuclides ore.urring alone. If mixtures of radionuclides are present, the concentrations of individual radionuclides shall be reduced so that the dose for the mixture would not exceed the basic dose limit. Explicit formulas for calculating residual concentration guidelines for mixtures are given in the supplement, i i The generic guidelines for residual concentrations of Th-232. Th-230, Ra-228, and Ra 226 are: I - 5 pCf/g, averaged over the first 15 cm of soil below the surface l l - 15 pCi/g, averaged over 15 cm thick layers of soll more than 15 cm below the surface i The guidelines for residual concentrations in soil material of all other radionuclides shall be derived from basic dose limits by means of an environ-mental pathway analysis using site-specific data. Procedures for deriving these guidelines are given in the supplement. C.2 Airborne Radon Decay Products Generic guidelines for concentrations of airborne radon decay products shall apply to existing occupied or habitable structures on private property that are intended for unrestricted usei structures that will be demolished or 1 buried are excluded. The applicable generic guideline (40 CFR 192) is: In any occupied or habitable building, the objective of remedial action shall be, and reasonable of fort shall be made to achieve, an annual average (or equivalent) 1 radon decay product concentration (including background) not to exceed 0.02 WL.* In any case, the radon decay product concentration (including background) shall not exceed 0.03 WL. Remedial actions are not required in order to comply with this guideline when there is reasonable assurance that residual radioactive materials are not the cause. C.3, [ sternal Camma Radiation The level of gamma radiation at any location on a site to be released for unrestricted use, whether inside an occupied building or habitable structure or outdoors, shall not exceed the background level by more than 20 pR/h.
~~A working level (WL) is any combination of short-ilved radon decay products in one 11ter of air that will result in the ultimate emission of 1.3 x 105 MeV of potential alpha energy, t~~
4 (V C.4 Surface Contamination The following generic guidelines, adapted from standards of the U.S. Nuclear Regulatory Commission (1982), are applicable only to existing structures and equipment that will not be demolished and buried. They apply to both interior and exterior surfaces. If a building is demolished and buried, the guidelines in Section C.1 are applicable to the resulting contamination in the ground. Allowable Total Residual Surface Contamination (dpm/100 cm8)t1 Radionucildest8 Averaget t* Maximumt*,t* Removablet' 8 Transuranics, Ra-226, Ra-228 Th-230, Th-228, Pa-231, Ac-227, 1-125, 1-129 100 300 20 Th-Natural. Th-232, Sr 90, Ra 223 Ra-224, U 232, 1-126, I-131, 1-133 1,000 3,000 200 U-Natural, U-235, U-238, and associated decay products 5,000a 15.000a 1,000a Beta gamma emitters (radionuclides A with decay modes other than alpha (") emission or spontaneous fission) except Sr-90 and others noted above 5,000p y 15,0006 y 1,0006 y 1 8 As used in this table, dpri (disintegrations per minute) means the rate of emission by radioactive material as determined by correcting the counts per minute measured by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation. 1 Where surface contamination by both alpha-and beta gamma-emitting radio-nuclides exists, the Ilmits established for alpha-and beta gamma emitting radionuclides should apply independently. 18 Measurements of average contamination should not be averaged over an area of more than 1 m. For objects of less surface area, the average should m be derived for each such object. 14 The average and maximum dose rates associated with surface contamination resulting from beta gamma emitters should not exceed 0.2 mead /h and 1.0 mrad /h respectively, at 1 cm. 16 The maximum contamination level applies to an area of not more than 100 cm8 to The amount of removable radioactive material per 100 cm2 of surface area 'should be determined by wiping that area with dry filter or soft absorbent paper, applyin0 moderate pressure, and measuring the amount of radioactive material on the wipe with an appropriate instrument of known officiency. When removable contamination on objects of surface area less than 100 cm8 I is determined, the activity per unit area should be based on the actual ,V area and the entire surface should be wiped. The numbers in this column are maximum amounts.
