ML20202F160
| ML20202F160 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1977 |
| From: | Cunningham R, Hard J, Mason E NRC COMMISSION (OCM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20202F147 | List: |
| References | |
| IAEA-CN-36-484(, IAEA-CN-36-484(IIIA), NUDOCS 9902030339 | |
| Download: ML20202F160 (14) | |
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REGULATORY REQUIREi4Ei;TS FOR RADIAT10M PROTECTION E. A. MASOM, R. E. CUMt;It:GHAM, J. E. HARD, R. J. MATTSON R. U. SN itt, ano n. 7. PET ERSON, JR.
U.S. Iluclear Regulatory Cor. mission Us'.k p r, D. C.
20555 United States of America
. ABSTRACT diation have evolved and
' Regulatory requirements for protecting man from raDue to the wide adoption of reccmen natured over several decades.
the International Commi,ssion on Raciacion Prou mt: (M, there is inter-This national consistency in tne principles followed for radiation protection.
foundation will be increasingly important due to the growing need for inter-national agreements and stendards for radiation protection and radioactive materials management 25 the nuclear industry develops.
During the early years of the commercial nuclear industry, primary reliance was placed on the protection of the individual, both in the work farce and as Uith the grcuth of nuclear power in the 1960's and a member of the public.
1970's, environmental impct assessments and expert reviews of bio-effects data have focused a~ttention on stati.stical risks to large population groups and the use of the collective dose commitment concept to estimate potential ef fects.#
The potential release of long-lived radionuclides from the nuclear fuel cycle requires further consideration of radionuclide accumulation in the biosphere and calls for controls conceived and implemented at the international 1cvel.
l d have
.The initial development efforts for addressing these concerns a rea yHowever, f
. been instituted by the ERP and the IAEA.
ment and a unified set of international standards may be required the recommendations of these groups.
of radiation protection are also called for in developing uaste managemen for fuel tices and radioactive effluent control technology, port of high-level wastes in various forms.
hips and will be involved, it will be useful to reexamine dose-ef fect relationsImprov to develop explicit societal goals for health protection.
d DENC PDR a..
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.I AEA-CN-35/484 (IIIA)
REGULATO?.X REQUIREMEliTS FOR RADIATION PROTECTION i
E. A. MASON, R. E. CU!211NGHAA, J. E. HARD, R. J. MATTSON R. D. SMITH, and H. T. PETERSON, JR.
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U.S. Nuclent Regulatory Commission l
Washington, D. C.
20555 j
United States of America INTP.00UCTION The application of r.eclear energy as an important source of elec is beccming a reality.
concerns no longer are restricted to a few localized developmental facilities This scope is particularly appropriate for dis-but are international in scope.
j cussions of the nuclear fuel cycle, i
Some of the radioactive materials associated with nuclear fuel cycle opera-tions tend to be longer lived than the radionuclides of primary concern at power i
reactors (short-lived noble gases and radioiodines) and several o truly global pcilutants.ated fuel cycle and waste disposal operations requires con Effluents lative and additive nature of releases from multiple source locations.
can move beyond national boundaries so that interna bodies of water which cross national boundaries.
These two f actors, the release of global pollutants, and the potentially cumulative and additive nature of releases from a multiplicity of sources, sug-further international cooperation and agreement are needed on the gest that f
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- .2 p'rinciple's for setting regulatory requirements for restrics.ng ef fluents from nuclear fuel cycle facilities and for the siting of reprocessing and caste dis-This need is further strengthened by the need for attention posal facilities.
to the statistical effects of radiation on large population groups.
