ML20202F858
| ML20202F858 | |
| Person / Time | |
|---|---|
| Issue date: | 09/15/1975 |
| From: | Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Train R ENVIRONMENTAL PROTECTION AGENCY |
| References | |
| NUDOCS 9902040191 | |
| Download: ML20202F858 (54) | |
Text
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Bonorable Russell n. Train 03 Administrator ru. 4 39 g V
t U. S. Environmental Protectton Agency y
Washington, D.C.
20460
Dear Mr. Train:
This is in reply to the notice in the Federal Register, Volume 40 r
Number 104, May 29, 1975, wherein the. Environmental Protection Agency proposed Environmental Protection Standards for the Uranium Fuct Cycle i
L (40 CFR Part 190), and to the letter (Rowe to Muller, June 2, 1975) requesting comments on the Draft Environmental Impact Statement for the rulemaking action.
The NEC strongly supports EPA's mission to develop generally applicable environmental radiation standards. We believe tne national interest and our regulatory program would benefit by a numerical expression of safe limits on radioactivity in the ambient environment within which radio-L active emissions from rne facilities in the uranium fuel cycle could oe j
i regulated. Suca standards snould be developed with full consideration "4
given to the balancing of resource expenditures for health prother ion for tne uranium fuel cycle versus similar expenditures for control of other activities unica af f ect the puplic nealth aspects of the environ-ment.
Existing Federal regulat ions and current regulatory practices provide assurance that for normal operation the uranium fuel cycle facilitles will be designed and operated in a osaner which limits to as low as reasonably achievable the levels of release of radioactive material and exposures to radiation.
In view of the demonstrated effectiveness of the existing t
regulatory program, we do not believe there is a need for further restrictions for these facilities at this time, futhermore, any small changes in radiation exposure wnico might be ef fected by toe proposed EPA standards do not justify the considerable costs associated with tne standards. The apparent lack of cost effectiveness should be examined in perspective to reductions whien signt be afforded by expenditures for control of more significant environmental problems. We believe that EPA's broad responsibilities for pollution abatement and tne diverse expertise repre,sented by the EPA staff would permit examination of these trade-offs.
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j We find that the EPA proposed standards are in reality a ' fine t uning of existing effluent regulations.
To demonstrate why this is objectionable, h~p consider the relationship between the EPA proposed standard and the NMC 1
9902040191 750915 P
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Honorable Russell L. Train 10 CFR Part 50, Appendix I.
The
,cical guidelines in Appendix I were derived from a thorough -
ideration of the costs and environmental l
effsets of radioactive effit..gs which were presented during a public rulemaking hearing. EPA'a proposed standards specify environmental radiation levels for activities in the uranium fuel cycle.
Yet, when applied to only one kind of facility within the fuel cycle, light water power reactors, the levels specified by EPA are in the same range as tne the guidelines of Appendix 1. Furthermore, the EPA proposed standards differ in specific details and are not conalatent with Appendix 1.
Tne EPA 14otice of Froposed Rulemaking states that Appendix I "will provide an appropriate ano satisfactory implementation" of these standards for light-water-cooled nuclear power reactors. The NRC staff does not agree that compliance witis Appendix I necessarily would provide compliance with the EFA proposed standards.
For instance, for a multiple reactor site it would be possible for the emissions to be within the Appendix I levels and in excess of tne EPA proposed standards. The EFA proposed at andards also would require the scheduled application of technologies which have not been demonstrated on a conenercial scale for removing and retaining radio-active iodine and krypton for long tern decay and for stabilizing mill tailing piles.
Implementation of tne 1;FA proposed standards would require a substantive effort to modify the NhC's regulations in order to remove these discrepan-cles, and it would not change significantly the overall environmental impact. Although the proposed standard would require a system foi imple-mentation whien would be similar in concept to the existing NRC system for regulating ef fluent s, there would be significant differences in the details of implementation unica would impose a significant administrative burden on the NRC.
It would be particularly difficult to develop a mechanism to demonstrate conformance with tne emission limits stated in curies per unit of energy generated.
Thus, we believe that the proposed standard requires further work.
Tne NRC staff believes that EPA's generally applicable environmental radiat ion standards should provide an upper limit for radiation exposures, predicated upon restricting the potential health impact from all sources of radiation exposure.
The duclear Regulatory Commission would require its licensees to operate within such limits and further restrict effluent releases and radiation exposures in a cost-effective manner to be as low as reasonably achievable. Several alternative approaches appear available to the EPA. The limita could be raised to reflect the concerns expressed I
above and in the IdRC staff comments whien are attached. Another possible approach would be tnat the Federal Radiation Council (FRC) radiation protection guides for doses to individuals be supplemented to limit doses from the nuclear fuel cycle f acilities to a larger fraction of the present FPS limits than tne factor of twenty reduction which is reflected in the 1;FA Droposto standard.
The f ract ional limits should be chosen on the basin l
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tionorable Roa' Train,
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_ a broad and balanced approach to resource expenditures for health protection. The MC staff is prepared to initiate furtner work with your staff to develop an appropriate and balanced standard which would allow flexibility within wnich effluents could be regulated without undue i
interruptions of electric power sources and with consideration of the
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proper distribution of allowable discharges among the various types of facilities in the fuel cycle.
t Sincerely, l
k34 teed) Lee O seesset i
Lee V. Gossick Executive Director for Operations
Enclosure:
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Honorable Russell E. Train Admi istrator U. S.
'ovironmental Protection Agency Washing n, D.C.
20460
Dear Mr. Tr in:
This is in rep to the notice in the Federal Register, Volume 40 Number 104, May 9, 1975, wherein the Environmental Protection Agency r
proposed Enviro tal Protection Standards for the Uranium Fuel Cycle (40 CFR Part 190), nd to the letter (Rowe to Muller, June 2,1975) i requesting comments the Draft Environmental Impact Statement for the rulemaking action.
The NRC strongly supports LPA's mission to develop generally applicable environmental radiation st dards.
de believe the national interest and l
our regulatory program woul benefit by a numerical expression of safe limits on radioactivity in tn ambient environment within which radio-active emissions from the faci
- ties in the uranium fuel cycle could be regulated. Such standards shou be developed with full consideration given to the balancing of resourc expenditures for health protection 1
for the uranium fuel cycle versus imilar expenditures for centrol of other activities which af fect the p lic health aspects of the environ-l I
ment.
I Existing Federal regulations and curren regulatory practices provide assurance that for normal operation the ranium fuel cycle facilities will be designed and operated in a manner whic limits to as low as reasonably achievable the levels of release of radios ive material and exposures l
to radiation.
In view of the demonstrated e fectiveness of the existing I
regulatory program, we do not believe there i a need for further t
restrictions for these facilities at this time.
Futhermore, any small l
changes in radiation exposure which might be ef eted by the proposed EPA standards do not justify the considerable cos a associated with the standards.
The apparent lack of cost effectivenes should be examined I
in perspective to reductions which might be afforde by expenditures for control of more significant environmental problems. W believe that EPA's r
i broad responsibilities for pollution abatement and the verse expertise represented by the EPA staf f would permit examination of ese trade-offs.
We find that the EPA proposed standards are in reality a " fine tuning of l
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existing effluent regulations. To demonstrate why this is objectionable, consider the relationship between the EPA proposed standard and the NRC r
e 1,
Honorable Russell E. Train i i
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l 10 CFR art 50, Appendix I.
The numerical guidelines in Appendix T were der'ved from a enorough consideration of the costs and envi
_ mental effects o radioactive ef fluents wnich were presented during public rulemaking earing. ZPA's proposed standards specify environmental Icvels which are in the range of the guidelines of Appendix I, but which differ in spe ific details and are not consistent with Appendix I.
The EPA Notice of oposed Rulemaking states that Appendix I "will provide an appropriate and satisfactory implementation" of these standards for ligh t-wa te r-cool nuclear power reactors.
The NRC staff does not agree that compliance w h Appendix I necesterily would provide compliance with the EPA proposed s adards.
For instance, for a multiple reactor site it would be possible for the emissions to be within the Appendix I levels and in excess of the A proposed standards. The EPA proposed standards also would require the cheduled application of technologies wnich have not been demonstrated on a c
.rcial scale for removing and retaining radio-active iodine and krypton or long term decay and for stabilizing mill tailing piles.
Implementation of the EPA pro, sed standards vould require a substantive effort to modify the dhC's regu ations in order to remove these discreoan-cies, and it would not enan2e si ificantly the overall environAental impact. Although the proposed st dard would require a system for imple-I sentation which would be similar in concept to the existing HRC system for regulating effluents, there woul be significant differences in the i
l details of implementation wnicu would
. pose a significant administrative burden on the NRC.
It would be particu rly difficult to develop a mechanism to demonstrate contormance witn tne emission limits stated in curies per unit of energy generated.
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Thus, we believe tnat the proposed standard r quires further work.
