ML20202F962

Informs Commission of Comments of NRC Staff on EPA Proposed Standards

ML20202F962
Person / Time
Issue date:	08/01/1975
From:	Gossick L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-75-408, SECY-75-408-R, NUDOCS 9902040214
Download: ML20202F962 (41)

Text

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SECY-75 40 8 Aue" -

, 1975 3

COMMISSIONER ACTION For:

The Comissioners Executive Director for Operatione

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Thru:

EPA PROPOSED ENVIRONMENTAL PROTECTION STANDARDS

,Sahject:

FOR THE URANIUM FUEL CYCLE (40 CFR 190)

To inform the Commission of the commente of

Purpose:

the NRC staff on EPA's proposed standards.

Discussion:

On May 29, 1975, the Environmental Protection Agency published for ucmment its Proposed Environmental Protection Standards for the Uranium Fuel Cycle (40 CFR 190). The July 28, 1975, deadline for comments has been extended by 15 days at the request of the Energy Research and Development Administration. is a letter to the Administrator of EPA to be signed by the Executive Director for Operations of the NRC.

It provides general staff comments on the EPA proposed standards and attaches more detailed technical comments.

The thrust of the general comments is that the Or w.w4;m g ),

EPA proposed standards should be redeveloped to j

, w (L gpA give proper accounting to the practicability of

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,g effluent controls.

v" OX1L The Commission should note that the EPA proposed Ag, Q3t '66-//l standards are closely related to the recently This gg published Appendix I to 10 CFR Part 50.

relationship has been the subject of previous discussion with the Commission.*

The. EPA deferred publication of the standards for comment until af ter NRC issued Appendix I.

However, EPA did not take advantage of the opportunity to incorporate the NRC substantive findings in the matter of Appendix I before publishing the proposed standard for comment.

Instead EPA reached the conclusion that Appendix I l

• See SECY-75-35, SECY-R-75-202 and Enclosure 2.

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NUCLEAR HEGULATORY COMMISSION 0.h4.IL

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Honorable Russell E. Train A

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Administrator U. S. Environmental Protection

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Dear Mr. Train:

Volume 40 This is in reply to the notice in the Federal Register,wherein tion Agency f

Number 104, May 29, 1975, h

proposed Environmental Protection Standards for 2, 1975)

Statement for requesting comments on the Draft Envitcamental Impact l

the rulemaking action.

rally applicable The NRC strongly supports EPA's mission to develop geneWe believe the n l expression of safe environmental radiation standards.

i our regulatory program would benefit by a numer cal hich radio-i active emissions from the facilities in the uran umSuch sta d

tion regulated.

given to the balancing of resource expenditures for control of for the uranium fuel cycle versus similar expenditurests of the environ-other activities which affect the public health aspec ment.

ctices provide Existing Federal regulations and current regulatory prafuel cycle facilitie assurance that for normal operation the uraniumi h limits to as low as will be designed and operated in a manner wh c terial and exposures practicable the levels of release of radioactive mad effectiveness of to radiation. In view of the demonstratefurther " fine tuning" of existing tory program, we question the need for Comparing the regulations standards for these facilities at this time.and controls believe that eny d

additional emphasis on environmental standar s ws of pollution.

effective if they were addressed to other source i

hich we find objec-As an example of the " fine tuning" of standards wEPA proposed standa i

h tionable, consider the relationship between t eThe numerical guidelines in

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of the costs and j

and the NRC 10 CFR Part 50, Appendix 1.

i Appendix 1 were derived from a thorough considerat onwhich we environmental effects of radioactive effluentsEPA's proposed standards spe during a public rulemaking hearing.

e of the guidelines of The EPA Notice of environmental 1cvels which are in the rang Appendix 1 but which differ in specific details.

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. T llonorable Russell E. Train eycopriate Proposed Rulemaking states that Appendix I "will provide

.ight-water-and satisfactory implementation" of these standards 'sc agree that The NRC staff da side compliance with the cooled nuclear power reactors.

compliance with Appendix I necessarily would.. two-reactor site it would be f

For instance, EPA proposed standards.

one Appendix 1 action levelc and possible for the emissions to be with' The EPA proposed standard also in excess of the EPA proposed standards.

have not would require the scheduled application of technologies which been demonstrated on a commercial scale for remov mill tailing piles.

Implementation of the EPA proposed standard would require a substan discrep-effort to modify the NRC's regulations in order to remove these tal ancies, and it would not change significantly the overal for which would be essentially the same as the existing NRC systemTh impact.

regulating effluents.

d by measurements and analyses, and doses to people would be projecte Despite j

analyses of environmental interaction of radioactivity with m for the NRC to implement the proposed standard, particularly in this similarity, 4 developing regulations to demonstrate conformance to the emission li stated in curies per unit of power generated.

Several We believe that the proposed standard needs further work.The limits could alternative approaches appear available to the EPA.

be raised to reflect the concerns expressed in the NRC staff di-Radiation Council (FRG) radiation protection guides for doses to in which are attached.

l viduals be supplemented to limit doses from the nu d d The of twenty reduction which is reflected in the EPA pro Such limits approach to resource expenditures for health protection.

ld be would conceivably allow ficxibility within which effluents cou d

regulated without undue interruptions of electric power sources an distribution with consideration by the regulatory agency of the proper i

in the of allowable discharges among the various types of facilit es fue' cycle.

The detailed staff review of the proposed standard is attached.

Sincerely, 1

i Lee V. Cossick Executive Director for Operations

Enclosure:

Staff comments l

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l COMMENTS OF THE NUCLEAR REGULATORY COMMISSION ON THE EPA PROPOSED RULEMAKING ON ENVIRONMENTAL P 40 CFR PART 190 JULY 1975 9

Suitability of the EPA Proposed Standards with Respec't to 1.

Statutory Authority Under Reorganization Plan No. 3 the following functions, with respec to radiation standards, were transferred to EPA:

i Energy Act "The functions of the Atomic Energy Commission under the Atom c such functions of the Commission of 1954, as amended,... to the extent that d rds consist of establishing generally applicable environmental stan a from radioactive materials.

for the protection of the general environment

levels, As used herein, standards mean limits on radiation exposures or il in the environment or concentrations or quantities of radioactive mater a,

possessing outside the boundaries of locations under the control of persons or using radioactive material."

d i i trator In addition, a 1973 memorandum from the Director, OMB, to the A ibilities of the of the EPA and the Chairman of the AEC clarified the respons two Federal agencies by stating that:

i ibility l

" EPA should continue, under its current authority, to have respons l

for setting standards for the total amount of radiation in the gene from all facilities combined in the uranium fuel cycle, i.e.,

environment the standard which would have to reflect AEC's findings as to an ambient practicability of emission controls."

he Nuclear The regulatory responsibilities of the AEC were transferred to t f 1974.

