ML20202F897

Recommends for Commission Approval,Ltr to Be Signed by Acting Executive Director for Operations,In Response to EPA Request for Comments on Draft Proposed Generally Applicable Standards for U Fuel Cycle

ML20202F897
Person / Time
Issue date:	02/11/1975
From:	Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT
To:
References
SECY-R-75-035, SECY-R-75-035-R, SECY-R-75-35, SECY-R-75-35-R, NUDOCS 9902040201
Download: ML20202F897 (35)

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, For: The Coussissioners Thru: Acting Executive Director h operations f31ses0 Lft[

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STAFF COMMENTS Ob EPA PROPOSED STANDARDS FOR Tile URANIUM FUEL CYCLE Category: This paper describes a routine staff action which relates to major NEC policy matters.

i j Furpose To recommend for Cosumission approval a letter to be signed

by the Acting Executive Director D Operations in response

, to EPA's request for consients on its draft proposed generally

applicable standards for the uranium fuel cycle, and to inform the Commission ti at this staff action relates to the AEC/Nfic proceeding for "as low as practicabledguidance for li nt2 water reactor effluents and to the EPA's responsibilities pursuant to tne Federal .iater Follut ion Control Acr.

Issue

Kelationsnio ol' tne proposed EPA standards to the ALAP j proceeding for light water reactors, and tne limiting nature of the proposed standards ou nhC licensing, activities.

I Decision Triteria: The Oh6 policy directive concerning practicability as stated in ene Asu memorandue.

. The pendinr, uRC decision on ALa? guidance for light water reactors.

i Apernatives: 1. Ask i;/A to further delay publishinr, the proposed standards pending ili<C decision on light water reactor ALAP.

2. Respond to u'A wi tn staf f comment s on. trae practicabili ty of the proposed standards and not e that t he. A1.A? r: at t er is er il L pendiny, before t he NRC. 4 discussion: In Sect-it-75-202 the comraissiocers were provideo wito cor,ies 9 g,

of a liot ice ot troposed Rulemaking by t he Et'A, t ne support int k envi ronment al st at e'nen t , the transmit tal letter from Jr'A t o i AEC requesting Regulatory conmenta, the Ash cie

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! deliricating the oFA/AEC interf ace on these matt ers, and a

,, _ l b{iet st ali dijcussion or trp content s of lt ne proposed fule.

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A major policy matter related to the proposed EPA  ;

standards is the ultimate disposition of the as lov  ;

as practicable rulemaking proceeding for light water '

reactors conducted by the AEC and deferred to the  ;

NEC for decision. In brief, if EPA issues the l proposed radiation standards for the uranium fuel cycle as now written, NRC will be, in effect, " bound i in" to something very similar to the staff proposed  !

Appendix I. This follows since NRC is required to l implement and enforce the EPA's standards, and to accomplish that requirement a regulation at least very similar to the staff proposed Appendix 1 would have to be adopted. Indeed, EPA says in its proposed Statement of Considerations that use of the proposed

! Appendix I of the Regulatory staff Concluding St at ement would " provide appropriate and satisf actory 1 implement at ion" of t he EPA standards. l The EPA must soon implement guidelines under the Federal f.

' water Pollution Control Act to be responsive to the recent cecision oy the Tenth Circuit Court of Appeals regarding EPA'a authority to write effluent limitation guidelines.* Such guidelines would define best practicable and best schievable t echnology for limiting radioactive discharges to navigable waters. It is l likely tnat EPA will adopt an edited version of its pro- ]

posed standards for the uranlun fuel cycle, where those -

standards apply to water, as supplemental regulations pursuant to the federal Water Pollution Control Act. Tne l EPA statt has also stated their view that having first l published a proposed uraniun fuel cycle standard in the Federal Kepister will lend credence to subsequent action by EFA pursuant to the FhfCA.

the EPA, at tue request of the Director of Regulation, {

, granted a 30 day extension of the comment deadline to l February 24, 1175. The Oau staff has requested tnat it oc informed of the " tenor of our coament s" when they have l been developed.

fhe proposed E/A standard specifically excludes nuclear i

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! d..m vu. rission is present ly seeking t o have the Tentu Circuit Court of Appeale lecisio- ......w- vy tue -upreme Lourt (see SLct-A-75-63, SECY-A-75-1, and

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• aal cases j to tne future.

Tne proposed stati response to t.ne EPA request for comments is provided in enclosure (1). The staff has found that the scope and format of the standard are in accord wirn the Ash memorandum. The NRC staff finds t hat compliance with the radiation dose commitment limits within the time frame proposed by the E/A cannot now be readily demonstrated for tnree isolated activities within the uranium fuel cycle.

i The information available to the staff suggests that j in these three areas additional engineering solutions l would have to be developed to assure compliance. The response to dPA addresses the practicability of such solutions in the time constraints proposed oy EPA.

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The three areas so identifico by the staff are*

1. direct and scat terea r,amma radiat ion from turbine components at Boiling water Reactors (turbine shine).

l Calculatea and neasurea of f-site whole dose Dody rates due to dirr.ct ano scat tered genma radiat ion from SmRs, taking l

into account reasonable periods of occupancy near the l i site coundary, indicate this source of exposure can be a significant fract ion of the 3roposed EPA standard for

sone small sites with hign puolic access to areas near  ;

! the site boundery. Inst standard limits t he whole body

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dose to 25 mrea per year for real persons from all sources due to normal operations of the entire uranium fuel cycle.  ;

, Ithen the dose contribution from direct and scat t ered genna l radiation is added to the doses from p,as'eous and liquid {

ef fluent s, the 25 mrem / year proposed limit would be  !

i exceeded at some EWK sites. Two effective measures for controlling whole body dose from direct and scat tered i gamma radiation are the increasinp of distance and tne decreasing of occupancy. t.s an alternat ive to these ceasures, sniciding or the source et radiation caa oe usea. Shieldint ot t urnine syst ems may ef fect tne l caint ainacility ano accessioility of equipnent. Inis i source er raditrion dcac was not considered in the ALAP I proceeding for liant water react ors. We are aware or l ongoing worx by toe indust ry comprised et enyineerint 4

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i shine fro- a turbine systems. Ine practice of the staff N ocen to examine engineering alternatives on .a c.se-Dy-case basis for dose estimation.

Consequently, we have only approximations of the costs associated with generic standards which would restrict turbine shine.