The r
HRC staff believes that EPA's generally applicable environmental radiation l
standards snould provide an upper limit for radiation exposures, predicated upon restricting the potential health impact from all sources of radiation exposure. The Nuclear Regulatory Coramission would require its licensees l
to operate well within such limits and further restrict ef fluent releases 1
l and radiation exposures in a cost-effective manner to be as low as reasonably achievable. Several alternative approaches appear available to l
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the EPA. The limits could be raised to reflect the concerns expressed j
l above and in the NRC staf f comments which are attached. Another possible l
. approach would be that the Federal Radiation Council (FRC) radiation protection guides for doses to individuals be supplemented to limit doses from the nuclear fuel cycle facilities to a larger fraction of the present FRC limits than the factor of twenty reduction which is reflected in the EPA proposed standard. The fractional limits should be chosen on the basis 4
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l donorable Russell E. Train.
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o a broad and balanced approach to resou-
.xpenditures for health pro ction. The NRC staff is prepared '
..itiate further work with your staf to develop an appropriate and ' aanced standard which would allow flexib'lity within which ef fluent; could be regulated without undue i
interru ions of electric power sources and with consideration of the proper ut tribution of allowable discharges among the various types of facilities in the fuel cycle, j
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Sincerely, i
I Lee V. Cossick Executive Director for Operations Enclos ure:
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Honorable Russell E. Train Administrator U. S. Environmental -
.metion i
Agency Washington,
".C.
20460
Dear Mr. Train:
l This is in reply to the notice in the Federal Register, Volume 40 Number 104, May 29, 1975, wherein the Environmental Protection Agency i
proposed Environmental Protection Standards for the Uranium Fuel Cycle (40 CFR Part 190), and to the letter (Rowe to Muller, June 2,1975) requesting comments on the Draft Environmental impact Statement'for L
the rulemaking action.
The NRC strongly supports EPA's mission to develop generally applicable environmental radiation standards. We believe the national interest and our regulatory program would benefit by a numerical expression of safe limits on radioactivity in the ambient environment within which radio-active emissions from the facilities in the uranium fuel cycle could be-i regulated. Such standards should be developed with full consideration given to the balancing of resource expenditures for health protection for the uranium fuel cycle versus similar expenditures for control of j
(
l other activities which affect the public health aspects of the environ-L ment.
i Existing Federal regulations and current regulatory practices provide
' assurance that for normal operation the uranium fuel cycle facilities l
will be designed and operated in a manner which limits to as low as l
practicable the levels of release of radioactive material and exposures i
to radiation. In view of the demonstrated effectiveness of the regula-tory program, we question the need for further " fine tuning" of existing l
standards for these facflities at this time. Comparing the regulations and controls provided for non-nuclear industries, we believe that.any additional emphasis on environmental standards would be more cost-effective if they were addressed to other sources of pollution.
As an example of the " fine tuning" of standards which we find objec-l i
tionable, consider the relationship between the EPA proposed standard and the NRC 10 CFR Part 50, Appendix I.
The numerical gpidelines in Appendix I were dcrived from a thorough consideration of'the costs and i
i environmental effects of radioactive effluents which were presented during a public rulemaking hearing. EPA's proposed standards specify environmental levels which are in the range of the guidelines of Appendix 1 but which differ in specific details. The EPA Notice of i
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1 Honorable Runen'" 5. Train,
josed Rulemaking states that Appendix I "will provide an appropriate and satisfactory implementation" of these standards for light-water-cooled nuclear power reactors. The NRC staff does not agree that compliance with Appendix I necessarily would provide compliance with the EPA proposed standards.
For instance, for a two-reactor site it would be possible for the emissions to be within the Appendix I action levels and in excess of the EPA proposed standards. The EPA proposed standard also would require the scheduled application of technologies which have not been demonstrated on a commercial scale for removing and retaining radioactive iodine and krypton for long term decay and for stabilizing mill tailing piles.
Implementation of the EPA proposed standard would require a substantive effort to modify the NRC's regulations in order to remove these discrep-ancies, and it would not change significantly the overall environmental impact. The proposed standard would require a system for implementation which would be essentially the same as the existing NRC system for regulating effluents. That is, discharges would be characterized by measurements and analyses, and doses to people would be projected by analyses of environmental interaction of radioactivity with man. Despite this similarity, a significant administrative burden would be required for the NRC to implement the proposed standard, particularly in developing regulations to demonstrate conformance to the emission limits stated in curies per unit of power generated.
We believe that the proposed standard needs further work.
Several alternative approaches appear available to the EPA. The limits could be raised to reflect the concerns expressed in the NRC staff comments which are attached.
Another possible approach would be that the Federal Radiation Council (FRC) radiation protection guides for doses to indi-viduals be supplemented to limit doses from the nuclear fuel cycle facilities to a larger fraction of the present FRC' limits than the factor r
of twenty reduction which is reflected in the EPA proposed standard. The fractional limits should be chosen on the basis of a broad and balanced approach to resource expenditures for health protection.
Such limits would conceivably allow flexibility within which effluents could be regulated without undue interruptions of electric power sources and with consideration by the regulatory agency of the proper distribution of allowable discharges among the various types of facilities in the fuel cycle.
The detailed staff review of the proposed standard is attached.
6 Sincerely, l
Lee V. Gossick Executive Director for Operations i
i Honor:bla Ru nell E.
.ain.
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sonorable Administra unsell E. Train
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Washington, D.
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20460
Dear Mr.' Train:
This is in reply to t Number 104
, wherein the Environmental Protectio i
May 29, 19 Agency prop,osed Envir i
fi Fuel Cycle (40 CFR Part 1 0), and to the letter (Rowe tnta June 2,1975) requesting c
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Statement for the rulemaki ats on the Draft Environmental impact o Muller, i
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action.
The NRC strongly supports dPA' i
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applicable environmental radiat nission to develop gene ~ rally l
national interest and our a stan(.ards.
We believe the environment within which radioactivregulat ry program w l
numerical expression of safe limit a
1 on radioactivity in the ambie'at in the uranium fuel cycle - could beesissions from the facilities l
be developed with full considerationulated.
r Such standards should cycle versus similar expenditures for co tresource e 7(
n for the uranium fuel which affect the public health aspectsrol of other activities of he environment.
Existing Federal regulations and curr assurance that for normal operation the ura ent re will be designed and operated in a usaner wni 1 story practice fuel cycle facilities nt practicable the. levels of release of radio limits to as low e
exposures to radiation.
as acti material and of the regulatory program,In view of the demonstr ted effectiveness Comparing'the regulations and controlstuning" of exist we question the need f further " fine e facilities believe that any additional emphasis ondestry to tho t this time.
- on-nuclear industries, we sources of pollution.would be more cost-effective if they were addre j
e to other i
As sa example of the " fine tuning" of standard and the NRC 10 CFA Part 50 objectionable, co
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ween the EPA proposed guidelines in Appendix 1 were derived fro
, Appendix 1.
The numerical L
i m a thorough consideration I
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=
Honorable Russell E. Train
\\ of the costs and e i were prpeented dur_ag samental effects of radioactive 1
standards specify envir public rulemaking hearing.
effluents which EPA's proposed guidelines of Appendix 1 ut which differ in specific detailsntal lev EPA Notice of Proposed Ru e Making st light-water cooled nuclearan appropriate and satisfa tory implem The ation of these standards for that compliance with Appendi 1 would provide compliance with the proposed standards. Indeed, for the emissions to be withi e a two-reactor site it would be possible excess of the EPA proposed sta tne Appendix 1 action levels and in l
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ards.
1mplementation of'the EPA propos l
effort to modify the NRC's regula standard would require a substantive l
ancies without really changing the ons in order to remove these discrep-j 4
vera11 environmental impact.
The proposed standard would require i
i would be essentially the same as thesystem for implomentation which 4
effluents.
j and analysisThat is, discharges would isting MC system for regulating and dose 6 to people would characterized by measurements similarity, a significant administrativeof environme i
y with man. Despite this the NRC to implement the proposed rden would be required for in curies per unit of power generat dregulations to demo l
emission limits stated e.
achieve its objective.We recommend that the proposed standa d r underg Several alternative app further development to to the EPA.
The limits could be raised to reflecaches appear available in the NRC staff comuments which are att ached.
the concerna expressed Another possible approach would be th t (PRC) radiation protection guides f a
the Federal to a larger fraction of the present FRsupplemented to l j
ear fuel cyc1 facilities twenty reduction which is reflected iC limits than the factor of balanced approach to resource expenditfractional lim tandard.
The e basis of a bro Such limits would conceivably allow fl and ures for health prot etion.
effluents could be regulated without undue iexibility within whi nterruptions of' electric 1
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Honorr' assell E. Train power sources and with consideration by the regulatory agency of the proper distri tion of allowable discharges among the various types of facilities in the fuel cycle.
The detailed staff re *ew of the proposed standard is attached.
Sincerely, e V. Gossick E cutive Director to Operations
Enclosure:
Staff comumente l
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Ronorable Russell E. Train Administrator U. S. Environmental Protection Agency.
Washington, D.C.
20460 Dear Mr. Train.
This is in reply
.o tne notice in the Federal Re.1 ster, Volume 40 Number 104, May 2,1975, wherein the Enviro tal Protection Agency _ proposed En ironmental Protection Stan ards for the Uranium j
l Fuel Cycle (40 CFR art 190), and to the le er (Rowe to Muller, June 2,1975) reques ing comments on the D af t Environmental Iepact Statement for th rul king action.