Regulatory Commission (NRC) by the. Energy Reorganization Act o i

L

O the portion of.the EPA proposed is the view of the NRC staff that It for any' member of the standard which defines the annual dose equivalent

" and within the public is an appropriate " generally applicable standard l

The actual values proposed in the EPA standard l

EPA area of responsibility.

ed adequately reflect NRC's findings as to practicability *woress i

do not May 5, 1975, in Appendix I which was pub 11...ac in tne Federal Register on as discussed in Section 2, below.

ities The portion of the proposed standard which places limits on quan from the entire uranium fuel of long-lived materials entering the environment of electrical cycle and which is stated in tenas of curies per gigawatt year d"

It avoids stating the energy produced is not a " generally applicable standar.

is still an overall release standard it in terms of rates of release but limit s of these radionuclides in the i

which provides no real limit on the concentrat on lly The use of environmental concentrations would provice a " g environment.

l ides.

applicable standard" for such long-lived radionucl (40 CFR Part 190_)

Comparison of the EPA Proposed Uranium Fuel Cycle Standard 2.

9 50 with Appendix I, 10 CFR Part i lines for

_ Appendix I of 10 CFR Part 50, which provides numerical gu the criterion design objectives and limiting conditions for operation to meet i l in light-water-cooled i

"as low as reasonably achievable" for radioactive mater a C regulation on April 30, nuclear power reacsor ef fluent s, was issued as an NR 5 The numerical 1975, with notice in the Federal Register on May 5,197.

i n in Appendix I design objectives and limiting conditions for operation as g ve l

are presented in Table I.

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NUMERICAL GUIDELINES FOR LWR EFFLUENTS i

TABLE I i

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• Design Objectives sc)

I Release Mode (mrem per year per ~

Liquid Effluent 6

3 Whole Body 20 10 Any Organ i

Gaseous Ef fluent 10 5

Whole Body 30 15 Skin Radioactive Iodine & Particulates 30 15 Any Organ r

i additional In. addition to satisfying the design objective guidel nes, d by the regulation if the i

radioactive waste treatment components, are requ re by reductions of the dose to annual costs of those components ar'e justified i

the interim values of the population within 50 miles of the reactor us ng l

i for judging

$1,000 per person-rem or $1000 per person-thyroid-rom as cost effectiveness.

l Register with The statement of considerations published in the Federa x

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in part:

the EPA proposed standard 40 CFR' Part 190 states s

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for reactore is the view of the Agency (EPA) that this guidance "It f

50) will provide an appropriate and satisfactory f

(Appendix I, 10 CFR Part 190) proposed environmental implementation of these (40 CFR Part i h respect to light-radiation standards for the uranium fuel cycle w t i

fuel."

water-cooled nuclear reactors utilizing uran um i

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the provisions of Appendix I would j

Ths NRC st af f does not agree isf actory implementation" of the necessarily " provide an '

_spriate and sat The reasons are 190 for LWR power arations.

proposed'40 CFR Part j

several:

1. The design objective quantitiam of Appendix I and attendant doses l

I for the three release modes can be additive.

2. The design objectives apply to each reactor on a site (not _ to the the site entire site) and can be multiplied by the number of reactors on for estimating the equivalent values for the site.

3. The flexibility provided in Appendix I for the limiting conditions l

for operatior. (in recognition of the uncertainties in the source

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) would permit l

term estimates and in anticipated operational occurrences h as a faeror the design objective quantities to be exceeded by as muc of two.

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4. Appendix I applies'only to effluents from LWR power stations an does not apply to other radiation sources such as N-16 from the i n of radiation turbines, storage of radioactive material, or interact o from other nearby sites and radiation from other than LWRs on same s it e.

i For these reasons, a nuclear power station virh only two LWR un ts I

l in the doses presented operating in accordance with Appendix I could result in Table II.

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e POTENTIAL ANNUAL DOSE RATES TO AN INDIVIDUAL LWR STATION OPERATING WITHIN APPENDIX I, 10 CFR PART 50

. c. II.

Organ (mrem)

Whole Body (mrem)_

Release Mode 20

,6 Lig id Effluents 10 10 Gaseous Effluents 30 Iodine Particulates 60 l

16 Doses at " design objective" level 120 32 Doses st " action level" 75 (thyroid) 190) 25 Proposed Standard (40 CFR Part 25 (other organs)

Thus, the Appendix I design objectives and limiting conditions for opera-d standard tion for a two-unit LWR power station could exceed the EPA propose for whole-body dose (25 mrem per year) and for organ doses (75 and 25

) due to exposures from year for thyroid and other organs, respectively The total dose could be higher than that which could occur effluents only.

from exposure to effluents if consideration is given to radiation fr il onsite, the turbine of a BWR station, from storage of radioactive mater a s f

from transportation of radioactive material, from nuclear f acilities o i

station LWR, or from other nuclear sites in the near vicinity of the two-unit site.

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l There currently are more.than 80 LWR sites with two.or more units f

in operation or for which applications are being reviewed for licensing action.

3.

Conceptual Differences Between Appendix I and the EPA Proposed Standards There are. substantial conceptual differences between the " design objective" and " limiting conditions for operations" features of the NRC 10 CFR Part.50 Appendix 1 and the standards presented in the EPA proposed 40 CFR Part 190. -The design objectives of Appendix I are values which l

NRC has selected with due consideration of technical feasibility and cost

'e f fect ivenes s.

Design objectives are values which the designers and the operators of the facility are to use in selecting station features and operating procedures. A substantial technical effort was undertaken by f=

NRC in order to provide a data, base for defining design objective values.

Representative values were selected for each of the numero'us parameters which~ are required to be considered in order to, estimate' the quantities of each radionuclide which might be released and the exposures and doses 'which*

might! occur as a result of the release.

NRC recognized that each parameter could have a range [of values and j

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 dif ficulties more severe than those assumed-in develop-4 l

ing the.taff analytical models.

In recognition of these difficulties in

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' predicting impact, the NRC Appendix 1 of 10 CFR Part 50 provides an allow-f ance of as much as a factor of two between the " design objectives" and t

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7-d in the the " limiting conditions of operations" which are reflecte operating limits.

If th*

" technical specifications" which define plant renc rhe j

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limiting conditions are exceeded, the station personnel must I

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and

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matter to the NRC, determine the reasons for the higher re eases, l

determine a course of action which will reduce the releases to the desig l

This may be viewed as a graded scale of action rather l

objective levels.

of greater than The actions of the NRC, in ths event than a limit.

the anticipated releases would depend upon the magnitude of the releases, immediate need for the power generated by the station and other factors.