1 e 5 0. AUTHORIZED LIMITS FOR RESIDUAL RADICACTIVITY The remedial action shall not be considered complete unless the residual radioactivity is below authorized limits. Authorized limits shall be set equal to guidelines for residual radioactivity unless: (1) exceptions specified in Section F of this document are applicable, in which case an authorized limit may be set above the guideline value for the specific location or condition te which the exception is applicable; or (2) on the basis of site-specific data not used in establishing the guidelines, it can be clearly established that limits below the guidelines are reasonable and can be achieved without apprect-able increase in cost of the remedial action. Authorized limits that differ from guidelines must be justified and established on a site-specific basis, with documentation that must be filed as a permanent record upon completion of remedial action at a site. Authorized limits differing from the guidelines must be approved by the Director, Oak Ridge Technical Services Division, for FUSRAP and by the Director, Richland Surplus Fact 11 ties Management Program Of fice, for remote SFMP--with concurrence by the Director of Remedial Action Projects for both programs. E. CONTROL OF RESIDUAL RADICACTIVITY AT FUSRAP AND REMOTE SFMP $1TES Residual radioactivity above the guidelines at FUSRAP and remote SFMP sites must be managed in accordance with applicable 00E Orders. The DOE Order 5480.1A requires compliance with applicable federal, state, and local environmental protection standards. The operational and control requirements specified in the following 00E Orders shall apply to both interim storage and long term management, a. 5440.18, Implementation of the National Environmental Policy Act b. 5480.1A, Environmental Protection, Safety, and Health Protection Program for DOE Operations c. 5480.2, Hazardous and Radioactive Mixed Waste Management d. 5480.4, Environmental Protection, Safety, and Health Protection Standards e. 5482.1A, Environmental, Safety, and Health Appraisal Program f. 5483.1, Occupational Safety and Health Program for Government-Owned Contractor-0perated Facilities g. 5484.1. Environmental Protection Safety, and Health Protection Information Reporting Requirements h, 5484.2, unusual Occurrence Reporting System 1. 5820.2, Radioactive Waste Management E.1' Interim Storaae a. Control and stabilitation features shall be designed to. ensure, O. to the entent reasonably achievable, an effective life of 50 years and, in any case, at least 25 years. 4
/O u l b. Above background Rn 222 concentrations in the atmosphere above facility surfaces or openings shall not exceed: (1) 100 pCi/L given point. (2) an annual average concentration of at any/L over the facility site, and (3) an annual average 30 pCi concentration of 3 pC1/L at or above any location outside the facility site (DOE Order 5480.1A, Attachment XI-1). l c. Concentrations of radionuclides in the groundwater or quantities I of residual radioactive materials shall not exceed existing federal, state, or local standards, d. Access to a site should be controlled and misuse of onsite l material contaminated by residual radioactivity should be prevented through appropriate administrative controls and physical barriers--active and passive controls as described by the U.S. Environmental Protect 1on Agency (1983--p. 595). These control features should be designed to ensure, to the extent reasonable, an effective life of at least 25 years. The federal government shall have title to the property. E.2 Lona Term Manaaement a. Control and stabilization features shall be designed to ensure, O to the extent reasonably achievable, an effective life of V 1,000 years and, in any case, at least 200 years, b. Control and stabilization features shall be designed to ensure that Rn 222 emanation to the atmosphere from the waste shall 8 l not: (1) exceed an annual average release rate of 20 pC1/m /s, and (2) increase the annual average Rn 222 concentration at or above any location outside the boundary of the contaminated l area by more than 0.5 pCi/L. Field verification of emanation L rates is not required. l c. Prior to placement of any potentially biodegradable contami-nated wastes in a long-term management facility, such wastes shall be properly conditioned to ensure that (1) the generation and escape of biogenic gases will not cause the requirement in paragraph b of this section (E.2) to be exceeded, and (2) bio-degradation within the facility will not result in premature structural failure in violation of the requirements in para-graph a of this section (E.2). l d. Groundwater shall be protected in accordance with 40 CFR 192.20(a)(2) and 192.20(a)(3), as applicable to FUSRAP and remote $fMP sites, j e. Access to a site should be controlled and misuse of onsite material contaminated by residual radioactivity should be i O prevented through appropriate administrative controls and O physical barriers active and passive controls as described by the U.S. Environmental Protection Agency (1983--p. 595). These controls should be designed to be ef fective to the extent reasonable for at least 200 years. The federal government shall have title to the property, i