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l 2. Radioiodine thyroid dose rates from reprocessing i

plants, l

The staff in recent licensing activities for a reprocessine

! plant (Barnwell) tound that with current technology and

, assuming 160 day old fuel, the of f-site doses are in excess i

of the EPA proposed standard of 75 creme per year to the thyroid. In addition, the staff has an ongoing study to i define "as low as practicable" radioiodine dose rates for fuel reprocessing plants. The ALAP reneric study shows that changes in assumptions on fuel age beyond 160 days  !

do not si Fnificantly alter the calculated doses because of I the contrioution of long lived iodine 129. Tne staff s estimates that technology advances in ef flucnt t re at me nt I systems could be acnieved by 1980, if initiated now, to reauco tae site boundary thyroid dose rate pelow 75 mrem /

year. That date is three years beyond the 1977 compliance date proposed sy EPA.

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3. Jose rates to organs resulting from uranium milling l i

operations.

The tiKC staf t' has an ongoing study to define "as low ns

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practicable *' dose rates for normal uranium milling l operat ions , inis study and recent licensing reports in-dicate that off-site dose rates to organs due to normal milling operations can significantly exceed EPA proposed standards for organs other than t he thyroid, assuming total occupancy.* Jose rates encountered in the surroundings of uranium milline facilities principally result fron, t he air t ransport and sucsequent human inhalation of Madon 222, Inoriun 230, and Radium 22's free tailings piles. While the SEA exempt s An-222 and it s

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! F otal T ic~cupanc~y' is' defined as personal residence around tne clocx, M5 days i

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The practicability of engineering s t and ard s.

solutions for reducing the blowing of tailings piles, l ,

especially in the case _ of operating mills, has been studied. However, there are at present no demonstrated l

. methods that would allow compliance with the EPA standards. The difficulty is associated with the size l I of the piles (on. the order of several hundred acres),

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t he nature of t he tailings (a fine powder when dry),

l the form of the tailings as they come from the mill (a water slurry), and the dynamic nature of an active tailings pond.**

I The NRC st aff' believes that EPA's decision to include limits for releases of krypton-85 in the proposed standard is premature for two reasons: (a) the cost-l benefit . analysis performed by EPA requires the integration of very small individual doses from Kr-85 over the total world population in order to establish cost ef fect ivenes s ,

l and an integral over smaller populations would not sub-stantiate the cost effectiveness of krypton capture; and

! (b) t he capture of Kr-85 ext ends beyond domestic policy considerations to include the willingness of other nations to require Kr-65 collection, a matter which might best be

, addressed under the auspices of the International Atomic Energy Agency. An additional consideration that was not

' included in t he environmental impact statement prepared

. by EPA is the broad issue of what maximum benefit can be achieved by t he commitment of resources to improve man's envi ronme nt . The vast resources ($100,000,000 by EPA's estimate oy the year 2000 for the United States, alone) l whien would be required to capture Kr-85 should be I analyzed in view of other societal benefits which could l be obtained 'by application of these resources to reduction of ot her pollut ant s associated with ' the generat ion or power. In t he me ant ime , we agree wi th f.Pa t hat work should be continued to prove out krypton renoval l

• • The stabilization of inactive tailings piles is the subject of an ANSI standard

- (N313 - 1974) which has been implemented in Regulatory Guide 3.23, November 1974 1

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national agreement to limit releases of krypton-85.

Recommendation: That the Commission note the relationship between the i proposed response to EPA and the AEC proceeding ondas low as practicable" regulations for light water reactors; Note the relationship between the proposed response and the question of EFA responsibility for limitation of radioactive discharges to navigable waters under the 2

Federal water Follution Control Act; I

Approve transmittal of the proposed staff response to the JPA; I

isore that tne 0:1B staff will be apprised by telephone

'o'I~ine tenor of our coament s prior to their tracamittal to EPA; and sore tnar copics of tne response will be transmitted to ihE"JCAE and placed in the NXC public document room.

Coordination: The Offices of disclear Beactor Reputation, .4uclear f.aterials Safety and Safeguards, inspect ion and Lntorcement, and the Executive Legal Director concur in the recommendations of this paper.

Scheduling: for considerat ion at an early Policy Session.

I I DISTRIBUTION:

Central Files RJMattson S/

SD Rdg File RBMinogue l SHS Rdg File LVGossick Robert J. Minogue, Acting Director PStrom Ot fice of St andards Developoent ICR0berts

Enclosure:

Proposed hesponse to LPA i

Cont act : Dr. Koger Fiat t son Ext. 443-6955 Q

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UNITED STATES NUCLEAR REGULATORY COMMISSION W ASHIN GTON. D. c. 20555 Dr. William D. Rowe Deputy Assistant Administrator for Radiation Programs (AW-5SB)

U. S. Environmental Protection Agency  ;

l Washington, D.C. 20460 l

Dear Dr. Rowe:

Tnis is in reply to your 1ctrer of December 27, 1974, to the Director of . Regulation requesting comments on EPA's proposed generally applicable l j

standards for the uranium fuel cycle and associated documents. r We believe that progress has been made on the EPA draft of proposed generally applicable standards for the fuel cycle and that the present ,

i draft is within the intent of dr. Ash's memorandum of December 7,1973, with respect to scope and format.

We note that you has emphasized ia the Notice of Proposed Rulemaking that EPA is not, at this time, proposing revisions in existing Federal rediation protection guidance for the general public applicable to all sources of exposure other than medical and natural background radiation.

All of the activities licensed by the Nuclear Regulatory Commission are now and will continue to be carried out well within the Federal Radiation Council radiation' protection guides.

de understand that the purpose of the draft Notice of Proposed Rulemaking is to establish standards that are applicable only to normal operations of activities in the uranium fuel cycle. Further, the principal bases for the numerical levels in the draf t standards are t'.e relative ef fecti'.aness and cost of the controls available to reduce effluents rather than the acceptability of a given level of exposure based on comparative risks to which the public is commonly exposed from other activities.

As we pointed out in earlier staff discussions with EPA, the practicability of the EPA draft standard can be demonstrated in those areas where the technology is reasonably well proven in practice. In this regard, the AEC has' carried out extensive cost-benefit analyses in the process of deter-mining as low as practicable icvels for plants in the uranium fuel cycle.

