ML20202D701
| ML20202D701 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/1975 |
| From: | NRC |
| To: | |
| References | |
| SECY-A-75-014, SECY-A-75-014-R, SECY-A-75-14, SECY-A-75-14-R, NUDOCS 9902020086 | |
| Download: ML20202D701 (138) | |
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' March 3, 1975 bhk k h UNI T E D 5f4TFS SECY-A-75-14 NUCLEAR REGUL AiOHY CoMilissierJ MI\ 10 ADJUD!CATOR'T UEN. - --
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SUMMARY
SHEET
Subject:
- As Low.As Practicable Rulemaking Decision. ;
Attached for Commission review is a proposed D_iscussion: Commission decision in the "As LowThe ticable" rulemaking proceeding.
was drafted by three consultants -- W. Bibb, As decision Prac- Nl'1 l W. R. Grimes, and R. H. Bryan of Oak Ridge --
selected by the Atomic Energy Commission, in consultation with attorneys in the office of the Solicitor. Douglas Grahn, Argonne, parti-cipated in the most recent revision of the introductory chapter.
The current draft is in five chapters -- an introduction, a statement of the rule, and three chapters of text explaining how the con-sultants proceeded from the hearing record to the rule now proposed. Minor editorial changes have been made in the first two chapte'rs from the version circulated in preliminary form as SECY-A-75-10, as corrected.
(:) <:t The current draft represents the Oak Ridge r
consultants' collective view of an appropriate o cri EE Commission decision in this rulemaking, address-W M ing and deciding all significant technical it.Juee
!?. 6 [ raised during the lengthy proceeding. The con-W " sultants will meet with the Commission on C T W d Thursday of this week, presenting;an over i E of the issues raise.d during the hearing and hd g their suggested resolution. .
sn c2 7 The' attached draf t can be considered " final" in the sense that all issues,have been identif.ied gigm w 4., and a decision proposed. It is still a " draft",
since the Commission may well desire changes of M0% MFM Y) I substance and emphasis, Further editorial polish-ing and legal " fine tuning" will occur during-Aat 43 444 /W R h ched the, period of Commission review. (5 3.x 393 is (V tlL M6d hext wo It should be noted that the introductory chapter g suSegw* in M is intended to satisfy the legal requirement ;-!
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- TABLE OF CONTENTS !
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.I Summary............................................ 17
.2 II Text of the-Rule................................... 31 i De' sign Objectives..................................
s 1 . III for Limiting
-IV ' Guides on Technical-Specification 95 Conditions of Operation.......................... 104 V Implementation..................................... !
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7' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCKET NO. RM-50-2 ONDIiIONS CABLE" NUMERICAL GUIDES FOR DESIGN OBJECTIVES POWER A FOR OPERATION TO MEET THE CR REACTORS OPINION OF THE COMMISSION-I.
SUMMARY
Background its The Nuclear Regulatory Commission herewith announces l decision in the rulemaking proceedings concerning numerica for guides for design objectives and limiting conditions to operation for light-water cooled nuclear power reactors meet the criterion "as low as practicable."
the Commission published in the Federal _
On December 3, 1970, amendments to 10 CFR Part 50 Register (35 Fed. Reg. 18385) for nuclear which specified design and operating requirements ffluents power reactors to keep levels of radioactivity in e l The amendments provided qualitative "as low as practicable." when ii guidance, but not numerical criteria, for determ n ng i ments.
design objectives and operations meet the specified requ re Considerations to The Commission noted in the Statement of definitive the amendments the desirability.of developing more guidance in connection with the amendment.
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2 On. June 9, 1971, the Commission published in the Federal.
Register (36 Fed. Reg. 11113) for public comment proposed amendments to 10 CFR Part 50 which would supplement the The proposed Appendix regulation with a new Appendix I.
provided numerical guides for design objectives and tech-nical specification requirements for limiting conditions for operation for light-water-cooled nuclear power reactors.
Pursuant to & subsequent Federal Register notice, published on November 30, 1971 (36 Fed. Reg. 2275), a public rule-making hearing on the proposed amendments was held, beginning on January 20, 1972, before a hearing board consisting of Algie A. Wells,.Esq., Chairman, Dr. John C. Geyer, and The primary participants in the rulemaking Dr. Walter Jordan.
hearing included the Commission's Regulatory staff, a con-solidated utility group, Consolidated National Intervenors, In General Electric Company, and the State of Minnesota.
addition, 18 persons or organizations, including the Environ-mental Protection Agency, made limited appearances.
The hearing was suspended in May of 1972 pending preparation of an Environmental Statement concerning the proposed rule-making in implementation of the National Environmental Policy Act of 1969. A' Draft Environmental Statement was
3 forwarded to the Council on Environmental Quality on Jan-uary 15, 1973, and circulated for comment to interested including the Federal agencies and members of the public, hearing participants.
Notice of public availability of the Statement and an invitation for comment were published in the Federal Register. Comments on the Draft Statement were received, and a Final Environmental Statement was issued on July 26, 1973. In November 1973, the public hearing was resumed for consideration of the Environmental Statement.
1973, The evidentiary hearing was concluded on December 6, and concluding Statements of Position were subsequently 4172 filed. The proceeding covered some 25 days of hearings, and thousands of pages of pages of hearing transcript, Additionally, I prepared written direct testimony and exhibits.
1974.
oral arguments were heard by the Commission on June 6, As the record developed during this rulemaking shows, there is a general consensus concerning the need to define "as low The major issues as practicable" with numerical criteria.
of controversy involved the feasibility of achieving the proposed numerical criteria and the cost of compliance with and the perceived benefits of the criteria. The Commission has carefully considered the entire record and the views of those who participated in the r'ulemaking hearing in reaching the decisions involved with this rule.
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It should be emphasized that the Appendix I guides as here adopted by the Commission are not radiation standards. The Commission's radiation standards, which are based on recommen-dations of the Federal Radiation Council (FRC) as approved by the President, are contained in 10 CFR Part 20, " Standards for Protection Against Radiation," and remain unchanged by this Commission decision.1! As in the case of parallel recommendations of the National Council on Radiation Protection and Measurement and the International Commission on Radiologi-cal Protection, these FRC and AEC/NRC standards give appro-priate consideration to the overall requirements of health protection and the beneficial use of radiation and atomic energy. The Commission believes that the record clearly indicates that any biological effects that might occur at the low levels of these standards have such low probability of occurrence that they would escape detection by present-day methods of observation and measurement.
1I The radiation protection guides established by the FPC for individual members of the public are 500 millirems per year to the total body and bone marrow and 1500 millirems per year to the thyroid and bone. The guide for average dose to the population is 5 rems in 30 years to the gonads (an annual average dose of 170 millirems per person averaged over the population).
These guides and recommendations apply to exposures from all sources other than medical procedures and natural background.
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The Commission has always subscribed to the general principle that, within-established radiation protection. guides, radia-tion exposures to the'public should'be kept "as low as practicable." This general principle has been a central one The .
in the' field-of_ radiation protection for many. years. .
term "as low.as practicable" is defined in the Commission's to mean "as low as is prac-regulations [10 CFR 50.34a (a))
ticably. achievable taking into account the state of tech-nology,-and the. economics of improvements in~ relation to benefits to the'public health-and safety in relation to the The l utilization of' atomic energy in the public interest." 1 numerical guides of' Appendix I which we announce today are a quantitative: expression of the meaning of the requirement that radioactive material in effluents released to unre- -
stricted areas from light-water-cooled nuclear pcVer reactors be kept "as low as practicable." .
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We note that the International Commission'on Radiological Protection, in ICRP Publication No. 22, has replaced the
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I phrase'"as low as practicable" with "as low as is reasonably Their recommendation'has also been expanded to achievable."
identify two specific considerations -- economic and social --
that are tcf be taken into account in determining a level of
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achievable.". Other considerati6ns, such as ethical ones, are.not excluded by'this wording and may indeed be considered to befincluded.by the adjective " social." We' endorse this attempt to.make this basic concept of radiation protection more understandable and believe the rule we announce today to'be. consistent with the "as low as is reasonably achiev-able"/ concept.
The principal changes from the proposed amendments published in the' Federal Register on June 9, 1971, are as follows:
-1. Liquid Effluents The design objectives in.the proposed rule for radioac-tive material in liquid effluents were based on: (a) an annual release of 5 curies, excep't tritium, (b) specified concentration limits on tritium and other radioactive materials released to the environment, and (c)' the provision for increasing or decreasing the design-objective quantities and concentrations for
. specific sites subject to keeping annual doses to the !
total body or any organ of the individual in an unre-The design stricted area to not more than 5 millirems.
objective in the adopted' amendments-limits the total quantity of all radioactive naterial released in liquid effluents from each light-water-cooled nuclear power
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7 ; l reactor to a level that maintains the annual dose or dose commitment for any individual in an unrestricted 5
. area from all pathways of exposure to not more than I millirems to the total body and 15 millirems to any organ.
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upon quantities of' radioactive material to be released l,
j since the record shows that such limits have little if l any independent significance. Protection of future users of the near environs of the reactor is provided I by the additional requirement that all augments with a I
favorable cost-benefit balance be included in the I radwaste system and by the provision that the estima-tion of exposure be made with respect to such potential L
' land and water use and food pathways as could actually exist during the term of plant operation.
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l 2. Gaseous Effluents The principal difference in the design objective in the amendments adopted by the Commission dealing with external i
dose from radioactive material in gaseous effluents is the separate treatment of total-body dose and skin dose.
t The proposed design objective limited both the annual total-body and the annual skin dose to 5 millirems, whereas t
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. 8 the new design objective limits the annual total-body dose to 5 millirems per light-water reactor and increases the annual dose to the skin to not more than 15 milli-rems per light-water reactor. The design-objective annual dose to the skin has been increased from 5 millirems to 15 millirems as a result of evidence in the Final Environ-mental Statement and the rulemaking hearing showing that
.it is not technically practicable to design and operate a light-water-cooled nuclear power reactor with a limit on the annual skin dose from beta radiation of not more than 5 millirems. It is noted that an annual dose to the skin of 15 millirems is one-half of one percent of the radia-tion dose limits for a member of the public recommended by the International Commission on Radiological Protection.
- 3. . Radioactive Iodine and Particulate Matter The proposed design objective for radioactive iodine and radioactive material in particulate form released in gaseous effluents was expressed as a limit on the average concentrations of radioiodines and radioactive material in-particulate form at or'beyond the site boundary. The concentration values were designed to limit the annual dose to the thyroid or other organs to not more than 5 i
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- millirems. The design objective in the amendments set out below is expressed as the annual quantity of radioac-tive iodine and radioactive material released which limits the annual dose or dose commitment to any organ, including the thyroid, of any individual in an unrestricted area from all pathways of exposure to not more than 15 milli-rems per year per light-water-cooled nuclear power reactor.
In determining the quantity based on the annual dose or dose commitment, the portion due to intake of radioactive material via the food pathways may be evaluated at the locations where the food pathways actually exist. The i design-objective annual dose for radioactive iodine has been increased from 5 to 15 millirems as a result of evidence developed in the hearing which showed that the previous design-objective annual dose of 5 millirems per year'for doses to the thyroid from the milk pathway was not practicable.
- 4. Per Site vs. Per Reactor From the foregoing it is clear that the Commission's policy is to minimize the radiation exposure of human beings from the effluents of light-water-cooled nuclear power reactors.
-# We have chosen to express the design objectives on a per light-water-cooled-nuclear-power-reactor basis rather than i
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10 on a site basis, as was originally proposed. While no site limits are being adopted, it is expected that the dose commitment from multi light-water-cooled reactor sites should be less than the product of the number of reactors proposed for a site and the per-reactor design-objective guides because there are economies'of scale due to the use of common radwaste systems for multi-reactor sites which are capable of reducing exposures. More appropriately we note the overall environmental impact of nuclear sites is a topic to be specifically addressed in the energy-center study mandated by the Energy Reorganization Act of 1974.
- 5. Cost-Benefit Requirements In addition to the numerical design-objective guides de-scribed in paragraphs 1, 2, and 3 above, our decision requires that radwaste systems include all items of reasonably demonstrated technological effectiveness which, when added to the system sequentially and in order of diminishing cost-benefit return, can effect reductions in dose to the general population at costs not in excess of $1000 per man-rem or $333 per man-thyroid-rem.
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This requirement envisions that a cost-benefit analysis will be done to determine what specific augments should
'be included on each plant.
is The problem in striking a proper cost-benefit balance in l' the difficulty of expressing both costs and benefits Nevertheless there has been general
! commensurate units.
l recognition by the hearing participants of the need to quantify risks in monetary terms and an acceptance of i d the procedure whereby each man-rem of exposure is ass gne a dollar value.
Even if the dollars-per-rem approach is judged an appro-a further diffi-i priate basis for cost-benefit analysis, culty arises in trying to ascertain the specific value per The Commission recognizes that there is no man-rem.
l consensus regarding what might be termed an optimum l
value. Cost-benefit studies identified in the record suggested values that ranged from $30 to $980 per man-rem.
In order to allow for intangibles, we feel d
confident that a reasonable value lies between $200 an
$1500 per man-rem.
We further note that for light-water-cooled power reactors the cost-benefit analysis is not highly sensitive to values between $500 and $1500
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in view of other factors influencing the conclusion, such as the apportionment of costs among design objec-tives, some of which are not related to minimizing exposure to the off-site popolation.
- 6. Licensee and Commission Action Revisions have been.made in the guides for limiting con-ditions for operations-with respect to when appropriate action must be taken to reduce release rates of radioac-tive material. The proposed action levels provided that, if rates of release of quantities and concentrations in effluents actually experienced over any calendar quarter indicate that annual rates of release were likely to exceed 2 times the design objectives, the licensee should take corrective action. If such annual rates were likely to exceed a range of 4 t'o 8 times the design objectives, the commission would tace appropriate action to ensure The provisions that the release rates were reduced.
adopted require the licensee to initiate action if the average dose rate off-site during any calendar quarter exceeds 10 millirems whole body per year or 30 millirems to the skin and any organ per year.
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I Existing Commission regulations (10 CFR 50.36a) have recognized the need for licensees to be permitted flexi- !
bility of operation compatible with considerations of health and safety to ensure that the public is provided a dependable source of power even under unusual operating conditions that may temporarily result in releases higher than the numerical guides for design objectives. Some flexibility of operation is believed to be essential and warranted in view of the restrictive nature of the Appendix I guides and the fact that, even with this flexibility, it can be ensured that the average population exposure will still be a small fraction of doses from natural background radiation. The Commission notes, however, that, in using this operational flexi-bility under temporary or short-term unusual operating conditions, the licensee m'ust continue to exert his best efforts to keep levels of radioactive material in efflu-ents within the numerical guides for design objectives.
In order to provide assurance that releases of radioactive materials are known, the Commission has expanded the surveillance and monitoring program beyond current requirements for licensees to report on the quantities of the principal radionuclides released to unrestricted
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L ' areas.1 program will be used by licensees as a basis for initiating. prompt and effective corrective action towards' ensuring that the actual off-site exposures per
(- reactor-are compatible with the design-objectives as adopted.
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These guides will continue to provide operating flexi-L
.bility and at the same time. ensure a positive system of.
control by.a graded scale of action first by the licensee and second.by the-Commission, if the need arises, to reduce the release of radioactive material should the-
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rates of-release actually experienced substantially i-exceed the' design objectives. !
.The proposed Appendix I was silent on the method for :
implementation of the numerical guides. The' Commission
' believes, however, that Appendix I should guide the
' Commission staff and other interested persons in the use
.of appropriate calculational 1 procedures for applying the Consequently, numerical guides for design ~' objectives. !
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Lthe provision adopted states that compliance with the t.
guides'on design objectives shall be demonstrated by calculational-procedures based on models and data such
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that will not substantially underestimate the actual exposure of an individual through appropriate pathways, 4
all uncertainties being considered.
e Quantitative measurement of radioactive materials rel'ased
'in effluents from licensed light-water-cooled nuclear power' reactors is required by the amendments to 10 CFR Part 50 published December 3, 1970. This requirement-is made more specific by Appendix I and reflects the need for the use of the best available experimental data as well as calculational models, in order to achieve increased accuracy and realism. Strong incentives already exist for improving the calculational models used in establish-ing design objectives in view of the economic penalty associated with needless overdesign for conservatism.
Actual measurements and surveillance programs can provide data.for improving these models. It is recognized, however,_that measurements of environmental exposures and quantities of radioactive materials in the environs are complicated by the very low concentrations that are encountered, compared to background, and by the fact that there are a number of variables in both time and space and effect and concentration. Thus, the correlation of the best measurements with the best calculations is tedious 4
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and difficult. However, since calculational procedures . . . .
must be employed in implementing the design-objective guides of Appendix I, the Commission has adopted an implementation policy that encourages the improvement of calculation models and the use of the best data available.
.The foregoing has briefly summarized the technical context of i The changes the issues presented and the changes introduced.
and the reasons for them are set out in detail in the sections l that follow the rule. !
17 -
II. TEXT OF THE RULE Pursuant to the Atomic Energy Act of 1954, as amended, and Sections 552 and 553 of Title 5 of the United States Code, Chapter 1, Code of the following amendment's to Title 10i Federal Regulations, Part 50, are published as a document (30 days after subject to codification to be effective on publication in the Federal _ Register).
A.
Section 50.34a of 10 CFR Part 50 is amended by adding the following sentence to the end of paragraph (a):
(a) * *
- The guides set out in Appendix I provide numerical guidance on design objectives for light-water-cooled nuclear power reactors to meet the requirement .
that radioactive material in effluents released to un-These ,
restricted areas be kept as low as practicable.
numerical guides for design objectives and limiting conditions for operation are not to be construed as radiation protection standards.
B.
Section 50.36a of 10 CFR Part 50 is amended by adding (b) :
the following sentence at the end of paragraph (b) **
- The guides set out in Appendix I pro-vide numerical guidance on limiting conditions for operation for light-water-cooled nuclear power reactors
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18 to meet'the requirement that radioactive materials in effluents released to unrestricted areas be kept as. low as practicable. .s C. A new Appendix I is-added to 10 CFR Part 50 to read as follows:
APPENDIX I - NUMERICAL GUIDES FOR DESIGN OBJECTIVES AND LIMITING CONDITIONS FOR OPERATION TO MEET THE CRITERION "AS LOW AS PRACTICABLE" FOR RADIOACTIVE MATERIAL IN LIGHT-WATER-COOLED NUCLEAR POWER REACTOR EFFLUENTS.