The developrent of standards for radiation protection traditionally has l
This consensus has been achieved evolved through internatier.al consensus.
through multinational groups of experts such as the International Comission on Radiological Protection (ICRP) and througn the er. change of technical informa-tion at conferences sponsored by the IAEA and other organizations, such as the The fundarental approaches and International Radiction Protection Association.
reco=endations issued by the ICRP. have been employed in the develop :ent of national standards, such as the recommendations of the U.S. fiational Council on Radiation Protection and reasurements (UCRP), and for regulatiens issued by The governmental agencies, such cs the U.S.' Muclear Regulato
~
i mendations of the ICRP has resulted in a beneficial international uniformi'cy in This uniformity can become the the basic principles for radiation protection.
l
. foundation for further international agrecrents for radiation natro.
TliE EVOLUTION OF THE FA.GICAL BASIS FOR RADIATION PROTECT The earliest raditMu standards tere based upon acute observable injury, such as the recomendation of A. Mutscheller in 1925 [1] for a maximu.n doseA level based upon a fraction of the erythena dose.
~
lation was limited to only a few researchers, this appeared to be a satisfactorv h ever, as more use was made of X-rays and radium in d
medical treatment, research, and industrial applicctions, the size of the expose basis for protection.
population grew and, consavently, the association bet i
protection.
The confirmation of the mutagenic properties of radiation by R. 4. Muller
[2] in 1927 added concern for protection against the production of mut This in the gene pool as a basis for the development of ra in order j
to limit the damage to future generations.
Ep'idemiological studies have given emphasis to the importance d i t of any tistical risks from radiation which, although small from the stan po n individml, may result in potential health effects if large h
of Atomic Radiation (UNSEE',R), the British U,e are ex., sed.
il have been par-the U.S. Hational Acacemy of Sciences - National R hs effects.
i The growing body of information on radiation bioeffects con basis for pro-that the current ICRP recer.mendations [3] provide a satisfactory Despite the fact that the hazards of radiation and tection of the individual.
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- _ - _ _ _ _ _ - _ _ _ _ rad ioac th t*E'sn i i, c ri. i., G-,,,1..- ;;
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_ _ _ __ R agent or pollutant, that.
cill is uncertainty regarding rid at loa doses Recent assessments [a,o] have cast doubt cn and its dependence uocn dose-rate.
the validity of linear cytrapolations of the dose-ef f :t colationships cbserved Ho.,ever, in the absence of unequivocal evidence that a threshold at high doses.
dose exists below..hich there is no biological damage, these low-level, low-dose-rate exposures still must be considered in setting regulatory requirements for radioactive material releases into the environment if large population Global physical dispersion processes prodre groups would be expos 2d.
extreccly low radionuclide concentrations and, consequently, this will result in small individual cm delivered at very lou dose rates to large population Thus, consideration of low-level doses is par:icularly important for those impacts of the re. dear fuel cycle which transcend national boundaries.
groups.
This, however, is rot to say that the assumption of dose-effect linearity should 1
f be used to obtain realistic estimates of the p'ot:ntial biological damage to large population groups.
1 RECENT U.S. EXPERIEi!CE IT DEVELOPII;G REGULATORY REQUIRE:iEriTS FOR RAD DISCHARGES TO THE EfWIRDTOT Concurrent with the growing body of knowledge on radiation bioeffects, there has been a corres onding evolution of the methodology for setting radia,_
Traditionally, basic radiation protection standards tion protection criteria.
to individuals or have been expressed in terms of " maximum permissible doses"1Although!
"maximun permissible cenctntrations."
the terminology "Radh.t%n Protection Guides" (as these dose levels are not always permissible nor are they "maxicum" doses for all circumstances), we do agree with the concept of setting upper exposure levels f : indiv The basic foundation for regulatory requirements specifying the upper f
bounds for individual ex nsures would, of course, be the recommendations
'.S. Hational Cauncil._i so.
ICRP [3] and those of related nationa' todies sr on Radiation Protectico. and P.easurements (i;CRP) [6].
14ethodology is evo'ivirig for imolementing the ICRP guidance that ex be kept as low as is readily achievable.ICRP Report No. 22 {7] c: tails As for further reductions in radiation doce below the ICRP recenend l
noted, both in ICRP Report flo. 9 [3] and by the !;CRP [8], there is consicer difficulty in applying this approach in practice because of the uncertainties Considerable further inherent in attempting to quantify the risks and benefits.
development is required in this area and should entail international ef f experts in scientific and social disciplines.
