ML20202D464
| ML20202D464 | |
| Person / Time | |
|---|---|
| Issue date: | 08/30/1974 |
| From: | Nelson J NRC |
| To: | |
| References | |
| SECY-A-75-020, SECY-A-75-020-R, SECY-A-75-20, SECY-A-75-20-R, NUDOCS 9902010403 | |
| Download: ML20202D464 (127) | |
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!yt ADJUDICATORY ITEM
SUMMARY
SHEET-i.
Sub.iect:
As-Low-As-Practicable Proceeding, RM-50-2.
Purpose:
Prt:11minary draft Conmission Decision.
Discussion:
Tre attached preliminary draft is intended for discussion purposes only.
cf the substantive determinations it contains, rathe from an editorial standpoint. Editoriahy, it is being between Dr. Bibb and the Solicitor's office.substa the decision-making process, we reconnend Comission dis-To expe cussion of the consultants' substantive conclusions at an early date.
_Schedulina:
Comission consideration at an adjudicatory session on September ;'17,1974.
e V Jerome Nelson
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Solicitor
Contact:
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Leon Silverstrom X-3483 DISTRIBUTION NO. OF COPIES Secretary *
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Commissioner Anders*
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. August 16, 1974
-Page' 1-Historical background of the liearing Background on Radiation Protection 7
7 A.
Radiation protection standards
'11 B." The linear hypothesis 15 C.
Estimates of risk from radiation 25 Basis for Desiga Objective Values 25 Dosage limi,ts or dosags plus quantity limits A.
36 5.
Individual vs population dose C.
Direct gama radiation from nuclear power reactor 42 and associated equipment 43
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D.
Occupuuoual radiation exposure
.E.
Per' site versus per reactor 47 53 Selection of Specific _ Design objective values 53 A.
Cost benefit considerations 53 1.
Worth of a man-rem
-p 58 Co.st of radvaste systems
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64 3.
The cost benefit balance 67 B.
Choice of Specific Design Objective Guides 1.
For individual light-water"-cooled nuclear power 72
-reactors 2.
Multiple light-water-cooled nuclear power reactor 75 systems
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79 C.
Baseline In-Plant Control Measures 85 Impicmentation of. Numerical Guidelines Guides on Technical Specifications for Limiting 106 Conditions for Operation 4
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Par
~f Surveillance an'd Itaasurements in Operating Plants 111
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Implementation and Backfitting to Existirig Plants 116 Application of Appendix,I to other Facilities 121 O
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.m.m THE STATE T T OF CO':SID2'\\TIONS 9
HISTORICAL EACKCROC D OF THE HEARING The Atomic Energy Cocaission established, in Part 20 of its regulations, limitsforradioactiveemissionsfromlicensedreactors.O These limits were basedonradiationguidesandrecommendationsoftheFhderalRadiationCouncil (TRC) the National Council on Radiation Protection (NCRP) and the Inter-national Co: mission on Radiological Protection (ICRP). The FRC radiation protection guides, approved by th'e President in 1960 and 1961, limit dosages for individual members of the public to 500 millirems per year to the total body and bone I: arrow,1500 millirecs per year to the thyroid and bone. Aver-age dose to the population is limited to 5 recs in 30 years to the gonads (or an annual average dose of 170 millirems per person averaged over the popu-lation). These guides and recoc=endations apply to exposures from all radi-
,ation sources other than the natural background-3! and those employed in m :~- 1 4
procedures. However, these FRC guides contain the further admonition that every effort be made to maintain radiation doses as far below the approved level as is practicable.
On December 3, 1970, the Atomic Energy Commission published in the Federal Register / amendments to 10 CFR 50 that specified design and operating 4
requirements for nuclear power reactors to keep levels of radioactivity in effluebtsaslowaspracticable.5/ The amendments provided qualitative guidance, 1/
- 10 CFR 20.101 et. seq.
The FRC's func on were transferred to the Environmental Protection Agency Pursuant to the President's Reorganization Plan No. 3 of 1970.
3/
- Average' total body doses due to natural background radiation in the United States are in the range of 100-125 millirems per year.
y 10 CFR-50.34a, 50.36a, 35' Fed. Reg. 18385.
The term "as low as practicable" is defined in the regulation to mean "as low as practicably achievable taking into account the state of technology, and the economics of improvements in relation to the benefits to the public health and safety and in relation to the utilization of atomic energy in the public interest.
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but not ""~'r'.??1 Crit,-rio,
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for determining when design objectives and opera-tions$eettherequiretentsforkeepinglevelsofradioactivityineffl ucats as low as practicaole.
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The Cocaission noted, in its Statement of Consideration for tho se amend-ments, the desirability of developing more definitive guidance for definiti
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on of "as low as practicable" and that it was initiating discussions with th e
nuclear power industry and other competent. groups to achieve this goa
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In the FEDERAL REGISTER on June 9, 1971 the Commission published 1
for Psblic comment proposed amendments to 10 CFR Part 50'that wou that part of the regulation with a new Appendix I to provide n s
umerical guides.
- for design objectives and technical specification requirements f t
or limiting
' conditions for operation for light-water-cooled nucicar power re actors to keep
.~~ radioactivity in effluents as low as practicable.
.'Shbsequsatly 'through notice 2,
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published on November 30, 1971 in the FEDERAL
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REGISTER, the Commission announced a public hearing to commence in
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early 1972 on the matter of the proposed numerical guidance.
The rule making hearing
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convened on January 20, 1972 before a Hearing Board consisting of Chairman Algie A. Wells, Esq., Dr. John C. Geyer, and Dr. Walter Jordan
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=ppearing in the proceedings were the following 5 primary participants:
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AEC Regulatory Staff
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- Consolidated National Intervenors -
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_,,,. Consolidated Utility Group General Electric Company i
State of Minnesota In alattion, eighteen persons or organizations, including the Environmenta e
' Pro'tection Agency, made limited appearances.
1 A#36 F.R. 11113.
2)36 F.R. 22775.
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3 As ori;;inally conceived, the hearing was to have been strictly legislativa However, as a matter of discretion, the Co= mission provided1/
in characte:.
for certain important adjudicatory features to be used in the rule caking Th'ese features included the opportunity for questioning of the hearing.
witnesses of other participants, requirements for participants to make appro-priate documents available, and "to produce on request documents on which they rely". Moreover, the Commission provided that its " determination in the rule making proceeding vill be supported by the record.'"2/
The hearing, beginning on January 20, 1972, continued intermittently for 17 hearing days until May 6,1972, at which time proceedings were suspended for preparation of, and receipt of coe=ents on, a Draf t Environmental State-ment (DES) and subsequent preparation of a Final Environmental 'itatement (FES). The DES concerning the proposed rule making was forwarded to the Ommeil on Environmental Quality on January 15, 1973 and was circulated for comment to participants in the hearing and to int;erested Federal Agencies on January 16,
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1973.3/ Some 36 individuals or organizations submitted written coc:ments on the DES.bI Af ter receipt and consideration of these cotenents, the FES was issued on July 26, 1973. In November 1973, as provided for by the Commission, the Public hearings were resumed for consideration of the (3 volume,1400 page) Final i
l Impact Statement and other aspects of the rule making which did not duplicate l
matters dealt with in the earlier phase of the hearing. Consolidated National l
Intervenors, who were I#Supplemental Notice of Hearing dated Jan. 8, 1972 (37 F.R. 287).
t' /
l Supplemental Notice of Hearing dated Jan. 8,1973, Rule 2 (37 F.R. 287).
1 3/
- Notice of availability of the Draft Environ = ental Statement was published in the Federal Recister for Jan. 16, 1973 (38 F.R. 1616 1
4/
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See Final Environmental Statement; Volume III.
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l active during ene first phase of the proceedings, chose not to participate in j
i the environmental portion of the hearing on the. ground that it had limited resources cnd "confidance in the ability of the Regulatory Staff to adequately proeget the public interest."A! The evidenciary hearing was, concluded on Dec.
6, 1973.
The entire proceeding covered 25 days of public hearing and produced 4172 pages of hearing transcript 'and thousands of pages of written testimony i
and exhibits.
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Each of the primary participants, other than the AEC Regulatory Staff, was encouraged to subnit written Concluding Statements of Position following
.conckusionofthehearing. Each of the three pri=ary particinants and one limited participant filed such stat.em. ente.2_,1,1,l/ o.n. or before Feb. 1, 1974.
.hfter receipt and consideration of this material the AEC Regulatory Staff prepared its concluding Statement, / which contained a revised proposed 6
Appendix I differing in several important regards as suggested by evidence at
.the,, hearing, from that originally proposed.7/ The Regulatory Staff published, at the same time,as an Appendix to it,s,C.oncluding St.atement, a set of draft regulatory guides for implementation of the revised proposed Appendix I.s/
,,,_ Ea,ch of the primary, participants was encouraged, as prev.iously arranged,E '
,to, submit written comments on the Concluding. Statement of the Regulatory Staff.-
hro of the primary participants, the Consolidated Utility Group 0/ and the General 1 -
1/ Letter of October 11, 1973 from Karin P. Sheldon to Hearing Board.
2/ Statement of Position by the Consolidated Utility Group, Jan. 19, 1974.
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_3/ Clos,ing Statement of the General Electric Company, Jan. 21, 1974.
f/ Final Statement of Position of the State of Minnesota, Feb. 1, 1974.
1/ Final Statement of Position, Andrew P. Hull (Limited Participant), Jan. 30, 1974.
6/ Concluding Statement of Position of Regulatory Staff, Feb. 20,1974.
1/ See F.R. 11113, 8/ Draft Regulatory Guides for Impicmentation, Feb. 20, 1974.
9/ Sec Hearing Transcript, p
.I0,/ Reply of the Consolidated Utility Group to Concluding Statement of the Regulatory Staff, March 7, 1974.
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l'/~and two limited participants, the Environmental Protection Electric Companyr
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i 2/ a'nd Dr. Andrew ?. Eull3/ submitted such' written comments.
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Agency-Finally, the Cc :ission arrang?d for / and, on June 6, 1974, heard 4
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i from the Regulatory Staff, three pridary participants (Consolidated Oral Argucent Utilities Group, General Electric Company, and the State of Minnesota) and from I
one limited' participant (Dr. Andrew P. Hull).
The Co= mission noted in the Notice o,f Proposed Rule Making 5/
- that:
"The Cozaission has always subscribed to the general principle that, within established radiation protection guides, radiation exposures 1
l This general to the public should be kept as low as practicable.
principle has been a central one in the field of radiation Operating licenses include provisions protection for many years.
Experi-to limit a'nd control radioactive effluents from the' plants.
ence has shown that licensees have generally kept exposures to radiation and releases of radioactivity in effluents to levels well 3
below the limits specified in 10 CFR Part 20.
Specifically, experience with licensed light-water-cooled nuclear power reactors to date shows that radioactivity in water and air effluents has been kept at low levels -'for the most part small percentages of the Part l
l Resultant exposures to the people living in the immediate 20 limits.-
vicinity of operating' power reactors have been small percentages of
, Federal radiation protection guides.
l 1
14, 1974.
1/ Reply Statement of the General Electric Company, March 2/ Letter. with attachment, W. D. Rowe to L. Manning Nuntzing, received I
March 12,1974.
3/ Reply to the Concluding Statement of the Regulatory Staff, Andrew P.
Hull, March 15, 1974.
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I'36 F.R. 22775.
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" ' '.'"'he e-e+ents of Part 50 published on December 3.1970, were,
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.-t-[ intended to give appropriate regulatory effect, with respect to
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radioactivity in effluents from nuclear power reactors, to the qualitat ve guidance of the Federal Radiation Council that i
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The proposed guides set out below are intended to provide quantita-
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1 tive guidance to that end for light-water-cooled nuclear power
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reactors."
We conclude tha,t, while we might.possibly have differed with the
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.r-Hearing Board on occasfonal procedural details, the Board exercised its dis-cretion in an appropriate manner to develop a, record - tested by abundant cross examination - that is more than adequate for fopulation, of a sound rule.
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Accordiagly,. and af ter careful,c9nsideration d the hear:Ing record, we have adopted"a new Appendix I to 10 CFR Part 50 in the form set forth below to provide numerica'l guidance for design objectives and limiting conditions for operation l
to meet'the criterion "as low as practicable" for radioactive material in light-
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water-cooled nuclear power reactors. /
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.!/ The words "as low as practicable" with the definition given in Footnotethe rull supra has been used throughout The eason, we use that language and definition throughout this document.
and the National Council on Radiation Protection Federal Radiation Council The International Commission tese the same words and the same definition.
un Radiological Protection has, in recent years, preferred the wording "as a
low as readily achievable, economic and social considerations being taken' While individuals cry well have a preference for either of 3
into account."
these phrases, we believe that the intent of the two wordings is identical i
f asil that the two phrases are, for all practical purposes, synonymous.
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BACKCROCD ON RADIAT10N PROTECTION Radiation Protection Standards A.
Since its inception, the Atomic Energy Commission has, as a matter of policy, depended upon the reconnendations of the International Commission on Rad Protection (ICRP), the National Council on Radiation Protection and Measurements t
(3CRP), and since 1959, the Federal Radiation Council (FRC), for basic radiation Standards of these groups are compatibic.
protection standards and" guidance.'
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d safety
.They hav2 bcen used by the Cc:=ission as tha basis for regulations an The principles on which exist-requirements in the AEC's regulatory program.
ing radiation protection secadards are based are extensively discussed in the d
for the-
. hearing record ' '1 and are sucnarized by the FRC in their Memoran um 1
1960 which provides official radiation protection Presiden_t dated 18 Ma_7 gguidance for Federal, agencies as follows:
. " Basic biological assumptions. There are insufficient data to provide a firm basis for evaluating radiation effects for all I
There is particular uncertainty types and levels of irradiation.,
., with r,espect to the biological. effects at very low dos'es and low-It is not prudent t'herefore to assume that there is
- dose rates..
a level of radiation exposure below which there is absolute t
This consideration, in addition certainty that no effect may occur.
to the adoption of the conservative hypothesis of a linear relation b"stween biological effect and the amount of.dorse, dett:rmines our basic approach to the formulation of radiation protection guides."
it-NCT.P Exhibit 1, The Development of Radiation Protection Standards, Lauriston S. Taylor, Feb. 16, 1972.
IIHenring Transcript 2034-2061 and 2274-2291.
IIALAP AEC Begulatory Exhibit 1 Tab 1.
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s we, the Atomic As a ca.sult of th:: priniipley st -. trim sbove Energy Comai.sion, are faced with a situation in which no level of i
exposure to radiation can be considered to be without risk, and activit es d out under conditions
- resulting in c::posures to radiation should be carrie such that:
(a) the risks resulting from exposures to radiation are less important than the benefits to individuals and to society l
from activities which result in the exposures; and (b) any further reductions in risk become less important than the effort that would be required to accomplish such reductions.
Taking into account these considerations, the standards groups (FRC, NCRP, I,CRP) have recommended radiation protection guides, numeric permissible doses for workers', limits for exposure to individuals in the p The numerical lation, and limits for average exposures to the total population.
life-maximum permissible dose recommended for radiation workers is.a working h
time average of 5 rems per year to the total body; 30 rems in a year to t e 1
skini, bone, and thyroid; and 15 rems in a year to most other single organs.
I The, numerical dose limit recommended for individual members o the three groups. The ICRP recommends public varies to some degree among w;
annual. dose limits of 0.5 rem to the total body,, gonads, and red bone marro and thyroid, except 1.5 rems to the thyroid of
The NCRP recommends 2/ an annual dose of 0.5 rem to the total bod ith the following qualifications:
, organ
- 1 ICRP Publication 9, September 17, 1965.
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- NCRP Report No. 39.
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"It is, chsrefore.. logical to consider 0.5 rem par yatr as'an upper linit with'very few exceptions.
Special limits such as for skin'or hands, should be set on a '
' lowest practicable basis rather than automatically at on:-tenth the corresponding occupational limit. To have F
no organ or tissue exceed.0.5 rem per year is a reason-able target, but it is arbitrary, of course, and may not always be achievable."
1/
.The FRC has recor: mended a, dose to the individual of 0.5 rem per year; l1.5 rem per year to the thyroid; 0.5 rem per year to the bone marrow; and 1.5 rem per. year to the bone. The FRC provides no specific radiation protection guides with respect to other organs of the body.
All three of the standards groups have recommended that the average dose to the total popuistion not exceed 5 rems in 30 years, which is an
. average annual per eppita dose of 0.17 rem. These dose limits apply to the
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sua total of exposures from all sources o'f radiation other than natural back-ground and those use'd in medical procedures. All of the standards groups emphasize that.no one source of exposure should be permitted to contribute a disproportionate share of the total.
The standards groups.have conditioned the numerical dose limits with qualitative guidance of which the following are typical examples:-
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From the.Internat1onal Council on Radiation Protection
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"(52). As any exposure may involve some degree of risk, the Commission
' recommends that any unnecessary exposure be avoided and that all doses' be kept as low as is readily achievable, economic and social consider-ations being taken into. account..."
1/
- FRC Reports 1 and 2, May 13,1960 and september 1961, respectively.
.'/a ICRP_ Publication 9 - Recommendations of the In'ternational Commission on Radiological Protection (Adopted September 17. 1965).
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to u-o fand from the Federal Radiation Council 1/
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"(5) There can be no single permissible or acceptable level e
of' exposure without regard to the reason for pernitting the 1
It should be general practice to reduce exposure exposure.
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'to' radiation, and positive effort should' be carried out to ful-
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fill the sense of these recommen'dations. It is basic that exposure to radiation should result from a real determination of its necessity."
We, the Atomic Energy Commission, now adopt and as set forth below dosages to individuals from in App'endix I to 10 CFR Part 50, limits on
. effluents from light-water-cooled nuclear power plants that are markedly i
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. lower' than indicated in' the radiation protection standards described above.
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...We do this because no one' type of radiation source should.be' permitted't
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contribute a disproportionate share of the allowable dosage to the popu-
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I' lation and because experience has shown it to be practicable for radio-
- active materials in effluents from light-water-cooled power reactors to We wish to make emphatically clear be maintained at these low levels.
that our setting of these. markedly low'er limits is not the result of any
- new evidence, discovered by us or by others, that would indicate that current radiation standards described above are in any way improper.
Accordingly, the limits set in Appendix I, which apply only to radioactive materials in light-water-cooled nuclear power reactors - do not represent I
a change in the basic radiation protection standards.
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- ^ 1/TRC Memorandum for'the President - tby 18, 1960.
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~% om B. The Linear hypothe' sis As/hcaring record makes abundantly clear,1' 'E! virtually all of the the dats shouing real effects of radiation on the human population are derived from studies of persons exposed to doses greater than those that are presumab1'e under current radiation standards and far greater still than the low doses projected from light-water-cooled power plants conforming with Effects upon the human population of radiation dosage proposed Appendix'I.
levels below 500 millirems per year are so small that they cannot be demon-It is, accordingly, necessary to extrapolate.by
.strated with certainty.
some model or hypothesis from the known effects _at high dosages to the experimentally unobservable effects of small dosages.
Two hypotheses have been developed to predict whether or not effects occur'from dosages at 'these very' low level's. One holds'that a threshold may A
exist at low dosages and dosage rates below which no damage occurs.
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.second, the so-called linear hypothesis, assumes that da= age is proport o Neither hypothesis can be proved or dis-to dose down to zero dose levels.
Data on radiation effects on the human population are insufficient to proved.
demonstrate whether the magnitude of damage.is or is not proportional to the magnitude of dose for all dose levels; if the linear hypothesis were true effects would be so slight at low doses that unmanageably large exposed
' populations would be required to demonstrate the effects in a statistically
.significant way.
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- AEC Exhibit 2, Statement on the Somatic Ef fects of Ionizing Radiation, 1/
l Leonard A. Sogan, Jan. 12, 1972.
-- NCRPM Exhibit 1, The Development of Radiation Protection Standards, 2/
Lauriston S. Taylor, Feb. 16, 1972.
-CUG-T1, Statement on Behalf of the Consolidated Utilities Group, 3/
Morton I. Goldman, March 17, 1972.
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.m National Intervenors (NI) sponsored testimony /
1 by Dr. Ernest J.
Sternglass that would seem, at the least, to cauce serious dot.bts as to the However, the record 'b'b shows conservatist. of the linear hypothesis.
strong disacreement with this testimony; portions of the Sternglass calcu-E Moreover, careful lationsare'shown'b! to contain serious errors.
E of the same data used by Sternglass as well as of additional examination Accordingly, we material appears to produce quite different conclusions.
find the NI testimony unpersuasive on this point.
The State of Minnesota also sponsored testimony !
b to' indicate that the linear hypothesis lacks any element of conservatism, but the State seems to suggest that the linear hypothesis should be used.
Neither General Electric Company (GE) nor the Consolidated Utilities Group (CU) spokesmen attacked the linear hypothesis directly, but both appear, be-
'at times, to challeng'e this " assumption of a direct linear relationship CU states / " Proposed 6
tween biological effect and amount of the dose.
Appendix I f ails adequately to reflect the negligible and possibly nonexis-tent biological impact to individuals and population groups of the dose levels GE states / "Indeed these 7
at which its proposed numerical values are aimed.
dose levels are so lov that increasing the levels by factors of 5 N 10 would i
result.in no detriment to the public and hence such an increase could be 17, 1972.
NI-2 Summary Testimony of Dr. Ernest J. Sternglass, Marc l
1/
AEC-15 Rebuttal Testimony Concerning the Direct Testimony of Dr. Ernest 2/
J. Sternglass, Dr. Marvin Goldman.
AEC-14 Rebuttal Testimony Concerning the Direct Testimony of Dr. Ernest 3/
J. Sternglass, Dr. Edythalina Thompkins.
28, 1972.
4/ GE-2 Rebuttal Testimony, Dr. Richard I. Post, April 5/
Testimony of Arthur R. Tamplin.
Minn-1:
/ Statement of Position by the Consolidated Utilitics Group, Jan. 19, 6
1974, p. 8.
21, 1974, Summary of General Electric Company Cloring Statement, Jan.
7/
- p. 4.
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justified, if necessary, on the grounds of af.inistratite convenic:ce aloce."
It is clear from these and similar statements from GE and CU that they are
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convinced that the linear codel.is excessively conservative.
Limited. participant Andrew Eull presented testimony 1/
to indicate that 'the 31near hypothesis overstates the population damage by a considerable and, perhaps, excessive margin.