The NRC strongly support EPA's missi to develop generally i
applicable environmental adiation s andards. We believe the j
national interest and our egulato program would benefit by a numerical expression of sa limi on radioactivity in the ambient environment within wnich rad osc ive emissions from the facilities in the uranium fuel cycle cou be regulated.
Such standards should be developed with full consid arton given to tha balancing of
)
resource expenditures for he it protection for the uranium fuel cycle versus similar expen ture for contrcl of other activities r
which affect the public h alth as et s of the environment.
Existing Federal regul. ions and cur ent regulatory practices provide assurance that for no al operation t e uranium fuel cycle facilities are designed and ope sted in a manner ich limits to as low as practicable the le is of release of ra *oactive material and exposures to radi ion. -In view of the monstrated effectiveness of the regulato program, we question the need for further " fine runing of exi.ing standards for these fac ities at this time.
Comparing the egulations and controls provi for the nuclear in-dustry to th se which are provided for non-nue ear industries, we believe th any additional emphasis on environ ntal standards would be re cost-effective if they were addres d to other sources f pollution.
As an zample of the " fine tuning" of standards whic we find obje ionable, consider the relationship between the A proposed standard and the NRC 10 CFh Part 50, Appendix I.
The merical ruidelines in Appendix I were derived from a thorough co sideration I
Honorable Russell f>. Train t of the costs and environmental effects of radioactive effluents which were presen ed during a public rulemaking hearing.
EPA' proposed standards specify environmental levels whi are O.ae range of the guidel nes of Appendix I but which di er F specific details. The EPA No ice of Proposed Eule Making tates that I
Appendix I "will prov de an appropriate and sati fact ory implementation" of the e standards for light-wa/er-cooled nuclear j~
power reactors. The NR staff does not agree / hat compliance with Appendix I would pr vide compliance wit the EPA proposed standards.
Indeed, for a two-reactor site would be possible for the emissions to be w hin the Appendi I action levels and in excess of the EPA propo d standards.
l Implementation of the EPA pr osed sta ard would require a substantive effort to modify e NRC' regulations in order to remove these discrepancies wit t r ally changing the overdll environmental impact.
The proposed standard would requ' e a system for implementation which would be essentially the as the existing NRC system a
for regulating ef fluents.
Th is, discharges would be characterized by measurements and an lysis, and doses to people' would be projected by reali ic analy es of environmental inter-action of radioactivity wi man.
Des ire this similarity, a significant administrativ burden woul be required for the NRC to implement the propose standard, par 'cularly in developing regulations to demonstr e conformance t the emission limits stated in curies per u t of power genera ed.
We recommend that th proposed standard und rgo further development to achieve its obje ive. Several alternati approachee appear available to the EP. The limits could be r ' sed to reflect the concerns expresse in the NRC staff comments which are attached.
Another possible approach would be that the FRC radiation protection guides for dose to individuals be supplemented to limit doses from the nuclear fu cycle facilities to a more substantial fraction of j
the present limits. The fractional limits should be chosen on the basis of a broad and balanct.d approach to resource expenditures for health protection. Such limits would conceivably allow flexibility within which effluents could be regulated without undue interruptions of electric power sources and with consideration by the regulatory
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Honorable Russell E. Train..
1 agency of r e proper distribur!_a of allowable discharges among the various pes of facilities in the fuel cycle.
The detailed at ff review of the proposed standard'is attached.
N 4
Sincerely,
/
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Lee V. Coss ek
\\ xecutive/ Director E
\\ or Opsrations f
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Enclosure:
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Staff comments l
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COMMENTS OF THE NUCLEAR REGULATORY COMMISSION STAFF ON THE EPA PROPOSED RULEMAKING ON ENVIRONMENTAL PROTECTION STANDARD 40 CFR PART 190 i
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JULY 1975 i
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O O
1.
Suitability of the EPA Proposed Standards with Respect to Statutory Authority Under Reorganization Plan No. 3 the following functions, with respect to radiatica standards, were transferred to EPA:
" Ice funct ions of the Atomic Energy Commission under the Atomic Energy Act of 1954, as amended, to the extent that such functions of the Commission consist of establishing generally applicable environmental standards for the protection of the general environment from radioactive materials.
As used herein, standards mean limits on radiation exposures or levels, or concentrations or quantit ies of radioact ive material, in the environment ou tside the boundaries of locations under the control of h:c 3**-ce?'ec19ts
-e 24+ *. P.trT*T.
..M -.. M1 or using radioactive material."
la addition, a 1973 memorandum from the Director, OMB, to the Administrator of the EPA and the Chairman of the AEC clarified the responsibilities of the two Federal agencies by stating that:
" EPA snould continue, under its current authority, to have responsibility for setting standards for the total amount of radiation in the general environnent from all facilities combined in the uranium fuel cycle, i.e.,
an ambient standard which would have to reflect AEC's findings as to the practicability of emission controls."
f The regulatory responsibilities of the AEC were transferred to the Nuclear I
Regulatory Co==ission (NRC) by the Energy Reorganization Act of 1974.
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, It is the view of the NRC staff that the portion of the EPA proposed standard which defines the annual dose equivalent for any member of the j
public is an appropriate " generally applicable standard" and within the EPA area of responsibility. The actual values proposed in the E?A standard do not adequately reflect NRC's findings as to practicability expressed l
i in Appendix I which was published in the Federal Register on. Yay 5,1975, as discussed in Section 2, below.
The portion of the proposed standard which specifies limits on cuantities of long-lived materials entering the environment is not, in our opinion, a generally applicable environmental standard. These limits which are expressed in curies per gigawatt-year of electric energy generation are, j=- ~ ~Iai~aTf4r'act-icai purpos es, discharge limitations for spent fuel Yeprocessing plants and, in our opinion, represent release limits for a specific type of facility.
The proposed approach provides no real limit on the concentrations j
of these radionuclides in the environment. The use of environ = ental concentrations would provide a " generally applicable standatd" for such long-lived radionuclides.
2.
Comparison of the EPA Proposed Uranium Fuel Cycle Standard (40 CFR Part 190) with Appendix 1, 10 CFR Part 50 Appendix 1 of 10 CFR Part 50, which provides numerical guidelines for design objectives and limiting conditions for operation to meet the criterion "as low as reasonably achievable" for radioactive material in light-water-cooled nuclear power reactor ef fluent s, was issued as an NRC regulation on April 30, 1
i 1975, with notice in the Federal Register on May 5,1975.
l
~-
3-In addition to satisfying tne design objective guideli:
, additional radioactive isaste treatment components are require' the regulation if the s
annual costs of those components are justifi-of reductions of the dose to the population within 50 miles of the reactor using the interis values of
$1,000 per person-rem or $1000 per person-thyroid-rem as the basis for judging cost effeet iveness.
The statement of considerations published in the Federal Register with the EPA proposed standard 40 CFR Part 190 states in part:
"It is the view of the Agency (EPA) that this guidance for reactors-(Appendix 1,10 CFR Part 50) will provide an appropriate and satisfactory j
implementation of these (40 CFR Part 190) proposed environmental w -,adiation standards for the uranium fuel-cycle with respect to light-r i
u,--
i water-cooled ' nuclear reactors utilizing uranium fuel."
The NRC staff does por agree that the provisions of Appendix I would necessarily " provide an appropriate and satisfactory i=plementation" of the proposed 40 CFR Part 190 for LWR power stations. The reasons are several:
- 1. The design objective quantit ies of Appendix I and attendant doses for the three release modes under some circumstances could be additive.
- 2. The design objectives apply to each reactor on a site (not to the entire site) and can be multiplied by the number of reactors on the site for estimating the equivalent values for the site.
- 3. The flexibility provided in Appendix I for the li=iting conditions for operation (in recognition of the uncertainties in the source
7
- 4 l
- t. -
i i
term estimates r
.a anticipated operational occurrences) would permit the Jasign objective quantities to be exceeded under certain conditions.
- 4. Appendix I applies only to ef fluents from LWR power stations -and does nor' apply to other radiation sources such as N-16 from the I
turbines, storage of radioactive material, or interaction of radiation l
fran other nearby sites and radiation from other than LWRs on the l
i same site.
For these reasons, a nuclear power station with only three LWR units designed and operated in accordance with Appendix I could result in the l
doses presented in Table I.
l
'l.
TABLE I.
POTENTIAL ANNUAL DOSE RATES TO AN INDIVIDUAL NEAR A THREE-UNIT LWR STATION OPERATING WITHIN APPENDIX I, 10 CFR PART 50 i
Release Mode Whoie Body (mrem)
Organ (arem)
Liquid Ef fluents 9
30 l
Gaseous Effluents 15 15 l
45 Iodine and Particulates Doses at " design object ive"l evel 24 90 l-Proposed Standard (40 CFR Part 190).
25 75 (thyroid)
L 25 (other organs) i n:
i
_...m.m.._
^
i l
L o
.i
, l Inc total dose from ef fluents is almost equal to the EPA whole-body dose and could exceed the organ dose limits.