ALARA, (or "as low as practicable", ALAP) has b
}
In the precise terminology of ICRP Report IJo. 9, the term " maximum d
I missible dose" is reserved for application of limits fo
!!ote:
ing routine exposures cf individual mecters of the public and population 3-b
'wN e
n U.S. tiuclear Regulatory Cc=ission and its predecessor agency', the U.
The incorporation of this concept followed Energy Commission, since 1970.
guidance issued by the former federal Radiation Council [9] (whose fun l
are now carried out by the U.S. Environmental Protection Agency)
I Specific design and operating requirements mendations of the fiCRP.
l performed on a case-by-c3Se basis.for meeting the criterion "as lo 3, 1970 [10].
water-reactors were initially publi~shed on December ments did not specify numerical criteria defining ALAP.
D The development of generic numerical criteria for levels of radioactive r
to co=ents material in light-water rector effluents was initiated in resp The conservation groups that farored more definitive qua 9,1971 [11], pro-starting with the publication of a proposed rule on July issu-1975[12], which, incidentally, was
' ance of a final regulation in the Spring of l
Regulatory Commission
' ~ one of the first major decisions of the new t;uc ear 19, 1975.
following its formation on January r
The proposed critdrfa changed'several times in the course of th dropped making proceeding as shown in Table I.
tions on radionuclide cencentrations in air and water which i
as being unnecessary for the implementation of individual dose restric Similarly, restrictions on the total quantity of rad dditional were dropped in favor of a cost-benefit analysis of the need for a the controls to reduce populatica doses beyond the controls require of effluent controls until the incremental cost per unit reduction individual dose limitations.
00 per man-rem tive dose to the population within 50 miles (80 km) exceeds $1,0T d is balance point is an interin value which is believed to be conserv or $1,000 per man-thyroid-ren.
f radiation slightly higher than previously published values for the wor lower value exposure reductions. dose is also an interim measure as biological sures.
for the worth of reductions in the thyroid dose than for whole b i
f reducing At present, we are attempting to define better the monetary iterion than the radiation exposures in order to provide a better decision cr somewhat arbitrary $1,000 per man-rem value presently used.
i d imple-We have gained useful experience in the course of develop i
i perience both for menting these ALARA guidelines.
point out the need for definitive data from operat What is "as low As major effluent as practicable" cannot be determined without prac se points become signifi-l t be well characteri:cd.
cant contributors to the estimated dose.not bee
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e Evolution of NRC Guidelines' ft - "As low As is Reasonably Achievable" Levels of Radioactive materials in Light-Water-CoolcJ fluclear Power Reactor Effluents, j
Table I.
Commission Staff Concluding Occision and Proposed Rule S ta tement Effective Rule Publication June 9,1971 [11]
February 20, 1974 [13]
flay 5, 1975 [12]
Date Annual Destbn Objectives Total Activity Released per reactor liquids (exclusive of 5 curies per year 5 curies per year deleted in lieu of tri tium) requirement for cost-benefit evaluation radiciodine - 131 Ho restriction 1 curie per year (airborne) a Concentrations of Radionuclides in 20 pCi per liter deleted water (total less H) 3 (tritium) 5,000 pCi per liter Air: radiciodines and 10-5 of 10 CFR Part 20 particulates Appendix B, Table II, Column I concentrations 10 millirem per year see below see below noble gases S
(Continued)
t e
Evolution of NRC GuideTir es for "As low As-is Reasonably Achievable" Le'vels of R materials in Light-Water-Cooled Nuclear Power Reactor Effluents.
Table I.