...t..Dr. Lauriston S. Taylor, President of the National Council on Radiation Protection'and Measurements, stated of the. linear hypothesis in his written
. testimony:2/
"It is well known that such a simple relationship usually
- does not hold, and that simple extrapolations from high-dose.
r-effects co low-dose effects are most likely to err in varying
. - degrees on the safe' side; that is, the effects at low dose and
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_ low dose-rates will,-almost certainly be less' than predicted on'~
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,.. a. basis of simple extrapolation..Such a model ignores the
_.. existence of dose-rate effects and, hence, biological recovery ta.a bio-system exposed to radiation. Never.theless the model is
....useful for giving some kind of upper l'imit of dose effect."
inn have, in keeping 'with the preponderance of evidence on the record, shYul~ea 1.he'usefbliEess' of thI lisea'r h'y'pothesis 'tliat damage 5.s proportional co
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dose at.all. levels._._We.do this,. An_ common with the ICRP, the NCRPM and the FRT, to' assure a reasonable conservatism in assessment of radiological damage; our
-- Final Statement of Position, Andrew P. Hull (Limited Participant), Jan. 30, 1/
1974.-
E auriston S. Taylor, "The Development of Radiation Protection Standards,"
L NCRPM-1, February 16, 1972, pp. 19 and 20.
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- )4-yrw assu=ption, as theirs,' implies no en'dorsement'of the scientific validity of Indeed, we recognize that assumption of this hypoth-the linear hypothesis.
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esis deviat2s from the approach generally used in toxicology.
We, neverthe-3 i.
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less, accept the' linear hypothesis, for purposes of this rule-making and at i
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. least until such time as an alternate hypothesis can be scientifically sub-stantiat'e', because we firmly believe that it is prudent to assume a model d
We that is likely to establish the maximum level of risk to the population.
believe that the actual risk _ associated with any small dose probably falls somewhere between zero and the level defined by the linear hypothesis.
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+wn Estinttas of Risk from Radiation
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C.
it If radiation effects are to be understood in proper. perspective, is important to remember that people are continually exposed to radiation from several natural sources. These sources include: cosmic radiation a
from outer space, radiation frem natural sources in the ground and in the air, and radiation from within their bodies that has as its source the natural' radioactivity in wate'r and foods. The contribution from ea'ch of these sources varies, depending upon such factors as altitude. geographic Within the location, personal habits of individual persons, and diet.
United States the average yearly exposure from all such natural cources is To this " background" (and inescapable) exposure the about 125 millirads.
radiation' dose from other human activities - principally that from medical x-rays - must be added. The average annual. dose from medical x-rays,in the United States is estimated to be approximnely 150 millirads to the bonc marrow and 90 millirads to the gonads.1/ Accordingly, rad.iation exposure from human activities, coupled with that from natural sources, results in an average annual exposure to individuals in this country from all sources of approximately 300 millirads.1/-
It is, of course, well known that exposure to very high levels of radiation produces biological effects that can be detected both in animals oFin persons exposed (somatic effects) as well as in their off-spring
~
(genetic effects).
and Dr. Dean A. Parker ! estified on behalf t
Dr. Leonard A. Sagan hftheAECStaffonthesomaticandgeneticrisks,respectively, associated with lov level radiation to population groups in the population dose ranges NALAP AEC Exhibit 2. " Statement on the Somatic Effcces of Ionizing Radiation," Leonard E. Sagan, Jan. 12, 1972.
- ALAP AEC Exhibit 3, " Statement on Cenatic Effects of Ionizing Radiati. n,"
2/'
Dean R. Parker, Jan. 7, 1972.
e b
am mm, o
Aagw -
16 Both stressed the absence of any scientific estimated for Appendix I.
evidence of biological effect at these dose levels and both emphasized observed effects at dose that their estimates were extrapolations'from Both also stressed that their levels many orders of magnitude higher.
calculations were. based on the conservative linear hypothesis that biological ef fects were linearly proportional to the dose received' and were independent of dose rate.
On this basis Dr. Sagan concluded:
"For each one million people exposed to 1 millirad a maximum of l
.,,. ~.
- 0.14 cases of cancer would occur during the lifetime of the exposed population,/ n addition to those which would normally be
'2 i
expected in a population exposed only to natural background raatation (about 250,000).
It is e=phasized that the estimates discussed above are upper The true value estimates based on highly' conservative hypothesis.
for increase in incidence of cancer at these ver'y low dose levels i
i lies somewhere between zero and these upper estimates."
l Similarly, Dr. Parker / estimated the possible increase in congenital 1
" diseases associated with low level exposures to large population groups.
i Assuming 4 million live births per year in the United States, he cone uded:
l "With no added exposure, above natural background, the annual rate 0
would be 240,000 (6.0 x 10 x 4.0 x 10 ).
Af ter a single generation
-2 of' exposure of the total population to an extra 1 mrem per year, this number would increase to nearly 240,002, and when equilibrium is ALAP AEC Exhibit 3 " Statement on Genetic Ef fects of lonizing Radiation," Dean R. Parker, Jan. 7,1972.
-- Application of the linear hypothesis would yield the result that exposure 2/
1 -i'linn acanlo encS to 1 millirad per year would cause an additional nF
17 m.-
ld reached after some 10-20 generations of exposure the incidence wou 6
-2 x 4.0 x 10 ),
plateau at about 240,016 (6.0004 x 10 I wish to temper this estimate by again stating that it is based on
~
ill truly the assu=ption that linear extrapolation to low doses w The existence of dose-rate effects and predict genetic effects.
other evidences of repa'ir of premutational damage do not lend credi-bility to the supposition."
Both Dr. Sagan / and Dr. Parker / testified that if the average 2
1 i
population dose were to be assumed to be 0.1 millirad or millirem, t calculation of biological effects would be louer by a factor of ten.
3/ and The State of Minnesota both in cross-exa=1 nation of'Dr. Sagan-b! contradicted Dr. Sagan's in the direct testimony of Dr. Arthur Tamplin iderably position that effects on humans were observed only at dosages cons Br. Tamplin, higher than the radiation protection guidelines of 500 cm/ year.
primarily on the basis of publications of Stewart
- and MacMahon !n-2 i dicating an increase in childhood cancer and leukemia following in utero d
' irradiation, presented evidence that ef fects on humans have been observ at dosage levels at or below the previous 500 millirem / year guideline
! earing Transcript,p. 1061.
H 2/
1064-65.
-- Hearing Transcript, pp.
3/
-- Hearing Transcript, pp 453-57.
-- ALAP Minnesota Exhibit ', Testimony of Arthur R. Tamplin.
4/
1185-1187 (1970).
E! ewart,A., and G. W. Kneal, The Lancet },,
St Med. J. 1, 1495-1508 (1958).
-- Steward, A., J. Webb, and D. Hewitt, _Bri t.
6/
28, 1173-1191 (1967).
-- MacMahon, B., J. Natl. Cancer Inst.,
7/
e l
l g e
'**pe me e
l l
-~
i
+H 1
18 In its Final State =ent,-/ The State of Minnesota, relying upon the 1
BEIR Report, / indicated risks dif fering slightly from those presented by 2
For example, Minnesota quotes: /
3 Drs. Sagan and Parker.
"Such calculations based on these data from irradiated humans lead to the prediction that ndditional exposure of the U.S. population of 5 rem per 30 years could cause from roughly 3,000 to 15,000 cancer deaths annually, depending on the assucptions used in the calculations.
The Committee considers the most likely estimate to be approximately 6,000 cancer deaths annually, an increase of about 2% in the spontaneous c'ancer death rate which is an increase of about 0.3% in the overall death rate from all causes."
,,,And, in addition /
4 "A major! concern of the Subcom=ittee is the possible existence of a
~
class of radiation-induced genetic damage that has been left out of
...;;the estic'ates..By relying so heavily on experimental data in the
--.. mouse we may have overlooked important effects that are not readily l
,de,ected,in mice, or the mouse may not be s. proper laboratory model l
t for the study of man.", _
__,1,t sh, uld be noted that the BEIR Reports "most likely estimate" of o
6,'000 additional cancer deaths annually per 200 million people exposed to 5 rem per 30 years is equivalent to 0.176 additional cancer deaths annual.'y per l
million people exposed to 1 millirem per year; this figure agrees closely with Dr. Dagan's estimate of 0.14 additional ' annual cancer deaths per million 1
people exposed to 1 millirad per year qv.ated above.
-- Final Statement of Position of The State of Minnesota, Feb.1,1974, 1/
'pp. 5-8.
2/
-- NAS-NRC, The Ef fects on Populations of Exposure to Low Levels of Ionizing I
l Radiation (The BEIR Report), Repcrt of the Advisory Committee on the Biological Effec'.s of Ionizing Radiation, November, 1972.
l 3/
-- NAC-NRC, ibid, p. 2.
l I
l
s 19 wm Some testimony / presented for National Intervenors, Incorporated 1
(NI) gave a slightly different estimate of th'e risk to the population from In this testimony Dr. Edward P. Radford stated:
low icvels of radiation.
"On the assumption of the linear dose-response hypothesis a continuous k
exposure to 1 mrem /yr would on the other hand increase the cancer ris by only 0.004% to 0.02%, a risk which I believe any reasonabic person would conclude to be sufficiently small to be considered negligible.
The new proposed standards attempt to reach a level of risk which is still acceptable and yet not so unnecessarily restrictive as 1 mrem /yr would be.
Given this order.of risk, the decision of the figure to adopt for acceptable levels of exposure to man becomes a matter of judgement.
- In my opinion the proposal of a whole oody dose of i mrem per year is quite acceptabic, and indeed may be too restrictive, if only be-cause it will be difficult to monitor effluents at levels consistent with this low exposure rate."
d' Dr. Radford's testimony, both written and under cross examinatie made clear, however, his personal 3/ concern that present radiation protection 1!
Dr. Radford stated:
standards may be too lenient:
'."From the most recent evidence of cancer risk to man, I consider that a continuous lifetime dose of 500 crem per year vould increase the risk of cancer by 2 to 10%, in my opinion an unseceptable risk to an individual not directly benefitting from the source of the risk."
ALAP,NI Exhibit 3, Testimony for U.S. Atomic Energy Commission Hearings 1
from Nucicar on Standards for Release of Radionuclides to the Environment
. Facilitics.
2/
- licaring Record, pp. 2067-2068.
3/
- llearing Transcript, p. 2090.
w,.,
4., e,a mH 30 rec:rd' that the nur.bers quoted ir.ediately It is cicar fr:m th:
3/
above are Dr. Radfords'own estimates-derived through his pr'rticipation in preparation of the BEIR report whose conclusions (and the similarity of these conclusions to those of the Regulatory Staf f witnesses) were
~
It is also clear / that the phrase "new 3
briefly summari=cd above.
evidence" is intended to mean reworking and improved modeling of data diready in the published literature, and that Dr. Radford's estimates dono[differsubstanticilyfromthoseofDr.SaganandoftheBEIRreport.
4/ seemed to indicate Other testimony presented for National Intervenors-considerably hisher risks to the population from low levels of radiation.
~
4 5/
Dr. Sterngla:,s asserts,-
"As will be shown below, all the recent statistical studies on large h'uman popu stions carried out by a number"of indepenaent investigators
~
~
h n'ot conni.
2d with any government 'ag'encies lead to approximately t e isme dotes.sien, namely that an additional d'ose of only 1 millirad per year from fission products in the environment or 1% of normal background
~
~
ridintion,1 cads to about a 1/4% of 1% increase in mortality rates both for the newborn and the total population."
and further,4/
-n
.ur c__.t:.:.
T' the data as summarized below suggest that the radioactive "In effect, material created in the course of nuclear operations are somewhat more 9
toxic than the radioactive elements normally found in our environment, since the typical background radiation of close to 100 mr per year is believed to be responsibic for only some 5-207. of all chronic diseases, 1/
- Hearing Transcript, 2064.
2/
- Hearing Transcript 2090.
-H3/ earing Transcript, 2096-99.
- ALAP NI Exhibit No. 2.
Summary of Testimony by Dr. Ernest J. Sternglass, 4/
March 17, 1972.
5/
- !! eating Transcript, 1913-1919,
~.
-.. ~.
wpa 21
" ' 'T emAi etncars and genetic defects, viile the radioactive materials created
'in the course of nuclear operations seem.to lead to a 25% to 100%
' increase in mortality for a similar annual dose of 100 millirad."
Again the record indicates. strong disagreement with the conclusions 1'
seem to us to present and of this t:estimony. Rebuttal witnesses '-
there are serious shortcomings in the statistical sustain the position that choice of data,and the interpretations indicated in this methods, tha testimony. While we are aware that, as Dr. Sternglass and others point out, the developing embryo and the young are more sensitive to radiation than is to the risk estimates the adult population,we are unable to give weight provided by Dr. Sternglass.
Mr. Andrew P. Hull, a limited participant, also presented written testimony as to radiation risks. His calculations suggested that exposure of 2 million people to 1 millirem per year would produce a mortality rate of 0.2 per year and contrasted this value with the value of 400 per year I
l from natural disasters.
5/
In its Final Environmental Statement the AEC Staff based its estimates of the upper 1%it of biological risk on the BEIR report rather t.han on the l
j However, the conclusions testimony of Drs. Sagan and Parker notedsabove.
l as suggested in the preceding paragraphs, sub-of' the BEIR report are not; stantially different from those of Drs. Sagan and Parker.
M LAP Regulatory Staf f Exhibit 15 Rebuttal Testimony Concerning the Direct ATestimony of Dr. Ernest J. Sternglass, Dr. Marvin Goldman.
ALAP Regulatory Staf f Exhibit 14 Rebuttal Testimony Concerning the Direct 2/
Testimony of Dr, Ernest J.-Sternglass, Dr. Edythalina Thompkins.
i 28, 1972.
NALAP G.E. Exhibit 2 Rebuttal Testimony, Dr. Richard I. Post, April 4/
20, 1974.
- Final Statement of Position, Andrew P. Hull, Jan.
ALAP Final Environmental Statement, Wash-1258, July 1973, Vol 1, p 9
u e s.
~~
- - - =
~
6t '
'~~.%,
C as..i It is apparent that, although there are disagreements regarding the
)
degree of conservatism in the' calculations, and although the State of Minnesota warne / " Prudent public health practice requires the upper limit -
1 l
estimate of effects :Ln The BEIR Report to be used when setting standards I
and regulations," there seems to be a gratifying consensus as to the magni-l tude of the risks to the population from small levels of r'adiation.
1 Moreover, it seems to be very unlikely that effluents from light-water-cooled nuclear power plants will in the foreseeable future, if ever, i
\\
expose the population at large to dosage levels as high as 1 millirem per Mr. Rogers and Dr. Gamertsfelder have stated 2/ that, assuming a 500
~
' year.
millirem per year dose from noble gases to the most exposed individual at the boundary,
"[u] sing realistic population distributions and wind direction j
frequencies for 11 different power reactor sites, the theoretical
]
average' population dose rate for the whole population included
, ithin a circle with a radius of 50 miles of these plante would be
~
w approximately 1 millirem per year."
Thus, in terms of Appendix l's much lower dose. objective to the " worst
~' '
case" individual, the average annual dose from noble gases to the general population within 50 miles would be less than 0.05 millirem.
-~~~
l IIFinal Statement of Position of The State of Minnesota, Feb. 1, 1974, p 7.
2/
-- ALAP AEC Staf f Exhibit 11, L. Rogers and C. Gamertsfelder, U.S. A.
Regulations for the Control of Releases of Radioactivity into the Environ-ment in Effluents from Nuclear Facilities 133 (1970).
e
W4h lT 1
9 L. k.. :
eu.
23 Testimony by witnesses for the Utility group generally confirm that population doses from gaseous' effluents would be in the range suggesi Dr. Walton A. Rodger's calculations,1/
Mr. Rogers and Dr. Gamertsfel'dcr.
showed' that for noble gases assuming 5 millirem to the worst case individually at the boundary, the average annual dose to the general population within 50 miles would be 0.02 millirem..
2/ treatment of general population dose frem Dr. Morton I. Goldcan's-gaseous cffluents show that for over fifty plants evaluated, plant contri-butions to dose to the general population.within 50 miles'would average about 0.01 percent of background doses within the same region, and would 0.01-0.014 millirem per I'
correspond-to a general population dose of about I
year due to gaseous effluents.
l-As to contributions to general population dose from liquid effluent L
3/ and in his summary of
-sources, Dr. Gamertsfelder in his written testimony-i that testimony / estimated that the average annual dose to populations using l
'4 l-l drinking water from the natural bodies of water into which the effluents of Dr.
currently operating reactors flow is less than 0.01 millirem.
G'amertsfelder added that since populations near some reactors presently or 'under construction will be higher than the populations around existing l'
l i
j-4 19, 1974, p 22.
1 Statement of Position by Consolidated Utility Group, Jan.
lidated Utilities
-- ALAP UG-TI, Statement by Morton I..Goldman on Behalf of Conso 2/
Group, March 17, 1972, p 17.
ALAP'AEC Staff Exhibit 3,
'4/ esring. Transcript, pp.39-40.
-- li e
.. - - - ~. _. ~. _.
4
+-
a f
I
)
24 l-plants,. the total population dose could be higher than 0.01 millirem,
}
~
l provided these larger populations actually'obtain their drinking water from the water bodies into which liquid effluents flow. Even for any planned sites where the general population doses from liquid effluents-might be higher than 0.01 mil'lirem, Dr. Gamertsfelder stated: "{i]t is not expected that the average annual whole body dose to individuals in a large 4
population would be any larger than about 0.1 millirem for individual reactors operated within the proposed design objectives."
.c From the foregoing it seems clear that operation of light-water-cocied
. nuclear power plants - even in very substantial numbers - under the Appendix I guide lines should not expose the population to levels as high as.0.1 millirem per. year. That fact when coupled with the risk estimates l
. ccc.
'. detailed above should lead to a very small (though not completely
)
,/n'egligible),risktothepublichealthandsafety.
[
_ f..
c I-M e
f e
e e
g 4
i<
I'
m_,
Y -
BASIS FOR DESICN OBJECTIVE VALUES
,w,i Dosage Limits or Dosage Plus Quantity Limits
. A.
The AEC Regulatory Staff originally contended that, although dosage levels to off-site individuals were the basic criteria for the design objectives, such dosage levels should be limited by sp'ecifying, limitations on quantities and concentrations of radioactive materials in effluents
~
from light-water-cooled nuclear power plants. / For example, it was state 1
"As explained in the preamble to the Notice of Proposed Rule. Making the design objectives are expressed in the proposed guide as limitations on The quantities and concentrations of radioactive material in effluents.
power reactor and associated waste treatment equipcent would be designed to make it unlikely that the specified quantities or concentrations would be exceeded during normal operation, including anticipated unusual occur-The specified quantities and concentrations would generally limit rences.
exposures to members of the public living near the s1.te boundary to about 5 millirems per year from radioactive material in liquid effluents and about 5 millirems per year from radioactive material in gaseous effluents.
As a practical matter it is not likely'that a given individual would be exposed to both liquid effluents and gaseous effluents at a icvel approach-ing 5 millirems per year from each source."
and,further:E'O "The basic criteria for the design objectives are the limiting dose of l
5 millirems per year to individuals of fsite from radioactive material 1 ALAP AEC Regulatory Staff Exhibit No. 1, Tab 1, pp. 13-19.
2/
- Reference 1, this page, p. 13.
OALAP AEC Regulatory Staff Exhibit No. 1, Tab 1, p. 14.
4/
- Hearing Transcript pp 25-26.
C %,4 wre 26 in 11guid ef fluents and 5 millirems per year to individuals offsite from radioactive material in gaseous effluents. The specified quanti-ties and concentrations are substantially more conservative than would be required to meet these doce limiting criteria for many sites."
~
During, and as a consequence of, the Hearing the Regulatory Staff modi-The version of Appendix I presented in the Staff's fled its position.
no longer specified concentration limits on tritium Concluding Statement and other radioactive materials released to the environment but did inicude
- in addition to limitations to the dose to any individual in an unrestricted area -- limits upon the quantity of radioactive material (except tritium and dissolved gases) in liquid effluents and upon the quantity of iodine which could be released.
The Staff position that both offsite h and quantity li=itations should be required is clearly intended to remove the possibility that future land use The Staff patterns in the neighborhood of reactor' sites might be prejudiced.
states:1
" Basically at issue here is the extent to which site-released parameters should dictate design objectives and the nature of the assumptions that should be used with respect to those parameters, such as the present and future uses of the environment."
and:E' "It is the Staff's position, for example, that for purposes of design objectives for nuclear power reactors it is inadequate to base parameters only on uses of the environment as of the time the reactor is designed 1/
- llearing Transcript pp 25-26.
- Concluding Statement of Position of the Regulatory Staff, Feb. 20, 1974, p 50.
2/
!Ibid., p. 52.
4/
- See also !! caring Transcript, pp 343-344.
?!
27
,w.
Rather, future uses'of the env,1ronment should be taken and constructed.
into'af. count'and those uses n'ot foreclosed by installing. inadequate vaste treatrent systems based on offsite dose calculations that take into ac-count only present uses of the environment."
and, further:1/
"If design objectives are based on estimates of individual doses offsite t
alone, failure to assune in models future uses of the environment could, for some particular sites where the site environs are not being 'used at time of construction of the reactor, result in designs of radwaste systems that do not use even the rudimentary, readily available technology to reduce releases so that large quantities of radionuclides could be released.
As future uses of the site environs develop, backfitting might.well be required to meet.the dose objectives."
The General Electric Company (GE) argued consistently throughout the hear-Lag'E'b'E!. that specification of quantities.and concentrations of emitted radioactive materials is unnecessary in light of the primacy of the dose criteria On this aspect of the and is, furthermore, undesirable for several reasons.
original Appendix I, Mr. Smith testified 1! as foll'ows on behalf of the General Electric Company:
s "The General Electric Company feels that Sections II-A and B of Proposed Appendix I, the sections containing the emission quantity and concentration guides, should be eliminated. - Failing that, these quantity and concentra-1/ oncluding Statement of Position of the Regulatory Staff, Feb. 20, 1974, p. 53.
-C 1'/ALAP CE Exhibit No. 1, March 17, 1972, pp 7-13.
3/llenring Transcript, pp 1435-36.
4/
- Closing Statement of the Cencral Electric Company, Jan. 21, 1974, p 13.
5/~ EeP y Statement of the General Electric Company, March 14, 1974, pp 43-48.
l l
i l
i i
.....m.,
~ - -..
~... -
-. - ~
%.-e
%'2*-
- p. i}
%wi 28 tion jdd::: %::1d at least be emoved from their present position of j
prominence in Appendix I.
"We believe these changes are desirable, since first the quantity and
^
~
Lw
~
t L
concentration guides lack independent signific'ance. They do not protect l
any public interest in their own right, but are merely offered as a shor~tcut means of 'd'emonstrating compliance with the dose objectives of I
L Section II-C.
i "Second, the quantity and concentration guides do not perform their intended function. That is, they do not provide any significant savings
}
of calculational effort.
" Thirdly, if applied, the guides of Section II-A and B would le'ad to
. costly overdesign of nuclear power plant effluent treatment systems.