For example, we believe that information is available to show that the standards are practicable as they relete to radioactive materials in liquid ih

- anc gaseous ef fluent s from light-water-cooled On the nuclear other power hand, reactors there are f w t ies acilit present plant siting configurat ions. ,

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.O in the uranium fuel cycle for which there is very li' aperating experience or the commercial scale. It becomes more and m v .~ificult to make a finding of practicability as an operating li ' _. set, such as the EPA standard, close to the projected limits c' ..cformance of a tect.c.alogy which has not been proven by operatins- e erience. It is premature to establish generally applicable stand as on a cost-effectiveness basis  ;

where the technology has not been proven. In any case, sufficient margin should be included in any generally applicable standard to take into account the uncertainties of performance of the technology, provided, of course, that the standard is well within existing FRC Radiation Protectios. Guides.

We have the following specific coments to of fer concerning the proposed  !

standards- i l

1. Light-Water-Cooled Huclear Power Peactors.

a. Liquid and Caseous Ef fit.ents We agree that the standards are practicable to control radioactive  ;

materials in liquid and gaseous cf fluents released from nuclear power '

reactors with present configurations of plants on sites. While this is  ;

, the staff view on radioactive effluents from light water reactors, it l should be recog..ized that the definition of as low as practicable for l such effluents is presently pending before the Commission in a rule l making proceeding (PRM-50-2). As pointed out in our staff discussions, i the EPA draft environmental statement does not provide the data or  !

analysis to demonstrate the practicability of the standards as related I to the integrated exposure to an individual from many nuclear power plants l in a given region. While we believe it is practicable to meet these i standards on a regional basis, we urge that the environmental statement be expanded to deal with this subject.

b. Direct and Scattered Radiation fron. Boiling Water Reactor Turbine Systems The design of boiling water reactor turbine systems is such that nitrogen-16, a 6.1 or 7.1 MeV gamma emitter, is circulated through the turbine system. This can be a substantial source of direct and scattered radiation to offsite areas in the case of a small site or a site with high public access (e.g. boating and fishing) to regions near the site boundary. The energy of the radiations and the configuration of the turbine system make it difficult to provide shielding to reduce the radiation to extremely low levels at the site boundary in instances <

where turbine systems design dictates the placement of separators and piping above ground level. The radiation level decreases with distance very rapidly beyond the site boundary, and this source of radiation does not represent a significant population exposure problem. Existing information also shows that exposures to any single individual that frequents an area near the site boundary is not likely to exceed about 5 percent of the FRC Radiation Protection Guide of 500 millirems per I l

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Da . William D. Rowe -

year. Furtba me number of such exposed individuals would be expected j to be ver" 11. Therefore, the potential health risk frc direct and sc at t e- a radiation is extremely low. However, it is not unlikely that the s.posure to a few individuals during normal operations from the combined pathways of radioactive materials in gaseous and liquid ef fluents, transportation, and direct and scattered radiation would occasionally i exceed the EPA standard of 25 millirems per year. As yao know, the I AEC excluded direct and scattered radiation from its propose.4 Appendix 1 rulemaking proceeding. Measures to control this source of ,

radiation are reviewed on a case-by-case basis. We are prepared l to work with EPA to determine the cost-effectiveness level for controlling radiation from light-water-cooled nuclear power reactors.

2. Effluent Releases from Milling Operations Information is availabic to demonstrate that it is practicabic to meet the draft EPA standards for all releases of radioactive material from uranium mills to the environment, except for potential exposures resulting from airborne transport of. particulates from tailings piles. As you know, the NRC staff has an on-going study to estimate as low as practicabic '

l 1evels for normal uranium milling operations. This study has not established a practicable engineering solution for stabilizing tailings piles. For the most part uranium mills are located in remote areas and human occupai.cy is sufficiently distant from the mills that significant exposures ,

are unlikely. We suggest a joint EPA-NRC study to characterize dose commit- l ments to persons living near existing milling facilities.

Exposures from the tailings piles result from the airborne transport and subsequent human inhalation of radon-222, thorium-230 and radium-226.

EPA han recognized the problem in the control of radon from tailings piles of mills on page 17 of the Statement of Considerations. We agree with EPA'.s assessment of the special nature of the exposures from radon and its daughters and believe that the same considerations might apply to thorium-230 and radium-226 from tailings piles. We believe that exposures from all radinnuclides resulting from airborne transport from tailings piles warrant separate consideration until such time as field measurements characterize real dose commitments and engineered systems can be proven in practice to improve stabilization of operating tailings piles.

3. Fuel Reprocessing Plants - Radioiodine Thyroid Dose Rates In recent licensing hearings for the Barnwell Reprocessing Plant extensive testimony was given concerning the current state of technology for removal of

, radioiodine. Our present staff analyses indicate that with current technology the EPA proposed standard of 75 millirems per year to the thyroid assuming

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r.' .m D. Rowe  !

l 160-day old fuel in process could not be met if milk is a pathway of exposure near the site boundary. The NRC staff also has an on going study to l estimate as low as practicable levels for fuel reprocessing operations.

l This study indicates that technology advances can be achieved by 1980 to reduce the level of radioiodine released to well below 75 millirems l' per year through the milk chain. The achievement of the above goal l by 1980 requires policy and financial commitments to proceed within' I

a short time.

4. Chemical Reprocessing Plants - Limits on the Release of Krypton-85 The EPA draft standard provides that effective January 1, 1983, the quantity of the noble gas krypton-85 entering the environment from the uranium fuel cycle shall not exceed 50,000 curies per gigawatt year of electrical energy produced by the fuel cycle. We believe that it is premature for EPA to issue a staadard on the quantity of krypton-85 in the environment. Several important considerations should be fully explored prior to a decision on this issue.

Estimated dose rates as a result of assumed releases of krypton-85 from all the won'd's nuclear facilities through the year 2000 are about 0 03 millirems whole body 'per year or about 1/2500 that of doses from I ' natural background radiation. The United States' contribution is estimated to be about 0 008 millirems per year. Skin dose rates for such conditions are calculated to be about 3 millirems per year and the United States' contribution about 0.8 millirems per year. The additional risk to the individual at these extremely low levels of exposure is so small that health and welfare will not be significantly i changed by the presence or absence of the radiation dose.