,t 7 O F. EXCEPTIONS Exceptions to the requirement that authorized limits be set equal to the i guidelines may be made on the basis of an analysis of site-specific aspects of a designated site that were not taken into account in deriving the guidelines. 1 Exceptions require approvals as stated in Section D. Specific situations that warrant exceptions are: a. Where remedial actions would pose a clear and present risk of injury to workers or members of the general public, notwith-standing reasonable measures to avoid or reduce risk. b. Where remedial actions--even af ter all reasonable mitigative measures have been taken--would produce environmental harm that is clearly excessive compared to the health benefits to persons living on or near affected sites, now or in the future. A clear excess of environmental harm is harm that is long term, i manifest, and grossly disproportionate to health benefits that may reasonably be anticipated. i i c. Where the cost of remedial actions for contaminated soil is l unreasonably high relative to long-term benefits and where the ~ residual radioactive materials do not pose a clear present or future risk af ter taking necessary control measures. The O likelihood that buildings will be erected or that people will spend long periods of time at such a site should be considered in evaluating this risk. Remedial actions will generally not be necessary where only minor quantities of residual radio-i i l active materials are involved or where residual radioactive materials occur in an inaccessible location at which site-l specific factors limit their hazard and from which they are l costly or difficult to remove. Examples are residual radio-l active materials under hard surface public roads and sidewalks, around public sewer lines, or in fence post foundations. In order to invoke this exception, a site-specific analysis must be provided to establish that it would not cause an individual to receive a radiation dose in excess of the basic dose Ilmits stated in Section B, and a statement specifying the residual i radioactivity must be included in the appropriate state and local records. ( d. Where the cost of cleanup of a contaminated building is clearly f unreasonably high relative to the benefits. Factors that shall be included in this judgment are the anticipated period of occupancy, the incremental radiation level that would be effected [ by remedial action, the residual useful lifetime of the building, the potential for future construction at the site, and the applicability of remedial actions that would be less costly than removal of the residual radioactive materials. A state-i ment specifying the residual radioactivity must be included in { O the approproate state and local records, j e. Where there is no feasible remedial action. l
} 8 f') m \\m / G. SOURCES Limit or Guideline Source Basic Dose Limits Dosimetry Model and Dose International Commission on Radiological Limits Protection (1977, 1978) Guidelines for Residual Radioactivity Residual Radionuclides in 40 CFR 192 Soil Material' Airborne Radon Decay 40 CFR 192 Products External Gamma Radiation 40 CFR 192 Surface Contamination U.S. Nuclear Regulatory Commission (1982) Control of Radioactive Wastes and Residues Interim Storage DOE Order 5480.1A t f'"s Long-Term Management DOE Order 5480.1A; 40 CFR 192 v) t H. REFERENCES International Commission on Radiological Protection. 1977. Recommendations of the International Cn,mmission on Radiological Protection (Adopted January 17, 1977). ICRP Publication 26. Pergamon Press, Oxford. [As modified by " Statement from the 1978 Stockholm Meeting of the ICRP." l Annals of the ICRP, Vol. 2, No. 1, 1978.] International Commission on Radiological Protection. 1978. Limits for Intakes of Radionuclides by Workers. A Report of Committee 2 of the International l Commission, on Radiological Protection. Adopted by the Commission in l July 1978. ICRP Publication 30. Part 1 (and Supplement), Part 2 (and Supplement), Part 3 (and Supplements A and B), and Index. Pergamon Press, Oxford. U.S. Environmental Protection Agency. 1983. Standards for Remedial Actions at Inactive Uranium Processing Sites; Final Rule (40 CFR Part 192). Fed. Regist. 48(3):590-604 (January 5, 1983). U.S.' Department of Energy. 1984. Formerly Utilized Sites Remedial Action Program. Summary Protocol: Identification - Characterization - Designation - Remedial. Action - Certification. Office of Nuclear Energy, l 3 Office of' Terminal Waste Disposal and Remedial Action, Division of Remedial l L Action Prcjects. April 1984.