"And fourth, although they are intended to provide merely one alternative method of satisfying Appendix I, inclusion of the quantity and concentra-tion guides is affirmatively undesirabic, especially if they retain their L
present position of prominence. These guides will lead to substantial misunderstanding and confusion regarding compliance with effluent emission criteria. This confusion will inevitably adversely affect public accep-
'\\
tance of nuclear. f acilities, and it will distort the evaluation of plant applications during licensing."
l CE con'tinues to urge ' - that the remaining quantity limits be eliminated from Appendix I.
They argue,2/ in the case of the limit upon radioactive materials s
(
in liquid effluents:
l l Closing Statement of the General Electric Co=pany, Jan. 21, 1974, p 13. L 2/ - Reply Statement of the General Electric Company, March 14, 1974, pp 43-48 I e e j l
a.
- 34 29-
- "....these lhsits are directed toward matters of completely subsidiary importance -- the absolute level of pla:it emissions -- rather than to diation exposure. the parameters of basic concern - the icvels of human ra resulting from L E cffluent releases and the measures appropriate to By imposing quantity limits in addition to the minimize these exoosures. basis dose objectives, and applying "whichever [ provision) is more restrictive" (Staff Concluding Statement, p. 55), the Staff's new.recem-f dose formulation would h . mendations jeopardize. the advantages that t e otherwise provide -- namely, an ALAP regulation that is fitted to th; i-particular characteristics of individual plants and sites and that en-l. courages the applicant's choice of a favorabic site. Second, the proposed quantity 1 mits are ill-chosen in view of the Staff s The stated basf
- far the 5 curie per year liquid
^ 5 underlying concerns.' (pages ef fluent limit, as indicated in the Staff's Concluding Statement 55-56), is the concern that releases satisfying the fundamental dose-build-limiting objective may nevertheless cause an undesirable long-term ify up of radio delides in some circumstances.. No such concern can just AP record the 5 curie limit,-however,-since there is,no evidence in the AL ' to indicate that.any.significant long-term build-up of radionuclides can occur as a result of LWR liquid releases." I l d h and, with regard to th'e limit on quantity of radiciodine to be release, t ey l f statedt ar limit '"Likewise, the concern underfying the Staff's new 1 curie per ye on 1-131' releases seems to be a belief that, if limited only by a dose l build and operate. -objective Jor-radioiodine emissions, licensees vil l '. n c. > March 17, 1974, p 46. y - Reply' Statement.of the General Electric Compan, 1/
+,.... 44w 30 reactors that 'do not use even the rudimentary, readily availabic tech- ~ nology to reduce releases' and consequently will ' release large quanti- ,...a ties'of [ radio] iodine simply on the basis that no cows are located within many miles of'the reactor at the time of construction.' The ALAP record, 'however, demonstrates that such an eventuality is not a realistic pos-sibility with regard to EliR's." The Consolidated Utilitics Group (CU) also argued consistently that In its Conclud-quantity and concentration limits be omitted from Appendix 1. ) 1 ing Statement CU argues as follows: "Although there was uniform support for the belief that dose is and should i I be the primary basis for numerical guidance on the "as low as practicable" thece was also recognition of the administrative difficulty
- concept, associated with practical application of the dose objective, since at the range of very small exposure levels contemplated under Appendix I, it is generally agreed that most doses 're not subject to accurate measurement a
with presently available techniques and equipment.. Consequently, from the standpoint of measurement and control, we have no quarrel with the principle that limits must be set on releases from specific nucicar power . plants. The important issue is therefore not whether the Commission should estab-I f lish limits on radioactive ef fluents for inclusion in individual plant One operating licenses, but how those limits are to be established. approach, which we believe to be wrong, is to sta ndardize effluent limits if not all, plants would assure compliance with at a level which for most, - Statement of Position by the Consolf dated 'Jtility Group, Jan. 19, 1974, pp 1/ 51-52. e
P_ I 'd sm 32 Staff's sudden proposal that a 5 curic limit bc superimposed on the' 5 mrem dose objective as a limit in its om 4right." 31 And in its-discussion of the limit on release of I from each reactor, 1! CU argues! "The Staff further proposes an over-ride limit on I-l' 1 which can be 3 released from each reactor of one curie per year. The proposal is ncy and has no foundation in the record of the proceeding. The Staff justi-fication for adding this limit is in essence that there could be reactor i sites so remotely located that the measures required to meet Appendix I dose objectives for the nearest individuals could be so minimal as not i not to include even those augments which.can be justified on the basis of total population dose reduction. As a practical matter we believe ~ there vill be very few sites at which this condition could occur." The propriety of this c=phasis on dose was strongly supported by Dr. s' Taylor, testifying ' on behalf of NCRP, by Dr. Eisenbud, who made a limited appearance on behalf of the Atomic Industrial Forum and by R. M. Hartman who made a limited appearance on behalf of Ebasco Services, Incorporated.. The National Intervenors endorsed this position; Dr. Radford6/ stated that: '"The concept proposed by the Atomic Energy Commission that the standard should indicate an acceptable millirem dose per year... is superior to l .the idea of maximum permissible concentrations, formerly applied by the Atomic Energy Commission." E 'L/ eply of Consolidated Utility Group to Concluding Statement of Regulatory -R Staff, March 7, 1974, p 13. -2/ earing Transcript, pp -H 1737-38. 3/ - Ifearing Transcript, pp 2055-56. / earing Transcript, p'88. 4 H .5/ - llearing Transcript pp 109-116. 6/ - ALAP National:Intervee ~. ^^'u~
P 1 ne.a das 33 ,In addition, limited participant Andrew P. Hull said in his final statement: +. ir "Furtharmore, considering the' highly variabic nature of nuclear reactor i sites, I believe that the specification of release and concentration
- limits,' over and above'an overall exposure limit, is also unwarranted and in many if not most cases would lead to significant expenditures for protection against non-existent or completely inconsequential risks."
On the other hand, the State of Minnesota has consistently argued '1'- E that quantities and concentrations of radioactive material released should be j minimized. Although it is clear that Minnesota's intent is the protection of j individual $andespeciallythosenearnuclearfacilities,the'languagerecommended in its Final Statement / suggests that Minnesota would give primary attention to 5 quantities and concentrations of radioactive materials released. We, the Atomic Energy Cocaission, certainly agree with the overwhelming j preponderance of evidence upon the record that the primary purpose of Appendix I is the protection of the public from radiation dosages resul' ting from radio-- active materials in effluents from light-water-cooled' nuclear power plants. ~We further agree that Appendix I should be written to make clear the primacy L Af_ controlling such dosages. We agree that the Regulatory Staff was correct in removing the concentration limits for radioactive caterials in liquid effluents from light-water-neDied nuclear power reactors from its version of recommenited Appendix I.b fibether li=its upon quantities of radioactive materials to be released should be specified in addition to limits upon doses to people is a more compicx qustion. 11, 1974, p 4. 1_/ Final Statement of l'osi; ion, Andrew P. llull (limited Participant) Feb. 2/itearing Transcript pp 177841779. ))tFinal Statement of Position of State of Itinnesota, Feb.1,1974. r
- innesota, Feb.1,1974, pp 21-22.
h,fTN1b5$$$$n $n $$o Ih7 S a e o ~ o Statement of position of the Regulatory Staff, Feb. 20, 1974, pfConcludingA-?7, .. - -pp.11 arm
m#q ~ 34 It is obvious that, especially at the lov levels of Appendix I, many of i h existing - the doses are not in themselves subject to accurate measurement w t n-Consequently, the quantities and concentrations as techniques and equipment. be measured, well as the identities of the radioactive materials released must This is, of and the d'oses must be 1Eferred by, calculations from these. data. course, a basis for argument for inclusion of limits upon such quantities in moreover, impressed with some of the arguments against the rule. He are not, l We are, for example, not persuaded of GE's claia inclusion of such limits. that: "These guides { chat is those containing quantity limits] will lead to substantial misunderstanding and con' fusion regarding compliance with effluent emission criteria." 2/ 3/ We do find persuasive, however, the arguments advanced by GE-and C" l that imposition of quantity limits of the magnitude proposed by the Regu atory i i would otherwise . Staff could jeopardize the advantages that the dose lim tat on provide (namely a regulation that is fitted. to the particular characteristics i 1 of individual plants and sites and that encourages the applicants choice of It is clear that the Regulatory Staff in stating / about an 4 l' a favorable site). . earlier formulation of the rule "The specified quantities and concentrations are substantially more conservative than would be required to meet these dose limiting criteria l for many sites." We have, accordingly, adopted an recogn,ize sode. validity to this argument. s/ eference 3, page 27, R 2/ eference 2, page 28. R 3/ -- Reference 1, page 30, - References 3 and 4, page 25 of this Statement 4/
~ .a . ii schah 35 Appendix I that does not specify quancity or concentration limits for the We expect, as effluents from light-water-cooicd nuclear power plants. recocciended by CU,1/. that licits on quantities of radioactive materials, other ~ <. than tritiu a and dissolved gases 16 liquid ef fluents, would be incorporated in the technical specifications of the individual plant operating license. i Though we do not include quantity limits in ^ppendix I, we do agree with the Regulatory Staff argument that "it is inadequate to base parameters only,on uses of the environment as of the time the reactor is designed and constructed." f ) We certainly wish to assure that the rule cannot result in approval of " designs of radwaste systems that do not use even the rudicentary, readily available technology to reduce release -." We do not believe that the nuclear indastry we note'that -has intentions of doing this, and/both GE and CU declare that nothing of the We consider it obvious, however, tha't our responsibilities sort will be done. to the people cannot be satisfied by an Appendix I that depends upon the Accordingly, continuing good will and gobd' intentions of any other party. although we have not included quantity limits, we believe - as described in l_ detail in a subsequent scetion - we have by another and more justifiable l f the . mechanism obtained the necessary protection for potential future uses o l t r I . environs. ..2 N eference 1, page -30 of this Statement. R .f e 4 i a
_ Aeu f i nA 2 36 %d \\ B.~ Individual vs Population Dose 111ng consider- _ - The Consolidated Utility Group (CU) holds that the contr ay
- ation in establishing nu:erical dose objectives should be population rather
/ ..In its Statement of Position 1 CU ' than individual radiation exposures. states: "2. -The controlline consideration in establishine nur.erical dose objectives should be oopulation rather than individual radiation At dose levels below accepted radiation standards, exposures. ~ Statis-the levels of risk to individuals are negligibly small. tice11y significant risks can be calculated only for large. . For regulatory sicplicity it may bc desirable population groups. that Appendix I continue to express its design objectives in teams of off-site individuals. However, the choice of the indivi-i dual dose objective, and of the individual to whom it applies, should reflect the paramount icportance of the population dose objective and should not be more stringent than can be justified on a cost-benefit basis in terns of population dose reduction." . In spite of this contention CU, apparently for the sake of " regulatory ' ' s'implicity',' in its Statement of Position states its recommendations on CU would,however, make de sign objectives in terms of dosage to individuals. the individual dosage compatible with a primary population dose objective aid would specify an' individual other than the one " maximally exposed" for PStatement of Position by the Consolidated Utility Group, Jan. 19, 1974, p. 9. r 6 .a l b
l -4,w t,u:.: c o.. -, - m.& " e i 37 i { L t To that end they state: ' / 12 I the dosage calculation. ,u n "We believe that if an individual dose is to be used, the proper- . approach is to consider first a population dose objective which can reasonably be justified as " practicable" on a cost-benefit basis and then to determine a compatible individual dose objective. r - %e selection of arr extrc=ely low individual dose objective.as an end in itself,-without reference to population dose effects, cannot \\ l we believe be justified. It is even less justifiable when the l individual chosen for dose estimating is one whose living and 4 recreational habits, including food and water consumption, are wholly unrepresentative of the population group in the general l$icinityoftheplant." i and, in addition: "3. Dose Assumptions. In addition to requiring that realistic assumptions be used for-individual dose calculations, Appendix 1 should specify that the individual selected for dose calcula-tion be one whose living and recreational habits, including the source and quantity of his water,and food consumption, are representative of a significant number'of individuals living in ~ the general vicinity of the plant." 19, 1974, h.I. Statement of Position by the Consolidated Utilities Group, Jan. ~ , pp. 26-27. ~ 2/ - Ibid., p 69. i,, 1 l 9 -
~ 38 ?+?Ett i misww-Limited Participant, Andrew.P. Hull also favored primary consideratien to total population dose and subordination of individual dose limits to that 1/ limit. In his concluding statement Dr.. Hull states:- nn ~ the availabic biological data do not justify going "In my judgment, i Since the beyond the specification of an overall population limit. -bencfit of a nuclear power plant is the amount of electricity generated, this population dose limit ought to be specified with relation to plant E A logical scheme for such capacity rather than on a per plant basis. a limit was suggested in an earlier critique of Appendix I (Hu11-1972). It was based on a proposed design guide of 2 man-rem per year per This would Icad to an inte-megawatt of installed electrical capacity. At a grated. dose of 2,000 man-rem for a typical 1000 MW(e) plant. risk level of 2 x 10 per can-rem, cnis would Jead to an esticated ~ risk of less than one additional cancer case per year per 1000 MW(e) If the Regulatory Staff estimate that a 5 mrem /yr " boundary" " ~ plant. limit would lead to 400 man-rems per year is accepted, then a boundary t limit of 25 mrem /yr would be consistent with the proposed 2,000 man-rem population limit." ~ Ebasco Services Incorporated, as a limited participant, also argued that l. popu'lation. dose should be recognized as an important factor in decisions re-garding Appendix I. Mr. R. M. Eartman stated for Ebasco that, in his opinion, AEC had gone too far in details for implementing the dose limit to the nearest offsite individual and not far enough in considering the dose to a sizeable nearby population group. Mr. Hartman suggested: Final Statement of Position, Andrew P. Hull (Limited Participant) Feb. 11.1974, p 4. 2/ p 111. - Hearing Transcript, I
pw.w ] . sw. iypl + f aLQ,. : .) 39 i l la "To c'onsider population dose more specifically than' the current appen
- dix, d to real-we believe that the ? applicant should additionally be requeste J *+ + -
ulation from plant relSases in a h .istically c iculate man-rems to t e pop Lower release quantities or concentra- '25-mi1E perimeter of ene. plant. E t off-site tions (as derived from consideration of ' dose.to the neares ~ ld q individosi) dould be necessary if. it appears that such releases wou 3 reactor power level during result in greater than 0.1 man-recs /yr per 15 . normal operation." l General Electric (G.E.), on the other hand, would specify ~ the 1(7 In its Closin's Statemecc numerical guides for the nearest neighbors. GE affirms:1/ -The'ALAP n__2.ical guides should be estab- "1. Dose Objectives. lished in-terms of dosd-limiting objectives for the nearest neighbors of light-water reactors and should equal one percent of the prese6t Federal Radiation Council Guides for the whole. body and 3 Specifically, the objectives should be 5 milli-
- each body organ.
rams perLyear for the1 total-body,15 millirems per year for the a - thyroid and 30 millirems per' year 'for the skin." l-i ^ i l 4' ~1/ earing Transcript p, 114. 21, 1974, p. 13. -- H - Closing Statement of the General Electric Company, Jan. l: 2/ ~ L i 4 6 -.w .m--
'-?%c m 40 individual i that 1 The State of Hinnesota clearly supports the posit on l tion should be the dosage levels and not the average doses to a large popu a 1/ from the In this connection, Minnesota quotes-controlling factors. E Federal Radiation Counci1 ge figure, as '."Especially, it. is noted that the use of the avera ~ ' dose to individuals, is ' a substitute for evidence concerning the f appreciabl,e homo-permissible, only when there is a probability o ithin the geneity concerning the distribution of the dose w population included in the average." 1/ and states:- in keeping with the American "The important' point here is that, f the individual, no one (and one might . tradition of the importance o disproportion-f one's'off-spring) should be required to assume a add, aa ate amount of, the risk." has taken the position that, while average The AEC Regulatory Staff i imized, primary attention population exposure is important and should be m n iduals living in close must be given to limitations upon dose 'to indiv The.ree.ords,shows that this position has 3/ . proximity to the reactor site.- In Oral Argument, Mr. not substancia11y' changed throughout the hearing. i b for the Regulatory Staff Rogers stated b e "I think the primary objective of the regulation is, num er on, dividuals, actual individuals to reduce the exposures and the risk to in to as low as practicable that exist at the present time near the site, levels." Minnesota, Feb.1, 1974, pp. I'2-13. ! nal Statement of Position of the State of Fi i i Protection FRC, Dackground Mr.terial for the Development of Rad at on II Standards, Report No.1, tby 13,1960, p. 27. $! ce, for example, AEC Staff Exhibit No.1. Tab 1, Ja i ' S 4 m. m mm v'-".r' s
41 hav and, in its Concluding Statement the Staf f noted "The individual living near the power plant is most. concerned about the risk to himself and his fawily, not the average exposure to the general population."1/ .The Staff has further indicated that exposures to potential future users of the environs of nuclear reactor facilitics must be considered. Mr. Rogers statea.13/ !'At the same time I think you must' take into account the exposure to potential individuals, and by that I mean future users of the environ-ment. I don't think that you can assume that the environment is not going to change and is not going to be used in the' future; and I think that the proper approach is to base design objectives and limiting conditions of operation on the basis that the environment will be used in the future." We, the Atomic Energy Commission, agree with the Regulatory Staff's position thaq though the population dose is important and should be minimized; the primary thrust of Appendix I should be protection of those individuals who live near the light-water-cooled nuclear powe.r plant facility. It seems quite cicar that if such " maximally exposed" individuals are suitably protected dosage',leve'is to the public at large will be very low.4/ We further agree, as ) stated' abovqr/ with the Regulatory Staff position that account must be taken of 5 Potential near neighbors of the facility and that future users of the immediate reactor environs should not be prejudiced by emissions from the reactor facility. 1/ - Concluding Statement of Position of The Regulatory Staff, Feb. 20, 1974, pp 47-48. 2/ -- Oral Argument Transcript, p 23-24. 2/A14P Regulatory Staff Exhibit 1, Tab 1, p 14. 4/ - See Section C, Estimate of Rf.sk f rom Radiation p.15. above. 5/ - See page of this Statement. e e e 9
~hn~n 42 Power. Reactor and Associated l -C. ' Direct Caema Radiation-from tiuc ear fEquipnant-u.H boundary dose The' State of Minnesota' takes the position that App 1 h 1 calculations should specifically include t e c 2/ also raised this point concerning radiation Consolidated National Intervenora-from light-water-cooled 'other.than that.from radioactive materials in effluents An early position of the Environmental Protection nucicar power-reactors. i hould Agency (EPA)EI also included the = suggestion that direct gamm 4/ t be considered; EPA apparently no longer holds this view since it sta d to "We' recognize that the scope of the present rulemaking is limite 9 ddress the material effluents, and that for this reason did not a i issue of direct and indirect ga=ma radiation frou onsite locat ons. h We suggest the Commission deal with this category of expos h radiation." early issuance of limiting criteria for doses to suc the Experience to date has shown that the highest radiation dose from this source site boundary is generally less'than 10 millirems per year ligible levels with and'that, since this dose. rate decreases rapidly to neg contributes only a frcction of a 7 . distance from the site boundary, this source 5/ ean-rem per year t'o the population dose.- "as low J This, Hearing has been concerned from the beginning with kee terial_s in effluents i as practicable" the risks to the public from radioact ve ma Moreover, as the Regulatory Staff j from light-water-cooled power reactors. f 3. $/ inal Statement of Position of the State of Nunnesota, Chapt F Teb. 1, 1974. 15, 1972, p 6. E nthony Roisman to Mr. Algie Wells, et al., Feb. 973, Vol. 3, pp 263-264. I A - Final Environmental Statement, Wash. 1253, July 1 h 12, 1974, p 3. 3/ i 4/. D. Rowe, PhD to Mr. L. Manning fiuntzing,' Received Marc l. -- W f f, Feb. 20, l'U4 -- Concluding Statement of Position of the Regulatory Sta 5/ ll
- p. 6 5.-
l3 I n -s w w
M u a:n. nn M*, 43 te'st'ified1. proposed Appendix I was' not intended to include direct radiation from the. nuclear facility. Va,tkuAtomicEnergyCot=1ssion,agreecompletelythatsuchdirector scatt'ered 'ga=ma radiation f rom the turbine building and from waste storage tanks and other equipment containing radioactive material should continue to be takIen into account in the licensing process and should be carefully controlled ~ by proper design and operation of the reactor and associated equipment.. It =ay ^ be appropriate to issue further guidance on levcis "as low as practicable" from this rad'istion source, but such guidance should clearly be separate from .' Appendix I. D. Occupational Radiation Exposure The Consolidated Utility Group (CU), the American Industrial Forum (AIF), 'and to a lesser extent the Cencral Electric Company, show concern about the The AIF in possible effect of proposed Appendix I on occupational exposure. 2/ ici comments on the Draft Environmental Statement says:- "Another area where the Draft Environ = ental Statement appears to be-particularly negligent is in its lack of consideration of occupational radiological expocures and potential increases in these exposures with We feel that increases in implementation of proposed Appendix I. exposures to on site personnel could be substantial with the additional holdup and storage of radioactive materials in conjunction with ' meeting provisions of proposed Appendix 1." 1/ earing Transcript, pp 595-598. H - Final Environmental Statement, Wash-1258, July 1973, Vol. 3, p 98. 2/ 8 4
~ W,V 44 umy 1I CU concludes that: f In its closing position statement,- '"There is a serious danger that the reduction in off' site doses sought to be ac.complished by proposed Appendix I will be more than offset by an increase in occupational exposure." 2/ in objecting to equipment The General Electric Ccepany closing statement,- required as a result of "farfetc ed assump'tions," comments: produce a net increase in the "Such equipment could, in fact, exposure of; the. human gene pool to radiation by increasing the doses to the employees of tihe I.E facility." f These positions of CU and GE seem to be based to a substantial extent testimony of Dr. Morton I. Goldman3'-4/ concerning likely increases in occupa l tive tional exposure due to aug:;ents to radwaste systems and of the re a l he importance of such radiation exposure compared to radiation exposure to I In his testimony Dr. Gold =an asserts _/ "Thus the International 5 population. i Co= mission for Radiation Protection considers that the occupational popu I dose may be about 10 times as significant as that to the general public". his belief and Dr..Goldman seems to base much of the thrust of his testimony on Dr. Goldman gives as the basis for his view an execrpt that such is the case. from a publication 6/ of the International Co= mission Radiation Protection k No. RM-50-2, - Statement of Position by the Consolidated Utility Crwo," Doc et 1/ Ja,n. 19, 1974, p 17. k No. RM-50-2, - Closing Statement of the General Electric Company, Doc et 2/ Jan. 21, 1974, p 34, lidated - Additional Testimony of Dr. Morton I. Goldman on Behalf of the Conso 3/ Utility Group (Part 1) Occupational Exposure, Docket No. RM-50-2. / earing Transcript pp 3605-3614 and 3999-4048. 4 1t lidated - Additional Testimony of Dr. Morton I. Goldman on Behalf of the Conso S/ Utility Group (parts 1 and 2) Dochec No. rat-50-2. - ICRP Publication 22, paragraph 18. 6/ D
.d2,ie 45. 1 "(18) It is then helpful to express the population dose not only l in man-rems, but also in social and economic terms, for exampic, in terms of detriment or monetary units, so that , the advantage of a reduction in co11cetive dose can be compared diractly with the detrizont or cost of achieving'this reduction. In this way, the methods of Appendix III can be directly applied. In the. region of individual dose near the dose limit, the need i .for-the additional effort can be indicated by. arbitrarily increasing the monetary equivalent of the man-rem, perhaps by a factor of 10 or so. Some published estimates of the possible monetary' equivalent of the man-rem are given in Appendix II." The recordif ceemstomakecicarthatDr.Goldmanhasmisinterpreted th'e ' intent of the pertinent Paragraphs of the International Commission for-. Radiation Protection document. We believe that, without such a factor to give increased weight to occupational exposure, the data presented 2/ '~ do not supp$rttheconclusionthat the probabic impact of Appendix I'on occupational exposure will outweigh the probabic reduction of exposure to the population. In assessing the probable impact of Appendix I on occupational exposure, ~ the AEC Regulatory Staff attempted an analysis of data equivalent to that presented by Dr. Goldman. It was found that no conclusions were warranted on the basis of the data, and that a more detailed evaluation was necessary. ~ The staff proceeded to study occupational exposure oy visiting eleven ~ selected operating nucicar power plants, reviewing exposure records, and holding discussions with utility personnel.- This study suggested that aur. mentation of the radwaste treatment systems to meet the objectives of l/lllearingTranscriptpp 4015-4013. '2/ " Additional Testimony of Dr. Morton 'I. Goldman on Behalf of the Consolidated UtL11ty Grot.p (Parts 1 and 2) Docke; No. RM-50-2. ~3/ Ch.irten A. Willis, "A Study of the Occupational Radiation Exposure Due to Itidw ir.t o Treatment Systems at Nuclear Power Plants," Docket No. PJt-50-2, r
q .a [ ~ proposed Appendix I might be expected to increase occupational exposure by sa Of more significance was the observation that little if any some 7 percent. Much of the' occupational of the increase in exposure would be unavoidabic. m exposure in nucicar power plants is due to such things.as inadequately shielded tanks, lack of access for maintenance, lack of remote controls, and lack of ) jf ' remote-viewing equipment. The general conclusions of the'AEC Regulatory d d Staff, which seem not to be challenged in the replies by the Consoli ate Utility Grouh and by General Electric ! o the Concluding Statement of 5 t Position of the Regulatory Staff, are that "impicmentation'of Appendix I 7 neet not significantly increase ogeupational exposure.',- / ~ We, the Atocic Energy Commission, nevertheless, continue to be concerned about the level of occupational exposure in nuclear power, plants, and steps are being taken to reduce occupational exposures to icvels that are "as low as prac-ticable." Regulatory Guide 8.8, issued in July 1973, details the occupa-tional exposure control inforcation that should be provided in license applica-This information is now being reviewed in the, licensing process, and tions ' applicants are being asked to improve plans, -procedures, and designs where appro- + The SAR Standard Format document is.being revised to priate to reduce exposure. , increase emphasis on occupational exposure control. Thus, the importance of keep-ing occupational exposure "as. low as practicable" is recognized, and progress is - being made toward that objective, but we do believe that implementation of AP-Pendix I is compatible with the reduction of occupational exposure. - Reply of the Consolidated Utility Group to Concluding Statement of the 1/ nenulatory Staff, March 7, 1974. $lReply Statement of the General Electric Company, March 14, 1974. 4/ Concluding Statement of Position of Regn1 story Staff, Docket No. RM-50-2, i F.h. 20, 1974, p 64. ~. L. = -. 4>
._m
- . w.