The only possible justification on a cost-benefit basis for capturing krypton-85 from reprocessing plants is th< dose commitment (n.an-rem) derived by integrating extremely low individual doses over the world's population. It cannot be justified based on the risk to the U. S. .

population alone. We believe that the following statement of the International Commission on Radiological Protection in Publication 22, Paragraph 13, directly addresses a most important cost-benefit consideration on this issue:

"To decide whether a reduction in dose is readily achievable, it is l

necessary to consider both the social Bain arising from the reduction I and the social costs of its achievement. As yet, the Commission has suggested no alternative to the linear dose-risk relationship for estimating the social gain of a dose reduction. In setting quantitative dose limit s, it is cautious to assume that the slope of 2

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1 . William D. Rowe this linear relationship is obtained by linear ext rapolation from icvels of dose high enough to produce ef fects in measurable amount s.

However, the use of a linear relationship derived in this way for assessing the social gain of a dose reduction is less satisfactory, because the linear relationship implies the same social gain from unit reduction in dose, independent of the level of dose and dose rate. Any likely form of non-linear dose-risk relatienship implies that the social gain of a unit reduction in dose will be smaller over some range of low doses and dose rates than the value implied by the linear extrapolation from the high doses at which human ef fectb have been observed. The linear extrapolation from high doses thus may overestimate the social gains of dose rate and may lead to an expenditure of effort not balanced by corresponding social gains."

Considered from a world-wide standpoint, if all krypton-85 is released, fuel reprocessing facilities in the United States would contribute approximately 1/4 of the krypton-85 dose commitment to the world population. Fuel reprocessing facilities in other countries would contri-bute approximately 3/4 of the dose commitment. Th2s, if dose reduction is to be accomplishiI, it is essential that not only the U.S. but all other nuclear countries require krypton-SS removal from fuct reprocessing i facilitics. For this reason, we believe that this issue should be explored at the international Icvel. Additional questions that should be considered pre: (a) the benefits associated with krypton-85 capture as compared with the potential risk associated with storage and handling of captured krypton-85 gases, and (b) the relative benefit that can be achieved by the commitment of resources to the capture of krypton-85 ($100,000,000 -

EPA's estimate for the U.S. alone) as compared to the benefits which could be obtained by application of these resources to the reduction of other pollutants associated with the generation of power.

We would be pleased to work with EPA in e::ploring these issues with other countries through the International Atomic Energy Agency or other forums to develop a compatible approach on an international basis. In the rec antime ,

we agree that work should be continued to prove out krypton removal equipment in practice in a fuel reprocessing plant particularly in view of the possibility of international agreement to limit releases of krypton-85. It appears that it is technically feasible to have such equipment fully proven and in commercial operation within the time frame of 1983 to 1985, if additional work is initiated now.

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A more detailed discussion of these subjects is contair' . the enclosure to  !

i this letter. '

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There are other matters of lesser import from policy viewpoint , such as the I ,

of the cumulative radiological impact .

question of methodology for assessment l

! from several sites and other details of the draf t environmental statement  !

where technical differences remain to be resolved. We shar* your view that such issues should be addressed and resolved on the record of tbe public proceeding. We plan to submit further detailed comments- in this regard during the public. comment pe riod . Technical questions related to these comments and the enclosure should be addressed to Dr. Roger Mattson (443-6955) in our office of Standards Development.,

Sincerely, i

l Lee V. Cossick Acting Executive Director for Operations

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Enclosure:

l Detailed Discussion l

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.,nd REGULATORY C0FDtISSION STAFF j COMMENTS.OF THE '

ON PROPOSED ..<ULEMAKING ON RADIATION STANDARDS  !

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190) that would The EPA intends to propose rulemaking (40 CFR Part f

for normal operations specify radiation dose and quantity release standards While technical questions remain to be resolved of the uranium ^ fuel cycle.

between the EPA and the NRC, there is sufficient evidence that compliance i h three with the proposed EPA standards can be achieved _ practicably, w t l

exceptions. The exceptions are described below and are related to the f

, At present, in only a dose rate limiting standards for individuals.

f few instances is there potential for members of the general. public to l Those be subjected to dose rates in excess of the proposed standards.

now be areas where compliance with the proposed standards cannot l

l demonstrated' or cannot be assured within the time constraints for compliance l

l follow. Control proposed by the EPA are discussed in the sections that of Kr-85 doses is also discussed in some detail.

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l Direct and Scattered Radiation from Boiling Water Reactors - Whole-Body l

Dose Rates '

! l Steam produced in boiling water reactors is delivered directly l In the reactor, the nuclear reactions N-15 (n,y) to the turbines.

l N-16 and 0-16 (n, p) N-16 take place and the short-lived proJuct

= 7.1 seconds) N-16_ is transported through t he turbine system with

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@ In the decay of N-16 to stable 0-16, energetic gamma radiation the steam.

This highly penetrating radiation con-is emitted (6.1 Mav, 7.1 Mev).

potentially could deliver whole-body doses at rates of stitutes a source that significance to individuals located near the boundaries of several propo l In estimating whole-body doses that might be delivered t o and existing sites. I

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_ members .of the public from the decay of N-16, the empirically derived relationship. I_1207~

(1)

D(r, P) = 0.844fP exp - [~P +0.00892rj This relationship is based upon data and the form of l

has been used. 1,2,3 in their studies of l l al empirical equations provided by Lowder, et l l

Oyster Creek.

-In equation (1):

i D is the whole-body dose for continuous occupancy (mrem /yr);

P is reactor power (MWr);

l r is the distance from the high pressure turbine (m); and  !

4 f is the plant _ utilization factor. i f.

Direct and scattered radiation dose estimates from 4 turbines using For Monticello, the equation (1) have been' compared with measured values.

for the SSW and HE calculated ' values are f airly close to measurements e

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radiais, but underestimate the measured WSW radial values by a factor J

ot 2. The data' for Oyster Creck, being the basis for the correlation, ,

saakce agree with the cal.culated values. The measured values for Vermont are a factor of 2 or more lower than predicted by equation (1). Thus, available measurements support the use of equation (1) as a reasonable estimate of of f-site whole-body doses from the turbine systems of boiling water reactors.

As seen in Table I, the direct and scattered radiation doses to the public at existing or licensed facilities from N-16 alone can approach the standard of 25 mrem whole-body dose proposed by EPA to include all sources within the uranium fuel cycle. The Regulatory staff is aware of no published cost-benefit studit; associated with turbine system layout and shiciding to reduce a

shine. We are aware, however, of preliminary parametric design studies and cost-benefit analyses by architectural engineering firms and turbine suppliers.

