ML20206E990
| ML20206E990 | |
| Person / Time | |
|---|---|
| Issue date: | 06/11/1986 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| NUDOCS 8606240073 | |
| Download: ML20206E990 (200) | |
Text
. __ _ _ - - _ _
JUN 111985 Robert B. Minogue, Director (
MEMORANDUM FOR:
Office of Nuclear Regulatory Research FROM: William J. Dircks -
Executive Director for Operations
SUBJECT:
CONTROL OF NRC RULEMAKING s
By memorandum of February 13, 1984, " Control of NRC Rulemaking by Offices Reporting to the EDO," Offices were directed that effective April 1,1984, (1) all offices under ED0 purview must obtain my approval to begin and/or continue a specific rulemaking, (2) resources were not to be expended on rule-makings that have not been approved, and (3) RES would independently review rulemaking proposals forwarded for ray approval and make recommendations to me concerning whether or not and how to proceed with the rulemakings.
In accordance with my directive, the following proposal concerning rulemaking has been forwarded for my approval.
Proposed rule, " Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees." (Sponsored by RES - memorandum, Minogue to EDO dated June 5, 1985.)
I approve continuation of this rulemaking. The NRC Regulatory Agenda (NUREG-0936) should be modified to reflect the status of this rulemaking.
(SipesWilliam).Dircks William J. Dircks Executive Director for Operations cc: V. Stello J. Roe H. R. Denton J. Taylor !ao62g073e60611 J. G. Davis PDR P. G. Norry Distribution:
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\...../ PA x ur JUN 5 1985j h /"7 MEMORANDUM FOR: William J. Dircks
- Executive Director for Operations FROM
- Robert B. Minogue, Director Office of Nuclear Regulatory Research
SUBJECT:
CONTROL OF NRC RULEMAKING: RES REVIEW 0F ONG0ING RES SPONSORED RULEMAKING Based on our-review of the' ongoing RES sponsored rulemaking, " Emergency Pre-paredness for Fuel Cycle and other Radioactive Material Licensees," RES rec-ommends that the rulemaking should continue. This recommendation in draft form has been coordinated with NMSS and IE. ;
The Conunission has directed- the staff to consider the need for
- increased emergency preparedness at such facilities. In June 1981, the Commission published an Advance Notice of Proposed Rulemaking on the subject.
l .
A proposed rule is in preparation and will be submitted to you in July.
RES, NMSS, and IE management met with you..on-March-18.-1985._In_that meeting'
- ;it3aragreed that:-(1) thh iFUl'ein_aking should proceed, (2) th'e Theinicil
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toxicity of UFfii651d be considered, (3) the licensee must have a clear requirement to Motify response organizations in the event of 'an a'ccident, (4) written State and local plans were not needed and should not be required, (5)
NRC should be consistent with EPA public notification policy on toxic
, chemical . accidents, (6) the needed requirements were more properly emergency
, procedures rather than emergency plans, and (7) realistic - or typical dose
. calculations should be presented in the Regulatory Analysis in addition to
- conservative or worst-case calculations in order ~to provide perspective.
- Since that meeting, we have learned that EPA has authority under Section 6(a) of the Toxic Substances Control Act (7 U.S.C 136) to require public notifica-
- tion of potential hazards of toxic chemicals, but EPA has not issued any reg-ulations nor are they currently developing regulations to require that infor-mation be given to the public.
We have also completed the realistic dose estimates to add perspective. In general, the typical case dose estimates are a factor of 100 lower than the
, conservative estimates. We, therefore, now present a range of doses antic-ipated to result from a severe accident, but we continue to base the need for an emergency plan on the conservative case dose estimates.
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4.e William J. Dircks 2 JUN 5 1985 The rule as it now stands would require far less extensive emergency pre-paredness than NRC requires for nuclear power plants because potential releases are much smaller. The preparedness that would be required is closer to what NRC now requ'res for research reactors. For example, the following items would not be required: (1) written State and local government plans, (2) State ar T Tocal government approval of licensee plans, (3) FEMA involve-ment, (4) public information programs, (5) an emergency classification sys-tem, (6) emergency action levels, (7) defined emergency planning zones, and (8) real-time dose estimates.
The complete draft RES review package has been sent to OED0 (Attention:
DEDR0GR) and to the Director, NMSS and to the Director, IE.
Robert B. Minogue, Director Office of Nuclear Regulatory Research 1
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SUBJECT:
CONTROL OF NRC RULEMAKING: RES REVIEW 0F ONGOING RES
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i K i p; -Based on our review of the ongoing RES sponsored rulemaking, " Emergency Pre-g paredness for Fuel Cycle and other Radioactive Material Licensees," RES rec-I p emmends thet the rulemaking should continue. This recommendation in draft hi fonn has been coordinated with INSS and IE.
EN The Commission has directed the staff to consider the need for l
increased emergency preparedness at su b facilities. In June 1981, the q
yj h{k Commission published an Advance Notice of Proposed Rulemaking on the subject.
A proposed rule is in preparation and will be submitted to you in July.
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,. 18, 1985. In that meeting I RES, it wasIMSS, and agreed that: IE manag(ement met withshould
- 1) the rulemaking you onproceed.
March (2) the chemical j f@ toxicity of UF would be considered. (3) the licensee must have a clear h(
lM requirement to kotify response organizations in the event of an accident, (4) written State and local plans were not needed and should not be reouired (5)
H f MRC should be consistent with EPA public notification policy on toxic lg chemical accidents (6) the needed requirements were more properly emergency
'g procedures rather than emergency plans, and (7) realistic or typical dose S calculations should be presented in the Regulatory Analysis in addition to iI,i conservative or worst-case calculations in order to provide perspective.
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l'C Since that meeting, we have learned that EPA has authority under S(: tion 6(a) of the Toxic Substances Control Act (7 U.S.C 136) to require public notifica-
< tion of potential hazards of toxic chemicals, but EPA has not issued any reg-3 ulations nor are they currently developing regulations to require that infor-c, nation be given to the public.
p lC We have also completed the realistic dose estimates to add perspective. In
'y general, the typical case dose estimates are a factor of 100 lower than the
) conservative estimates. We, therefore, now present a range of doses antic-Mi: 1 pated to result from a severe accident, but we continue to base the need for y an emergency plan on the conservative case dose estimates.
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d.- - William J. Dircks 2 JUN 5 1o85
- i. The rule as it now stands would require far less extensive emergency pre-
, paredness than NRC requires for nuclear power plants because potential 3- releases are much smaller. The preparedness that would be required is closer p to what NRC now requires for research reactors. For example, the following b items would not be required: (1) written State and local governnent plans, jf, (2) State and local gnvernment approval of licensee plans, (3) FEMA involve-V ment, (4) public information programs, (5) an emergency classification sys-1- tem, (6) emergency action levels, (7) defined emargency planning zones, and
} (8) real-time dose estimates.
F The cortplete draft RES review package has been sent to OEDO (Attention:
k DEDR0GR) and to the Director, NMSS and to the Director, IE.
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TO: F. P. GILLESPIE, CHAIRMAN, RIRB FROM: K. R. Goller, Member, RIRB TITLE OF RULEMAKING: Imergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees -
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AGREE WITH REC 0!MENDATIONS g '
IN RES RULEMAKING REVIEW PACKAGE 5
- MODIFY RECOPMENDATIONS IN NOT PARTICIPATING.
RES RULEMAKING REVIEW f, PACKAGE AS INDICATED BELOW
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RES INDEPENDENT REVIEW BOARD VOTING SHEET TO: F. P. GILLESPIE, CHAIRMAN. RIRB FROM: G. A. Arlo to Member, RIRB TITLE OF RULE KING: Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees AGREE WITH RECOMENDATIONS h IN RES RULEMAKING REVIEW PACKAGE MODIFY RECOMMENDATIONS IN NOT PARTICIPATING.
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RES RULEMAKING P.EVIEW PACKAGE AS INDICATED BELOW COMMENTS AND SUGGESTIONS:
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T RES INDEPENDENT REVIEW BOARD VOTING SHEET TO: F. P. GILLESPIE, CHAIRMAN. RIRB FROM: W. M. MORRISON, MEMBER, RIRB TITLE OF RULEMAKING: Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees IRB AGREE WITH REC 099tENDATIONS
- IN RES RULEMAKING REVIEW PACKAGE MODIFY RECOMMENDATIONS IN NOT PARTICIPATING.
X RES RULEMAKING REVIEW
- - - PACKAGE AS INDICATED BELOW COMMENTS AND SUGGESTIONS:
I recommend that the draft Minogue to Dircks memorandum, which recommends that the subject rulemaking be continued, be modified as follows:
s In the second paragraph which provides the basis for the RES recommendation, modify the second bullet by adding at the end of this bullet: "and promulgated by rulemaking."
The third bullet of the second paragraph should be made into a separate paragraph to provideinformation only. The fact that virtual agreement on the text of the proposed rule has been reached by the staff should not be -
one of the bases for the RES recommendation.
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/dK//M M W. M, MORRISON MEMBER. RIRB JANUARY 24, 1985 DATE
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Eurf p e.4 0k M w RIRB members are requested to conduct an independent review of the attached RES rulemaking review package and provide the Chairman, RIRB, with their voting sheets indicating their positions on the rulemaking..
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will be appreciated. RAMRB will use the voting sheets to assemble the complete RES review package for eventual transmittal to the OED0 and the Director -
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r IEMDRARDUM FOR: William J. Dircks Executive Director for Operations FROM: Robert B. Minogue, Director i
- Office of Nuclear Regulatory search
SUBJECT:
CONTROL 0F IIRC RULEMAKING RES REVIEW OF ONGOING RES SPONSORED EMAKING Based on our review of the ongoi RES sponsored rulemaking " Emergency Pre-r paredness for Feel Cycle and et r Radioactive Material Licensees," RES recom-sends that the rulemaking sh d continue. This reconmendation in draft form has been coordinated with and IE.
The basis for our recomme ation is as follows:
o The Comuniss n has directed the staff to consider the need for increased rgency preparedness at such facilities. In June 1981, the Comum sion published an Advance Notice of Proposed Rulemaking on the sub ct.
o The sue of what level of emergency preparedness should fuel cycle l a other radioactive material licensees have is a major policy that s ld be-decided formally by the Cossaission.
The comp 1 te RES review package has been sent to OEDO (Attention: DEDROGR) and l to the rector,llMSS and to the Director, IE.
Robert B. Minogue, Director Office of Nuclear Regulatory Research Distribution RAMRB r/f i Circ /Chron
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NRC REGULATORY AGENDA ENTRY l
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f TCi.N PREPAfEDIESS 3 Toft RIEL CVCLE AND OTHER i - rwEumRiAi.s a armenessa .
Sagal Amstertty: er Uec aset; 42 USC 5641
. Cpft casuost to CFR 30; 10 CFR'40; 10 CFR 70; 10 CFR 72 4hetract: ne proposed rule would require about u3 fuel cycle and other
==dia=r*ive asterials l' r:::. to subunit an emergency plan that would ,
among other actions, require the madhation of local authorities in case af asPacri<lant and that the licensee h proiective actions for the Mc.De propeeed raie is intended to 4mrther protect the publit: from -
acAdantal exposure to redistion. ne e5essed Ecossees are those whose, ponenesien listite ladirme the potential por an accident that could deliver a sediation dose effsite escoeding one rem effective dose uivalent or 5 reme to the thyroid or d cause e soluble uranium inhalation of e millagrams (a domical toxicity hasard).
Based on preliminary data contaM in the draft regulatory analysis for this proposed rule, the costs of emergency preparedness are expected to exceed
- the benefits in terms of protecting
' public health sad safety. Hbwever, the proposed requirements may be ble in terms of the intangible t af being able to reassure the public that if an accident does c,: cur, they will be warned and told what to do to protect th=== elves.
Timetable:
Action Date PYt Cete ANPRM 06/05/81 46 FR 29712
- ANPRM 00/00/81 46 FR 29712 Corement Period Begin N 18/03/81 Comment .
Portod End NPRM 06/D0/85 ,
Smet Erstity: Yes Analysis. Preeminary RfA 06/00/81' Agency
Contact:
Stephen A. nadiaire, Nuclear Regulatory Commission. Office of Nu , lear Regulatory Research, Washington, DC 20555,301443 7538 M N: 3150-AMt i
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TITLE:
+ Emergency Preparedness for Fuel Cycle and Other Radioactive Materials Licensees CFR. CITATION:
10 CFR 30; 10 CFR 40; 10 CFR 70; 10 CFR 72 ABSTRACT:
The advance notice of proposed rulemaking sought comments on a proposal that would increase emergency preparedness requirements ;
} for fuel cycle and other radioactive materials licensees with the potential for accidents involving radioactive materials that
- might involve exposures to the public in excess of EPA's protective action guides. The issues being considered in this rulemaking include--(l) Whether increased emergency preparedness is needed for.various types of facilities; (2) Whether State and local plans are necessary; and (3) Whether FEMA should review emergency preparedness requirements.
TIMETABLE:
ANPRM 06/03/81 46 FR 29712 ANPRM Comment Period Begin 06/03/81 46 FR 29712 ANPRM Comment Period End 08/03/81 NPRM _n n m','O r o y, f LEGAL AUTHORITY:
42 USC 2201; 42 USC 5841 EFFECTS ON SMALL BUSINESS AND OTHER ENTITIES: Yes a
fr AGENCY CONTACT:
Stephen A. McGuire Office of Nuclear Regulatory Research h'
Washington, DC 20555 .
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. 1 NUCLEAR REGULATORY COMMISSION MAY 3 01985 l
10 CFR PARTS 30, 40, and 70 Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees AGENCY: Nuclear Regulatory Commission.
ACTION: Proposed rule.
SUMMARY
- The Nuclear Regulatory Commission (NRC) is proposing to amend
~
?* its regulations to require certain NRC fuel cycle and other radioactive material licensees to establish increased levels of emergency prepared-ness. The proposed rule would require approximately 30 licensees to have an emergency plans for responding to a release of radioactive material.
The proposed rule would require procedures to reduce or mitigate releases and to promptly notify offsite response organizations if an accident occurs that might cause an airborne release of radioactive material such that radiation doses offsite could exceed the lower end of EPA's protective action guide range.
DATES: Comment period expires . Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or before this date.
" Insert date 90 days after publication in Federal Register.
1 Enclosure 1
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1 ADDRESSES: Submit written comments to the Secretary of the Commission, yr
- U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention
Docketing and Service Branch. Copies of comments received by the Com-mission, the Regulatory Analysis, and the environmental assessment and finding of no significant impact may be examined in the Commission's Public Document Room at 1717 H Street NW., Washington, DC.
FOR FURTHER INFORMATION CONTACT: Dr. Stephen A. McGuire, Regulatory Analysis and Materials Risk Branch, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 2C555 (telephone:
301-443-7636).
SUPPLEMENTARY INFORMATION: The NRC believes that certain of NRC's non-reactor licensees may have the potential for accidental releases of radio-active material that could cause radiation doses to the public exceeding the Environmental Protection Agency's (EPA's) protection action guides or could cause injury due to chemical toxicity. Based on NRC's conserva-tive accident scenarios, the greatest potential hazard to the public with regard to both consequences and probability of an accident has been deter-
! mined to be the sudden rupture of a large multi-ton cylinder. of UF..
Chemical toxicity rather than radiation dose would be the primary concern in this type of accident. Major facility fires at certain large byproduct material facilities are considered to be the next greatest potential hazard.
Radiation doses rather than chemical toxicity would be the concern in such l
i cases.
l l 2 Enclosure 1 l
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[7590-01]
i f The NRC is now proposing to require that certain licensees establish i and maintain an emergency plan for responding to such releases. The pro-
- posed requirements would be similar in nature to current NRC emergency preparedness requirements for reseach reactors because potential releases are relatively small in both cases.
The NRC already requires licensees to be prepared to cope with many types of accidents and emergencies. However, the NRC believes there is a need for certain fuel cycle and other radioactive materials licensees to have an emergency plan that include coordination with offsite authorities to assure that those authorities are promptly notified of an accident so that effective offsite action can be taken to notify and protect the public.
The proposed rule would require licensees to inform offsite author-ities of the potential hazard posed by a serious accident at the licensed facility, to recommend to the offsite authorities how to best protect the public in case an accident should occur, and to promptly notify those authorities if an accident occurs.
BACKGROUND During the Commission's deliberations concerning nuclear power plant emergency preparedness after the Three Mile Island accident, the Commis-sion directed the staff to evaluate the need to change the emergency pre-paredness regulations for fuel cycle and other radioactive material licensees.
In late 1980, the staff reevaluated previously submitted emergency plans for radioactive releases for fuel fabrication plants and found some apparent weaknesses. For example, some plans did not describe recommendations 3 Enclosure 1 l
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i for specific protective actions for the public, such.as sheltering or
+ evacuation, and arrangements for prompt notification of offsite response organizations.
Upon noting these weaknesses, the NRC staff prepared orders requiring 62 licensees to submit comprehensive onsite radiological contingency plans (46 FR 12566). These orders, which were issued in February 1981, required some licensees, based on their licensed possession limits, to plan for actions that would be needed in the event of an accident. The actions
- would be those necessary to: protect workers, limit the release of
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radioactive materials, assess radiation doses, and mitigate adverse conse-quences of the accident. The orders were issued to operators of fuel
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processing and fabrication plants, UF. production plants, and radioactive material users authorized to possess large quantities of radioactive mate-rials in unsealed form. The licensees selected were those authorized to possess quantities of radioactive materials that could as a result of a severe accident potentially result in a radiation exposure in excess of 1 rem effective dose equivalent to someone offsite. As a result of these orders, about half of the affected licensees reduced their authorized possession limits for radioactive material, thus no longer requiring them .
to submit contingency plans to NRC.
On June 3,1981, the Commission published in the Federal Register (46 FR 29712) an advance notice of proposed rulemaking on emergency pre-paredness for certain fuel cycle and other radioactive material licensees.
In this advance notice, the Commission proposed to codify the radiological contingency planning requirements set forth in their orders, as well as consider offsite preparedness The Commission noted in the advance notice that they would use factors such as possession limits, potential for acci-4 Enclosure 1
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$ potential radiation hazards for all of the NRC licensees whose radioactive material possession limits were such that severe accidents could result in offsite radiation doses exceeding the lower end of the protective action guides established by the EPA.
PUBLIC COMMENTS ON THE ADVANCE NOTICE The Commission, in the advance notice, requested public comments and received 18 responses. Comments were received from five Federal agencies, four State agencies, five corporations, one university, one laboratory, one non profit Federal corporation, and the Conference of Radiation Control
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Program Directors. The following discussion summarizes the major comments and gives the Commission's response to each comment.
Comment.
Many commentors questioned the need for the suggested regulations.
One Agreement State said there is "little likelihood of a serious acci-dent; those incidents which have occurred have been handled adequately .
without pre-existing plans, using existing resources and guidelines."
Commentors said that many of the facilities that would be covered do not 1
have the potential to exceed the EPA's protective action guide dose of 1 rem under any credible accident conditions. Uranium mills, UF. conver-sion plants, and low level waste burial grounds were cited by commenters as examples. Another example where emergency plans were not considered necessary was the case in which the radioactive materials are spread 5 Enclosure 1
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j among many different buildings so that release of a large proportion due y to a single event is not credible. Several commentors said NRC already requires them to be adequately prepared to respond to an emergency, and that there is no need for additional regulations. The Agreement States of New Mexico and Washington said they were already adequately prepared for any credible accident and saw no need for a regulation. On the other hand, the State of New York saw a need to reevaluate the adequacy of its existing emergency planning. One commentor said the need for the regula-tion should be tested against past accident experience to determine the urgency and realism of the proposal. Another commentor said that, compared to nuclear power plants, fuel cycle and byproduct material licensees have
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much less radioactive material, do not have a large energy supply to act as a driving force and do not concentrate their radioactive materials in a single location. Thus the consequence of an accident would be much smaller, and there would never be a need to evacuate or shelter people.
Response.
The NRC has carefully analyzed accident source terms, potential r
release fractions, and radiation doses for fuel cycle and other radioactive l
( material licensees. The details are given in "A Regulatory Analysis on l
l Emergency Preparedness for Fuel Cycle and other Radioactive Material Licensees, "NUREG-1140.2 Specific conservative accident scenarios have j
been considered for specific types of licensees, and release fractions and doses have been calculated on these scenarios. The accident history l
l 2 Single copies are available without charge upon written request from:
l NRC Sales Office, NRC, Washington, DC 20555.
l 6 Enclosure 1
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t- :
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$ of different types of facilities has been considered. As a result of the analysis some facilities, such as uranium mills, are excluded from needing an emergency plan for responding to a release. On the other hand, the analysis does indicate that, at a few licensed facilities, offsite doses due to an accident might exceed the lower end of the range of doses for 1
which the EPA recommends that protective actions to protect the public be considered. The NRC would especially like to receive comments on the accident scenarios presented in the analysis. The NRC is particularly interested in comments concerning the conservatism in the analysis as it pertains to specific classes of facilities.
Comment.
A second major comment was that the need for emergency plans should be evaluated on a case-by-case basis. Several examples were given wherein the licensed possession limits might indicate the need for a plan, but the actual circumstances would make a large release impossible. For example, a radiopharmaceutical manufacturer said that they use only a small quantity of their iodine-125 at one time. The rest is stored in ,
lead containers in a fume hood whose air is filtered three times before release. Commentors said the remoteness of the site should be a factor taken into consideration. In the case of one uranium mill, the nearest residence is 22 miles away. The comment was made that case-by-case review of the need for plans is feasible because so few licensees would be affected, i
2 7 Enclosure 1
6 [7590-01]
it E
5' Response.
{
The proposed rule would allow licensees the opportunity to demon-strate that an emergency plan for responding to a release would not be needed because no accident could result in doses approaching the protec-tive action guides.
Comment.
Several commentors thought FEMA review of State and local emergency response capabilities was unnecessary because possible accidents would be
' ~~
so much smaller than at nuclear power plants. It was said that simpler, less complex review and evaluation processes were better. Several Agree-ment States objected to a FEMA review of their programs. Other commentors thought FEMA could make valuable contributions.
l
, Response.
l l .
The NRC has considered the nature and depth of the needed offsite response capabilities in the previously mentioned Regulatory, Analysis and concluded that written site-specific State and local plans reviewed by FEMA are not needed because the accidents can be responded to as part of the community's general emergency response capabilities. These capabil-l ities are routinely used for emergencies of all sorts. The small potential f doses, small areas affected, small numbers of people involved, and quick l
response times needed are factors indicating that the community's normally existing emergency response capabilities are appropriate and that additional t
response capabilities are not necessary.
l 8 Enclosure 1
~ ~~~~~
}(( ~~
c [7590-01]
Y:
.; Comment.
r Some commentors thought failure of uranium mill tailing dams should be included.
Response.
The NRC has considered such events and concluded they should not be included because radiation dose rates are so low that EPA protective 2
action guides would not be exceeded even over a very long time (months or years). A complete explanation is presented in "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," NUREG-1140. 8 Comment.
Many commentors thought the NRC should provide a document describing the contents of the licensee's emergency plans and the nature of the pre-paredness needed.
l l
Response.