47 I n *,r,e l ...Per Site versus Per Reactor L N The AEC Regulatory Staff has, throughout the hearing, taken the-l. position that the design objective doses should be those resulting from +w 1 radioactive materials in effluents from all light water-cooled power reactors at a site.1' ! The State'of Minnesota, apparently on the ground ~ j l that "...no group of individuals should be expected to assume a dispro- - l d! portionate: amount of the radiation risk" supports this position l Both the General Electric Company (GE) and the Consolidated Utility ~ Group. (CU) recccmend that the design obje:tive dose valu'ebapply only l to all reactors on a site.- CU, in its conclud-individual ructors and not ing Statenenth argues: I the limitations on dose are applicable to '?Under proposed Appendi:: At the dose the combined releases for all reactors on a single site. -levolm contemplated in the proposed rule (particularly with respect to gaseous releases), the effect of a. site limitation will be to dis-courage and possibly prevent'the placing of cultiple reactor unite on It will also work an unnecessary hardship on existing ) a single site. multi-unit stations, including several three or four unit stations which are now planned or under construction. ~ We believe there are strong economic and environmental reasons for .o + encouraging maximum utilization of existing sites and the planning Obvious and development of new sites for two or more reactor units. economic advantages lie in the sharing of a large tract of land, in the sharing of facilities,'and in the sharing of much of the expense T/" Al AP ACC Regulatory Staf f Exhibit 1 Tab 1' 20, 1974, p 61. Concluding Statement of Position of Regalatory Staf f, Feb. 'f i 1/Plu.it Statement of Position of the State of Minnesota, Feb.1,1974, p 17. 19, 1974,
- ,/St atencat of Position' by the Consolidated Utility Group, Feb.
pp 57-58. 4 y
.~ L 48 s. wi of site inv:stigati:n, ::ginacring, licensing, constru'ction canags-Environmental advantages flow from ment and operating supervision. h the minimizing the inevitable environmental impacts associated wit development of new iniustri:1 sites." I other than that obtained by the -C'U would apparently place no limit doses.from multi-reactor sites, but they insist:1/ "per reactor '. limit - on "The resulting of fsite dose to individuals living near multi-unit lly sites vould still be a small fraction of Part 20 limits and genera l risk accepted radiation standards and constitute a trivial incrementa i 'to their health." ~ ~ In its Reply, Statement,I CU points out that, while the proposed ~ ~ ' limits on d'oses from liquid effluents may not prove unduly' burdensom ~ multi-react $r sites, the limits on doses from noble gases and iodine may severefy'1'imit the n' umber hf reactors at a site unless stacks and, for s ~ b fit cases, rad-waste augments which it considers unjustified on a cost-ene basis are employed. ~ d by that per-reactor application of the guid'es is justifie E E GE argues I and points ' ' out the A J co'st-benefiS considcrations that control Appendix ~ i dicating thatt$c'RegulatoryStaffhasperformednocost-benefitanalyses~n
- the con'trary.
c. : -~.. - - :m. - , Statement of Position by the Consolidated Utility Group, Feb.19, 1 16. Al f the 1! eply of Consolidated Utility Group to Concluding Statement o R' Regulatory Staff, March 7, 1974, pp 21-25. 14, 1974, p. 32. - Reply Statement of the General Electric Company, March 3/ / - Hearing. Transcript 3429-8.0..and 3482. 4/ 5/ - hearing Transcript 3486-87. G j t - l i-4 m
rns ly ,) '} f - },y' '.,y, ~ l' 49 L GE contends ! 1 that: .... a per-reactor design objective guide that is 'as low as practicabla'. for a single reactor-and the numerical guides of Appendix I meet and surpass that standard--will remain as lov as l-practicable even if several reactors are congregated on a single On the same reasoning, equipnent augments unjustified on a l site. cost-benefit basis for a single reactor can never be justified on a cost-benefit basis for multiple reactor f acilities. /
- Indeed, the environmental and other advantages of multi-reactor siting subgestthat,ifanything,morelenienceshouldbeallowedforper-reactor emissions from a multi-reactor facility since these advan-tages vill off-set any add'd per-reactor radiological detriment, and e
the added leniency would encourage the desirabic clustering of power ~ generating installations. '* Scale economies beyond tho. two-unit facilities analyzed in the AL'AP-FES are ~ unlikely in view of plant availability considerations, plant physical si::e parameters, and other f actors." Nevertheless - and to some extent in spite of this argument - GE would place an additional limit on the dosage levels for a multi-reactor site. IndtsClosingStatement,GEreco= mends:2/ "For any combination of nuclear power reactors on one site, on adjacent nearby sites, the applicant or applicants shall, in addi-sites, or ot-tion, provide reasonable assurance that the total incremental annual 1 exposure (from either airborne or waterborne effluents) to any indivi-dual in unrestricted areas will not exceed four (4) percent of the 1/ 14, 1974, p 33. - Reply Statement of the Cencral Electric Company, March 21, 1974, p. 28. -[losingStatementoftheGeneralEl'ectricCompany,Jan.
~ 50
- 4 c
u o e' Federal P.adiation Protection Guides, as set forth in Federal Radiation Council Reports Numbers 1 and 2, May 13,1960 and September 1961, for doses to the total bcdy or any organ." ll and further states:- "Both the Consolidated Utility Group and C E took the position in the ALAP hearings that the Appendix I numerical guides must make special allowance for multi-reactor installations at a single site in order to preserve the overall environmental and economic ad-vantages of minimizing the total number of power generation sites. The FES analyses, even when carried out with a "best-esticate" dose evaluation, show that application of ALAP design objectives as over-all site limits, regardless of the number of reactora present, may limit the number of units on a site below that nu ber that may be desirable for environmental and Such a forced geographie distribution of reactor economic reasons. sites of one or two units each will not reduce total population i it could increase total' radiation dose from LtTR cffluents; in fact, population dose if the distributed sites in toto have a lesser degree of local isolation than would the probably more favorable sites that would be selected for multi-unit use. t l Allowing the nearest neighbor dose resulting from waterborne or air-borne effluents from a number of closely-located light-water reactors, .each meeting the regular single-reactor ALAP guides, to approach four i (4) percent of the Federal Radiation Protection Guides would i - Closing Statement of the General Electric Company, Jan. 21, 1974, pp 28-29. 1/ e
- w
~,. ~_ - ji uth 1: u.m e. e 51 L-- t stillTimit such doses to a small fraction of permissible dose t i and a fraction of natural background exposure, and it would keep them j i ithin the United .wi. thin the variation in natural background radiat on w I ~ ~. e. :. _. Sta'tes ? ' h ore Overh11~,' the' proposed multi-unit dose objective recognizes t e m desirable environmental characteristics, the greater electrical power \\ contribution, and the reduced overall site investigation and licensing fits time inherent in multi-unit siting, and it preserves these. bene with~o~dt sacrificing considerations of minimizing public radiation i Th6 ' proposal also addresses the subject of total dose to eip6sdre. individuals 'from nearby but separate sites, whic'h was not covered in The recognition in 10 CFR 50.34a that "as-low- .~ .c -proposed Appendix I. ahb~c~ tic $ble" must be defined "in relation to the util aEoSicenergyinthepublicinterest"requiresallowanceofslightly inbre'ased, but still tr'ivial,' exposures in-order. to. achieve a doubling ~ or tHplinb of electrical output at a-site and the other environmental aNya' Eta'g'es' of' multiple unit siting."t -*-e---- . e -... ~ ^ Ourexamidationof'the'reeordindicatesthatnoneoftheotherparties h ld in this hehring has directly addressed this question of whether the limits 1/ National Intervenors- (in its belief d on a per reactor or per site basis. .be base l is harmless, we that,since the AEC could not prove that radiation at any leve fr should permit no radiation releases at' alDwould seem certainly to pre e Anthony J. Roisman to Algic A. Weils, et a1., Feb. 15, 1972. i
.g ,w w. +4 52 J this sould presumably imply a h ore ctringent; whichaver limit:tien is t e m i n from all reactors at a site. i preference for a stringent limit upon em ss o 1/ advocated limits based Dr. Andrew'P. Hull,who has, as indicated above,-large and who h + primarily upon dosages to the population at bjective;seems to favor i man-rem per 1000 In!(e) as a limiting des gn o h testimony A similar observation may be made conc 2 reactor limitation. of Mr. R. M. Hartman in a limited appearanceper 1000 MW(t) be e who recomnended that a limit of 0,1-man-ren limit on population dosage. ilization of there are genuine advantages to the ut It is our belief that of light-water-cooled nuclear. i atomicenerh,yinthepublicinterestfromgroupng ld certainly not discourag h power reactors on sound sites, that Appendix I s ouly does nothin l such a practice, and that the Hearing Record c ear design objectives h We have, accordingly, written Appendix I so that t e d to each light-water-cooled view. and limiting conditions of operation are applie . nuclear reactor. i expoused by the We are mindful of, and have sympathy for the posit on, ld be expected to assume h State of Minnesota, that "no group of individuals s ouBut it must be k" a disproportionate amount of the radiation ris. f ever be realized o such a situation, however desirable, can seldom i i lly harmful mater.ials Even if radioactive releases (or, for that u.atter potent a ility) were kept "as low as released from any other nuclear or non-nuclear fac e a disproportionate share possible" near neighbors of the f acility would assum to assure that the of the risk. It is clearly our responsibility, however, To low as is practicable." ris'k, disproportionate though it may be, is "asin addition to the restri t that end we have, as set forth belov, set -- P. Hull (Limited Participant) Feb.11, ~ l - Final Statement of Position, Andrew 1/ l 1974, p 4.
! ?;^"I 53 , es? = on esch lig.ht-water-cooled nucicar power reactor -- stringent, but va believe justifiable, limits upon tne dosages to individuals from radioactive materials in ef fluents from all light-water-cooled nuclear reactors capabic of affecting those individuals. SELECTION OF SPECIFIC DESIGN OBJECTIVE VALUES A. Coct Benefit Considerations The general benefits to be derived through generation of electricity from light-water-cooled nuclear power plants is not a consideration in the i-I decisicas concerning Appendix I. Such benefits and the associated costo are'a real consideration in the process of licensing and siting of power l stations. The cost-benefit balance appropriate to decisions regarding Appendix I deal with the costs for and the benefits from installation of sophisticated radwaste treatment systems. This need to balance the cost j for each incremental reduction in dose and the benefit to protection of i human health and well being from the resultant reduction in risk is clear- 'ly inherent in any judg=ent of whether a given dose level is "as low as practicabic." For such decision making both sides of the cost-benefit balance should be expressed in commensurate units such as dollars. 1. Worth of a man-rem '.._The Regulatory Staff agrees with the desirability of doing this ..s. ,, but have in practice been very reluctant to assign a dollar value to a man-rem for this purpose. The Staff states / 1 "There is no agreement on monetary values for reduction of risk j to human life or to suffering or how such values should be applied. It is not possible to reflect properly the worth of reduction of l-risk to human life in monetary terms since there are overriding moral values that cannot be quantified." l 1/ - Final Environmental Statement, Wash. 1258, July 1973, Vol. 1, p 8-3. m
l '** Aat$/** A'.t<j hg% 54 4 the scvaral publish d esticates for vorth of a 1/ 'The Staff citas-They note that / 2 i man-rem;these range from about $30 to 'S9SO per man-rem. "The majority of the estimates were in the range from $100 to. ( "o values have been suggested for dose to $600 per person-rad. However, the relative risk . single organs such as the thyroid. of the do'se to the thyroid compared to dose to the total body t id-rem than.for a -would suggest a lower value for a person-thyro l person-res." they do not endorse any absolute but continue to make clear the fact that Forexampletheystate! E value for the worth of a dose' reduction. d that m'any aesthetic, human ^ i ..."At the same time it must be recogn ce and environmental factors are not quantifiable and must be given f weight in the decision-making process by informed, though subjective, Thus, references to dollar cost per unit of reduction of j udgments. dos ~e used.by the staff in the FES and in the record of the hearing - are intended for comparison purposes only without implication of recommended absolute monetary value worth of such dose reduction. In spite of this reluctance the Staff stater- ~' '"In spite of the inherent difficulties in the direct use of dosetirf values, it appears useful to express, to the extent practic-able, both costs of reduction of risk and benefits to society from such reduction in monetary units as at least one of the factors to Wash 1258, July 1973, Vol.1, pp 8-2,-3 AIFinal Environmental Statement, 2/ -- Ibid. pp 83. 20, 1974, p 43. 3/ConcludingStatementofPositionofRegulatoryStaff,Feb. i L 9 ' ' ~ ~ - - - - - - - m.
~~"1,' 55 be considered in arriving at judgments on redm ty r ', y ",,., L., as practicable icvels." In both the Final Environmental Statement and its Concluding S: ate-ment-the Staff does calculate, fron its esti=ates of rmi-wante .t a em costs and the resultant reduction in population dose, values for cout ;cr man-rem reduction. They do not, however, appear to accept or reject i radwante systems because of the cost of such reduction. Indeed, it is clear from the testimony 1I that the Staff would leave to us, the Atomic Energy Commission, the decision as to dollar value of ~ the man-rem to be used and the extent to which such a value would be r,1ven weight along with other considerations in the decision. The Consolidated Utility Group (CU), on the other hand, did choose ' 5'6/ 4 St a value for the worth of.a can-rem. For CU, Dr. Walton Rodger stated ' "You may duck the-issue all you want but in order to make a meaning-ful cost-benefit analysis you simply have to bite the bullet' and assign a value to a man-rem. We recognize that.this isn't casily done, that there are great subjective factors involved, and that this is an area in which reasonabic persons may reasonably disagree. Nonetheless we chose a value. We chose $1000/ man-rem (and 1/3 of that for a man-thyroid rem). The FES quotes a number of.cstimates for this value ranging from $10 to $980 with most being in the range of $100 to $600. A very current new estimate is $250. We deliberately / 1 Fitial Environmental Statement, Ussh 1258, July 1973, Vol.1, p 8-2. 2/ - Concluding Statement of Position of Regulatory Staff 3/ - Hearing Transcript pp 3472-73. 4/ - A1AP UG Exhibit No. 5, Additional Testimony of Dr. Walton A. Rody,er on Behalf.of the Consolidated Utility Group, No. 9, 1973. 5/ - A1.AP UG Exhibit No. 6. Summary o.f Additional Testimony dated Nov. 9,
- 1971, of Dr. Walton A. Rodger on Behalf of the Consolidated Utility Grouti, li.'.
f./ earing Transcript pp 3913-15. H
r_ iw~" 56 issW . chose a value above the range quoted for two reasons: to be conservative in our assessment of the value of augments, 1) to make allowance for " overriding moral values" and other 2) intangibles which are hard to quantify." l. these values of $1000 per man-rem and As the record makes cicas but were $333 per man-thyroid-rem represent no independent assessment obtained by CU simply by taking a value somewhat higher than t.he range of u l values suggested by the several studies cited.3/ l- ) The General Electric Company, while generally accepting the cost-l- benefit analyses presented by CU, seems to have made no recocmendations for the worth of a man-rem. The State of Minnesota also made no assignment or decision as to worth of a man-res. / Minnesota has argued consistently that releases of radio-4 i l activity should be minicized but has not really tied this recommendat.". to the resultant dose effects nor has it made cost-benefit analyses in support of its reconmendations. /- However, it seems clear from the record 4 l that the State of Minnesota would put a high value on the worth of a'can-rem. S/ l In its Final Statement, it states:- l " Minnesota also believes that the actual costs, as described by both AEC witnesses and the utilitics, seem less reasonable than when l Testi-l expressed in terms of their impact on individual consumers. mony by a Minnesota witness / showed that. typical augments might- - Supplement Testimony for the State of Minnesota at the Atomic Energy
- /
Commission's Rulemaking Hearings, "As Low As Practicable," by Kenneth Dzugan. 1/ " llearing Transcript pp 3944-45. ^/ Statement of Position by Consolidated Utility Group, Jan. 19, 1974, p 31. 3/ Final Environmental Statement, Wash 1258, July 1973, Vol. 1, p 82-83.
- t. /liearinn Transcript pp 1778-1779.
'/" P!nal Statement of Position of the State of Minnesota, Feb.1,1974, p.14.
Y iw,' = 57 l representi an addition of several percent to the average residential user's cost. Minnesota believes such incrc=ents in cost are Minnesota reasonable, when they go to protect the public health. urges the Co= mission to consider the cost-benefit analyses of both ~ the regulatory staff and the utilities in this light." We certainly agree with the Regulatory Staff and with the Consolidated subjective factors to be considered in any Utility Group that there are great On the other hand,it is clear that a judgment of the worth of a man-rem. dollar figure for such worth is necessary for the cost-benefit analysis that must form a part of the basis for the decision as to the specific minical After careful consideration of the guides of Appendix I. several points of view expressed in the record,it seems to us prudent
- .o the worth of a =an-rc= be assigned the value of $1500 and the recommend that Accordingly, we worth of a can-thyroid-ren be assigned the value of $500.
so reco==end an.d these values will be used where appropriate in cost-benefit i considerations for this Appendix I. It will develop,in a later section of this Statement of Considerations,that a merningful cost-benefit study can be made only for the dose benefit to a large population. those augments to a rad-waste system that have a It seems manifest to us that favorable cost-benefit ratio for reduction of dose to the population at large should be required of all light-water-cooled power reactors. We havealreadydecidedfhat those individuals living near to the light-ws.ter-A Accordingly, as we arcue cooled power reactor must be properly protected. below. installation of equipment with a favorable cost-benefit ratio for l dosage to the population at large is necessary, but it may,- in several. l cases, not be cuf ficient to satisfy the requirements of Appendix I. l O age of this Statement of Consideration P
- MM 4 nWp - 58 2. Cost of Raduaste Systems During the initial phase of' the AIAP Hearing (prior to May 6,1972) the Ibgulatory -Staf f presented little. information,1'2_/ and that of a preliminary and Information nature, concerning the costs of radwaste systems. fra-mentary concerning costs.of radwaste systems was presented, in this initial hearing phase, by the Consolidated Utility Group. ! and, to a limited extent,by General I l Electric.5/' Dr. Walton Rodger, who nione presented what might fairly be called and'of annualized costs ! during this b a comprehens.ve formuletN n'of costs d period setaed:6/ It is my opinion that:
- 1) the cost estimates. given by the Staf f are low by factors of from two to ten depending on the assumptions and models used; the cost per unit reduction (S/ man-rem per year) are quite out of 2) proportion with the biological d-d.ficance of a man-res; the augments (and costs) considered by the Staff do not touch the E
3) misec11aneous sources." Publication by the Staff of the Draft Environmental Statement, its con-sideration of the many diverse comments upon this document, and subsequent pub-Meation of the Final Environmental Statement were important steps in providing a basis for proper Csting Of radysste eystems and for cost-benefit analyses. Comments upon the Draft Environmental Statement showed, as might have becn ' expected, some disagreement ~with the estimated costs of radwaste equipment. bALAP Regulatory St9ff Exhibit 1 Tab 2, p al and Tables 12 and 13. i h I!earingTrasacript 536-590 H E! Statement of Dr. Walton A. Rodger on Behalf of the Consolidated Utility Group, 1748-1752. Dated March 17, 1972 and' incorporated i.,IIcaring Transcript pp 4/ Dr. Usiton Rodger-on Schalf of the Ce>nsolidated Utility - Suppicmental Statement, incorporated in Hearing Transcript p 2753. Group, April 26, 1972, 5. - ALAP General Electric Company Exhibit 3, April 26, 1972, Items 4 and 5/
-mm-.