The total dose could be higher-than that which could occur from exposure to ef fluents if consideration i
is given to radiation from N-16 in the turbine of a BWR station, from' i
storage of radioactive materials onsite, from transportation of radioactive material, from nuclear f acilities other than LWR, or from other nuclear i
sites in the near vicinity of the station site.
l 3.
Conceptual Differences Between Appendix 1 and the EPA Proposed Standards
(
l There are substantial conceptual differences between the " design objective" and " limiting conditions for operations" features of the NRC b
10 CFR Part 50 Appendix I and the standards presented in the EPA proposed l
40.CFR Part 190. The design objectives of Appendix I are values which NRC has selected with due consideration of technical feasibility and cost L.
ef f ect iveness.
Design object ives are values which the designers and the I
1 l
operators of the facility are to use in selecting station features and t
operating procedures.
A substant ial technical ef fort was undertaken by NRC in order to provide a data base for defining design objective values.
1 i
Representative values were selected for each of the numerous parameters I
which are required to be considered in order to estimate the quantities of i
each radionuclide which might be released and the exposures and doses which might occur as a result of the release.
i i
r l
~
- )
NRC recognized that each parameter could have a range of values and the selected value was believed to be " realistically" conservative but any particular facility, depending on actual experience, might have greater or lesser releases or impacts than predicted by analytical models used by the NRC staff. NRC also recognized that any particular facility could experience operating difficulties more severe than those assu ed in develop-ing the staff analytical models.
In recognition of these difficulties in predicting impact, the NRC Appendix 1 of 10 CFR Part 30 provides for
~
operating flexibility between the " design objectives" and the " limiting conditions" which are reflect ed in the " technical specifications which define plant operat ing limit s.
If the limting conditions are exceeded, the matter to the NRC, decednine the j
=Fneustat ipn personnel must report and determine a course of action which will reasons for the higher releases, reduce the releases to the design object ive levels.
Inis may be viewed as a graded scale of action rather than a limit.
In contrast, the values proposed by the EPA in 40 CFR Part 190 are limits rather than design objectives, and if they are exceeded the facility presumably would have to cease operat ions unless the SRC made a " variance" finding that the release was unusual, of a temporary nature, and the societal interests would be served best by continued opera: ion.
4.
Direct Radiatiln Exposure f rom Onsite Sources The proposed EPA dose limits include dose contributions from direct and scattered radiation arising from radioactive marerials which are con-fined within onsite structures.
Appendix I defines as lov :s reasonably achievable design objectives for radioact ive materials in effluents and I
i
P _.
I l
j 7-i 1
does not address direct radiation.
Dose contributions from th'
..urce 1
uher the Draft i
- would be additive to the doses arising' from ef fluents.
1 Environmental Statement. nor the referenced technicai documents provide
~
radiation and adequate bases for limiting the combined dose due to direct
. radionuclide discharges to the proposed limits.
1-5 Studies of the direct dose due tc N-16 in BWR turbines show that the dose rate f alls of f rapidly with distance from the turbine building.
and, therefore, does not represent major source of population. exposure.
Individuals residing near the site boundary could receive whole-body dose contributions from this source.
The magnitude of this exposure is very I
dependent upon plant design conditions (power level, turbine design and shielding, equipment orientation, etc. ), upon the geometric relationship of the receptor to the source (distance, direction, and orientation to the turbine axis), and upon the nabits of the exposed individual. such as j
the type of residence (which determines shielding) and the amount of time i
J spent at that location (occupancy).
Because of the multitude of factors which can affect the exposure, it is difficult,to specifyLthe magnitude for j
of the individual dose contributed from this exposure pathway except l
1 specific sites and plants. Appendix A provides caleclations which indi-care the potential magnitude of these doses. Although parametric studies i
6,7 of turbine shielding have been performed, the costs of backfitting shielding installations would be highly dependent upon individual plant Because of the dif ficulty in formulating a general
' design characterist ics.
1 model for estimating turbine shine, this source of exposure is addressed l.
by NRC on a case-by-case basis in its licensing actions.
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I'
. 5. Fuel Reprocessing Plante - Thyroid Dose Rates
%e AEC (now the NRC) staff initiated comprehensive engineering, In 197.
environmenta and cost studies to provide part of the data base for establishing "as low as reasonably achievable" levels of radioactive
~
8 material in ef fluents from fuel reprocessing plants.
The initial step in the studies, which were perfor=ed at the Holifield National Laboratory (formerly tiic CENL), was to develop a :odel fuel reprocessing plant typical of current design and operation using present The cost /
licensing limitations on the release of radioactive caterials.
benefit of decreasing the release of radioactive wastes through the use of e-b e -
m.e - ;:: =;;W -e f f ect ive radwaste syst ems was analyzed.
Decontamination The factors and source terms were evaluated for each radwaste system.
i radwast e syst ems. ranged from present practice to the foreseeable limits of available technology and were analyzed with respect to nor..a1 operations.
The technology of several of the radwaste systems considered has not been i
demonst rat ed on a product ion basis, and those systems, therefore, are not j
available for 'immediate application. Thus, some of the radwaste synees assess:ent might not that were considered for purposes of a cost-benefit achieve projected removal ef ficiencies with demonstrated practicability.
i Radiological impact on the environment depends upon effluent and site Two
. characteristics, population distribution, and land and water uses.
site regimes, similar to sites previously approved by the AEC, were select ed for the study in order to assess tre range of impacts fr x site-related charact er ist ics:
a site on a plair, in a rural southeastern coastal area r
p 1
t e
l I
i i \\
into an estuary; to a continuously flowing stream which empties f
adjacent i
ent adjacent and a site located on a plain in a rural midwestern env ronm i
into a large river. Human l
i to a continuously flowing stream which empt es i e were hypothesized i
activities and land and water uses for each s te reg m thways. Doses from and analyzed to determine potential radiation exposure pa i iduals in the vicinity identified exposure pathways were calculated for ind v for the population within 55 miles of the. plants, Hypo-of_the plants and ion, and to organisms near thetical doses to individuals, to the populat i
i fuel reprocessing plants were evaluated for interaction of rad o i
f in effluents from the plants with food and water and irradi I-material Dose models and pathways used in the study to persons in the environs.
with those used in the licensing of assess exposures are consistent from proposed activities.
f acilities to evaluate the environmental impact idwestern and southeastern Average meteorologic data' from representative m h
ic dispersion factors coastal regions were used to calculate average atmosp er f
ion. The dose for use in calculating doses to individuals and to the populat i
ificantly higher than commitments calculated for these sites might be s gn introduced int are actually experienced owing to the conservatism those that lieu of definitive data from operating experience.
the calculation i~
l dose The results of these studies indicate that the maxi t d at a via the milk pathway to the thyroid of a child loca e commit ment could approach 500 mrems per year durin distance of 0.5 mile from the plant that reprocessed fuel cooled for 160 dayr equilibrium operations of a plant
?
I i
4 t
l !'
l l
is due to the fraction of_this estimated dose commitment A significant Therefore, variation in cooling time beyond 160 days release of 1-129.
The ALAP studies l
would hav,e very lit tle effect on estimated dose rates.
t i
r year at a the dose could be reduced to about 190 mrem pe 8
indicate that (aboat S3.80 per of approximately $35,000 I
total annual operating cost i ular resin rad-l person-thyroid-rem on a population basis) using macroret c r
1j It should be noted that only preli=inary i
f waste treatment equipment.
iticular laboratory - studies have been made.of the performance of thes icability of Development work would be needed to confirm the pract I
resins.
tional ici exchange the process, which is similar otherwise to conven i n and CMmu,,- a and t o establis.h' suitable' methods for resin regenerat o
- "'4-----
pr v... ;,
The elapsed time to handling of the resins and the spent regenerant.
timated to be
' demonstrate the practicability of this process has been es 8
initiation.
three years from project 30 this dose rate could be reduced to less than The staff believes that iodine during disolution l
mrem per year by modifying the processing to evo ve equipment. This process is not complex, and providing additional rreatment would be used in a commercial reprocessing and conventional equipment The process has been successfully demonstrated on a la plant.
and a demonstration of the process However, engineering development scale.
i recaired. It is with irradiated LWR fuel and dissolver solut on are procure:ent and design engineering, equip =ent the development est imat ed that ll up and testing, and integration into the overa and inst allation, start 5 years from proje::
f could reasonably be accomplished in about plant ' cir cuit i
. ~ _._ ___
m s
t e
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i 3
initiation in view of the simplicity of the process and the use <
i I
l I-Operation of this aquipment could require an convent ional equipment.
8
($130 per person-thyroid-annual operating cost 'of approximately $275,000-l rem on a population basis).
Recent public hearings have been conducted on the environmental of the Barnwell Nuclear Fuel Plant pursuant to the National Environ-impact The staff has estimated that normal mental Protection Act of 1969'(NEPA).
operations of the Barnwell Nuclear Fuel Plant could yield maximum d inhalation f
thyroid dose rates to the thyroid of an infant via the milk an 9
This dose rate has been estimated for a pathways of 88 mrema per year.
a distance of 1.5 miles from the facility (i.e., the closest I'
location at 1
uncontrolled distance from the plant).