SECTION I. INTRODUCTION Section 50.34(a) provides that an application for a permit to construct a nuclear power reactor shall include a description of the preliminary design of equipment to be installed to maintain control over radioactive materials in gaseous and liquid effluents produced during normal reactor operations, including expected operational occurrences.
In the case of an application filed on or after January 2, 1971, the application must also identify the design objectives, and the means to be employed, for keeping levels of radioactive material in efflu-ents'to unrestricted areas as low as practicable.
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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 as low as practicable.
This Appendix provides numerical guides for design objectives and limiting conditions for operation to assist applicants for, and holders of, licenses for light-water-cooled nuclear power reactors in meeting the requirements of Sections 50.34a and 50.36a by assuring that the radiation exposure to indivi-duals as a result of radioactive material in effluents. released from these facilities to unrestricted areas be kept as low as practicable. Design objectives and limiting conditions for operation conforming to the guidelines of this Appendix shall t'
deemed to comply with the as low as practicable requirements The guides presented in oc 10 CFR Sections 50.34a and 50.36a.
tiis Appendix are appropriate only for light-water-cooled nuclear power reactors and not for other types of nuclear t.
facilities.
l GUIDES ON DESIGN OBJECTIVES FOR LIGHT-WATER-j SECTION II.
COOLED NUCLEAR POWER REACTORS LICENSED UNDER 10 CFR PART The guides on design objectives set forth in this section may a
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' be used by an applicant for a permit to construct a light-water-cooled nuclear power reactor as guidance in meeting the requirements of 50.34a(a) . The applicant shall provide reasonable assurance that the following design objectives will be met. i A.
The ca?:ulated annual total quantity of all radioactive 2/ to be released from each material above background light-water-cooled nuclear power reactor in liquid effluents to unrestricted areas will not result in an estimated annual dose or dose commitment for any indi-vidual in unrestricted areas from all pathways of exposure in excess of 5 millirems to the total body or 15 millirems to any organ.
B.l. The calculated annual-total quantity of all radioactive material above background to be released from each light-water-cooled nuclear power reactor in gaseous effluents to the atmosphere will not result in an estimated annual air dose _at any location near ground S/ Here and elsewhere in this Appendix background means radioactive materials effluents from in the environment light-water-cooled and in power reactors notthe generated in, or attributable to, the reactors of which specific account is required in determining design objectives.
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level.which could be occupied by individuals in un-restricted areas in excess of 10 millirads for gamma f.
radiation or 20 millirads for beta radiation.
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- 2. Notwithstanding the guidance of s'ubparagraph B.1 above:
The Commission may specify, as guidance on design
~(a) il objectives, a lower quantity of radioactive mater ad above background in gaseous effluents to be release
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to the atmosphere if it appears that the use of the design objectives in that subparagraph is likely to l result in an estimated annual external dose to any individual in unrestricted areas in excess of 5 l
millirems to-the total body; and (b)
Design objectives based upon a higher _ quantity of radioactive material above background in gaseous h
effluents to be released to the atmosphere than t e quantity specified in that subparagraph will be deemed to meet the requirements for keeping levels low of radioactive material in gaseous effluents as ble as practicable if the applicant provides reasona ill not assurance that the proposed higher quantity w result in an estimated annual external dose to any individual in unrestricted areas in excess of 5 m rems to the total body or 15 millirems to the skin.
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I 22 C. The calculated annual total quantity of all radioactive iodine and radioactive material in particulate form above background to be released from each light-water-cooled nuclear power reactor in effluents to the atmo-sphere will not result in an estimated annual dose or dose commitment for any individual in unrestricted areas from all pathways of exposure in excess of 15 millirems to any organ.
B, and D. In addition to the provisions of paragraphs A, C above, the applicant shall include in the radwaste system all items of reasonably demonstrated technology that, when added to the system sequentially and in order of_ diminishing cost-benefit return, can effect reductions in dose to the general population for costs (in 1974 dollars) not in excess of $1000 per man-rem or of $333 per man-thyroid-rem.
SECTION III. IMPLEMENTATION A.l. Compliance with the guides on design objectives of Sec-tion II shall be demonstrated by calculational procedures 1
based upon models and data such that the actual exposure of an individual through appropriate pathways is unlikely l-to be substantially underestimated, all uncertainties t-I
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e w-being' considered together. Account shall be taken of the cumulative effect of all sources and pathways within the plant contributing-to the particular type of effluent being considered. For determination of design objectives in accordance with the guides of Section II the estimation of exposure shall be made with respect to such' potential r
~1and and water usage and food pathways as could actually exist during the' term of plant operation, provided that, if the requirements of' paragraph B of Section III are fulfilled, the applicant shall be deemed to have complied ih with the requirements.of paragraph C of Section II w t respect to radioactive iodine if estimations of exposure are made-on the basis of such food pathways and individual I
receptors as actually exist at the time the plant is
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The characteristics attributed to a hypothetical recep o
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'for the purpose of estimating internal dose commitment '
shall take into account reasonable deviations of indi-The applicant may take vidual habits from the average.
account of any real phenomenon or factors actually <
!: including I' affecting the estimate of radiation exposure, the characteristics of the plant,' modes of discharge of radioactive materials, physical processes tending to
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24 attenuate the quantity of radioactive material to which an individual would be exposed, and the effects.of averaging exposures over times during which determining factors may fluctuate.
B. If the applicant determines design objectives with re-spect to radioactive iodine on the basis of existing-conditions and if potential changes in land and water usage and food pathways could result in exposures in excess of the guideline. values of paragraph C of Section II, the snplicant shall provide reasonable assurance that a monitoring and surveillance program will be per-formed to determine:
(1) the quantities of radioactive iodine actually released to the atmosphere and depo' sited relative to those estimated in the determina-tion of design object. vest (2) whether changes in land and water usage and food pathways which would result in indivi-dual exposures greater than originally estimated have occurred; and (3) the content of radioactive iodine and foods .
involved in the changes, if and when they occur, !
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25 SECTION IV. GUIDES ON TECHNICAL SPECIFICATIONS FOR LIMIT CONDITIONS FOR OPERATION FOR LIGHT-WATER-COOLED ,
~ POWER REACTORS LICENSED UNDER 10 CFR PART 50_ ;
The guides on limiting conditions for operation for light-water-cooled nuclear reactors set forth below may be used by an applicant for a license to operate a light-water-cooled nuclear power reactor as guidance in developing technical
, to keep levels of specifications under Section 50.36a(a) radioactive materials in effluents to unrestricted areas as low as practic'ble.
Section 50.36a(b) provides that licensees shall be guided by certain considerations in establishing and implementing -
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 hi best effort to keep levels of radioactive material in efflu- .
The guidance cet forth below ents as low as practicable. .
provides additional and more specific guidance to licensees i
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in this respect.
In using the guides set forth in this Section it is expected l
that the annual releases of radioactive material in affluents from light-water-cooled nuclear power reactors can generally :
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26 be maintained within~the levels set forth as numerical guides for design objectives in Section II.
At the same time, the licensee is permitted the flexitility of operation, compatible with considerations of health and 1 l
safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such numerical guides for design objectives, but still within levels that assure that the average population exposure is equivalent to n,aall fractio'ns of doses from natural back-ground radiation. It is expected that in using this opera-tional flexibility under unusual operating conditions, the licensee will exert his best efforts to keep levels of radioactive material in offluents within the numerical guides for design objectives.
A. If the quantity of radioactive material actually re-leased in effluents to unrestricted areas from a light-water-cooled nuclear power reactor during any calendar quarter is such that the resulting radiation exposure, calculated on the'same basis as the respective design objective exposure, would exceed one-half the design
_ . _ . __. . _ . . _ _ . . _ _ _ . ~ . _ _ _ _ _ _ . _ _ _ ._. _ __ _ . _ . ._ _ _ . _
~_4 un s
- 27 objective annual exposure derived pursuant to Sections I and III, the licensee shall: E/
'(a) Make an investigation to identify the causes for such release rates; (b) Define and initiate a program of corrective action; and (c) Report.these actions to the Commission within 30 days from the end of the quarter.during which the release occurred.
B. The licermee shall establish an appropriate surveillance and monitoring program to:
(1) Provide data on quantities of radioactive material released in liquid and gaseous effluents to assure that the provisions of paragraph A are met; (2) Provide data on measurable levels of radia-t tion and radioactive materials in the environment t
2/ Section 50.36a(2) requires the licensee to submit certain reports to the Commission with regard to the quantities of the principal radionuclides released to unrestricted areas. It also provides that, on the basis of such reports and any additional information the Commission may obtain from.the licensee and others, the Commission may from time to time require the licensee to take such action as the Commission deems appropriate. ,
Should commission action be appropriate, it will be based upon a careful evaluation of the effects of its action on the health and safety of the public and on the public need for power.
__ =, ,,.. _. . _ . _ _ _ . _ . _
2- '
.t' 1 A-28 )
i I
I
' to evaluate the relationship between quantities i
of radioactive material released in effluents and resultant radiation doses to individuals ani l
' from principal pathways of exposure; I (3) Identify changes in.the use of unrestricted i
i areas (e.g., for agricultural purposes) to L
permit modifications in monitoring programs i
for evaluating doses to individuals from ;
l l principal pathways of exposure. l C. If the data-developed in the surveillance and monitoring l
program described in paragraph 5 of this section and in paragraph B of Section III or from other monitoring pro-grams show that the relationship between the quantities of radioactive material released in liquid and gaseous effluents and the dose to individuals in unrestricted areas is significantly differen: from that assutad in the calculations used to determine design objectives \
j l-pursuant to Section I and III, the Commission may modify the quantities in the technical specifications defining the limiting conditions for operation in a license i
L authorizing operation of a light-water-cooled nuclear i
power reactor.
1 b.
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s 29
- SECTION V. EFFECTIVE DATES A.- The guides for design objectives and limiting conditions for operation set forth in this Appendix shall be appli-cable in any case in which an application was filed on or after January 2,'1971,.for a permit to construct a light-water-cooled nuclear power reactor.
B. For each light-water-cooled nuclear power reactor ~ con-structed pursuant to a permit for which application was filed prior to January 2, 1971:
(1) 2he holder of the permit or a license autho-rizing operation of the reactor shall, within a period of twelve months from (the effective date of this Appendix), file with the Commissions (a) such information as is necessary to evaluate the means employed for keeping levels of radioactivity in effluents to unrestricted areas as'.. low as practicable, including all such information as is required by Section 50.34a not already contained in his application; and (b) plans and proposed technical specifications developed for the purpose of keeping re-leases of radioactive materials to
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30 unrestricted areas during normal reactor operations, including expected operational occurrences, as low as practicable.
(2) The technical specifications included in any license authorizing operation of the reactor shall, within a period of thirty-six months from (the effective date.of.this Appendix),
or by.the date of issuance of such license, whichever is later, conform to the requirements of Section 50.36a; provided that the commission may extend the period as may be deemed necessary to allow for evaluation by the Commission.
- - . . . . . _ _ _.. ._ - -. , . . _ . _ . . . _ _ . _ _ . . .___.~__.m .
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.4 31 l
1 III. GUIDES ON DESIGN OBJECTIVES _
Section 50.34a of 10 CFR Part 50 contains provisions to 1
. ensure that re eases o f radioactive material from nuclear l .
power reactors to unrestricted areas during normal reactor operations, including expected operational occurrences, are kept as 1cni as practicable. The Appendix I that we adopt
'l provides specific guidance to licensees in this respect.
A. The Rule '
Section II of Appendix I defines design objectives for effluents ,
When used by an appli-from light-water-cooled power reactors.
cant for a permit to construct a light-water-cooled power ;
reactor, these guides ensure compliance with the requirements Four guides provide this of Section 50.34a of 10 CFR Part 50.
insurance: they set limits upon radiation doses or dose commitments to individuals in unrestricted areas from radio-active materials (1) in liquid effluents, (2) in gaseous I
effluents, and (3) as radioiodine and particulate emissions, and (4) they require that the radwaste systems include all items of. reasonably demonstrated technology that for a favorable cost-benefit ratio can effect a reduction in the radiation dose to the general population.
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32 The total quantity of all radioactive material above back-ground to be released each year in liquid effluents from each light-water-cooled nuclear power reactor to unrestricted areas sha11 not result in an estimated annual dose or dose I
commitment for any individual in unrestricted areas in excess of 5 millirems to the total body or 15 mil'lirems to any organ.
The calculated quantity of all radioactive material above background to be released.to the atmosphere annually from l
each light-water-cooled nuclear reactor in gaseous effluents shall not res 't in an estimated annual air dose in excess of --
10 millirems for gamma radiation and 20 millirems for beta radiation at any location near ground level which could be occupied by individuals in unrestricted areas.
The Commission may specify a smaller quantity of radioactive I
material to be released in gaseous effluents to the atmosphere if such smaller quantity appears necessary to prevent an annual external total-body dose in excess of 5 millirems to any Conversely, if the applicant individual in an unrestricted area.
l can provide reasonable assurance that a larger quantity of amitted radioactivity will not result in an estimated annual external dose to any individual in unrestricted areas in excess of 5 millirems to the total body or 15 millirems to l
.- . . . - - - - . _ - - - . - . . - - - . ~ . - . - - . . _ _ . . _ . . . . - . - . . _ - . -
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i 33 i
the skin, such larger quantity of emitted radioactivity may be deemed to meet the requirements of "as low as practicable."
The calculated annua 1Ltotal quantity of all radio 4ctive iodine and radioactive material in particulate form above background d
to be released to the atmosphere from each light-water-coole nuclear power reactor in effluents shall not result in an t
estimated annual dose or dose commitment from all pathways !
of exposure for any individual in unrestricted areas in excess of 15 millirems to any organ. As described in more detail in '
Section V, th- portion of the dose or dose commitment due to l
I intake of radioactive material through food pathways may be -
l l
I evaluated at the locations where the food pathways actually i
exist. '
In addition to these limits on liquid, gaseous, and radiciodine and particulate effluents, the radwiste system of erch light-water-cooled nuclear power reactor shall include all equipment l
items of reasonably demonstrated technology which can effect l i for costs not
-a reduction in dose to the general populat on in excess of $1000 per man-rem or $333 man-thyroid-rem. :
- doses to We.believe these requirements ensure that radiation near neighbors of light-water-cooled nuclear reactors will be limited to a small fraction of the doses permitted by the l
l l
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4 34 Federal Radiation Protection Guides and to well within the variation in natural background radiation levels. At the same time, radiation doses to members of the population at large will be held to very low values.
B. The Considerations Adoption of these design' objectives for effluents from light-water-cooled nuclear power reactors required that we make
. decisions on a variety of questions that, as the Hearing Record shows, were contested strongly by the several Hearing participants. We describe these contesting views, discuss our assessment of the Record, and report our several decisions under individual headings below.
- 1. Shall Quantity and concentfratitg Limits be Included in Addition to Dosage Limits?_
The Hearing Record shows an almost complete consensus that the basic purpose of the design-objective values is the limitation of radiation-dose levels to off-site members of the public. HowcVer, in early stages of the Hearing, the Regulatory staff contended that these dose levels should be limited by placing limits on the quantities and. concentrations of radioactive materials in effluents from light-water-cooled
,2/
nuclear power plants.
jl Regulatory staff, Exhibit 1, Tab. 1, pp. 13-19.
_2/ Tr., pp. 25-26.
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35 The Regulatory staff modified this position during the course of the Hearing. The version of Appendix I presented in the staff's concluding statement2/ did not specify concentration limits on tritium and other radioactive materials released l
to;the environment, but it did include, in addition to
' limitations on doses to any individual in an unrestricted (except area, limits on the quantity of radioactive material tritium and dissolved gases) in liquid effluents and on the quantity of iodine that could be released.
i.e., that quantity The Regulatory staff's final position, limits, in addition to dose limits, should be required, was intended to remove the possibility that future land-use patterns in the neighborhood of reactor sites might be pre-l judiced. The staff argued that dose limits alone could permit sites releases of excessive quantities of radionuclides at l
where the environs were unpopulated at the time the reactor was built; such releases might preclude future use of these environs.3,5/
i 3/ Regulatory staff, Concluding Statement of Position, Feb. 20, 1974.
4 Ibid., pp. 50-53.
Tr., pp. 343-344.
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36 The General Electric Company (GE) argued throughout the l hearing 6-9/ that specification of quantities (and concentrations) l of radioactive materials released in effluents is unnecessary in view of the primacy of the dose limitation. They insisted that such quantity limits protect no public interest and )
l '
ffort in i
provide no significant saving of calculational e S!
demonstrating compliance with dose limits.2/ And they argued I
that quantity limits on radioactive materials in liquid effluents would jeopardize the advantages that a dose formu- j lation alone would provide, namely, an as low as practicable (ALAP) regulaulon that encourages the applicant's choice of a favorable site.
0,11/ consis-The Consolidated Utility Group (CU) also argued tently that quantity and concentration limits be omitted that, though from Appendix I. They took the position 1SI dose should be the primary basis for numerical guid4nce on ALAP, they had no quarrel with the principle that quantity limits on releases from specific plants might be needed.
They insisted,bS/ however, that such quantity limits should General Electric, Exhibit 1, Mar. 17, 1972, pp. 7-13.
Tr., pp. 1435-36. Jan. 21, 1974, p. 13.
General Electric, Closing Statement,14, 1974, pp. 43-48.
General Electric, Reply, Mar.
1 Consolidated Utility Group, Statement of Position, Jan. 19, 1974, pp, 51-52. 17.
11/ Consolidated Utility Group, Reply, Mar. 7, 1974, p.
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>FY 37 not be incorporhted in the Rule and thereby be standardized for all light-water-cooled nuclear power plants without regard to the environmental factors and potential pathways associated with a particular site. Instead, they sti.ongly endorsed inclusion in the technical specifications of plant operating licenses of individual quantity limits set for each plant so as to achieve the dose objectives of Appendix I on the basis of actual site conditions and actual exposure pathways.
Both GE b2/ and CUBS! argued strongly against the Regulatory staff's proposed limit 2/ of 1 curie of iodine-131 per reactor.