- %fhH te)
IIt!" d.;w $9 Consoli. dated Edison Company of Ucw York, Inc. stated 1/ that cost esti-mates in the Draf t Environmental Statement seemed to be generally lower than their experience would indicate and showed a few specific exampics where.the estimated costs-appeared to be low by at 1 cast 3-fold. The' Consolisated Utility Group (CU) in its comments on ti Draft Environ-mentalStatementstated:2/ i "The DES has presented, we believe, a reasonably good set of cost asti-mates for the additions proposed for the vctious cases discussed..To the extent possibic we have tried to cross check these cost esticates against other'estinating procedures and against act.a1 instclied equip =ent of sinilar design. We conclude that the cost values presented are generally .on the low side of the expected range but not drastically so. We believe that all of the costs should be increased by 10 to 20% largely because we do not believe that the esti=ates prer----d in the DES properly ref1cet the increasing demands of the Directorate of Licensing for higher code classifications and, increased quality control. These requirements typically can add from 50 to 100% to the cost of individual equipment pieces." However, CU argues strongly that the cost picture is badly distorted by using - as was done in the Draf t Environmental Statement and the Final Environmental \\ Statement - a two reactor site in which cuch of the radwaste equipment was shared CU argues / that the suggested capital cost savings 3 between the two reactors. l can be realized only if two reactors are built at the same site and at approxi-mately the same time. l J A Final Environmental Statenent, Wash 1258, July 1973, pp 311-312. E! Ibid., p 243. 3/ -- Final Environmental Statement, Wash 1258. July 20,1973, p 244. l
w A ss V <n dvd - 60 1/ publication of the' Final Environmental State:cnt CU stated: Afte 1 '"The costs presented in the FES appear to be almost a factor of two ~~ lower than those of the DES and we can no longer avoid taking iss6e 4 Our criticism of FES costs fall into '-' with the Staf f cost estimates. '~~ ~ the following categories, each cf which is discussed core fully below:
- 1).- Specific cost ite=s omitted from the FES analyses.
Comparison of certain key components between DES and FES. 2) Comparison of specific FES equipment cost estimates with actual ) 3 experience. Comparison of the ratio of bare equipment cost to installed cost 4) with actual experience and with current estibating practice. '5) Omission in the FES of adequate provision for the additional '~~~~~tilitIesand'ccrvicesreqhired'bythesuggestedhugments. u ' lack of redundancy in the FES -- redundancy required both by 6) ~ ' ~ bpsraclng and licensing considerations... ~7)'"Ehadequa'te'provisionoftheFEScostesti=atesforpresentday "'quailtyassurancerequirements. ~ Shriously inadequate pr' vision ihr operatisg labor'in the O&M o ~ ~' 8) ~ ~ ' ~ ' ~ ~ ~'"~~ ~~ 'sictisns' of thh FES cost'Enalysei'."" .~. '~~ ~~ i is .After a detailed._ elaboration of these several points, the conclus on . : 37, ~ ~ - - ~t -j 2/ "From all of the foregoing we conclude that there is no possibic way in 'which the various FES cases could be built and operated at less than twice Testimony of Walton A. Rodger on Behalf -1/ earing Transcript p 3909, Additional 19, 1973, pp 38-39. -Hof the Consolidated Utility Group, Nov. 2/ - Ibid'., 3909, page 51. _2 ---.-_x____--_.__.--.-.-_-___.___------._-
v:, ne s e p 61
- w**
e the co.its allowed for in the FES. Takina into consideration the need for re'dundancy and th,e fact that the FES estimates are based on two i reactors built simultaneously and sharing radwaste equipment.a more likely cost is three to four times that given in the FES." CU continues to naintain1/ its belief "that in its Concluding Statement l the cost of installing and operating waste treatment systems has been under-stated perhaps by a factor of 3 or 4." l J The Regulatory Staff, on the other hand continues to defend the cost esti-J (FES). In its Concluding mates presented in the Final Environnental Statement Statement the Staff points out that the CU data was based on " industrial CU experience" and included overt 1=e and other exceptional factors, that incl'uded backfitting experience,3'4/ and included optional redundant equipment. l The Staff arguer 1 that none of these items should be included in cost of rad-2 ) waste systems for cost-benefit analysis. The Staf f did include redundant components in costing the radwaste systems in the Draf t Environmental Statement but, at least partly because of criticis=s in comments on the DES, removed such redundancy frcm the systems evaluated in the Final Environmenta'l Statement.E/ The Regulatory Staff says of optional redun-5 dant equipment: / i ".....vhich is not required for meeting ALAP or licensing requirements and therefore should not'be included in costs for meeting dose reduction in cost-benefit analyses." 36. - Statement of Position by the Consolidatec Utility Group, Jan.1974, p 1/ 20, 1974, I! oncluding Statement of Position of the Regulatory Staff, Feb. C pp 43-45. 3/ -- llearing Transcript p 3975. 4/ - llearing Transcript p 3985. 20, 1974, }- Concludic.; Statement of Position of the Regulatory Staf f. Feb. pp 44-45. O
} .:34 6ewfwh h 4#tMj 62 SU.,.on,the other han,d,,takps,the Pos.it. ion:#/ 5 "It,is not the practice of ut.ilities -to install such systems withodt 9 Provis, ion of adeqpate redundancy ;for safe.and rp_1.iable opera.cion f.h e condi.t_ ions -would 907.is,1.t likely in pe,tual prac.tice.t. hat'AEC Jicens. The Sechnipal spe.cificat. ions of existing f.BJP.it them to do otherwise. licPPP.es as wel,1 p.s,the proposed.Appen,d,ix _I J,im.1.. ting,c.ond.ition_s PPPFP)_ ion coy _1d fpyca 3.he,shp.spwn of,a pu.c_ lear Spwpy 9,lant.in the t f fpr $nov. y_adwaste PVP.np,of pn ppyage of imppypant yadwaste py.s.tems. 7,ypppas,_a p,tili y sjcply gppuo.t affoys tp a_1l.ow pp.eya.tipa p.f the pla t $0 $PPPS.d on yhe avaiJpbili.ty pf,a.sippJp piec. p.f.radwa.spe equipme e h!!9F SC9sipeppgipo of the spvpra.1 diffprences bptween the.Srpff and the l l tps, gnp pypff pplievess/"that $here ara op 41;;cificant itne;$plained 9 i 6 Gff rf I $15!9?PACC8 V.ith yeppec,t to post est_icates." WPi_thp htomic fagrgy Cpypissipn, )g_l,gvp a.frer consippragipn of the rec i $.hp, $he Sepf f gost p. yf;:atps fpr gonstygggfpn and operation pf radwast s t 3py )e -1 w )y an apprggiabig ampunt but that t. ese esgh: ate.s by the Eggff are h r 9 l 3 py 4, !$ pepes $p ys that to the Sufpp pp}}, ply to pe f. pyycy py fag 5pys s? k n thgt pggipment rgdgniappy fp required 'py the gyppnt ppd pply to t'hp p.tgnt : x of push redundant $ temp should be included in the }{gpnsiggprocessphpgpst It seems equally g ear that the additional costs, l gotp1 costing of the system. if any, due to increased attengion to quality assurance should be included in E.Affitipnal7pspinonypfDr,WaltenA.RpdggrpngehalfofConsolidagedUtility Group, Nov. 9, 1973, p 49, 20, 1974, p 45. = Congluping Statement pf Ppsipipn pf the Regulagpry Sgaff, Feb, e a
-~ s. 4Q. ^ e. 63. ? *: ' 'On the other hand, it'does not seem reasonabic the radwnste system costs. heaturesthatmayhave,in M:. + . to include costs of overtime or other special specific' instances, contributed to higher than normal costs of' installation. On the othat hand, the costs of cperation o'f the augmented, equipment'should be realistically estimated; such estimates should include reasonable. allowances for maintenance of equipment land for the increased work force ~and payroll . based, insof ar as is possible, on. actual experience as this experience exists or becomes availabic. i 2/ that evenLthough the -We note and are impressed with the CU conclusion, ~' Regulatory Sta#f's cost. estimates are low by some factor this difference make little if any change in the list.of radwaste augments that'are justifiable on a cost-benefit basis. ' Dr. 'Rodger states: h appear ' justified' usthg FES values might "Some of the augments whic become ' unjustified' if 'the costs doubled or trebled, but the degree of 'unjustification' would not beccme so great as' co give rise to II and . conclusive arguments that any of the augments listed in Exhibits i III should be recoved." 4 l i I i 3; i i - 1 i f: 1 earing Transcript p-3912, Summary of Additional i H l 28, 1973, p 9. -2/ earing Transcript 3927-3928. -H t V 1 t + 9 ~
- v-
~ c.,., y n,,-.. - e
y, ~, ~. sseus - 1 eo, 1 e$n \\I s i 64 'L,, The Cost Benefit Balance-Thoul'a the costs of installation and operation of radwaste systems were, "'i differ-ns indicated above, a matter of #:ontroversy, an even more fundamental r Staff and the etr ee of. opinion existed (primarily between the Regulatory [ 'llonso'lidated Utility Group) over',the canner in which cost-benefit bala F F yas to be' done. the Regulatory Staff has, for each effluent type, added the i In effect, i . ld several radwaste augments as c unit to the ba:e case dual light-water-coo e 12/ From esti=ates of the cost of the radwaste
- nucicar power.reacter system. '-
f augment package and calculation of the resulting decrease in radiation expo in dollar cost per man-rem of , to the population the Staff obtained a value i The Staff also included ' / I in the L resulting reduction in population dose. dose; total coct of th'e radwaste system the cost of the residual p'opulation for this calculation the Staff showed costs resulting from a vide range of This added cost, dollar values for cost of a man-rem of' radiation exposure. f radwaste augments, yhich is.very small for all except quite unacceptabic sets o neems not to have been objected to by other parties who replied to tha staff s Concluding Statement. the 'After publication by the Staff of the Final Environmental Statement, I initial position of CU included a real objection to the Staff's choice of the In his written testimony, Dr. Walton A. 7.odger base case radwaste systems. characterized as!" completely unrealistic" the base case radwaste systems for PWR liquids / and for BWR liquids.b! He also argued that the base case for E AIFinal Environmental Statement, Wash 1258, July 1973. 20, 1974. 2/ oncluding Statement of Position of the Regulatory Fraff, Feb. C l A. Rodger on Uc- -- Hearing Transcript. p 3909, Additional TO.;timony of Dr. Wa ton 3/ half of the Consolidated Utility Group, :;ov. 9,1973, p 25. b! Ibid., p. 32. e
e m m PWR gases was unrealistic 1/ but stated that the base case for BWR gases was reasonably representative of an unaugmented EWR. - In the Su= mary of this testimony Dr. Rodger made the same claim of "unrealism" for the base case PUR 3/ and DWR ligef.d :radsaste systens-but suggested that th'e base case gaseous radwaste syste::.s for both reactor cypes were reasonabic.4/In response to questioning Dr. Rodger stated that the degree of unrealism for the PWR base case gaseous radwaste system "is not really enough to argue about." / 5 It is cle;ar that if the base case radwaste system were improperly chosen so as to lead t:o large (calculated) doses to the population the subsequent cost-benefit balance: might show that unrealistically expensive radwaste augments could be justified. This could be true especially if the cost-benefit balance were done by considering several radwaste augments as a unit. We believe that the recor6 shows cicarly that the base cases for gaseous radwaste systems are not unrealistic. It is entirely possible that the liquid radwaste base cases celected by the Staff are somewhat unrealistic in that they do not represent How-the systems employed in modern light-water-cooled nucin r power systems. ever, as it will develop in the following discussion,this "unrealism" - if it exists - has little or no effect upon the actual cost-benefit conclusions. ThemajorthrustoftheCUargumentagEinsttheStaff'scost-benefit balance, however, concerns the practice of adding the several radwaste augments As Dr. Walton Rndger stated for CU:6/ to the base case as a unit. i N aring Transcript p 3909, Additional Testimony of Dr. Walton A. Redger on He Behalf of the Consolidated Utility Group, Nov. 9, 1973, p 8. NIbid., p 16. - Hearing Transcript p 3912, Summary of Additional Testimony dated November 9, 1973, 3/ of Dr. Walton A. Rodger on Behalf of the Consolidated Utility Group, Nov. 28, 1973, p 4. Ibid., p 6. 5/ - Hearing Transcript p 2950. MHearingTrancriptp3909,Dr.WaltonA.Rodger,Nov.9,1973,p1. s
- m. -
66
- %sen "OraofthemajorcommentsUnichtheUtilityGroupmadeconcerning the cost-benefit analyses of the Draft Environriental Statement was
'~' - thst the data were presented in such a manner as to hide the extra-- ordinarily high ratio of cost-to-public benefit received for most of'the compor.ents of the cases which were chosen for presentation. ~ l In the preparation of the Final Environmental Statement the Staf f I they went even farther in masking I i not only ignored this comment, the fact that some of the additional treatments p,roposed are vastly This was done by eliminating even the more expensive than others. rudimentar; case-by-case differential costs which were included in the DES." ' n the Summary of his written testimony / Dr. Rodger stated: 1 I "The thrust of the Testimony which we filed on November 9,1973 was to break town into their component parts the cost-benefit analyses presented in the FES. The first purpose for doing this j' was-to demonstrate that while some augments to the gaseous and i' liquid radwaste systems of PUR and EWR are justified on a cost-l i L benefit basis, others are not. In fact many of the augments con-sidered in the FES result in the expenditure of incredibly large The " lumped" i ^ numbers of dollars for every dollar of'value returned. L l approach used in the FES cost-benefit analyses completely hides t this fact." In effect, Dr. Rodger used the Regulatory Staff's dose calculational models and _ the Sta f f's values for annual releases of radioactivity and annual costs for the radwacte augments and conducted the cost-benefit study by adding Hearing Transcript p 3912, Summary of Additional'Testicony Dated Nov. 9, 1973 ,on Behalf of the Consolidated Utility Group, p 1. e e
W' ?
- t' aW
-67 augments individually and sequentially to the liquid, the noble gas, and the iodine and particulate radwaste systems. By this technique of sequential addition of the most effective radwaste (so that in eff ect each addition constitutes with the other augments augment aircady present a new base case to which the next is added) the cost-benefit i ~ 4 evaluation can show the true' worth of each individual augment. We, the Atomic Energy Cem=ission, must agree that the cost-benefit . balancing methods employed by CU are superior to the approach used by the Regulatory Staff. Accordingly, where Appendix I, below, directs that augments that sh'ow a f avorable. cost-benefit ratio for _ reduction of population dose be included in the radwaste systems 'for light-water-cooled power reactors, we intend _ that the worth of the augment be assessed by this procedure. 4 In the cases, and it appears that there are several, where the radwaste system consistency of all items showing this favorable cost-benefit balance for decreased dosage to the population will also ensure that doses to individuals near the light-water-cooled nuclear power reactor facility is within the design Where such objective guides no further augments appear necessary or desirable. a system, and it alsu appears that there may,be several such cases, does not ' meet the design objective guides for doses to neighboring individuals then additional augments are required even though they cannot be shown by this or other techniques to have a favorable cost-benefit ratio. B. Choice of Specific Design Objective Guides In its original version of Appendix V the Regulatory Staff proposed to limit the annual dose to any individual from radioactive materials in both liquid and gaseous effluents from all light-water cooled power reactors on a p
- s. )
n 68 sh total body or to any organ.1,2_/ site to 5 millir:m: to th2 General Electric (GE) has reco= mended that the design objective dose i values -for each light-water-cooled nucicar power reactor be modified to l'.' of 3/ CE states-- the FRC radiation pr.otection guides. The ALAP numerical guides should be estab- "1. Dose Objectives. 11shed in terms of dose-limiting objectives for the nearest neighbors I f of light-water reactors and should equal one percent o f the present I l Federal Radiation Council Guides for the whole body and each body \\ l Specifically, the objectives should be 5 millirems per year i organ. for the total body, 15 millirens per year for the thyroid and 30 millirems per year for the skin." 4/ The Consolidated Utility Group indicates in its Statement of Position- "2. Dose Levcis.. W strongly urge at a minimum the adoption of 1% of ICRP values for individuals in the general population, including ICRP The individual thyroid values for organs other than the whole body. dose objective should be changed to 15 mrem f or children and 30 ctrem for adults, and the individual skin dos'e should be changed to 30 crem. If undue costs and restrictions on siting are not to be incurred, (i.e. seicetion of a more representative individual for dose calculations and 'iimitations of doses from radioactive efflucnts on the basis of each If neither of these recommen-reactor instead of a site limitation). dations is accepted, a very much larger increase in permissibic individual dine thyroid dose vill be required to avoid the addition of expensive io 1 1!A1AP AEC Staf f Exhibit 1 Lb 1. / - Concluding Statement of Position of the Regulatory Staff, p 48, 2/ j 21, 1974, - Closing Statement of the Genatal Electric Company, Jan. 3/ pp 12, ~', 28. 19, 1974, - Statement of Position by the Consolidated Utility Group, Jan. 4/ pp 68, 69.
wa. \\ Ay. 1= wp. 69 .= control and treatnent systems which are entirely unwarranted in tems i 3-of population dose reduction." g, The State of liinnesota in its Final Statement appears to endorse the original Regulatory Staff pocition to limit the annual dose from all reactors at a site to 5 millires to the total body or any organ.1/ Douglas LaFollette has also indicated his strong support of this position.EI Several other suggestions were made. The Tennessee Valley Authority E suggested that "the costs an.d consequences of achieving 1% of Part 20 limits shc41d be carefully balanced against the cocts and conseqsences of achieving instead, for exa=pic, 10,*: of Part 20 limits." Dr. Merril Eisenbud suggested ] on behalf of the Atomic Industrial Forum the value, 5 millires to the whole body, gonads or bone carrow and 15 millire= to all other organs.4'5/ National Intervenora, / while agreeing that it is technologically possibic for plants 6 to be operated =t 1% of Part 20 limits argues that no radioactive discharges should be permitted. At the other extre=e, C. Hoyt Whipple 'E considers that 1 numerical guide lines other than those given in 10 CFR Part 20 are unnecessary . since."the interpretation of 10 CFR Part 20 by the nuclear industry has resulted in perfomance so exec 11ent that there is no need for further incentive." Andrew P. Bull, who was a li=ited participant throughout the hearing, E! that a boundary limit of 25 millire=s per year whole body dose would argued be consistent with his proposed population dose of 2000 naa-ren per year limit for population dose from each 1000 MWe reactor. 1 Final Statement of Position of the State of Minnesota, Feb.1, 1974, pp 8 and 17. 2/ - Final Environmental Statement, Wash-1258, July 1973, Vol. 3, p 38. M1 bid, p 314. t, / - Ibid, p 96. 5/ " livaring Transcript, p 36, Statement bv Merril Eisenbud, p 5. ' t/Anthony Z. Roesman to Algie A. Well et al., Feb. 15, 1972, p 7. Ulhat 1:nvironmental Statement, Wash. ~ 253, July 1973, Vol. 3, p 94. n / h.n t j e.,m.. ,, r c. u-.f. me-,u, -un n- ~ 4 u-cM f y V ro 10 rra nwr to
.,~rm : 70 the limiting In its Concluding Statencnt the Regulatory Staff agrees that dose for all light-water-cooled nuclear power reactors on a sice to the thyroid 1/ should be changed fros 5 =1111rens to 15 millire s per year and states:- "As a practical matter the dose to the child's thyroid is controlling The Staff's for purposes of design objectives and operational control. shows reco:mendation is based on evidence developed in the record that l that a design objective of 5 millire=s per year is not practicab e at ~ co'the state-of-technology and costs of iodine ~ this time with respect removal equipent for those sites where milk cows grace in the near vicinity of the sita." 1 the Regulatory Staff also recer.:= ends In thd same C ncluding Statement that: "the skin dose due to external exposure from beta and ga=ma radiation released in gaseous effluents should be changed fren 5 to 15 millire a per year because it is not prceticable to design to limit the beta dose to 5 millire=s per year." The Regulatory Staff continues to reco==end that the design objective dose from radioactive catorials in liquid effluents from all. light-water-cooled the total nuclear power reactors at a site Le kept at 5-millirems per year to 2/ The Staff argues that both the' Consolidated Utility body or to any organ.- is b agree that this design objectivt Group _/ and the General Electric Company 3 practicabic for liquid effluents. 20, 1974, p 49 1! oncluding Statement of Position of the Regulatory Staff, Feb. C and pp 25-30. 20, 1974, p 50. 2 lConcit. ding Statement of Position of the Regulatory Staff, Feb. '1! earing Transcript pp 3996-3998. H 21, 1974, p 16. 1IClosing Statement of the Cencral Electric' Company, Jan.
a_. E mq'a 71 Eo::cycr, in its Repl-[! the Cer.r:lidated Utility Group stated: "In'our testimony at the hearing on the FES, due to time limitations, We have we confined our cocments en the liquid cases to River Sites. now been abic to analyze in d6 tail the liquid cases for both FUR's and ] BWR's 'for all three site reginas and for both once-through cooling and It is true,that'for River Sites, for either PWR or' ' cooling towers. 'BWR and for either cooling node, there is no cost penalty, over and above costs of augments which are ' justified on a population cost-benefit basis, to meet a licit of 5 cres/ycar to an, individual even using the Staff's conservative dose models. When the analysis is expanded to include Lake and Seacoast Sites, however, this is no longer true. Using the Staff's bodels, bases, and cost estimates, additional augments, over and above those which can be justified on a cost-benefit basis, are required to meet the design objective dose of '5 mrem / year for the following combi- ~ nations: Reactor Type . Regime Cooling Mode *[' FWR Lakeshore Cooling Tower Cooling Tower FWR Seacoast BWR Lakeshore Cooling Tower BWR Seacoast Once-through BWR Seacoast Cooling Tower
- The dominance of cooling tower cases in the above listing reflects the smaller discharge streams and therefore higher concentrations of radio-These higher concentrationc in turn increase nuclides in those streams.