190 are the values proposed by the EPA in 40 CFR Part In contrast, limits rather thann design objectives, and if they are exceeded the facility presumably would have to cease operations unless the NRC mad l

the release was unusual, of a temporary nature, a " variance" finding that i

and the societal interests would b'e served best by continued operat on.

l Bd Direct and Scattered Radiation from Boiling Water Reactors - Whole-o 4.

i Dose Rates Steam produced in boiling water reactors is delivered directly to the '

In the reactdr, the nuclear reactions N-15 (n, y ) N-16 and 0-16 turbines.

d p) N-16 take place and the short-lived product N-16 is transporte (ng In the decay of N-16 to stable through the turbine system with the steam.

This highly 0-16, energetic gamma radiation is emitted (6.1 Mev, 7.1 Mev).

potentially could deliver penetrating radiation constitutes a source that rares of-significance to individuals located near the whole-body doses at boundaries of several proposed and existing sites.

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l Radiatio? dose rates from turbines wer-ared at five BWR power 1.

1,2,3,4,5 stations.

The dose rate

.ary from station to station, with j

distance, and with orientation to the turbine in a complex aanner which is being studied at the present time. Table III presents the highest dose

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rates measured at the location where members of the general public could have access.

Dose rate values presented in Table III are based on 100%

occupancy by an individual without shielding by structures or topographic 1

features and would have to be adjusted for actual conditions of occupancy to estimate real doses.

TABLE III. MEASURED DOSE RATES (100% OCCUPANCY) FROM N-16 DECAY AT SELECTED LOCATIONS NEAR BWR TURBINE SYSTEMS Measured Dose Rate Station (arem/ year)

Location of Measurement Cooper 1000 River bank Duane Arnold 10 River bank Monticello 800 River Oyster Creek 10

> 500 meters Vermont Yankee 100.

Elementary schoole,*00 meters e

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P fit studies act. aware of any published cost-bene The NRC staf' d shielding to reduce the N-16 associate' trh turbine system layout an We are aware, however, of preliminary parametric design radI cion source.

l studies and cost-benefit analyses by architectural engineering firms and 6

Another shadow shielding parametric study has been l

rurbine suppliers.

7 The results

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reported to the NRC staf f by an architectural engineering firm.

be of this parametric analysis are relative in nature; i.e., they cannot They can be used, applied directly to estimate doses from a given plant.

however, to qualitatively characterize the shielding required to reduce substantial concrete or steel walls and The results indicate that doses.

and scattered gamma radiation slabs would be required to reduce the direct from the by about an order of magnitude for distances of 300 to 3000 feet Shielding additions of this scale are estimated to cost on the turbine.

Before order of several hundred thousand dollars per reactor unit.

definitive conclusione are drawn from existing parametric analyses, thei scope would have to be significantly increased to investigate inter-c relationships among maintainability, accessibility, and functional pertorman ility of of turbine system component s, which are related to safety and reliab

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nuclear. power plants, and benefits to be derived from reducing rad at on Work is continuing exposures to operating personnel and the general public.

The technology of shielding is well known, but its applica' tion in this area.

i straightforward in this instance which involves complex geometr es, is not and highly penetrating gamma radiation.

need for access to equipment, i

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Fnel Reprocessing Plants - Thyroid Dose Rates i

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In 1973 the AEC (now the NRC) staf f initiated comprehensive eng ne of the data base studies to provide part environmental, and cost levels of radioactive material in for establishing "as low as practicabl="

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effluents from fuel reprocessing plants.

the Holifield The initial step in the studtes, which were performed atd l fuel l

National Laboratory (formerly the ORNL), was to develop a mo e t

typical of current design and operation using presen The cost /

j reprocessing plant l

licensing limitations on the release of radioactive materials.

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se of-I benefit of decreasing the release of radioactive wastes through t e u Decontamination increasingly ef fective radwaste systems was analyzed.

f The factors and source terms were evaluated for each radwaste system.

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practice to the foreseeable limits of I

radwaste systems ranged from present i

i to normal operations.

l available technology and were analyzed witn respect d has not been l

The technology of several of the radwaste systems considere f e are not demonstrated on a production basis, and those systems, there or,

j Thus, some of the' radwaste systems available for immediate application.

fit assessment might not that were considered for purposes of a cost-bene d practicability.

achieve projected removal ef ficiencies with demonstrate I

depends upon ef fluent and site

'Ng Radiological impact on the environment uses. Two characteristics, population distribution, and land and water d by the AEC, were selected site regimes, similar to sites previously approve l ted for the attdy in order to assess the range of impacts from site-re a site on a plain in a rural southeastern coastal area i

characteristics:

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to a continuously flowing stream which empties into an estuary; adjacent i

adjacent and a site located on a plain in a rural midwestern environment Human to a continuously flowing stream which empties into a large river.

i activities and land and water uses for each site regime were hypothesiza d f

Doses from and analyzed.to determine potential radiation exposure pathways.

identitied exposure pathways were calculated for individuals in the vicinity Hypo-of the plants and for the population'vithin 55 miles of the plants.

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near thetical doses to individuals, to the population, and to organ sms fuel reprocessing plants were evaluated for interaction of radioactive l

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f material in effluents from the plants with food and water and irradiation o Dose models and pathways used in the study to persons in the environs.

assess exposures are consistent with those used in the licensing of l

from proposed activities.

facilities to evaluate the environmental impact 1

Average meteorologic data from representative midwestern and southeastern coastal regions were used to calculate average atmospheric dispersion factors The dose for use in calculating doses to individuals and to the population.

commitments calculated for these sites might be significantly higher than l

d d into those that are actually experienced owing to the conservatism intro uce i

the calculation in lieu of definitive data from operating exper ence.

The result s of these studies indicate that the maximum annual i

j commitment via the milk pathway to the thyroid of a child located at a

could approach 500 mrems per year during distance of 0.5 mile from the plant j

reprocessed fuel cooled for 160 days, that I

equilibrium operations of a plant i

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l-A significant fraction of this estimated dose commitment is

.s the release of I-129.

Therefore, variation in cooling *'

seyond 160 days I.

would have very little ef fect on estimated do-

. ares. The ALAP stuoies indicate that the dose could be reduced to about 190 mrem per year at a l

total annual operating cost of approximately $35,000 (about $3.80 per l

person-thyroid-rem on a' population basis) using macroreticular resin rad-t waste treatment equipment.