Both argued that the proposal had no foundation in the Record and that it was based solely on the belief that without such a quantity limit licensees would build and operate reactors which did not use readily available technology and which would, consequently, release large quantities of rauiciodine at sites where no milk pathways exist within miles of the reactor.
Both CU and GE insisted that such an eventuality was not a realistic one.
General Electric, Reply, Mar. 17, 1974, p. 46.
1 Consolidated Utility Group, Reply, Mar. 7, 1974, p. 13.
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The proprietary of dose limits rather than quantity limits was strongly supported by Lauriston Taylor, 4'1 I on behalf of the National Council on RadLation Protection, by Merril ,
L Eisenbud, E who made a limited appearance on behalf of the Atomic Industrial Forum, and by R. M. Hartman, b who made a limited appearance on behalf of Ebasco Services, Incorporated.
Dr. Radford, who testified on behalf of National Intervenors, also endorsed this position. In addition, limited participant l Andrew P. Hull testified to his belief that the specifica-tion of release and concentration limits, over and above an overall expos.;e limit, is unwarranted and in many cases would lead to significant expenditures for protection agtinst nonexistent or completely inconsequentiai. risks.
The State of Minnesota, on the other hand, consistently
- argued 0-22/ that quantities and concentrations of emitted Although it is radioactive material should be minimized.
clear that Minnesota's intent is the protection of individuals, 1 Tr., pp. 1737-38.
Tr., pp. 2055-56.
Tr., p. 88.
Tr., pp. 109-116.
IjT National Intervenors, Exhibit 3, p. 2.
jl9 Andrew P. Hull (Limited Participant), Final Statement of Position, Feb. 11, 1974, p. 4.
2 Tr., pp. 1778-79.
State of Minnesota, Final Statement of Position, Feb. 1, 1974.
Oral Argument, Tr., pp. 159-160.
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39 and especially those individuals near nuclear facilities, the language recommended in its final statementE2/ suggests that l I
Minnesota would give primary attention to quantities and concentrations of radioactive materials released.
The overriding purpose of Appendix I is to establish limits on radiation doses to the public. We, the Nuclear Regulatory Commission, consider this to be obvious and are pleased that the Record shows essentially complete agreement with this view. Whether additional limits on quantities of emitted radioactive materials should be included is a more complex question.
We agree that the Regulatory staff was correct in recommending removal of concentration limits for radioactive materials in liquid effluents from its proposed Appendix I. Since, however, many of the very low doses of Appendix I are not in themselves subject to accurate measurement, the quantities and concen-trations of the radioactive materials must be measured, and doses must be inferred from calculations with these measure- 1 l
ments. This fact affords a basis for argument for inclusion in )
l ,..
Appendix I of 13mits on such quantities.
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23/ State of Minnesota, Final Statement of Position,
~~~
i Feb. 1, 1974, pp. 21-22.
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Not all the arguments against inclusion of such limits are persuasive. We are not impressed, for example, by the GE claim ~that guides containing quantity limits will lead to substantial misunderstanding and confusion regarc'.ing compliance i 1
with effluent-emission criteria. i We do find persuasive, however, the arguments advanced by GE and CU that the imposition of quantity limits in addition to dose limits could jeopardize the advantages that dose limitations alone',would provide and might preclude a
' regulation which is fitted to the particular characteristics of individual plants and sites and which encourages the applicant's choice of a favorable site. It is clear that the Regulatory staff recognized some validity in this argument when it indicated M that the specified quantities and concen-
.trations are substantially more conservative than would be required to meet the dose-limiting triteria for man; sites.
We have, accordingly, adopted an Appendix I that specifies neither quantity nor concentration limits for the effluents from light-water-cooled nuclear power plants. As recommended
-by.CU,E it seems reasonable to us that limits on quantities of emitted radioactive materials compatible with dose limits and the, characteristics of specific sites might be incorporated in the technical specifications of the individual plant operating license.
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Though we do.not include quantity limits in Appendix I, we
~do agree with the Regulatory staff argument $[ that it is inadequate to base parameters on uses of the environment only at ths time the reactor is designed and constructed. We certainly wish to ensure that the rule cannot result in approval of designs of radwaste systems that do not use the rudimentary, readily available technology to reduce releases.
We are convinced that the nuclear industry has no intention of doing this, and we note that both GEb ! and CU b2! d eclare that no such actions will be taken. We consider it obvious, however, that our responsibilities cannot-be satisfied by an Appendix I that depends upon the continuing good intentions l
of another party. Accordingly, although we have not included I quantity limits, we believe that by including the requirement that all augments with a favorable cost-benefit ratio be included in the radwaste system we have, as described in detail l
l in a subsequent section of this statement, obtained the neces-i sary protection for potential future uses of the environs.
- 2. Shall Primary Consideration Go to Neighboring Individuals or to the General Population?
l The Record contains considerable controversy on whether the design objectives should be based on radiation exposure of the population at large or on exposure of individurls who i
live near light-water-cooled nuclear power plants.
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~4 42 It is abundantly clear that at radiation dose levels well below those described in existing radiation standards (such as those of FRC) the levels of risk to the health of an individual are very small. Accordingly, statistically signifi-cant risks from very low levels of radiation can be calculated ,
only for large population groups. Any attempt at a cost-benefit analysis that compares money spent to reduce already low radioactivity release levels with the value of the lessened risk to the health and well-being of people is meaningful'only when large. population groups are considered. [ Exposure of 200 million people to 2 millirems per year of total-body radiation dose might lead to 72 deaths per year from cancer above the (very much larger) normal incidence. E An analysis of the costs vs. the. benefits of halving these numbers can be meaningfu1].
t on the other hand, it is equally clear that the individual living near the light-water-cooled nuclear power plant is concerned about the risk to himself and to his family and has only a secondary interest in the obviously lower average exposure to the. general population.
f
- 24/ NAS-NRC The Effects on Populations of Exposure to Low Levels of Ionizing Radiation (The BEIR Report), Report of the l
Advisory Committee on the Biological Effects of Ionizing f- Radiations, November 1972.
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43 The Consolidated Utility Group (CU) argued that the controlling consideration in establishing' numerical dose objectives should be radiation doses to the general population rather than to individuals. They held 21/ t hat, although for regulatory !
simplicity it might be desirable for Appendix I to continue to express its design objectives in terms of off-site. individuals, i the choice of the individual dose objective and of the individual to whom it applies should reflect the paramount importance of the population dose objective and should not be more stringent than can be justified on a cost-benefit basis in terms of population doue reduction.
In spite of this contention, CU, apparently for the sake of regulatory simplicity, stated its recommendations on design However, CU would objectives in terms of dose to individuals.
make the individual dose compatible with a primary population dose objective2 p/ and would specify_22/'that the individual selected for dose calculation be one whose living and recrea-tional habits, including the source of his water and food and.the quantity of his consumption of both, are representative of a significant number of individuals living in the general vicinity of the plant.
l 25/ Consolidated Utility Group, Statement of Position,
~~
j Jan. 19, 1974, p. 9. I 2 Ibid., pp._ 26-27.
Ibid., p. 69.
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b.A 44 Andrew P. Hull also favored primary consideration to total population dose and subordination of individual dose limits to that' limit. In his viewSS/ the available biological data
) would not justify going beyond the specification of an overall population limit,.and, since the benefit of a nuclear power j
plant is the amount of electricity generated, this population i
dose limit ought to be specified with relation to plant
! capacity rather than on a per plant basis.
Ebasco Services, Incorporated also argued that population l dose should be recognized as an important factor in decisions l regarding Appendix I. R. M. HartmanS ! stated for Ebasco that, in his opinion, AEC had gone too far in details for implementing the dose limit to the nearest off-site individual and not far enough in considering the dose to a sizeable nearby population group.
General Electric (GE), on the other hand, would specify the numerical guides for the nearest neighbors. The GE closing statement $S! suggested that the ALAP numerical guides be established in terms of dose-limiting objectives for the nearest' neighbors of light-water reactors and equal 1% of
' the present Federal Radiation Council Guides for the whole l body and each body organ.
t j28 Andrew P. Hull (Limited Participant), Feb. 11, 1974, p. 4.
L ]{/ Tr., pp. 111-114.
30/ General Elaf.ric, Closing Statement, Jan. 21, 1974, p. 13.
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45 The State of Minnesota clearly supports the position that s individual dose levels and not the average doses to a large population should be the controlling factors.25/ In this connection Minnesota also noted that, "in keeping with the American tradition of the importance of the indisidual, no one (and one might add, no one's offspring) should be required to assume a disproportionate amount of the risk."$$/
The Regulatory staff has taken the position that, although average population exposure is important and should be minimized, primary attention must be given to limitations on the dose to individuals living in close proximity to the reactor site.32,33/ ,
The Record shows that this position did not substantially change throughout the hearing. During oral argument, Lester Rogers stated $$/ f or the Regulatory staff:
"I think the primary objective of the regulation is, number one, to reduce the exposures and the risk to individuals, actual individuals that exist at .tue present time near.the site, to as low as practicable levels. 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 environment."
31[ State of Minnesota, Final Statement of Position, Feb. 1, 1974, pp. 12-17.
32 Regulatory staff, Exhibit 1, Tab. 1, Jan. 7, 1972.
Regulatory staff, Exhibit 1, Tab. 3, Jan. 7, 1972.
Oral Argument, Tr., pp. 23-24.
4
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We, the Nuclear Regulatory Commission, agree that radiation dose levels.to the general population are most important - ;
considerations and that these levels should be kept to low values. We do not, however, agree that' simple spacification of an average population dose level will suffice. It seems clear to us that, in general agreement with the position of J the Regulatory staff, Appendix I must provide adequate protection of those individuals who live near the light-water- ;
cooled power reactor facility.
'It seems' axiomatic that, if the near neighbors of a nuclear J
plant, and consequently those maximally exposed to its emissions, s
receive low radiation doses, then the general public will receive very low doses. It does not necessarily follow, however, that such population doses will in all cases be as low as practicable. A light-water-cooled nuclear power station in a very ' remote location (or even 7ne employing ta? 1 stacks) might ensure adequately low doses to its neighbors yet permit higher than necessary doses to the general population.
' We believe that the design-objective guides that we adopt afford the needed and reasonable balance in this regard. The primary thrust of the numerical guides is the protection of near neighbors of the reactor. At the same time, the require-ment for inclusion of all radwaste equipment with a favorable
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benefit' ratio serves to ensure that, regardless of the reactor site characteristics, the general public is protected.
We are mindful of and have sympathy for the position espoused by the State of Minnesota 21/ that no group of individuals should be Lexpected to assume a disproportionate a;acur.t of the radiation risk. But it must be obvious that such a situation, Even if
'however desirable, can seldom be realizad on earth.
radioactive releases (or, for that matter potentially harmful materials from any nuclear of nonnuclear facility) were kept as low as possible, near neighbors of the facility would assume a disproportionate share of the risk. We believe that the design-obsective guides that we adopt do meet our responsi-bility to ensure that the risk to those individuals, dispro-portionate though it may be, is as low as practicable.
- 3. Shall the Limits Apply to Each Site or to Each Reactor?_
Whether the design-objective guidcs should be applied to each water-cooled nuclear reactor or to all such reactors on a site is a fundamental question that provoked strongly contested and conflicting positions and for which the Record shows no agree-ment. The several arguments are, in brief, the following.
Throughout.the Hearing, the Regulatory staff took the position that the design-objective guides should apply to doses from l
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effluents from all light-water-cooled power reactors at a i site. '30! The Regulatory staff position is based in part on the argument that near neighbors of multireactor sites should not be required to accept radiation dose-12vels higher
'than those required of near. neighbors of a single reactor.
The State of Minnesota, apparently on the ground that "...no group.of individuals should be expected to assume a dispro-portionate amount of the radiation risk
- supported this
. position. b Both th'e. General Electric Company (GE) and the Consolidated Utility Group (CU) strongly recommended that the design-objective guides limit doses from individual reactors at a site. They supported these recommendations by several arguments.
General Electric contended b that a per-reactor design-objective guide that is as low as practicable for a single reactor will remain as low as practicable even if several reacto s are congregated on a single site and that equipment augments unjustified on a cost-benefit basis for a single reactor can never be justified on a cost-benefit basis for multiple-reactor facilities. Indeed, GE suggested b that the environmental and other advantages of multireactor siting indicate that more lenience should be allowed for per-reactor emissions from a j35 Regulatory staff, Exhibit 1, Tab. 1.
j36 Regulatory staff, Concluding Statement of Position,
'Feb. 20, 1974, p. 61.
& General Electric, Reply, Mar. 14, 1974, p. 33.
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multireactor facility since these advantages will offset any
'a'dded per-reactor radiological detriment and the added <
lenience would encourage.the desirable clustering of power- l generating installations.
General Electric contended further ! that per-reactor appli-cationLof'the guides is justified by the ALAP cost-benefit J considerations that control Appendix I and argued
~4 ! that the Regulatory staff has performed no cost-benefit' analyses indicating'the contrary.
'In its stater *nt of position, IA/ CU expressed its belief that
.there are strong-economic and environmental reasons for encouraging maximum use of existing sites and for planning
' and developing new sites for two or more reactor units. They ,
1 pointed out that obvious 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.of site investigation, engineering, licensing, construction management, and operating supervision and that environmental advantages flow from minimizing the inevitable environmental impacts associated
.with the development of new industrial sites.
38/ General Electric, Reply, Mar. 14, 1974, p. 32.
Tr., pp. 3479-80 and 3482. i Tr., pp. 3486-87.
Consolidated Utility Group, Statement of Position,
-Feb. 19, 1974, pp. 57-58.
5
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. 1 50 The Consolidated Utility GroupAS/-insisted that, at the dose levels contemplated in the proposed rule (particularly with respect to_ gaseous releases), the effect of a site limitation ;
would be to discourage and possibly prevent multiple reactor units from being placed on a single site and that it would also work an unnecessary hardship on existing multiunit stations, including several three- or four-unit stations now planned or under construction. In a similar vein 32/ CU pointed out that, although the proposed limits on doses from
! liquid effluents may not prove unduly burdensome for multireactor sites, the li its on doses from noble gases and iodine may severely limit the number of reactors at a site unless stacks l
and, in come cases, radwaste augments that it considers unjustified on a cost-benefit basis are employed.
General Electric restated with added emphasis its position and that of CU in its closing statement $2/ in the fellowing words:
"Both the Consolidated Utility Group and GE took the position in the ALAP hearings that the Appendix I numerical guides must make special allowance for multireactor installations at a single site in order to f L
l.
4 Consolidated Utility Group, Reply, Mar. 7, 1974, 21, 1974, pp. pp.
21-25.
28-29.
}j2_3/ General Electric, Closing Statement, Jan.
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1 72, -
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3 51 preserve the overall environmental and economic advantages of' minimizing the total number of power generation sites. The FES analyses, even when carried l out with a "best-estimate" dose evaluation, show that application of ALAP design objectives as overall site limits, regardless of the number of reactors present, may limit the number of units.on a site below that number that may be desirable for environmental and economic reasons. Such a forced geographic distribution of reactor sites of one or two units each will not reduce total prmulation radiation dose'from LWR effluents; in fact, it could increase total 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."
Our examination of the record indinates that none of the other ]
parties in this hearing directly addressed this question of whether the limits should have a per-reactor or per-site basis. National Intervenors$$/ (in their belief that, since we cannot prove that radiation at any level is harmless, we should permit no radiation releases at all) would seem certainly to prefer whichever limitation is the more stringent; this would 44/ Anthony J. Roisman to Algie A. Wells, et al., Feb. 15, 1972.
i I
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52 l
presumably imply a preference for a strict limit upon emissions from all reactors at a site. Andrew P. Hull, who advocated$b!
limits based primarily on doses to the population at large and who has suggested 2 man-rems per megawatt (electric) as a limiting design objective, seemed to favor essentially a per- ,
1 reactor limitation. A similar observation may be made l l
l concerning the testimony of R. M. Hartman in a limited appear- )
ance for Ebasco Services, Incorporated, who recommended $5! that 0.1 man-rem to the average individual per 1000 megawatt I 1
(thermal) be employed as a limit on population dose. !
l l
The Consolidated Utility Group would apparently place no limit, l other than that obtained by the per-reactor limit, on doses from multireactor sites, but they insisted $2/ that the resulting off-site dose to individuals living near multiunit sites would still be a small fraction of Part 20 limits and of generally accepted radiation standards and wo'11d constitute a crivial incremental risk to the health of the individuals.
On the other hand, GE would, despite its arguments described above, place an additional limit on dose levels from a multiple 45/ Andrew P. Hull (Limited Participant), Final Statement of Position, Feb. 11, 1974, p. 4.
j46 Tr., pp. 109-116.
_4_7/ Consolidated Utility Group, Statement of Position, Feb. 19, 1974, p. 16.
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light-water-cooled nuclear reactor site. In its closing statement $E/ GE recommended the language:
i "For any combination of nuclear power reactors on one :
site, on adjacent sites, or on nearby sites, the appliant ,
)
or applicants shall, in addition, provide reasonable 1
assurance that the total incremental annual exposure l l
(form either airborne or waterborne effluents) to any 1 1
individual in unrestricted areas will not exceed four (4) l 1
percent of the Federal Radiation Projection Guides, as !
set forth in Federal Radiation Council Reports Numbers 1 and 2, May 13, 1960 and September 1961, for doses to the total body or any organ."
In support of that recommendation, GE argued $! that the recog-nition in 10 CFR Part 50.34a that "as low as practicable" must be defined ~"in relation to the utilization of atomic energy.
in the public interest" requires allowance of slightly increased, N. but still trivial, exposures in order to achieve a doubling or tripling of electrical output at a site and the other environ-mental advantages of multiple-unit siting. Further, GE noted 48/ General Electric, Closing Statement, Jan. 21, 1974, p. 28.
I{/ Ibid., pp. 28-29.
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that allowing the nearest-neighbor dose resulting from a number of closely located light-water reactors, each meeting the regular single-reactor ALAP guides,.to approach 4% of the Federal Radiation Protection Guides would still limit such L doses to a small fraction of permissible dose and to a fraction of natural background exposure and would keep such doses within the variation in natural background radiation within the United States. In addition, GE pointed out that such a limit also addresses the subject of total dose to individuals from nearby but separate sites, which was not covered in proposed Appendix I.