I The NRC agrees and plans to revise its reports, NUREG-0762, " Standard l Format and Content for Radiological Contingency Plans for Fuel Cycle and Materials Licensees," and NUREG-0810, " Standard Review Plan for the Review of Radiological Contingency Plans for Fuel Cycle and Materials Facilities." The revised reports would be published, possibly as Regula-tory Guides, concurrently with the final rule.
9 Enclosure 1
[7590-01]
y Comment.
w i k Several commentors thought the suggested regulations would be burden-some and expensive to both licensees and to States and that the cost would greatly exceed the benefits.
Response.
The NRC considers that the rule as proposed would not be expensive and burdensome to States or local governments. States and local govern-ments would not be expected to write specific plans for specific facili-t -
ties or have other special emergency preparedness. The NRC considers the normally available capabilities of States and local governments for responding to industrial emergencies and the normally available radio-logical health capabilities of States adequate to deal with accidents at fuel cycle and other radioactive material licensees. These radiological emergencies would involve small (not life threatening) doses, small areas, and small numbers of people. The potential risks are much lower than the risks from accidents involving chemical plants or the shipping of hazar-1 dous chemicals, to which States and local governments routinely respond.
In other words, the response to radiological accidents at fuel cycle and other radioactive materials licensees can and should be handled by State and local governments as part of its normal emergency response capability without additional resources. Thus, an appropriate level of emergency preparedness should not be a financial burden to State and local govern-
~
ments.
l 10 Enclosure 1 l- - -.- ..
9- [7590-01]
$9 i
, With regard to benefits, the benefits are admittedly small because of the low probability of exceeding protective action guide doses and the low probability that a dose of a few rems would have harmful consequences.
Costs to licensees were found to significantly exceed potential benefits (see Regulatory Analysis, Section 3). However, the Commission considers that the protection provided by engineered safety features must be bolstered by the ability to promptly notify offsite authorities if an accident occurs so that protective actions can be taken should they be needed.
Comment, r
~~
Several commentors thought NRC should provide funding to States for State planning.
Response.
The NRC sees no need for funding for State planning because a need for additional site-specific state planning was not identified.
Comment.
Several commentors objected to the way in which EPA's protective action guides were applied. They said the whole body guide was actually a 1 rem to 5 rem range, whereas the NRC arbitrarily selected 1 rem.
11 Enclosure 1
w-. -
][ [7590-01]
E:
d' Response.
l The NRC considers I rem as the point at which planning should begin.
The potential releases are relatively small, and the areas and numbers of people involved are small. Thus, it is practical to take actions at the lower end of the protective action guide range. 3 Comment.
Other commentors said that the ICRP Publication 26 methodology s
should be used to determine the protective action guides for radioactive
' -~
materials that are inhaled and deposited in the body.
Response.
- The ICRP Publication 26 methodology has been used.
l Comment.
One commentor said Part 72 spent fuel storage licensees should be covered under the regulation.
Response.
The need for licensee emergency procedures for offsite releases by Part 72 licensees is being considered in a separate rulemaking scheduled to be published in 1985. Part 72 licensees were found not to need l
12 Enclosure 1 l
l
W .
[7590-01]
l f
t
- emergency plans for responding to releases because potential offsite doses would not exceed EPA's protective action guides and thus no response woul'd be needed by people offsite. The analysis to support this finding is contained in the Regulatory Analysis.2 Comment.
One commentor said sealed sources should be covered under this regu-lation.
Response.
The NRC considers there is no need to include sealed sources in this rulemaking because sealed source accidents are already adequately dealt with in other parts of the regulations. (See, for example, S 20.402(a),
S20.403, S 30.33(a)(2), 6 34.25, S 34.32(g) and (h), and $70.60). In addition, based on the history of accidents involving sealed sources n l'icensed facilities, the NRC finds that additional emergency preparedness beyond that now existing at these facilities is not needed. .
However, the NRC is uncertain about whether it should include in its rulemaking foils, plated sources, thin-window sealed sources such as sometimes used for americium-241, and sealed sources using low-melting temperature metal such as aluminium. The NRC specifically requests experimental information or other analyses that will help it decide the question.
13 Enclosure 1
n . - _ - .
[7590-01]
f 1 Comment.
The comment was made that a large number of byproduct material licensees do not list the specific radionuclides they will possess, but only a total curie limit for classes of nuclides, for example those with atomic numbers 3 through 83. (This approach is recommended in Regulatory Guide 10.5, " Applications for Type A License of Broad Scope," Item 8A and Item 80.) This makes it impossible to determine, based on possession limits, whether extensive emergency preparedness is really appropriate.
Response.
The NRC will not require emergency procedures for offsite releases unless a plausible release of radioactive materials could cause doses exceeding protective action guides. If a licensee would be covered by the rule because the licensee is authorized to possess material he does not possess and has no intention of possessing in the future, the obvicus s'olution is for the licensee to request a license amendment to reduce the licensed possession limit. If the licensee actually possesses or may possess in the future enough material to be covered by the regulation, but there are site specific reasons why a significant release is not plausible, the proposed rule would allow the licensee to demonstrate this.
THE PROPOSED RULE The Commission is proposing these amendments to 10 CFR Parts 30, 40, and 70 on emergency preparedness. The proposed rule would cover fuel 14 Enclosure 1
y [7590-01]
4t cycle and other radioactive material licensees which may have the potential
{
. for accidents that could result in radiation doses offsite that exceed the lower end of the EPA's protective action guides or could result in injury due to chemical toxicity. These proposed regulations would require certain licensees to maintain an emergency plan for responding to a release. The proposed requirements are similar to current NP.C's emergency
-. preparedness requirements for research reactors because potential releases are relatively small in both cases.
The criteria selected for establishing whether a licensed facility would be required to establish and maintain special emergency procedures for offsite releases is whether a severe accident could deliver a radia-tion dose of I rem effective dose equivalent, 5 rems to the thyroid, or soluble uranium intake exceeding 2 milligrams to a person offsite.
The EPA recommends that actions to protect the,public be considered if projected whole body doses due to an accident are in the range of 1 to 5 rems, taking into account the practicality of the actions that would be taken. The proposed rule uses the 1-rem low end of the dose range as the criteria for establishing whether a licensed facility needs an emer-gency plan for responding to a release. In addition, conservative assump-tions have been used to estimate the doses which could result from an accident. Doses that would result from an actual accident would probably
- be well below the calculated doses on which the regulation is based.
l l The EPA's draft protective action guides apply to radiation received uniformly over the body. These guidelines are not applicable if the i radiation dose is not uniform or if only some body organs receive the 1
radiation dose. To account for radionuclides that are deposited nonuni-l formly in the body, such as those possessed by fuel cycle and other l
15 Enclosure 1
[7590-01]
?
T
- , radioactive material licensees, the effective dose equivalent from these radionuclidesisusedtorehlacethewholebodydoseequivalent.
The effective dose equivalent is defined as the sum of the external radiation dose equivalent plus the dose equivalent to each body organ due to radioactivity deposited within the body multiplied by a risk weighting factor for the organ. The weighting factors are taken from Publication 26 of the International Commission on Radiological Protection.
The conservative accident scenarios and dose calculations which form the technical basis for the proposed rule are described in detail in the ,
previously mentioned, " Regulatory Analysis of Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," NUREG-1140, which
~
is available upon request.2 Except for radioiodine doses, doses are calculated for an average adult. Doses to children would be slightly different due to differences in their metabolisms. However, doses to children have not been calculated for the modern ICRP Publication 26 dosimetric models except for a few radionuclides. The NRC considers the differences between adult dosos and child doses to be insignificant in comparison with the other uncertainties in the analysis. The NRC also considers that the inherent conservatism .
in its accident dose calculations and its use of the 1-rem lower end of the range for protective action consideration provide an adequate margin of safety. Public comments on this item are specifically requested.
For most licensees that would be required to establish and maintain a plan, the degree of risk f5 smali. For most licensees, worst-case doses to an individual on the plume centerline resulting from the most severe postulated accident are less than 5 or 10 rems. The areas where people 16 Enclosure 1
[7590-01]
g.
y should take protective actions in case of an accident are small, generally I a few city blocks around a facility. For most licensees the area where doses could exceed protective action guides would be no more than a few-hundredths of a square mile. Finally, the probability of a major release is small - less than 10 '/yr, and the probability of a major release l simultaneous with highly adverse meteorology is less than 10 '/yr. Details '
are provided in the Regulatory Analysis, Sections 2.4, 2.5, and 3. The I
rupture of a large heated cylinder of UF. is an exception in that the consequences due to the chemical toxicity of the released material could be greater than those from any radiological accident.
Airborne releases due to a severe accident at these licensed facili-
~
ties are likely to occur rapidly with little warning. The only types of
, accident identified for which protective actions might be needed offsite are a fire, a UF. cylinder rupture, and a criticality accident. Releases from a fire could start before the fire is detected or shortly thereafter.
Plume travel time to nearby people is likely to be no more than a few minutes. Releases would usually end within half an hour to an hour when t'he local fire department controlled the fire. As a result, protective actions would have to be taken quickly to be effective. Thus, NRC proposes that predetermined actions to be recommended for people at or near the
! site such as firemen, policemen, and nightwatchmen at the plant. Police l
departments and fire departments are experienced and capable of providing the type of emergency response appropriate. The NRC does not propose dose projections or complicated decisionmaking during the accident, nor participation in any decisionmaking or in the immediate response by j personnel not at or very near the site.
i i
17 Enclosure 1
[7590-01]
I-I The proposed amendments to Parts 30, 40 and 70 would require that h licensees authorized to possess in excess of certain quantities of by-product materials, source materials, and special nuclear materials evaluate potential doses from a severe accident and submit emergency plans for responding to releases if an evaluation shows it is needed.
The proposed rule would also cover any future plutonium fuel fabgication plants.
The table of quantities that would require evaluation of the need for an emergency plan was taken from "A Regulatory Analysis of Emergency
- Preparedness for Fuel Cycle and Other Radioactive Material Licensees,"
NUREG-1140. The table lists quantities that might deliver an effective i .-
dose equivalent of I rem in the event of a severe accident. The quantities
. were calculated by assuming that the most exposed individual would inhale a fraction of 10 5 for materials with no deposition and slightly lower for materials that deposit on the ground. External doses from cloudshine and groundshine are then added to the internal dose. The 1-rem effective dose equivalent is a 50 year dose commitment calculated by the metheds of ICRP Publications 26, 28, and 30.
- The table includes all nuclides listed on 20 or more of NRC's approx- -
i imately 9000 licenses, except for I-129. I-129 was not included because saturation would prevent the thyroid from absorbing enough I-129 to reach the 5-rem protective action guide for thyroid dose. The table also includes all beta gamma emitters listed on any license for which the quantity to deliver a 1-rem effective dose equivalent would be less than 10,000 curies.
The table includes all alpha emitters listed on any license for which the quantity to deliver a 1-rem effective dose equivalent would be less than j
2 curies.
18 Enclosure 1 4
e [7590-01]
a i7
( The quantities in the table are different from quantities previously published in NUREG-0767, " Criteria for Selection of fuel Cycle and Major Materials Uicensees Needing Radiological Contingency Plans," Federal Register Not.'ces with Orders to Licensees (46 FR 12566), and an Advance Notice of Rulemaking (46 FR 29712). The main reasons are: (1) dosimetric models from ICRP Publications 26, 28, and 30 have been used instead of the older models from ICRP Publication 2 and (2) release fractions have changed as the result of further study. The intercept fraction remains essentially as 10 ' for nondepositing radionuclides. In addition, two new pathways, external radiation from groundshine and from cloud shine, are considered.
~
Licensees are given the option of demonstrating that emergency pro-cedures for offsite releases are not needed because doses to people offsite would not exceed 1 rem effective dose equivalent as a result of a credible accident. The table of radionuclides in the proposed regulations was developed using conservative, pessimistic, or " worst-case" assumptions.
Each assumption is possible at some " generic" facility, but may not be r'ealistic for a specific actual facility. Thus the licensee is given the j option of analyzing accidents for the actual existing facility and deter-i mining a site-specific maximum release. If the resulting dose is below j 1 rem, an emergency plan for responding to a release would not be required.
l The licensee also has the option of revising facility design, operat-ing procedures, or possession limits to reduce potential offsite doses below I rem effective dose equivalent in lieu of preparing an emergency plan fo. responding to a release.
If an emergency plan for responding to a release is needed it would i include:
- 19 Enclosure 1
f [7590-01]
e; 1 p
T (1) A brief description of the facility and site area. The purpose is to provide the reader with enough basic information to c-evaluate the licensee's plan. Significant facilities, such as schools, for which protective actions might be appropriate should be included in the site area description.
4 (2) An identification of each type of accident for which offsite a
protective actions might be needed. Typically, the accidents of concern are fires involving radioactive materials, releases of large quantities of uranium hexafluoride, and critica11 ties involving high-enriched uranium or plutonium.
(3) An analysis of the offsite doses from each type of accident, including doses from naturally occurring or accelerator produced radio-active material (NARM) in addition to licensed material. This analysis should include dose vs. distance curves. Data to calculate the curves are contained in the Regulatory Analysis for this proposed rule, NUREG-1140.
(4) Identification of the means of detecting each type of acci-dent in a timely manner. The means of detection could include one or more of the following: fire alarms, criticality alarms, visual observation, or radiation monitors on stacks, as appropriate.
1 (5) A brief description of the means and equipment for. mitigating the consequences of each type of accident, including those provided to protect workers onsite. Mitigating actions could include actions to reduce or stop the release and actions to protect workers by means such as evacuation of the building or decontamination of personnel. Means for limiting releases could include sprinkler systems and other fire suppres-sion systems, fire detection systems, filters, physical separation of material, storage in fire-resistant containers, use of fire resistant l
l 20 Enclosure 1 f
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ T77.: T.__2 *._[.i. . . _ _ . . _ __ _ . , , _ , _ . _ , . _ , _ _ _ _ _ . _ _ _ _ . _ . ,
[7590-01]
(
[ building materials, fire-fighting capabilities, procedures prohibiting flammable materials in areas where radioactive materials are found, i filter systems, use of water sprays to knock-down UF., and others.
Equipment might include respiratory protection equipment, evacuation alarms, and equipment possessed by the licensee to reduce or stop the release. It would not include equipment to be used by offsite personnel, such as for firefighters, for example. Where site personnel would have responsibility for firefighting, general firefighting equipment should not be identified. Only special equipment unique to firefighting at the particular facility would be identified.
This item is not intended to require backfits or design changes.
' ~
Plant design is subject to a more complete safety review when the license application is reviewed.
(6) A brief description of the methods and equipment to assess releases of radioactive materials. This does not mean real-time assess-ment. It is assumed that measurement will generally only be feasible after the release has occured.
~
(7) A brief description of the responsibilities of licensee personnel should an accident occur, including the identification of personnel notify-ing offsite authorities and notifying the NRC Incident Response Center.
Offsite authorities would generally include fire, police, and medical personnel. The licensee need not notify the State unless the State is assigned some essential and urgent function.
(8) The means of promptly notifying offsite authorities and of requesting offsite assistance resources. Notification would most commonly be by telephone. In a few cases, the licensee may want to seek assistance from the Department of Energy under the Federal Radiological Emergency Response Plan (see 49 Federal Register 3578, January 27,1984).
21 Enclosure 1
w_- . . . _ _ _
[7590-01]
[
g 2
(9) Methods for assuring that recommended protective actions and
{
i distances are unambiguously l communicated to response organizations.
The licensee should decide on recommended protective actions and distances in advance. They should be written down so that may be read to offsite authorities ny nontechnical personnel. A request that the receiver read back the message is desirable to reduce the likelihood of messages being incorrectly received.
(10) Any special instructions the licensee would give to fire,
, lice, medical, and emergency personnel. Instructions to fire, police and medical and emergency personnel on how to deal with the radiation release should be appropriate for the personnel and should clearly state the specific actions expected of them and things they should or should not do.
(11) A brief description of the means of restoring the facility to a safe condition after an accident. Detailed procedures are not appropriate because the exact nature of the accident cannot be forseen. Instead general criteria are appropriate.
(12) Provisions for conducting onsite drills at intervals not to exceed two years. The drills are for the purpose of familiarizing the licensee personnel with the procedures and training them in the use of the procedures. Participation by offsite personnel is not required (nor j
prohibited).
The NRC has also considered the need for formal public information programs for people who might be advised to take protective actions if an accident occurred. The NRC could not identify any compelling need for such programs but is willing to consider the need for public information programs and include a requirement for them in the final rule if a need could be established.
22 Enclosure 1
f~'
q .
. ~. _ - -
[7590-01]
lE g Most if not all of the licensees who would be required to submit an
. emergency plan by this regulation have already submitted onsite Radio-
? logical Contingency Plans under the orders issued in 1981. Those plans already include much of the information that would be required under the new regulation. The NRC would not expect those licensees to rewrite those plans. Rather it would be acceptable to submit a supplement to the Radio-
, logical Contingency Plan that contained any information now required that is not in the Radiological Contingency Plan.
In its review of the licensee's emergency plan, the NRC will consult x
with FEMA under the terms of the FEMA-NRC memorandum of understanding as v
appropriate on a case-by-case basis.
- ~
The staff identified 62 NRC licensees who would be covered by the rule as proposed. It is likely, however, that about 16 of those licensees would lower their possession limits so they would not be covered and that about 15 would demonstrate that the 1-rem dose is not plausible. Realis-tically, probably no more than about 31 licensees would actually be required to submit an emergency plan. Perhaps about 5 to 10 Agreement State licensees
~
would also eventually be covered because the new requirements would be a matter of compatability with Agreement States.
l FINDING OF NO SIGNIFICANT ENVIRONMENTAL IMPACT: AVAILABILITY r
l The Commission has determined under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Subpart A of 10 CFR Part 51, that this rule, if adopted, would not be a major Federal action significantly affecting the quality of the human environment and therefore an environmental impact statement is not 23 Enclosure 1
_ _ _ _ ~.__:.___: : _ - . . _ _ _ . _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ .__ __
2' ' . --
[7590-01]
+
i required. The rule would not affect the probability or the size of accidental radioactive rele(ases. It might in some cases reduce the 7
doses people near the facility site would receive. The environmental assessment and finding of no significant impact on which this deter-mination is based are available for inspection at the NRC Public Document Room, 1717 H Street NW., Washington, DC. Theenvironmenpal assessment and finding of no significant imoact are contained in Sec-tion 4.3 of "A Regulatory Analysis for Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," NUREG-1140. Single copies are available without charge upon written request from NRC Sales Office, NRC, Washington, DC 20555.
PAPERWORK REDUCTION ACT STATEMENT This proposed rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). This rule has been submitted to the Office of Management and Budget for review and approval of the paperwork requirements.
l -
REGULATORY ANALYSIS The Commission has prepared a regulatory analysis on this proposed l regulation. The analysis examines the accident scenarios considered by the Commission as well as the costs and benefits of alternative actions considered. The analysis is available for inspection in the NRC Public Document Room, 1717 H Street NW., Washington, DC. Single copies of the f
24 Enclosure 1 6 _: ._ ~ .-_-._:.2_. ___ . -
v - _
h
[7590-01]
Ir y
- g. analysis (NUREG-1140) may be obtained without charge upon written request from: NRC Sales Office, U.S. Nuclear Regulatory Commission, Washington, 4
DC 20555.
As indicated previously, the Commission is particularly interested in receiving public comments on the regulatory analysis. Comments on the analystis may be submitted to the NRC as indicated under the ADDRESSES heading.
REGULATORY FLEXIBILITY CERTIFICATION As required by the Regulatory Flexibility Act of 1980, 5 U.S.C.
~
605(b), the Commission certifies that this rule, if adopted, will not
. have a significant economic impact upon a substantial number of small entities. A small entity has been defined as one with gross receipts under $1,000,000/ year. No such entities would be covered under the proposed rule.
Any small entity subject to this regulation which determines that, b'ecause of its size, it is likely to bear a disproportionate adverse eco-nomic impact should notify the Commission of this in a comment that indi-cates the following:
- a. The size of their business and how the proposed regulations would result in a significant economic burden upon them as compared to larger organizations in the same business community.
- b. How the proposed regulations could be modified to take into account their differing needs or capabilities.
25 Enclosure 1
- 2 [7590-01]
bp
. c. The benefits that would accrue, or the detriments that would be
^ avoided, if the proposed regulations were modified as suggested by the
~
commentor.
- d. How the proposed regulations, as modified, would more closely equalize the impact of NRC regulations or create more equal access to the benefits of Federal programs as opposed to providing special advantages to any individuals or groups.
- e. How the proposed regulations, as modified, would still ade-quately protect the public health and safety.
The comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555, ATTN:
Docketing and Service Branch.
8 LIST OF SUBJECTS FOR 10 CFR PARTS 30, 40, AND 70 1
Part 30 - Byproduct material, Government contracts, Intergovernmental j
relations, Isotopes, Nuclear materials, Penalty, Radiation protection,
! Reporting and recordkeeping requirements.
Part 40 - Government contracts, Hazardous materials - transportation, ,
l Nuclear materials, Penalty, Reporting and Recordkeeping requirements, Source material, Uranium.
l Part 70 - Hazardous materials - transportation, Nuclear materials, i
Packaging and containers, Penalty, Radiation, Reporting and recordkeeping
! requirements, Scientific equipment, Security measures, Special nuclear material.
26 Enclosure 1 i
- : :_ = - r r r : - ,- - . - - . . - _ - _ . - - . - - _ _ _ - . - . . - . _ - . - . - - - - - ,
=~
JL [7590-01]
ik -
Under the authority of the Atomic Energy Act of 1954, as amended, I the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments to 10 CFR Parts 30, 40, and 70.
PART 30 - RULES OF GENERAL APPLICABILITY TO DOMESTIC LICENSING OF BYPRODUCT MATERIAL
- 1. The authority citation for Part 30 is revised to read as follows:
AUTHORITY: Secs. 81, 82, 161, 182, 183, 186, 68 Stat. 935, 948, 953, 954, 955, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C.
2111, 2112, 2201, 2232, 2233, 2236, 2282); secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, 1244, 1246 (42 U.S.C. 5841, 5842, 5846).
Section 30.7 also issued under Pub. L.95-601, sec. 10, 92 Stat.
2951 (42 U.S.C. 5851). Section 30.34(b) also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.C. 2234). Section 30.61 also issued under sec. 187, 68 Stat. 955 (52 U.S.C. 2237).
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. ,
2273); SS 30.3, 30.34(b) and (c), 30.41(a) and (c) and 30.53 are issued urder sec. 161b, 68 Stat. 948, as ame~nded (42 U.S.C. 2201(b)); and l
l SS 20.36, 30.51, 30.52, 30.55, and 30.56(b) and (c) are issued under sec.
1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
d
- 2. A new $ 30.35 is added to read as follows:
6 30.35 Emeroency procedures for offsite releases.
(a) Each licensee authorized to possess radioactive materials in unsealed form, on foils or plated sources, or sealed in glass in excess 27 Enclosure 1
[7590-01]
e
( -of the quantities in S 30.72, " Schedule C - Quantities of Radioactive r Materials Requiring Consideration of Need for an Emergency Plan for Responding to a Release," s'iali submit either (1) An evaluation showing that the maximum dose to a person offsite due to a credible release of radioactive materials would not exceed I rem effective dose equivalent; or (2) An emergency plan for responding to a release of radioactive s
material.