Commission Staff Concluding Decision and l
Effective Rule Statement i
proposed Rule Publication June 9, 1971 [11]
February 20, 1974 [13]
May 5,1975 [12]
Date Annual Design Objectives _
Individual Doses from 5 millirem por 3 millirem per Liquid Effluents 5 millirem per year (total body)
(site) year (site) reactor-year 5 millirem per 10 nillirem per 5 millirem per year (organ) year (site) reactor-year 10 millirad per 10 millirad per Noble gases (ganna air dose) year (site) reactor-year 20 millirad per 20 millirad per (beta air dose) year (site) reactor-year 5 millirem per 5 millirem per 5 millirem per year (total body dose)
(site) year (site) reactor-year 15 millirem per 15 millirem per (skin dose) year (site) reactor-year 15 millirem per 15 millirem per Radiciodines & Parti-5 millirem per year year (site) reactor-year
.culates (organ dose)
(site)
Limiting Conditions for Operation one-half of the one-half of the 2 times annual Design annual design annual design Licensee Action objective objective in any objective in any (one-half of the annual calendar quarter calendar quarter design objective in any calendar quarter) 4 times annual not specified 4-8 times annual design objective
~
NRC Action design objective
There are numerous other sources of u.
ertainties in the cost and performance of unproven ef fluent treatment syste:r.s; in the radionuclide composition, ma
~.
f tude, and physiochemical form of the fffluents; in the environmental transport models; and in the parcmeters for predicting dose that must be allowed for in establishing regulatory requirements based upon cost-effectiveness analyses.
Several approaches have been umployd in recent U.S. regulations to allow for the uncertainties in the theoretical cost-effectiveness analyses of radio-In the MRC's development of ALARA effluent active waste treatment rfstems. limitations, we have specified the numerical guide and permit operating fitwibility above the annual dose des one-half of the annual design objective in a calendar quarter.
The cost-effectiveness of radioactive effluent control systems was also considered during the 6mlopme'nt of the generally ap The EPA standards set forth by the U.S. Environractal Protection Agency [14].d l in contrast to the
. environmentally acceptable dose limits for indivi ua s,The annual dose limitt design objectives of Twendix I of 10 CFR Part 50.
established are were 25 millirem to the whole body, 75 millirem to the thy gland, and 25 millirem to any other organ from all operations (except m l
transportation, and waste disposal) in the light-water-reactor uranium fue j
Departures frc'm theoretical predictions of effluent control system ef fectiveness and unex;ected operational difficuities in reaching or maint cycle.
ing the required levels are accounted for by a variance provision wh h
the regulatory agency (2C) to issue a temporary variance to operate abo standards for limited periods of time necessary to correct the deficienci system operation.
We have had apprcximately two years experience in the implementat the design objectives of Appendix I to 10 CFR Part 50.
by effluent measurements combined with environmental dispersi This calculational approach is used because the radionuclide concentrations in the environment which correspond to the design obje lation models.
doses are so low that taasurements are difficult.
developed that describe the NRC staff's models f l
License applicants may use and human intake, and equipment costs [15-19).other mod fic site-
' related conditions if they realistically depict actual physical processes.
resulted in major equipment additions beyond t
This is despite systems required to meet the individual dose design objectives.
h id-rem the presumably conservative value of $1,000 per man-rem, or man-t y but it can be This was not totally expected The cost-benefit analysis is based upon population dose an used as the balancing criterion.
fore, the value of effluent reductions is related to the population d explained.
Sites Population densities are generally low in the vicinity of reactor sit l efflu-are rare that have a sufficient population density to warrant addition i
few miles ent limitations and that do not have any individual or farm with n a.
. a'..
Thus, ivr most situations, the design osaectives based upon
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individual dose limitations will be the governing restriction.
Our experience in formulating and implementing regulatory requirements based on the principle of "as low as readily achievable" silows that such require-1 The primary lesson that we have learned ments can be successfully errployed.
from the Appendix I rule making proceeding is that suf ficient allowance must be made for departures from the predicted operation of unproven effluent treatment Therefore, some operatirig flexibility cust be permitted between the theoretical cost-benefit cptimum and the control level set forth in regulations.
systems.