I 2
We, the Nuclear Regulatory Commission, note that, though much qualitative argument was presented, the Hearing Record contains little specific information that will permit evaluation of
. dose levels from emissions from sites containing more than two light-water-cooled nuclear power reactors.
The Regulatory staff prepared the Final Environmental Statement and did its cost calculations on the basic of sites containing two reactors. In its concluding statement bS! the staff l
discussed the effects its recommended design-objective (per site) doses would have on limiting the number of reactor per t hat site. From these considerations the staff concludedE1/
d i.
i 50/ Regulatory Staff, Concluding Statement of Position, Feb. 20, 1974, pp.84-131.
51/ Ibid., p. 62.
- %Q ,,
a-55 the design-objective doses for liquid and gaseous effluents, other than iodine, pose no practical limitations on the number of reactors per site. The design-objective thyroid dose for iodine poses limitations on the number of reactors per site for those sites where milk is a pathway of exposure within 500 to 1000 meters of the site unless stacks or extensive in-plant iodine-removal equipment is used. If stacks are used or in milk is not a pathway of exposure within 3000 or 4500 meters of the site, there appears to be no practical limitation on the number of reactors per site even with the iodine design objective.
With respected to liquid releases, CU stated:!2/ "while neither we nor the staff have done the refined calculations necessary to establish the effect of multiple reactors on doses from liquid effluents, we would not expect that the proposed site limit on such doses would be a major factor in limiting the number of reactors per site."
However, CU argued that the situation for doses from iodine I and noble gases is entirely different and pointed out that the staff's findings, which confirm the CU calculations,53/ show j j
that for sites with a cow-milk-infant food pathway in close Sj2 Consolidated Utility Group, Reply, Mar. 7, 1974, p. 22.
5_3/ Ibid., pp. 22-24.
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56 proximity to a 500-meter site boundary the site limits of l,,
g 15 millirems to the skin from noble gases and 15 millitems l
to the thyroid would be severely limiting. They indicated that for such cases boiling-water reactors with all augments justifiable by cost-benefit analysis would be limited to 2 per site b'y the skin-dose limit and to zero by'the thyroid-dose limit. Pressurized-water reactors with augments' justified by cost-benefit analysis would not be appreciably limited
'(7 to 10 would. be possible) by the skin-dose limit, but the Adding i thyroid-dose limit would permit no reactor to be built.
100-meter stac's, which do nothing to reduce doses to the general population, would permit 4 to 6 boiling-water reactors or 2 pressurized-water reactors to be built.
We, the Nuclear Regulatory-Commission, are convinced that the grouping of light-water-cooled nuclear power reactors on well chosen and suitable sites creates genuine advantages to the use of atomic energy in the public interest. We believe-that The Appendix I certainly should not discourage such a practice.
LHearing Record seems to us to substantiate this view.
We adopt, accordingly, an Appendix I that designates dose The L limits to near neighbors on a per-reactor basis alone.
l-i Hearing Record does not, we believe, provide' quantitative I'
-u 4
i s
,w 57 s that a per-site information that can substantiate t he va ue l
limit should have. We are mindful that doses to the general population will not be increased and that they may be minimized We are by grouping light-water-cooled' nuclear power plan;c.
also of the opinion that it will be at least several years before sites containing as many as five light-water-cooled nuclear power plants are developed. Consequently, we see no way that design-objective guides set on a per-reactor basis can, in the near future, result in individual exposures that are more Indeed, we believe than 5% of present-day radiation standards.
that, with the required inclusion of all radwaste augments justified on a cost-benefit basis and with the realizatioa that several reactors cannot physically be placed so as to all be a minimum distance from the maximally exposed individual, the actual doses received by individuals will be appreciably less than this small percentage.
Our decision based as it must be on the Record cannot include The ALAP Hearing properly did items not covered by that Record.
not address the possibilities or the problems of sites containing many nuclear reactors along with other nuclear facilities or even It may be that many light-water-cooled nuclear power plants.
so-called nuclear power parks - or even sites that contain many have especial virtues light-water-cooled nuclear power plants t'
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- in the national nuclear economy. We do not know. By the time such multireactor sites are necessary or desirable, technologies not now known may be available for minimizing radioactive materials in effluents from them. Again, we do not know. "t seems clear that such installations will require large and favorably situated j sites and that such installations are several years, at least, in the future. Meanwhile, much valuable experience will be ,
1 gained concerning radioactive emissions from sites containing a few light-water-cooled nuclear plants. It would seem to us that, in due course and when experience is available, the question of the desirabillsy of a per-site limitation on emissions from multireactor sites should be examined. .
I
- 4. What Shall Be the Numerical Values of the Design-Objective Guides?
A superficial examination of the Record might suggest only I f minor disagreement over the numeric.11 values of the design objectives. A more detailed examination, however, reveals that this notion of minor disagreement is illusory.- In fact, the general similarity of the design-objective values recommended by the several parties tends to mask the considerable differences in the bases on which these values are suggested. This is another question on which we, the Nuclear Regulatory Commission, have had to decide among conflicting views.
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59 The proposed Appendix I limited the annual dose to any individual from radioactive materials in liquid, gaseous, 4
and as radioiodine and particulate. matter from all reactors 54,55/
on a site to 5 millirems to the total body or to any organ.
4 General Electric (GE) recommended bb! that the design-objective dose values for nearest neighbors of each light-water-cooled nuclear power reactor be set at 1% of the FRC radiation protection guides. They recommended specifically that the objectives should be 5 millirems per year for the total body, 15 millirems per year for the thyroid, and 30 millirems per year for the skin.
Consolidated Utility Group strongly urged E1/ the adoption of 1% of ICRP values for individuals in the general population, including ICRP values for organs other than the whole body.
They suggested that the individual thyroid-dose objective should be changed to 15 millirems for children and 30 millirems for.
adults and'that the individual skin dose be changed to 30 millirems.
Regulatory staff, Exhibit 1, Tab. 1.
Regulatory staff, Concluding Statement of Position, p. 48.
' General Electric, Closing Statement, Jan. 21, 1974, pp. 13, 26 and 28. -
j7/ Consolidated Utility Group, Statement of Position, Jan. 19, 1974, pp. 68-69, t
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si 60 The State of Minnesota in its final statement appeared to "m endorse the proposed Appendix'I position to limit the annual
. dose from all reactors at a site to 5 millirems to the total l body or-any organ. b Douglas LaFollette has also indicated !
his strong support of this position. E Several other suggestions were made. The Tennessee Valley Authority suggested b that "the costs and consequences of l achieving 1% of Part 20 limits should be carefully balanced l against the costs and consequences of achieving instead, for example, 10% of Part 20 limits." Merril Eisenbud suggested, on behalf of the Atomic Industrial Forum, the value 5 millirems ;
to the whole body, gonads, or bone marrow and 15 millirems to al?. other organs.61,62/ National Intervenors,6_3/ argued that i no radioactive _ discharges should be permitted. At the other extreme, G. Hoyt Whipple '
! considered that numerical guidelines other than those given in 10 CFR Part 20 are 5_8/ State of Minnesota, Final Statement of Position, Feb. 1, 1974, pp. 8 and 17.
59/ Final Environmental Statement, WASH-1258, July 1973, Vol. 3, p. 38..
6 Ibid., p. 314.
Ibid., p. 96.
'Tr., p.-86, Statement by Merril Eisenbud, p. 5.
Anthony 5. Roseman to Algie A. Well, et al., Feb. 15, 1972,
- p. 7.
64/ Final Environmental Statement, WASH-1258, July 1973, Vol. 3, p. 94.
65] G..Hoyt Whipple, Testimony on the Proposed Appendix V to 10 CFR Part 50, Feb. 20, 1972.
m mayn; = ~ r = = --
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~1 s 61 unnecessary since the interpretation of 10 CFR Part 20 by the v
nuclear industry has r'esulted in performance so excellent that g; there is no need for further incentive.
p Andrew P. Hull, who was a' limited participant throughout the .
Hearing, argued I that a boundary limit _of 25 millirems per year whole-body dose to individuals would be consistent with his proposal of 2000 man-rems per year limit for population dose from each 1000 megawatt (electric) reactor.
The Regulatory staff modified its original position as a result of the Hearin.. In its concluding statement 1! the Regulatory staff. agreed that the limiting dose to the thyroid should be changed from 5 to 15 millirems per year because as a practical matter the dose to a child's thyroid is controlling for purposes of design objectives and operational control and evidence developed in the Record shows that a design objective of i
L 5 millirems per year is not practicable at this time, with respect to.the state of technology and the costs of iodine-removal ,
l equipment, where milk cows graze in the near vicinity-of the site.
I The' Regulatory staff also recommended 2[ that the skin dose I
i due to external , exposure from beta and gamma radiation. released in gaseous effluents be changed from 5 to 15 millirems per year 66/ Andrew P. Hull, Final Statement of Position, Jan. 30, 1974.
((/ Regulatory staff, Concluding Statement of Position, Feb. 20, 1974, pp. 48 and 25-30.
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62
, - , , because it is not practicable to design to limit the beta dose to 5 millirems per year.
The Regulatory _ staff continued to recommend that the design-objective dose from radioactive materials in liquid effluents from all-light-water-cooled nuclear power reactors at a site be kept at 5 millirems per year to the total body or to any organ.bS!
The staff argued that both CUBS! and GE2S! agree that this design objective is practicable for liquid effluents.
In its reply statement, however, CU insisted that it no longer entirely agree; with that summation. They stated 21/ (presumably for a two-reactor site) that for river sites with either PWRs or BWRs and with either cooling mode there is no cost penalty, over and above costs of augments that are justified on a popu-lation cost-benefit basis, in meeting a limit of 5 mrems per year to an individual using the staff's conservative dose models.
When the. analysis is. expanded to include lake and seacoast l sites, however, this is no longer true. With the staff's models, bases,.and cost estimates, augments over and above those which can be justified on a cost-benefit basis are required to meet the design-objective dose of 5 mrams per year for several situations in all but one of which cooling towers are used.
I l j68 Ibid., p. 50.
L 69/ Tr.,.pp. 3996-98./ General Electric, Closing Statement, Jan. 21, 1974, p. 16.
,1/
7 Consolidated Utility Group, Reply, Mar. 7, 1974, pp. 15-17.
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; -,-w 63 We have already announced and discussed our decision E that the design-objective guides that we adopt will apply to each individual light-water-cooled nuclear reactor.
In general agreement with the preponderance'of' evidence in the Record and in recognition of the relative weighting of total-body and organ dose limits recommended by the PRC, the ICRP, and the NCRP, we adopt as our basic design-objective guides I the limits.for doses to individuals from effluents from each light-water-cooled nuclear power reactor of 5 millirems per
. year to the' total body;and-15 millirems per year.to organs and the skin..
The design objectives limit the radioactive material that may be released in liquid affluents from light-water-cooled nuclear power reactor to that annual total quantity which will result in'an annual dose to any individual in unrestricted areas not in excess of 5 millirems to the total body and 15 millirems to the skin or any organ. For calculation of such doses, it is assumed that rivers are used as sources of drinking water and'that rivers or other pertinent bodies of water are.used as .
. sources of fish or other. seafood unless positive evidence is ;
provided to prove otherwise. The models also assume (as
- y This document, Section III.B.3.
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44 64 discussed in more detail under Implementation, Sec. V, this document) that near neighbors of the light-water-cooled nuclear power reactor include indi.viduals with habits differing significantly from the average, We believe that the Record indicates that it is practicable to meet this design objective and that for many, if not all, reactor sites this design objective can readily be met with radwaste systems that show a favorable cost-benefit balance for reduction of the dose to the general population. The design objective to control exposure from gaseous effluents has been expressed in terms of a limitation on the annual dose due to gamma radiation or beta radiation from each reactor at or beyond the boundary of the site. This design objective, in effect, provides flexibility for considering site-related meteorology and the distance from the reactor to the site boundary, but it requires the assu.mption that peopic may live jsut outside the site boundary. The specified dose rates of 10 millirads per year for gamma radiation and 20 millirads per year for beta radiation would normally be considered to limit doses to individuals in unrestricted areas to not more than 5 millirems to the total body and to less than 15 millirems to the skin. Provisions are made to decrease this annual dose if for a particular site there are special circumstances that
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a- : 65 necessitate such a decrease to ensure that an individual in an unrestricted area shall not receive more than 5 millirems total- ; body exposure. Provision is made for an increase in this release rate if special site characteristics or circumstances indicate that such an increase will not lead to individual doses above 5 millirems per year to the total body or 15 millirems to the skin. In practice, such an increase seems unlikely to be invoked; the additional requirement for all radwaste equipment with favorable cost-benefit balance for decrease of population dose is expected to be controlling for many sites. We believe the , record indica as that this design objective is practicable for individual light-water-cooled power reactors at essentia]ly all sites. The design objective for radiciodine and radioactive material in particulate form was probably the most difficult issue in this proceeding. The design objective has been set to ensure that emission of radiciodine and radioactive material in particu-late form from each light-water-cooled nuclear power reactor shall not result in an annual dose for any individual in unrestricted areas from all pathways of exposure in excess of 15 millirems to any organ. For virtually all cases, the thyroid dose will be the only one of real consequence from this source. I i (
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As indicated in detail under Implementation (Sec. V, this document), the design-objective quantity 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. Future uses of the environment with respect to food pathways i will be protected by limiting conditions of operation that require monitoring and surveillance programs designed to identify changing land uses that may result in exposure of individuals to iodine. Appropriate control measures, I including the modification of land uses, would be required if monitoring programs during operation indicate that the design-objective guide levels are being exceeded. l 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 population for costs - not in excess, in early 1975 dollars, of $1000 per man-rem or $333 per man-thyroid-rem. Juch a provision will ensure that selection of a very large and isolated site cannot
. justify the release of large quantities of radioactive materials, especially radiciodine, simply because no substantial individ-ual doses would result.
0%% . .
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M 67 1
- 5. What Are the Bases on Which Cost-Benefit Evaluations Will Be Made?
l Benefits to the general public from the generation of electricity j by light-water-cooled nuclear power plants are not germane to the decisions concerning Appendix I. Such benefits and their associated costs are a real consideration in the process of 4 licensing and siting power reactors. The cost-benefit balance appropriate to decisions regarding Appendix I deals with-the costs for the benefits from installation of sophisticated augments to radwaste treatment systems. The nned to balance the cost for each incremental reduction in dose and the benefit to the pro-tection of human health and well being from the resultant reduction in risk should clearly form a part of any judgment of whether a given dose level is as low as practicable.
- a. What is the Monetary Value of Reduction in Dose to the General Population?
Such balancing of cost and benefit . requires that bota sides of the balance be expressed in commensurate units. It is difficult to escape the conclusion that such commensurate units should be units of money. The Regulatory staff agrees with the desirability of expressing the cost-benefit in this way,13/ but it has been most reluctant to assign a dollar value to the reduction of radiation dose to 73/_ Final Environmental Statement, WASH-1258, July 1973, Vol. 1,
- p. 8-3.
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68 - l 4 the general population. The staff has taken the position b that there is no agreement on monetary values for the reduc-tion of risk to human life or suffering or on how such values j should be applied. They reason that it is not possible to reflect properly the worth of reduction of risk to human life in monetary terms since there are overriding moral values that cannot be quantified. The staff cites in the Record the several published estimates of the monetary cost of radiation exposure of the i public; these range from $30 to $980 per man-rem. The staff has observed I that the majority of the estimates are in the range from $100 to $600 per man-rem. No values have been suggested for dose to single organs, such as the thyroid. However, the relative risk of the dose to the thyroid compared to the dose to the total body would suggest a lower value for a man-thyroid-rem than for a man-rem. The staff continued to make clear the fact that they do not endorse any absolute value for the worth of dose reduction. For example, they suggested that it must be recognized that many aesthetic, human, and environmental factors are not j74 Ibid., pp. 8-2 and 8-3. 75/ Ibid., p. 83.
)l/ Regulatory staff, Concluding Statement of Position, Feb. 20, 1974, p. 43.
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+/ u 69 quantifiable and must be given weight in the decision-making Thus, process by informed, though subjective, judgments.
I references to dollar cost per unit of dose reduction used by (FUS) snd in the staff in the Final Environmental Statement the Record Hearing are intended for comparison purposes only; no absolute monetary value for such dose reduction is recommended. On the other hand, the staff holds that despite the inherent difficulties in the direct use of monetary values, it appears useful to express, to the extent practicable, both costs of reduction of risk and benefits to society from such reduction , in monetary units as at least one of the factors to be considered in arriving at judgments on reducing risk to as low as practicable levels. Z2! and its concluding statement,2 ! the staff In both the FES -
- does calculate, from its estimates of radwaste-system costs and the resultant reduction in population dose, values for cost per man-rem reduction. They do not, however, accept or reject radwaste systems because of the cost of such reduction.
- It is clear from the Record 1S! that the staff would leave to us, the Nuclear Regulatory Commission, the decision as to 22/ Final Environmental Statement, WASH-1258, July'1973, Vol. 1, p. 8-2.
78 Regulatory, staff, concluding Statement of Position. Tr., pp. 3474-73.
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70 dollar value of man-rom reduction in population dose and the extent to which such a value would be given weight along with other considerations in the ALAP ruling. In contrast, the Consolidated Utility Group did choose80-82/ a value for the worth of a man-rem. For CU, Walton Rodger stated 81/
"You may duck the issue all you want but in order to make a meaningful cost-benefit analysis you simply have to 4 ' bite the bullet' and assign a value to a man-rem. We
- recognize that this isn't easily done, that there are 1
', great subjective factors involved, and that this is an 'l area-in which reasonable persons may reasonably disagree. h Nonetheless, we chose a value.- We chose $1000/ man-rem. (and 1/3 of that for a man-thyroid-rem) . The FES quotes l~ a number of estimates 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 chose a value above the range quoted for two reasons: 80/ Consolidated Utility Group, Exhibit 5; Walton A. Rodger, t Additional Testimony on Behalf of the Consolidated 7 Utility Group, Exhibit 9, 1973.
; 81/ Consolidated Utility Group, Exhibit 6, Summary of Additional
" Testimony dated Nov. 9, 1973, of Walton A. Rodger on Behalf
; of the Consolidated Utility Group, p. 2. , 82/ Tr., pp. 3913-15.