the dose to the " maximum individual" reflected in Staff models." 1! onsolidated Utility Group Reply C e
w r,+ 0' } ^w. mWi 72 For Individual Light-Water-Couled Nuclear Power Reactors 1. f
- ke have decided, -largely.in recognition of the relative weighting o s
h total body and organ dose limits recommended by the FRC,the ICRP and t e NCRP, to adopt as our basic design objective guides the limits for dosages 3 to individuals,from effluents f, rom each light-water-cooled nuclear power l reactor of'5 millirem per year to the total body, 30 millirem per year to s I "he thyroid. Such adoption, which ,\\? the skin and 13 r.111res per year tw is only partially responsive to the reco=mendations of the Regulatory Staff, h essentially adopts as the design objective guide for an individual lig t-water-1 cooled nuclear power reactor a value equivalent to 1% of the FRP standards.. i the radioactive material ll. .For: liquid effluents the design objective lim ts that.may be. released'from each idght-water-cooled nuclear power reactor to in an annual dose to any individual ' that annual total quantity that will result l body, 30 in unrestricted areas not in excess of 5 millirems to the tota - It is assumed 1 millirems to the skin, and 15 mi]lirens tc any other organ. i t that rivers are used as sources of drinking water and rivers or other part nen h afood unless. positive ' bodies of water are used as sources of fich or ot er se The models also assume (as discussed h ' evidence to prove otherwise is provided. in more detail under Implementation, below) that near neighbors of the light-water-cooled nuclear power reactor include individuals with habits We believe that the record indi- . differing significantly from the average. 1 t cates that it is practicable to meet this design objective and that for
- h..
many if not all reactor sites this design objective can be met with radwaste ~ dosage to . systems which show favorable. cost-benefit balance for reduction of I the general population. l I r e f ~
v t#M%r>4. .aP : w I gme E 73 The ' design objective to control caternal exposure from gaseous effluents J has been expressed in terms ;of. a limitation on' the annual dose rate duc' to gamma radiation or beta radiation from each reactor.at or beyond the boundary of'the site. This design objective, in effect, ;*ovides ficxibility for 'f considering: site-r-laced'c.:w.1.co. logy and the distance-from the reactor to the site. boundary, but requires the assumption be made that people may live 'just outside the site boundary. The specified dose rates of 10 millirads per year for gamma radiation and 20 millirado per year for beta radiation would normally be considered to meet the objective of ' limiting do.ses to individuals in unrestricted areas to not more than 5 millirems to the' total ' body and to icss than 30 millirems to the skin. Provisions are made to decrease this annual dose rate if, for a particular site, there are special circumstances that necessitate'such a dect==== to assure -that an individual q in an unrestricted area cnall not receive more than 3 milliress total body permit release . Provision is made to / increase in this/ rate shod 1d special site exposure. characteristics or circu= stances indicate that such increase vill not lead to individual dosages above 5 milliress per year to the total bo *y or 30 milli-rems to the skin. In practice, such an increase seems unlikely to be invoked .since the additional requirement for all radwaste equipment with. favorable s co.st bcnefit balance for decrease of population dose is expected to be We bell' eve that the record indicates that this design objective controlling. I is practicable for individual light-water-cooled power reacters at essentially all sites. The design objective for radioiodine and radioactive material in particu-late form was, as indicated in many places in this statement, probably the most difficult iscue in this proceeding. The design objective has been set 4 e b -m
~<, a YI) Ski Yhsk - 74 i l in particu-to insure that emission of radiciodine and radioactive mater a ' late from each light-$ tater-cooled nucicar power reactor shall not result in .ya h an annual dose for any individual in unrestricted areas from all pat ways For virtsally all cases of exposure in excese of 15 millire'es to any organ. his source. the thyroid dose vill be the only one of real consequence from t As indicated in' detail under Implementation, below, the design objective qu'antity is to be calculated at the location of the nearest milk cows that are actually present at the time of design and' construction of the reactor. The design objective is not required to be based on an assumption that cows are present where there is potential pasture land in the vicinity of the reactor if they are not actually present at the time of design and construction of the The future uses of the environ =ent with respect to food pathways will reactor. be protected by the lihiting. condiciens of operation that 'rcquire monitoring and surveillance programs that are designed -to identify changing innd uses 1 L Appro-with respect to food' pathways that may result in exposure from iodine. l priate control ceasurcs, including the modi.fication of land uses, would be l the design t \\, required if monitoring programs during operation indicate that objectiveguidelevelsarebeingexceeded.- Ns I As a further requirement in addition to the design objective guides described above, the radwaste systems shall include all items of reasonably demonstrated technology that can effect reductions in dose to the general ,r r . population for costs not in excess of $1500 per' man-rem or $500 per man-thyroid-rem. Such a provision will assure that selection of a very large 'n 1 18olated site cannot justify release of large quantities of' radioactive t and, especially radioiodine, simply because no substantial individ-nstert.ild tist-doses would result. e t e a
__[ mW ! mw : f+ r 75 \\ %W s 2. Multiple Light-Uster-Cooled Nuclear Power Reactor Systems in a previous Section of this Statement of Considerations we announced, 2 after consideration of'the several points of view in the Record, a decision .g s in f avor ~ of design objective guides. to be met by each light-water-cooled nuclear reactor with an additional limit upon releases by all such reactors on a site.or on nearby sites. 'To this end, Appendix I, which he now adopt, would require the applicant to provide reasonable assurance that the proposed . reactor, in combination with all other light-water-cooled nuclear p'ower y reactors on the site and on nearby sites, would meet the several design objec-In this rule "other light-water-cooled nuclear power reactors" is to tives. mean light-water-cooled nuclear power reactors for which applications have been filed with the' Commission for construction permits and.which are expected to operate while the proposed reactor operates. As indicated in detail in a preceding portion of this. Statement of Con-siderations1/ the AEC Regulatory Staff and the Statement of Minnesota have con-sistently f avcred design objective guides that would limit releases from all reactors on a site. CU and GE have f avored guides on a per reactor basis, and all other participants (though one can infer a preference in this matter) have remained silent upon this question. .The' Consolidated Utility Group argues for no additional limit on radio-General active releases other than that imposed by the per-reactor limit.
- Electric, on the other hand, suggested 2/ that:
For any combination of nuclear power reactors on one site, on adjacent sites, or on nearby sites, the applicant or applicants shall, in addi-tion, provide reasonable assurance that the total incremental annual 1[ BASIS F0n DESIGN OBJECTIVE VALUES: D. Per Site versus Per Reaction, pp 47-53. 21, 1974, p 28-29. AIClosing Statement of the General Electr:.c Company, Jan. I as f 9 w .n m ---g w )
m, i wars % l!} 76 exposure (fromeitherairbo'rneorwaterborneeffEuents)toanyin-divisual in unrestricted areas will not exceed four (4) percent of the Federal Radiation Protection Guides, as set forth in Federal Radiation Council Reports Numbers 1 and 2, iby 13,1960 and ' September 1961, for doses, to the total body or any organ." Vc, the Atoale Energy Commission, are convinced, as stated in a that thz Record amply justifies design previous section of this Statement, objective guides for multi-reactor sites that differ from those for an indi-However, the Record vidual light-water-cooled nuclear power reactor. scarcely addresses the question of - and presents little if any specific . information concerning - the quantitative evaluation of what such limits It is,accordingly and after careful consideration of the Hearing should be. Record, ne essary that we nse our collective judgement upon this question that an arbitrary one. and/we pronounce a decision that must be, to some, extent, the design objective guides proposed by the General We believe that Electric Company -- that is that the releases from a site a'nd from nearby sites should be permitted to be as much as 4 times the permitted releases per reactor - are too liberal to be ccustrued as "as low as practicable." We ' Eave instead chosen to set the limits upon all. light-water-cooled nuclear power reactors on a site and on nearby sites in the following way': For liquid effluents the calculated annual' quantity of all radioactive material above background to be released from the proposed reactor in combi-nation with all other light-water reactors on the site or on nearby sites must not result in an estimated annua'l dose for any individual in unrestricted areas from all pathways of exposure in excess of 10 millirems to the total e 9 9
c:,, @n,na L:. 77 K. This y other, organ. body, 60' millirems to the skin, or Il0 millirems to anto an indiv guide - which effe'etively limits the dosage f givingits an appreciable l water-cooled nuclear power reactors capab e otor - seems to us, ) dosage to.twice the permitted level from a single reac dily achievable at most if not af ter -consideration of the Record to be rea bic gases to unrestric- .all-sites. The' design objective guides for release.of the no d nuclear power reactors on a site or on ted arcas_from all light-water-coole values for an indivi-h are also set at values thct are twice t e As in the case for indiv'idual~rea'etors, there nearby sites dual reactor of this type. lease rate for noble gases f ' are' provisions for increasing or decreasing this re se' vithout exceeding an should special circumstances permit such an increa or'more than 30 ~ '1 bodv, ta individual dose of more than 5 m1111 rems r
- ke' to l circumstances' require such a millirecc to the skin or should specia dosi in excess of 10 decrease to insure that no individual sh i
~ millires to the total body. i able for viriually all sites view that these design objectives are pract cWe are and combination of sites, s' indicated above vill release rates permitted under special circumstancete system seldom occur since the requirement that radwas ulation exposure vill justifiable on a cost'-benefit basis for total pop t generally be controlling. f radioactive iodine and ' The design objective values for release o ll reactors on a site radioactive material in particulate form from aindividual receiv nearby sites have been set to assure that no o e
0,_ .wg wy 78 ~ f This value is equiva-source organ doses in excess of 45 millirem per year. 1ent to three (3) times the design objective guide for an individual light-l, This guide in somewhat more liberal water-cooled nuclear power reactor. (3x rather than 2x) than those for liquid effluents and for noble gas efflu-ents because the Record.makes abundantly cicar that for most sites this It seems to us that, while there guide is by far the most difficult to ceet. l may well be several sites when this guide will require radwaste augments over and above those justifiable on a cost-benefit basis for doses to the total population, this guide as stated will not unduly restrict grouping of. light-water-cooled nucicar power plants on favorable sites. The language of this portien of'the rule is such, and we the Atomic i Energy Cc= mission intend, that the burden of compliance should be upon the applicant for (an) additional reactor (s) at a site or at a nearby site. Should the applicant have control of (own) the "other light-water-reactors" he would clearly have a choice as to,the extent he wished to change their radwasto systens to ease the requirements upon the new reactor (s) cntering Should the applicant be proposing a reactor on, a site nearby ~' the cocplex. to other light-water-coolad nuclear reactors that he does not control he would of necessity have to show that his proposed reactor would meet not only the (in . design objective guides for individual reactors but would not result combination with others already approved, planned, or operating) in releases Since a above the design objeccive guides for the total system. separation distance of a very few miles seems adequate in nearly all cases to avoid appreciable additive effects'for dosage to any individual it does not ecem to us likely that this rule will often prevent use of generally . favorabic sites by applicants.
-~. .~ ~. -.. - ~ ~. - - - - '- u me ' C. Besalins'In-Plant Control Measures lIn the revised version of Appendix I included in its Concluding Statement, 't the Regulatory Staff. introduced' for the first time in this Hearing the position ' that exceptions to certain of the numerical guides for design objective values would be allowed if certain " baseline in-plan't control censures" were proposed by the applicant (in his radwaste system design.1/ Those excep'tions were avail-able for liquid radwaste syste=s, and for sy. stems for control of radiciodine and radioactive materials in particulate form. ) 1The' Staff's proposed design objective guides for liquid effluents are set 12 / forth in the following:- b in liquid effluents to be f "A. For radioactive material A ove background -b . released te unrestricted areas: The calculated annual total quantity of all radioactive material from j 1. all light-water-cooled nucicar power,regg,t,o,rs at a site should not result in an annual dose or dose c ::it=ent to the total body or to any organ of in ,,,,,, an individual in an unrestricted area from all pathways of exposure ^ 1 excess o'f 5 millire=s; and The calculated annual total quantity of radioactive material, except 2. tritium and dissolved gases, should not exceed 5 curies for each light-water-cooled reactor at a site. s
- " Background," means the quantity of radioactive material in the effluent
.from light-water-cooled nuclear power reactors at a site that did not originate in the reactors." t.. I b Concluding Statement of Position of the Regulatory Staff, Feb. 20, 1974, pp 26,27 and 30. '2/Ibid..pp 26-27. 4 { l k .5 ' 0 4
8 Q' ] 3. Notwithstanding the guidance' in paragraph A.2, for a particular site, l l if'an applicant for a permit to construct a' light-water-cooled nuclear g - ' reactor has proposed baseline in-plant control measures- / to reduce the possibic sources of radioactive material in liquid effluent releases and the calculated quantity exceeds the quantity set forth in paragraph A.2, the requirements for design, objectives for radioactive material in liquid effluents may be decced to have been met provided: the applicant submits an evaldh ion of the potential for effects a. from long-tern buildup in the environment in the vicinity of the site of radioactive material, with a radioactive half-life greater I than one year, to be releases; and ~ b.' the provisions of paragraph A.1 are met.
- Such measures may include treat =ent of clean liquid waste streams (normally critiatcd, aonaerated, low concuccivity equipment drains
~ and pump seal leakoff), dirty liquid waste streams (n'ormally non-tritiated, aerated, high conductivity building sumps, floor and sample station drains), steam generator blowdown streams, chemical waste . streams,. low purity and high purity liquid streams (resin regenerate and laboratory wastes), as appropriate for the type of reactor." It is clear-from this proposed rule that incorporation of these-baseline -plant control measures would permit annual releases of more than 5 curies-of' radioactive material (other than tritium and dissolved gases) per reactor. However, the Staf f has not proposed exceptions to the dosage limit even if these measures are used. We, the Atomic Energy Commission do not believe that inclu-sion of " baseline in-plant control measures'i would justify an increase in the permitted design objective values, which we have set for dosages to individuals, noT do we believe that the record would justJ.fy such an action. Accordingly, and since we have already (as described above) removed the quantity limits from y +
M w: 85 m $?$. IMPLC:C TAT 0:: OT :::::CICAL GUIDELINES Tha numerical guidelines of Appendix I, when applied in accordance with l the conditions specified therein, are a quantitative expression of the ccaning e+w If the requirc=cnt that radioactive =aterial in effluents reless,ed to unre- ) stricted areas from light-water-cooled nuclear power reactors be kept as low as 4 These guidelines,'particularly with respect to design objectives, 1 practicable. The-are expressed as specific nunerical limits for three types of effluents. ) . numerical aspects of this translation of the basic rule of Section 50.34a, stand-ing along, are clearly a compromise of the rule, in the sense that a quantitative level that might be precisely as low as practicable in one case would not neces-The nu=erical guidelines were chosen'on the basis that sarily be so in another. the record shows these limits 'to be practicably achievable for almost all cases ~~ to which we consider them applicab1e. Furthernore, in viev of the elements of conservatism and realism inherent in the evaluations presented in the proceeding, we believe the record supports the con,,clusion that the caximum individual ex-posure likely to ensue frem operation of a single nuclear power reactor in con-formance with Appendix I is sufficiently s=all that no additional expense could be justified for reducing the exposure of an individual further. It must be understood, in discussing the matters of calculational conserva-tism and realism, that Appendix 1 means, implicitly, that any facility that conforms to the numerical and other conditions thereof is acceptable without It is just as essential that further question with respect to Section 50.34a. Appendix I be understood as not i= plying, conversely, that any facility not con-Thus the nu=crical guidelines are, in this forming is necessarily unacceptable. sense, a conservative set of requirements, and are indeed based upon conservative evaluations. .4 e e
asym; t s py :. AM, 86 The numerical guideline values were adopted in the light of numerous These evalu-evaluations ofl typical nucicar plants at various types of sites. ,+ ations, presented by various parties, were based upon calculations of radiation l doses, which generally could be understood as estimates of the icvel of exposure of ' individuals in the general public.from assumed releases of radioactive Similar estimates.will have t'o be made on a case-by-case basis'by - material. applicants for licenses for light-water-cooled nucicar power reactors in order to establish appropriate design objectives. It is. evident from the record that numerical estimates of radiation exposure These assumptions may vary'widely, depending upon the particular assu=ptions made. hnaturalphenomena, involve the selection'of appropriate mathematical expressions o including the assignment of numerical values to the parameters contained'in the Inasmuch as results of calculations can vary widely, an issue has . expressions. been raised' by some p#articipants as to how the numerical guidelines may be im v The necessity and importance mented in consonance with the process of their adoption. of adequate attention to numerical calculational procedures was expressed by D Walter H. Jordan, a member of the ASLB:11 "[t]he interpretation of Appendix I is almost going to be as important a factor in what is practicable as the regulation itself." Some parties proposed that Appendix I include guidance on implementation in order to assure that applican:s have the opportunity of using reasonably re 2 3,4/ istic assumptions in their procedures for estimating radiation exposure.,_- The d necessity of explicit guidance is suggested on the argument that the procedure -by the Staff for calculating doses show. a predisposition to make unnece 1 r 2547-48. T '1! Closing. Statement of the General Elcetric Company, pp 26-4f. 1 13-14, 71, and A-4. [ M atement of Position by the Consolidated Utility Group, pp St 4/ . t + m ~ ~ -
..w s -r, 87 m.w -
- ~
conservative assumptions. A typical ' expression of such an argument is the 1 statement of General Electric: "In spite of th'e evidence submitted by the ALAP participants, and in' x., spite of'the admissions of the Regulatory Staff,-the draft Regulatory Guides circulated by the Directorate of Regulatory Standards with the i ' Staff's Concluding Statement confirm the previously evidenced tendency ' toward the use 'of overly conservative calculational assumptions." The methods described in the Final Environ = ental Statement and in draft Regulatcry Guides attached to the Staff's concluding statements are opposed in some particulars;2/ furthermore it was also argued that the Staff has, in the course of reactor licensing ' actions, generally been quite conservative in its qdantitative assessment of effluent controls Particular areas of controversy shifted as the proceeding progressed. Both General Elcetric and the Utilities su:marized their areas of concern 4 l i with regard to conservatism in closing statements as follows:3/ CU states; "Exampics of overly conservative asse:ptions and codels used by the Staff are difficult to extract unambiguously f. rom the record for two basic e reasons: e (a) the time spanned by these proceedings has resulted in some changes in.the assu=ptions apparently used; and . (b) it is not clear whether or not models and assu=ptions used in the FES are also intended by the Staff.to be applicable to the analysis of individual applications in the implementation of Appendix I." 1/ -- Reply Statement, page 10. -- Closing Statement of General Elcetric and State =ent of Position by CU above. 2/ GE Exhibit 6, and GE Exhibit 7, and Oral Argument, TR 110-See also Testimony '127. 3/ - Statement of Position, page 44. O 9 e =cm
! t % me
- y y
- ;
"*tiftth$c t i ' ' General Electric:1/ ~ [ " Examples of overly conservative implementation methods likely to be l licens-xm . employed for Appendix I--as they have been in current project -f dio-ing -include excessive source-tcrs assumptions with regard to ra l h emissions, of their , lodine c.nissions; neglect, with regard to suc chemical form, actual release points and modes, and expected plume ~ l behavior; overestimation of deposition rates.and retention factors for radiciodine on forage; and' postulation of nonexistent dairy cows a'nd unrealistic milk consumption patterns." l ding statement, Following the filing of the Regulatory Staff's conc u General Electric noted.important i=provecents in the Staff's proposed Appen dix I, including.some dealing with calculational models; but they maintained "[t]he first--and in our view the most serious -- defect of Rev i. l. Appendix I is the continued absence of any guidance therein for the l. i l R'evised Appendix I still fails to l l implementation of.'the Regulation. specify whether' the calculational assumptions and models to be emplo i in implementation are to be established.on a continuing ' conservative I basis or, as CE urges, on the basis of best-estimates _of the relevant I physical phenomena."- The' Staff argues neither fors nor against including guidance or calculational as sumptions in Appendix I, although in testimony the Staff's principal witness con-cedes:M f l "....there are particularly critical points that have been raised in the hearing in specific areas with respect to implementation where perhaps at the time of issuance of Appendix I, some specific point needs to be pretty l well pinned down at that point." 1/ - Closing Statement, page 5. 2/ ~, Reply Statement, pages 2-3.
tn [ A%V4 gg g%- Tha Staf f observes that Minnesota advocated including a " standard set of models ano input dna" in~ the Regulation while both Cencral Electric and Consolidated Utilitics suggest that "models, assu=ptions and parameters" be put into i. RegulctoryCuides.E f + We believe the evidence at hand supports the decision to include Co= mission guidance re'specting the use of conservative or realistic calculational proce-We dures in the application of the numerical guides for design objectives. wish' to sum:tarize the matters involved in reaching this conclusion and in apply-ing the guidelines in accordance with Commission intent. Calculational procedures used, in the application of Appendix I for making the numerical estimations of radiation doses have been variously called by such terms as " calculational assumptions and models", "models and input ditta," " assumptions and models" or simply "models." Such procedures require the skillful use of mathematical expressions characterizing natural phenomenas it' - % also evident that such expressions are generally expected to yield quantita-tive results which are, at best, approximations to reality. Simpler models, for exa=ple, ones which would not embody any facility for taking into account differences in plant design, would not be expected to produce estimates as close to reality for a vide variety of designs as would more complex models. f Calculational procedures used for dose estimations in essence describe, 4 albeit'approximately: i (1) sources of radioactive materials and the pathways inside a plant by j which such materials are released; (2) the natural processes by which released material.is transported through the environs; and l - Concluding Statement, Regulatory Staff, page 74 and State of Minnesota, 1/ l' Final Statement, page 11. l [ i
i ""#' 90 y e h%t44W1 ths model receptor, that is, a real or hypothetical individual ulti-(3) mately crposed to radiation. The selection of specific nodels for cach of these three portions of the proce-First one must select modela and dure involves two types of determinations. ~~ For cxcmple, the data which. represent the situation deemed to be important. choice of a hypothetical receptor rather than an existing individual might ..t=.... . the intent to use the guidelines as a cechanism to provide reflect, in part, The Regulatory Staff for future changes in occupancy of areas near the site. identifico this as a means of expressing Regulatory intent: proper 1 "It is the Staff's position, the example, that for purposes of design objectives for nuclear power reactors it is inadequate to base param- , - = - - -. as of the time the reactor is eters only on uses of the environment Rather, future uses of the e.tvironment should designed and constructed. = (. be taken into account....'- - Secondly, models and data cust be found which represent the physical phenomena ' Conflicting views have been advanced, in involved with some useful precision. on all portions of the calculational procedures and evidence and in argument, .w--. for both types of relections.- T: - - - It was observed by both General Elcetric and Consolidated Utilities that considerabic progress toward agreement on models was made in the course of the ~ - :.. 2-proceeding, although the intent of the Staff in future impicmentation of the . : - - - 1.-- numerical guidelines on a case-by-case basis recained in doubt after the Staff's - c. Concluding Statement was filed.3/ We believe we have developed a suitable resolution of the differences for all practical purposes, although we realize ))See Cloning Statement, page 52. -- Note particularly the citations above to testimony, closing statement and 2/ argument of General Electric Statement of P;sition by Consolidated Utilitics. 3/ -- General Electric, Reply Statement, page 2. f {
%u? lm. 91 .y 1 ! - i that some other set of guidelines might have served our purpose 'and pleased one party or he other more. Our resolution strongly favors the suggestions that ca1culational methods be rea? tstic, which in turn has influenced our i This adoption of particular nuscrical guideline values for dose objectives. ] ~ f resolution, thus, haa been a strong f actor in our reconciliation of the dif-ferences among parties as to thdse values; for GE states in their reply to Co'nchudingStatementoftheStaff:3, ~ ~ "The evidence is clear that, realistically applied, the dose objectives now presented in Revised Appendix I can be met without reliance on ex-ceptionsorspecialprovisions...." The essence of our conclusions on calculational procedures to be used in s.. determining design objectives is given in the five following points, which we zu _ -- z. -- -~ neither presume nor intend to be uniform in detail or comprehensive. ,, __1.. An. applicant should.be free to utilisc as,ealistic.a model for' r characterizing natura.l..ph. enceena, i. nc..lu.. ding, plant performance, as he considers usefu_l.. An. a.pplicant. may t.a.k.e i.nt.o.. account s.__.. _. ._ ___. situations not adequately characterized by a standard model with ._. g?.espect.to specific fe.atures_of plant design,_ proposed modes of ___g_.s.,.; plant.operatiou or local.. natural environmental features which are r _,_.,.not,likely to change significantly during the term of plant operation. _ General Electric notes several effects that should be recognized,2/ and we restate some of them 'here to illustrate natural phenomena which might be parEiallyorentirelyneglectedinstandar.d,_mo.delsbutproperlyconsidered: radioisotopic co position of effluents; A~... :.. r
- .;..m:,
._. :.m. :.- c' -- Reply, page 24. 1/ - - IConcluding Statement; pages 28-32. l
4 ~s.: auk u ipn ; ~ 92 ~ e n" radioactive decay o'f released nuclides prior to exposure.of ths f receptor;. waterway flow and the associated-diffusion'and dilution; j ,e.,- ' removal of radioactive caterialffrom solution or suspension in t ~- .the trater by.sedicentation or other naturally occurring ecchanisms or by water treatment. processes; l .) exposure modes'and occupancy or use factors; release conditions (to the' atmosphere) includingielevation of l release poin't, effluent stream buoyancy and momentum, and- ~ bui1 ding geometry; local meteorological and aerodrnymic conditions influencing- . i, airborne effluent pluce dispersion; beta and gamma. radiation energies for the radioisotopes released i and,the associated dose effects; chemical form and physical behavior.of the effluent constituents;; i plume elevation, si:c, and depletion; shielding effects; d other retention.and depletion effects; 6 partitioning, filtration, an deposition rates and velocities for the various chemical forms of released radiciodine on of f-site vegetation, ground, and other sur-faces, with~ appropriate apport.ionment to the vegetation cf its capture fraction; and weathering and other icos factors for radiciodine on grass and other vegetation. Clearly other natural phenomena must be adequately taken into account in I These are sufficiently estab-l models used for determining design objectives. lished in practice that they need not be repeated here. Although both General Electric and Consolidated Utilities asserted that the Regulatory Staff's intentions are uncertain, we believe the Staff is, agreeable to In their Concluding
- secepting realistic models different from standard models.