For example, recent estimates of N-16 whole body doses for shadow-shielded turbine compunents for a two unit BWR at distances of 1500 and 2000 feet are about 5

120 and 40 mrem per year, respectively. Another shadow shielding parametric study has been reported to the Regulatory staff by an architectural 6

engineering firm. This study employed the QAD and CGG computer codes to In calculate doses due to N-16 sources located above the turbine floor.

the study a worst case situation was assumed in which the moisture-separator-reheater and associated piping were located with the turbine at the turbine deck level of the Auxiliary Building. Various shielding configurations were then assumed. The results of this parametric analysis are relative in nature;

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i.e., they cannot be applied directly to estimate doses from a given l

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plait. They can be used, however,.to qualitatively characterize  :

the shielding required to reduce doses. The result s indic.1t c  ;

.4 concretc l j that combinations of 6 inch thick concrete walls, 30 inch ti-f slabs, 5 inch thick steel slabs, and walls up to 30 feet high would be expected  !

an order of magnitude f to reduce the direct and scattered gamma radiation by about r Shielding noditions for distances of 300 to 3000 feet from the turbine.  ;

y of this scale are roughly estimated by the staf f to cost on the order hundred.

of several/thousand dollars per unit. Before definitive conclusions f are drawn from existing parametric analyses,theirscope would have to be i significantly increased to investigate interrelationships among maintainsbility, 1

accessibility act functional performance of turbine system components, J 1

I which are related to safety and reliability of nuclear power plants, and benefits to be derived from reducing radiation exposures to operating ,

personnel and the general public. 'Se staff understands that related work is ongoing in several architectural engiacering firms, the General Electric Company and an ANSI Committee. The technology of shielding is well known, but its application is not straightforward in this instance and which involves complex geometries, need for access to equipment, highly penetrating gamma radiation. I I

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.- ( l CALCULATED WHOLE BODY DOSES (OCCUPANCY CG;;SIDERED)

TABLE 1. i DUE TO N-16 DECAY IN BWR TURBli4E SYSTM13 l '

.. .j Y R , )  ;

CALCULATED DOSF l

AT OR NEV .. BOUNDARY

.S.I_TE _= esp '

Allen's Creek 0.3 Bailly 25 (steel mill workers) 6 Barton 0.6 Brown's Ferry 5

Brunswick 0.17 (Boating)

Clinton 1

Duane Arnold 1

Dresden 2 & 3 Fitzpatrick-Nine Mi.Pt. 15.5 (Boating) l 1

Grand Gulf 3.5 1

t Hanford 2 3

Hatch 3.3 (Boating)

Hope Creek 5 (Boating)

Limerick 11 (Fishing)

Millstone 1 10 (Fishing)

Monticello 0.2 (Eishing)

Oyster Creek Peach Bottom 2 & 3 2.4 13 (Boating)

Perry 7

River Bend Skagit 6.4

(

l 1

! Susquehanna Vermont Yankee 20 (Residence) i

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11.A. Fuel Repre- y; Plants - Thyroid Dose Rates In ke" - , with the past nractice of providing licensees with guidance tha* as specific as possible, comprehensive engineering, environmental, and cost studies were initiated in early 1973, to form the bases for establishing specific guidance on "as low as pract icable" ef fluent releases 7

from fuel reprocessing plants.

The initial step in the studies, which were performed at the llolifield National Laboratory (formerly che ORNL), was to develop a model fuel reprocessing plant typical of current design and operation using present The licensing limitations on the release of radioactive materials.

cost / benefit of decreasing the release of radioactive wastes through the use of increauingly ef fective radwaste systems was analyzed. Decontamination The

' f actors and source terms were evaluated for each radwaste system.

radwaste systems ranged from present practice to the foreseeable limits of availabic technology and were analyzed with respect to normal operations. Th e.

technology of several of the radwaste systems considered' has not been demonstrated on a production basis, and those systems, t.serefore, are not aval able for immediate application. Thus, some of the radwaste systems that were considered for purposes of a cost-benefit assessment might not achieve i

! projected removal efficiencies with demonstrated practicability.

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Radiological impact on the environment depends upon ef fluent and i site characteristics, population distribution, and land and water Two site regimes, similar to sites previously approved by the AEC, uses. I were selected for the study in order to assess the range of i nnacts l

from site-related characteristics; a site on a plain in a rural southeastern 1

coastal area adjacent to a continuously flowing stream which empties t ,

l l

.into an estuary; and a site located on a plain in a rural midwestern i

environment adjacent to a continuously flowing stream which empties into  ;

l a large river. Human activities and land and water uses for each site i regime were hypothesized and analyzed to determine potential radiation Doses from identified exposure pathways were calenlated f exposure pathways.

f l

r for individuals in the vicinity of the plants and for the population r within 55 mil s of the plants. Hypothetical doses to individuals, to l

the population, and to organisms near fuel reprocessing plants were l

evaluated for interaction of radioactive material in effluents from the plants with food and water and irradiation of persons in the environs.

I Dose models and pathways used in the study to assess exposures are l

consistent with those presently used in the licensing of facilities to evaluate the environmental impact from proposed activities. Average

! coastal meteorologic data froa representative midwestern and southeastern regions were used to calculate average atmospheric dilution factors for use in calculating doses to individuals and the population. The dose l

)

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commitments calculated for these sites are significantly higher than those that een be expected to be delivered in reality. They are, however, estimates of doses that have a low probability of occurrence.

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The results of these studies indicate that the maximum annual i dose via the milk pathway to the thyroid of a child located at a distance s

of 0.5 mile from the plant could approach 500 mrems per year during i equilibrium operations of a plant that reprocessed fuel cooled for 's0 days. f I

Therefore,  !

A significant fraction of this estimated dose is due to I-129. l variation in cooling time beyond 160 days would have very little effect

\

on estimated dose rates. The ALAP studies indicate that the dose could be  !

. 1 reduced to about 190 mrem per ' year at a total annual operating cost of approx 1-l mately $35,000 (about $3.80 per person thyroid rem on a population basis) using  :

i

. macroreticular resin radwaste treatment equipment.

It should be noted thar ,

• l

'only preliminary laboratory studies have been made of the performance l of these macro:sticular resins. Development work would be needed to con-I firm the' practicability of the process, which is otherwise similar to .