On the basis of the above studies, and depending on the location of compliance with the proposed EPA standard nearest "real" cow, it appears that i
- ble, of 75 millirems per year to an individual's thyroid may not be ach eva 2 years as required by with practicability a consideration, within the next the EPA report, which is stated to provide L
the EPA standard. We not e that hat the the technical backup for the proposed standard, acknowledges t f
from spent fuel technology required to control iodine and krypton releases i
(EPA-520/9-7 3-003-D, Table B2, page B15).
1 reprocessing plant s is " unproven."
plants designed and approved af ter 1980 could However, it is likely that l
d but comply with the level of exposure proposed for 1980 in the standar,
4 i
require additional time to modify (backfit) s ene plants then operating might 1
A l
1 I
equipment.
l
)
s d.
Fuel Reprocessing Plants - Quantities - '
.29 Released
,-er gigawatt-year electrical for the 6.
_ EPA proposes a standard of 5 mci date of January 1,1983 i
release of I-129, 'with an ef fective imple=entat on idera-the Holifield National Laboratory include cons f
Studies carried out at i i dine, I-129 (half life =
tion of the control of the long-lived rad o o the use of treatment systens f
7 8
The studies indicate that 1.6 x 10 years).
129 releases to incorporating macroreticular resins, could contain I-i cost of 62 mci per gigawatt-year electrical ar an annual operat ng Further NRC staff analysis indicates
$35,000 for a model plant.
ice in about 3 years from about this-improvement can be reduced to pract The addition of iodine evolution equipment to the that i
""r#6 Te c t-init iat ion.
f reducing I-129 releases i, [
--reprocessing system is believed to be capable o I
l and is f
1.6 mci per gigawatt-year electrical for a =odel p ant to abcut in annual operating costs.
estimated to require approximately $275,000 to practice is expected to require l
Reduction of this advanced equipment Therefore imple=entation of the initiation.
5 years from project for iodine-129 appears to be about
~
limit proposed 5 mci per GWe-year effluent achievable by 1983 d in relation to thyroid The improvements listed above have been discusse The EPA proposed standards also doses of individuals from radioiodine.
i the i al. We expect that address 1-129 releases per gigawatt-year elect 1
installation of radwaste treatmentld satisfy the proposed standards l
thyroid dose rate standards also wou i
f related to 1-129 release quantity.
l t
i 4
4 7.
Uranium Mills - Or-sose Rates The. functio" uranium mills is to extract uranium in concentrated form f sa naturally occurring ore deposits which generally contain three to six lbs. of U 0 per ton of ore (0.15 to 0.30% U 0 ).
In addition to 38 38 uranium, the ores contain other radioactive constituents, such as thorium-230, radium-226, radon-222, lead-210, etc., whic'a are radioactive decay products of uranium.
i At the beginning of 1974, there were 15 c:. n;ing mills in the United States, plus one mill on a standby basis.
Information regarding these mills is provided in Table 11.
The nominal capacities of the 10 mills range from 400 to 7000 tons of ore per day.
i b
TABLE II.
URANIUM MILLS IN THE UNITED STATES IN 1974
" Nominal" Capacity Stat e Status of Mill No. of Mills Short Tons of Ore Per Day New Mexico
- Act ive 3
13,500 Wyoming Active 7
9,050 Coloradoe Act ive 2
1,750 Wa sh ingt on*
Active 1
400 Texas
- Active 1
1,750 Utah-Active 1
500 TOTAL 15 26,950 l't ah Inact ive 1
1,500 dAgreement: states L
1 F
l
-e
. crushed and then a mill, it is first After ore is received at Af ter the ore has reached a fine sand-slur ry.
finely ground into a wet is contacted with chemicals which selectively f
like consistency, it lids.
The barren dissolve or leach the uranium from the finely ground so l
solution and nant solids (tailings) are then separated from the preg I
solution d)
The pregnant pumped to waste arcrage areas (tailings pon s.
The stripped and purify the uranius.
is then chemically treated to extract y the solid waste solution is then used as the pumping fluid to conve tailings to the tailings pond.
ills and the i
,m___.
" " w.
.m to characterize the locale of uranius m
!wo pricary sources L" "_
" ~
- n is important are released.
type of radioactive materials that These h
ic environment.
contribute radioactive materials to the atmosp er d particulates (1) the release of ef fluent s containing raden an stacks following in-plant are:
carrying radioact ive material from the discharge and (2) the escape of radon gas treatment; collection and effluent i l fro dust of particulates carrying radioactive cater a and the wind transport the r ailings area.
from the standards Doses from radon are specifically excluded presently available to control Practicable means are not proposed by EPA.
stacks or tailing areas.
releases of radon from either mill dischargecollectio l
The opplication of existing dust i h e
from the releases of airborne particulates from =ill d doses EPA.
stacks to within the standards proposed by p
l
_.__.m_.
w 4
The major dose contribution' from uranium milling is from wind The tailings transported particulates from railings reten' tion systems.
I' uranium mills are constructed similarly to those retention systems at 11 In the usual of other ore dressing and hydrometallurgical plants.
case an initial earth dam is construct'ed using native soils or mine l
Tailings slurries are then discharged along t1'e inner. edges of l
l wastes.
the embankments.
Tailings retention systems range in size from a few acres to hundred During the construction of acres containing millions of tons of railings.
substantial. areas of railings and operation of railings retention systems, i
i seepage, and drainage of the liquid will form beaches due to evaporation, l-lower elevations within the i
fraction of the waste slurry by grav ty to Thus, as tailings become exposed by I
overall waste retention system.
beach formation within these waste retention systems, the finely grou 1
i become solid railings, containing the radioactive descendants of uran um, This erosion, along with the diffusion of radon subject to wind erosion.
from railings systems, results in the dispersel of radioactive mater into the surroundings of uranium milis.
l Environmental surveys in the environs of uranium mills have been ill based on the collection and analyses of airborne samples collected b licennees, an AEC program to determine airborne concentration 12 closed mills, an AEC-PHS active materials around tailings piles at 13 t o determine radon concentrations around such systems, sponsored program l
inact iv-and an HEW evaluation of the' potential ef fects of unstabilized i
f I
1 i
I l.
i
l c
. 14 In addition, limited calcule' s
piles on tne Colorado River Basin.
to the National Environmental Poli at to have been made pursuant son only from milling estimate potential exposures to individuals by inhal 15 three new mills commencing operations since 1970.
activities at and environmental studies have also been initiated at Engineering, cost, 16 under the direction of the NRC for the tne Holifield National Laboratory purpose of providing information on "as low as reasonably achievable" effluent releases from uranium mills.
12 of airborne concentrations of radioactive The AEC measurements caterials around railings piles at inact ive mills indicate that airborne concentrations of thorium-230 at 1500 feet from a tailings pile, which had only been inactive a few months and which contained significant mois-2 0 l imi t s. -Th i s-co r.re s pA _,,_, m ture, averaged 55; of applicable 10 CFR Part 825 mrem per year from inhalation of thorium-to a lung dose rate of about in such an environment.
i 230 alone to an individual continuously present i
inactive mills are more prone to wind f
It is recognized that tailings at i
erosion than those at active mills.
The question of ALARA releases from uranium mills is under active study by the NRC staff.
i as low as reasonably achievable" studies performed by HNL estimate d
Ihe 0.5 the total maxi =um annual bone dose rate to a hypothetical individual at 1
miles from a tneoretical model operating uranium mill and tailings area I
in Wyoming to be 1060 m' em per year, assuming total occupancy at that r
It is 100% of the food consumed is produced locally.
location and that this dose rat e overe.t imates reality because of the sparse recognized that
4
~
the unlikely assumption that population in the vicinity of most mille However, the subject of real
~
scally.
an individual obtains all his fe i
l sions
' doses to real people will s squire further study before f rm conc u l
lly can be reached with regard to establishing the conformance to genera uranium mills.
applicable limits as they affect of environmental impacts from uranium mills 15
- Recent evaluations d
pursuant to NEPA resulted in the calculated dose rate equivalen in Table III.
15 ESTIMATED OFFSITE DOSES FROM URANIUM MILL AIRB IABLE III.
Dose (mrem / year)
Bone Lung Location Mill 4
38 38.6 Petrotomics Outside Fence
'42 23 Ranch Sumeca 1
3.4-12 Ranch Highland 0.4 1.0 Shirley Basin Ranch These are from inhalation only.
These calculated dose rates result 20.
a small fraction of the 3 rem bone and 1.5 rem lung limits of Part ides at The boundary dose rates are hypothetical, since no individual res and The dose rates include radionuclides from the m the site boundaries.
include radionuclides that have beco:e mine ventilation system,s, but do not Again, addit ional studie.* would airborne owing to wind erosion of railings.
be required to identify the dose to a real individual.
A
. 8.