(b) An evaluation submitted under paragraph (a)(1) may include consideration of the following factors:
(1) The radicactive material is physically separated so that only a portion could be involved in an accident.
(2) All or part of the radioactive material is not subject to release during an accident because of the way it is stored or packaged.
(3) The release fraction in the respirable size range would be lower than the release fraction assumed in developing 9 30.72 due to the chemical or physical form of the material.
~
(4) The solubility of the radioactive material would be different than the solubility assumed in developing 9 30.72. ,
(5) Facility design or engineered safety features in the facility would reduce a release to lower values than those assumed in developing
$30.72, (6) Operating restrictions or procedures would prevent a release as large as the released assumed in developing S 30.72.
(7) Other factors appropriate for the specific facility.
(c) An emergency plan for responding to a release of radioactive material submitted under paragraph (a)(2) of this section must include the following information:
28 Enclosure 1
^
[7590-01]
Y (1) A brief description of the facility and site area.
? (2) An identification of each type of accident for which offsite protective actions may be needed.
(3) An analysis of the offsite doses from each type of accident, including doses from naturally occurring and accelerator produced radio-active material in addition to all licensed material.
^
(4) Identification of the means of detecting each type of accident in a timely manner.
(5) A brief description of the means and equipment for mitigating y the consequences of. each type of accident, including those provided to 7 protect workers onsite, f -
(6) A brief description of the methods and equipment to assess releases of radioactive materials.
(7) A brief description of the responsibilities of licensee personnel should an accident occur, including identification of personnel responsible for notifying offsite authorities and notifying the NRC Incident Response Center.
(8) The means of promptly notifying of offsite authorities and of requesting offsite assistance resources. ,
(9) Methods for assuring that recommended protective actions and distances are unambiguously communicated to response organizations.
(10) Any special instructions the licensee would give to fire, police, medical and emergency personnel.
(11) A brief description of the means of restoring the facility to a safe condition after an accident.
29 Enclosure 1
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[7590-01]
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5 (12) Provisions for conducting onsite Wills at intervals not to
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e exceed two years. 7 (d) The licensee shall allow the local governmental authorities expected to respond in case of an accident 60 days to comment on the licensee's emergency plan before submitting it to NRC. The licensee shall ,ubmit any comments received within the 60 days to the NRC yith
- the emergency plan.
- 3. A new $ 30.72 is added to read as follows:
S 30.72 Schedule C - Quantities of Radioactive Materials Requiring Consideration of the Need for An Emergency Plan for Responding
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to a Release.
Radioactive Quantity Radioactive Quantity Material (Curies) Material (Curies)
H-3 20,000 Te-127m 5,000 C-14 1,000 Te-129m 5,000 Na-22 9,000 I-125 7 Na-24 10,000 I-131 5 P-32 100 Xe-133 900,000 P-33 1,000 Cs-134 2,000 S-35 900 Cs-137 3,000 C1-36 5,000 Ba-133 10,000 K-42 9,000 Ba-140 30,000 -
Ca-45 20,000 Ce-141 10,000 Sc-46 3,000 Ce-144 300 Ti-44 100 Pm-145 4,000 V-48 7,000 Pm-147 4,000 Cr-51 300,000 Sm-151 4,000 Mn-56 60,000 Eu-152 500 Fe-55 40,000 Eu-154 400 Fe-59 7,000 Eu-155 3,000 Co-60 5,000 Gd-153 5,000 Ni-63 20,000 Tb-160 4,000 Cu-64 200,000 Ho-166m 100 Zn-65 5,000 Tm-170 4,000 Ge-68 2,000 Hf-172 400 Se-75 10,000 Hf-181 7,000 Kr-85 6,000,000 Ir-192 40,000 Sr-89 3,000 Au-198 30,000 30 Enclosure 1
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c 4 Radioactive Quantity Radioactive Quantity Material (Curies) Material (Curies)
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90 Am-243 2 Y-91 2,000 Cm-242 60 Zr-93 400 Cm-243 3 Zr-95 5,000 Cm-244 4 Nb-94 300 Cm-245 2 Mo-99 30,000 Cf-252 (20 mg) 9 Tc-99 10,000 Any other beta gamma Tc-99m 400,000 emitter 10,000 Ru-106 200 Mixed fission products 1,000 Mixed corrosion products 10,000 Ag-110m 1,000 Contaminated equipment, Cd-109 1,000 beta gamma 10,000 Cd-113m 80 Irradiated material, In-114m 1,000 any form other than Sn-113 10,000 solid noncombustible 1,000 Sn-123 3,000 Irradiated material, Sn-126 1,000 solid noncombustible 10,000 Sb-124 4,000 Mixed radioactive
. - Sb-126 6,000 waste, beta gamma 1,000 Hg-203 10,000 Package mixed waste, Pb-210 8 beta gamma ** 10,000 Bi-207 5,000 Any other alpha emitter 2 Bi-210 600 Contaminate equipment, Po-210 10 alpha 20 Ac-228 4,000 Packaged waste, alpha ** 20 Np-237 2 Combinations of radioactive Am-241 2 materials
- listed above Am-242 2 3or combinations of radioactive materials, an emergency plan is required if the sum of the quantity of each radioactive material authorized divided by the quantity for the material in Schedule C exceeds unity.
- Waste packaged in Type B containcts does not require an emergency plan. ,
! PART 40 - DOMESTIC LICENSING OF SOURCE MATERIA!.
l l
l 4. The authority citation for Part 40 continues to read as follows:
I AUTHORITY: Secs. 62, 63, 64, 65, 81, 161, 182, 183, 186, 68 Stat.
i 932, 933, 935, 948, 953, 954, 955, as amended secs. 11e(2), 83, 84, Pub.
L.95-604, 92 Stat. 3033, as amended, 3039, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2014(e)(2), 2092, 2093, 2094, 2095, 2111, 2113, 2114, 31 Enclosure 1
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2201, 2232, 2233, 2236, 2282); sec. 274, Pub. L.86-373 Stat. 688 (42 f
h U.S.C. 2021); secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, i 1244, 1245 (42 U.S.C. 5841, 5842, 5846).
Section 40.7 also issued under Pub. L.95-601, sec.10, 92 Stat.
2951 (42 U.S.C. 5851). Section 40.31(g) also issued under sec. 122, 68 Stat. 939 (42 U.S.C. 2152). Section 40.46 also issued under sec 184, e 68 Stat. 954, as amended (42 U.S.C. 2234). Section 40.71 also issued under see 187, 68 Stat. 955 (42 U.S.C. 2237).
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.
2273); $$ 40.3, 40.25(d)(1)-(3), 40.35(a)-(d), 40.41(b) and (c), 40.46, x
40.51(a) and (c) and 40.63 are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); and $$ 40.25(c) and (d)(3) and (4).
40.26(c)(2), 40.35(e), 40.42, 40.61, 40.62, 40.64, and 40.65 are issued under sec. 161o, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
- 5. A new paragraph (1) is added to S 40.31 to read as follows:
S 40.31 Applications for specific licenses.
e e e e e
.(i)(1) Each licensee authorized tc possess uranium hexafluoride in .
ex:ess of 50 kg in a single container or "00 kg total shall. submit either an evaluation showing that the maximum intake of soluble uranium by a person offsite due to an accident would not exceed 2 mg or an emer-gency plan for responding to a release. An evaluation may include consideration of the following factors:
(1) All or part of the radioactive material is not subject to release during an accident because of the way it is stored or packaged.
1 32 Enclosure 1
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$ (ii) Facility design or engineered safety features in the facility I
- would reduce the size of the release.
(iii) Other factors appropriate for the specific facility.
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(2) An emergency plan submitted under paragraph (t)(1) of this section must include the following:
(1) A brief description of the facility and site area.
(ii) An identification of each type of accident for which offsite protective actions may be needed.
(iii) An analysis of the offsite exposures to toxic licensed materials from each type.of accident.
4 (iv) Identification of the means of detecting each type of accident
~
in a timely manner.
(v) A brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to protect workers onsite.
(vi) A brief description of the methods and equipment to assess off-site releases of radioactive materials.
- (vii) A brief description of the, responsibilities of licensee personnel should the accident occur, including identification of personnel responsibl,e for notifying offsite authorities and notifying the NRC Incident Response Center, i
(viii) The means of promptly notifying of offsite authorities and of requesting offsite assistance resources.
(ix) Methods for assuring that recommended protective actions and distances are unambiguously communicated to response organizations.
4 33 Enclosure 1
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[7590-01]
7 (x) Any special instructions the licensee would give to fire, police, I medical, and emergency personnel.
- (xi) A brief description of the means of restoring the facility to a safe condition after an accident.
(xii) Provisions for conducting onsite drills at intervals not to exceed two years.
(3) The licensee shall allow the local government authorities expected to respond in case of an accident 60 days to comment on the licensee's emergency plan before submitting it to the NRC. The licensee shall submit any comments received within the 60 days to the NRC with the emergency plan.
PART 70 - DOMESTIC LICENSING OF SPECIAL NUCLEAR MATERIAL
- 6. The authority citation for Part 70 is revised to read as follows:
AUTHORITY: Secs. 51, 53, 161, 182, 183, 68 Stat. 929, 930, 948, 953, 954, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2071, 2073, 2201, 2232, 2233, 2282); secs. 201, as amended, 202, 204, 206, 88 Stat. 1242, as amended, 1244, 1245, 1246 (42 U.S.C. 5841, 5842, 5845, 5846).
l ,
Section 70.7 also issued under Pub. L.95-601, sec. 10, 92 Stat. 2951 (42 U.S.C. 5851). Section 70.21(g) also issued under sec. 122, 68 Stat.
939 (42 U.S.C. 2152). Section 70.31 also issued under sec. 57d, Pub. L.93-377, 88 Stat. 475 (42 U.S.C. 2077). Sections 70.36 and 70.44 also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.C. 2234). Section 70.61 also issued under secs. 186, 187, 68 Stat. 955 (42 U.S.C. 2236, 2237). Section 70.62 also issued under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138).
34 Enclosure 1
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& 1 For the purposts of sec. 223, 68 Stat. 958, as amended (42 U.S.C.
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- 2273); SS 70.3, 70.19(c), 7p.21(c), 70.22(a), (b), (d)-(k), 70.24(a) and I (b), 70.32(a)(3), (5), (6), (d), and (i), 70.36, 70.39(b) and (c),
70.41(a), 70.42(a) and (c), 70.56, 70.57(b), (c), and (d), 70.58(a)-(g)(3),
and (h)-(j) are issued under sec.161b, 68 Stat. 948, as amended (42 U.S.C.
2201(b)); SS 70.7, 70.22a(a), and (d), 70.20b(c), and (e), 70.21(c),
70.24(b), 70.32(a)(6), (c), (d), (e) and (g), 70.36,70.51(c)-(g),70.56, 70.57(b) and (d), and 70.58(a)-(g)(3) and (h)-(f) are issued under sec.
1611, 68 Stat. 949, as amended (42 U.S.C. 2201(1)); and $$ 70.20b(d) and (e), 70.38, 70.51 (h) and (1), 70.52, 70.53, 70.54, 70.55, 70.58(g)(4),
(k), and (1), 70.59 and 70.60(b) and (c) are issued under sec.1610,
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68 Stat. 950, as amended (42 U.S.C. 2201(o)).
- 7. In 6 70.22 paragraph (1) is revised to read as follows:
S 70.22 Contents of applications.
(1)(1) Each licensee authorized to possess enriched uranium or i p"lutonium in quantities such that a criticality accident alarm systen is required, uranium hexafluoride in excess of 50 kg in a single container or .
1000 kg total, or in excess of 2 curies of plutonium shall submit either --
(1) An evaluation showing that the maximum dose to a person offsite due to a credible release of radioactive materials would not exceed I rem effective dose equivalent.or an intake of 2 mg of soluble uranium, or (ii) an emergency plan for responding to a release of radioactive materials.
(2) Each evaluation submitted under paragraph (i)(1)(1) of this section may include consideration of the following factors:
i 1
35 Enclosure 1
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- - (1) The radioactive material is physically separated so that only a portion could be involved in an accident.
(11) All or part of the radioactive material is not subject to release during an accident or to criticality because of the way it is stored or packaged.
(iii) In the case of fires or explosions, the release fraction would be lower than 0.001 due to the chemical or physical form of 8the material.
(iv) The solubility of the material released would reduce the dose received.
- (v) The facility design or engineered safety features in the~ facil-ity would reduce a release to lower values than those assumed in developing this section.
(vi) Operating restrictions or procedures would prevent a release large enough to cause an individual offsite to receive a dose exceeding I rem effective dose equivalent.
(vii) Other factors appropriate for the specific facility.
(3) Emergency plans submitted under paragraph (t)(1)(11) of this section must include the following information:
(1) A brief description of the facility and site area. -
(ii) An identification of each type of accident for which offsite l
protective actions may be needed.
(iii) An analysis of the offsite doses or, for the case of uranium hexafluoride, exposures to toxic radioactive material, from each type of accident.
l l (iv) Identification of the means of detecting each type of accident in a timely manner.
1 1
36 Enclosure 1 1
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& (v) A brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to o
prote.t workers onsite.
(vi) A brief description of the methods and equipment to assess releases of radioactive materials.
(vii) A brief description of the responsibilities of licensee personnel should an accident occur, including the identification of personnel responsible for notifying offsite authorities and notifying the NRC Incident Response Center.
(viii) The means of promptly notifying offsite authorities and of requesting offsite ' assistance resources.
(ix) Methods for assuring that recommended protective actions and distances are unambiguously communicated to response organizations.
(x) Any special instructions the licensee would give to fire, police, medical, and emergency personnel.
(xi) A brief description of the means of restoring the facility to a safe condition after an accident.
. (xii) Provisions for conducting drills at intervals not to exceed two years.
(4) The licensee shall allow the offsite governmental authorities expected to respond in case of an accident 60 days to comment on the licensee's emergency plan before submitting it to NRC. The licensee shall submit any comments received within the 60 days to the NRC with the emergency plan.
37 Enclosure 1
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[, 8. In S 70.23 paragraph (a)(11) is revised to read as follows:
S 70.23 Requirements for the approval of applications.
(a)(11) Where the proposed activity is processing and fuel fabrica-tion, scrap recovery, or conversion of uranium hexafluoride, the applicants proposed emergency plan for responding to releases of radioactive material is adequate.
Date at this day of , 1985.
For the Nuclear Regulatory Commission.
Samuel J. Chilk, Secretary of the Commission.
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i 38 Enclosure 1
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3/nAr Fnr: The Commissioners From: William J. Dircks, Executive Director for Operations
Subject:
PROPOSED RULE ON EMERGENCY PREPAREDNESS FOR FUEL CYCLE AND OTHER RADI0 ACTIVE MATERIAL LICENSEES
Purpose:
To obtain Commission approval for publication of a proposed rule
- in the Federal Register.
Category: This paper presents a policy issue on which the Commission has expressed interest.
Issue: Whether new emergency preparedness requirements for certain fuel cycle and other radioactive material licensees should be imposed through a rulemaking proceeding.
Background:
During the Commission's deliberations concerning nuclear power l plant emergency preparedness after the Three Mile Island accident, the Commission directed the staff to evaluate the need to change the emergency preparedness regulations for fuel cycle and other radioactive material licensees.
In late 1980, the staff reevaluated previously submitted emergency procedures and plans for fuel fabrication plants and found some
! apparent weaknesses.
Contact:
Stephen A. McGuire, RES 443-7636 03/27/85 CP EMER PRE FUEL CYCLE 3 - - i m - M""'**" _
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a For example, some licensees had no procedures on recommendations for specific actions the public should take to protect itself, such as sheltering or evacuation and arrangements for prompt notification of local government agencies.
Upon noting these weaknesses, the NP.C staff prepared orders to ,
require 62 licensees to submit comprehensive onsite radiological contingency plans (46 FR 12566). These orders, which were issued in February 1981, required some licensees, based on their licensed possession limits, to plan for actions that would be needed in the event of an accident. The orders were issued to operators of 4 fue1' processing and fabrication plants, UFs production plants, and radioactive material users authorized to possess large quant-ities of radioactive materials in unsealed form. As a result of these orders, about half of the affected licensees reduced their authorized possession limits for radioactive material so that they would not be required to submit contingency plans to NRC.
i On June 3, 1981, the Commission published in the Federal Register (46 FR 29712) an Advance Notice of Proposed Rulemaking on emer-gency preparedness for certain fuel cycle and other radioactive
! material licensees. In this advance notice, the Commission pro-posed to codify the radiological emergency requirements set forth in the orders mentioned above and to require that appropriate l arrangements to obtain needed support and resources be made with local, State, and Federal agencies. The Commission requested public comment and received 18 letters in response to its request. .
The comment letters were received from five Federal agencies, four State agencies, five corporations, one university, one laboratory, one non profit Federal corporation, and one letter from the Conference of Radiation Control Program Directors. The main comment was that there is no need for the regulations. In response, the staff has conservatively analyzed possible accident scenarios and concluded that at some facilities accidents for 1 03/27/85 CP EMER PRE FUEL CYCLE l_... . .. .. I ;
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- f The Commissioners 3 5
e l which protection actions should be taken by the public are possible.
The staff does find that the proposed emergency preparedness regu-lations are not cost effective, but that they are a matter of prudency. The analysis of accident scenarios is contained in the i Regulatory Analysis (Enclosure 3).
- - Discussion
- The staff is now requesting Commission approval to publish in the Federal Register proposed amendments to 10 CFR Parts 30, l' 40, and 70 on emergency preparedness for fuel cycle and other
. radioactive material licensees which may have the potential for l accider.ts that could result in radiation doses offsite that exceed l EPA's protective action guidelines for radiation exposure or might 1 approach the threshold for transient injury due to chemical toxi-
! , city. These proposed regulations would require certain licensees to maintain emergency procedures for offsite releases for which i NRC would make a determination of adequacy. The requirements j would be similar in nature to what NRC now requires for research i reactors because potential releases are relatively small in both cases. The criteria selected for establishing whether a licensed j facility needs such emergency preparedness to protect the public
- is whether an accident could deliver a radiation dose of 1 rem effective dose equivalent or 5 rems to the thyroid or n soluble uranium intake exceeding 2 milligrams (chemical toxicity) to an .
individual. Radiation doses for radionuclides deposited in the body are 50 year dose commitments, the dose that would be delivered over the 50 year period following inhalation.
The EPA recommends that actions to protect the public be consid-l ered if projected whole body doses due to an accident are in the range of 1 to 5 rems, taking into account the practicality of the l
actions that would be taken. The 1-rem dose was established parti-l cularly for the most sensitive members of the population (the unborn fetus and pre-school-age children). According to the linear non-threshold hypothesis of radiation effects, a 1-rem dose has 1 03/27/85 CP EMER PRE FUEL CYCLE
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I The Commissioners 4 chance in 10,000 of causing a cancer fatality. One rem is used because the potential releases are small. Thus, relatively small area and small numbers of people would be involved, thereby making it practical to take actions at a 1-rem projected dose. Thus, the staff believes 1 rem is an appropriate dose for requiring special emergency preparedness.
The EPA's 1 to 5 rem whole body protective action guides apply to radiation received uniformly over the body. To account for inhaled radionuclides that are deposited nonuniformly in the body, the effective dose equivalent from these radionuclides is used to replace the whole body dose equivalent. The effective dose equivalent is defined as the sum of the external radiation dose equivalent plus the 50 year dose equivalent to each body organ due to radioactivity deposited within the body multiplied by a risk weighting factor for the organ. The weighting factors are taken from Publication 26 of the International Commission on Radiological Protection.
Based on the conservative accident scenarios developed by the staff, the most serious accident considering consequences and probability is considered to be the rupture of a large hot cylinder of UFa. Chemical toxicity, not radiation dose, is the ,
overall concern.* The next most serious type of accident is considered to be a major facility fire at a large byproduct material licensed facility where radiation dose, not chemical toxicity, is the overall problem.
The accident scenarios and dose calculations which form the technical basis for the proposed rule are described in detail in "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle
- An ELD memo supporting NRC's authority to regulate UFs released based on chemical toxicity is attached (Enclosure 5).
03/27/85 CP EMER PRE FUEL CYCLE m;
n 1 I .
1 The Commissioners 5 and Other Radioactive Material Licensees," NUREG-1140,
)
(Enclosure 4). This document would be available to the public '
during the public comment period and comments on the degree of conservatism in the analysis would be specifically requested.
The staff has screened by computer all NRC's licensees gnd identified only 62 who would be covered by the proposed rule.
However, it is likely that about 16 of these licensees could amend their licenses to reduce the quantities of material they are authorized to possess and about 15 could perform an evalu-ation showing no need to be covered by the rule. Realistically, probably no more than about 31 NRC licensees would actually submit emergency procedurer, for offsite releases. These 31 licensees are essentially identical to those issued orders to require onsite contingency plans in 1981. An additional 5 Agreement State licensees might have to submit emergency procedures for offsite releases because the rule would be made an item of compatability with Agreement State programs. This estimate is based on assuming that about the same proportion of NRC and Agree-ment State byproduct material licensees would need emergency procedures for offsite releases.
Alternatives: 1. Publish the proposed rule (Enclosure 1) for public comment. ,
This has the advantage of allowing public comment on NRC's proposed policy and subjecting the staff's analysis to public l scrutiny. The disadvantage is that the value of the rule is much smaller than the cost of implementing it.
- 2. Issue license conditions instead of a proposed rule. This has an advantage of simplicity and speed. About 62 orders would be required. It has the disadvantage of not allowing public comment, not codifying NRC policy in this area, and not dealing with new licansees or amended licenses.
03/27/85 CP EMER PRE FUEL CYCLE
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- 3. No new requirements. The Commission may decide that no new requirements are needed. This could be based (1) on the unfavorable value/ impact, (2) on the very favorable accident history, or (3) on the basis that because of the nature of the desired response, it would be effectively accomplished without a special preparedness (i.e., people will move out of dense smoke and irritating HF clouds without having to be told to do so). The advantage of this approach is that there would be no additional expenditure of NRC resources or licensees resources.
~
R; source Estimate: NMSS staff estimated that the review of each new set of emergency procedures for offsite releases, including revisions, would require 4 man-weeks of effort. Review of each set would require only 4 man-weeks of effort because onsite contingency plans for all of the 31 licensees have already been reviewed. Thus 31 sets of emergency procedures for offsite releases would require 124 man-
> weeks or about 2.5 man years. This effort would re-occur every 5 years with license renewals for an annual effort of 0.5 man-years / year.
j IE staff estimated that the inspection of 31 plans would require 1.5 man years of effort the first year and 0.75 man years / year ,
thereafter.
RES staff estimated that Regulatory Guides on contents and formats of emergency procedures for offsite releases, instrumentation, and guidance on evaluations of accidents would require 2 man-years of effort.
Recommendation: That the Commission:
- 1. Approve a notice of proposed rulemaking (Enclosure 1) that would amend 10 CFR Parts 30, 40, and 70 to set out emergency 03/27/85 CP EMER PRE FUEL CYCLE l
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preparedness requirements for fuel cycle and other radio-active material licensees.