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- (1) to be conservative in our assessment of the value of !
augments, l (2) to make' allowance for " overriding moral values" and l other intangibles which are hard to quantify." !
' 4! these values of $1000 per man- l As the Record makes cl' ear, id-rem represent no independent assess-
. rem and $333 per man-th yro ment. They were obtained by CU simply by taking a value some-
)
what higher than the range of values 2S/ suggested by the several 1 studies cited. ! While general 2v accepting the cost-benefit analyses presented by CU, Gk seems to have made no recommendations for the worth of a man-rem. r I l The State of Minnerota s made no assignment or decision as to l E/ Minnesota has argued consistently 1 the worth of a man-rem l that releases of radioactivity should be minimized bist has not tied this recommendation to the resultant dose effects nor has it made cost-benefit analyses in support of its However, it seems clear from the Record recommendations.8}/ 1 8 Tr., pp. 3944-45. ition,
)j3_4/ Consolidated Utility Group, Statement of Pos Jan. 19,-1974, p. 31.
>- 85/ Tr., pp. 1778-79. , i a
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72 thac the-State of Minnesota would put a very high value on a man-rem.S5/ We certainly agree with the Regulatory staff and with CU that i I there are great subjective factors to be considered in any judgment of the value of reduction of a man-rem in dose to the general population. It is also clear, however, that a dollar figure for such value is necesary for the cost-benefit analysis that must form a part of the basis for decision as to the specific minimal guides of Appendix I. After careful l consideration of the several points of view expressed in the Record, we think it prudent to recommend that a man-rem reduction in population dose be assigned the value of $1000 and a man-thyroid-rem reduction in such dose be assigned the value of $333. Accordingly, we so recommend; these values will be used where appropriate in cost-benefit considerations . l for this Appendix I. ) It seems manifest to us that those augments to a radwaste system which have a favorable cost-benefit ratio for reduction of dose to the population at large should be required of all light-water-cooled power reactors. In a previous section of this document,E2/ we announced our 6: cision that those j6/ State of Minnesota, Final Statement of Position, l Feb. 1, 1974, p. 14. , l
!7/ This document, Section B.2.
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l '*A l-I 73 A f 1 individuals living near the light-water-cooled power reactor must be' properly protected. Accordingly, installation of equipment'with a favorable cost-benefit ratio for dose to 9 the population at large is.necessary, but it may in some cases not be sufficient to satisfy the requirements of Appendix I.
- b. What are the Monetary Costs of Augments to Radwaste systems?
During the initial phase of the ALAP Hearing (prior to May 6, 1972), the Regulatory staff presented information of a preliminary and fragmentary nature concerning the costs of radwaste systems. Other information concerning costs of i radwaste systems was also presented in this initial phase of the Hearing by CU 90.91/ and-to a limited extent by GE.S ! Walton Rodger, who presented what might fairly be called the only comprehensive formulation of costsES/ and of arnualized I l 8 Regulatory staff, Exhibit 1, Tab. 2. Tr., pp. 536-590. ; Walton-A. Rodger, Statement on Behalf of the Consolidated 1748-52, Utility Group, Mar. 17, 1972, incorporated in Tr. , pp. 91/ Walton Rodger, Supplemental Statement on Behalf of theincorporated in ! Consolidated Utility Group, Apr. 26, 1972, Tr., p. 2753. 92/ General Electris,~ Exhibit 3, Apr. 26, 1972, items 4 and 5.
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4 74 costa b d uring this period, criticized $ the staff's data.
-Little substantive information on radwaste system costs was presented in this period.
The Regulatory staff's pubiication of the Draft Environmental Statement,b its consideration of the many diverse comments on this document, and its subsequent publication of the Final Environmental Statement were important steps in providing a basis for proper costing of radwaste systems and for cost-benefit analyses. Comments on the Draft Environmental Statement showed, as might have been expected, some disagree-ment with the estimated costs of radwaste equipment. Consolidated Edison Company of New York, Inc., stated b! that cost estimate in the Draft Environmental Statement seemed to be generally lower than their experience would indicate. They showed a few specific examples in which the estimated costs appeared to be low by at least a factor of 3. In its comments on the Draft Environmental Statement, CU had only minor criticisms of the estimated costs of individual 13/ 3 Walton A. Rodger, Statement on Behalf of the Consolidated Utility Group, Mar. 17, 1972, p. 41. 9y Notice of Availability of the Draft Environmental Statement was' published in the Federal Register Jan. 16, 1973, (38 F.R. 1616). j95 Final Environmental Statement, WASH-1258, July 1973., (- j96 Final Environmental Statement, WASH-1258, Vol. 3, July 1973, pp. 311-312. 97/ Ibid. , p. 243,
w w .- a
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75 However, CU argued strongly items of-radwaste equipment. in the
.that the cost picture was badly ~ distorted by the use Draft Environmental Statement and the Final Environm Statement of a two-reactor site in which much of the r They insisted i
equipment was shared between the two reactors. ld be realized only
.that the suggested capital cost savings cou if two reactors were built at the same site and at approxi-mately the same time.
1 that, Moreover, after publication of the FES, CU insisted in since costs in the FES were nearly a factor of 2 less than the draft statement, they could no longer avoid taking issue After a detailed elaboration with the staff's cost estimates. i of many points on which they found the staff's cost est mates E that the FES radwaste systems deficient, CU concluded i could not possibly be built and operated for less than tw ce be the costs indicated and that more likely the cost would three to four times that given in the FES. _98_f Ibid., p. 244. DJ/ Behalf Tr. , p.of3909; Walton A. Rodger, additional testimony the consolidated Utility Group, Nov. 19, 1973, on pp. 38-39 100/ Ibid., 3909; p. 51. i ?
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76 01/ its In its concluding statement CU continued to maintain belief "that the cost of installing and operating waste-treatment systems has'been understated perhaps by a factor of 3 or 4." i I The Regulatory staff, on the other' hand, continued to defend the cost estimates presented in the FES. In its concluding statement 02/ the staff pointed out that the CU data were based ~on " industrial experience" and included overtime and 1 other exceptional factors and that CU had included backfitting The experienc:103,104/ and optional redundant equipment. staff argued 102/ that none of these items should be included in the cost of radwaste systems for cost-bene' fit analysis. The staff did include redundant components in costing the radwaste systems in the Draft Environmental Statement but, at least partly because of criticisms in comments on the draft, removed such redundancy "...which is not required for meeting AIAP or licensing requirements and therefore should not be included in costs.for meeting dose reduction in cost- ' benefit analyses," from the systems evaluated in the FES. 101/ Consolidated Utility Group, Statement of Position, Jan. 1974, p. 36. 102/ Regulatory Staff, Concluding Statement of Position, Feb. 20, 1974, pp. 43-45.
- 10 Tr., p. 3975.
Tr., p. 3985.
/ Regulatory staff, Concluding Statement of Position, Feb.- 20, 1974, pp. 44-45.
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77 l l l i that l The Consolidated Utility Group took the posit on They pointed j redundant radwaste equipment is often necessary. l J 1E5/ that it is not the practice of utilities to install ; out ~ d y I such systems without the provision of adequate redun l anc for safe and reliable operation nor is it likely in h actua to practice that NRC license conditions would permit t em For most radwaste systems, a utility simply do otherwise. depend on cannot afford to allow operation of the plant to ipment. the availability of a simple piece of radwaste equ the After consideration of the several differences ES2/ that between staff and the CU estimates, the staff concluded ith there were no significant unexplained differences w respect to cost estimates. nsider-We, the Nuclear Regulatory Commission, believe for after co ation of the Record that the staff's costbeestimates low construction and operation of radwaste systems may likely to by an appreciable amount but that they are quite un It seems to us that to the be in error by factors of 3 or 4. t redundancy extent - and only to the extent - that equipmen h redundant is required by the licensing process the cost of suc h lf of 106/Consolidated Walton A. Rodger, Additional Utility Group, Testimony Nov. 9, 1973, p.i49. on Be a 107/ Regulatory staff, Concluding Statement of Posit on, Feb. 20, 1974, p. 45.
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e 954md 78 9 items should be included in the total costing of the system. It seems equally clear that the additional costs, if any, due to increased attention to quality assurance should be included in the radwaste-system costs. It does net seem reasonable to include costs of overtime or other special i features that may have in specific instances contributed to higher than normal costs of installation. On the other hand, 1 the costs of operating the augmented equipment should be i realistically estimated; such estimates should include i reasonable allowances for maintenance of equipment and for 1 the increased 'ork force and payroll based, insofar as is possible, on actual experience as this experience exists or be comes available. We note and are impressed with the CU. conclusion 108,109"/ that, ,- even though the Regulatory staff's cost estimates are low by 4 some factor, this difference makes little if any charge in the list of'radwaste augments that are justifiable on a cost-benefit basis. In this connection, Walton Rodger stated for CU:
"Some of the augments which appear ' justified' using PES values might become ' unjustified' if the costs doubled or trebled, but the degree of 'unjustification' i
108/ Tr., p.-3912; Walton A. Rodger, Summary of Additional Testimony dated Nov. 9, 1973, on Behalf of the Consolidated Utility Group, Nov. 28, 1973, p. 9. 109a/ Tr., pp. 3M7-28.
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arguments that any of the augments listed in Exhibits II 1 and III should be removed."
- c. How Shall the Cost-Benefit Balance Be Calc'ilated?
The costs of installation and operation of radwaste systems were'as indicated above, a matter of controversy, but an even more -fundamental dif ference of opinion existed (primarily between the Regulatory staff and CU) over the manner in which cost-benefit balancing was to be done. The Regulatory staff has, in effect added for each effluent type the several radwaste augments as a unit to the base-case dual light-water-cooled nuclear power reactor system.3,95/ From estimates of the cost of the radwaste augment package and of the resulting decrease in radiation exposure to the population, the staff obtained a value in dollar cost per man-rem of the resulting reduction in population dosa. The staff also included},95/ in the total cost of the radwaste system the cost of the residual population dose; for thLs calculation they showed costs resulting from a wide range of dollar values for the cost of a man-rem of radiation exposure. This added cost, which was very small for all except quite unacceptable sets of radwaste augments, seems not to have been objected to by other parties who replied to the staf.f's concluding statement.
w- w- , ;.~-..-n = ,. G - n.-.--... - T ~.. _ .- - .. . - - - 2 , Dt' 80 L.4 After publication of the FES, the initial position of CU included a real objection to the staff's choice of base-case radwaste systerus. In his written testimony, Walton A. Rodger characterized as " completely unrealistic" the basa-case
! and for BWR liquids. '!
- radwaste systems for PWR liquids 10/
He also argued that the base-case for PWR gases was unrealistic but stated that the base-case for BWR gases was reasonably
! In the summary of representative of an unaugmented BWR.
this testimony, Dr. Rodger made the same claim of "unrealism"
! but for the base-case PWR and BWR liquid-radwaste systems suggested that the base-case gaseous-radwaste systems for both
! In response to questioning,
> reactor types were reasonable. i Dr. Rodger stated that the degree of unrealism for the PWR base-case gaseous-radwaste system "is not really enough to l argue about.114/ ; l 4 109b/.Tr., p. 3909; Walton A. Rodger, Additional Testimony .,~ on Behalf of the Consolidated Utility Group, Nov. 9, 1973,
- p. 25.
109c Ibid., p. 32. Ibid.,-p. 8. Ibid., p. 16
/ Tr., p. 3912 Walton A. Rodger, Summary of Additional Testimony dated Nov. 9, 1973, on Behalf of the Consolidated Utility Group, Nov. 28, 1973, p. 4.
jll3 Ibid., p.'6 114/ Tr., p. 2950. 4 a
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..m 81 It is clear that if the base-case radwaste system were impro-perly chosen, i.e., chosen so as to lead to large (calculated) doses to the population, the subsequent cost-benefit balance )
might, if several radwaste augments were considered as a
~
unit, show that unrealistically expensive radwaste augments could be justified. We believe the Record shows clearly that the base-cases for. gaseous-radwaste systems are not unrealistic. j It 1.s possible that the liquid-radwaste base-cases selected by the staff are somewhat unrealistic in that they do not represent the systems used in modern light-water-cooled nuclear power systems. However, as it will develop in the following discussion, this "unrealism," if it exists, has little or no effect on the actual cost-benefit conclusions. .. The major thrust of the CU argument against the staff's cost-benefit balance concerned the practice of adding the several radwaste augments to the base-case as a unit. As > Walton Rodger stated for CU 115/ f i
)
"One of the major comments which the Utility Group made concerning the cost-benefit analyses of the Draft Environmental Statement was that the data were presented in such a manner as to hide the extra-ordinarily high ratio of cost-to-public benefit 115/ Tr., p. 3909; Walton A. Rodger, Nov. 9, 1973, p. 1.
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"" received-for most of the components of the cases which were chosen for presentation. .In the preparation of the Final Environmental Statement, the staff not l
only ignored this comment, they went even further in masking the fact that some of the additional treatments l proposed are vastly more expensive than others. This l was done by eliminating even the rudimentary case-by-case 1 differential costs which were included in the DES." I In the summary of his written testimony 116/ Dr. Rodger stated:
"The thru t of the Testimony which we filed on November 9, 1973 was to break down into their component parts the cost-benefit analyses presented in the FES. The first purpose for doing this was to demonstrate that while some augments to the gaseous and liquid radwaste systems of PWR and BWR are justified on a cost-benefit basis, i
others are not. In fact many of the augments considered in the FES result in the expenditures of incredibly v large numbers of dollars for every dollar of value returned. The " lumped" approach used in the FES cost-benefit analyses completely hides this fact." 116/ Tr., p. 3912; Walton A. Rodger, Summary of Additional Testimony dated Nov. 9, 1973, on Behalf of the Consolidated Utility Group, p. 1. i
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>fl' In effect,;Dr. Rodger used the Regulatory staff's dose calcu-lational models and the staff's values for annual releases of radioactivity-and annual costs for the radwaste augments and conducted the cost-benefit study by addir.g augiaat.ts
' individually and sequentially to the liquid, the noble-gas, l and the iodine and particulate radwaste systems, i
By this technique of sequential addition of the most effective
-radwaste augments (so that in effect each addition ~ constitutes with the other augments already present a new base-case to which the next augment is to be added), the cost-benefit evaluation can show the true worth of each individual augment.
l We, the Nuclear Regulatory Commission, must agree that the cost-benefit balancing methods employed by CU are superior . toL the' approach that appears tx) have been used by the . Regulatory staff. Accordingly, where Appendix I directs L l - l' that augments showing a favorable cost-benefit ratio for l E reduction of population dose be included in the radwaste t systems for light-water-cooled power reactors, we intend that the worth of the augment be assessed by this superior procedure. In cases, and it appears that there are several, where the radwaste system consisting of all items showing a favorable cost-benefit balance for decreased dosage to the population
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84 l I will also ensure that doses to individuals near the light- l l water-cooled nuclear power reactor facility are within the design-objective guides, no further augments appear necessary or desirable. Where such a system does not meet the design-objective guides for doses to neighboring individuals, then I additional augments are required even though they cannot be shown by this or other techniques to have a vavorable cost-benefit l ratio.
- 6. Shall Exceptions to the Design-Objective Guides Be Allowed If Radwaste Systems Contain " Baseline In-Plant Control Measures"?
In its concluding statement the Regulatory staff introduced the recommendation that exceptions to the design-objective guides for liquid effluents 117/ and for radioiodine and radioactive materials in particulate form 18/ be allowed if certain " baseline in-plant control measures" were included in the radwaste-systems design. For liquid effluents the design-objective guides proposed by the staff stated that 117/ the calculated annual total quantity of all radioactive material from all light-water-cooled nuclear 117/ Regulstory staf f, Concluding Statenent of Position, Feb. 20, 1974, pp. 26-27. 118/ Ibid., pp. 29-30.
4wa . , aq - 85 power reactors at a site should not result in an annual dose or dose commitment to the total body or to any organ of an individual in an unrestricted area from all pathways of exposure in excess of 5 millirems, and the calculated annual total quantity of radioactive material, except tritium and dissolved gases, should not exceed 5 curies for each light-water-cooled reactor at a site. However, if the applicant had proposed l baseline in-plant control measures (of which several typical examples were listed), the calculated annual total quantity could be permitted to exceed the 5-curie limit for each light-water-cooled nuclear power reactor provided the design-objective 1 guide for the dose limit was met. The staff has proposed no increase in its design-objective ' (per site) dose level even if the baseline in-plant control I measures are included in the liquid-radwaste system. We, the Nuclear Regulatory Commission, believe that inclusion of such measures would certainly not justify an increase in the (per reactor) design-objective dose levels that we have adopted. Accordingly, since we have not included quantity limits in our design-objective guides,119/ we include no provision for baseline in-plant control measures for liquid effluents in the Appendix I that we adopt. 119/ ,his document, Section III.B.4.
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For emissions of radioactive iodine and radioactive material in particulate form, the staff proposed that exception to the design-objective dose be allowed if the baseline in-plant l control measures were included in the radwaste-system design.118/ l The staff recommended that the (per site) annual dose limit j from radioiodine and radioactive material in particulate form should not exceed 15 millirems to any organ of an off-site l l individual and that the calculated annual total quantity of I iodine-131 in gaseous effluents should not exceed 1 curie for each reactor. If, the applicant had proposed baseline in-plant P control measuras (of which several typical examples were listed), he could be permitted releases of radioiodine and radioactive material in particulate form in quantities that did not exceed four times the quantity that would yield the 15 millirem dose to any organ of an off-site individual. Both GE and CU argued strongly against inclusion of ',uch baseline in-plant control measures in Appendix I. They claimed that the baseline in-plant control measures approach is un-warranted since the ALAP record shows that most of the
" measures" are unjustifiable on a cost-benefit basis,120-123/
120/ General Electric, Reply, Mar. 14, 1974, pp. 22-23. 121/ Walton A. Rodger, Additional Testimony on Behalf of the Consolidated Utility Group, Nov. 9, 1973, pp. 1-38. 122/ Consolidated Utility Group, Statement of Position, Jan. 19, 1974, pp. 29-41. 123/ Consolidated Utility Group, Reply, Mar. 7, 1974, pp. 6-7.
- .n.4 .