9 O U.S. Department of Energy. 1985. Supplement to U.S. Department of Energy Guidelines for Residual Radioactivity at Formerly Utilized Sites Remedial Action Program and Remote Surplus Facilities Management Program Sites. A Manual for Implementing Residual Radioactivity Guidelines. Prepared by Argonne National Laboratory, Los Alamos National Laboratory, Oak Ridge National Laboratory, and Pacific Northwest Laboratory for the U.S. Depart-ment of Energy. (In preparation.) U.'S. Nuclear Regulatory Commission. 1982. Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termi-nation of Licenses for Byproduct, Source, or Special Nuclear Material. Division of Fuel Cycle and Material Safety, Washington, DC. July 1982. [See also: U.S. Atomic Energy Commission. 1974. Regulatory Guide 1.86. Termination of Operating Licenses for Nuclear Reactors. Table I.] V lO l \\
. -= - l l 4 O ) l RISK BALANCING: AN APPROACH TO RISK ASSESSMENT AND MANAGEMENT i Thomas L. Gilbert Environmental Research Division Argonne National Laboratory 4 O Presentation for t Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission June 18, 1985 4 i l O
- 4 O BACKGROUND 1 Based on insights gained during the development of U.S. Department of Energy Guidelines for Residual Radioactivity at FUSRAP* and remote SFMPt sites l O
~~FUSRAP = Formerly Utilized Sites Remedial Action Program tSFMP = Surplus Facilities Management Program I~~
O
i O i i GENERAL APPROACH TO ESTABLISHING GUIDELINES Establish basic dose limit Derive guidelines from basic dose limit Establish site-specific authorized limits based on guidelines Establish management criteria for sites that cannot comply O with,imits Apply ALARA* concept to reduce residual radioactivity or potential exposure below limits
~~ALARA = As Low As Reasonably Achievable O~~
. O UNDERLYING ISSUES AND PROBLEMS Distinguishing questions of policy from questions of science Identifying and quantifying benefits, costs, and risks Providing a sound scientific basi.s for risk estimates Taking uncertainties in risk estimates into account Trade-offs: balancing benefits, costs, and risks O Achieving an equitable distribution of benefits, costs, and risks Responding to public concerns, perceptions (and misperceptions) in a consistent and rational manner How safe is safe enough? How much can we afford for risk reduction? l l HOW SHOULD WE ALLOCATE LIMITED AVAILABLE RESOURCES FOR REDUCTION OF DIFFERENT RISKS? O
~~'O MAJOR CONCERN Different government agencies focus on different risks, excluding consideration of other risks Leads to inconsistent regulation:~~
some risks receive much more attention than others, with little regard for relative risks or total risk O "eed for be eacia9 or dirrereat risks O
I lO A RISK BALANCING APPROACH i Guiding Principle: The purpose of government should be to maximize the quality of life and achieve reasonable equity. QUALITY OF LIFE (Q) = BENEFITS (B) - COSTS (C) - [ RISKS (R) + COST OF LIMITING RISKS (L)] O where: Q = Quality of life in a society B = Benefits (monetary and nonmonetary) to all individuals from all societal activities l l C = Costs (monetary and nonmonetary) for all societal activities except ris~k reduction l R = All risks (adverse consequences times probability) l L = Monetary costs for reducing risks to a specified limit
~~O i~~
= _ i l O A RISK BALANCING APPROACH (Continued) There is a maximum, L = Lmax, that a society is willing to allocate to limiting the total risk. The optimum risk management strategy is to minimize the total risk R subject to the constraint that L~= Lux-O O
. A RISK BALANCING APPROACH: MATHEMATICAL FORMULATION N N R n=1 " " n=1 where: n = Index labeling different categories of regulated risk (e.g., cancer deaths from disposal of radioactive waste, fatalities from airplane crashes or traffic - accidents,etc.) W = Risk weighting factor for public concern n R = Total of risks for a given category n L
~~I (Rg) = Cost of limiting the nth risk, which will n~~
nbe a function of the level, R, to which the risk is n reduced l Statement of Problem: 6R/6R =0 n L=L, O i