- 2. Certify that this rule, if promulgated, will not have a significant economic impact on a substantial number of small entities in order to satisfy the requirements of the Regulatory Flexibility Act (5 U.S.C. 605(b)).
- 3. Note:
- a. The proposed rule would be published in the Federal Register for a 90-day public comment period.
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- b. Appropriate Congressional committees will be notified of the proposed rule change (draft Congressional letter is Enclosure 2).
- c. An environmental impact appraisal prepared in connection with the subject amendment indicates that the proposed rule would not have substantive or significant environ-mental impact.
- d. The Chief Counsel for Advocacy of the Small Business ,
Administration will be informed of the certification regarding economic impact on small entities and the reasons for it as required by the Regulatory Flexibility Act.
- e. This proposed rule contains information collection requirements subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). This rule has been submitted to the Office of Management and Budget for review and approval of the paperwork requirements.
l 03/27/85 CP EMER PRE FUEL CYCLE m .. .- ._ . . .. ..u-
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T Itr The Commissioners 8
- f. Copies of the Federal Register notice of proposed rule-making will be distributed to all affected licensees, state governments, and persons who submitted comments on the advance notice of proposed rulemaking.
- g. A public announcement (Enclosure 3) will be issued when the proposed rule is filed with the Office of the Federal Register.
- h. A Regulatory Analysis has been prepared (Enclosure 4).
- 1. A copy of the proposed rule was provided to the ACRS for their information.
- j. Agreement States have been given a draft of the proposed rule for review and will be informed when the proposed rule is published. The final rule will be made a matter of compatability for Agreement States.
Sunshine Act: Recommenc; consideration at an open meeting.
William J. Dircks Executive Director for Operations
Enclosures:
- 1. Federal Register Notice of Proposed Rulemaking
- 2. Oraft Congressional Letter
- 3. Pubi'c Announcement
- 4. Regulatory Analysis
- 5. ELD Memo on Authority to Regulate Releases of UFs Based on Chemical Toxicity 03/27/85 CP EMER PRE FUEL CYCLE f..
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d TASK LEADER EVALUATION t
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SUPPORTING STATEMENTS TITLE:
Proposed Rule on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees CFR CITATION:
10 CFR 30, 40 and 70 TASK LEADER:
Stephen A. McGuire .(X37695)
SCREENING:
- a. The issue to be addressed. What is the appropriate level of emerging pre-paredness for certain fuel cycle and other radioactive material licensees for which a serious accident may have the potential to deliver a dose to a person offsite exceeding 1 rem effective dose equivalent, 5 rems to the thyroid? (The chemical toxicity of soluble uranium would also be con-sidered.)
- b. The necessity for addressing the issue. The Commission directed the staff to address the issue.
- c. Alternatives to rulemaking. The alternatives to rulemaking are: (1) re-quire by means of license conditions a level of preparedness equivalent to what the proposed rule would require, or (2) impose no new requirements on the basis that there is no demonstrated need for increased emergency pre-paredness. ,
! d. How the issue would be addressed through rulemaking. Certain facilities would be identified as requiring emergency plans. Those facilities would be those handling large quantities of UF, quantities of byproduct material in excess of specified amounts, or enougK special nuclear material that criticality accidents are plausible. The scope of the plans has not yet been agreed upon, but according to a llovember 1984 draft rule, the plans would include (1) an identification of the accidents for which offsite protective actions may be needed. (2) an analysis of the offsite conse-quences of those accidents, (3) the means of detecting those accidents, (4) the actions to be taken by the licensee to mitigate the consequences of the accident, (5) the responsibilities of licensee personnel should the accident occur, including identification of pecsonnel responsible for notifying local governmental authorities, (6) identification and telephone numbers of the local governmental authorities to be notified, (7) the text of the basic message to be given to the local governmental authorities, including what protective actions are recommended for the public and l
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J' distances to which the actions are recomended. (8) the resources the licensee expects to be provided by the local governmental authorities, (9) letters of agreement with local fire, police, and medical departments to provide those resources, (10) any specialized training the licensee would make available to the local authorities, and (11) criteria for reentering the facility and resuming normal operations after an accident.
- e. How the public, industry, and NRC would be affected. The public would have the assurance that in case of a serious accident they would be warned to take protective actions. The industry would be required to prepare emergency plans. The NRC would be required to review the plans and inspect the level of preparedness required by the plans. An estimate of NRC resources needed for enforcing the rule is under consideration.
- f. NRC resources and scheduling needed for the rulemaking.
- Staff time: 2 Man -Years } al.;r .ld., l- up ,1J ,
Contract support: .$395K
.." Scheduling: To EDO 3/85.
.- QUALITY CONTROL EVALUATION
- 1. A draft proposed ruled and a Regulatory Analysis have been prepared and
- were circulated for Office Concurrence on November 8, 1984.
- 2. A Supporting document for OMB approval will be prepared.
- 3. Congressional Comittees will be informed of the action.
- 4. A public announcement will be prepared.
l DRAFT RECOMMENDATION The rulemaking should continue.
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SUPPORTING DOCUMENTATION
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AIAY 3 01985-A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees
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T Manuscript Completed: May, 1985 Dr. Stephen A. McGuire Regulatory Analysis and Materials Risk Branch Division of Risk Assessment and Operations Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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N r c e
EXECUTIVE
SUMMARY
The question this Regulatory Analysis sought to answer is: Should the NRC impose additional emergency preparedness requirements on certain fuel cycle and other radioactive material licensees for dealing with accidents that might have offsite releases of radioactive material? To answer the question, we analyzed potential accidents for 15 types of fuel cycle and other radioactive material licensees.
The most potentially hazardous accident, by a large margin, was determined to be the sudden rupture of a heated multi-ton cylinder of UFe. Acute fatalities may be possible in the immediate vicinity of the release point. Acute permanent injuries may be possible for many hundreds of meters, and clinically observable transient injury of unknown long term consequences may be possible for distances up to a few miles. These effects would be caused by the chemical toxicity of the UFs and the products resulting from its reaction with moisture. Accompanying radiation doses would not be of significance.
The most potentially hazardous accident due to radiation exposure was determined to be a large fire at certain facilities handling large quantities of alpha-emitting radionuclides (i.e., Po-210, Pu-238, Pu-239, Am-241, Cm-242, Cm-244) or radiciodines (I-125 and I-131). However, acute fatalities or injuries to people offsite due to accidential releases of these materials do .
not seem plausible. A few other radionuclides are of lesser importance (H-3,
, P-32, Sr-90, and Cs-137). If plutonium were to be handled at fuel cycle
- facilities, a fire in such a facility may also be of significance.
The only other signif:lcant accident was identified as a long-term pulsating criticality at fuel cycle facilities handling high-enriched uranium or plutonium in aqueous solutions.
Aside from fires or accidents that lead to fires, UFe releases, or cri-ticality accidents, no other significant accidents were identified. Explosions were not sten to yield as large a release unless they were followed by a fire.
l Tank ruptures were not identified as having a potential for significant releases.
Earthquakes also were not identified as leading to significant releases unless i
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,T they were followed by a fire. Tornados might cause large release, but would disperse the material so widely ,that significant doses would not result.
The criterion for deciding whether an accident was significant is whether
} a release could cause a person outside the plant on the plume centerline to receive within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> an effective dose equivalent of more than 1 rem, a thyroid dose of more than 5 rems, or an intake of soluble uranium exceeding 2 mg. One rem whole body or 5 rems thyroid are at the lower end of the range of dose for which the EPA says protective actions should be considere8. A rough screening identified 64 licensees authorized to possess quantities of radioactive materials for which an accident release could cause doses exceeding 1 rem effective dose equivalent, 5 rems thyroid, or intake of 2 mg of soluble uranium. However, some of these licensees do not actually possess all of the materials authorized by.the license. These licensees are likely to amend their licenses to lower their possession limits rather than submit a plan. Other
- licensees could demonstrate that a significant release is not possible. In actuality, only about 30 plans would be submitted. For most of these licensees, however, the degree of hazard is small. For most such licensees maximum doses for even the most severe postulated accidents are only a few rems. The areas within which people should take protective actions are small - for most licensees much less than a square mile. At most sites these areas would contain l
few people. And the probability of a major release is small - less than 10 4/yr.
j The probability of a major release simultaneous with highly adverse meteorology is less than 10 s/yr. Thus the probability of even a single person's receiving a dose in excess of 1-rem at most of these facilities has about the same probability as a core melt accident with containment failure at a nuclear power, plant.
A further feature of major accidents at such licensed facilities is that airborne releases are likely to occur rapidly with little warning. Ruptures of UF. cylinders and fires would give little or no warning. Releases could start before a fire is detected or shortly thereafter. Plume travel time to nearby people is likely to be no more than a few minutes. Releases would in a majority of cases end within half an hour to an hour when the fire department controlled the fire. In most instances, actions taken half an hour after accident detection would be fairly ineffective. Actions taken 15 minutes after accident detection could on the average be expected to be roughly 50%
effective. Thus protective actions would have to be taken quickly. This requires predetermined actions to be taken by people in the vicinity of the ii
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site to notify nearby residents. There is not likely to be enough time for dose projections or complicated decisionmaking during the accident, nor for participation of personnel not in the immediate vicinity of the site.
An appropriate plan would (1) identify accidents for which protective actions should be taken by people offsite. (2) list the licensee's respon-sibilities for each type of accident, including notification of local authorities (fire anc. police generally), and (3) give sample messages for local authorities including protective action recommendations. This approach more closely follows the approach used for research reactors than for power reactors. The low potantial offsite doses (acute fatalities and injuries not possible except for UFe releases), the small areas where actions would be warranted, the sma'l number of people involved, and the fact that the local
- police and fire departments would be doing essentially the same things they normally do, are all factors that tend to make a simple plan adequate.
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o CONTENTS Page
.......................... 1 EXECUTIVE
SUMMARY
ACKNOWLEDGEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . vii a
- 1. PROPOSED ACTION . . . . . . . . . . . . . . . . . . . . . . . . . I 1.1 Description of the Proposed Action . . . . . . . . . . . . . 1 1.2 Need for the Proposed Action . . . . . . . . . . . . . . . . 3
- 2. TECHNICAL BASIS FOR THE PROPOSED RULE . . . . . . . . . . . . . . 4 2.1 Methodolo'gy ........................ 4 2.1.1 The Accident History Approach . . . . . . . . . . . . 4
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2.1.2 Accident Source Terms . . . . . . . . . . . . . . . . 6 2.1.3 Calculations of Doses . . . . . . . . . . . . . . . . 7 2.1.4 Protective Action Guides .............. 12 2.1.5 A Discussion of the Conservatism in the Calculations .................... 14 2.2 Fuel Cycle Facilities ................... 17 2.2.1 Uranium Mining ................... 17 2.2.2 Uranium Milling . . . . . . . . . . . . . . . . . . . 17 2.2.3 UFs Conversion Plants . . . . . . . . . . . ..... 25 2.2.4 Enrichment Plants . . . . . . . . . . . . . . . . . . 37 2.2.5 Fuel Fabrication - Uranium ............. 39 2.2.6 Fuel Fabrication - Plutonium ............ 50 l 2.2.7 Spent Fuel Storage ................. 56 2.2.8 New Fuel Storage .................. 59 -
2.2.9 Reprocessing of Spent Fuel ....... ...... 59 2.2.10 Research with Nuclear Fuels . . . . . . . . . . . . . 64 2.3 Byproduct Material Facilities ............... 66 2.3.1 A Generic Overview ................. 67 2.3.2 Radiopharmaceutical Manufacturing . . ........ 81 2.3.3 Radiopharmacies and Hospitals . . . . . . . . . . . . 83 2.3.4 Sealed Source Manufacturing . . . . . . . . . . . . . 84 2.3.5 University Research Laboratories .......... 89 2.3.6 Waste Warehousing and Burial ............ 90 2.3.7 Depleted Uranium Products . . . . . . . . . . . . . . 93 2.4 Summary of Facilities to be Covered ............ 96 l
. 2.5 A Protective Action Strategy . . . . . . . . . . . . . . . . 98 l
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CONTENTS (Continued)
.P. a[Le 2.5.1 The Initial Response ................ 98 2.5.2 The Relocation Phase ................ 104 2.5.3 The Assessment Phase . . . . . . . . . . . . . . . . . . . 105 2.5.4 The Food Pathway . . . . . . . . . . . . . . . . . . . . . 107
- 3. VALUE/ IMPACT .......................... 107 3.1 Alternatives . . . . . . . . . . . . . . . . . . . . . . . . 107 3.2 Value of the Propose Action ................ 107 3.3 Cost . . . . . . . . . . . ................. 109 3.4 Value/ Impact of Alternatives . . . . . . . . . . . . . . . . 110 n 4. STATUTORY CONSIDERATIONS ......... ........... 111 4.1 NRC Regulatory Authority . . . . . . . . . . . . . . . . . . 111 4.2 Agreement States . . . . . . . . . . . . . . . . . . . . . . 111
_- 4.3 Environmental Impact Appraisal . . . . . . . . . . . . . . . 111
- 5. CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . 112 FIGURE
- 1. Atmospheric dispersion calculated by CRAC2 for F stability, 1 meter /second wind speed . . . . . . . . . . . . . . . . . . . . 11 TABLES
- 1. Fires in Uranium Mills . .. ....... ........... 19
- 2. Uranium Mill Tailings Releases, 1959-1984 . . . . . . . . . . . . 20
- 3. Accident Source Terms and Doses From Uranium Mill Accidents . . . 22
- 4. Accidents Involving UF. Releases ................ 27
- 5. Criticality Accidents In Fuel Cycle Facilities ......... 40 .
- 7. Other Accidental Releases from Uranium Fuel Fabrication Plants . 43
- 8. Amounts of Radioactive Materials Released to Room Air Due to a Criticality Accident . ......... ........... 45
- 9. Offsite Doses Calculated for Fuel Fabrication Plants ...... 47
- 10. Calculated Releases and Doses from Spent Fuel Storage Accidents . 60
- 11. Fires and Explosions Involving Release of ByprodJCt Materials . . 68
- 12. Accidental Releases of Byproduct Material Except Fires i and Explosions ......................... 69
- 13. Quantities of Radioactive Materials Requiring Evaluation of the l
, Need for Offsite Emergency Preparedness . . . . . . . . . . . . . 75 l 14. Radiopharmaceutical Manufacturing: Maximum Possession Limits, Release Fractions, and Doses Due to a Major Facility Fire . . . . 82
- 15. Radiopharmacy: Maximum Possession Limits, Release Fractions, and Doses Due to a Major Facility Fire ............. 85 v
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CONTENTS (Continued)
- i Page TABLES (Continued)
- 16. Sealed Source Manufacturing: Maximum Possession Limits, Release Fractions, and Doses Due to a Major Facility Fire . . . . 87
- 17. University Research Laboratories: Maximum Possession Limits Release Fractions, and Doses Due to a Major Fire ........ 90
- 18. Waste Warehousing Airborne Releases and Doses Due to a Major Facility Fire . . . . . . . . . . . . . . . . . . . . . . . . . . 91
- 19. Beaufort Wind Scale (Simplified) ................ 99
- 20. Pasquill's Relation of Turbulence Types to Weather Conditions . . 100
- 21. Dose for Different Meteorologia1 Conditions Relative to F, 1 m/s . . . . . . . . . . . . . . . . . . . . . . . . . . . 100
- 22. Downwind Distances to Which Protective Actions Should Be Considered for an Accident Inyolving Five Times the Quantity of Material in Table 13 . . . . . . . . . . . . . . . . . . . . . 101
- 23. Downwind Distances to Which Protective Actions Should Be Considered for an Accident Involving 50 Times the Quantity
-- of Mate ri al i n Tabl e 13 . . . . . . . . . . . . . . . . . . . . . 103
- 24. Comparison of Costs and Benefits of Special Emergency Preparedness .......................... 110 O
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ACKNOWLEDGEMENTS We would like to thank the following people for helping us prepare this Regulatory Analysis.
David Benuett, Eugene Runkle, Daniel Alpert, Kenneth Adams, and i- David Aldrich of Sandia National Laboratory for performing dose calculations and meterological modeling.
Peter Dwczarski, Sue Sutter, Jofu Mishima, and Mark Halverson of Battelle-Pacific Northwest Laboratory for performing release fraction experiments, analyzing release fraction experiments, reviewing the literature on release fractions, developing accident scenarios, and analyzing accidents.
Moshe Simon-Tov and Reid Williams of Martin-Marietta Energy Systems, Oak
, Ridge, for performing analyses of UFs releases. Robert Just for discussions
, on the health effects of UFe.
Andreas Jensen of the John Hopkins University Applied Physics Laboratory for descriptions of the U.S. Department of Transportation accident modeling i
methods.
Joseph Logsden of the U.S. Environmental Protection Agency for discussions on the use of the EPA's protective action guides.
Paul Morrow of the University of Rochester and Mcdonald Ed Wrenn of the University of Utah for discussion on the chemical toxicity of uranium.
Duane Hall of 3M for hosting a tour of the 3M sealed source manufacturing ~
plant in New Brighton, Minn, and for discussion on the release fractions of poloni um-210.
Edward Janzow of Monsanto Research Corporation for hosting a tour of the Monsanto Dayton, Ohio, sealed source manufacturing plant and for information on the particle size of americium oxide powder.
Melita Rodeck of the Federal Emergency Management Agency for helpful comments.
Al Arcuni and Sandy Mullen of International Energy Associates Limited for helpful comments.
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7 On the NRC's Office of Nucient Material Safety and Safeguards staff:
[ Fritz Storz, Lee Rouse, and John Roberts for assistance in preparing the section on spent fuel storage; Dennis Sollenberger and George Gnugnoli for j
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assistance in preparing the section on uranium milling; Fred Fisher, Ed Shum, and R. Gerry Page for suggestions throughout the analysis; Joseph Wang for assistance in preparing sections in byproduct material licensees; Ron Cardarelli for help in collecting information in emergency plans submitted to NRC.
On the NRC's Office of Nuclear Regulatory Research staff: Steveh Bernstein and Don Solberg for assistance on accident scenarios and release fractions, as i well as contract assistance; Robert Kornasiewicz and Leta Brown for comments and assistance on meterological modeling; James Martin and Leonard Soffer for comments and assi, stance with regard to existing NRC policy on emergency prepar-edness, especially as it relates to nuclear power plants; James Norberg, Philip Ting, Robert Bernero, James Malaro, and Karl Goller for many helpful 4 i - comments and valuable support.
On the NRC's Office of Nuclear Reactor Regulation staff: Irwin Spickler
.- for many valuable comments and discussions on meterological modeling.
On the NRC's Office of Analysis and Evaluation of Operational Data staff:
Kathleen Black and Eugene Trager for help in collecting information on accident histories.
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t A REGULATORY ANALYSIS ON EMERGENCY PREPAREDNESS FOR FUEL CYCLE AND OTHER RADIOACTIVE MATERIAL LICENSEES
- 1. PROPOSED ACTION 1.1 Description of the Proposed Action This regulatory analysis evaluates the need for a proposed rule to require additional emergency preparedness for certain fuel cycle and other radioactive material licensees. The purpose of the rule would be to require, for certain licensees who are authorized to possess radioactive materials in large quantity, emergency procedures for offsite releases of radioactive materials. These would include:
(1) A brief description of the facility and site area.
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(2) An identification of each type of accident for which offsite ~
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(3) An analysis of the offsite doses from each type of accident, including doses from naturally occurring and accelerator produced radioactive material in addition to all ifcensed material.
(4) Identification of the means of detecting each type of accident in a timely manner.
l (5) A brief description of the means and equipment for mitigating the consequences of each type of accident, including those provided to protect workers onsite.
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(6) A brief description of the methods and equipment to assess offsite
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releases of radioactive materials and doses actually received.
(7) A brief description of the responsibilities of licensee personnel should an accident occur, including identification of personnel responsible for notifying offsite authorities and notifying the NRC Incident Response Center.
6 (8) The means of promptly notifying offsite authorities and of requesting offsite assistance resources.
(9) Methods for assuring that recommended protective actions and distances
- are unambiguously communicated to response organizations.
(10) Any special instructions the licensee would give to fire, police, medical and emergency personnel.
(11) A brief descriptien of the nearc, of restoring the facility to a safe condition after an accident.
(12) Provisions for condccting onsite drills at intervals not to exceed two years.
The question is not whether licensees should have any emergency preparedness.
That question was addressed long ago. The NRC has long required licensees to be prepared to cope with emergencies. The question is whether there should be additional requirements. For example, should NRC require formal written state and local government plans for coping offsite with serious radiation accidents?
Such plans might include provisions for early evacuation by the public or notifying them to take shelter indoors.
The question is also not whether State and local governments should have emergency preparedness capabilities for dealing with radiation accidents.
Police departments, fire departments, and other agencies that are routinely 2
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prepared to cope with emergencies already exist. This rulemaking is intended .
,$ to assure that, where needed, there exist emergency procedures for mitigating
- and coping with offsite releases.
We must also distinguish between emergency response and formal emergency procedures. If an accident happens, the licensee and State and local govern-ments can be expected to respond to the best of their abilities whether or not there are any formal written emergency procedures for offsite releases. The question is whether the response would be adequate if there were no written i
emergency procedures for coping with the emergency.
This regulatory analysis considers plausible accid 3nts for various types of fuel cycle and other radioactive material licensees. The analysis then determines for which types of facilities the response to an accident would f* involve so many people,'such large areas, and require such prompt actions that the response would not be adequate unless there were available additional special resources beyond those already existing.
1.2 Need for the Proposed Action The NRC has always required that its licensees take steps to reduce the likelihood of serious accidents to a minimal level, but yet be prepared to cope with accidents should they occur. However, during the Commission's delibera-tions on rulemaking concerning nuclear power plant emergency preparedness l
following the accident at Three Mile Island, the Commission directed the staff to evaluate the need to strengthen the emergency preparedness requirements for fuel cycle and other radioactive material licensees.
In late 1980, the staff reevaluated previously submitted emergency plans for fuel fabrication plants and found some weaknesses in the plans as written.
For example, some plans did not describe (1) timely alerting of potentially affected public to a hazard, (2) recomendations for specific actions the public should t3ke to protect itself, such as sheltering or evacuation, and (3) arrangements for prompt notification of NRC and state and local government agencies.
In February, 1981, the NRC issued orders ta 62 licensees to either submit comprehensive radiological emergency plans or 'ower their possession limits for radioactive material. About half of the licensees submitted plans, and half lowered their possession limits or surrendered their lice'se. Then, an 3
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- I Advance Notice of Proposed Rulemaking on the subject of offsite emergency pre-paredness was published in the Federal Register on June 3, 1931 (46 FR 29712). 1
- 2. TECHNICAL BASIS FOR THE PROPOSED RULE 2.1 Methodology This regulatory analysis identifies the classes of fuel cycle and other radioactive material licensees that could have accidents that might result in radiation doses to the public exceeding protective action guides established by the EPA. (Chemical toxicity is also considered for the special case of uranium hexafluoride and soluble uranium releases.) The plausibility of exceeding the EPA's protective action guides was considered from two points of view: (1) the accident history of fuel cycle and byproduct material licensees,
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and (2) theoretical calculations of the releases and offsite doses of accidents considered to be possible.