Statement the Staff quoted from the official statement published with each 1! Regulatory Guide: 7 1/ ~ - Concluding Statement, page 83. h o
~ 1 ~W w, 93- " Regulatory Guides are not substitutes for regulations and compliance' with them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basia for the findings requisite to the issuance or continuance of a permit or license by the Co= mission." As further evidence of tiiis disp,os,ition of the Staff (but not of the validity of their model) w'e further note that the Staf f stated, in the written response 4 to our request during Oral Argument:-/ 1 " Additional data available from staff measurements at BWRs (Ref.4) but which were not received in time for inclusion in the parameters and i bases given in WASH-1258 indicate that iodine releases from the radwaste building are greater than that calculated by the Staff's model and chat the model should be revised.... -In summary, the Sta'f has. attempted to c'evelop a model which realistically f i assesses the iodine releases from proposed reactors using data obtained i from operating reactors where pos'sible." We particularly expect all parties to licensing actions to which Appendix I applies to note both the potential utility of Regulatory Guides and their sub-We believe the ordinate status relative to Co= mission regulations and opinions. testimony of Staff witnesses in this proceeding night, by some reasonable persons, indeed be construed as indicating that the Staff has been excessively zealous in applying Regulatory Guide models. It seems reasonabic to expect the Staff to be willing to freely consider case-by-casedeviationsfromstandardjodels,fortheystate:-/ 2 1 t- 'A AEC Regulatory Staff's Response to Commission's Request During Oral Argument page 28. 2/ -- Ibid., pages 37-38. l l1
i v.m ,ym M/hd ,, 9 4 4 "There are many factors which influence the release acrodynacies for Some of these are shape and size, effluents emitted frca roof vents. f of the reactor facility building conplex, position of natural dra t n. coolin;; towers, position of vents within the cocplex,1ccal terrain While it conditions, and'plu=e rise due to momentun and buoyancy. h will permit is. agreed that at every sit'e hhere are circumstances whic the vent plume to escape wake cavity mixing, these circumstances are Therefore, a not readily definable f or many sites froa existing data. described in Renulatorv Guides _, general orocedure, which is custe?.arily this time. How-cannot'be incornorated into Reculatorv Guide 1.DD at d de- ~ ever, as with all Reculatory Guides, an adecuatelv substantiate d on a_ parture from the rodels cresented in the cuide will be acecote case-hv-case be.sg." Uhere selection of data is strictly a matter of interpreting ex-2. pericental evidence, both applicant and the regulatory staff should utilize . # */ prudent scientific expertise to select those values which would be exp ~ to yield estinates nearest the real case. 'The matter of how to deal with uncertainties in choosing data has been 'an implicit part of the evaluations made by participants in the proceeding. The data used by the staff in the evaluations presented in the Final Environ-acatal Statement were considered by General Electric and Consolidated Utilitie-to be seriously conservative.1,2_,3,y The staff has conceded that conserva-5/ It is our judgment, tisms exic':ed and were being re-evaluated continually.- l A! eneral Electric Closing Statement, pp 5 and 29 to 43. G E estimony of Ned R. Horton, GE Exhibit 6. T - Statement of Position, consolidated Utilitics pp 13-14 and 42 to 50. 3/ -4/ r 3909. -T O aff Response in discussion, Point 1, supra. St 4 N
ann m,a v4 95 in consideration of the detailed discussions of the models and data in testi-mony, in closing statements, and in oral argument, that specific models and data should not be standardized by incorporation in Appendix 1, as proposed by Minnesota. / Naither do we intend to judge in this decision which of the 6 many controversial parameter values would be particularly appropriate for use j in implementing the design objec't19e guidelines. We believe that the oppor-tunity to modify models and data as new experimental information comes to light _is a persuasive argument for permitting this matter to be dealt with by the preparation of_ Regulatory Guides.and
- y. case-by-case evaluations.
b
- 7I3.1-If: approximations implicit-in-c-model may produce a deviation fIios-the-true-result-the-directiendwhich is either uncertain or would tidddd;o-tinderestimate-dosage-or-if-available experimental information Icaves-a-rak-*sntial range of uncertainty as to the best esti= ate of some girEmeter val.ues,or both... data should be chosen so as to make it unlikely,
-.,--v.ith__all _such. deviations and_ uncertainties taken into account together, .._: Shat-the true dose _ would be underestimated substantia 11y'. J).q_got.ential. sources of deviation from a realistic dose estimate are Orte.is_the. self-inflicted use, at an applicant's dis-o_f_po.n..ern here. c --cretion,- of a-simplifi.ed. model which necessitates, in all propriety, the use The other is the exis- __,_ _of..some conservatism in.. setting design objectives. .tence, in spite of the best efforts of all parties, of experimental un-certainties respecting the selection of certain parameter values. I Mathematical mo,d_els describing the various sequences of natural ose to releases of radioactive material ' ~ he novhich relate.-radiation p 6/. Concluding Statement,.p 11. . r- -s ,. ;, r.. - ; -- y -, gy - b
W' 96 This has been frequently observed in this p 'a. vary in detail and' complexity. y be proceed'.ng. Through circumstances peculiar to his case one applican his proposal' l abletopresenttotiteP.egulitoryStaffadequatesupportfor l while j through the use of simple models and conservative parameter va ues, [ There is no regulatory another app'licant could not' prove his case so easily. h necessity for performing the most realistic dosage estimates that are tec - be nologically achievabic, if a less complex and less expensive analysis can The use of the 'made to demonstrate compliance with licensing requirements. in l simpler procedure may, however, introduce. a wider range of uncertainty i Hence the proper choice of estimated doses than a more complicated analysis. I _r r-- be more conservative than . parameter values for a simple calculation cight l values used in a more precise calculation. discussed at several t - ._.The matter of dealing with uncertain data was 1! There was an apparent reluctance to . points in the Orai Arguments.-_ expr,e,ss,,.in concise, language, a-general _ definition of the ' degree of con- ,( l servatism or realian considered appropriate or a precise definition of "best estimate.". We, al.so,. are r.e.lu_c_t.a_nt to propound a precise genera F onsthis. point, because the circumstances of _ application vary too widely to .The record shows that.,the quality and quantity of experi-l permit us to do-so-mental data are far from un.i.f.o.r.m.from. case to...c.ase, site to site, and t phenomenon to phenomenon. -We believe the record contains adequate evidence that sufficient data exist for making all the necessary dose estimates, although there are un-i I certainties respecting many,of the parameters., Values that would be appro-priate are sometimes said to lie between an " upper bound" and " lower ~....-..._ 1/ 21, 35-40, 104-110, and 129-130. - Oral' Argument Tr O
. t N ':. W Y 97 cr, in.ome cases, the value vouId lie somewhere among scattered crperi-3.,_ mental data po nts. The Oral Argument exc=plifies the difficulty of stating i a preci:e rule for dealing with such uncertainties but supports the pro-1 priety of striving for realism while maintaining some sense of conservatism. The Regulatory Staff's at.:itude is: '.'....that.we do not take a thorough conservative upper bound or the Icwer bound consistent:1y on these parameters."1-s -- Later, in the course of lengthy discussion Mr. James M. Smith of General , Electric explained:2/ "If you have a nine-at pathway, you may have to use averages to ccmc.up with a. reasonable best estimate throughout the entire path-w_:c.=_2 vay.,If._your pat way is much simpler, involving only one or two h . ;. 3_. % , factors, then there may be some justificatioa for being on the ...__..c.on.serva.tive side of the mean." The models described in the rec'ord of the hearing and the evidence and arguments advanced with regard to numerical estimation of dosage lead s+-u.<- .s.. us to the conc 1 union that one should try to attain realistic estimater, n :-. but where uncertainties exist one should choose calculational procedures that are unlikely to produce substantial underc.stimates. We believe,
- ~..:.
furthermore,that it is in the best interest of the public to make realistic estimates, even vith uncertain data, and to depend upon the programs for fanproving models and data, particularly programs of in-plant measurements, to determine whether proper case-by-case design decisions were made.3/
- .t : a-..s.
.e,._ 1/ r.'L' ester Rogers, Oral Argument TR 38. " Bound',' was
- transcribed as " band'.'
~ ) M 1'/ ral Argument TR 129-130. O -SceStaff'sCondu~dingStatement, pages 60-61.' 3/
.wm +e 98 4 i d by existing . Surveillance and quantitative conitoring of effluents are requ re regulations; additional guidelires for collection of data, for each operating plant, have been proposed for and are included in Appendix 1.
- 4. ' The models used in describing ef fluent ' releases should' take into e
and th'e estimated account all'real sources:and pathways within the plant; releases should be characteristic of the expected average releases over a i long period of time, with account taken of normal operation and anticipated operational-occurrences over the lifetime of the plant. The record is free from si;nificant controversy as to the general model t of an operating plant.that should be assumed for the purpose determining The schedule of operation assumed by an applicant, if it design objectives. turns out to be unrealistic, may later impose some inconvenience or expense on him through the influence of, limiting conditions of operation adopted in accordance with Appendix'I. This possibility is one to which the applicant would normally be sensitive but would,not di=inish the protection of the i public from the effects of radioactive discharges. 5. The model of the exposed individual and the assumed characteristics of the environs with. respect to human occupancy and to land and water use should be determined in each case in accordance with the intent indicated below for each particular category of effluent for which design objective guidelines are given. For design objectives affected by assumptions as to consumption of a. water or food (other than fresh milk) produced in the environs one should consider the model individual to be that hypothetical individual i p who would be maximally exposed with account taken only of such potential occupancies and usages as could actually be realized during the term of plant operation. ?
m=----------- 4:" ' l ma. e 99 b. For design objectives affected by exposure as a direct result of human occupancy (itsersion exposure) the codc1' individual should be the hfpo-r thetical individual maxi =sily exposed with account taken only of such potential occupancies, including the fraction of time an individual would be exposed, which could actually be realized during the term of plant operation. We are persuaded by the evidence that at most sites,with realistic modeling of tho natural phenomenon affecting these exposure pathways, design objectives based upon reasonable occupancy times and intake values could conform to guide-linevaluesatreasonablecostofcontrol,evenforahypotheticalreceptord/ Consolidated Utilitics presented substantial evidence, as an extention of Staff to estchlish a evaluations presented in the Final Environmental State =ent, 1evel of effort they consider to be " justified on a cost-benefit basis." They e conclude "For both PWR and BWR liquid effluents waste treatment augcents, with the additio'n of t e augments 1.isted above which appear to be justified on a cost-benefit basis in ter=s of population dose reduction, the individual whole body dose objective of 5 mrem from liquid effluents is also met. None of the other augments considered 'in the Final Environmental Statement are either justified or necessary." This conclusion and the further conclusions of Consolidated Utilities in this same place / with respect to justification of noble gas effluent centrols, when 3 1/ -- See General Elcetric Reply, page 24. 2/Statemen't of Position, p 33. 3/ - Statement of Position, items 2 and 3, pages 33-34.
w.-a
- aws, Son considered with the numerical guidelines of Appendix I 'now issued, point to a fortunate capacity to control effluents from the light-water-cooled reactors We in most expected circumstances on the gasis of a hypothetical individual.
considered the possibility of specifying that all design objectives be deter-mined solely on the gasis of actual human occupancy at the time of plant design such as was proposed by Consolidated Utilities.1/ To adopt guidelines which would leave generally all consideration of futura use of the environs to post-licen$ingregulationwouldbeunwiseintheinstanceswhereithasbeenclearly shown that an acco==odation of reasonable potential future uses can be accom-This is the case for all effluents except radio-p11shed at reasonable cost. We believe the aEtive iodines and particulates released to the accosphere. - rico'rd'shows it would be better in these instances to detemine the design ~ This not only takes the objectives 'with respect to potential future uses. economic balance into account but also the less tangibic but equally important values of environmental'quility anf protection of the individual. We have taken into account the fact that tha analyses which have led to such We are mindful a general conclusion were based upon conservative hypotheses. as already mentioned, that the numerical guidelines cannot coincide exactly e effects of measures that are "as low as practicable" in every case. th Therefore, the Appendix I guidelines should not and do not prohibit an applicant Fho any have difficulty comply g with the guidelines with respect to these We aure pathways from proceeding on the basis of Section 50.34a alone. ex anticipate that some special circumstances may arise which would make it advantageous to the applicant to base his case upon a cost-benefit analysis. Statem5 int of Position, items 2 and 3,,pa v A-4.
m TlT eww -. '101 We believe this option will provide adequate relief in such a case, for the ConsolidatedUtilitiesstated:bI "We would not, of course, object to a requirc cat that all in-plant control censures which can be justified by a cost-benefit analysis for a particular site be included." General Elcetric descriicd their conception of proper use of exceptions to design objectiva guidelines as follows:S/ ) "Such exceptions should be restricted to unusual situations and effects not reficcted in the standard itself or in the decisional processes Icad-ing thereto. Thus, for exc=ple, exceptions =1ght properly be incorporated in Appendix I for the special cases of: (1) currently operating reactors for which the cost-benefit status of eqci;;:nt argtents is highly site-dependent and differs substan-tially from that for plants in thc design stage, (2) culti-reactor sites as to' which certain environ =, ental and economic considerations not fully explored in the ALAP proceeding may apply on a case-by-case basis, or Such (3) unique or highly unusual sites or reactor installations. exceptions should not, however, be s major intended means of avoiding the cicarly unjustifiable operation of general standards for large numbers of plants whose characteristics were fully explored in the ALAP proceeding and were, in fact, taken as the norm for the Staff's testi-many and Environ =cntal Statements." i 1/ -- Statement of Reply, page 10.
- 7 Reply,, pp 23-24.
z_bg 102
- we Th2re is substantial controversy in the_ record on the proper' assumptions respecting such factors as the location of the source of drinking water, the habitat of fish caught and consumed locally and individual intake of water, fish, and other foods.
Some of these assumptions, in our_ view, are in the realm of na ural phenomenology and, therefore, should be dealt with in accordance with points 1 to 3, supra. For example, dilution of effluents in receiving waters, fish habits, and normal hu=an intakes of food and water should be considered 4 v, O on the basis of experimental evidence scientifically evaluated.. p We do believe, however, that the particular habits of' the hypothetical recepror s should take into account a reasonable and real departure of the habits of people.from the average. We would not think it reasenable on the other hand, to assume bizarre characteristics as titose of a hypothetical gardener, who receives all of his fresh vegetables from a hypothetical fence-post <;arden and consumes them it:mediatet' *:ren Mr vesting. without washing or other processing, as was assumed for some of the evaluations of the Final Environmental Stateme 1 i Such extreme assumptions have served their purpose in simplifying the evaluations ' nvolved in reaching a ddcision on Appendix I but would not be appropriate in i 4 case-by-case implementation of the guidelines'. We doubt that we differ much in this regard with the recommendation of s L Consolidated Utilities, who stated:2_/ i "Iri our view the off-site individual selected for determining the limiting dose should instead be one whose living and recreational habits, and whose T water and food co: aption habits, are representative of a significant number of persons living in the area of maximus exposure. Further, the dose ' calculational models used in estimating doses to such an individual should be as realistic as possible." NTr3402-3,3429-30. / Statement of Position, pages 43-44. 2 l-1 1
i-wannabes.ce , M A:J l 103 mm e .With realistic calculational models,, food chains, and occupancy taken into ac-count, we believe the record shows that one should and can account for persons l who are not average, even in a local sense. l For design objectives relative to thyroid dose as affected by -- c. I consumption of milk the iodine pathway through the environs of a pladt a d the characterist.ics of the model receptor should be ~ essentially as they actually exist at the time of licensing. - There was strong agreement among participants throughout much of the ~ hearing that the iodine pathway leading to thyroid exposure through consump-l tion of milk would be the most difficult one to accommodate in the context or originallj proposed numerical guidelines for establishing design objectives. At this time it is still an execptional case. The estimated economic costs of. ~ instituting in-plant controls of iodine emissions are high enough to change the ovdrall balance of the decision in f avor of requiring that only actually e ~ Of course this does not l exi'sdng food pathways need to be taken into account. deny any' applicant the pri.vilege of as'sucing more conservative hypothetical pa~t'hvays and th's avoiding the task of keeping up in detail with future changes u 'in the environs. - -Many elements of conservation ectimates of radiation exposure discussed in 'pYnts.1 to 4 suora, were of serious concern to the parties only with respect to the. iodine-milk-thyroid pathway. The implementation guidance respecting attainment of more realistic estimates will permit many plants to conform to the thyroid dosage guidelines irrespective of whether a real or hypothetical Nevertheless, on the environmental pathway is the basis of design objectives. l basis of present kn'owledge of the entir'e pathway from in-plant source to receptor, there would be many plants that could not ccet the numerical guideline on the basis of a hypothetical food pathway to an individual without in-plant controls the cost of which of which outweighs the increncntal benefic to the 1 1 l population at large. l 1
m t 4m .y 9 104 m. In adopting this guidance for radioactive iodines'and particulates discharged into the atmosphere we have considered the following special questions: Is'every individual adequately protected from excessive exposure? Is icdtvidual freedom of access and use of unrestricted areas assured? In the likely coct of implementation in'this way less than that of r j providing' additional in-plant controls at the outset? Is the possible future curtailment of productivity of the environs L justifiable? The record supports an affirmative answer to each of these questions. Individual protection of real persons'is no less than that provided for other effluents. - Special requirements for surveillance are included to detect, before If such significant exposure could occur, any important changes in land usage. changes were to necur the licensee, not the member of the public, would be l obligated to control emissions or other elements of the exposure pathway its such a way as to maintain individual exposures in confernance with design objective ~ Thus an individual would be free of any infringement upon his guidelines. rights'to use the environs. The practicability of deferring some controls until real necessity is eminent is evident from the evaluations of the Staff, General Electric, and Such a course was recocmended in the Closing Statement Consolidated Utilities. General Electric expresses the principle arguments in one of these three parties. 9 'placeasfollows:N ' O osing Statement, page 35. See also further argument on pp 39-41. Cl e e O e ne i 6 _, _ --_ _ _ _ _
f.Wo. T,';j wWa, 105 "In the extremely rare instance where, af ter licensing, plans are j l developed and actions are taken to bring about such production and consumption patterns, doses as large as those predicted by the Staff will, in all probability, still not result because'the des'ign cargins customarily built'into LWR, equipment vill normally cause actual emissions to remain below their design basis values....Even if doses exceeding the numerical guides should result, reasonable and inexpensive i steps vould almost certainly be avauable at that time to reduce such 1 exposures without the necessity of expensive equipcent augmentation such as thet which the Staff's approach would =andate in each instance during initial plant construction." _ Furthernore the ev1dence shows that with additional, experience and data frca cperating pinnts the cost likely result vill b @at esticates based upon present-day source models and assumptions are unrealistically high.1/ This factor will be of transitory value, however, in providing a buf fer against having to backfit; because, as models used at the time of plant design become more realistic there is less chance of proving significant improve =ent in co=putational methods with further experience. It is our judg=ent, therefore, that the most beneficial use of resources in control of these particular effluents will be attained by permitting the use of actually existing food pathway in determining design objectives. l It should be noted that it would be pcruissible for a licensee to effect compliance with Appendix I by making arrangements with persons holding land rights in the vicinity of a nuclear plant so as to control or restrict the production and consumption of milk. The i= pact of any such controls as might i be needed to comply with the guidelines on the potential productivity of a local region would, at worst be negligible.
su,a 106 s c..m 5004N GUIDES ON TECE!ICAL SPECIFICATIONS FOR LIMITI!!G C0:DITIO11S FOR OPERATION Section 50.36a(b) of 10 CFR Part 50 provides that licensees shall be guided by certain considerations in establishing and irplementing operating procedures specified in technical specifications that take into account the need for operating flexibility and at the same time assure that the licensee will exert his best efforts to keep icvels of radioactive caterials in ef-fluents as low as practicable. The Appendix I that we adopt'provides more specific guidance to licensees in this respect. We expect that the annual releases of radioactive materials in ef-fluents from light-water-cooled nuc1 car power reactors can generally be maintained within the icvels set forth in the foregoing as nu=erical guides It is certainly expected that the licensee will, for design objectives. under all circunstances, exert'his best efforts to keep icvcis of radio-i active materials in effluents fro: light-water-cooled nucicar reactors within l the design objective guides. At the same time the licensee should, in our l opinion, be per=itted so=e ficxibility of operation, consistent with sound considerations of public heal'th and safety, to assure that the public is - unusual conditions of provided with a dependable source of power even ur- ' operation that may tc=porarily lead to releases of radioactive materials higher than those specified as the design objective guides. The Regulatory Staff has consistently argued 'S! 1 that such operating flexibility is necessary, especially in view of the very low release levels inherent in their versions of Appendix I. As the Record shows, there is considerable disagreement as tc the need for-and/or to the quantitative 1 AIALAP Regulatory Staff Exhibit 1 Tab 1. E! oncluding Statement of Position of the Regulatory Staff, pp 32 and 68-70 C 1 1
a emne cw, 107 nature of - such operatin~, ficxibility. 1 that "the degree of opera-The Consolidated Utility Group has argued cing ficxibility provided in proposed Appendix I is too restrictive and may threaten pr.ier system reliability." Dr. Merril Eisenbud, appearing for the Atomic Industrial Torum, also indicated that the action IcVels proposed by the Regulatory Staff were unduly restrictive.- The Guld General Atomic Cc=pany ! also has argued that insufficient operational flexibility is E provided as has the Bechtel Power Corporation.4/ Similar arguments were presented by Ebasco Services.5/ In addition, the American Electric Power Service Corporation 6/ would permit the radioactive release limits of 10 CFR Part 20 to serve as action li=its to insure adequate operating ficxibility. On the other hand, National Intervenors, Inc. contended that no pro-visions for operating ficxibility warc necessary or desirable.7/
- Moreover, the State of Minne,cota in its' Fins 1 Statement ! argues that there has been no showing by the utilitics of a need for operating flexibility that such provisions for operating ficxibility should be deleted, and.that the numer-ical guides for design objectives should be treated as maximum limits never to be exceeded.