Re:cval
. ate Gases from fuel Reprocessing Plant Effluents
.. tacipal concern arising from the release of noble gases from T
_ processing plants (particularly Kr-85) is the dose commitment (man-rem) delivered to populations. Over the period 1980-2000, the United States would contribute approximately 25% of the Kr-85 dose commitment to the world population. Thus, if the United States were the sole nation to require r.oble gas removal from reprocessing plant effluents, the desired i
consequer:es of control would be largely negated.
Similarly, the costs associated with reductions in dose commitments may be related to both the j
United Stat es population and that of the world.
Estimates of these costs are provided in Table IV.
TABLE IV.
COSI ESTIMATES PER MAN-REM REDUCTION OF KR-85 DOSE COMMITMENT FROM U.S. LWR REPROCESSING PLANTS
..g
... : a ~.
a=
1 Cost in Dollars Per Man-Rem Reduction Year No. of Plants U.S. Population World Population 3
3 holdup Holdup and BF Holdup Holdup and BF 1975 0
1980 0
1985 2
29,800 36,500 352 393 1990 L
19,900 26,500 228 277 1995 6
20,400 25,000 224 249 2000 11 19,700 23,500 204 222 t
l.
In addition t o SFS, AGNS, and KFRD plant s.
2.
In dollars of 1973.
3.
Plants built prior to 1983 backfitted (BF) to recover 99% of the krypton in the fuel received.
I 1
l
b 1
As may be seen in Table IV, the costs per man-rem reduction in dose to the population of the United States is about a factor of 90 greater tnan that to the worldwide population.
An interim value of $1,000 per man-res and $1,000 per man-thyroid-rem are specified in Appendix I for judging the cost effectiveness of ef forts to reduce population doses.
Kr-85 removal equipme nt installation and operation would not be cost-ef fect ive when con-sidering the U.S. population dose from Kr-85.
Only in terms of world popula-tion can the installation of Kr-35 removal systems be argued as justifiable in terms of cost effectiveness.
Unilateral action on the part of the United States to remove Kr-85 would have little effect on the dose delivered to the entire world population.
Foreign fuel processing will contribute about 3 times the Kr-85 dose contributed by processing in the United St'ates if Kr-85 is not collected by any count ry.
Given these considerations, it is
)
the view of the staff that the self-imposition by 1983 of Kr-85 removal l
systems upon United States fuel reprocessing plants should be deferred pending resolution of developing standards now in progress under auspices of the l
International Atomic Energy Agency.
A delay in imposing standards for Kr-85 release for the purpose of establishing policy will impose virtually no added risk to any individual.
Estimated dose rates as a result of assumed releases from all worldwide l
facilities of Kr-85 through the year 2000 are about 0.03 mrem whole body 17 per year or about 1/2500 that of natural background radiation.
Skin dose rates for such conditions are calculated to be about 3 mrem per year.
1
l A
4 i.
d
~
he Prior to the i pesition of release standards for Kr-85 with t i
l and operations, the staff believes that i
i invest ents in equipment consequent l risks and alternative
}
i these costs should be exa:ined in terms of soc eta
..c e This view is in cone-beneficial investcents of tne nation's resources.
18 that states "... it is becoming i
- with a conclusion given in the BEIR report j
expend enormously large resources to that society not increasingly important the expense of greater risks that reduce very 'scall risks still furtner, at a cost-benefit analy-l go unattended; suca unoalances may pass unnoticed un ess explored, the decisions will If'these matters are not sis is attecpted.
bitrarily or by still be made' and the complex issues resolved either ar t such since the setting and implementation of standards represen default a resolution."
development While the above considerations appear to be overriding, thed to practice in fuel reprocessing plants shoul of krypton removal ecuipment
== - - _.. ^ ~..
ibility..or_1pggi, - n a be. fostered and continued, particularly in view of the poss the The staff also notes that releases of Kr-85 national agreecents to limit of restricted Kr-65 release by the U.S. could also unilateral require:ent in processing fuel adverse'ly affect'the co=petitive position of the U.S.
i nt.
of foreign countries which do not have such a requ reme 1
compared to that l
noble gas removal. systems appropriate to the fue l
It is expected that in 1983 if appropriate research reprocessing industry could be operational 8
This date, when com-l and develop =ent ef forts were to:be initiated now.
be optimistic.
pliance with the-IPA Kr-85 release standards is proposed, may, i
f i
6 s
- ~ _.
_~
_a on noble gas recovs' Kowever, the EPA proposes that the development m be reviewed in the future to establish tb-octicability of removal
. systems prior to 1983. At present,
,,o noble gas removal systems appear to have the' greatest promise. These systems may be described as the selective absorption and the cryogenic distillation systems.
Description of these l
l systems and' estimated schedules.for their proof of practice certificationt 1
are provided in References 17 through 26.
- 9.. Utility.of the EPA Proposed Standard In 1971, the AEC amended -10 CFR Part s 20 and 50 to include the follovir.;
criteria:
-10 CFR Part 20.1(c) persons engaged in act ivities under licenses... should, in addi-tion to complying with the requirements set forth in [TO CFR Part 207...
make every reasonable effort to maintain radiation exposures and releases of radioactive material in ef fluents to unrestricted areas as far below ' he limits specified in [10 CFR Part 207 as practicable."
t 10 CFR Part-50.34a(s) anuclearpowerreactor)
"... The applicant flor a permit to const ruct shall... identify the design objectives, and the means to be employed, for keeping levels of radioactive material in ef fluents to unrestrict ec areas as low as practicable."
The terminology "as low as practicable" is defined in 10 CFR Parts 20 and 50 to be:
"... as low as.is practicably achievable taking into account the state
-of technology and the economics of improvements in relation to the i
1.'
f s
i l l i
l I
ene health and safety and in relation to the utilization benefit'
.2 of atonic energy in the public interest."
i In 1971 the AIC proposed numerical guidelines for radioactive material in LWR effluents to meet the criterion "as low as practicable." An evidentiar7 public hearing was held on the rulemaking action.
About 4,200 pages 'of testimony, a three-volume environmental impact statement, and
?
I thousands of-pages of written testimony and exhibits were produced in this rulecaking act ion. The public hearing was completed on December 6, 1973, t
and the NRC published Appendix I as an amendment to 10 CFR Part 50 on
- May 5, 19 75. 7thile the rulemaking action was time consuming and, extensive, it per=itted participation by all interested parties and'was responsible
- - -- c for the develop:ent of a subs tant ial data base upon which' 1r sUund'rtrie"~--- -
could be drawn.
Further, the criterion "as low as practicable" which exists in 10 CFR Parts 20 and 5' 0 was applied in the licensing of reactors in,an effective manner during the four-year period that was required to complete the rulezaking process.
Upon completion of the public hearing on Appendix 1, an effort was initiated to develop the generic technical and economic data base for
[
selection of nucerical guides to meet the "as low as practicable" criterion for uranium fuel cycle facilities other than LWR power stations.
While 'a substantial amount of data has been produced from this effort, the I
generic ef fort has not been completed and the numerical guidelines for all 4 -
uraniu: fuel cycle facilities are specified on a case-by-case basia in the i
licensing review.
l l
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l In view of the effective ef fort demonstrated by the NRC to restrict e::po-sures and releases of radioactive material from licensed nuclear facilities to 1.
as low as reasonably _ achievable levels, it appears that the proposed EPA J
l 40 CFR Part 190 would not significantly reduce the population exposure froc j
reactor and fuel cycle ef fluent s, but ir does have significant administ rat ive j
i impacts.in other areas as described below.
)
i
}
- 10. Implementation of the EPA Proposed Standard Among the alternatives to 40 CFR Part 190 considered by EPA was one t
which would set lower values 'for the standard. This alternative was rejected j
by EPA because, as stated in the EPA DES, ... it would impose a large t
l administrative burden on NRC in order to insure compliance."
t 190 become an ef fect ive rule, implementation l
Should the proposed 40 CFR Part of that rule would impose a substantial administrative burden.
The t
following technically substantive administrative problems are representative of those which would be presented to NRC if 40 CFR Part 190 were to become i
a rule.
l a.
Revise 10 CFR Part 20 and the recently amended Part 50 (Appendix I) l to implement 40 CFR Part 190.
t -
)
b.
Revise Technical Specifications for all_ licensed LWR power stations l
I l
to reflect the requirements of 40 CFR Part 190.
l t
' Review all licensing actions to. identify f acilities which will require c.
additional radwaste treatment or other features which will permit com-l i
l 1
pliance with 40 CFR Part 190 and identify methods by which compliance l
l could be accomplished. and demonstrated.
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. d.
Decide, as a matter of policy, wSether the facilities should be designed for current land and water usage by persons in the near vicinity of the station and require backfit or restrictions should usage change, or design for potential land and water usage to avoid the more costly backfitting, operating restrictions, and extensive surveillance requirements.
Determine whether the quantit ies of Kr-85 and I-129 which would be e.
permitted by 40 CFR Part 190 af ter January 1,1983, refer to all uranium fuel processed after that date or only to that fuel which was used to generate electrical power after that date. A finding on this issue could influence decisions on matters such as the schedule for processing spent fuel and similar issues dealing with fuel and waste management.
f.