- l% b 87 that monitoring data at operating light-water-cooled nuclear power reactors show that most of these " measures" are unneces-and that, should sary to meet the design objectives,124,125/
augumentation for building air ventilation releases be neces-sary, most of the " measures" would be technically and
/
economically inappropriate for reducing such emissions.125 In addition, GE argued l26/ that, until the release of the 7tatement, the guides of proposed Regulatory staff's concludinc Appendix I and the alternativt. e/vvisions proposed by other parties to the proceeding had been drawn exclusively as performance standards. The suggested incorporation of equip-ment criteria represented a fundamental change in the underlying regulatory approach and would allow the staff to prescribe specific effluent-treatment equipment--thereby intruding on the traditional role and responsibility of the applicants and their engineering consultants--vithout reference to the performance and cost-benefit status of the equipment prescribed. We, the Nuclear Regulatory Commission, are impressed with the argument that the design-objective guides should be drawn as unless necessary for performance standards and should not, 124/ Regulatory staff, Exhibit 24, Oct. 1973. T2T/ General Electric, Exhibit 5, Nov. 9, 1973. 126/ General Electric, Reply, Mar. 14, 1974, p. 21. l - - - _ _ - -
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88 the protection of the public health and safety, incorporate requirements for specific equipment. We believe that the Record does not indicate that installation of the baseline in-plant control measures - and the consequent relaxation of the design-objective guides on doses to individuals - is necessary or desirable for such protection of the public health and safety. We note that CU has stated l27/ that PWR's and BWR's using the assumptions in the FES and with the radwaste augments justi-fiable on a cost-benefit basis (and which we would require) wottid release about 0.6 and 0.3 curies per year of iodine-131, respectively. Such releases of iodine-131 from a typical reactor site would be expected to result in total doses of about 60 and 30 man-thyroid-rem to the population. Additional radwaste augmentation may well be required to limit the thyroid dose to specific individuals via the milk pa'.hway where cows graze close to a site. However, we believe that, y with the design-objective values of our adopted Appendix I, l [ the near neighbor of the light-water-cooled nuclear power i l- reactors will be suitably protected and that the baseline in-plant control measures would seldom, if ever, be necessary. l Accordingly, we have not included provisions for such measures in the Appendix I that we adopt. 127/ Censolidated Utility Group, Reply, Mar.7, 1974, p. 12-13.
~ - - - - -- ~ -ae ~,. 4, 89 1
j Shall Limits Upon Direct Gamma Radiation From Reactors. 7. and Associated Equipment Be Included? The State of Minnesota took the position that Appendix I boundary-dose calculations should specifically include the contributions from direct gamma radiation from the reactor '! site (gamma shine).128/ Consolidated National IntervehorB also raised this point concerning radiation other than that from radioactive materials in effluents from light-water-cooled nuclear power reactors. An early position of the Environmental Protection Agency (EPA)
! also included the i-suggestion that direct gamma radiation should be considered.
The Environmental Protection Agency no longer holds this view; it states:131/
"We recognize that the scope of the present rulemaking is limited to material effluents, and that for this reason did not address the issue of direct and We suggest indirect gamma radiation from onsite locations.
the Commission deal with this category of exposure through early issuance of limiting criteria for doses for such radiation." l 128/ State of Minnesota, Final Statement of Position,
~
Chapter II-E, Part 3, Feb. 1, 1974. 15, 1972, 129/ Anthony Roisman to Algie Wells, et al., Feb.
- p. 6.
130/ Final Environmental Statement, WASH-1258, July 1973, Vol. 3, 1974. pp. 263-264.Rowe to L. Manning Muntzing, received Mar. 12, 131/ W. D.
- p. 3.
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ir-90 l The Hearing Record. reveals that experience has shown the highest radiation dose rate at the site boundary to be generally less than 10 millirems per year from this source; since the dose rate decreases rapidly to negligible levels with distance from the site boundary, this source contributes only a fraction of a man-rem per year to the population dose. 32/ This Hearing has been concerned from the beginning with keeping "as low as practicable" the risks to the public from radiactive materials in effluents from light-water-cooled power reactors. Moreover, as the Regulatory staff testified, proposed Appendix I was not intended to include direct radiation from the nuclear facility. We, the Nuclear Regulatory Commission, agree that such direct or scattered gamma radiation from the turbine building and from waste storage tanks and other equipment containing radioactive material should' continue to be taken into account in the licensing process. Such gamma radiation should be carefully controlled by. proper design and operation of the reactorfand associated equipment. It may be appropriate to issue in.due course further guidance on levels "as low as practicable"'from this radiation source, but we believe that such guidance should clearly be separate from Appendix I. 132/ Regulatory staff, Concluding Statement of Position, Feb. 20, 1974, p. 65. 133/ Tr., pp. 59'-598.
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- 8. hill Increased occupational Exposure to Radiation Prejudice the Faborable Effect of Appendix I?
The Consolidated Utility Group (CU), the American Industrial Forum (AIF) , and to a lesser extent the General Electric Company showed concern about the possible effect of proposed Appendix I on occupational exposure. The AIF, in commenting on the Draft Environmental Statement,b$d! deplored that statement's lack of consideration of potential increases in occupational radiological exposures with the implementation of proposed Appendix I and suggested that the additional holdup and storage of radioactive materials neces-sary could result in substantial increases in on-site exposures. In its closing position statement,135/ CU concluded that there is a serious danger that the reduction in off-site doses sought through proposed Appendix I will be more than offset by an increase in occupational exposure. In objecting to equipment required as a result of " farfetched assumptions," GE in its closing statement}} / stated that such equipment could, in fact, produce a net increase in the exposure of the human gene pool to radiation by increasing 134/ Final Environmental Statement, WASH-1258, July 1973, Vol. 3,
- p. 98.
135/ Consolidated Utility Group, Statement of Position, Docket RM-50.2, Jan. 19, 1974, p. 17. l l 136/ General Electric, Closing Statement, Docket RM-50-2, ! Jan. 21, 1974, p. 34.
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92 j l the doses to the employees of the light-water-reactor facility. , l These positions of CU and GE seem to be based to a substantial j 137,138/ extent on the testimony of Morton I. Goldman concerning likely increases in occupational exposure due to augments to radwaste systems and of the relative importance of such radiation exposure compared to radiation exposure to the population. In his testimony Dr. Goldman asserted 9! "Thus, I the International Commission for Radiation Protection considers i that the occupational population dose may be about 10 times as i significant as that to the general public..." and seems to base much of 'he thrust of his testimony on his belief that such is the case. Dr. Goldman gave as the basis for his view an excerpt from a publication 140/ of the International Commission for Radiation Protection. The Record 4 ! seems to make clear that Dr. Goldman has misinterpreted the intent of the pertinent paragraphs of the
- 137/ Morton I. Goldman, Additional Testimony on Behalf of the Consolidated Utility Group (Part 1) , Occupational Exposure, Docket RM-50-2, 138/ Tr., pp. 3605-14 and 3999-4048.
139/ Morton I. Goldman, Additional Testimony on Behalf of the Consolidated Utility Group, Parts 1 and 2, Docket RM-50-2. 140/ ICRP Publication 22, paragraph 18. 141/ Tr., pp. 4015-18.
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mA 93 ,. i International' Commission for Radiation Protection document. We believe that, without such a factor to give increased l39/ do weight to occupational exposure, the data presented not support the conclusion that the probable impact of f Appendix I on occupational exposure will outweigh the probable reduction of exposure to;the population. A i In assessing the probable impact of Appendix I on occupational exposure, the Regulatory staff attempted an analysis of data ,
' equivalent co that presented by Dr. Goldman. They found that ,
l 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 by visiting 11 selected operating nuclear power plants, reviewing exposure records, and holding discussions with utility personnel.142/ This study suggested that augmentation of the radwaste-treatment systems to meet the objectives of proposed Appendix I might le expected to increase occupational exposure by about 7%. The observation that'little if any of the increase in exposure . would be unavoidable seems of even more significance. The general conclusion of the Regulatory staff is that " implementation of Appendix I need not significantly increase occupational 142/ Charles A. Willis, A Study of the Occupational Radiation Exposure Due to Radwaste Treatment Systems at Nuclear Power Plants, Docket RM-50-2, Exhibit 23.
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. exposures to levels that are "as low as practicable."
Regulatory Guide 8.8, issued in July 1973, details the occupational-exposure control information that should be provided in license applications. This information is now being reviewed in the licensing process, and applicants are being asked to improve plans, procedures, and designs where- ,. appropriate to reduce exposure. The SAR Standard Format document is being revised to increase emphasis on occuptional-exposure control. Thus, the importance of keeping occupa-tional exposure "as low as practicable" is recognizrd, and progress is being made toward that objective. However, we believe'that implementation of Appendix.I is compatible with the reduction of occupational. exposure, and we are convinced that increases, if any, in the levels of such exposures will be small. 143/ Regulatory staff, Concluding Statement of Position, Docket RM-50-2, Feb. 20, 1974, p. 64. 144/ Consolidated Utility Group, Reply, Mar. 7, 1974. 14T/ General Electric, Reply, Mar. 14, 1974.
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95 IV. GUIDES ON TECHNICAL SPECIFICATIONS FOR 1 LIMITING CONDITIONS FOR OPERATION Section 50.36a(b) of 10 CFR Part 50 provides that licensees shall be guided by certain considerations in establishing , and implementing operating procedures specified in technical specifications which take into account the need for operating flexibility and at the same time ensure that the licensee will exert his best efforts to keep levels of radioactive < materials in effluents as low as practicable. The Appendix I that we adopt provides more specific guidance to licnesees , in this respect. Y A. The Rule Section IV of Appendix I specifies action levels for the licensee. If, for any individual light-water-cooled nuclear , l I power reactor, the quantity of radioacitve material actually 1 il released in effluents to unrestricted areas during any
- calendar quarter is such as to cause radiation exposure, ,
calculated on the same basis as the design-objective exposure, which would exceed one-half the annual design-objective exposure, the licensee shall make an investigation to identify the causes of these high release rates, define and initiate r ! a program of action to correct the situation, and report these actions to the Commission with 30 days of the end I l
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,, 96 ef the calendar quarter. On the basis of reports required by Section 50.36a (2) and Appendix I and any additional information that the Commission may obtain from the licensee and others, the Commission may from time to time require the licensee to take such action as the Commission deems appropriate.
Should Commission action be appropriate, it will be based upon a careful evaluation of the effects of its action on the health and safety of the public and on the public need for power. These provisions will, we believe, ensure the necessary operating flexibility.for light-water-cooled nuclear power reactors and 6 the same time ensure that radiation exposures to individuals in the vicinity of such nuclear reactors will be at the most a small fraction of exposures permitted by present radiation protection standards. The licensee is also required (1) to conduct an appropriate surveillance and monitoring program to provide data an quantities of radioactive materials released in liquid and gaseous effluents to ensure that the provisions of this Appendix I are met, (2) to provide data on measurable levels of radiation and radioactive materials in the environment so that the relationship between quantities of radioactive materials released and radiation dosages to individuals can be evaluated, and (3) to identify changes in the use of 4
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aj unrestricted areas so that monitoring programs for evaluating the doses to individua16 from principal pathways of exposure , J can be modified. It is further provided that,.if the data developed in the sur-veillance and monitoring program described above show the relationship between quantities of radioactive materials released in effluents and the dose to individuals in unrestricted areas is significantly different from that assumed in the calcula-tions used to determine design-objective limits, the Commission can modify the quantities in the technical specifications' defining the limiting conditions for operation in the license that authorizes If operation of the light-water-cooled nuclear power reactor. radioactive-iodine design objectives are determined on the basis of conditions existing at the time the reactor is licensed without regard to future land use, an augmented surveillance and monitor-ing program may be required. B. Discussion of Section IV of Appendix I
- 1. Action Levels and Licensee and Commission Action We expect that the annual releases of radioactive materials in effluents from light-water-cooled nuclear power reactors can L
f L generally be maintained within the levels set forth as numerical i: guides for design objectives. It is certainly expected that the licensee will, under all circumstances, exert his best efforts to keep levels of radioactive materials in effluents from light-water-cooled nuclear power reactors'within the design-objective
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i 4 guides. At the same time the licensee should, in our opinion, be permitted some flexibility of operation, consistent with sound considerations of public health and safety, to ensure that the public is provided with a dependable source of power I l even under unusual conditions of operation that may temporarily ) i lead ~to releases of radioactive materials higher than those specified as the design-objective guides. l i TheRegulatoryf'affhasconsistentlyargued,' t that operating ! flexibility is necessary, especially in view of the very low release levels inherent in the staff's versions of Appendix I. As the Record shows, there is some disagreement as to the need ; for such operating flexibility and a diversity of opinion on the formulation of guidelines in this regard. The Consolidated Utility Group has argued that "the degree of operating flexibility provided in (the originally] proposed Appendix I is too restrictive and may threaten power system reliability." Similar arguments were presented by the Atomic Industrial Forum,4 the Gulf General Atomic Company, the Bechtel Power Corporation, Ebasco Services,I and the American 1 Regulatory staff, Exhibit 1, Tab. 1. Regulatory staff, Concluding Statement of Position, pp. 32 and 68-70. 3 Consolidated Utility-Group, Statement of Position, p. 16. 4 Tr., p. 86; Merril Eisenbud, Statement, p. 6. Final Environmental Statement, p. 61. 6 Final Environmental Statement, pp. 91-92. 7 Tr. pp. 109-116.
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~4 On the other hand, ulectric Power Service Corporation.
National Intervenors, Inc., contended that no provisions for Moreover, operating flexibility were necessary or desirable.9 10 argued that there the State of Minnesota in its final statement has been no showing by the utilities of a need for operating flexibility, that such provisions for operating flexibility should be deleted, and that the numerical guides for design objectives should be treated as naximum limits never to be exceeded. Nevertheless, Minnesota recommended guidelines for limiting conditions for operation. The evidence shows that there will be variations in the performance of fuel elements and radwaste equipment, that these variations may, on a transient basis, result in levels of radioactivity in affluents which exceed the design-objective guide values, and that operational flexibility, within the very low ranges of release rates involved, is necessary if nuclear reactors are to have adequate reliability as a source of power. The arguments l to the contrary are not supported in evidence. Argttnents of I l the several parties that the limiting conditions for operation 1 would be too restrictive were specifically directed to the guide-lines originally proposed. In our judgment the guidelines we have adopted are necessary and reasonable. 0 Letter from Robert S. Hunter to Secretary, U. S. Atomic Energy Commission, Feb. 22, 1972. 9 Anthony Roisman to Algie A. Wells et al., Feb. 15, 1972. l O State of Minnesota, Final Statement of Position, pp. 4-5. l l l l
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" 100 We decided to omit the proposed level for initiating Commission action, since the Commission is already free to act and a numerical guide at this point might suggest that the Commission would be inattentive to releases of smaller magnitude.
- 2. Surveillance and Measurements in Operating Plants Experience with operating light-water-cooled nuclear power reactors and with measuring. effluents from these plants was recognized by the Commission as.one of the substantial bases on which the as low as practicable provisions of 10 CFR Part 50 were proposed and adopted in 1970.11 The quantitative data that can be acquired in the future through programs of measurement end surveillance in the plant as well as in the environment have been noted by several participants as being of special importance in implementing the "as low as practicable" policy and Appendix I.
Quantitative measurement of radioactive materials released in effluents has always been required of persons licenred to operate nuclear power plants. Indeed, the amendments to Part
- 50, published December 3, 1970, require that all such licensees peridoically report to the Commission "the quantity of each of the principal radionuclides released to unrestricted areas in
. liquid and in gaseous effluents... and such other information 11 35 F.R. 5414 and 18387.
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- s may be required .by the Commission to estimate maximum potential annual radiation doses to the public resulting from effluent releases."12 It is clear that information derived from actual observation and measurement of environ-mental factors should be an essential part of the data supplied to the Commission pursuant to paragraph 50.36a(a) (2) cited above.
From the standpoint of ensuring control during reactor operation, measurement of effluents and exposures at the low Edward levels proposed in the Hearing Record are difficult. P. Radford, testifying for the National Intervenors, would l
. prefer higher design-objective doses if that were necessary to'make measurement of human dose practicable.13This preference for measured confirmation of estimates was shared l
by other participants. As discussed in Chapter V of this l document, the incentives for improving calculational models, which.must necessarily be used in establishing design objectives for each reactor, are strong.14 Mtasurements at operating reactors are a means for making improvements.15 We are in l sympathy with those who cite the virtures of designing and 12 10 CFR 50.36a (a) (2) . 13' Edward P. Radford, Testimony on Behalf of National Intervenors: 5 National Intervenors, Exhibit 3, p. 3; Tr., p. 2072; and Tr., p. 2077. 14 General Electric, Closing Statement, p. 5; consolidated Utility Group, Statement of Position, pp. 13-14, item 7. 15 negulatory staff, Concluding Statement, p. 16; Lester Rogers, Testimony for the Regulatory staff, Tr., p. 3409.
S TT**~ 5 M M iff'F:9f9 5 5 # 9 9 E i M Zi ? Z- RZ Z T "E TO C l w 102 bd aparating effluent-control systems with the enlightenment of real experience rather than with arbitrarily conservative calculational models.. Measured levels of environmental radioactivity are generally small in comparison with values calculated'from known or presumed release rates.16 Deviations of measured from calculated doses are not altogether a result of deficient calculational methods. Measurements of environmental exposures and' quantities of radioactive materials in the environs are. complicated by the very low concentrations encountered, compared to background, and by the fact that a multitude of factors, many varing in time and space, affect l the concentration. Thus the correlation of the best of measure-ments with the best of calculations is tedious and difficult.17 We are.not in the position of being able to avoid calculational procedures in implementing the design-objective guidelines of Appendix I or to depend completely on monitoring, measurement, and environmental surveillance to indicate compliance of operating plants. Programs of measurement and surveillance entail cost to the utilities;18 however, we are assured that surveillance and monitoring are feasible for the more sensitive 16 Consolidated Utility Group, Statement of Position, P. 36; General Electric, Reply, pp. 16-18.
'17 See the discussion of the iodine pathway study in the Final
~ Environmental Statement, Regulatory staff, Exhibit 21, Vol. 1, pp. 9-16 to 9-21; Regulatory starf Exhibit 24; and die .ussion i of this study at Tr., pp. 3522-84. i 18 James M. Smith, Testimony for General Electric, Exhibit 7, pp. 12-21, and Regulatory staff, Exhibit 26.