It should be noted that only preliminary laboratory studies have been made of the performance of these macroreticular resins. Development work would be needed to confirm the practicability of the process, which is similar otherwise to conventional ion exchange processes, and to establish suitable methods for resin regeneration and handling of the resins and the spent regenerant. A realistic schedule for the i

practical demonstration of this process would require an elapsed time from project initiation of about three years.

The staff believes that this dose rate could be reduced to less than 30 mrem per year by modifying the processing to evolve iodine during disolution l

and providing additional treatment equipment. This process is not complex, and conventional equipment would be used in a commercial reprocessing l

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plant. The process has been successfully demonstrated on a laboratory j

scale.

However, engineering development and a demonstration of the process with i

irradiated LWR fuel and dissolver solution are required.

It is estimated t

that tne development and design engineering, equipment procurement and l

installation, start up and testing, and integration into the overall plant circuit could reasonably be accomplished in about 5 years from project i

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I

8 e initiation in view of the simplicity c' fcocess and the use of l

of this equipment could require an l

conventional equipment. Oper-

. annual operating cost

.eproximately $275,000 ($130 per person-thyroid-rem on a populatica basis).

i Recent public hearings have been conducted on the environmental to the National Environ-of the Barr.well Nuclear Fuel Plant pursuant impact The staff has estimated that normal mental Protection Act of 1969 (NEPA).

i could yield maximum iodine operations of the Barnwell Nuclear. Fuel Plant l

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thyroid dose rates to the thyroid of an infant via the milk and inha at on 9

Thir, dose rate has been estimated for a pathways of 88 mrems per year.

a distance of 1.5 miles from the facility (i.e., the closest location at

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uncon rolled distance from the plant).

On the basis of the above studies, and depending on the location of the appears that compliance with the proposed EPA standard nearest "real" cow, it of 75 millirems per year to an individual's thyroid may not be achievable,

However, it is with practicability a consideration within the next 2 years.

likely that the level of exposure proposed in the standard could be co i

ih with by 1980, with the possible exception of existing plants wh ch m g t require additional time to modify (backfit) equipment.

Fuel Reprocessing Plants - Quantities of 1-129 Released 6.

J EPA proposes a standard of 5 mci per gigawatt-year electrical for the l

983.

release of I-129, with an effective implementation date of January 1,1 l

the Holifield National Laboratory include considera-i Studies carried out at f life =

l tion of the control of the long-lived radioiodine, 1-129 (hal 1.6 x 10 years).

The studies indicate that the use of treatment systems 7

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.,srating macroreticular resins, could contain I-129 re eases P

an annual operating cost of 62 mci per gigawatt year electrical at l

Further,NRC staff analysis indicates about $35,000 for a model plant.

that this improvement can be reduced to practice in about 3 years from 9

i The addition of iodine evolution equipment to the project init iation.

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reprocessing system is believed to be capable of reducing I-129 releases 1.6 mci per gigawart-year electrical for a'model plant and is i

to about in annual operating costs.

l estimated to require approximately $275,000 Reduction of this advanced equipment to practice is expected to require i

about 5 years from project initiation.

The improvements listed above have been discussed in relation to thi l

doses of individuals from radioiodine. The EPA proposed standards also We expect that the address 1-129 releases per gigawatt year electrical.

' systems to satisfy proposed individual installation of radwaste treatment f

thyroid dose rate standards also would satisfy the proposed standards related to 1-129 release quantity.

7.

Uranium Mills - Organ Dose Rates The function of uranium mills is to extract uranium in conce form from naturally occurring ore deposits which generally contain three In addition to per ton of ore (0.15 to 0.30% U 0 ).

to six lbs. of U 0 38 38 uranium.. the ores contain other radioactive constituents, such as i

i thorinm-230, radium-226, radon-222, lead-210, etc., which are rad oact ve decay products of uranium.

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At the beginning of 1974, there were 15 operating mills in the Information regarding l

United States, plus one mill on a standby basis.

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f The nominal capacities of the these mills is provided in Table IV.

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

l TABLE IV URANIUM MILLS IN THE UNITED STATES IN 1974 l

" Nominal" Capacity Short Tons of Ore Per. Day Status of Mill No. of Mills State 13,500 New Mexico

• Active 3

9,050 Active 7

Wyoming 1,750 Colorado

• Active 2

400 Washington

• Active 1

1,750 I

Active 1

Texas

• 500 1

Active Utah 26,950 15 TOTAL 1,500 Inactive 1

Utah I

• Agreement States l

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After ore is received at a mill, it is first crushed and then

..e sand-l Af ter the ore has reached finely ground into a wet slurry.

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. electively like consistency, it. is contacted with chemicals whic' l

The barren dissolve or 7each the uranium from the finely ground solids..

solids (tailings) are then separated from the pregnant solution and The pregnant solution f

pumped to waste storage areas (tailings ponds).

I The stripped is then chemically treated to extract and purify the uranium.

solution is then used as the pumping fluid to convey the solid waste tailings to the tailings pond.

It is important to characterize the locale of uranium mills and the Two primary sources type of radioactive materials that are released.

These contribute radioactive materials to the atmospheric environment.

(1) the release of effluents containing radon and particulates are:

l carrying radioactive material from the discharge stacks following in dust collection and ef fluent treatment; and (2) the escape of radon gas i l from and the wind transport of particulates carrying radioactive mater a the tailings area.

Doses from radon are specifically excluded from the standards Practicable means are not presently available to control proposed by EPA.

releases of radon from either mill discharge stacks or tailing areas.

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The application of existing -dust collection techniques will contro l

doses from the releases of airborne particulates from alli discharge 1

stacks to within the standards proposed by EPA.

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atting is from wind

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The major dose contribution from uran i

The tailings transported particulates from tap

,, retention systems.

stils are constructed similarly to those retention systems at urani" 11 In the usual of other ore dressing and hydrometallurgical plants.

case Han initial earth dam is constructed using native soils or mine Tailings slurries are then discharged along the inner edges of 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 tailings.

ilings and operation of tailings retention systems, substantial areas of ta f the liquid will form-beaches due to evaporation, seepage, and drainage o fraction of the waste slurry by gravity to lower elevations within the Thus, as tailings become exposed by

- overall waste retention system.

beach formation within these vaste retention systems, the-finely groun solid tailings, containing the radioactive descendants of uranium, beco l

This erosion, along with the diffusion of radon

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subject to wind' erosion.

from tailings systems, results in the' dispersal of radioactive materia into the surroundings of uranium mills.