2.1.1 The Accident History Approach The history of accidents involving radioactive byproduct material (Part 30 licensees), source material (Part 40 licensees), special nuclear material (Part 70 licensees), and spent fuel storage (Part 72 licensees) was surveyed.
In summary, we found no evidence that any accidental release of radioactive material from facilities of these types has ever caused an effective dose equivalent to any individual offsite exceeding even 1% of th4 EPA's 1-rem protective action guide.
The value of the historical review is that it identifies types of accidents that have occurred and draws our attention toward accidents similar to those that have occurred. In addition, accidents that have happened cannot have violated the physical laws of nature. This statement cannot be made about theoretical calculations. Theoretical calculations can use simplifying issump-tions that are internally inconsistent or inconsistent with the laws of nature. '
More information on the nature, causes, and frequency of accidents is available for fuel cycle and other radioactive material licensees than is available for nuclear p&wer plants because there are so many more fuel cycle and other radioactive material licensees than nuclear power plants. Currently 4
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Y l the NRC regulates about 9,000 non-reactor licensees. In addition, Agreement
- States regulate roughly another 12,000 non-reactor licensees. A large number of these licensees have operated for many years, and the combined experience 1 of these licensees approaches half a million licensee years. By contrast, there are only about 70 nuclear power plants operating with about 1,000 plant-I years of combined operating experience. Thus more experience exists for fuel cycle and other radioactive material licenraes than exists for nuclear power plants.
Operating experience may be more relevant for these licensees than for nuclear power plants because of the nature of the accident driving force. In nuclear power plants the driving force is the enormous amount of heat in the reactor. The available energy is so large that some unique occurrences are conceivable, such as molten cores, large-scale metal-water reactions, and rupturing the containment by overpressurization. Because these events have
- never happened they can only be studied theoretically. The dominant driving forces for accidents at non-reactor licensees are common industrial accidents--
fires, chemical explosions, leaks, and the like. A great deal of industrial accident experience can be drawn upon in analyzing these potential accidents.
Much information on the accident history of fuel cycle and other radio-active material licensees is available. NRC regulations require the reporting of all significant events. All licensees must notify NRC of (1) the overexposure of any individual to radiation [10 CFR $20.403 and $20.405], (2) the airborne release of large quantities of radioactive material [10 CFR $20.403 and
$20.405], (3) the loss of one day or more of the operation of any facility
[10 CFR $20.403], (4) damage to property in excess of $2000 [10 CFR $20.403), ,
(5) the loss or theft of licensed material [10 CFR $20.402], (6) excessive radiation levels or contamination on packages received [10 CFR $20.205], and I
(7) major defects in equipment or noncompliance with regulations that have major safety significance [10 CFR $21.21]. In addition, there are other reporting requirements in NRC regulations that apply to specific classes of licensees. The reports that licensees have filed provide extensive information s
for evaluating the history of accidents in this part of the nuclear industry.
Since January 1975, the NRC has carefully and systematically published i reports describing accidents of significance, " Report to Congress on Abnormal Occurrences," NUREG-0090. Accidents in the fuel cycle and at byproduct mate-rial facilities are included for NRC licensees and Agreement State licensees.
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" l All these reports for the period from January, 1975, to September, 1983, were
- reviewed for this Regulatory Ar.alysis.
> Also, a comprehensive file of over 5,000 events from the period of 1950 through 1978 was compiled at Argonne National Laboratory. The file includes primarily events from NRC licensees (formerly AEC licensecs) and government-owned laboratories run by DOE (formerly ERDA and AEC), and some reports on accidents from Agreement State licensees and facilities in foreign countries.
Thefileincludeseventsfromnuclearpowerplants,thenuclearfuelbycle, and other radioactive material usage. A brief summary of 1634 events,in the commercial nuclear fuel cycle was published in 1981.* The Argonne file also includes some events from 1979, but is not complete for that year.
- In addition, other sources were searched for this analysis, such as NRC's
._ annual reports on radiation exposures, NRC's preliminary notification of unusual event reports, the memory of NRC staff members, and accounts published I -
in the open literature.
Using all these sources cf information this analysis should include most significant accidents for the years from 1950 through 1983. Although some events may have been omitted, it is believed that all relevant events in the United States that caused a significant release of radioactive material outside l a restricted area have been included.
l 2.1.2 Accident Source Terms l
Many plausible accident scenarios were considered for various types of facilities. The NRC considers in Safety Evaluation Reports a number of possible accidents and their effects on public health and safety before issuing licenses I
for fuel cycle facilities. The NRC requires applicants to evaluate possible i
accidents. Additionally, the NRC performs its own analyses of several severe accidents to determine whether there is adequate protection of public health and safety. The NRC's analyses are then issued when the license is issued.
l This regulatory analysis makes use of those NRC staff analyses in developing accident source terms.
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- Deborah J. Bodeau et al., Data Base for Radiation Events in the Commercial l
Nuclear Fuel Cycle. 1950-1978, NRC Report NUREG/CR-2429, 1981.
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The significant accidents were determined to be UFs releases, fires, and criticality accidents. Aside from the special cases of UF. releases and cri-ticalities, the release fractions for fires were considered to be larger than ,
the release fractions for other types of accidents. Thus, release fractions for fires, as described in Section 2.3.1.2, are used to determine the need for emergency preparedness.
2.1.3 Calculations of Doses Doses from airborne releases were calculated by assuming release fractions for radioactive materials, assuming a atmospneric dispersion model, and calcu-lating doses from three pathways-inhalation, cloud-shine, and ground-shine from
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particulates deposited on the ground. In general, the highest doses come from inhalation.
Two kinds of doses were calculated: effective dose equivalent and child's thyroid dose." The effective dose equivalent is the sum of the 50 year dose equivalent commitment to each body organ multiplied by a weighting factor for
- each organ as given in ICRP Publication 26 and, for the skin, ICRP Publica-tion 28.** For the inhalation pathway, dose conversion factors from ICRP Publication 30*** were used. Thyroid dose is the dose equivalent delivered to the thyroid by inhaled radiciodines. The child's thyroid dose is calculated by multiplying the value calculated for an adult by two.
For the two external dose pathways dose conversion factors from Kocher****
were used. An 8-hour ground exposure time and a 0.7 shielding factori (30%
- David E. Bennett et al., Preliminary Screening of Fuel Cycle and Byproduct Material Licenses for Emergency Planning," NUREG/CR-3657, March,1985.
- Statement from the 1978 Stockholm Meetina of the ICRP, Publication 28, International Commission on Radiological Protection, Pergamon Press,
- Oxford, 1978.
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- Limits for Intakes of Radionuclides by Workers, Publication 30, International Commission on Radiological Protection, Pergamon Press, Oxford, 1979 and 1980.
! ****D. C. Kocher, " Dose-Rate Conversion Factors for External Exposure to Photon j
and Electron Radiation from Radionuclides Occurring in Routine Releases from Nuclear Fuel Cycle Facilities," NRC Report NUREG/CR-1918, 1981. Also D.C.
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Kocher, " Dose-Rate Conversion Factors for External Exposure to Photons and Electrons, " Health Physics, g , 665, 1983.
i t" Reactor Safety Study," NRC Report WASH-1400, Appendix VI, page 11-23, 1975.
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I reduction) for a not perfectly flat surface were used to calculate the external exposure from radionuclides deposited on the ground. The basis for the 8-hour exposure to ground shine is that even if there is no pre-existing offsite emergency preparedness it should be possible to locate areas with high dose rates due to ground shine (greater than 100 mR/hr) and move people out within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The contaminated areas from which people would need to relocate would be small and generally near the site. >
The atmospheric dispersion model is a standard Gaussian plume model. Doses were calculated for two sets of meteorological conditions: stability class F with 1 m/s wind speed and stability class D with 4.5 m/s wind speed. The F, 1 m/s assumptions are those traditionally used by NRC in hazard evaluations and represent,very adverse weather conditions. The D, 4.5 m/s assumptions are
< those traditionally used by DOT in calculating evacuation distances for accidents involving toxic chemicals) and represent more typical weather. DOT considers
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evacuation distances based on D, 4.5 m/s adequate to protect public health and safety as demonstrated by experience with toxic chemical releases. The NRC's proposed rule associated with this analysis bases the need for emergency preparedness on the traditional NRC assumptions if F,1 m/s. The doses calcu-lated using the DOT assumptions of D, 4.5 m/s are included for perspective to show doses that would be expected under more typical or realistic conditions.
The intercept fraction for inhalation of 10 s is considered to be about the maximum value likely to be inhaled in an accident.* Using F, 1 m/s meteor-ology and the assumptions described below, 10 s corresponds to a distance of l 100 meters for the entire duration of the accident. Limiting the intake to 10 8 in effect means that a person on the plume centerline in dense smoke closer tha.h 100 meters from the release point will move out of the smoke before the release ends. Thus, the distance at which doses were calculated was taken to be 100 m i
from the release point in our mathematical model. This distance results in an intercept fraction of 0.89 x 10.s for radioactive materials that deposit on the t" Hazardous Materials-Emergency Response Guidebooks," Materials Transportation Bureau, U.S. Department of Transportation, DOT Publication DOT-P5800.2, 1980.
"" Upgraded Emergency Preparedness for Certain Fuel Cycle and Material Licensees,"
i 4_6 Federal Register 29712, 1981; " Criteria for Selection of Fuel Cycle and Major Materials Licensees Needing Radiological Contingency Plans," NUREG-0767, 1981; and Allen Brodsky, "Resuspension Factors and Probabilities of Intake of Material in Process (or Is 10 8 a Magic Number in Health Physics?)"
Health Physics, 39, 992, 1980.
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m ground. In other words a person on the plume centerline is assumed to inhale at most about one one-millionth of the material released regardless of the meteorology. )
Doses were calculated for a person standing in an open field in the down- ;
wind direction on the plume centerline breathing at a rate of 2.66 x 10 4 m8 /s.
Atmospheric stability class F and wind speed of 1 m/s were assumed. Doses to people in buildings would be smaller than the doses given in this analysis because buildings provide shielding and some respiratory protection. Doses to people standing outside in urban and suburban areas or wooded areas would be less than those given here because obstacles to wind flow would cause the plume to broaden.
Doses were calculated using a slightly modified version of the CRAC2 A computer code.* The CRAC2 code has been used extensively by the NRC for calcu-lations of doses that could result from nuclear power plant accidents.
~
The key input parameters for the CRAC2 calculations are building size, release duration, release height, dose conversion factors for each radio-nuclide, radioactive halflife of each radionuclide, and deposition velocity for particulates.
Building size determines the building wake factor or the initial plume dimension. In most cases the building size was assumed to be 25 m wide by 10 m high. For buoyant releases no building wake factor was used. At close in distances the building wake effect from a 250 m2 building significantly reduces the concentrations of airborne materials from a release. At distances of 1000 m, the building wake factor is relatively unimportant.
The release duration determines the amount of plume meander. Plume meander was not included at 100 m because the plume is considered to be still in the building wake.
Release height determines plume height and thus affects ground level concentrations. Greater release heights cause lower ground level air concen-trations. In this regulatory analysis, the release height was assumed to be ground level or at 20 meters. The 20-meter release height was used to account for buoyant plumes.
l *L.T. Ritchie et al., "CRAC2 Model Description," NRC Report NUREG/CR-2522, 1983.
i 9
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-The CRAC2 code accounts for the radioactive decay of materials in transit.
- In most cases this correction it, negligible. However, Kr-89 with a 3-minute
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half-life dominates the external dose from a criticality accident, so that in thi., case the decay correction is significant.
The CRAC2 code does not calculate radioactive decay while a material is held up in a building before release. A separate correction factor was deve-loped to account for radioactive decay before release to the atmosphere. This factor was used to reduce the quantities of short-lived radionuclides for cri-ticality accidents.
In calculating external dose due to clouds, the CRAC2 code performs the calculation for a finite-size cloud rather than an infinite-size cloud. The difference between the two can be substantial at distances as close as 100 m for stable atmospheric. conditions. For example, failure to correct for this factor at 100 m from a point release (i.e., no building wake) during class F stability
. - would cause external doses to be overestimated by a factor of almost 40. How-ever, the finite cloud correction factor is much smaller when building wake factors are used.
The results of the atmospheric dispersion calculations for inhalation are shown in Figure 1 for both F, 1 m/s and D, 4.5 m/s assumptions. Figure 1, giving X/Q in s/m3, can be used to calculate inhalation dose D in rems due to a released quantity Q in uCi by using the equation:
D = DCF x B x x/Q x Q where: DCF = dose conversion factor, rems /uCi inhaled, as given in Table 13 and ,
B = breathing rate, which is 2.66 x 10 4 m8 /s.
t The doses due to ground-shine and cloud-shine should be added to the inhalation dose to obtain a person's total dose. As a practical matter, however ground-shine and cloud-shine doses will be considerably smaller than the inhala-tion dose except for a few radionuclides (xenon, krypton, Na-24, Mn-56, Tc-99m, and Ru-105).
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~ bouyent releases.
- 30 minute release duration
- 1 cm/sec deposition velocity s
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2.1.4 Protective Action Guides
? I Protective action guides are projected doses to individuals in the popula-tion which warrant taking protective action. The EPA has published draft guides for taking protective action in order to avoid exposure to radiation as the result of an accident at a nuclear power plant.* The EPA recommends that pro-tective actions should be considered by responsible officials if projected 6 whole body doses are in the range of 1 to 5 rems. The lower dose of 1 rem is a level which "should be used if there are no major local constraints in providing pro-tection at that level, especially to sensitive populations" (children and preg-nant women). The EPA believes that "in no case should the higher value (5 rems) be exceeded in determining the need for protective action." Put another way,
- protective actions 'may be considered optional at I rem, to be taken if readily feasible, and mandatory at 5 rems. Note that the 1-rem and 5-rem doses are
~
projected doses that might occor after the protective action decision. Doses received prior to the decisionmaking and during the protective action imple-mentation time are not considered in the decisionmaking. Only dose savings l
as a result of taking a protective action are to be used in determining whether such protective action is warrented.
For radioactive materials that deliver dose to the body nonuniformly after
- they are inhaled, the resulting effective dose equivalent is compared to the
- EPA's protective action guides. The effective dose equivalent, as defined in the previous section, is the sum of the external gamma dose equivalent, the dose equivalent delivered to each body organ multiplied by a weighting factor for the organ from ICRP Publication 26, and the external beta dose equivalent delivered to the skin multiplied by the weighting factor from ICRP Publication 28.
The factors used to convert intake of radionuclides to an effective dose equiva-lent are taken from ICRP Publication 30.
The Commission's policy on the use of the EPA's protective action guides to establish planning zones for nuclear power plants is stated in NUREG-0654.**
- EPA-520/1-75-001, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," Draft Revision of June, 1980.
- NUREG-0654/ FEMA-REP-1, Revision 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," joint NRC/ FEMA Report, 1980, page 12.
l 12
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"The size (about 10 miles radius) of the plume exposure emergency planning
- zone was based primarily on the following considerations
- a. projected doses from the traditional design basis accidents would not exceed protective action guide levels outside the zone;
- b. projected doses from most core melt sequences would not exceed protective action guide levels outside the zone;
- c. for the worst core melt sequences, immediate life threatening doses would generally not occur outside the zone;
- d. detailed planning within 10 miles would provide a substantial base for expansion of response efforts in the event that this proved necessary."
For nuclear power plants the tradition design basis accident assumes the
- containment does not fail. In other words, one major barrier to a radioactive release remains. Failure of all engineered safeguards is evaluated with respect to life threatening doses rather than protective action guides in the 1 to 5 rem range. In addition, planning is not based on avoiding all loss of life for the worst case imaginable.
A later report elaborates on the Commission policy. NUREG-0771* states:
"For the small releases, the lower ranges of the protective action guides (PAG) would be used as the appropriate measure to base plan-ning. For somewhat larger releases, the criteria shift to the upper ranges of the PAG and levels of exposures which would still be less than medically detectable. For intermediate level releases early l,
injuries would be used as the measure to base the EPZ distance judg-ment on. Finally, for the most severe accidents, early fatalities become the immediate concern and therefore the measure to base the criteria upon. . ."
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i l *NUREG-0771, " Regulatory Impact of Nuclear Reactor Accident Source Term i Assumptions," for comment, June, 1981, page 35.
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For application to fuel cycle and byproduct material licensees, the lower end of the range (1 rem) of the EPA's protective action guides is used in con-junction with calculations of releases and offsite radiation doses due to severe accidents, such as a major facility fire, to establish the need for a plan.
Thus the lower range of the protective action guides is used to detemine the need for offsite emergency preparedness.
The actual assumptions that were used for each facility type are, discussed in separate sections in the remainder of this report. The reasons for selecting the assumptions are also discussed.
2.1.5 A Discussion of the Conservatism in the Calculations The Commission's policy is that, " Emergency planning should be based on realistic assumptions regarding severe accidents."*
The doses calculated in this Regulatory Analysis have been conservatively calculated. Doses to people near a plant experiencing a severe accident are likely to be far below the doses in this analysis, probably by an order of mag-nitude or more, except in very unusual circumstances. The accident history of such facilities in the U.S. is that there is no known case of a member of the public receiving even as much as 1% of the doses calculated in this analysis as the result of an accidental airborne release from any nonreactor facility.**
A number of factors which cause this analysis to be conservative are discussed below.
- "U.S. Nuclear Regulatory Commission Policy and Planning Guidan'ce - 1985,"
U.S. Nuclear Regulatory Commission, NUREG-0885, Issue 4, 1985, page 6.
a plume centerline dose equal to 4% of the 1-rem effective dose equivalent guide was calculated using conservative assumptions (no deposition, open l
field diffusion parameters, no wind direction shift, etc.) However, the
- ' report stated, "No specific information regarding the presence of individuals during the releases was available." Because no one is known to have stood on or near the plume centerline, we can say there are no known exposures exceeding 1% of 1-rem. The dose calculations are contained in an unpublished report, " Dose Assessment of Airborne Releases from NFS-Emin Fuel Facility -
1972-1981," U.S. Nuclear Regulatory Commission, Region II, Atlanta, Georgia,
! May, 1983.
14 I
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i 2.1.5.1 Conservative Factors
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- 1. Entire possession limit assumed to be involved. In calculating the quantities of radioactive material for which an emergency plan would be needed, this analysis generally assumed that the licensee's entire or nearly entire possession limit would be involved. In actuality, most licensees at any particular time possess much lasc material than they are legally authorized to possess. In many cases the possessed material will be located at different locations and will not all be subject to release during a particular accident.
l For example, the National Institutes of Health is authorized to use and store licensed material in more than 1,000 different laboratories.
! 2. Worst-case release fractions. The release fractions due to fires (the accidents with highest potential release) were determined from experiments designed to maximize releases. In such experiments a finely powdered material l
- is typically placed on top of a large amount of combustible material. Having the entire licensed inventory unenclosed on top of a large quantity of combusti-l ble material would be most unusual. Radioactive materials are usually within shielded " pigs" and kept in metal safes or well shielded hot cells or glove boxes. Amounts of combustible materials present are generally kept low.
- 3. No credit for engineered safeguards or response efforts. No credit is generally given for design or operating features that could reduce releases.
No credit is given for sprinkler systems designed to stop fires. Generally, no i
credit is given for filter systems during a fire. No credit is given for fire fighting efforts to stop the fire before it reaches radioactive materials.
Little or no credit is given for holding up the release of the material by mean,s of deposition or plateout. For UFs releases outdoors, no credit is given for knocking the uranium out of the air using fire hoses.
- 4. The exposed individual makes nu response. In the case of fires and UFs releases, the dose is calculated for a person who stands directly on the plume centerline for 30 minutes. Such a person would be standing in dense smoke or irritating acid fumes. Realistically, people can be expected to move from such positions to avoid smoke inhalation. People close in would only have to move about 20 meters to get completely out of the plume.
- 5. No plume-rise for smoke. Even where the assumed accident is a large fire no credit is given for plume rise due to buoyancy in calculating the cuantities of radioective material for which an emergency plan would be needed.
The smoke is assumed to be released at and remain at ground level.
15
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- 6. Conservative dosimetry. The material is assumed to have the solubil- 1 ity which would result in the highest dose per curie inhaled. Particulates are
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generally assumed to have a size of 1 micron making them highly respirable and transportable.
- 7. Adverse meteorology. Quantities of radioactive material for which an emergency plan would be needed were calculated for atmospheric stability class F with a 1 m/s windspeed. These conditions result in minimal dilution and high plume centerline doses, but also very narrow plumes. It is probable that the actual weather would cause lower doses. For example, doses during a moderately sunny day with average winds would be a factor of 50 times smaller than the doses calculated for the analysis.
- 8. Open-field site assumed. A rural open-field site is assumed. Greater
- atmospheric dispersion and thus lower doses would occur at an urban or suburban site. Buildings, trees, or other obstacles in the plume path would broaden the
~
plume. Heat sources would increase the plume height.
- 9. No wind shifts. Doses are calculated only on the plume centerline.
It i:: assumed that no wind direction shifts occur during the accident. In addi-tion, correction factors for plume meander are conservative; the factors were selected to envelope the experimental data. Normally greater plume meander would be expected.
- 10. 8-hour criticality. The source term assumes a pulsating criticality i' with a total of 48 bursts occurring over 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (see Section 2.2.5.2). This I
is a highly conservative source term.
- 11. There may be no one standing on the plume centerline. The doses are calculated for single point, and they fall off rapidly as one moves away from -
the point. Even with no protective actions, the highest dose anyone would receive is likely to be well below the assumed dose.
2.1.5.2 Nonconservative Factors On the other hand there are certain assumptions in the dose calculations that may be nonconservative in certain instances. These factors are discussed below:
- 1. Adult doses. Doses are calculated for adults rather than children (except for radiciodine doses which are calculated for children). This is because dose conversion factors for children using modern dosimeter models are generally not available. For some inhaled radionuclides a child standing in 16
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r the plume may perhaps receive a dote 2 or 3 times higher than an adult standing at the same location.
- 2. Breathina rates. The breathing rate used in the dose calculations Breathing rates for (2.66 x 10 4 m8 /s) represents an average breathing rate.
above average activity would be higher.
- 3. Site-specific factors not considered. The table of quantities of material for which emergency planning should be considered was based on assump-tions (for example building wake) that would usually be conservative, but may not be conservative for all instances. For example, the building wake factor for a particular building could be less than assumed although it would generally be larger. This should be a minor factor. Any increases in dose due to such factors would not be significant in size by comparison with the sizes of the
" conservatisms discussed above.
2.2 Fuel Cycle Facilities 2.2.1 Uranium Mining Uranium mining is not considered in this report because the NRC has no regulatory jurisdiction over uranium mining. Uranium mining is regulated l instead by the Mine Safety and Health Administration, the Environmental Protec-tion Agency, and the individual states.
2.2.2 Uranium Milling
~
i l
Uranium mills extract uranium from ore that typically averages about 1 part per 1000 uranium. The mills produce concentrated uranium compounds, which are shipped out in 55 gallon drums, and waste " tailings," which contain radium-226 and thorium-230 not removed from the ore by the mill processes. In late 1984 there were about 10 full-scale uranium mills operating in the U.S. In addition, there are smaller facilities that perform some of the processes found in milling.
Roughly half the mills are licensed by the NRC. The others are licensed by Agreement States.