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pathways to radiation exposure.19 Studies to relate emissions and doses should be confined to the radionuclides and pathways to human exposure likely to be of practical value.20 The pathway of greatest concern is the radiciodine course from air to grass to cow to milk to child. The Commission and the Environmental Protection Aiency J made a study of this pathway, including a program of independent measurements in the vicinity of three operating light-water-cooled nuclear power plants.21 This study and further evidence in the Record show the practicability of making useful measurements pertaining to the radiciodine pathway in situations in which radiciodine presents a problem.22 We have required, by Appendix I, special sur-veillance measures for such situations and have adopted an implementation policy that should encourage applicants to use the best data available in any case. 19 General Electric, Closing Statement, p. 41; James M. Smith, Testimony for General < Electric; General Electric, Exhibit 7. 20 National Intervenors, Exhibit 3 (Dr. Radford) , pp. 2-3. 21 Refdrences related to Regulatory staff, Exhibit 24, above. 22 See for example Regulatory staff, Exhibit 26.
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.o 104 V. IMPLEMENTATION i Two aspects in the implementation of Appendix I were con-sidered in the Hearing. The manner in which the new rule is applied to existing reactors and to other reactors in vari-ous stages of licensing is one problem. This matter, including the question of backfitting, is covered below under the heading " Applicability." The other sense in which imple-mentation was considered concerns the guidance given by the Commission to the Regulatory staff and to applicants in applying the numerical guidelines to the design objectives of a specific _aactor. This is discussed below under the heading " Numerical Guidelines." Appendix I incorporates i
these two matters in Section V, Effective Dates, and Section III, Implementation, respectively. A. Applicability
- 1. The Rule The guides for design objectives and limiting conditions for
- operation set forth in Appendix I shall be applicable in any case in which an application was filed on or after January 2, 1971, for a permit to' construct a light-water-cooled nuclear power reactor.
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=For=each light-water-cooled nuclear power reactor con-structed pursuant to a permit for which application was
' filed prior to January 2, 1971:
(a) The holder of the permit or a license authorizing
- ]
j operation of the reactor.shall, within a period cf I ' twelve months from-(the effective date of this Appen- , 1 dix), file with the Commission: (1) such information as is necessary to evaluate the means employed for keeping levels of radioactivity in effluents to unrestricted areas as low as practicable,-including all such information as is ,
' required by Section 50.34a not already contained in his application; and (2) plans and proposed technical specifications de-veloped for: the purpose of keeping releases of radioactive materials to unrestricted areas during normal reactor operations, including expected operational occurrences, as low as practicable.
(b) The technical specifications included in any license authorizing operation of the reactor shall, within a _ period of thirty-six months from (the effective date of this Appendix), or by ;the date of issuance of such
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106 license, whichever is'later, conform to the require- ) ments of Section 50.36a;-provided that the Commission i l
-may: extend the period as may be deemed'necessary to allow for evaluation by'the Commission.
1
- 2. Discussion of Applicability 1
The "as low as practicable" amendments to 10 CFR Part 50 published on December _3, 1970,M institute 6 new requirements ! for! ) . (a) information contained in applications for permits to construct nuclear power reactors; (b) information contained in applications for licenses to operate cuch reactors; and (c) particular technical specifications to be-included in i- ~ each operating license with respect to operating pro-I
'cedures and reports to the Commission.
These amendments contained no guidance concerning the manner in which~the additional information in applications would be considered nor criteria for acceptance of a proposal. Con-siderations by which licensees would be guided in establish-
'ing and implementing operating procedures to be included in
' technical specifications were included in the amendments.
M 35 F.R. 18387. J
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,,a 107 The requirement i that applications for construction permits identify design objectives and the means to be emploicd for keeping fevels of radioactive material in effluents to un-restricted areas "as low as practicable" applies, according to'those amendments, to cases in which applications are filed on or after January 2, 1971. Other provisions of the amendments became effective on January 2, 1971.
Appendix I now adopted.contains two types of guidance per-taining to the amendments cited above. The first is con-cerned with determination of " design objectives" and."means to be employe_?.that would'be acceptable to the Commission.M The other is concerned with " limiting conditions for opela-tion" to be included in technical specifications. b The manner and timing for applying the additional guidelines of Appendix I to various cases are matters that stimulated considerable debate in the Hearing. The essence of the Regulatory staff's position is:M
...that the limiting conditions for operation de-scribed in Section IV of Appendix I be applicable E 10 CFR 50.34a (a) .
Y 10 CFR 50.36 (c) (2) and 50.36a. M Regulatory Staff, Concluding Statement, pp. 73-74. i L, ! ! l w v w' '- - " =--
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r, M 108 upon publication to technical specifications included in any license authorizing operation of a light-water-
.c cooled nuclear power reactor constructed pursuant to a construction permit for which application was filed on or after January 2, 1971. For all other operating licenses, technical specifications in conformity with the guides in Section IV should be developed within 24 months from the effective date of Appendix I and included in any license authorizing operation of a light-water-cooled nuclear power reactor. The amendments to Part 50, Sections 50.34a and 50.36a requiring that levels of radioactivity in effluents from light-water-cooled nuclear power reactore Ibe kept as low as I-acticable] have been in effect for more than three years and substantial progress has been made by licensees in augmenting radwaste systems. It is the staff's view that 24 months is a reasonable period of time to complete modifications that may be required to meet the Appendix I limiting conditions of operation to be included in technical specifications of operating licenses."
General Electric, in its reply to this staff proposal, commented only on the merits of backfitting, that is augmenting of plants already constructed or in operation with additional control equipment.S/ Tney argued that the facts require that the numerical guides of Appe'ndix I, if they are to be consistent A/ General Electric, Reply pp. 34-35. l l l
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with the basic standard, must make special allowance for i currently operating plants.and that guides and limits that are "as low.as practicable" for plants that still exist only on
' paper must-necessarily be lower than " practicable" for plants
~
.that can install augmented effluent-treatment systems only on ,
a more costly.backfit basis. The Consolidated Utility-Group { also favored a case-by-case consideration of backfitting.E/ i Although the backfitting issue arose over the part of ' -proposed Appendix I that dealt only with " limiting conditions ,f for operation," it is clear that the implication of this part 4 of Appendix I would have been that persons holding licenses ; i for light-water-cooled nuclear power plants now in operation 1 would have been required to comply with the design-objective provisions as well, even if such compliance involved back- ; fitting.5/ We note that the Record shows that some such. , licensees had already undertaken steps, including backfitting, . t to comply'with' proposed Appendix I, even though it was not an j I effective part of the Commission's regulations.2/ The Regulatory staff agreed, however, that backfitting should be considered on , I "a case-by-case basis.18/ b[ Consolidated. Utilities, Reply, p. 25. b/ Lester Rogers,-Testimony for the Regulatory staff, Tr.,.pp. 340-341. , 1/ Tr., P. 4147. . la/ ester: L Rogers, Testimony, Tr., pp. 3591-92.
.- 4 ~, . _ . . , __
_ _ . _ . _ _ - ~ . . . - - . l If . 110 The Record clearly shows that ths costs of augmsnting an existing plant would generally be substantially greater than the cost of installing similar control equipment in a plant that is still being designed.8'9 / Furthermore, the information on the quantities of radioactive material in effluents of these plants indicates no need for any precipitous action that would be applicable to all existing plants alike. b Tnese two factors led us to conclude that the licensos for existing plants should be considered case-by-case. As noted elsewhere in this document, the design-objective guidelines of Appendix I do not preclude an applicant from prosecuting his case on the fundamental definition Under of the term "as low as practicable" in Section 50.34a (a) . the terms of Appendix I as presently adopted, a person holding a license to op rate an existing plant has, inherently, no less it is unnecessary and would right to follow such a course. Hence, be redundant to include any statement for this special case Likewise, specifically permitting a case-by-case evaluation. we consider it superfluous to state, in the detail suggested by General Electric, the methods that would be permissible as bases for establishing design objectives. We agree that it would be preferable to base evaluations of design objectives on actual operating experience with the reactor in question in cases where substantial relevant information has been accumulated during plant operations. 8,/ Final Environmental Statement, Vol. 1, pp. 3-4 and 3-5. b Regulatory staff, Exhibit 25, pp. 4 and 10. E! egulatory R ataff, Exhibit,27. S ! General Electric, Closing Statement, pp. 54-56.
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.he scheduling of compliance with Section 50.36a in the light of the new guidance of Appendix I is a further matter 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 applicable, as soon as effective, to all cases for j
which an application for a construction permit was filed on or after January 2, 1971. For all other cases, the Regulatory staff originally proposed a 36-month period for compliance and finally proposed a 24-month period.12,13/ General Electric proposed that 36 months be allowed for compliance;1S/ while the Consolidated
. Utility Group would set no deadline except for a 12-month period within which wolders of permits or licensees would have to file plans with the Commission.15!
In view of the facts already asserted that there is no hazard presently and generally being imposed by plants that were not licensed in accordance with the specific guidelines of Appendix I, we have concluded that it is reasonable to allow 12 months for development and submission of plans for Commission approval and 36 months for complete conformity of operating reactors, with allowance for any unusual delay for Commission review. In arriving at these time allowances, we have little factual evidence from any party as to the time actually needed. The information-in the Regulatory staff's concluding statement on 12/ 36 FR 11113. 12! R egulatory staff, Concluding Statement, p. 35. bd/ General Electric, Closing Statement, pp. 54-57. 15/ C onsolidated Utility Group, Statement of Position, pp. A7-A8.
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i, the actions of licensees to comply with "the staff's interim 7.icensing design objectives and guidelines" would have been of little value for this purpose, even if it had been undisputed or a part of the evidentiary record.15/ We believe, however, that with official notice being taken of the times actually elapsed from dates of application to dates of issuance of permits and licenses the period allowed for compliance is adequate. B. Implementation of Numerical Guidelines
- 1. The Rule We have decided that Appendix I should explicitly include Commission guidance to the Regulatory staff and to other interested persons with respect to the use of conservative or realistic calculational procedures in the application of the Accordingly, Section numerical guides for design objectives.
III of Appendix I states that compliance with the guides on procedures design objectives shall be demonstrated by calculational based on models and data such that the actual exposure of an individual through appropriate pathways is unlikely to be sub-stantially underestimated, all uncertainties being considered together. Account shall be taken of the cumulative effect of all sources and pathways within the plant contributing to the particular type of effluent being considered. For determination of design objectives in accordance with the guides of Section II of Appendix I, the estimation of exposure shall be made with bb/ Regulatory staff, Concluding Statement, p. 73 and Annex.
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resp ct to such potential land and water use and food pathways as could actually exist during the term of plant operation, pro-vided that, if special surveillance measures are carried out, the requirements of paragraph C of Section II with respect to radioactive iodine may be made on the basis of such food path-ways and individual receptors as actually exist at the time the plant is licensed. The characteristics attributed to a hypothetical receptor for the purpose of estimating internal dose commitment shall take into account reasonable deviations of individual habits from the average. The applicant may take account of any real phenomena or factors actually affecting the estimate of radiation exposure, including the characteristics of the plant, modes of discharge of radioactive materials, physical processes tending to attenuate the quantity of radio-active material to which an individual would be exposed, and the effects of' averaging exposures over times during which , determining factors may fluctuate. If the applicant determines design objectives with .espect to radioactive iodine on the basis of existing conditions and if potential changes in land and water use and food pathways ' 'could result in exposures in excess of the guideline values of paragraph C of Section II, the applicant shall provide reasonable assurance that a monitoring and surveillance program i will be performed to determine: f' l 1 l l
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u . , 114 m (a) the quantities of radioactive iodine actually released to the atmosphere and deposited relative to those estimated in the determination of design objectives; (b) whether changes.in land and water use and food pathways which would result in individual exposures greater than originally estimated have occurred; and (c) the' content of radioactive iodine in foods involved in the changes, if and when they occur.
- 2. Discussion The numerical guidelines of Appendix I, when applied in accordance with the conditions specified therein, are a quantitative expression of the meaning of the requirements that radioactive material in effleunts released to unrestricted areas fror., light-water-cooled nuclear power reactors be kept as low as practicable.
These guidelines, particularly with respect to design objectives, are expressed as specific numerical limits for three types of effluents. The numerical aspects of this translation of the basic rule of Section 50.34a, standing alone, 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 necessarily be so in another. The numerical guidelines were chosen on the be. sis that the Record shows these limits to be practicably achievable for almost all cases to which we consider them applicable. Furthermore, in view of the elements of conservatism and realism inherent in the evaluations presented 1
a r . 115 , .
'n ths.Hocring, wa believe the Record supports the conclusion that the maximum in'dividual exposure likely to ensue from operation of a single nuclear power reactor in conformance with Appendix I is sufficiently small that no additional expense could be justified for reducing the exposure of an individual further than required by Appendix I.
It must be understood in discussing the matters of calculational l conservatism and realism that Appendix I means, implicitly, that any facility that conforms to the numerical and other conditions thereof is acceptable without further question with respect to Section 50.34a. It is just as essential that Appendix I be understood as not implying, conversely, that any facility not conforming is Tecessarily unacceptable. Thus'the numerical guide-
]
lines are, in this sense, a conservative set of requirements and are indeed based upon conservative evaluations. The numerical guideline values were adopted in the light of numerous evaluations of typical nuclear plants at various types of sites. These evaluations, preseated by various parties, were based on calculations of radiation doses which generally could be understood as estimates of the level of exposure of individuals in the general public from hypothetical releases of radioactive material. Similar estimates will have to be made on a case-by-case basis by applicants for licenses for light-water-cooled nuclear power reactors in order to establish m_._ .m. _ _ _ _ _ _ . _ _ _ . _ - . . _ _ _ _ _ _ _ _ _ _ _ - _ _ . _ _ _ _ _ _ _ _ _
116 appr,opriate design objectives.. Thus the use of calculational procedures based at leas't partially upon hypotheses is unavoidable. of It is evident from the Record that numerical estimat09 I radiation exposure may vary widely, depending upon the particular , assumptions made. These assumptions involve the selection of m appropriate mathematical expressions of natural pheno.ena, in-l cluding the assignment of numerical values to the parameters contained in the expressions. Inasmuch as results of calculations can vary widely, an issue has been raised by some participants as to how the numerical guidelines can be implemented in consonance j with the process of their adoption. The necessity and importance of adequate attention to numerical calculational procedures was aptly expressed by Walter H. Jordan, a member of the ASLB 1
"[t]he interpretation of Appendix I is almost going to be as important a factor in which is practicable as the_ regulation itself."
Some parties severely criticized the conservatism of the Regulatory staff and proposed that Appendix I include guidance on implementation in order to ensure that applicants have the opportunity to use reasonably realistic assumptions in their 18-20/ The procedures for estimating radiation exposure. 11[ TR., pp. 2587-48. bS/ General Electric, Closing Statement, pp. 26-45. Reply, p. 10. ES/ C onsolidated Utility Group, Statement of Position, pp. 13-14, 71, and A-4. S[ Andrew P. Hull, Final Statement of Position, p. 4. I a
- ' ' 117 l
f necessity of explicit guidance is suggested on the argument that the procedures used by the Regulatory staff for calculating l doses show a predisposition to.make unnecessarily conservative assumptions. The draft Regulatory Guides circulated by the Directorate of Regulatory Standards with the staff's concluding
- statement reflects a tendency toward the use of overly ,
conservative calculational assumptions. The calculational ' o methods described in the Final Environmental Statement and in draft Regulatory Guides are opposed in some particulars;SS! furthermore it was also argued that the staff has, in the course of reactor licensing actions, generally been quite conservative in its quantitative assessment of effluent controls. , Particular areas of controversy shifted as the Hearing pro-l gressed'.SS/ It was not clear to participants whether or not , models and assumptions used in the Final Environmental Statement f were also intended by the Regulatory staff to be applicable to i the analysis of individual applicantions for licenses in the implementation of Appendix 1. Examples of overly conservative implementation methods, as they have been used in current t licensing include: excessive source-term assumptions with regard to radiciodine emissions; neglect, with regard to such S1/ Closing Statement of General Electric and Statement of Position by Consolidated Utility Group referenced above; see also Testimony in General Electric, Exhibits 6 and 7 and the Oral Argument, Tr., pp. 110-127. SS/ C onsolidated Utility Group, Statement of Position, p. 44.
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6 118 amissions, of their chemical form, actual release points and modes, and expected plume behavior; overestimation of deposition f l rates.and retention factors for radioiodine on. forages; and f I l postulation of nonexistent dairy cows and unrealistic milk- i i I consumption patterms. E Following the filing of the Regulatory' staff's concluding i
-statement, General Electric noted important improvements in the staff's proposed Appendix I, including some dealing with f
L calculational models; but GE noted that the staff's proposed l Appendix I still failed to specify whether the calculational assumptions and models to be used in implementation are to be established on a " conservative" basis or, as GE urged, on the i basis of best-estimates of the relevant ph'sical y phenomena. E
.The staff argued neither for nor against including guidance on calculational assumptions in Appendix I, although in testimony the staff's principal witness conceded that particularly critical points had been raised in the Hearing with respect to implementation and that at the time of issuance of Appendix I some specific understanding should be attained. E W General Electric, Closing Statement, p. 5.
E eneral G Electric,' Reply, pp. 2-3. E -Lester Rogers, Testimony, Tr., p. 3412. u t
~. 119 , ;
1 We believe the evidence at hand supports the decision that Appendix I should include Commission guidance'respecting the i use of conservative or realistic calculational procedures in the application of the numerical guides for design objectives. We summarize below the matters involved in reaching this con-clusion and in applying the guidelines in accordance with Commission intent. Calculational procedures used in the application of Appendix I for making the numerical estimates of radiation doses have been variously called by such terms as " calculational assumptions and models," "models and input data," " assumptions and models," or simply "models." Such procedures require the skillful use of mathematical expressions characterizing natural phenomena. It is evident that such expressions are generally expected to y3 91J quantitative results that are, at best, approximations to re'ality. Simpler models, for example, ones that would not embody any facility for taking into account differe.ces in s
, plant design, would not be expected to produce estimates as close to reality for a wide variety of designs as would more complex models.