Environmental surveys in the environs of uranium mills have been i

i based on the collection and analyses of airborne samples collec licensees, an AEC program to determine airborne concentration I

12 an AEC-PHS active materials around tailings piles at closed mills, to determine radon concentrations around such systems, 13

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sponsored-program i d inactive l

and an HEW evaluation of the potential effects of unstabil ze A

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In addition, limited calculations

. the Colorado River Basin.

pile to to the National Environmental Policy Act nave been made pursuant l

from milling l

estimate potential exposures ro individuals by inhalation on y 15 three new mille ommencing operations since 1970.

l-l activities at ii d at Engineering, cost,' and environmental studies have also been in t af f the NRC for the the Holifield National Laboratory under'the direction o 16-l" effluent purpose of providing information on "as Icw as practicab e I

i r

releases from uranium mills.

'j l

Airborne samples collected by licensees have in the past general l

These' assay results have been been assayed for natural uranium only.

FR Part 20 for compared to paragraph 4'of the Note to Appendix B of 10 C i

20.106 purposes of showing compliance with the requirements of Sect on L

ium are con-of 10 CFR Part 20. Insofar as conce trations of airborne uran d uranium cerned, these survey results indicare char concentrations aroun l

1, Table mills are generally well below the limi.rs specified in Co umn II, Appendix B of 10 CFR Part 20.

conducted by AEC-PHS,'the significant conclusions 13 In the radon studies the sites studied were not significantly reached were char railings piles at i

beyond a affecting the natural local atmospheric radon concentrat ons tions distance of 1/2 mile in the prevailing wind directions, yet concentra fi locations of airborne radon resulting from the piles at nearby of s te 20 limit for releases of radon into could. exceed 1 pCi/ liter-(the 10 CFR Part i

I

-unrestricred environs).

l

)c

\\

i i

t.

i l

i l

l

_ 19 -

l 12 of airborne concentrations of radioactive l

The AEC measurements airborne l

inactive mills indicate that materials around tailings piles at from a tailings pile, which 1500 feet concentrations of thorium-230 at had only been inactive a few months and which contained significa This corresponds i

ture, averaged 55% of applicable 10 CFR Part 20 limits.

j 825 mrem per year from inhalation of thorium-to a lung dose rate of about in such an environment.

230 alone to an individual continuously present inactive mills are more prone to vind It is recognized that tailings at erosion than those at active mills.

The "as low as practicable" studies performed by HNL estimate the l at 0.5 total maximum annual bone dose rate to a hypothetical individua ilings area miles from a theoretical erdel operating uranium mill and ra that in Wyoming to be 1060 mrem per year, assuming total occupancy at

~

It is 100% of the food consumed is produced locally.

location and that e

recognized that this dose rate overestima tes reality because of the l i 'that j

population in the vicinity of most mills and the unlikely assumpt on However, the subject of real an individual obtains all his food locally.

i doses to real people will require further study before firm conclus ons lly can be reached with regard to establishing the conformance to genera uranium mills.

applicabale limits as they affect of environmental impact s f rom a uranium mill 15 Recent evaluations d in to NEPA resulted in the bone dose rate equivalents presente pursuant Table V.

i i

E t

- 2C -

ESTIMATES OF BONE DOSE EQUIVALENTS FOR THE HUMECA MILL TABLE V.

l l

Annual Bone Dose Location i

Boundary, 1500 ft. SW of main shaf t 124 mrem Boundary, 8000 f r. NW of vent shaft 221 mrem l

i 42 mrem Redd Ranch i,

These dose rates result from inhalation only. The boundary dose rates j

i the site boundaries. The j

are hypothetical, since no individual resides at i

l dose rates include radionuclides from the mill and mine ventilation system, include radionuclides that have become airborne owing to wind but do not erosion of railings.

Removal of Noble Cases from Fuel Reprocessing Plant Effluents 8.

The principal concern arising from the release of noble gases from r

is the dose commitment (man-rem) reprocessing plants (particularly Kr-85) delivered to populations. Over the period 1980-2000, the United States would contribute approximately 25% of the Kr-85 dose commitment to the Thus, if the United States were the sole nation to world population.

require noble gas removal from reprocessing plant effluents, the desired Similarly, the costs consequences of control would be largely negated.

associated with reductions in dose commitments may be related to both the of the world. Estimates of these costs United States pcpulation and that are provided in Table VI.

I I.

~ ~ --

~

f 1

I TABLE VI l

LOMMITMENT COST ESTIMATES PER MAN-REM REDUCTION OF KR-85 FROM U.S. LWR REPROCESSING P' 2

1 Cost in Dollars Per Man-Rem Reduction Year No. of Plants U.S. Population World Population 3

3 l

Holdup Hoidup and BF Holdup Holdup and BF 1975 0

1980 0

l 1985 2

29,800 36,500 352 393 1990 4

19,900 26,500 228

-277 i

1995, 8

20,400 25,000 224 249

~

?

2000 11 19,700 23,500 204 222 l

l 1

1.

In addition to NFS, ACNS, and MFRD plants, l

2.

In dollars of 1973.

I 3.

Plants built prior to 1983 backfitted (BF) to recover 99% of the krypton l

in the fuel received.

l As may be seen in Table III, the costs per man-rem reduction in dose t

i to the population of the United States is about a factor of 90 greater than that to the worldwide population. An interim value of $1,000 per man-rem and $1,000 per man-thyroid-rem are specified in Appendix I for judging the l

Kr-85 removal l

of efforts to reduce population doses.

l cost ef fectiveness installation and operation would not be cost-effective when con-equipment sidering the U S. population dose from Kr-85. Only in terms of world popula-tion can the installation of Kr-85 removal systems be argued as justifiable 6

in terms of cost ef fectiveness.

I S

I l

l

~ - _

._--____.m i

i i

i of the United States to remove Kr-85 would Unilateral action

.ne part l

have little e.tect on the dose delivered to the entire world population.

i i

j Foreign fuel processing will contribute about 3 times the Kr-85 dose con-i tributed by processing in the United States if Kr-85 is not co'11ected by Given these considerations, it is the view of the staff that any country.

the self-imposition by 1983 of Kr-85 reaoval systems upon United States fuel reprocessing plants should be deferred pending consultation with the International Commission on Radiation Protection, the International Atomic Energy Agency, and affected foreign countries.

A delay in imposing standards for Kr-85 release for the purpose of estsklishing policy will impose virtually no added risk to any individual.

• ed dose rates as a result of assumed releases from all worldwide Est.

facils.ies of Kr-85 through the year 2000 are about 0.03 mrem whole body 1

17 Skin dose 1/2500 that of natural background radiation.

per year or about rates for such conditions are calculated to be about 3 ares per year.