. conventional ion exchange processes, and to establish suitabic methods for resin regeneration and handling of the resins and the. spent regenerant.

A realistic schedule for the' practical demonstration of this process would require an elapsed time from project initiation of about three years.

4 The s'taff estimates that this dose rate could be reduced to less than 30 mrem per year with additional treatment equipment (iodine evolution equipment) . This process is not complex, and conventional equipment would u

4

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be used in a commercial reprocessing plant. The process has been i  !

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i successfully demonstrated on a laboratory scale. - l t

l' llowever, engineering development and a demonstre- .t i inn are required.  !

the process with irradiated LWR' fuel and dissolver <

1 It is estimated that the. development and der' engineering, eqvipment j ond testing, and integration j procurement and installation, start u- ,

into the.overall plant circuit could reasonably be accomplished in l i

about 5 years from project initiation in view of the simplicity of ,

the process and -the use of conventional equipment. Operation of this- ,

equipment could require an annual operating cost of approximatcly $275,000  !

l

'($130 per person thyroid rem on a population basis).

j Recent public hearings have been conducted on the environmental J j

impact of the Barnwell Nuclear Fuel Plant pursuant to the National j l

Environmental Protection Act of 1969 (NEPA). The staff has estimated l l

that normal operations of the Barnwell Nuclear Fuel- Plant could yicid maximum iodine thyroid dose rates to the thyroid of an infant via 8

the milk and inhalation pathways of 88 mrems per year. This dose l

rate has been estimated for a location at a distance of 1.5 miles from the f acility (i.e., the- closest uncontrolled distance from the plant).

On the basis of the above studies it appears that compliance wf *h the proposed EPA radioiodine dose standard of 75 millirems per year to an individual's thyroid could not be achieved within the next 2 years.- However, it is likely that the level of exposure proposed in the standard could be complied with by 1980, with the possible exception of existing plants which could require additional time to modify (backfit)

I i I equipment.

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l Fuel Reprocessing Plar quantities of 1 129 Released 11.B. .

.adard of 5 mci per gigawatt-year electrical EPA proposes r for the relers. of I-129, with an ef fective implementation 'date of 3

i L  !

I ' January 1, 1983. .

Studies carried out at the Holi the field National i l

Laboratory include consideration of the control of/long-lived racioiodine, >

7 7 (T , = 1.6 x 10- years). The studies indicate that the use of I-129  ;

1/2 treatment systems incorporating macroreticular resins, could contain l

an annual operating f 1-129 releases to 62 mci per gigawatt-year electrical at Further NRC staf f analysis cost of : about $35,000 for a model plant.

l indicates that this improvement can be reduced to practice in about i

' 3 years from projact initiation. The addition of iodine evolution l

equipment to the reprocessing system is believed to be capable of 1

I f  ;

t 1.6 mci per gigawatt-year electrical .

reducing I-129 releases to about j i

j for a model plant and is estimated to require approximately $275,000 in l

\

l Reduction of this advanced equipment to practice annual operating costs.  !

from project initiation.  ;

is expected to require about 5 years l The improvements listed above have been discussed in relt. ion to individual radioiodine thyroid doses. The proposed EPA standards We expect l also address 1-129 releases per gigawatt-year electrical. i treatment systems to satisfy proposed that the installation of radwaste individual thyroid dose rate standards would also be expected to I

i satisfy proposed standards related to I-129 quantity releases.

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III.

am Mills - Organ' Dose Rates The function of uranium mills is to extract uranium in concen-trated ' form from naturally occurring ore deposits which generally contain three to six lbs. of U 0g3 per ton of ore (0.15 to 0.30% U3 B ).

C In addition to uranium, the ores contain other radioactive constituents, such as thorium-230, radium-226, radon-222, lead-210, etc. , which are descendants of naturally occurring uranium.

At the beginning of 1974, there were 15 operating mills in the United States, plus one mill on a standby basis. Information regarding these mills is provided in Table II. The nominal capacities of the 9

mills range from 400 to 7000 tons of ore per day.

TABLE _I1, l

f URANIUM MILLS IN THE UNITED STATES IN 1974 "NOMINAf," CAPACITY STATUS OF MILL NO. OF MILLS SHORT TONS OF ORE PER DAY STATE Active 3 13,500 New Mexico

• Active 7 9,050 Wyoming Active 2 1,750 colorado

• Active 1 400 Washington

• Active 1 1,750 Texas

• Active 1 500 Utah-15 26,950 TOTAL t

1,500 Utah Inactive 1

• Agreement States.

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is first crushed and then After ore is received at a mill, it into Af ter the ore has reached a finely ground l/ a wet slurry.

i l hich is contacted with chem ca s w  !

fine sand-like consistency, it I finely ground i selectively dissolve or Icach ' the ur anium from the The barren solids (tailings) are then separated from the solids. (tailings ponds) .

pregnant solucion and pumped to waste storage areas and purify I solution is then chemically treated to extract The pregnant f The stripped solution is then used as the pumping fluid to i the uranium.

convey the solid waste tailings to the tailings pond.

l It is important to characterize the locale of uranium mills d Two primary and the type of radioactive materials that are release .

h ric environment.  ;

sources contribute radioactive materials to the atmosp e

' l (1) the release of effluents containing radon and particulate These are: k following in-plant l

carrying radioactive material from the discharge stac s treatment; and (2) the escape of radon gas and  !

(

' dust collection and ef fluent l dioactive material from l the wind transport of particulates carrying ra l l

l the tailings area. d d Doses from radon are specifically excluded from the stan ar s  ;

i Practicable means are not presently available proposed by EPA. stacks or i h to control releases of radon from either mill d sc arge I i

tailing areas.

f

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The . application of existing dust collection techniques w j f i d' a ge I

doses from the releases of airborne particulates from m ll l stacks to within the standards proposed by EPA. l id  ;

?