Calculational procedures used for dose estimations in essence describe, albeit approximately: (a) sources of radioactive materials and the pathways inside a plant by which such materials are released;
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L (b) the natural processes by which released material is ; I i i transported through the environs; and (c) the model receptor, i.e., a'real or hypothetical in-dividual ultimately exposed to. radiation. l The selection of specific moC.els for each of these three l l portions of the procedure involves two types of determinations. l First, one must select models and data that represent the ! situation deemed to be important. For example, the choice of a hypothetical receptor rather than an' existing individual i might reflect, in part, the intent to use the guidelines as a mechanism to provide for future changes in occupancy of areas l near the site. The Regulatory staff properly identifies this l j as a-means of expressing. Regulatory intent. b Second, models and data must be found which represent the physical phenomena involved with some useful precision. Conflicting views have been advanced, in evidence and in argument, on all portions i of the calculational procedures and for both types of selections.27-31/ E Regulatory staff, Closing Statement, p. 52. b General Electric, Closing Statement, pp. 26-45. b Ned R. Horton, Testimony, General Electric, Exhibit 6. b James M. Smith, Testimony, General Electric, Exhibit 7. M oral Argument, Tr., pp. 110-127. N C onsolidated Utility Group, Statement of Position, pp. 13-14 and=71. L
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4 121 4 It was observed by both General Electric and the Consolidated Utility Group that considerable progress toward agreement on models was made in.the course of the Hearing, althou3 h the intent of the Regulatory staff in future implementation of the numerical guidelines on a case-by-case' basis remained in fdoubt after the staff's concluding statement was filed.$$[ We believe we have developed a suitable resolution of the
. differences for all practical purposes, although we : realize that some other set of guidelines might have served our purpose Our resolution strongly and please one part or the other more.
favors the suggestions that calculational methods be tealistic, which in turr has influenced our adoption of particular This resolution, numerical' guideline values for dose objectives. thus, has been a strong factor in our reconciliation of the differences among parties as to those values; for, as one party. stated $$/ "The evidence is clear that, realistically applied, the dose objectives now presented in (the staff's proposed] Revised Appendix I can be met without reliance on exceptions or special provisions...." The essence of our conclusions on how calculational procedures 1 should be used in determining design objectives is given in the five following points.
$2/ General Electric, Reply, p. 2.
dd/: General Electric, Reply, p. 24. 4 i
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122 i 2 (1) An apptioant should be free to use as realistic a modet for characterising natumt phenomena, including plant perfomance, as he considers useful. An appVwat may take into account
'd by a standani modet situations not adequately chav~ r-with respect to specific features of plant design. proposed modes of plant ope n tion, or tooat natu m t environmentat features whfah'are not likely to change significantly during the tem of plant opention.
34/ General Electric noted several effects that should be recognized,- I and we restate some of them here to illustrate natural phenomena that might ba partially or entirely neglected in standard models but could be ,;operly considered: (a) radioisotopic composition of offluents; (b) radioactive decay of released nuclides prior to exposure of the' receptor; (c) waterway flow and the associated diffusion and dilution; (d) removal of radioactive material from solution or suspensa.2 in the water by sedimentation or other naturally occurring mechanisms or by water-treatment processes; (a) exposure modes and occupancy or use factors; I I b General' Electric, Concluding Statement, pp. 28-32. 4 i
7._ ' 123
- e.m (f) release conditions (to the atmosphere) including elevation of release point, effluent stream buoyancy and momentum, and building geometry; (g) local ~ meteorological and aerodynamic conditions influencing airborne effluent' plume dispersion; Ch) beta and gamma radiation energies for the radio-isotopes released and the associated dose effects; (i)- chemical form and physical behavior.of the. effluent constituents; (j) plume elevation, size, and depletion; (k) shielding effects; (1) partitioning, filtration, and other retention and
' depletion effects; deposition rates and velocities for the various I
(m) L chemical forms of released radioiodine on offsite vegetation, ground, and other surfaces, with ,
. s;
,- appropriate apportionment to the vegetation of
( J,f. '? - its capture fraction; and weathering and other loss factors for radioiodine
<:[ki-t (n) on grass and other vegetation.
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- ',Cisarly other-natural phenomena must also be adequately taken into' account in models used for determining design objectives, ut these are sufficiently established in practice that they goednotbe,repeatedhere.
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1 < 124 ,a l A'.though both General Electric and the Consolidated Utility Group asserted that the Regulatory staff's intentions are un-certain, we believe the staff is agreeable to neepting realistic In their concluding models different from standard models. b
]
statement the staff quoted from the offic!.al Commission statoment published with each Regulatory Guide: b
" Regulatory Guides are not substi.tutes for regulations Methods and and compliance with them is not required.
solutions different'from thcae set out in the guides will 1 be acceptable if they provide a bcsis for the findings requisite to the issuance or continuance of a permit or license ' v the Commission." The models last proposed by the Regulatory staff b are different from the highly criticized versions used in the b evaluations presented in the Final Environmental Statement. Testimony of the staff indicates that the models used by the staff and described in Regulatory Guides will contin *2e to change. b We believe Regulatory Guides to be useful; however,
~ Regulatory Guide models should not be applied as a norm to be l
b Lester Rogers, Testimony, Tr., p. 3411; Peter O. Strom, Tr., P. 3447. N Regulatory staff, Concluding Statement, p. 83. b Attachment to Concluding Statement of Position of the Regulatory staff. b Regulatory staff, Exhibit 21. b Lester Rogers, Tr., p. 3409. l-I
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~4 125 .
i ebandoned at the peril of the applicant. We believe the testimony of staff witnesses in this Hearing might, by some reasonable persons, indeed be construed as indicating that
' the staff has been excessively zealous in applying Regulatory Guide models. We particularly expect all parties to licensing ,
actions to which Appendix I applies to note both the potential utility of Regulatory Guides and their subordinate status t relative to Commission regulations and opinions. (2) Where selection of data is strictly a matter of interpreting experimental evidence, both the applicant and the Regulatory staff should use prudent scientific expertise to select those values which would be expected to yield estimatee nearest the reat cae. The matter of how to deal with uncertainties in choosing data
~
has been an implicit part of the evaluations made by participants in the Hearing. The data used by the staff in
-the evaluations presented in the Final Environmental Statement were considered by General Electric and the Consolir.ated Utility Group to be seriously conservative.40-43/ The staff has conceded that conservatisms existed and were being re-evaluated continually. b It is our judgment in consideration N General Electric, Closing Statement, pp. 5 and 29-43.
b Ned R. Hortan, Testimony, General Electric, Exhibit 6. b C onsolidated Utility Group, Statement of Position, L- pp. 13-14 and 42-50. N Walton A. Rodger, Testimony, Tr., 3909. N Lester Rogers, Testimony, Tr., pp. 3409, 3439-40, and 3460; Earl H. Markee, Tr., pp. 3432-33; and John T. Collins, Tr., pp. 3449-52. l i I
1, - 126 4 , l 1 of the detailed discussions of the models and data in testimony, in closing statements, and in oral argument that specific models and data should not be standardized by incorporation in Appendix I, as proposed by the State of M'innesota. b Neither do we intend to judge in this decision which of the many controversial parameter values would be I particularly appropriate for use in implementing the design- i objective guidelines. We believe that the opportunity to modify models and data as new experimental information comes to light could have substantial advantages over a rigid rule, which is a persuasive argument for permitting this matter to 1 be dealt with by the preparation of Regulatory Guides and by case-by-case evaluations. If approximations imptioit in a modet can produce a deviativn
) (3) from the true reeutt the direction of which is either uncerta or would tend to underestimate dosage or if available experi-
\
mental information leaves a substantial range of uncertainty 1 as to the best estimate of some parameter values, os both,
)
l data should be chosen so as to make it unlikely,sdth att
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such deviations and uncertainties taken into aooount together, that the true dose vould be underestimated substantially.
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Two potential sources of deviation from a realistic done ( (stimate are of concern here, one is the use, at an l pplicant's preference, of a simplified model, which necessitates, su seate of xinnesota, conc 1oding seatemene, g. 11. I
/
127 in all propriety, the use of some conser*.<atism in setting design l
.obj ectives. 'The other is the existence, in spite of the best
, M. c.m efforts of all parties, of experimental uncertainties in para- . vQ meter values.
. Mathematical models describing the-various sequences of natural 3
- s. <
> iq. f- phenomena which relate releases of radioactive materici'to i radiation dose vary in detail and complexity. This.was frequently observed in the Hearing. Through circumstances peculiar to his
~1 case, one applicant may be able'to present to the Regulatory j
' staff adequate support for his proposal through the use of simple models and conservative parameter values, while another applicant can ot prove his case so easily. There is no ;
regulatory necessity for performing the most realistic dose estimates that are technologically achievable if a less complex and less expensive analysis can be made to demonstrate compliance with licensing requirements. The une of the simpler procedur<>
; may, however, introduce a widet range of uncertainty in
~~ estimated doses than a more complicated an.tlysia. I.,ance t.he for a tiimple calculatiosa proper choice or parameter values m i g h t. tio . n.o r e ' < unnes va t i ve than valio a appsupsinte los a mu s e i
- l. precian caleulaiion.
.t i i n q witla unro s I a 11. if at a 4.a n 4 t i u.:n o ne .1 at The mit t.o r o r .ti
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128 reluctance of participants to express in concise-language a l general definition of the degree of conservatism or realism considered. appropriate or a precise definition of "best l estimate." We also are reluctant to. propound a precise I
-general rule on this point because the circumstances of The record
-applicant vary too~widely to permit us to do so.
shows that the quality and quantity of experimental data are 3 far from uniform from case to case, site to site, and phenomenon to phenomenon. The models' described in the Hearing Record and the evidence and arguments advanced with regard to numerical estimation l a of dose lead us to the conclusion that one should try to attain L realistic estimates; but, where uncertainties exist, one should choose calculational procedures that are unlikely to produce We believe, furthermore, that it substantial. underestimates. is in the best interest of the public to make realistic estimates, even with uncertain data, and to depend upon the programs for improving models and data, particularly programs of in-plant-measurements, to determine whether proper case-by-case design decisions were made.$2/ Surveillance and quantitative monitoring of effluents are already required by existing regulations;-additional guidelines for collection of data for each operating plant necessary for this purpose are included in Appendix I.
$2/ Regulatory staff, Concluding-Statement, pp. 60-61.
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.,4j 129 s (4) % modate used in describing effluent releases should take into account att reat sources and pathways within the plant; and the estimated releases should be characteristic of the
'espected average releases over a long period of time, with account taken of normat operation and anticipated operationat occurrences over'the tifetime of the plant.
The record is free from significant controversy as to the general model of an operating plant which should be assumed for the-purpose of determining design objectives. The schedule of operation assumed by an applicant, if it turns out to be unrealistic, may later impose some inconvenience or expense on ..im 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'it would not diminish the protection of the
- public from the effects of radioactive discharges.
(5) % modet of the exposed individual and the'aeeumed characteristice of the environs with respect to human
\
occupancy and to land and uater use should be detemined in each case in accordance with the intent indicated betou for each particular category of effluent for which design-objectivc guidelines are given. (a) For design objectives affected by assumptione as to consumption of water or food (other than mith) produced in the environe, one should consider the modet individual
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'wi to be that hypothetical individuat who would be maximatty esposed with account taken only of such potential occupancies and usages as could actually be reatised during the term of plant opemtion.
(b) For design objectives affected by exposure as a direct I result of human occupancy (innerefon exposure), the modet indivl. dual should be the hypothetical individual maximatty exposed with account taken only of such potentiat occupancies, including the fraction of time an individual would be exposed, i l as could actually be reatised during the term of plant ope m tion.
)
We are persuaded by the evidence that, at most sites with realistic modeling of the natural phenomena affecting these exposure pathways, design objectives based on reasonable occupancy times and intake values could conform to guideline values at reasonable cost of control, even for a hypothetical receptor. b The Consolidated Utility Group presented substantial evidence, as an extension of Regulatory staff evaluations presented in the Final Environmental Statement, to establish a level of effort they consider to be " justified on a cost-benefit basis." They conclude that in-plant controls for liquid effluents i N General Electric, Reply, p. 24. i
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augmented as justified on a cost-benefit basis in terms of population dose reduction would meet the individual whole-body dose objective of 5 millirems.AE/ We note that the Consolidated Utility Group presented further conclusions, 4 after the evidentiary hearing concluded, that certain lake-shore and seacoast situations would require unjustifiably costly augments to conform to the guidelines for liquid effluents if "the staff's conservative dose models" were used.5S/ While we are not adopting their opinion as our own, this conclusion and the further conclusions of the Consolidated Utility Group in this same place 51/ with respect to justification of noble-gas effluent controls, when considered with the numerical gui_31ines of Appendix I now issued, point to a fortunate capacity to control effluents from the light-wcter-cooled reactors in most expected circumstances on the basis of a hypothetical individual. We considered and discarded the possibility of specifying that 4 all design objectives be determinec solely on the basis of actual human occupancy at the time of plant design, as was proposed by the Consolidated Utility Group.5 ! To adopt guide-lines that would generally leave all consideration of future use of the environs to post-licensing regulation would be unwise ISI Regulatory staff, Statement of Position, p. 33. 55/ Consolidated Utility Group, Reply, pp. 15-17. , bb/ Consolidated Utility Group, Statement of Position, items 2 and 3, pp. 33-34. b ! C onsolidated Utility _ Group, Statement of Position, items 2 and 3, p. A-4.
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in the instances where it has been c learly shown that an accommodation of reasonable potential future uses can be accomplished at reasonable cost. This is the case for all f effluents except radioactive iodines and particulates released to the atmosphere. We believe the Record shows it would be better in these instances to determine the design objectives i with respect to potential future uses. This takes not only the economic balance into account but also the less tangible but equally important values of environmental quality and protection of the individual. We have taken into account the fact that the analyses that have led to such a general conclusion were based on conservative hypotheses. We are mindful, as already mentioned, that numerical guidelines cannot coincide exactly with the effects of measures that are "as low as practicable" in every case. Therefore, the Appendix I guidelines should not and do not prohibit an applicant who may have difficulty complying with the '
. guidelines with respect to these exposure pathways from pro-We anticipate ceeding on the basis of Section 50.34a alone.
that some special circumstances may arise which would make it advantageous to the applicant to base his case on a cost-benefit L analysis. Such circumstances may involve: currently operating l reactors for which-the cost-benefit status of equipment l augments is highly site-dependent and differs substantially l-4- i from that for plants in the design stage; multireactor sites 1 4 1 I t
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. ,4 133 a to which certain environmental and economic considerations
- not fully explored in the Hearing may apply; or unique or highly unusual sites or reactor installations.E3/ We believe this option will provide adequate relief in such cases, for licensees generally do not object to a requirement that all in-plant control measures which can be justified by a cost-benefit analysis for a particular site be included.E$/ ,
There 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 natural phenomenology and, therefore, should be dealt with in accordance with points 1 to 3 above. For example, dilution of effluents in receiving waters, fish habits, and normal human intakes of food and water should be considered on the basis of scientifically evaluated experimental evidence. We do believe, however, that the particular habits of the l hypothetical receptor should'take into account a reasonable l l and real departure of the habits of some people from the j-average. We would not think it reasonable, on the other hand, to assume such bizarre characteristics as those of a hypothetical - 5d/ General Electric, Reply, pp. 23-24. EA/ Consolidated Utility Group, Reply, p. 10.
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gardener who receives all his fresh vegetables from a 1 I hypothetical fence-post garden and consumes them immediately upon harvesting without washing or other processing, as was ; assumed for some of the evaluations of the Final Environmental Statement. N l Such extreme assumptions have served their purpose in simplifying the evaluations involved in reaching a decision ) on Appendix I but would not be appropriate in case-by-case implementation of the guidelines. With realistic calculational l models, food chains, and occupancy taken into account, we believe the Record shu.rs that one should and can account for persons who are not average, even in a local sense. (c) For design objectives relative to thyroid dose as affected by conswnption of milk, the iodine pathway through the environs of a plant and the characteristics of the modet receptor should be essentiat!y as they actuatty 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 consumption of milk would be the most difficult one to accommodate in the context of originally proposed At I numerical guidelines for establishing design objectives. this time it is still an exceptional case. The estimated b Tr., pp. 3402-03 and 3429-30.
s 7 -uy T * ,~a o 135 i t economic costs of instituting in-plant controls of iodine emissions are high enough to change the overall balance of the decision in favor of requiring that only actually existing Of course, this food pathways need to be-taken into account. does not deny to any applicant who considers it practicable the privilege of assuming more conservative hypothetical pathways and thus avoiding the task of keeping up in detail with future changes in the environs. Many elements of conservative estimates of radiation exposure discussed in points 1 to 4 above were of serious concern to the parties c.ly with respect to the iodine-milk-thyroid pathway. The implementation guidance respecting attainmcnt of more realistic estimates will permit many plants to conform to the thyroid-dosage guidelines irrespective of whether a real or hypothetical environmental pathway is the basis of design objectives. Nevertheless, on the basis of present knowledge of the entire pathway from in-plant source to receptor, there would bs many plants that could not meet the numerical guide-line on the basis of a hypothetical food pathway to an individual without in-plant controls the cost of which out-weighs the incremental benefit to the population at large. In adopting this guideline for radioactive iodines and particulates discharged into the atmosphere, we~have considered the following special questions:
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i 136 .
. l Is every individual adequately protected from excessive exposure? Is individual freedom of access and use of !
Is the likely cost of j unrestricted areas assured? j l implementation in this way less than that of providing additional in-plant controls at the outset? Is the i possible curtailment of future productivity of the i environs justifiable? The Record supports an affirmative answer to each of these j ! questions. Individual protection of real persons is no less l than that provided for other effluents.- Special requirements l for surveillance are included to detect, before significant ! If i exposure can occur, any important changes in land use. such changes were to occur, the licensee, not the member of the public, would be obligated to take appropriate action, namely, to control emissions or other elements of the exposure pathway in such a way as to maintain individual expcsures in conformance with design-objective guidelines. Thus an individual would be free of any infringement upon his rights E to use the environs. The practicability of deferring some controls until real necessity is imminent is evident from the evaluations of the Regulatory staff, General Electric, and the Consolidated Utility i I l l l c-7 v - ' n - v- -+-s e}}