Prior to the imposition of release standards for Kr-85 with the consequent investments in equipment and operations, the staff believes that l

these costs should be examined in terms of societal risks and alternat This view is in consonance beneficial investments of the nation's resources.

18 that states "... it is becoming l

with a conclusion given in the BEIR report society not expend enormously large resources to increasingly important that the expense of greater risks tnat reduce very small risks still further, at analy-r-

go unatten'ded; such unbalances may pass unnoticed unless a cost-benefit sis is attempted.

If these matters are not explored, the decisions will r

l t

O still be made and the complex issues resolved either arbitrarily or by default since the setting and implementation of standards represent such a resolution."

While the above considerations appear to be overriding, the development of krypton removal equipment to practice in fuel reprocessing plants should be fostered an.1 continued, particularly in view of the possibility of inter-national agreements to limit releases of Kr-85.

The staff also notes that the unilateral requirement of restricted Kr-85 release by the U.S. could also adversely affect the competitive position of the U.S. in processing fuel compared to that of foreign countries which do not have such a requirement.

It is expected that noble gas removal systems appropriate to the fuel reprocessing industry could be operational in 1983 if appropriate research and development efforts were to be initiated now.

This date, when com-

)

pliance with the EPA Kr-85 release standards is proposed, may be optimistic.

Howevet, the EPA proposes that the development program on noble gas removal be reviewed in the future to establish the practicability of removal systems prior to 1983. 'At present, two 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 systems and estimated schedules for their proof of practice certifications I

are provided in References 17 through 26.

9.

Utility of the EPA Froposed Standard In 1971, the AEC amended 10 CFR Parts 20 and 50 to include the following criteria:

l

i I

i l

10 CFR Part 20.l(c) persons engaged in activities under licenses... should, in addition 207...

to complying with the requirements ser forth in /IO CFR Part I

~

to maintain radiation exposures and relear-make every reasonable effort 1

of radioactive material in ef fluents to unrestricted areas as far below the. limits specified ir. /TO CFR Part 207 as practicable."

10 CFR Part 50.34a(a) to construct a nuclear oower reactor 7

"... The applicant /for a permit f

shall... identify the design objectives, and the means to be employed, for keeping levels of radioactive material in effluents to unrestricted

)

areas as low as practicable."

l The terminology "as low as practicable" is defined in 10 CFR Parts 20 and l

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 benefits to the health and safety and in relarion to the utilization of atomic energy in the public interest."

In 1971 the AEC proposed numerical guidelines for radioactive material in LWR effluents to meet the criterion "as low as practicable."

An About 4,200 evidentiary public hearing was held on the rulemaking action.

statement, and pages of testimony, a three-volume environmental impact i

thousands of pages of written restimony and exhibits were produced in th s 1

The public hearing was completed on December 6, 1973, rulemaking action.

to 10 CFR Part 50 on and the NRC published Appendix I as an amendment While the rulemaking action was ti.a consuming and extensive, May 5, 1975.

l i

1

- _ ~ _ _ _, _, _.

l t

.ute

~ it permitted participation ~ by all interested parties and was re-l

,,ound rule for the development of a substantial data base upon whir' l

Further, the criterion "as low ar f racticable" which could be drawn.

exists in 10 CFR Parts 20 and 50 was applied in the licensing of reactors I

in an effective manner during the four-year period that was required to t

complete the rulemaking process.

Upon completion of the public hearing on Appendix 1, an effort was initiated to develop the generic technical and economic data base for the "as low as practicable" selection of numerical guides to meet i

criterion for uranium fuel cycle facilities other than LWR power stat ons.

the While a substantial amount of data has been produced from this ef fort, e

i for all generic effort has not been completed and the numerical guidel nes f

i in the uranium fuel cycle facilities are specified on a case-by-case bas s I

licensing review.

In view of the effective ef fort demonstrated by the NRC to restrict expo-iii to sures and releases of radioactive material from licensed nu 1

I EPA as low as reasonably achievable levels, it appears that the proposed 190 would not significantiy add to existing regulatory control of 40 CFR Part reactor and fuel cycle effluents.

10. Implementation of the EPA Proposed Standard l

190 considered by EPA was one I

Among the alternatives to 40 CFR Part This alternative was rejected lower values for the standard.

which would set l

it would impose a large by EPA because, as stated in the EPA DES, "...

administrative burden on NRC in order to insure compliance.

3 4

1 J

l

s I

• 1 i

Should the proposed 40 CFR Par

• oecome an effective rule, implementarien of that rule would impose substantial administrative burden. The l

following administrative problems are representative of those which would j

l be presented to NRC if 40 CFR Part 190 were to become a rule.

I a.

Revise 10 CFR Part 20 and the recent'ly amended Part 50 (Appendix I) i to implement 40 CFR Part 190.

j b.

Revise Technical Specifications for all licensed LWR power stations to reflect the requirements of 40 CFR Part 190.

j i

Reviek all licensing actions to identify faellities which will require c.

additional radwaste treatment or other features which will permit com-pliance with 4v CFR Part 190 ano identify methods by which compliance could be accomplished and demonstrated.

d.

Decide, as a matter of policy, whether 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 j

the more costly backfitting, operating restrictions, and extensive survelliance requirements.

Devise a system for relating release quantities of Kr-85, I-129, and e.

long-lived transuranic elements to the power generated by LWR power stations and allocating permissible release quantities among uranium 1

fuel cycle facilities.

Allocation of release quantities among newer and older facilities would be complicated by factors such as possible competitive advantagen which might ~ be realized by older stations, t

l

h a

w& '

atght not have features which will be included,in new f acilities, should they be granted release allotments based on considerations other than fuel burnup quantities.

On the other hand, backfitting of f

older f acilities can be extremely expensive and place these facilittes l

t a competitive disadvantage if the backfitting is required.

at i,

Determine whether the quantities of Kr-85 and I-129 which would be f.

190 af ter January 1,1983, refer to all uranium permitted by 40 CFR Part i

fuel which was used to fuel processed after that date or only to that A finding on this issue date.

generkte electrical power after that could influence decisions on matters such as the schedule for process fuel, the scheduling of mixed oxide fuel in LWR power stations, spent and similar issues dealing with fuel and waste management.

Review, evaluate, and make findings on the adequacy of safety features g.

of reprocessing facilities to permit compliance with the restricted release of long-lived material in a manner which will not produce l

undue risks to health and safety from operating the systems and from lon~g-term storage of Kr-85 in high pressure bottles or by other storage mechansima.