In addition, this section considers "in-situ" solution uranium mining, in which a solution that has leached uranium from the ground is pumped up and uranium extracted from the solution.
17 l
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" 2.2.2.1 Accident History
- l 4
Uranium mills have experienced major fires and accfdental releases from tailings ponds due to dam failures or tailings line breaks.
Uranium mills have a potential for large fires because large quantities of kerosene are used as a solvent to extract uranium in one mill process. The kerosene contains dissolved uranium and is contained in large open tanks. Two a
large fires in solvent extraction circuits have occurred. ETable 1 lists fires known to have occurred. It is notable that the fires that have occurred have caused little release of radioactive material even though two of the fires were very intense.
Aside from fires, the other notable type of accident at uranium mills 7 has been tailings pond releases. There have been at least 16 instances where uranium mill tailings solids and liquids were released from tailings impound-ments. ETable 2 describes these releases. In no instances were there radiation dose rates that would cause doses to the public in the range of the EPA's protective action guides. In no case was drinking water contaminated above NRC limits (Appendix B of 10 CFR Part 20).
l 2.2.2.2 Accident Source Terms Potential releases of radioactive materials and potential doses that could result from accidents at uranium mills are shown in Table 3. The largest potential releases were determined to occur as a result of: (1) fires, (2) undetected failures of air cleaning systems, (3) tailing pond releases, and (4) tornadoes. Some reported calculations of the quantities released and projected offsite doses are shown in: Table 3.
l These calculations show that the largest offsite radiation doses would be l
l due to a fire in the solvent extraction circuit or an undetected failure of the air cleaning system servicing the yellowcake drying area. However, the
- undetected failure of the air cleaning system servicing the yellowcake drying area does not provide a basis for actions to protect the public. As long as the failure remains undetected no emergency plan can be activated and no protec-tive actions can be taken. As soon as the failure is detected, the release i can be stopped by turning off the ventilation blowers. Airborne concentrations l
l 18
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Table 1. Fires in Uranium Mills Fire Date Mill Description Offsite release 3-19-59 Vanadium Corp., Fire in yellowcake None detected of America, dryer Durango, CO 6-25-65 American Metal, Fire in ore None detected Grand Junction, dryer for 3-5 min.
l $2600 damage CO l'
2-68 Western Nuclear, Workers started a None detected Jeffery City, WY fire tc thaw a frozen ore dryci . Fire ignited propane from a leaking tank.
11-10-68 Petrotomics Co., Solvent extraction None detected Shirley Basin, WY circuit.
$300,000 damage
- 12-25-68 Atlas Corp. , Solvent extraction None detected l Moab, UT circuit. Cause unknown.
$1,000,000 damage i
! 10-23-80 Minerals Exploration, Major fire burned None. Radioactive Sweetwater, WY in mill before it material was started operation not yet being processed.
l 1-2-81 Atlas Corp., Fire in yellowcake None detected Moab, UT scrubber stack for 15 min .
l 19 l
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- 1 Table 2. Uranium Mill Tailings Releases, 1959-1984 l Date Mill Type of Incident Release 8-19-59 Union Carbide Tailings dam washed ~ 15,000 T sands lost to Green River, UT out river in flash floods; no increase in dissolving Ra e was noted in river.
8-22-60 Kerr-McGee Raffinate pond 240,000 gal of raffinate Shiprock, NM dike failure releases into river
- l
~ 50 x 10.s pCi/ml Ra-226; I river samples collected ,
several days after release showed no increase in Ra-226 background.
12-6-61 Union Carbide Tailings dike ~ 500 T solids released Maybe11, C0 failure from tailings area; 200 T reached unrestricted area;
- no liquid reached any stream.
6-11-62 Mines Develop- Tailings dike 200 T solids washed into ment, Inc. failure creek and some carried Edgemont, SD 25 mi into reservoir.
8-17-62 Atlas-Zinc Slurry pipeline Est. 280 T solids + 240 T Minerals rupture liquids released from Mexican Hat, UT broken tailings discharge line into draw 1.5 mi from
- river.
6-16-63 Utah Construction Precautionary Material released by 2 ft Riverton, WY release drainage cut made to prevent cresting due to heavy rains; ,
i material released below 10 CFR Part 2a values.
11-17-66 VCA Raffinate line Est. 16,000 gals of liquid Shiprock, NM failure lost because of break in raffinate line; material spread over 1/4 acre; break occurred 1 mi from river with some small amount reaching river.
2-6-67 Atlas Corp. Line failure 440,000 gal lost; average Moab, UT Ra-226 concentration was was 5.5 x 10 s mci /ml.
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[ Table 2. (continued)
I h Date Mill Type of Incident Release 7-2-67 Climax Uranium Tailings dike Dike failure released Grand Junct. ion, failure 1-10 acre-ft of waste CO liquid into Colorado River; no indication that Ra conc.
in river exceeded 10 CFR Part 20 limits.
11-23-68 Atlas Corp. Slurry pipeline 35,000 gal of tailings Moab, UT rupture slurry lost; flowed 1/2 mile to Colorado River;
- most solids settled out 7 in drywash.
2-16-71 Petrotomics Secondary tailings 2,000 gal of liquid lost Shirley Basin, dike failure to unrestricted area; spill WY froze in place.
t 3-23-71 Western Nuclear Tailings line and Break in slurry line casued Jeffrey City, dike failure a dike failure allowing sand WY tails to flow into natural basin adjacent to tailings site on licensee's property.
2-5-77 United Nuclear- Slurry pipeline 50,000 tons of solids and Homestake rupture slimes and somewhere between Partners 2 million and 8 million gal Grants, NM of liquid. All material was confined to company property.
4-77 Western Nuclear, Failure of tailings ~ 2 million gal of liquid Inc. pond embankment tailings and 55 yd8 of Jeffrey City, WY solids were released. No -
material was released to l unrestricted areas.
9-26-77 United Nuclear Release from Approximately 1 ton of 9-27-77 Church Rock, NM tailings slurry solids and 900 gal of liquid line entered the watercourse.
7-16-79 United Nuclear Tailings dike 100,000,000 gallons of tail-Church Rock, NM failure ings solution and 1,100 tons of tailings solids. Most of the solids were deposited near the impoundment, but much solution reached a river.
Reference:
Regulatory Guide 3.11.1, " Operational Inspection and Surveillance of Embankment Retention Systems for Uranium Mill Tailings."
21
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Table 3. Accident Source Terms and Doses From Uranium Mill Accidents Failure of the Air Fire in Solvent Cleaning System Serving the Yellowcake Drying Area Talling Pond Release Extraction Circuit Tornado Dose Release Dose Release Release Dose )
Reference Release Dose Small. Cleanup < 13 kg U < 1.36 rem a 11 kg insoluble 86 mrom ,
GEIS 11,400 kg U total < 2.2 x 10 7 rem 1400 tons solid < 0.65 kg thorium
- to bone at U oxides - to lung l to lungs at 500m 14,000,000 gal. assumed over 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at 2000 m
< 11,400 kg U 500 m i respirable 11gulds
- < 1.1 kg U 10 7 ren 12 kg insoluble 10 8 res 4550 kg U total < 1.1 x 10 7 rem Same as GEIS to bone U oxides over to lung at Sand Rock
< 4550 kg U at 4000m at 8000 m 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 8000 m DES respirable (max. dose) (nearest (nearest i
residence) residence)
- - 1.3 kg U 0.01 to -
This -
0.1 rem EDE Report References GEIS:
" Final Generic Environmental Impact Statement on Uranium Milling," NUREG-0706, Volume 1, pp 7-1 to 7-20. Septembe Sand Rock DES:
" Draft Environmental Statement Related to the Operation of Sand Rocks Mill Project," NUREG-0889, pages 5-1 to 5-12, March, 1982.
The value should The solvent extraction was assumed to contain 5% as much Th-230 as uranium by weight.
- The dose value from GEIS is in error.This error causes the dose to be overestimated by a factor of about 50,000 times.
have been 5% by activity.
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C of radioactive material promptly drop to very low levels. External exposure 7
y is negligible because uranium is a very weak gamma emitter.
l Tornadoes could release a larger amount of radioactive material. However, they spread the material so greatly that resulting doses are very small,* as shown in Table 3. Because the doses that would be caused by tornadoes are so much smaller than doses from other accidents, releases and doses due to torna-does are not discussed further in this analyses.
- Tailings pond failures also release a large quantity of material. However, the dose rates are less than 0.1 mR/hr and radioactive material concentrations 4
are so low that prompt emergency action is not needed to prevent anyone's dose from exceeding the EPA's protective action guides.
Thus we conclude that a fire in the solvent extraction circuit is the accident of greatest significance for emergency preparedness. We assume the release from the building is 1.3 kg of uranium. The 1.3 kg release is based on 0.1% of the material in process becoming airborne and escaping from the building. Experiments on releases of uranium in a kerosene fire showed average releases of 0.025% when the residue is not heated with a propane torch after dryness occurs.* Due to licensing policy requiring automatic fire detection and supression systems *** (such as automatic sprinklers, foam, or halon systems) significant heating beyond dryness would not be expected. 0ther experiments showed similarly low releases.t The uranium would be in insoluble form (solubility class Y) because a large kerosene fire would produce temperatures exceeding 400*C, the temperature at which the uranium should form insoluble oxides.**** The uranium may be class Y if the fire completely oxidizes the .
l*NUREG-0706, Volume 1, " Final Generic Environmental Impact Statement on Uranium Milling," September, 1980, p. 7-4.
- Jofu Mishima and Lyle Schendiman, " Interim Report: The Fractional Airborne Release of Dissolved Radioactive Materials During the Combustion of 30 Percent Normal Tributyl Phosphate in a Kerosene-Type Diluent," BNWL-B-274, Pacific Northwest Laboratory, 1973.
- Regulatory Guide 8.31, "Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium Mills Will Be as Low as Is Reasonably Achievable," Section C.3.4.
TD. Whitney Tharin, Jr. , " Burning of Radioactive Process Solvent," Savannah l River Laboratory Report LP-942, Aiken, South Carolina,1965.
'****R. C. Merritt, The Extractive Metallurgy of Uranium, Colorado School of Mines Research Institute, pp. 252-4, 1971.
23
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, soluble class D uranium in the solvent extraction tanks and converts it to insoluble uranium.
This source term of 1.3 kg of uranium is also considered to be suitable i'
for "in-situ" solution mining. Some "in situ" mining processes use solvent
. extraction processes similar to those in uranium mills. More severe accidents i than described above were not identified for "in-situ" mining.
I j 2.2.2.3 Calculations of Doses A 1.3 kg release of natural uranium due to a fire at an uranium mill could
- result in a potential dose of 0.1 rem effective dose equivalent during adverse weather (F, 1 m/s),or 0 01 rem during typical weather (D, 4.5 m/s). Assumptions were that the building size was 10 m high by 25 m wide, the release height was grcund level, and the release duration was 30 minutes. The factors for deter-j mining effective dose equivalent from ICRP Publication 30 for a particle size l of 1 micron AMAD and class Y solubility are
- 1.31 x 10s rem /Ci for U-234, 1.21 x 10s rem /Ci for U-235, and 1.17 x 10s rem /Ci for U-238. If 1 curie of uranium is composed of U-234, U-235, and U-238 in their naturally occurring proportions, the dose conversion factor is 1.24 x 10s rem /C1.
The calculated dose from this accident is small (0.1 rem or less) because of the very low specific activity of the uranium and the low volatility of the I
uranium compounds, which causes a low release fraction.
Low release fractions are the reason why no offsite ground contamination was ever detected due to the fires listed in Table 1. ,
2.2.2.4 Implications for Emergency Preparedness On the basis of the very low doses calculated, the staff concludes that there is no need for offsite emergency protective actions on the part of the public at uranium mills or for "in-situ" mining.
The staff concludes that no credible accident would justify emergency protective actions because radiation doses to the public offsite from an acci-dent would be below the EPA's protective action guides. Also, the quantity cf uranium inhaled is below the quantity where chemical toxicity effects are 24
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observed.h Thus, neither radiation doses nor chemical toxicity from licensed
- materials is a concern with respect to the need for prompt protective actions.
In the event of such a fire, the licensee would be required by existing NRC regulations to take certain actions. Among these, the licensee would be required by $20.201(b) to conduct surveys (offsite if appropriate) to determine whether the NRC's limits on radioactivity in effluents to unrestricted areas in $20.106 were exceeded. A major fire would also require immediate notifica-tion of NRC by telephone and telegraph ($20.403). If appropriate, the NRC could elect to immediately send an inspector to the site to make any necessary radiation measurements or evaluate the situation.
With respect to tailing dam failures, rapid emergency response is not needed to avoid doses exceeding protection action guides because dose rates at a spill site are very low. An appropriate response is to monitor drinking water, especially for radium-226, to be sure that drinking water standards are
- - met. Gamma ray monitoring of the ground is also appropriate to determine where the tailings have been deposited. However, ground contamination presents little immediate hazard to the public because the gamma dose rates are low. Gamma dose rates in contact with tailings should be less than 0.1 mR/hr. Since the EPA's protective action guides would not be exceeded, a rapid emergency response is not needed. A clean-up of the spilled tailings would be expected, but this could be done effectively without preexisting emergency preparedness.
2.2.3 UF Conversion Plants Conversion plants convert yellowcake shipped from uranium mills into .
uranium hexafluoride (UF.). Heated liquid UF is put into 10-ton or 14-ton cylinders. The cylinders are cooled for several days until the UFs solidifies.
! Eventually, the filled cylinders are shipped to enrichment plants to enrich the uranium in U-235. There are two NRC-licensed conversion plants: Kerr-McGee in Oklahoma and Allied Chemical in Illinois.
The uranium is handled in many different chemical forms in UFs conversion plants, but the UF. itself is the only chemical form of uranium that is readily dispersible. For example, the dispersibility of yellowcake is essentially the ,
- R. A. Just and V. S. Emler, " Generic Report of Health Effects for the U.S.
Gaseous Diffusion Plants," DOE Report K/D 5050,Section VIII, Part 1, I page 6, 1984.
25
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same as that of yellowcake at uranium mills. Accidents involving yellowcake were previously discussed and found not to require offsite emergency preparedness.
The release of UFs in significant quantity is possible because UFs is volatile above room temperature. The UFs released will react with water in the air as follows:
1 UF, + 2H 2O = UO2F2 + 4HF + 52.2 kcal/ mole
- The UO 2 2F forms a particulate, very soluble in the lungs, which will be carried away by wind and will settle onto the ground. The HF is a corrosive acid vapor that can severely harm the lungs if sufficiently concentrated. 'The release of 1 kg of UFs combining with 0.1 kg of water results in release of 0.88 kg of UO 2 2F (which contains 0.68 kg of uranium) and 0.23 kg of HF.
2.2.3.1 Accident History Table 4 lists significant releases of UFs that have occurred from all types of facilities, not just conversion plants. There have been many releases of UFs.
The releases have caused at least two prompt fatalities and several injuries.
The significant UFe releases have consistently been with UF heated above its melting point (65'C). The releases have generally been fairly rapid--lasting from a few minutes to an hour. The plumes, where they are highly concentrated, have been visible and immediately irritating to the lungs. The escape of UFs
~
can be diminished greatly if the leak can be sprayed with water.
Inhalation of uranium due to a UFs release can be verified by measurements of uranium concentrations in urine taken within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the exposure. The l
uranium from UFs has a biological half-life for expulsion via the urine of 4 to l 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.** Workers exposed to high concentrations have suffered edema of the lungs, presumably from exposure to HF, and kidney damage due to heavy metal
- Minton Kelly, Oak Ridge National Laboratory, Sept. 1983.
- M.W. Babcock and R. C. Heatherton, " Bioassay Aspects of a UF. Fume Release,"
Proceedings of the 12th Annual Bio-Assay and Analytical Chemistry Meeting, AEC Report CONF-661018, 1966, pp 147-159.
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z Table 4. Accidents Involving UF. Releases
?
I Type of Quantity of Facility facility UF released Cause and consequence Date Pre 1949 AEC facility Experimental Very large Rupture or explosion laboratory amount accom- of large tank. Two panied with workers killed. Three live steam other workers seriously injured, 13 others less seriously injured.
Pre 1949 AEC facility Not Believed to Sudden leak in a hot identified be 13 kg cylinder. One worker received injury to respiratory tract, 4 eyes, and kidneys.
Babcock & Fuel Not Leak in heat exchanger 5-10-60 allowed UO22F to escape Wilcox, fabrication reported
- Apollo, PA to river water. 60 x MPC at discharge point.
11-17-60 Union Carbide. Uranium Not Rupture of 10-ton Oak Ridge, TN enrichment reported cylinder.
Nuclear Fuel Fuel 15 kg HEU in An overheated 15-kg 5-25-62 Services, fabrication 5 min. 6 kg cylinder ruptured and Erwin, TN metal recovered in released its contents plant in the building.
3-20-64 Huclear Fuel Fuel 1 kg in 2 hrs. Overpressure burst tube Services, . fabrication Half recovered Erwin, TN metal onsite 2-14-66 National Feed 2300 kg in Operator accidentally Lead, material 1 hr. Much removed valve on a hot
- Fernald, OH production absorbed by 10-ton cylinder, deve-water spray loped lung edema, hospitalized 6 days.
No observed injury to kidney.
6-29-67 Kerr-McGee , UFa 45 kg in Gasket leaked due to Gore, OK conversion 15-20 min overheating.
45 kg of 1.6% Valve accidentally left 7-19-68 Kerr-McGee Fuel Crescent, OK fabrication enriched U open during heating.
in 15-20 min 27
g.
E'
- Table 4. (continued) 4- .
- Type of Quantity of Date Facility facility UFs released Cause 11-12-68 Allied UF, 43 kg Valve failure Chemical, IL conversion 5-2-73 Goodyear UF 100 kg in Worker broke valve on Atomic processing 20 min 10-ton cylinder.
Oak Ridge, TN (inside) 4-20-74 Numec, Mixed oxide 6 kg, slightly Apollo, PA fuel enriched fabrication 12-2-76 Exxon Nuclear, Fuel Small Worker disconnected
+ Richland, WA fabrication line but had forgotten to close valve.
~
3-7-78 Portsmouth Enrichment 9500 kg Rupture of dropped hot Gaseous plant in 1/2 to 14-ton UFs cylinder.
Diffusion 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Plant, OH 12-3-78 GE Fuel not known Block valve opened fabrication 8-7-79 NFS, Erwin Fuel <3 kg Accidental venting of TN fabrication cylinder to stack.
5-20-80 GE Fuel <1 kg Pipe flange failure fabrication 9-15-81 GE Fuel <<74 kg Gasket leak fabrication -
10-12-81 NFS, Erwin, Fuel 0.05 to 0.1 Release via main TN fabrication kg, HEU scrubber stack.
2-25-82 Exxon Fuel <<25 kg Gasket leak fabrication 12-83 Edlow Inter- Warehouse None Fire in warehouse.
national, East St. Louis, IL 28
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Persons injured or poisoning from uranium. At least two workers were killed.
killed in this manner have all been workers in a room working close to a UF.
cyliner.
Two of the cases involving the most serious exposures were reported by Howland.h These involved two fatalities, four serious injuries, and slight injury to 13 other people. One of the fatalities showed by autopsy roughly 1000 mg of uranium in the lungs. Howland concluded that the most serious injuries (observed on the skin, eye, mucous membrane of the upper respiratory tract, esophagus, larynx, and bronchi) were all caused by the action of the fluoride ion on the exposed tissues. Uranium produced transient urinary-tract changes. The conclusion is that HF and uranium both have adverse effects, but that the HF effects are the more severe.
In the National Lead-Fernald accident, one worker suffered lung edema, presumably from exposure to HF.**
No injury to his kidneys was observed. He excreted in urine over 1 mg of uranium in the first two days after the acci-dent, suggesting a total intake of roughly 2 tu 3 mg of uranium.
The largest release of UFs was the 1978 accident at the Portsmouth, Ohio gaseous diffusion plant. In this accident a heated thin-walled cylinder con-taining 14 (short) tons of natural UF. was dropped 6 to 10 inches and ruptured below the liquid level.*** Within one hour, about 9500 kg of UFs escaped.
This is equal to about 6400 kg of uranium. The release was outdoors. The air temperature was 32*F, the wind speed was 2 meters /sec, and a mixture of snow and freezing rain was falling. Snow covered the ground. About 550 kg of uranium were recovered on the ground afterva*ds. Agglomeration is likely to -
[
have increased the settling. About 4800 kg of uranium (75% of the release) were estimated to have become airborne and dissipated in the air, much thereby l
leaving the site. The site boundary in the downwind direction was at a distance of 2.2 km.
f
- Joe W. Howland, " Studies on Human Exposures to Uranium Compounds," in Pharmacolony and Toxicology of Uranium Compounds, edited by Carl Voegtlin i
and Harold Hodge, McGraw-Hill, New York, 1949, p 993.
- Babcock and Heatherton, op. cit.
- " Investigation of Occurrence Involving Release of Uranium Hexafluoride from a Fourteen-Ton Cylinder at the Portsmouth Gaseous Diffusion Plant on March 7, i
1978," DOE Report ORO-757, June,1978.
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- Water samples from a drainage ditch located near the release had a peak
{ uranium concentration of 450 mg/1, 10 times the NRC's radiological limit for I water to be released to unrestricted areas.*
The reported environmental effects were minimal. Workers who drove
. through the plume showed no detectable uranium in samples of their urine.
Significant ground and water contamination were confintd to distances of a few hundred yards from the release point. Airborne concentrations at the site 6
boundary (2.2 km) were calculated to be not high enough to be harmful for brief exposures.
Another large release of UF. occurred in France in 1977.t As the result
- of a handling error a valve ruptured on a container heated to 90-95'C. The UF immediately started to spill out onto the ground. The liquid flow lasted 5 10 to 15 minutes until the level of liquid in the container had fallen below '
the valve opening. Then UF. continued escaping as a gas until the valve was plugged with a wooden peg 30 minutes after the rupture. Of the 8800 kg of liquid UF. in the container, 7100 kg escaped.
Water and carbon dioxide were used to prevent the escaped UF from becoming airborne. However, 330 kg of uranium and 1600 kg of HF were not recovered.
Thus 7% of the uranium and 98% of the HF that escaped the container apparently became airborne. Weather conditions favored rapid dilution. It was a warm i and sunny afternoon with a windspeed of 9 m/s.
The French workplace limit for HF of 2.4 mg/m 3was exceeded up to a distance of 1200 meters. Ground contamination by uranium of up to 10 mg/m 2 was observed up to 600 meters. The area on which virtually all the solid uranium compounds settled did not exceed 1000 m2 , .
No injuries were observed. Urine samples were taken from 449 people.
Two workers excreted more than 0.5 mg during the first day, but no physio-logical symptoms were observed. No symptoms of the HF exposure were observed.
- The NRC limit for water in unrestriced areas in 10 CFR Part 20 Appendix B is 3 x 10.s microcuries/ml. Using the specific activity of natural uranium of 6.77 x 10 7 microcuries/ microgram, the effluent water standard is equiva-lent to 44 milligrams / liter.
TA.J. Docouret, "An Experience of Accidental Release of UF.," Coeurtex Plant, Pierrelatte, France.