The major dose contribution from uranium milling is from w n  ;

l t The railings transported particulates from tailings retention sys ems. .

l. i ilarly to those retention systems at uranium mills are constructed 10 s m f In the usual i of other ore dressing and hydronetallurgical plants. f i ils or mine i case an initial earth dam is constructed using nat ve so l

Tailings slurries are then discharged along the inner edges  ;

wastes.

j of the embankments.

l Tailings r.tention systems range in size from a few acres to During the 4

hundreds of acres containing millions of tons of tailings.  !

l i t s substantial construction and operation of tailings retent on sys em ,

L i seepage, and areas of tailings will form beaches due to evaporat on, lower drainage of the liquid fraction of the waste slurry by gravity to Thus, as tailings i elevations within the overall waste retention system. l become exposed by beach formation within these vaste retentian dioactive descendents the finely ground solid tailings, containing the ra This erosion, along of uranium, become subject to wind erosion. in the dispersal l l

with the dif fusion of radon from tailings systems, resu ts i ills.

of radioactive materials into the surroundings of uran um m 4

I

. . - ~ . . - . . ~ - . . - - - - - - . . . - . . . - - - - .- . _ . . _ . . . . - -

.. 'e', ..

i s Environmental surveys in the environs c E ..uum mills have been l

! of airborne samples co11ceted by mill based on the collection and ans' licensees, an AEC progra- s determine airborne. concentrations of radioactive 11 f l an AEC-PHS sponsored l

I materials around tailings piles at closed mills, l

12 program to determine radon concentrations around such syst0ms, and a l ~

l HEW evaluation of the potential ef fects of unstabilized inactive piles 13 In addition, limited calculations have been on the Colorado River' Basin.

to estimate potential made pursuant to the National Environmental Policy Act

' exposures to individuals by inhalation only from 14 milling activities at Engineering, cost, a nd -

three new mills commencing operations since 1970.

the llolifield National environmental studies have also been initiated at f providing i

. Laboratory under the direction of the NRC for the purpose o l

' 15 information ~on "as low as practicable" effluent releases from

' uranium mills.

Airborne samples collected by licensees have in the past generally These assay results have been been assayed for natural uranium only.

compared to paragraph 4 of the Note to Appendix B of Part 70 for purposes DFR 20.

of showing compliance with the requirements of Section 20.106 of 10 Insof ar as concentrations of airborne uranium are concerned, these survey results indicate that concentrations around uranium mills are generally well'below the limits specified in Column 1, Table 11, Appendix B of Part 20.

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12 conducted by AEC-PHS the significant In .adon studies tailings piles at the sites st died were not

~1usions reached were that don concentrations i

significantly af fecting the natural local atmospher c ra yet i i beyond a distance of 1/2 mile in the prevailing iles atwind d rect i.earby ons, offsite concentrations of airborne radon resulting from the p 20 limit for releases of- radon int locations could exceed 1 pCi/ liter (the Part That is, natural radon concentrations in some locati unrestricted environs).  !

can exceed the Part 20 timits.11 of airborne concentrations of radioactive The AEC measurements airborne inactive mills indicate that materials around tailings piles at from a tailings pile, f 1500 feet concentrations of thorium-230 at hs and which contained . significant which had only been inactive a few mont 20 limits. This corresponds moisture, averaged 55% of applicable 10 CFR ,

from inhalation of thorium- l to a lung dose rate of about 825 mrem per year l in such an environment. i to an individual continuously present 230 alone tailings at intetive mills are more prone to wind It is recognized that erosion than those at active mills. i the total The "as low as practicable" studies performed by llNL est mate individual at 0.5 miles from maximum annual bone dose rate to a hypothetical ilings area in Wyoming a theoretical model operating uranium mill and ta t that location and to be 1060 mrem per year, assuming total occupancy a i

l l

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" .004 of the food consumed is produced locally. It is recognized i

that this dose rate overestimates reality because of the sparse population in the vicinity of most mills and Ihe unlikely assumption that an individual obtains all his food locally. However, the subject of real doses to real people will require further study before firm conclusions can be reached with regard to establishing the aonformance to generally applicable limits as they affect uranium mills.

14 Recent evaluations of environmental impacts from a uranium mill pursuant to NEPA, resulted in the following bone dose rate equivalents:

ESTIMATES OF BONE DOSE EQUIVEENTS FOR Tile HUMECA HILL Location Bone Dose Boundary, 1500 ft. 124 mrem /yr SW of main shaft Boundary, 8000 ft. 221 mrem /yr i NW of vent shaft Redd Ranch 42 mrem /yr  !

These dose rates result from inhalation only. The boundary dose rates are i

hypothetical, since no one resides at the site boundaries. The dose rates include radionuclides from the mill and mine ventilation system, but do not include radionuclides that have become airborne due to wind erosion of l

l tailings.  !

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o IV.- 1-c. oval of Noble Geses from F'uel Reprocessing Plent Effluents The principal concern' arising from the release of noble gases from reprocessing-plants, (particularly Kr-85), is the dose commitment Considered from a worldwide standpoint (man-rem) delivered to populations.

an were the United States and foreign fuel reprocessing facilities to re from removing noble gases over the period 1980-2000, the United States would contribute approximately 1/4 of the Kr-85 dose commitment to the world population. Thus, if the United States were the sole nation to require noble gas removal from reprocessing plant ef fluents, Similarly, the desired consequences of control would be largely negated.

the. costs associated with reductions in dose commitments may be related Estimates to both the United States population and that of the world.

of these costs are -ovided in Table III.

TABLE III 6

f COST ESTIMATES PER MAN-REM REDUCTION OF KR-85 DOSE COMMITMENT FROM U.S. LWR REPROCESSING PLANTS l j 2

l 1 l COST IN DOLLARS PER MAN-REM REDUCTION YEAR NO. OF PLANTS WOLLD FOPULA1: UN l U.S. Por0LA110N 3

! 3 I HOLDUP AND BF_ HOLDUP y0LDUPANDBF {

HOLDUP 1975 0 L980 0 352 393 l 29,800 36,500 1985 2 228 277 l 19,900 26,500 1990 4 224 249 20,400 25,000 1995 8 204 222 19,700 23,500 2000 11

1. In addition to NFS, AGNS, and MFRD plants. l

2. In dollars of 1973.

3. Plants built prior to 1983 backfitted (BF) to recover 99% of the krypton in the fuel received.

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.. on in oose l As say be seen in Table 111, the costs per man-rer l

.. tor of 90 greater than to the population of the United States is about that to the world-wide population. Valo- asigned by a number of sources I

to the man-rad range from $10 to $9',s. Even if the upper value were chosen I

to represent the worth of a man-rem, clearly Kr-85 removal equipment l installation and operation would not be cost-beneficial when considering j the U.S. population as a basis. Only in terms of world popuistion l

l can the installation of Kr-85 removal systems be argued as justifiable in term of costs and benefits. Unilateral action on the part of the United States to remove Kr-85 would have little ef fect on the dose delivered to the entire world population. Foreign fuel processing l

will contribute about 3 times the Kr-85 dose contributed by processing in

' the United States if Kr-85 is not collected by any country. Given these considerations, it is the view of the staff that the self-imposition by 1983 of Kr-85 removal systems upon United States fuel reprocessing plants i should be daferred pending consultation with the International Commission on Radiation Protection, the International Atomic Energy Agency, cnd af fected foreign countries.