Provide gui'delines on what constitutes "a temporary and unusual operat h.

condition" for a nuclear facility for which the NRC may grant a " varianc Guidelines also would have to be provided for judging the " necessity to the orderly the overall societal interest with respect i

to protect delivery of electrical power" should the need for a variance by NRC be required for a uranium fuel cycle facility.

i l

t

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I l

rr Review the analytical models currently used by NRC staf f to estimate i.

potential doses and consider porsible modifications or adjustments for It is actually doses to "real people" as stated by the EPA in the DES.

Impossible to determine accurately the actual doses to specific

'.... sw.-.aal.Vh5ing to the multiple exposure modes, the levels which are too low to measure, the mobility of individuals, unique characteristics of individuals, and other factors.

j.I Perform studies to determine the relationships between releases of radioactive material and the doses which might be received by indivi-duals'in a region where interactions of dispersica patterns from multiple nuclear facilities overlap, modifications on siting criteria for uranium fuel cycle

a. ' Determine what In view facilities might be required to comply with 40 CFR Part 190.

~

of the low dose limits specified in the EPA proposed standard, distance requirements required to assure compliance for normal operations of the facilities might be more restrictive than those required in con-sideration of serious accident situations.

The activity discharge limits for krypton-85, iodine-129, and alpha-1 emitting transuranic elements are expressed in units of activity (curies)

These limits are released per unit energy production (gigawatt-year).

l stated to apply to the sum of the activity discharged from all facilities in the uranium fuel ycle. However, in practice, they would be

' effluent limitations on spent fuel reprocessing facilities.

Insignificant l

amounts of iodine-129 and transuranic elements and only minor quantities I

I i

I I

i j

t of krypton-85 are emitted from light-water-cooled nuclear power reactors i

Tra'nsuranic elemente I

as compared with spent fuel reprocessing plants.

. cation could be discharged from mixed { plutonium-uranium) oxide fuel fe i

3 facilities, but these facilities should be considered as part of the l

plutonium fuel cycle not the uranium fuel cycle, i,

If tha contributions of the iodine-129 and alpha-emitting transuranics from light-water-cooled nuclear reactors wouuld have to be assessed in order to comply with the proposed standards, then a considerable expendi-ture of effort and money would be required to measure radionuclides l

l which, in themselves, contribute insignificantly to the radiation dose l

I If the reactor contribution could be j

i from nuclear power reactors.

]

omitted, then the standards would represent effluent. limitations solely l

for spent fuel reprocessing plants.

\\

l Even if the contributions from the reactor facilities were omitted, I

l limitations (such as the technical

~

i determination of a, priori effluent l

impossible.

specifications in NRC licensing conditions) would prove almost f

Because these proposed limits are tied to energy production, knowledge of the fuel burnup and the thermal efficiency of the reactor (to convert h of thermal energy to electrical energy) would be required for each batc Because of the variation in individual reactor designs, fuel reprocessed.

ible power level, and fuel management practices, it would be nearly impos to specify, beforehand, the total equivalent energy generated by the The reprocessing fuel.

annual reprocessing plant throughput of spent f acility would have to keep a running account of the total activity i

l l-

e l l and the total 6y whic'h had be'en generated released to the environment l

d tries would have to be compute by the fuel. The ratio of these qu-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.

compliance, the ratio of the total activity discharged and the total equivalent energy production for all rep'rocessing facilities would have insure to be calculated by NRC for every batch of fuel reprocessed to that the overall totals were in compliance.

l of the EPA Proposed Standard

11. Perspective of the Impact (DES)* states that imple-The EPA Draft Environmental Impact Statement an estimated 1030 190 would avert mentation of the proposed 40 CFR Part

" potential health ef fects" which would occur if current NRC regulatory The DE5 presents values for the potential practices were to continue.

health ef fects attributable to operation of the nuclear fuel cycle through the year 2000 at varicus environmental radiation protection levels.

Table 10 on page 82 of the DES contains columns which contain estimated ice,"

values based on existing " Federal Radiation Guides," " Current AEC Pract According to this table, there and " EPA Generally Applicable Standards."

d FRC would be a substantial dif ference between the values projected un er dix I guidance and AEC practice only for short-lived materials where Appen I

i

• Table 10, page 82, DES l

l I

- 's

s.

• i l

l sn~

levels below the l

_. to restrict releases in effluents to has been recogn?

The values projected under FRC guidance and AEC practice are FRC guides.

sufficient The DES does not present identical-for all other sources.

d but apparently

' details to determine the bases for the estimates presente,

recognize char the nuclear facilities have not been the estimates do not levels in doses to individuals at operated in a manner which would result i

the as high as those permitted by the FRC standards nor does it recogn ze i h the NRC existence of the "as low as recsonsbly achievable" criterion wh c that the

[

applies to all uranium fuel cycle facilities and which assures i

dose levels are well below the FRC gu des.

i In addition, the potential health effects are estimated assum ng a

~

i ion linear nonthreshold' relationship of ' somatic and genetic effects to d at a very-

' dose at-levels which approach zero and'which are delivere l

l-The bulk of the health eff'ects are postulated to occur as low dose. rate.

lived materials a result of integrating the extremely low doses from long-to the world's population over several decades.**

l l

d to Without a perspective, the estimated 1030 health ef fects postu ate Placed in occur over about 150 years might appear to be substantive.

all number in l

perspective, the estimated 1030 health effects are smal, a sm illion such health l-a statistical' sense when compared to the over four b i

i the same effects which can be estimated to occur from other causes dur ng l Cycle, i

• • Table '3, page 12, Environmental Analysis of the Uranium 1973 t.

u

. - -~

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i

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d 32 -

f time period. Table _VII presents an estimate of the norm &1 incidence o cancer and serious ' generic diseases of the types referred to as " health-

, effects."

f

.Numcrical estimates'of "heatrh effects" presented in the Dra t for-the Uranium Fuel Cycle standard are a

Environmental Impact Statement based upon.the hypothesis of a' linear, non-threshold, dose rate independent relationship between biological effects and doses applied at levels This is consistent with the recommenda-wh{ch approach natural background.

i

However, tions of scientific authorities in matters'of radiation protect on.

experimental data are inadequate to verify or to deny this hypothesis.

the probability of biological effects are An alternate hypothesis is that low dose rates and that an reduced'when the doses are delivered at If this. alternate hypothesis is correct, effective threshold exists.

the probability of biological effeces at very low dose levels could be More than 93% of the total-body dose commitment, which represent i

sero.

essentially all of the calculated health effects.are the result of

\\

I f

summing doses far less than one mrom per year to the entire population o Thus, a fair statement would be that the

'the world over several decades.

expected impact is likely to be within the range ' from zero to 1030 he effects.

t I

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1 I

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33 -

ESTIMATED NORMAL INCIDENCE OF " HEALTH EFFECTS!' IN TABLE VII.