30
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In addition to gaseous UF releases, conversion plants have released uranium to rivers. On Dec.1,1978 the Kerr-McGee conversion plant accident-
,a ally released 750 kg of natural uranium in the form of uranyl nitrate into a river. The liquid released had a uranium concentration of 1.4 times the MPC for water, which would then be diluted by the river water.
2.2.3.2 Accident Source Terms i
I The NRC staff, Sutter at Pacific Northwest Laboratory, and M. Simon-Tov
- at Oak Ridge National Laboratory have recently analyzed potential accidents at UF. conversion plants to estimate potential releases of UF..
The largest release postulated by the NRC staff is contained in an Environ-
- mental Impact Appraisal for the Allied Chemical conversion plant.** The NRC staff assumed that the largest release of UFs would be caused by the rupture of T
~
a heated 14-ton cylinder. The staff assumed that 9500 kg of UFs would escape and that the material would hydrolyze. As a result, 4800 kg of natural uranium would be released with the chemical form UO2 F2 , a highly soluble compound.
Sutter*** considered a number of possible accidents. These include:
( ,
J 1. The rupture of two 14-ton UF. cylinders outdoors in conjunction with :
a fire fed by 100 gallons of gasoline due to a truck crash
- 2. A leak of UF. from a pipe
- 3. A tornado strike j 4. Fires
- 5. Chemical explosions .
l I 6. Natural gas explosions The accident determined by Sutter to cause the most significant release is the rupture of two 14-ton UFs cylinders along with a gasoline fire. The initiation is assumed to be a truck accident in which the truck hits the 4
j *M. Simon-Tov et al., " Scenarios and Analytical Methods for UFs Releases j
at NRC-Licensed Fuel Cycle Facilities," NUREG/CR-3139, 1984.
- Environmental Impact Appraisal for Renewal of Source Material License, No. SUB-526. Allied Chemical Company UFm Conversion Plant, Office of Nuclear Material Safety and Safeguards, NUREG-1071, May, 1984, page 4-28.
- S.L. Sutter, et al., op. cit.
31
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A-cylinders, ruptures its gas tank, and catches on fire. A total release of
{ up to 3800 kg of UF. was calculated. The amount of material that could be released is limited by the amount of heat available to vaporize the solid UF .
Heat required to raise the temperature of the cylinder and UF. is neglected.
If the UF. cylinder is not ruptured, the heat is sufficient to raise the temperature of the UFs from 20 to 100*F. The pressure produced would not be enough to rupture the cylinder.
- Simon-Tov's work was directed toward determining accident scenarios and analysis methods for UFs releases. His work is the most recent and most comprehensive. Twenty-five release scenarios are described in his report (Chapter 5). The scenario most appropriate for this analysis is the rupture of a heated liquid-filled cylinder outdoors. At a temperature of 100*C, 57% of the liquid UFs could be vaporized. At 120'C, 65% could be vaporized (Figure 11, page 58). The most important parameter for determining the release is the temperature of the cylinder. Thus the largest release is from a cylinder just-filled. Analyses of plausibile fire scenarios involving cooled cylinders show that the UF. cannot be heated sufficiently to cause as large a release as from a hot cylinder.
For the purpose of this regulatory analysis, the release to be evaluated for UFs conversion plants will be one similar to the one that occurred at the Portsmouth gaseous diffusion plant. That accident involved the rupture of a hot 14-ton UFs cylinder outdoors with a release of 9500 kg of UFs (equivalent to 6400 kg of natural uranium). It is assumed that 4800 kg of natural uranium becomes airborne and the remainder settles on the ground due to agglomeration and impaction. The release was calculated by W. Reid Williams as likely to occur in about 15 minutes. There would be no advance warning. Because the i
release is assumed to be outdoors, no automatic detection or alarm system i
would detect the release. Rather, plant personnel are assumed to detect the release and then take emergency measures.
l The plume would be readily detectable to the human senses because of the HF and its resulting irritation. Therefore no monitoring instruments are needed to detect high concentrations.
32
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a 2.2.3.3 Calculations of Doses
. y The release of UF. presents a chemical rather than radiological hazard.
Exposures lethal due to uranium chemical toxicity or HF burns on lung tissue would not result in radiation cses exceeding 1 rem effective dose equivalent.
Therefore, radiation doses are not calculated. The release assumed is the escape of 9500 kg of UF in 15 minutes due to the rupture outdoors of a heated 14-ton cylinder. The mass of uranium in 9500 kg of UF is 6400 kg. Some of the uranium will be removed from the air initially by agglomeration and impac-tion. We assume 4800 kg of uranium becomes airborne. The corresponding mass of HF is 1620 kg.
Intakes are calculated for atmospheric stability class F with a wind speed of 1 m/s as well as stability Cisss D with wind speed of 4.5 m/s. The plume is assumed initially to have a centerline near ground level. The heat from the chemical reaction of UF. combining with the moisture in the air will cause the plume to become bouyant. Calculations by W. Reid Williams indicate the plume would lift off within 20 to 30 meters and a plume centerline height of about 20 meters would be obtained within 200 to 300 meters. However, we do not consi-der Williams' model to be sufficiently developed at this time (May, 1985) to use in this Regulatory Analysis exclusively. Therefore, we present a range of intakes, assuming the plume is neutrally bouyant for one end of the range and assuming a 20-meter plume centerline height (but not building wake) for the other end of the range.
The equation for uranium intake I is:
X I=QxBxg where Q = the released quantity (4800 kg),
B = the breathing rate (2.66 x 10 4 m8 /s), and X/Q = the atmospheric dispersion value from Figure 1.
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$ Uranium intake due to the airborne release of !
4800 kg of uranium 1 Uranium intake (ag) i Distance F, 1 m/s F, 1 m/s D, 4.5 m/s D, 4.5 m/s (meters) bouyant ground bouyant ground 100 0 4000 6 540 200 6 2000 53 210 300 46 1100 59 120 500 110 530 40 54 700 110 310 28 32 1,000 92 170 17 18 1,500 62 80 10 10 2,000
~
44 45 6 6
- i. 5,000 11 6 1.6 1.5
< 10,000 3 0.8 0.5 0.5
- 15,000 1 0.2 0.3 0.3 20,000 0.6 0.04 0.2 0.2 a -
The exposure to concentrations of HF can be calculated similarly. Expo-sures due to the airborne release of 1620 kg of HF are shown below.
HF exposure due to the airborne release of 1620 kg of HF HF exposure (eg/m3 )
Distance F, 1 m/s F,1 m/s D, 4.5 m/s D, 4.5 m/s (meters) bouyant ground bouyant ground 100 0 5900 9 790 i 200 9 2900 77 310 -
300 68 1700 86 170 l' 500 160 770 59 79 700 160 450 41 47 1,000 140 250 25 27 1,500 92 120 14 15 2,000 65 67 9 9 5,000 16 9 2.3 2.2 10,000 5 1. 2 0.8 0.7 15,000 1.8 0.2 0.4 0.4 20,000 0.9 0.06 0.3 0.2 34 u-. -
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[ 2.2.3.4 Implications for Emergency Preparedness
.p.
Of all the accidents considered in this Regulatory Analysis, the rupture of a heated 14-ton cylinder of UFs is clearly and by far the most hazardous to people offsite. The corrosive effects of exposure to HF and heavy metal poison-ing due to uptake of uranium are discussed separately below.
Heavy metal poisoning: We consider the best estimates of the health effects of uranium intake to be those in two DOE reports
- based on tdb work of a panel of experts on uranium toxicity. The effects are summarized below:
Health Effect Intake (ma) 50% Lethality 243 Permanent damage 45 Renal injury (transient) 8.6 No effect 4.5 It is not likely from the calculated results that lethal intakes are actually plausible for outduor releases of UFs. In order to calculate lethal intakes it is necessary to assume little or not buoyancy, which is believed to be incorrect, and little or not effort on the part of the exposed individual to escape the plume, which may not be a reasonable assumption. We conclude that lethal intakes of uranium by people offsite are not really plausible under realistic conditions.
Permanent kidney damage, on the other hand, does appear pos:ible. From the intakes calculated above permanent kidney damage could occur as far as 2000 m (1.2 miles) under very adverse weather (F,1 m/s) and no attempt to escape the plume, Under more typical conditions (D, 4.5 m/s, some buoyancy, and attempted escape) permanent kidney damage would not be expected offsite.
Transient kidney injury appears to be quite plausible. Under high adverse conditions (F, 1 m/s) it might be possible as far as five miles away. Under more typical conditions (D, 4.5 m/s and some escape attempt) transient injury might occur as far as 1 mile away.
- R. A. Just and V. S. Emler, " Generic Report on Health Effects for the U.S.
Gaseous Diffusion Plants," DOE Report K/D 5050,Section VIII, Part 1, 1984.
35
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I It is Commission policy for nuclear power plant accidents to plan to avoid 7 acute fatalities and serious injuries for the worst case accidents and protec-
- tive action guide doses for more probable accidents. With this in mind, the recommended protective action for rupture of a 14-ton cylinder would be evacua-tion to a distance of 1 mile, if possible. This would avoid acute fatalities and serious injuries for worst-case accidents and transient kidney injury under more typical conditions.
M: Estimates of the health effects are from a recent DOE repork.* The effects described here are based on concentration as applied to a 15 minute exposure:
Health effect HF concentration (mg/m3 )
Leth'al (15 min) 3500 Unbearable for 1 min 100
.- Irritation (15 min) 13 Detectable by smell but no health effects 2.5 From the calculated HF exposures given above, lethal exposures offsite are not plausible.
Unfortunately, levels for permanent injury are not known. As a consequence we are substituting the concentration of 100 mg/m 3 as the level considered to be " unbearable" for more than a minute. Such levels may occur out to about 1500 meters under adverse conditions. Generally, they would not be expected to occur offsites under typical conditions (D, 4.5 m/s) if one discounts some-what the ground level release values. .
Irritation appears possible out to at least 5000 meters (3 miles) under adverse meteorology and roughly 1500 m (1 mile) under typical conditions.
Thus the consequences of HF exposure are similar in seventy to those from uranium intake. Consequently the one-mile evacuation suggested for the rupture of a 14-ton cylinder of UFe is appropriate for protection against both uranium and UFs.
l
- R. A. Just and V. S. Emler, " Generic Report on Health Effects for the U.S.
Gaseous Diffusion Plants," DOE Report K/D 5050,Section VIII, Part 1, 1984.
36
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The U.S. Department of Transportation has also established evacuation guides
,'~. for HF releases.'P v For small leaks (drum, small container, small leak from a tank) the DOT recommends isolation in all directions to a distance of 240 feet (75 meters). For a large spill from a tank (i.e. railroad tank car) the DOT recommends isolation in all directions to a distance of 490 feet (150 meters) and then evacuation in a downwind direction to a distance of 1.8 mile and a width of 1.2 mile. The DOT distances, however, are based on a larger quantity of HF. Thus, the one-mile distance suggested here is consistent with DOT recom-mandations. DOT evacuation distances are based on atmospheric stability Class D and wind speed of 4.5 m/s. DOT states that evacuation distances based on those assumptions have proven to be adequate under actual accident situations.
. 2.2.4 Enrichment Plants At present there are no NRC-licensed enrichment plants, nor are there any immediate prospects for one. Basically, however, enrichment plants receive UF from conversion plants and ship UF , enriched in U-235, to fuel fabrica-tion plants. Thus the types of potential accidents are similar to those at conversion plants and fuel fabrication plants.
2.2.4.1 Accident History Several large releases of UF have occurred at enrichment plants, as shown in Table 4. These have been the result of the ruptures of heated large 10-ton or 14-ton cylinders. The largest release was the 1978 cylinder rupture .
at the Portsmouth, Ohio gaseous diffusion plant, which released 9500 kg of UFe.
I i
! *" Hazardous Materials-Emergency Response Guidebook", U.S. Department of i Tranf,portation report DOT-P5800.2, 1980, op. cit.
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$ 2.2.4.2 Accident Source Terms 7
Source terms for two types of accidents are considered: UF. releases and criticality accidents.
. The UF. release for natural uranium is considered to de the same as for the UF. release previously discussed for UF. conversion plants in Section 2.2.3.2.
The UFs releases for enriched uranium are considered to be the same as those for fuel fabrication plants that will be discussed in Section 2.2.5.2.
The criticality accidents is assumed to be the same at the criticality accident for the fabrication plants that will be discussed in Section 2.2.5.2.
2.2.4.3 Calculations of Doses Doses due to a UF, release from the rupture of a 14-ton cylinder of 5' natural uranium are the same as those given in Section 2.2.3.3 for UFs conver-sion plants. Doses due to UFs releases of low and high enriched uranium are the same as those that will be given in Section 2.2.5.3 for fuel fabrication plants.
Doses due to a criticality are the same as those given for a criticality at a fuel fabrication plant in Section 2.2.5.3.
2.2.4.4 Implications for Emergency Preparedness Offsite emergency preparedness at uranium enrichment plants should be based on chemical toxicity from a large UF release. Thus, uranium enrichment -
plants should be considered a potential chemical hazard, not a radiation hazard.
Basically, uranium enrichment plants should have the same level of offsite emergency preparedness as UFs conversion plants. Currently, enrichment plants, if licensed, would be covered under Part 50 of NRC regulations. The emergency preparedness requirements in Part 50, which were developed for nuclear power plants, are clearly excessive for enrichment plants. However, because NRC does not currently license any enrichment plants, the discrepancy is academic.
38
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- 2.2.5 Fuel Fabrication - Uranium
$ Fuel fabrication plants generally receive UF enriched in the uranium-235 isotope, convert it generally into highly refractory uranium oxides, form the i uranium oxides into pellets, and load the pellets into metal-clad fuel elements for shipment to nuclear power plants. In most cases the uranium-235 is enriched to less than 5%, but at several plants the enrichment exceeds 93%. However, only one licensed plant (Nuclear Fuel Services, Erwin, Tennessee) currently handles the volatile UFs in highly enriched form.
2.2.5.1 Accident History
- Among the accidents that have occurred in processing uranium are criti-cality accidents, fires, and releases of UFe.
~
Since the first successful self-sustair.ing nuclear chain-reaction there have been no less than 37 occasions when the power level of fissile systems rose unexpectedly because of unplanned or unexpected changes in system reac-tivity. Of these 37 cases, six cases caused eight deaths, two of which occurred in the early, rushed pace near the end of World War II.
Of these 37 criticalities, eight occurred in fuel cycle facilities (7 in the U.S. and one abroad) and are thus relevant to this analysis. The remaining 29 occurred in nuclear reactors or critical assembly experiments. The seven relevant U.S. fuel cycle facility criticalities are listed in(Table 5. One occurred in a licensed facility (Wood River Junction, R.I., 1964).
There are several lessons about criticalities that can be learned from -
studying these accidents. Accidental critica11 ties can occur and occasionally do. When they occur the doses to workers can be very large, sometimes fatal, and sometimes requiring hospitalization. Radioactive solutions can be ejected and can contaminate workers and the plant area. No offsite contamination or radiation doses have been reported.
l 39
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Table 5. Criticality Accidents In Fuel Cycle Facilities
! Contamination i
Total Contamination Out of Building l
Cause Fissions Duration Personnel Exposures In plant Dato Location Process 8 people. Doses of 461, Small local Mone 1.3 x 10 s 18 min June 16, Y-12 Process- Recovery of highly Wash water added to 418, 413, 341, 298, 87, contamination reported i-1958 ing Plant, enriched uranium UDa(NGs): solution 29 reds. No fatalities.
Oak Ridge. TM by chemical in 55 gal. drum.
methods. Mone Liquid phases of 1.5 x 1017 1 sec 3 people. Doses of Mone reported Dec. 30 Pu Process- Recovery of 12,000, 134, 53 rads. reported 1958 ing Plant, plutonium from plutonium separated One fatality.
Los Alamos, IM scrap. out.
Not Transfer of highly Solution transferred 4 x 101' 15 to 19 people. No direct Yes reported Oct. 16, Idaho Chemical 20 min gamma or neutron dose airborne Processing enriched uranium to unsafe geometry beta 1959 (5000 gal tank) because tank was Plant. Idaho solution. shielded, but beta activity l
Reactor Test doses from released Site radio activity of 50 ren, 32 rads, and
! smaller amounts for I 17 other people.
8 I see None. Shielded None Mone 1
Jan. 25 Idaho Chemical Transfer of highly Solution transferred 6 x 101' operation reported reported Processing enriched uranium to unsafe geometry
, 1%1 I Plant. Idaho solution.
I Reactor Test
- Site 3 people. Doses of 110, None None Hanford Works, Plutonium Plutonium solution 8 x 1017 37.5 hr reported reported I April 7 incorrectly siphoned 43, 19 rads.
1962 Richland, WA processing 3 people. Doses of 20E of Mone July 24, Scrap Recovery Recovery of highly Solution hand-poured 1.3 x 1017 2 short 10,000, 100, 60 reds. solution reported l into unsafe geometry pulses i 1964 Plant, Wood enriched uranium 1.5 hrs One fatality. splashed j River Junction, apart out of tank l
RI Air, monitors Filters 3 x 101s 15 min Less than .13 rem.
Oct. 17, Chemical Solvent extraction (In shielded cell) detected removed Processing column considerable most 'l 1978 Plant, NRTS, ID activity particles 1 < 1 hr f and " Recovery of ICPP from Criticality Event of
References:
William R. Stratton, "A Review of Criticality Accidents," AEC Report LA-3611,1967
) i October 17, 1978," DOE Report ACI-362. November, 1978.
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y
? l A number of fires and explosions involving uranium or thorium, which would I behave similarly, have been reported. Uranium metal is pyrophoric. Uranium metal, heated or in powdered form or heated as a solid will spontaneously ignite i if exposed to air. Reported fires and explosions involving uranium or thorium are included in Table 6 below. What is noteworthy is that these fires have had little consequence with regard to either personnel exposure or ground contamina-tion. Reported offsite contamination levels were generally below the levels that the NRC allows on equipment to be released for unrestricted use.h By comparison, the accident record for plutonium, which has a much higher specific activity, is much different. Plutonium accidents have been charac-terized by extensive radioactive contamination and personnel exposures. Yet even the most serious of these accidents, the Rocky Flats fire, caused only
, a small fraction of the plutonium involved to be released. Of hundreds of kilograms of plutonium involved in the fire, only 0.003 g was released through a damaged exhaust system.** Thus the overall release fraction for plutonium was about 10.s, based on the estimated release quantity compared to the quantity involved in the fire.**
Table 7 lists other accidents involving uranium fuel fabrication, but not including UFs releases, fires, or exposions which were listed previously.
These accidents in Table 7 all involved ventilation systems. None of the accidents listed in Table 7 caused any offsite doses approaching the 1 rem lower limit of the protective action guides.
- Surface contamination levels for uranium allowable on equipment to be released for unrestricted use are average: 5000 dpm alpha /100 cm2, maximum: ~
l 15,000 dpm alpha /100 cm2 , and removable: 1000 dpm alpha /100 cm2 . These values are found in Regulatory Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors," and " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," USNRC, July,1982.
- H. K. Elder, " Technology, Safety and Costs of Decommissioning Reference Nuclear Fuel Cycle and Non-fuel Cycle Facilities Following Postulated Accidents," NUREG/CR-3293, page 3.3, 1985.
41
r m_ _ ._._
e E
7y 7
Table 6. Fires and Explosions Involving Uranium and Thorium v
Date Facility Release Description 6-27-49 Los Alamos None reported Fire broke out in a drum Laboratory, NM containing uranium metal turnings.
10-29-52 Truck in Kansas Considerable Truck carrying uranium City, M0 metal burned. Urpnium ignited and much fras lost.
12-9-52 AEC facility None Molten uranium metal was being cast in a vacuum.
Spill ruptured vacuum.
Uranium then burned.
. 6-12-53 U.S. Onsite contamina- Explosion of powdered tion up to 15,000 uranium and CC1 4 in
' dpm/100 cm2 . glovebox.
8-20-56 AEC contractor 100,000 dpm/ Thorium explosion
- 100 cm2 onsite.
500 dpm/100 cm 2 offsite.
9-21-56 Truck in Detroit, None Drum containing thorium MI metal started to burn.
No contamination. No exposures.
6-23-58 AEC contractor No material Fire in slightly Attleboro, MA loss enriched uranium scrap in perchloroethylene.
9-26-60 M&C Nuclear Enriched U Magnesium explosion in Attleboro, MA no exposures. vacuum induction furnace.
9-20-63 Controls, Inc. None Fire in filter box i Attleboro, MA detected exhausting enriched ,
l uranium. No contamination '
on or offsite.
6-29-67 Kerr-McGee Minor Explosion in ion exchange Crescent, OK column.
9-2-72 United Nuclear Uranium at Flash fire caused by Fuel fabrication 15 times MPC organic contaminants in f acility ductworks. Considerable damage.
3-12-81 Nuclear Metals Minor inplant Fire in scrap packaging Concord, MA contamination building from spontaneous combustion of 10 lbs of uranium turnings. No overexposures.
42
E r Table 7. Other Accidental Releases from Uranium Fuel Fabrication Plants ;
- (UF releases, fires, and explosions excluded)
~k Date Facility Release Accident description l 4-2-71 Sabcock and Wilecx 10 Microcurie in Contamination outside a Research Facility plant hot cell due to a plug Lynchburg, VA being installed without a sealing bellows.
i 2-28-73 General Electric, Below MPC HEPA filter failed.
Wilmington, NC 8-24-73 8abcock and Wilcox Decontamination Enriched uranium released
- Apollo, PA required on and when corroded scrubber offsite. Release spray nozzle did not was 6.3 microcuries. provide enough scrubbing.
12-8-73 Babcock and Wilcox Offsite release of Inadequate ventilation Apollo, PA natural uranium of calciner allowed 4 times MPC. Offsite uranium to escape decontamination through canopy exhaust.
required.
9-6-74 Westinghouse UO 2 Leak in a roughing filter Columbia, SC allowed 002 power to be discharged directly to
, the Lir.
1-24-75 Babcock and Wilcox Enriched uranium Malfunction of scrubber /
Apollo, PA ventilation system.
1-79 General Electric, 62 Kg of low Two cans of powder stolen Wilmington, NC enriched U02 Powder and used in extortion stolen, attempt. Thief arrested, convicted and imprisoned.
l Powder recovered. -
l l
\
l 43 r
y .
R' '
7r 1
y e 2.2.5.2 Theoretical Calculations of Releases Criticality accidents, UF releases, fires, explosions, and tornadoes have been considered in various analyses of accidents in a fuel fabrication plant. The most serious accidents appear to be criticalities and UF. releases.
Thus, we consider those accidents here.
Criticality Accident: the NRC staff has developed a set of assumptions on the release of radioactive fission products from a criticality accident occurring in a solution. The assumptions are published in Regulatory Guide 3.34, " Assumptions Used for Evaluating the Potential Radiological Consequences of Accidental Nuclear Criticality in a Uranium Fuel Fabrication Plant," July 1979.
lb Regulatory Guide 3.34 assumes a criticality excursion occurs in a vented vessel of unfavorable geometry containing a solution of 400 g/l of uranium
~
enriched in U-235. The excursion produces an initial burst of 101s fissions in 0.5 second followed successively at 10 minute intervals by 47 bursts of
?t' 1.9 x 1017 fissions each for a total of 101e fissions in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The excursion is assumed to be terminated by evaporation of 100 liters of the solution. The amounts of radioactive materials assumed to be released from the solution
~
vessel to the room air are given in Table 8.