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 l

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2ra Laau: 3.03 mrem world wide facil' tic. of Kr-85 through the year 200) 17 l radiation.  ;

i whole bod- per year or about 1/2500 that of ac t ur al verk tgr act,c

' to oe about 3 mrem per year, f Skin dose rates for such conditions are calcult. the l Prior to the imposition of release standards for Kr-95 v't- l believes l t

consequent- investments in equipment and operations, the staf f I ik d i

that these costs should be examined in terms ofThis societalview r c s an 1 I

alternative beneficial investments of the nation's18resources. that states f is in consonance with a conclusion gisen in the EEIR report I that society not expend I

"....it is becoming increasingly important further, f I

enormously large resources to reduce very small risks ct ill bl e may f at the expense of greater risks that go unattended; such un a anc If the.e analysis is attempted.

pass unnoticed unicss a cost-benefit f d the .i matters are not explored, the decisions will still be made an f

l since the  !

complex issues resolved either arbitrarily or by defau t "

i l setting and implementation of standards represent such a resolut on.

the development While the above considerations appc. - ta he ovarriding, to practice in fuel reprocessing plants should of krypton removal equipment be fostered and continued, particularly in view of the possibility of international agreements to limit releases of Kr-83. 2 I

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. 9 .

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as .ex' .

&c :n :he It is expected that aiale

.t if : .

4 date, ,

fuel reprocessing indust ry cc i.d be a:; crc ;ar.a1

.3 proposed, may when compliance with the EPA Kr-63 relea;c standards the development

.be optimistic. However, the EPA proposes that tc est.Slish the program on noble gas removal be reviewed in the f utere i l

At pr e s er.t . two practicability of removal systems prior to 1983.  !

Thesc l tiie greatest promise. l noble gas removat systems appear tu have and the cryogenic l systems may be described as the selective absorption l l

distillation systems.

Description of these syster; aa1 cetimated schedules for their proof of practice certifications are provided in

/ References 1; 'hrough 26.

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.; r. tion E.<pasure  ;

1. Lowde r , W.M. and Raf t , F .D . , "Qv ' r n .+a: /. C . Pm-er ?l ent ," [

a '2c : 3 Ratas from Nitrogen-16 in the Tuca;.ts :t?:ev York. Cctober lit.. l Health and Safety Laboratory,' Uf.f i'  ;

" Environmental Gamma 2 .1 Lowder , W.H. , Ra f t , P.D . , ar.d Cogo isk , T ' , of a Large Boiling l Radiation form Nitrogen-16 Decay in the Turdinem USAEC, l f

' Water Reactor," Health and Safety Laboratory , R.iSL TM 72-) ,  ;

New York, February 1972. }

3. Lowder, W.M., Raft, P.D. , and Gogolak, C.V. , " Environmental Camma j Radiation from Nitrogen-16 Decay an the Turbines of a Large Boiling  :

Water Reactor," Health and Safety Laboratory, RAF,L-271, USAEC, ,

New York, January 1973. P

=

l

4. Memorandum, " Radiation Fields Nearby Operating B'JRc," J. Kastner to H. R. Denton, USAEC, July 19, 1973.

5. Private Communication, James M. Smith, Jr. , nuclear Energy E.

to Villiam liiviKreger, sion, i General ~ Electric Company, San Jose, California,  !

USAEC, Jar nry 17, 1975.

Stone and Webster Engineering

' 6. Private Communication, E. A. Warenn, ,

Corporation, to J. Kastner, USAEC. 1

7. " Amendment to Part 50-ALAP for Fuel Reprocessing Plants," Regulatory S'tandards Task FM-183-4, ' in progres s.

i

8. " Supplemental Testimony Regarding the Health Ef fect' to the Local '

I 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.

U.S. Atomic Energy Commission,

9. Statistical Data of the Uranium Industsy,

~62, 1974.

10. Herritt, Robert C. , The Extractive Metallurgy of Uranium, Colorado Schon1 of Mines Research Institute,1971.

11. HASL Technical Memorandum 64-14, July 31, 1964.

4 l

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1

21. Nichols, J. P. and binford , F. f , 'cto- n: 2:eSlc e e 1:<. - .

and Dispos al," ort 1L-T11-3515, Aax: .L iv7i.  ;

I

22. Bendixsen, C.L. and Offutt, G.f., '?cre O is Ie: ,

c.c....j at the Idaho Chemical Processing r!r't,' . .. Acrit 19c9.

Bendixsen, C.L. and Rohde, K.L., "C;_rr.riit. - Parfarnance and 23.

4 l

Safety of a Cryogenic System for :'.rypt on Recretery," *irans. Am.

Nucl. Soc., 15,(1), 96, 1972.

24. Davis, J.S. and Martin, J.R. , "A Cry,Renic Aporoach t o Juel l Reprocessing Caseous Radwaste Trs..tr ent ," Trans. am. Nucl. So ., l 16, 176-77, 1973. l

25. Draft Environmental Statement, I,irerick Generating St at ion. l Dockets 50-352 and 50-353.

26. Draft Environmental Statement, Sus ;uelianna Ste am Mlectric Station, Docket s 50-367 and 50-Jdo, t

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,RILJTION' . . .

i L ,ecretary. -t  !

l Chairman-Anders 2.  !

, ' Commissioner Rowden 2 I l-s Commissioner. Mason 2 ,

Commissioner Gilinsky -  !

Commissioner Kennedy 2 l

' Exec. Dir.-for-Operations 2 l Agency.' Inspector 6 Auditor 1 -

Public Affairs 2 General Counsel :3' .

Solicitor 5 i' Exec. Legal Director i Administration 4 Planning 6 Analysis 1 ,

Nuclear. Reactor Regulation 1 t.

Standards Development 3 Inspection 6 Enforcement- 1 l

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b biIl *$,$sif 3 f.E [b :Sh Y

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