1 1
CONSIDERATIONS FOR FUTURE STANDARDS DEVELOPMENT EFFORTS Adoption of tile ICRP dose limits for individual protection and the ALARA concept for monitoring unnecessary radiation exposure provides a' foundation for In the introduction of the development of future international agreements.
this paper, several areas were identified where further international standards development efforts are desirable. These areas were:
1.
limitation of global radioactive containments; protection of communal natural resources; 2.
development of consistent principles and procedares for 3.
risk estimation and regulation; and development of c:nsistent siting policies for nuclear fuel 4.
cycle facilities, it is appropriate at this point to elaborate on these concerns and provide examples of ongoing ef forts to resolve them.
Of primary concern is the need for uniform control over the long-lived radioactive emissions frcm nuclear fuel cycle cperations that are potential Several radionuclides can be identified which, by nature Krypton-85, tritium global pollutants.
cf their persistence and mobility, have this potential.
(hydrogen-3), and carbon-14 are of primary interest because of their dispersi Radionuclides such as iodine-129 bility, production yields, and half-lives.
and plutonium-239 presently are more of local and reg The uncertainty in the long-term behavior of widely.over thousands of years.such radionuclides in itself suggests that prec the accumulation of such caterials in the environment.
In the United States, we have made a national commitment to the institutio of further controls on releases of krypton-85, iodine-129 and alpha-emitting General environmental radiation standards for uranium fuel cycle operations were issued in the beginning of this year by transuranic elements.
Environmental Protection Agency [14).
tion of discharges of these materials to 50,000 curies of krypton-85, 5 mill curies of iodine-129, and 0.5 millicuries of alpha-emitting transuranic eleme The standard for the transu-per gigawatt-year of electrical energy production.ranic emissions
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f all fuel krypton-85 and iodine-129 mill be required for the reprocessing o 4
fuel irradiated on or af ter Jmuary 1,1933 if a decision is mad Studies are also
' testing of the required advanced effluent control system in the U.S.
b 14 and tritium.
The concern for the restriction of global radioactive pollutants.is Many other countries are instituting con-trictions means unique to the United States.
i trols on these emissions or are formulating standards which conta n res diation Protec-on the global collective dose commitment, such as the flordic Ra f Denmark, tion Standards recommended by the Radiation Pr.otection Institutes oHow Finland Iceland, i?arwy and Sweden [20).needed to broaden these emissions.
A second area where further international standards developm The limitation of ll warranted is the protection of communal natural resources.
d between nations radioactive material levels in bodies of water that are i
resources from ocean disposal of radioactive waste.
d ies, the several countries or le.se seas or lakes are located o t be controlled additive contributions frcm facilities in different countries m i t d by prior to insure that downstream f acilities are not unnecessar l
have been or are several nations has, of course, been recognized and agreements contamination.
being developed to deal with this general problem.
i Examples of international cooperation to limit radionuclide tion of Marine in communal waters are the International Convention on Canadian 1972 Pollution by Dumping Wastes and Other Matter [21] and the U.S. -T Agreement on Great Lakes Water Quality [22]. d other toxic material-prohibits the dumping of high-level radioactive wastes an A system of permits is set up for controlling the ocean The convention parallels in manythe Federal i
into the world oceans.
disposal of low-level radioactive wastes. respects the provi d Sanctuaries
' Pollution Control Act and in the ! brine Protection, Research, an Act of 1972.
from a The U.S. - Canadiaa Agreement on Great Lakes Mater Qu dian Boundary long-standing agreement on sharing common waters, the U.S.
l The Water Quality Agreement provides for a Great L d monitoring of Water Quality Board to establish objectives for the control a Waters Treaty of 1909.
l f radio-pollution in the lakes.is in the process of developing water qual for the Great Lakes.
activity in water and a radioactivity surveillance plan i
t The third area for future joint efforts is the development of i
aterials to principles and approaches for regulating releases of radioact ve m.
f
the environment. Tr.ere i on-going efforts by the ICRP cugh its Subcom-mittee fiumber 4 to provide additional guidante on implemeution o re:rmendations.