Provide guidelines on what constitutes "a temporary and unusual operating condition" for a nuclear facility for which the NRC may grant a " variance."
, Guidelines also would have to be provided for judging the " necessity to protect the overall societal interest with respect to the orderly delivery of electrical power" should the need for a variance by NRC be required for a uranium fuel cycle facility.
g.
Review the analytical models currently used by NRC staff to estimate potential doses and consider possible modifications or adjustments for doses to "real people" as stated by the EPA in the DES.
It is actually impossible to determine accurately the actual doses to specific
)
1 individuals owing to the nulviple e<posure modes, the levels which are too low to measure, the mobility of individuals, unique characteristics
\\
l of individuals, and other factors.
l
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h.
Perform studies to deter =ine the relationships be -
releases.of e
oe received by indivi-radioactive caterial and the doses which mig F I
duals in a region where interactions of dispersion patterns from multiple nuclear facilities overlap.
- i. Deter =ine what =odifications on siting criteria for uranium fuel cycle facilities might be required to comply with 40 CFR Part 190.
In view of the low dose limits specified in the EPA proposed standard, distance requirements required to assure compliance for normal operations of l
I the facilities might be more restrictive than those required in con-sideration of serious accident situations.
l
- j. Devise a syst e: for relating release quantities of Kr-85, I-f29, and long-lived transuranic elements to the powe.r generated,by LWR power _
.--,,,.<,.,+,,..,,w...~.-
. stations and allocating permissible release quantities among urantum fuel cycle facilities. Allocation of release quantities among newer and older facilities would be complicated by factors such as possible 1
. competitive advantages which might be realized by older stations, which might not have features which will be included in new facilities, j
i 1
-should they be granted release allotments based on considerations other than fuel burnup quantities.
On the other hand, backfitting of older facilities can be-extremely expensive and place these facilities at a co:petitive disadvantage if the backfitting is required.
If the contributions of the iodine-129 and alpha-emitting transuranics from light-wat er-cooled nuclear reactors would have to be assessed in order to comply wit. ' the proposed standards, tnen a considerable. expenditure of effort i
1 l
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- 26 l
l i
and money would be requ' to measure radionuclides which, in them-selves, contribute.asignificantly to the radiation dose from nuclear l
If the reactor contribution could be omitted, then l
power reactors.
f the standards would represent ef fluent limitations solely for spent fuel reprocessing plants.
Even if the contributions from the reactor facilities were omitted, determination of a priori effluent limitations (such as the technical specifications in NRC licensing conditions) would prove almost impo s s i b l e.
Because these proposed limits are tied to energy production, knowledge l
of the fuel burnup and the thermal efficiency of the reactor (to convert i
thermal energy to electrical energy) would be required for epch baten of l
fuel reprocessed. Because of the variat ion in individual reactor designs, power level, and fuel management practices, it would be nearly impossible to specify, beforehand, the total equivalent energy generated by the 1
annual reprocessing plant throughput of spent fuel.
The reprocessing facility would have to keep a running account of the total activity released to the environment and the total energy which had been generated by the fuel. The ratio of these quantities would have to be computed prior to initiation of processing for each batch of fuel in order to determine whether that batch could be processed without exceeding the Even if a given reprocessing plant were to remain In EPA standard.
l compliance, the ratio of the total activity discharged and the total equivalent energy production for all reprocessing facilities would have to be calculated by NRC for every batch of fuel reprocessed to insure that the overall totals were in compliance.
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- 11. Perspective of the Impact of the EPA Proposed Standard The EPA Draft Environmental Impact Statement (DES)* states that imple-mentation cf the proposed 40 CFR Part 190 would avert an estimated 1030
" potential health effects" wnich would occur if current NRC regulatory practices were to continue.
The DES presents values for the potential health effects attributable to operation of the nuclear fuel cycle through the year 2000 at various environmental radiation protection levels.
Table 10 on page 82 of the DES contains columns which ceurain estimated values based on existing " Federal Radiation Guides," " Current AEC Practice,"
and " EPA Generally Applicable Standards." According to this table, there would be a substantial difference between the values projected under FRC guidance and AEC practice only for short-lived materials where Appendix I has been recognized to restrict releases in effluents to levels bei s the FRC guides.
The values projected under FRC guidance and AEC practice are ide.ntical. for all other sources.
The DES does not present sufficient details to determine the bases for the estimates presented, but apparently the estimates do not recognize that the nuclear facilities have not been operated in a manner which would result in doses to individuals at levels as high as those permitted by the FRC standards nor does it recognize the existence of the "as low as reasonably achievable" criterion which the NRC applies to all uranium fuel cycle facilities and which assures that the dose levels are well below the FRC guides.
l i
l
- Table 10, page 82, DES 1
~
.4.
i i
I In addition, tne potential health effects are estimated assuming a linear nonthresnold relationship of somatic and genetic effects to radiation dose at levels which approach zero and which are delivered at a very low dose rate. The bulk of the health effects are postulated to occur as a result of ir.teFrating the extremelj low doses from long-lived materials to the world's population over several decades.**
' *4ithout a perspective, the estimated 1030 health effects postulated to occur over about 150 years might' appear to be substantive.
Placed in perspective, the est imated 1030 health effects are small, a small number in a statistical sense unen compared to tne billions of such health 1
effects which can be estimated to occur from other causes during the same i
time period.
Table V presents an estimate of the normal incidence;-of-
-=
cancer and serious genetic' diseases of the types referred to as " health effects."
Numerical estimates of " health ef f ects" presented in the Draf t Environmental Icpact Statement for the Uranium Fuel Cycle standard are i
based upon the hypothesis of a linear, non-threshold, dose rate independent relationship between biological effects and doses applied at levels which approach natural backgsound. This is consistent with i
i the reces=endations of scientific authorities in matters of radiation protection. Eowever, experimental data are inadequate to verify or to i
- Table 3, page 12. Environmental Analysis of the Uranium Fuel Cycle, Part III, Nuclear Fuel Reprocessing, EPA-520/9-73-003D, Oct. 1973 j
i l-
t a
'4 deny this hypothesis. An alternate hypothesis is.that the probabili+
low of biological effects.are reduced when the doses are delivere/
dose rates and that an effective threshold exists.
If this alternate
- I hypothesis is correct,.the probability of biological effects at very low i;
dose levels could be zero.
.More, than 93% of the total-body dose commitment,
i which represent essentially all of'the calculated health effects, are s
i-the result of su=:ing doses,far less than one mrem per year to the entire I
i j
population of the world over several decades.
Thus, a fair statement would-be that the expected impact is likely to be within the range from i
I zero to 1030 healta effects, 4
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TABLE V.
ESTIMATED NORMAL INCIDENCE 05' aLTH EFFECTS" IN THE U.S.
AND IN WORLD Period Popuistion Cancer Genetic 1/
2/
7 3/
1970-2020 U.S.
1.8x10 deaths 7
-4/
3.7x10 cases 5/
7 6/
5.0x10 cases 1970-2120-U.S.
1970-2020 World-7/
8 8/
5.9x10 deaths-9 1.2x10 cases 9
-9/
- 3. 0x10 cases 1970-2120 World i
Total health effects (cancer + genetic) cases i
7 U.S.
8.6x10 cases 9
World 4.2x10 cases 1/ A $0 year period was selected for evaluating cancer incidence to cocpare
- with the EPA postulated number of somatic effects resulting from doses from exposures to radiation originating in U-fuel cycle facilities during
.the several decades.
2,/ The population of the U.S. was based on Fig. D.1, p. D-9 of EPA-520/9-73-0033.
-3 3/ A cancer death rate of 1.29x10 per person year from the U.S. was selected
~
from World Health Statistics Annual 1966-67.
4/ The number of new cancer cases was assumed to be twice the number of cancer
~
deaths per the NAS/NRC BEIR Report.
5/ A 150-year period was selected for evaluating genetic disease incidence to correspond to the time period for the EPA genetic estimates.
~
6/ A value of 6% was selected for genetic disease incidence based on esticates
~
in the BEIR Report.
9 7/ The world population was assumed to be 3.5x10 in 1970 and to increase oy l
1.9% per year to be consistent with p D-15 of EPA-520/9-73-003D.
l
-3
~8/ A calcer death rate of 1.22x10 per person year for the world was est i.atec from data in the World Health Statistics Annual 1966-67.
~9/ The U.S. genetic disease incidence (6%) was assumed to apply the woric population.
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. zurther, the 1:nited States will contribut e only about one-quarter of the Kr-f;5 vorldwide inventory from uranium fuel cycle operations which will be the source of these worldwide low-level doses.
Neither national nor international autnorities in radiation protection have specifically addressed the significance of worldwide low-level doses and the need for international control of Kr-85 and similar radioactive sources.
~~ ile the values for normal incidence presented in Table VII are gross
=n estimates, it is clear that rne esticated 1030 health ef fects which EPA postulates to be averted by implementing the proposed 40 CFR Part 190, even if correct, would cost about $100,000,000 to the United States and would_
~
n-:.... w - u represent an increase of less than 0.0003% in the normal incidence',of these health effect s.
i i
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[
l l
i i
i
e 1.