.. O A RISK BALANCING APPROACH: SIMPLIFIED MODEL r Assume: L = A /R n n n 2 = emP rical constant i where: An Then the risks and costs of risk reduction for an optimum management strategy are: L,=4A/B c Where: B = (1/Lmax) n=1 o
l l ' O i A RISK BALANCING APPROACH: GENERAL CONCLUSIONS A risk category for which the costs of risk reduction are higher should receive a larger share of the total resources allocated i to risk reduction but The allocated share should be limited by allowing the risk for~ O that category to be larger I 'O

~~,_-----,-__.....y_~~

y,-_-, ._,.,._..-__--_____-,_-y_,
10-O t A RISK BALANCING APPROACH: ESTIMATING An 2 A /R L(R -1) - L(R ) = -6L /6R = n n n n n n = cost per fatality averted i (number of fatalities for nth risk)2 A = n x (cost per fatality averted) O 1 e O s, ,.--+-,4-e---y---w._ mv.-, m -,m-,- m- _,,-,my-,,---,m-,,,.,,y--m, ,_,,w.----------g-w---,--.- www- -9w. s
. _ _ = _ _ _ _ _ _ _ __ __ _ =_ _ - - LO A RISK BALANCING APPROACH: SAMPLE CALCULATION Relative Riskt1 Cost per Fatality Fatalities Class of Risk Averted per Year Optimum Actual f Traffic $100,000t2 50,000 1 1 Commercial ~4 -4 2 10 6 x 10 2 x 10 l aircraft $1,000,000t General radwaste -5 -6 3 q practice $10,000,000t 0.1 (est.) 2 x 10 2 x 10 V t1 Relative values of total risk of a given category to all exposed l individuals for W
~~l' n~~
2 1 Crouch and Wilson (from Cohen). 3 t Corresponds to $1,000/ rem. O
_ _ _ _. A RISK BALANCING APPROACH: ELABORATIONS Equity considerations may be introduced by limiting the risk to a critical group or maximally exposed individual. This may be done by redefining R as the risk to a critical n population group or maximally exposed individual rather than the risk to the entire exposed population. Public concerns may be taken into account by using a different weighting factor, W, f r different risk categories. n l t O 4
__._-- --_- -. _- O CONSEQUENCES OF UNBALANCE IN RISK REDUCTION Let R and L be the risk and cost of limiting risk, respec-n n
~~tively, for the nth category of risk with optimum management.~~
~~N R=Ry+RN-1 N-1~~
~~R n=2 c~~
N O ' = '1 + '"-1 '"-1 = E =2 'a n 1 Suppose that R is reduced belort optimum by a factor 1/f. y I i R --* R' =.R /f + RN-1 = R + 6R 1 Because L = L' = L is fixed and R is minimum, the max increment 6R must be positive; i.e., the overall risk must increase. [ l O 1 l' ,w ---,,--,--*w.--y-w

~~.----------,-------------.,wy~~

-r, -.e
_ /~'s V CONSEQUENCES OF UNBALANCE IN RISK REDUCTION (cont.) Incremental Risk Increase for a simple model: L = A /R n n n Case 1: Cost of reducing R below optimum is distributed y among all other risks. (f - 1)(L /LN-1) y 6R = 1 - (f - 1)(L /LN-1) 1 y Assume N large and Ay... A are equal n f = 2: 6R = R /2 y f n 1: 6R = (f - 2)Ry l l Case 2: Cost of reducing R below optimum taken y entirely from cost of limiting R2 l I a s f -* 1 + L / b, 6 R --+ = 2 l l This result (an artefact of the model) suggests that I distributing costs of unbalance may be the better O stratesy
.= - = - REFERENCES Barker, Brent. Cancer and the Problems of Risk Assessment: The Regulatory Role. Health Physics Society Newsletter 13(5), May 1985. (Reprinted from December 1984 issue of the EPRI Journal.) Crouch, Edmund A.C., and Richard Wilson. Risk / Benefit Analysis. Ballinger, 1982. Gilbert, Thomas L. Some Problems of Risk Balancing for Regulating Environmental Hazards. Proceedings of the Fifth DOE Environ-mental Protection Meeting. Vol. 1, pp. 59-76,1985. Gilbert, Thomas L., and Charles Luner. Analysis of Alternatives b for Greater-Confinement Disposal. 00E/LLW-31T. March 1984. International Commission on Radiation Protection. Cost-Benefit Analysis in the Optimization of Radiation Protection. ICRP Publication 37. June 1982. National Academy of Sciences. Risk Assessment in the Federal Government: Managing the Process. National Academy Press, 1983. Rowe, William D. An Anatomy of Risk. Wiley, 1977. U.S. Environmental Protection Agency. Risk Assessment and Manage-i O emt: Fre ework for oecisiom "exiaa. ee^ 5oo/9-8s-oo2-December 1984. _ _ -.}}

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