AND IN THE WORLD Genetic Cancer Period Population 7

3/

1/

~

2/

~

1:70-2020 U.S.

1.8x10 deaths

~

~

7

~4/

7 6/

3.7x10 cases

~

1970-2120~5/

5.0x10 cases U.S.

8 8/

7/

~

World' 5.9x10 deaths 1970-2020 9

1.2x10 cases 9

9/

3.0x10 cases 1970-2120 World i

Total health ef fects (cancer + genetic) cases 7

U.S.

8.6x10 cases 9

World 4.2x10 cases T/ A 50-year period was selected for evaluating cancer incidence to compare doses with the EPA postulated number of somatic ef fects r

~

003D.

2/ The population of the U.S. was based on Fig. D.1, p. D-9 of EPA-52 the several decades.

-3 per person year from the U.S. was selected 3/ A cancer death rate of 1.29x10 1966-67.

f rom World Health Statistics Annual 4/ The number of new cancer cases was assumed to be t

~

deaths per the NAS/NRC BEIR Report.

5/ A 150-year period was selected for evaluating genetic disease incid

~

correspond to the time period for the EPA genetic estimates.

6/ A value of 6% was selected for genetic disease incidence based

~

in the BEIR Report.

9

~

in 1970 and to increase by 7/ The world population was assumed to be 3.5x101.9% pe

~

-3 per person year for the world was estimated 8/ A cancer death rate of 1.22x10 1966-67.

from data in the World Health Statistics Annual 9/ The U.S. genetic disease incidence (6%) was assumed to apply th

~

population, t

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. ~.

. ~. - - -.

":.c m

' ye*

l !~

.out one-quarter of Further, the United States will' contribute onl*

i hich will' j

the Kr-85 worldwide _ inventory from uranium fuel cycle operat ons w Neither national nor be the source of these worldwide low-level doses.

international authorities in radiation protection have :pecifically addresse for international the significance of worldwide low-level Joses and the need 1

control of Kr-85 and similar radioactive sources.

While the values for normal incide.nce presented in Table VII are gross is clear that the estimated 1030 health effects which EPA l

estimates

• it i

0 postulates to be averted by implementing the proposed 40 CFR Part to the United States and would if correct, would cost about $100,000,000 I

f these represent an increase of less than 0.0003% in the normal incidence o

~

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i health effects.

e i

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l.

~-

. - _ ~ _ - _ - --,

.% y ls l 4

1 1.

Lowder, W. M. and Raft, P

Environmental Gamma Radiation Exposure Rates from Nitrogen-lf

.ne Turbines of a Large BWR Power Plant,"

l Health and Safety '

satory, USAEC, New York, October 1971.

t i

l 2.

Lowder, W.

M.,

daft, P.

D., and Gogolak, C.

V., " Environmental Camma Radiation from Nitrogen-16 Decay in the Turbines of a Large Boiling l

Water Reactor," Health and Safety Laboratory, HASL TM 72-1, USAEC, f

New York, February 1972.

3.

Lowder, W. M.,. Raf t. P.

D., and'Cogolak, 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, January 1973.

4.

Memorandum, " Radiation Fields Nearby Operating BWRs," J. Kastner to H. R. Denton, USAEC, July 19, 1973.

l S.

Memorandum to Participants in the April N-16 Radiation Surveys at the Arnold and Cooper Nuclear Power Stations. W. M. Lowder, ERDA/RASL, June 11, 1975 (and attachments).

Private Communication, James M. Smith, Jr., Nuclear. Energy Division, l

6.

General Electric Company, San Jose, California, to William E. Kreger, USAEC, January 17, 1975.

I I

Private Communication, E. A. Wtraan, Stone and Webster Engineering 7.

Corporation, to J. Kastner, USAEC.

Blanco, R. E., et al, Correlation of Radioactive Waste Treatment Costs 8.

and Environmental 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.

" Supplemental Testimony Regarding the Health Effect to the Local 9.

Population from Normal Operations of the Barnwell Nuclear Fuel Plant l

(The Reprocessing Facility)," F. J. Congel and K. F. Eckerman, l

i Docket No. 50-332, undated.

Statistical Data of the Uranium Industry, U.S. Atomic Energy Commission, I

10.

p 62, 1974.

11. Merritt, Robert C., The Extractive Metallurgy of Uranium, Colorado l

i School of Mines Research Institute,1971.

I

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

Evaluation of Radon-222 Near Uranium Tailing Piles, U.S. Public Health 13.

Service, DER 69-1, March 1969.

I

F

, Je" 36 -

" Disposition and Control of Uranium Mill Tailings Piles in the Colorado River Basin," Federal Water Pollution Control Administration.

Region VIII, U.S. Department of Health, Education and Welfare, Denver, March 1966.

15.

" Final Detailed Statement on the Environmental Considerations by Fuels and Materials, Directorate,of Licensing, USAEC, Related to the Issuance of a License to Rio Algom Corporation for the Humeca Uranium Mill," Docket No. 40-8084, unpublished, undated.

16. Blanco, R.

E., et al, Correlation of Radioactive Waste Treatment Costs 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 press.

17.

"The Potential Radiological Implications of Nuclear Facilities in the Upper Mississippi River Basin in the Year 2000," USAEC, WASH-1209, January 1973.

18.

"The Effects on Population of Exposure to Low Levels of Ionizing Radiation," Report of the Advisory Committee on the Biological Ef fects of Ionizing Radiations, Division of Medical Sciences, National Academy of Sciences National Research Council, Washington, D.C., November 1972.

19.

Stephenson, M. J. et al., "Experimenta~1 Demonstration of the Selectivee 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 y, 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 the Idaho Chemical Processing Plant," IN-1221, April 1969.

23.

Bendixsen, C. L. and Rohde, K.

L., " Operational Performance and Safety of a Cryogenic System for Krypton Recovery," Trans. Am. Nucl. Soc.,

15,(1), 96, 1972.

5

r

.a,' '. '

l 37 -

Davis, J. S. and Martin, J. R., "A Cryogenic Approach to Fuel 24.

Nucl. Soc.,

Reprocessing Gaseous Radwaste Treatment," Trans. Am.

6, 176-77, 1973.

25. Draft Environmental Statement, Limerick Generating Station, Dockets 50-352 and 50-353.

26.

Draft Environmental Statement, Susquehanna Steam Electric Station, Dockets 50-387 and 50-388.

N l

I l

i 1

l l

I