Lowder, W. M. and Raf t, P. D., " Environmental Camma Radiation Exposure Rates from Nitrogen-16 in the Turbines of a Large BWR Power Plant,"
Health and Safety Laboratory, USAEC, New York, October 1971.
2.
Lowder, W.
M.,
Raft, P.
D., and Gogolak, C.
V., " Environmental Gamma Radiation from Nitrogen-16 Decay in the Turbines of a Large Boiling Water Reactor," Health and Saf ety Laboratory, RASL IM 72-1, USAEC, New York, February 1972.
3.
Lowder, W.
M.,
Raft, P.
D., and Gogolak, C.
V., " Environmental Camma Radiation from Nitrogen-16 Decay in the Turbines of a Large Boiling Water Reactor," Health and Safety Laboratory, HASL-271, USAEC, New York, Janua ry 1973.
4.
Hairr, L. M., LeClare, P.C., Ph il bin, T.W., and Tuday, J.R., "The Evaluation of Direct Radiation in the Vicinity of Nuclear Power Stations,"
Environmental Analysts, Inc., Garden City, N.Y., Publication No. 303, June 1973.
5.
Memorandum to Participants in the April N-16 Radiation Surveys at the Arnold and Cooper Nuclear Power Stat ions, W. M. Lowder, ERDA/RASL, June 11, 1975 (and attacnments).
6.
Private Co=munication, James M. Smith, Jr., Nuclear Energy Divis_ ion,.,, _,
General Electric Company, San Jose, California, to Villiau ;.
a.cg*o.,
~ ~ ~ ~ ~ ^ ~ ^ "
USAEC, January 17, 1975.
7.
Private Communication, E. A. Warman, Stone and Webster Engineering Corporation, to J. Kastner, USAEC.
8.
Blanco, R.
E.,
et al, Correlation of Radioactive Waste Treatment Costs and Environmentcl Impact of Waste Effluents in the Nuclear Fuel Cycle for Use in Establishing "As Low As Practicable" Guides - Nuclear Fuel Reprocessing, ORNL-TM-4901, in press.
9.
" Supplemental Testimony Regarding the Health Effect to the Local Population from Normal Operations of the Barnwell Nuclear Fuel Plant (The Reprocessing Facility)," F. J. Congel and K. F. Eckerman, Docket No. 50-332, undated.
10.
Statistical Data of the Uranium Industry, U.S. Atomic Energy Commission, p 62, 1974.
- 11. Merritt, Robert C., The Extractive Metallurgy of Uranium, Colorado School of Mines Researen Institute, 1971.
12.
EASL Technical M'emorandum, 64-14, July 31, 1964.
13.
Evaluation of Radon-222 Near Uran;um Tailing Piles, U.S. Public Health Service, DER 69-1, Marcn 969.
I
s 4
I l
i l
14.
" Disposition and Control of Uranium Mill Tailings Piles in the j
Colorado River Basin," Federal Water Pollution Control Administrati-Region VIII, U. S. Department of Health, Education and Welfare, Denver, March 1966.
l 15.
Environmental Statements for Highland Uranium Mill (Docket No. 40-8102), the Shirley Basin Uranium Mill (Docket No. 40-6622), and the Humeca Mill (Docket No. 40-8084) and the Environ = ental Impact Appraisal for the Petrotomics Co. Uranium Mill (Docket No. 40-6659),
j 16.
Blanco, R. E., et al, Correlation of Radioactive Waste Treatment Cost s and Environmental Impact of Waste Effluents in the Nuclear Fuel Cycle for Use in Establishing "As Low As Practicable" Guides - Uranium Milling, ORNL-TM-4903, in pres s.
17.
"The Potential Radiological Implications of Nuclear Facilities in the Upper Mississippi River Basin in the Year 2000," USAEC, WASH-1209, January 1973.
l 18.
"The Effect s on Population of Exposure to Low Levels of Ionizing i
Radiation," Report of the Advisory Committee on the Biological Ef fect s of Ionizing Radiations, Division of Medical Sciences, National Academy of Sciences National Research Council, Washington, D.C.,
l November 1972.
i 19.
Stephenson, M.
J., et al, " Experimental Denonstration of the Select ive l
Absorption Process.for Krypton-Xenon Removal," Proceedings of the 12th Air Cleaning Conference Held in Oak Ridge, Tennessee, August 28-31, 1972, CONF-720823, Vol.1, January 1973.
20, Hogg, R.
M., "New Radwaste Retention System," Nuclear Engineering International _1_7, 98-99, 1972.
21.
Nichols, J. P. and Binford, F.
T., " Status of Noble Gas Removal and Disposal," ORNL-TM-3515, August 1971.
22.
Bendixsen, C. L. and Offutt, G. F., " Rare Gas Recovery Facility at tne Idaho Chemical Processing Plant," IN-1221, April 1969.
23.
Bendixsen, C. L. and Rohde, K.
L., " Operational Performance and Safety j
of a Cryogenic' System for Krypton Recovery," Trans. Am. Nucl. Soc.,
l 15(1), 96, 1972.
l l
e
r NSha -
6 7 g f.'
I 4
l 24.
Davis, J. S. and Martin, J.
R., "A C ryo ge -
Approach to Fuel Reprocessing Gaseous Radwast e Treatment, ' Trans. Am. Nucl. Soc.,
l 6, 176-77, 1973.
25.
Draft Environmental Statement, Limerick Generating Station, Dockets 50-352 and 50-35 3.
26.
Draft Environmental Statement, Susquehanna Steam Electric Station, Dockets 50-357 and 50-388.
1 i
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j 35 -
l APPENDIX A 16 cal.CULATED N TURBINE DOSES 1-5 Measure:ents at several boiling water reactors have shown that the i
dose rate fro: direct rrdiation falls off exponentially with distance i
according to tne formula:
1
-br D(r) = Ae where D(r) is tne dose rate at distance r in mrem / year, r is the distance l
l from the turbine in meters, and A and b are parameters which are uletermined sww.
j by fitting.tne Mel to experimental data. Th e s e c ons t an t s. are_.h ighl y,n -ne
_v. m..
dependent upon ene turbine building' design and the reactor power level as shown in Table A-1.
At present, these variations are not well understood.
The paraceters generally represent the dependence of the dose rate upon i
distance in the direction of the highest measured dose. The dose rate is l
also related to the direction with respect to the turbine axis so that the i
l doses calculated using those parameters represent upper bound estimates.
1 The exponential nature of the model indicates that the dose rates fall off i
l rapidly with distance.
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TABLE A-1 1-5 EXTERNAL DOSE PARAMETERS DETERMINED FROM EXPERDENTAL FIASUREMENTS Reactor Power Level A
b HWe Code 1
600 1250 0.0132 2
1840 716 0.0088 3
1555 543 0.0091 4
1000 (normalized) 108 0.011 5
1000 (normalized) 125 0.0066 6
1000 (normalized) 858 0.0099 7
1000 (normalized) 2470 0.0161 4
m.,,,.
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m.
m.
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1
. i In order to estimate the doses which may exist at typical reactor sites, i
1 l
the site boundary (exclusion radius) distance and the distance to the j
nearest residence were examined for 13 BWR reactors selected at random.
These distances were measured from the reactor building and not the turbine i
axis, but they give approximate est imatas of the distances which could represent actual site conditions for real reactor installations.
The range of values is represented in Table A-2.
l TABLE A-2 REPRESENTATIVE BWR SITE PARAKETERb i
Average Minimum Maximum I S. E.
1 Site Boundary (meters) 215 1340 650 ; 110 l
Nearest Residence (meters) 430 1560 925 + 115
~
These distances were used with the models in Table A-1 to determine the range of doses which might be expected to occur at real sites and distances.
The results of these calculations are shown in Table A-3.
As can be seen, the majority of the calculations yield doses which are considerably 1
below 1 mrem / year. However, for smaller sites the contributions to the 1
external dose rate could be appreciable fractions of the proposed EPA standard.
The site boundary doses assume continuous occupancy which would not actually occur, but even with a 10% occupancy (
880 hours0.0102 days <br />0.244 hours <br />0.00146 weeks <br />3.3484e-4 months <br /> per year) 1
ik
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)
' TABLE A-3 r
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CALCULATED DIRECT RADIATION DOSES FROM BWR TURBINES Calculated Dose Rate (mrem / year)
Location Distance Model 1
2 3
4 5
6 7
Average (m) l Site Boundary 215 minimum 73*
108*
76*
10*
30*
102*
78*
68*
1340 maximum 40.0001 0.0056 0.0026 <0.0001 0.018 0.0015
<0.0001 0.0039 650 average 0.23 2.4 1.4 0.085 1.7 1.4 0.07 1.0 Nearest Residence 433 minimum 4.0 16 10 0.92 7.2 12 2.3 7.5 1560 maximum
<0.0001 0.0008 0.0003 <0.0001 0.004 0.0002 40.0001 0.0008 925 average 0.006 0.21 0.12 0.0041 0.28 0.090 0.0008 0.10 ohypothetical doses based upon continuous occupancy
.