Advisory Groups to prepare technical guidance for r. ember states on developing Draft reports have been pre-regulations for radioattive ef fluent limitation. pared by I AEA Ad active Discharges to the Environment from Discharges to the Environment frem fluclear Facilities, on the Assessment of Collective Dose to Populations, and on the Principles of Establishing Limits for the Release of Radioactive Mate-These and other efforts by the IAEA and the ICRP rials to the Environment.
should provide valuam technical guidance on consistent methods which can be used in develcping national regulations and international agreements for con-trolling radioactive pollutants.
International ' agreement would be beneficial in defining the geographic scope of consideration to be uscd for evaluating the costs and the benefits of It is difficult to argue against the position that the proper This scope of consideration is particularly apprcpriate for nuclear porter.
radioactive pollutants from the nuclear fuel cycle which are capable of woric-It is now U.S. policy that, for environmental impact assess-ments performed under the !;ational Environn. ental Policy Act of 1969, the " human wide dispersion.
A more environment" is not to te restricted to U.S. territorial boundar the inpacts or costs 'are primarily confined to a small region.
t poier reactor licensing has been to require detailed data su calculations for the dose celivered to the U.S. and world populations for the environment impact assessrent.
One additional area where a need for international consensus can be clearly seen is the development of radiation protection re;&: ions which affect the siting of nuclear fuel cycle facilities and radioactive waste disposal sites.
Experience with Eurochemic shows that multinational spent fue
[23] and liRC's f;uclear Energy Center Site Survey [24] show that encrgy centers are feasible.
or centers containing nuclear power plants and reprocessing f acilities and, perhaps, fuel fabrication plants, are viable from the standpoint of public The localized concentration of several health and safety considerations.
nuclear fuel cycle facilities with possible inequitie
' effluent limitation be developed.
C0i!CLUSIOUS Prototypica1 international agreements already exist which can be used cornerstone for the development of further international controls on rad The international standards for the transportation of radioactive d
materials developed by the 11EA provide a well recognized and widely adop pollutants.
basis for uniform international regulation that aids in ensuring safety of.
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thereby promotes international.rade. Similar agree-
- nternati.onal shipments anu ments for the control of pollutants from nuclear fuel cycle facilities also sh be beneficial _
We believe that there is a need for reaching international agrcement on the development of requirements for controlling radioactive emissions fr l
nuclear fuel cycle operations.
f In
. protection set forth by the ICRP provide a foundation for suc j
together with the Energy ?.esearch and Development Administration, the Environ-mental Protection Agency, the Ocpartment of State, and the Department of.rans-l portation have agreed to ur.dertake the following actions:
i intensify U.S. tiforts and participation in international ef forts to 1.
develop codes and standards for envi'ronmental protection and to assess the environmental impact of alternative energy sources; advocate futher international cooperative efforts along these lines; 2.
continue support of IAEA and NEA activities to develop uniform stan-3.
dards for the transportation of radioactive materials and guidance to IAEA member states on the procedures for developing regulatory requirements for radioactive emissions; and encourage adoption of the provisions of the Convention on the Pre-4.
vention of tiarine Pollution as an international standard for the control of ocean disposal of radioactive wastes.
He urge that others intensify their efforts in support and refinement of taese objectives.
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~~
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[15]
Compliance with 10 CFR Part 50, Appendix 1. USNRC Regulatory Guide 1.109, USNRC, Washington, D.C. (March 1976).
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Systems for Light-Water-Cooled Nuclear Power Stations, U$ttRC Regula-USNRC, Washington,D.C.(March 1976).
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Light-Mater-Cooled Reactors, USNRC i.egulatory Guide 1.111. USNRC, Washington, D.C.
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[21)
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6 y.
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i