' 1/- Statement of Position of Consolidated Utility Group, Jan. 19, 1974, p 16, - Hearing Transcript, p 86, Statenent by Merril Eisenbud, p 6. 2/ - ALAP Final Environmental Statement, Wash 01258, July 1973, p 61. 3/ Ibid., pp 91-92. 5/ - Hearing Transcript, pp 109-116. k/ N nthony Roisman to Algie A. Wells et al., Feb. 15, 1972. A - Final Statement of Position of State of Minnesota, Feb.1,1974, pp 4-5. 8/ e
.. _ ~ _ _. .4%>~ ..i. 103 W We', t'.a Atomic Energy Co= mission, agree with the' Ec;ulatory Staf f that. l experience has shown that there will be variations in fuel elenent perform-ance and in radwaste equipment performance, that these variations cay, on a transient basis, result in levcis of radioactivity in ef fluents that exceed the design objective nuscrical guide values, and that operational flexibility, Y [within the very low ranges of release races involved is necessary in order l ~ l We, accordingly, that nuclear' reactors have a high degree,of reliability. i reject-the' arguments to the contrary presented by Consolidated National l We are almost equally uni = pressed Intervenors and by the State of Minnesota. with the.erguments of the several parties whose position is that the proposed limiting conditions for, operation are too restrictive. ~ l ---.' Accordingly, in the Appendix,I that'. we adopt we have set the guide on L. technical specifications for limiting conditions, for operation of light-water-l L . cooled.nucicar. power reactors as follows:_. licensee ---..For. any individual light-water-ccoled nuclear power. reactor the ".chall,1fthe.quantityofradioactivebaterialactually_releasedineffluentsto unrcstricted areas during any calendar quart 6r is such that the resulting radi-ation exposure - esti=ated on the same basis as the design objective exposures - vould exceed one half the design objective estL sted annual exposure, make an i-investigation to identify the causes-for these high release rates, define and initiate a program of action to correct the situation, and report these actions to the Commission within 30 days of the end of the calendar quarter. For individual light-water-cooled nuclear power reactors, the Commission release rates are reduced if (1) will take appropriate action to assure that the quantity of radioactive material actually released during any calendar quarter is such that the annual exposure, estimated on the same basis as the 4 6 4 e 9 s
H 4-l 'd% s. 2:g s MW, 109 L e ~ i' e l. -design objective exposures, would exceed twice the design objective annual exposure, or (2) if the quantity of such radioactive material actually. L l "r released in offluents to an unrestricted area during any consecutive 12 conths is such tha* the result 1ng radiation exposure - esti=sted on the same basis as the desi.a;n objective exposures - would er.ceed four times the design ob-1 jective exposure values. i It is intended that the limitations described immediately above shall l l apply to each light-water-cooled power reactor. We have, in addition, placed a further restriction upon all light-water-cooled nucicar power reactors on a . site or on neighboring sites. This'11=it seems to us to be practicabic since it is deemed likely that individual reactors will need the advantage of this l operating ficxibility for only a reistively s=all fraction of their operating time and all reactors on a =ulti,-reactor site could scarcely be presumed to require this operating flexibility provision simultaneously. Accordingly, we ~ have decided that the licensee shall-cake-an investigation to idenfity the causes for the increased release rates, define and initiate a program of corrective action, and notify the Atomic Energy Cc==1ssion if the quantity of radioactive materials from all light-vater-cooled reactors on a site or on near-by sites during any calendar quarter is such that the resulting radiation' ex-Posures during "that quarter exceed 75 percent of the estimated design objective i exposures. The Commission will take appropriate action to assure that release rates are reduced if the quantity of radioactive materials actually released in ef-fluents to unrestricted areas from all light-water-cooled nuclear power reactors L on a site or on nearby sites during any calendar quarter are such that (1) the resulting radiation exposure would exceed the estimated annual design objective exhosure'or(2)thatthequantityofradioactivematerialactuallyreleasedin I 4
1 4WM tri < wer ,M-110 a 'any consecutive 12 nonth period from'all light-water-cooled nucicar power e plants or on site'or on nearby sites is cuch that the resulting radiation ex- ~posure vould exceed'twice the annual. design objective exposure.
- 1 These provicions will, we believe, assure the necessary ficxibility
.for. operation of light-water-coo el d nucicar power reactors both alone and in combination while at the same time assuring that radiation exposures to j indi'viduals in the vicinity of such nucicar reactors vill be, at the most, a small fraction of those permitted by present radiation protection standards. t . The licensee is required.in addition, to conduct an appropriate sur-veillance and monitoring program. to provide {sta on quantitatives of radio-active material. released in liquid and gaseous effluents to assure that the ~ provi ion of this Appendix I are met, to provide data on measurable levels-of radiction and radioactive caterials.in the environ =ent to evaluate the 'l r.clationship between quantities of radioactive materfals released and radiation-dosages to individuals,and to. identify-changes in the use of unrestricted areas l to permit nodifications in monitoring the doscs to individuals from principa pathways of exposure. 3 ~ illance , _ It is further provided that if the data developed in the surve and monitoring' program described above show the relationship between quantities i of radioactive caterials released in effluents and the dose to individuals in unrestricted areas is significantly different from that assumed in the calcu- + lations used to determine design objective limits the Commission may modify the quantities in the Technical Specifications defining the limiting conditions for operation in a license authorizing operation of the light-water-cooled t L power reactor. e 4 4 4
'N 111 SUREII.L!J:C /J;D ICASURDE;TS o. IN OPERATII;G PLN;TS Experience with cperating nuclear power reactors of the light-water-cooled type and neasurement of effluents from thece plants was recognized by the Co iscion as one of the substancial bases on which t.he as low as practic-able provisions of 10 CFRpart 50 were propoced and adopted in 1970.1/ The quantitative data that can be a'cquired in the future through programs of ecasurocent and scuve111ance in the plant as well as in the environment have been noted by several participants as being of special importance in imple=en-ting the "as low as practicable policy and Appendix 1. Qucatitative =casure= cat of radioactive catcrials relea:,cd in of fluents has always been required of persons licensed to operate nucicar power planto. Indeed, the acendments to Part 50 published Decc:bcr 3, 1970, require that all cuch license.es periodically report to the Cecmission "the quantity of ecch of the principal radienuclides reJeased to unrestricted areas in liquid and in ~ gaseous effluents....and such other infor-ntion as may he required by the Commission to ectinate maxi =um potential cnnual radiation doses to the public resulting from effluent releases."U It is cicar that infor=ation derived frem actual observarion and measure-ment of environmental factors should be an essential part of the data supplied the Commission pursuant to paragraph 50.36a(a)(2) cited above. This position was strongly advocated by Dr. Edward P. Radford in teccimony offered on behalf of National Intervenors. "In my opinion the proposal of a whole body dose of 5 mrem per year is quite acceptable, and indeed may be too restrictive, if only because it 35 F.Rt 5414 and 18387. U10 CFR 50.36a(a)(2).
4h i 'e 'will be'. difficult to monitor effluents at 1cvels consistent with r.his 1/ low exposure rate."- He further stated: that are t reasure the ef fluents from a power plant "[I)f we canno. relevant to the htman dosc'at these low dose-rates, low total cumu-l lative doses,... then we have lost control of them because we are L simply asking someone to produce an cnvironmental effect that is not ~ measurable, almost. So the tenor.of some of my later remarks in my testimony reficct this . concern, that unicss we cc.n actually define the environmental radiation exposures in'a uay that can be translated into hu=an doses, we have .not necessarily made a step forward."2/ Finally, Dr. Radford was asked: "[Do you) believe that as an adequate measurement technique is to establish quantitics in c'enecntration icvels that the reactor itself might generate, and then to calculatc from these quantities and ' calculations wh'at the dose might be, at the. boundary, taking into at- -count the -- what we call -- site dependent characteristics?" to which he replied: "My ancwer to that question is no, I do'not, emphatically."E! This preference for measured confirmation of estimates was held also by With regard to observations that could be made at an opera-General Electric. ting plant they state: "The surveillance and monitoring approach for potential sensitive exposure pathways is entirely feasible for LWR stations in general, 1 ational Intervenors' Exhibit 3, page 3. N ' S TR 2072. 1/TR 2077.
TlG. 113 i mV e e and it would provide a means for refining and correcting the Staff's conservative calculational models."1/ General Electric r.'.so advocates that the backfitting decisions be made on tha. basis of results of on-site and off-site monitoring.2/ The evidence is convincing that further ceasurcecnts relating actual releases of radioactive caterials "to individual radiation exposure vill be of substantial value. Measured levels of environmental radioactivity are general-ly small in comparison with values calculated from known or pressured release rates. '- / The Staff's models for estimating radiation exposure are continually 34 subject.to revision as new-data become available.5/ Mr. Rogers testified for the Staff:- "So our p1sa is to issue specific guidance vit.h respect to the codels which.would be used in itplementing Appendix I. 1 am not sure exactly ~ Z rhat form those codels vould take because I think there is little -. question but that the cod 21s vill change as new infor=ation beco=es ....-availabic."O n-- The-conservatism of calculational codels necessitated by lack of data on which to substantiate more realistic models induces a strong economic in- .centive to seek, in some cases, more experimental censure =ents of important 7 m., 7 parameters. 7 ~ M osing Statement, p 41. See also supporting testimony of General Electric Cl (Mr.' James M. Smith), Exhibit 7. 2/ - Closing Statement, pp 55-56, 3/ - Consolidated Utilities, Statement of Position, p 36. 4/ - General Electric, Reply, pp 16-18. 'OStaff's Concluding Statement, p 16. 6/ - TR 3409. MGE Concluding Statement, p 5. Consolidated Utilities, Statement of Position pp 13-14, Iten 7.
im m 117 ih. The manner and timing for apply-to be.incleded in technical specifications. 'ing the additional guidelines of Appendix I to various cases are matters-which' stimulated considerable debate in the proceeding. The essence of the Staff's position is:1/ "...that the limiting conditions for operation described in Section IV of Appendix I be applicable upon publicaticn to technical specifications included in any license authorizing operation of's light-water-cooled nucicar power reactor constructed pursuant to a construction permit for which applier > ton was filed on or after January 2, 1971.. For all other operating lict uses, technical specificatiens in conformity with the guides in Section IV should be developed within 24 conths from the ef-fective date of. Appendix I and included in any license authorizing The amendments operation of a light-water-cooled nucicar power rcactor. to Part 50, Sections 50.34a an.d 50.36a requiring that icvels of radio-activity in ef fluents from light,-water-cooled nuclear power reactors be ~~~ ~ kept as low as practicabic have been in effect for core than three years and substantial progress has been cade by licensees in augmenting radwaste l It is the Staff's view that 24 conths is a reasonable period of systems. time to cosolete modifications.that may be required to meet the Appendix I I limiting conditions of operation to be included in technical specifications of operating licenses." 4 only on General Electric, la its reply to this Staf f proposal, commer.:
- tructed or the merits of backfitting, that is augmenting of plants aircady c.
2/ They argue:-- in operation with additional control equipment. 1/ Concluding Statceent, pages 73-74. .'/ eply,~pages 34-35. R t - - ~ - - - - -. __. ___
mm 4 +we A 119 P Furthermore, the information on the quantitics of radioactive uatorial in 'e effluents of these plants indicate no need for any precipitous action that-would be applicabic to all existing plants alike.1/ These two factors lead us to conel de; that the licenses for existin;; plants should be considered case-by-case. As noted ciscwhere in this statement, the design objective guidelines of Appendik I do not preclude an applicant from prosecuting his case on the fundamental definition of the tem "as low as practicable" in ~ Section 50.34a(a). Under the terms of Appendix I as presently adopted a person ) holding a license to operate an existing plant has, inherently, no less rig" ) to follow such a course. Hence,.it is unnecessary, and would be redundant, to include any statement for this special case specifically permitting a case-by-case evaluation. -Likewise, we consider it superflucus to state, in the detail suggested by General Electric,2/ the methods that would'bc permissibic as bases for estab'lishing design'ebjectives. We agree that it would be preferable to base evaluations of design cbjectives upon actual operating experience with i the reactor in question in cases where substantial relevant infomation has been accumulated during plant operations. ' The scheduling of compliance with Section 50.36a in the light of the new guidance of Appendix I is a further =atter for which varying resolutions were proposed. All parties considering this point in concluding statements agreed that guidelines with respect to both design objectives and limiting conditions for operation should be applicsble3as soon as effective,to all cases for uhich an application for a construction pomit was filed on or af ter January 2, 1971. For all other cases,the Staff originally proposed a 36 month' AEC Exhibit 27. U osing Statement, pages'54and 56. Cl e 4 y --__s ymm-.
ap s , 120-M an 1'E! Ceneral 8, id -period for compliance and finally proposed a 24 month per o. a Electric proposed that 36 months be a11 cued for compliance;E! whil 2 h period 2 Consolidated Utilitics would set no deadline except for a 1 -mont ,s,, file plans'with . within.which holders of permits or licensees would have to the-Co=mi$sion./ 4 .l In view of the f acts already asserted, that there is no hazard presently and generally being imposed by plants which were not licensed in accordance y with the s'pecific proposed guidelines of Appendix I, we have concluded that ~it is reasonable to allow tucive months for development and submission of plans for Commission approval and thirty-six conths for complete conformity of operating reactors, with allowance for any unusual delay for Co= mission In arriving at these ti=c allowances we have littic factual evidence review. from any party as to the tice actually needed. - The information in the Staf f's: ' Concluding Statenerrt on the actions of licensees to comply with "the Staff's interin licensing design objectives or.d guidelines" would have been of little value for this purpose, even if it had been undisputed or a part of the evidentiary record.5/ We believe, however, that with official notice being taken of the times actually elapsed from dates of application to dates of i d allowed for compliance is adequate. issuance of permits and licenses, the per o 9 - L II36 FR 11113. ! oncluding Statement, p 35. C E Closing St..tement,.pp 54-57. 4/ - Statement of Position, pp A7-A8. See Concluding Statement, p 73 and Annex. ~
W Mj ' j APPLICATION OF APPEUDIX I 10 0111ER FACILITIES i
- e The Ste.tc of Minnesota, / 2xpressed disappointment that Proposed Appendix 1
i I applied only to light-water-c.colod nuclear reactors. Minnesota argued that ju the types of vaste generated by other nucicar facilitics are similar to those of light-water-cooled reactors and that the cicanup technology considered in l. the. hearing could also be used at facilitics of other. types. They believe that the. record would support a Cc=aission decision to "make the dosage limitations o"f Proposed Appendix I applicabic to other facilitics in the uranium fuel 1 cycle."I-L National Intervernors, Inc. (NI) also addressed this point through testi-mony of Dr. Edward P. Radford ' who stated: ! "The proposed standards are to be applied only to nuclear power plant operations, and co=sercial fuel reprocessing plants hava not been in-cluded' This omission is serious,.'.nl because of it 92 have the ano--'-- that the Dresd6n, Illinois nucicar power plants presu= ably vill have to j meet these new standards, while the Midwest Fuel Reprocessing Plant less } than a mile away would be per=itted to release radionuclides in accord-J ance with the old standards." { I .;Several parties, including t.he Divisica of Health of' the State of Florida,4'5/ Dr. Michail McClintock,6/ Wisconsin State Senator Douglas Lafollette7/ and the ~ ~ State of'New York,8/ In their co==ents on the Draf t Environ = ental Statement also i MFinal Statement of Position of the State of Minnesota, Chapter IIA, Feb.1, 1974. 2/ - AI AP NI Exhibit 3, Testimony for U.S. Atomic Energy Commission Hearings on Standards for Release of Radionuclides to the Environment from Nucicar Facilitics, Edward P. Radford, M.D. / caring Transcript, 3 E 2065-66. / nal Environmental Statement, Wash-1258, July 1973, Vol. 3, p 30. 4 Fi l N Ibid., p'46. 6 / bid., p 36. -I / 7 ~ Ibid., p 38. - Ibid., p 115 A 8
uswa ' 2 4 l o identify the design objec- + .or'after' January 2, 1971, the application must a s tives, and the means to be employed, for keeping levels of radioactive material in effluents'to unrestricted areas as low as. practicable. Section 50.36a contains provisions designed to assure that releases of radioactive material from nuclear power reactors to unrestricted areas during normal reactor operations,' including expected operational occurrences, are kept L as low-as practicable. i d limiting L .This Appendix provides nu=crical guides for design object ves an i conditions for operation to assist applicants for, and holders of, licenses for light-water-cooled nuclear power r'eactors in meeting the requirements of Sections I 50.34a and 50.36a by assuring that the radiation exposure to individuals as a result of radioactive caterial in effluents released from these facilities to un-l f restricted arena ha kept ns low as practicable. Design objectives and limiting conditions for operation conforming to the guidelines of this Appendix shall be L i f deemed to ec= ply with the as low as practicable requirements of 10 CFR Sections I The guides presented in this' Appendix are appropriate only 50.34a and 50.36a. I for light-water-cooled nuclear power reactors and not for other types of nuclear facilities. L- $.SECTION II. CUIDES ON DESIGN OBJECTIVES FOR LICHI-WATER-COOLED _ t i 1 NUCLEAR POWER REACTORS LICENSED UUDER 10 CFR PART 50, i The guides on design objectives set forth in paragraphs A and B of this t section may'5e used by an applicant for a permit to construct a light-water-cooled nuclear power reactor as guidance in ceeting the requirements of 50.34a(a). The applicant shall provide reasonable assurance that the following design \\ A. objectives will be met. t e 0 0 t e
.. -. ~ va sy -nnva p i 1 4 1
- A',
f gasceus effluents as low =as practicable if the' applicant provides reasonable assurance that the proposed higher quantity will not. 1 I 1 d l in . result in an estimated annual cxternal dose to any indivi ua ~~~ unrestricted areas 'in excess of 3 millirems to the total body or I i 30 nilliress to the skin. i The calculated annual total quantity of all radioactive iodine and r,adio-3. active caterial in particulate form above background to be released from fluents to the atmos- .each light-water-cooled nuclear power reactor in ef an estimated annual dose or dose cocciteent for phere will not' result in any individual in unrestricted areas from all pathways of exposure in ex- ^~ '6es'i'of 15 aillirens to any organ. h A.1,A.2, and A.3 above, the _4, _ In addition to the provisions of subparagrap s ' applicant shall include in the radwaste systes all ite=s of reasonably de=onstrated technology that, when added to the system sequentially and ~ I effect reductions in ~ in order of'dindnishing cost-benefit return, can ] dose to the general population for costs not in excess of $1500 per can-rem or of $500 per can-thyroid-rec. l The design objective guides of subparagraphs A.1, 2, 3, and 4 of this f B. Sections $allappihseparatelytoeachifCt-water-coolednucicarpowerreactor. ~ h i In addition, the applicant shall provide reasonable assurance that the prol l ~~ l d nucicar power reactors . reactor, in combination with allother' 11ght-water-coo e 1/ on 'the site and on nearby sites will meet the following design objectives.- h poses of - "Other light-water-cooled nuclear power reactors" means, for t e pur lica-1/ this paragraph, light-water-cooled nucicar power reactors for which app ~~~ tions. have been-filed with the Commission f or construction permi are expected to operate while the proposed reactor operates. S d e r m
m 5 MJH %i, = ll radioactivo material above 4L . The calcitlated annual total' quant'ity of a ^ 1. d to be released from the proposed reactor in combination with all k .bac groun other light-water-cooled nuc1 car power reactors on the site and on nearby -l sites in liquid effluents to unrestricted arcas will.not result in an esti- -t eated annual. dose or dose commit =cnt for any individual in unrestricted areas i from'all pathways cf. exposure in excess of 10 millirems to the total body, 30 mill'irems to any organ and 60 millirems to the skin. 2.a. The calculated annual total quantity of all' radioactive material above beckground to be released from the. proposed reactor in co=bination with all t -i s other. light-water-cooled nucicar power reactors on the site and on nearby r d sites in liquid effluents to unrestricte'd areas will not result in an estimate annuai air dose at any location near ground icvel which could be occupied by l individuals in unrestricted areas in excess of 30 millirads for gamma radiation and 60 millirads for beta radiation.
- b. Notwithstanding the guidance of s,ubparagraph B.2.s above:
(1) The Com ission cay specify, as guidance on design objectives, a lower I i quantity of radioactive caterial above background in gaseous effluents ' to be released to the accosphere if it appears that the ase of the design objectives in that subparagraph is likely to result in an esti- ' mated annual external dose to any ' individual in unrestricted areas in 8 excess of 15 ~ millirems' to the total body; or l (2) Design objectives based'upon a higher quantity of radioactive mate I above background in gaseous effluents to be released to the atmosphere than the quantity specified in that subparagraph may be deemed to l meet the requirc=ents for keeping levels of radioactive material in gaseous effluents as low as practicabic if the applicant provides i l l. e 4 a 4 h w ~ .w i -}}