Regulatory Guide 3.34 allows credit for removal of fission products by filters in the ventilation system. In order to escape to the environment the room air must pass through a filter system by means of the building ventilation system. Even if doors are opened the ventilation system should exhaust the fission products through the filters. In this analysis the filters are assumed to remove 75% of the iodine but none of the inert gases. This analysis assumed the ventilation system operates at 5 air changes per hour.
The NRC staff has recently analyzed the potential consequences assuming a criticality accident for Exxon Nuclear in Richland, Washington," Combustion Engineering in Hematite, Missouri,** and Nuclear Fuel Services in Erwin,
- " Environmental Impact Appraisal, Exxon Nuclear Company, Nuclear Fuel Fabrication Plant, Richland, Washington," Docket 70-1257, NRC Office of Nuclear Material Safety and Safeguards, August, 1981.
'**" Environmental Assessment, Combustion Engineering, Inc., Nuclear Fuel Fabrication Plant, Hematite, Missouri," Docket 70-36, NRC Office of Nuclear Material Safety and Safeguards, November, 1982.
44 i
uw -
--,n-
~
Table 8. Amounts of Radioactive Materials Released or to Room Air Due to a Criticality Accident n (loss fi'ssions initially and 1.9 x 1017
.. fissions every 10 minutes for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />)
Radioactivity in Curies Half-life Radionuclide in hours 0-0.5 hr 0.5-8 hr Kr-83m 1.8 22 140 Kr-85m 4.5 21 130 Kr-87 1.27 140 850
Kr-88 2.8 91 560 Kr-89 0.05 5900 36,000 Xe-133 125. 4 23 Xe-135m 0.26 310 1900 Xe-135. 9.1 50 310 Xe-137 0.06 6900 42,000
. Xe-138 0.24 1800 11,000 i -
I-131 192. 0.3 1.9 2.3 I-132 38 240 I-133 21. 5.5 35 I-134 0.88 160 980 I-135 6.6 17 100 Source: Regulatory Guide 3.34, Table 1, July, 1979.
l The values for radioicdines in Table 1 of
! the guide were reduced by a factor of 4 to account for retention in the solution water.
Tennessee.* In each case the radionuclide releases from Regulatory Guide 3.34 were used.
~
Low-enriched UF.: The Exxon and Combustion Engineering analyses ** also considered releases of UFs, as did a recent analysis for the General Electric fuel fabrication plant in Wilmington, North Carolina.t The worst-case accident in the Exxon and Combustion Engineering analyses was assumed to involve the release of UF as might occur from valve or line failure of a heated cylinder l
being unloaded. Assuming that a full cylinder of UF. (2500 kg) at elevated
- " Proposed New Emergency Preparedness License Conditions at NFS-Erwin," NRC Commission Paper SECY-82-311, July 23,1982.
- 0p. cit.
t" Environmental Impact Appraisal, General Electric Company, Wilmington Manufacturing Department," Office of Nuclear Material Safety and Safeguards,"
NUREG-1078, June, 1984, page 69.
l i
l 45 l
l
-... ..., - -. - .,. , _ . - = . -, - - - - - - , - - - . . . :- --- -__ _. . _ _ _ _ _ - . - - - - - _ - - - - -
w
~* .
.E t
temperature started to leak and,tt.at no additional heat was supplied after cylinder failure, the No.C staff' estimated that about 22 percent of the material would be released before the UF, would be cool enough to solidify and have a vapor pressure low enough so that the release would stop. The NRC staff esti-mated that such a release would last for 15 minutes, and 540 kg of UF, would be released. This has a uranium content of 360 kg. The staff assumed the uranium released would react with water in the air and form highly soluble UO2 F2 of a respirable particle size.
High-enriched UF : In evaluating the need for offsite emergency prepared-ness at Nuclear Fuel Services, Erwin, Tennessee, the NRC staff concluded that the UFs accident to be considered was release from a 15-kg cylinder containing high enriched uranium.* This is largest cylinder used at the site for highly enriched UFs. An accident in 1962 breached one cylinder. Of the 15-kg contents, 6 kg was recovered but 9 kg was not recovered and presumably much of the
' ~~
material escaped from the plant.
t 2.2.5.3 Calculations of Doses Potential radiation doses due to criticality accidents and UFs releases previously calculated by the NRC staff for Combustion Engineering, Exxon, and Nuclear Fuel Services are summarized in Table 9.
t Criticality accident: To calculate the dose due to a criticality accident, I
the Exxon analysis assumed a wind speed of 1 m/sec, atmospheric stability class F, and a building wake factor of 1.0 beyond 500 meters (i.e. no building wake assumed). The building ventilation rate is assumed to be 30 air changes /hr.
The whole body doses were calculated to be 0.004 rem at 3600 m (the nearest residence) and 0.009 rem at 2000 m (the nearest industrial site). The doses to the thyroid were calculated to be 1.7 rem at 3600 m and 4.5 rem at 2000 m.
If one assumed only 25% of the iodines would pass through the filter system, the thyroid doses would be 0.4 rem at 3600 m and 1.1 rem at 2000 m.
The NRC analysis for the Combustion Engineering plant made similar assump-tions. The whole body dose at the nearest residence (800 m) would be 0.27 rem.
The thyroid dose at 800 m would be 1.7 rem. If the filters reduced the iodine concentrations by 75%, the thyroid dose would be 0.4 rem.
- " Proposed New Emergency Preparedness License Conditions at NFS-Erwin," NRC Commission Paper SECY-82-311, July 23, 1982.
46
i 4 y
-ano,miikf l
l Table 9. Offsite Doses Calculated for Fuel Fabrication Plants i
j Criticality UF.-low enrich. UF.-high enrich.
i Key Analysis Assumptions Effective DE Thyroid DE Effective DE Bone DE Effective DE NUREG-1140 Building size: 250 m2 0.5 to 1.1 to -
0.2 to ,
Wind: F, 1 m/sec 2.6 rems at 8.2 rems 1.5 rem Release height: ground 100 m at 100 m at 100 m (child's thyroid)
Combustion Building size: 0 0.27 rem 1.7 rems 0.05 rem 0.82 rem -
i Engineering Wind: F, 1 m/sec at 800 m at 800 m at 800 m at 800 m
- Release height
- stack 1
I Exxon Building size: 0 0.009 rem 4.5 rems 0.11 res 1.7 rems -
Wind: F, im/sec at 2000 m at 2000 m at 2000 m at 2000 m ,
Release height: ground NFS, Erwin Building size: 0 -
5 rems - -
1 rem t at 1000 m Wind: G, 0.5 m/sec at 1000 m Release height: same level as residence 9
_ _ _ _ _ _ _ _ _ _ _ _ _______J
M
^
, _ . T:T
[
g.
~
E 2 This analysis calculated an effective dose equivalent due to the airborne release from a criticality as 0.5 to 2.6 rem at 100 m. The dose from prompt
{ gammas and neutrons from excursions after the first one should be added to that dose, but those doses have not yet been calculated.
e We calculated the thyroid dose to a child due to the radiciodine release from a criticality accident to be 1.1 to 8.2 rems at 100 m.
Low-enriched UFa: For the UF. release, the Exxon plant analysis assumed a ground level release and calculated a dose to the bone of 1.7 rem al 2000 m.
The whole body dose was calculated to be 0.11 rem. In the analysis the NRC staff published for the Combustion Engineering plant, the release was assumed to be through a stack. The bone dose was calculated to be 0.82 rem at 800 m.
The whole body dose was calculated to be 0.05 rem.
s For purposes of this Regulatory Analysis uranium intakes and HF concentra-tions have been calculated. Radiation doses were not calculated since they are
~'
of lesser concern.
The release was assumed to be 540 kg of UFs at ground level. The uranium content is 364 kg. Atmospheric dispersion values from Figure 1 were used.
Uranium intakes are shown below for ground level releases. Buoyant releases are not calculated because there may not be enough material to create buoyancy.
Uranium intakes due to a ground level release of 540 kg of UFs Uranium intake (mg)
Distance I
, (meters) F, 1 m/s D, 4.5 m/s .
100 320 43 200 150 16 300 90 9 400 42 3 ,
500 24 2.2 1000 14 1.4 '
1500 6 0.8 2000 4 0.5
( 0.1 5000 0.5 i
High-enriched UFa: For the Nuclear Fuel Services Plant, the NRC staff previously calculated the effective dose equivalent at 1000 m due to the release of 15 kg of UF., high-enriched, to be 1 rem. For a 9 kg release of high enriched uranium, we calculated an effective dose equivalent of 0.2 to 48
-. - - - . _ _ _ ~ .
a t
1.5 rems at 100 m, a uranium intake of 0.3 to 2.6 mg, and exposure to HF at a c
concentration of 1.0 to 7.8 mg/m 8 . A building size of 10 m x 25 m, neutral buoyancy for the plume, ground level release, 5-minute release duration, 1.5%
U-234 with solubility Class D for uranium and F, 1 m/s and D, 4.5 m/s meteorology were the assumptions.
2.2.5.4 Implications for Emergency Preparedness The implications of criticality accidents and UFe releases are discussed separagelybelow.
Criticality accident: Using what are believed to be reasonable assump-tions, at 100 m effective dose equivalents of 0.5 to 2.6 rems for F, 1 m/s and D, 4.5 m/s meteorol'ogies were calculated compared to a 1 to 5 rem protective action guide. A child's thyroid dose of 1.1 to 8.2 rems was calculated compared to a 5 to 25 rem protective action guide. The calculated doses exceed the lower end of the range where protective actions should be considered out to about 200 to 250 m.
Low-enriched UF, release: For the release of 540 kg of low-enriched UFe, lethal intakes (242 mg) offsite do not seem plausible. Intakes sufficient to cause permanent kidney injury (45 mg) are calculated for adverse meteorology with not buoyancy to about 500 meters, although consideration of buoyancy might easily eliminate calculated permanent injury under any conditions. Transient kidney injury might occur to 100 meters under worse case meteorology and to perhaps about 300 meters under more typical meteorology. There would be no observable effects at 400 meters for typical meteorology. Therefore, in keep- -
ing with the Commission's policy on nuclear power plant emergency preparedness, l avoiding fatalities and serious health effects for worst case and protective action guide doses for more probable events, a response distance of roughly 400 meters is recommended.
High-enriched UFs: For the release of 9 kg of high-enriched UFs during F, 1 m/s meteorology, the dose at 100 m is 1.5 rems effective dose equivalent
! and the uranium intake is 5 mg. For D, 4.5 m/s meteorology the dose at 100 m i is 0.2 rem and the uranium intake is 0.7 mg. Buoyancy is not considered in either case since the quantity of material is so small. Protection actions to reduce dose may be appropriate during F, 1 m/s meteorology to a distance I
of 150 m.
49 i
/
s
?
t 2.2.6 Fuel Fabrication - Plutonium
/
There is currently no plutonium fuel fabrication being done in the U.S. ,
but accidents for facilities fabricating plutonium fuel have been analyzed in NUREG-0002, " Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light Water Cooled Reactors," 1976, usually called "GESMO." Because of the quality and thoroughness of that report, we will directly quote relevant sections for this analysis.
2.2.6.1 AccidentHistorE" "A summary of operational accidents in U.S. Government facilities, from
- 1943 to 1970, is given in WASH-1192. For some facilities and operations having a general resemblance to the various mixed oxide fuel cycle steps (in the areas of fuel reprocessing, fuel fabrication, and scrap recovery) there have been a number of accidents. Those which involved the possibility of environmental release include the following:
- Five solution criticality events (1958--2 events; one each in 1959, 1961, and 1962) in reprocessing or recovery operations involving highly enriched uranium or plutonium. All were of small consequence in terms of property' damage or releases of radioactivity to the environment, but one fatality and several high radiation exposures occurred among operating personnel.
~
Chemical explosion in evaporator (1953), related to fuel reprocessing.
Explosion and fire in plutonium purification facility (1963).
i l
' - Metallic fuel fire (reactive metal) in process dissolver (1960), related to fuel reprocessing.
Spontaneous fire in radioactively contaminated, combustible waste (1951).
- From GESMO, pages 11-45 to 11-48. The references given in GESMO are not included here to save space. The reader wanting the references should refer to the original GESMO.
50
v ..- . - . . - . . - _-. ~_
m
.y y
t Two fires at the Rocky Flats plutonium fabrication and recovery facility, A
[ (1957) and (1969). The 1969 fire caused $45 million in property damage.
Both fires are attributable to spontaneous ignition of plutonium metal which is not involved in the mixed oxide fuel cycle.
Fire around an anion exchange column, fuel reprocessing plant (1964).
"Some of these accidents occurred during the early years of operations with new facilities and newly developed technologies. All were investigated and corrective actions were taken (e.g., design changes) to make the events unlikely of recurrence. Such corrective actions have been carried forward,
[ where applicable, into design practices for new facilities, both government k and commercial. During'the past decade, criticality accidents have disappeared from the accident scene, and fire or explosion involving reactive metals has
~
become the predominant major accident in government facilities.
II
~
l "On a comparable basis, accident experience in commercial facilities to date include:
l- -
A solution criticality accident in recovery operations involving highly enriched uranium, fatal to operator (1964).
- A series of dissolver " fires" (reactive metal), fuel reprocessing plant l
(1967-1968).
- Final HEPA filter bank failure (inadequate mechanical support), fuel reprocessing plant (1968).
Fire in plutonium contaminated wastes, fuel fabrication facility (1973).
There was no detectable release of plutonium to the environment.
Explosion in plutonium glovebox, fuel fabrication facility (1972). About 5.6 pCi of alpha activity was released via the stack.
1 51
W~ *
~ ~
- 1. l
- g l
$L-
?
"The measured and estimated quantities of long-lived alpha activity
[ l
- released from the Rocky Flats plant during its first 20 years of operation are summarized in $nble 11-12....
"The specific and extensive modifications made to all plutonium handling facilities at Rocky Flats subsequent to the 1957 fire (especially the substitu-l tion of flame resistant filters for those formerly used, and the addition of fire protection in the filter banks and plenues) were clearly responsible for the vastly improved containment of alpha activity during the 1969 fire. The l
new plutonium recovery facility now under construction at Rocky Flats (as a replacement for older facilities) is being built under criteria that should u provide even greater assurance that the facility will be able to confine plu-
,4 tonium releases to exceedingly small values, even under severe abnormal circum-stances--including natural events, such as tornados."
" Table II-12 LONG-LIVED ALPHA ACTIVITY RELEASED FROM ROCKY FLATS Date Circumstances Quantity l 1958-1968 Leakage of Pu contaminated machine oil 5.3 Ci to soil at stored at the Rocky Flats site drum storage area i
1957 Fire in Bldg. 771 resulting in major 60 pCi, airborne, l mostly during fire t damage to filter system 1969 Fire in Bldg. 776 0.2 pC1, airborne, over 6-day period during and after -
fire 1953-1970 Normal effluent releases (cumulative) < 41 pCi, airborne 91 pCi, liquid effluents 52 n - - _ _ . __ - - - .
.. - ~ _ . - - - . -
1P
=
i r.
2.2.6.2 Accident Source Term
- e-
"A wide spectrum of credible accidents for these plants has been analyzed and their potential consequences estimated.
'Some incidents, such as punctures or tears of gloves or other glovebox malfunctions, are expected to occur as part of the normal operation. Other more serious accidents--such as glovebox window breakage--will occur kar less l often, although the offsite consequences from such accidents are judged to be insignificant, they are included in the estimate of airborne effluents result-ing from normal operations. Upper limit accidents that may occur include a criticality incident, an explosion, or a fire.... 1 Criticality "There have been no criticality accidents to date in process operations where undermoderation is a primary method of control, and few in aqueous or moderated systems. The number.of fissions has been estimated to be 101s in an accidental criticality. In calculating the effects, it is assumed that all of the noble gases krypton and xenon ard 25% of the iodine formed by the fissions would escape. In addition, it is assumed that 500 grams of Pu would become air-borne in a glovebox by the accidental criticality excursion. The ventilation filters are assumed to remain intact because a criticality is not an explosive process. The decontamination factor of three HEPA filters in series has been assumed to be 2 x 107, lower by a factor of 50 than the decontamination factor -
assumed for normal operating conditions. [Pu release = 0.29 pCi alpha] Calcu-lations show that the maximum offsite individual dose commitment results from absorption of fission product iodine in the thyroid and amounts to 360 mrem.
J This is comparable to the dose to the closest theoretical resident from a cri-ticality accident at a 002 fabrication plant. The slightly different fission product yield and the presence of small amounts of plutonium particulate do not significantly alter the effects of a Pu02 criticality accident relative to those of a 002 criticality accident.
"From GESMO, pages IV D-37 to IV D-39.
53
X .= :
~~ ~
I;t - _-
I' 5
l- Fire n
b "Unlike a criticality excursion or an explosion, a fire usually is not an instantaneous event and very often starts from a small flame source. The design, construction, and operation of fuel fabrication plants considers in detail the possibility of a fire and equipment and procedures for fire preven-tion. Regulatory Guide 3.16 presents methods Ecceptable to the NRC for a fire 6
protection program that should prevent, detect, extinguish, limit, or control fires and explosions and their hazards and damaging effects. Licensees must operate within these or acceptable equivalent constraints. Under these condi-tions, the probability of a fire of the magnitude considered in this statement is considered highly unlikely. In general, operators have time to react to and
, extinguish small fires. The process materials, oxides of uranium and plutonium, are not themselves flammable. The final filters are protected against fire by water spray systems installed in the duct some distance upstream of the final filters. Mist deflectors or collectors are installed between the water spray system and the filters to remove large drops of water. The water from the sprays collects in the bottom of the ducts and flows to a fire-water collection tank.
This tank is either a safe geometry tank or a fixed poison-controlled tank to preclude the possibility of a criticality accident as a result of a fire.
"The final HEPA filters are located some distance from the gloveboxes.
j This separation distance and the water spray system should be sufficient to protect the filters against the effects of an explosion or fire, but the fire or explosion is assumed to destroy the local filters on the gloveboxes. -
Plutonium and uranium oxides reach the final filters. Based on an assumed room volume of 1,000 m 8 and an air loading of 100 mg/m 8 for plutonium oxide ,
particulate, 100 grams of plutonium would reach the filters. Each of the filters is expected to remove 99.9% of the particulate reaching it, so that a total of 0.1 mg of Pu passes through the filters. [53 pCi alpha]
i 54
Y y
Explosion "An explosion might occur in a mixed oxide fuel fabrication plant at loca-tions where an explosive mixture of vapors in air could be present. There is a potential for the existence of combustible gases at the sintering furnance and in the clean scrap reduction operation. In addition, flammable solvents are used in the dirty scrap recycle operation and may be used for cleaning fuel rods and during cleanup and maintenance operations. These operations are essentially the only ones that have a potential for supporting an explosion.....
,, "The consequences of an explosion are similar to those of a fire. The amount of plutonium reaching or passing through the filters is estimated to be
'; the same as that estimated for the fire [53 pCi alpha] and would have the same relatively minor offsite consequences." [End of quote]
2.2.6.3 Calculations of Doses For the accidental releases above, GESMO assumed the nearest resident was at 500 m. GESMO used a chi /Q of 1.3 x 10 4 for Pasquill Stability Category D, wind speed 3 m/s, and 10 meter release height. GESMO assumed the plutonium to be soluble.
The following dose commitments were calculated for GESMO:
Type of accident Dose commitment (rem)
Criticality 0.36 (thyroid)
Fire 0.02 (bone) -
Explosion 0.02 (bone)
Using the standard assumptions in this Regulatory Analysis, doses would be slightly higher than those in GESMO.
2.2.6.4 Implications for Emergency Preparedness The GESMO analysis concluded that the design of plutonium fuel fabrication plants is adequate to prevent releases that would cause doses exceeding protec-tive action guides. Tr.us special emergency preparedness would not be needed offaite.
55
p -
ft =
g T
$ In addition, GESMO (page II-10) concluded there was little threat from the ingestion pathway.
"A study of indigenous and experimental animals kept for long periods in areas heavily contaminated with plutonium indicates that direct uptake of plu-tonium was small. Plutonium uptake by plants from soil and growth media has been investigated in the field and in the laboratory under a variety of condi-tions. The concentration of plutonium in plants on a dry weight basis was never more than one thousandth of that in the growth medium, and only about one ten thousandth of that in the soil. The fraction of available plutonium absorbed from the gastrointestinal tract of animals grazing on contaminated vegetation is less than one ten thousandth the total intake of the element and measurements
- of plutonium transfer from the blood stream to milk suggest a further reduction in plutonium concentration by another factor of at least 10. Consumption of
~
animal products by man will introduce another reduction factor of at least 10 4 in the plutonium concentration entering the systemic circulation, except in the very young infant where the factor may approach 0.01. It appears, therefore, that the possibility of transfer of plutonium from soil to man by way of the food chain is negligible."
2.2.7 Spent Fuel Storage
- Spent nuclear power plant fuel may be stored in pools of water, in dry storage casks, in drywells, or dry vault storage. Each of these methods is discussed in this section. -
1
- Source terms in this section were developed with the assistance of Fritz Sturz, Advanced Fuel and Spent Fuel Licensing Branch, Office of Nuclear Materials Safety and Safeguards, NRC.
56
. ~ . _ _ _ _ . _ _ _ , _ . . _ _ _
w-r !
[ 2.2.7.1 Accident History F .' l f There have been no accidents associated with spent fuel storage that have had any significance for offsite radiation exposure. Radioactive material has escaped to storage pool water when casks containing damaged fuel elements were opened. However, these events have no significance for offsite emergency preparedness.
2.2.7.2 Accident Source Term Pool storage: Pool storage for spent fuel storage in pools, possible accidents and their effects are discussed in a generic environmental impact
{h statement, NUREG-0575.*-
4
~
The accidents considered are:
1
- 1. The rupturing of fuel pins due tc the drop of a fuel assembly l
l 2. A tornado driven utility pole strikes the pool at the worst possible angle and ruptures a 45 foot row of assemblies
- 3. Fires and explosions l 4. A criticality accident l 5. High radioactivity in the pool water
- 6. Rupture of a waste tank or piping
- 7. Lowering of the water level in the pool
- 8. Loss of the ability to cool the pool water -
Of these accidents, the generic environmental impact statement for pool storage estimated that the most serious of these accidents is the rupture of a large number of fuel assemblies by a tornado-driven missile. The statement calculated the release of radioactivity to be 19,000 curies of krypten-85 and 0.00006 curies of iodine-129. (Actually, I-129 is of only academic interest.
Due to saturation, the 5-rem thyroid dose used as the protective action guide cannot be reached.)
- NUREG-0575, Generic Environmental Impact Statement on Handling and Storaae of Spent Light Water Power Reactor Fuel, pp 4-17 to 4-22, Volume 1, August 1979.
57
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ow '
ar L
A more recent NRC report on pool storage evaluated accident consequences
+ for the General Electric fuel storage facility in Morris, Illinois!" 'The most serious accident was considered to be the drop of a fuel storage basket in the water of the storage pool. The maximum drop would be about 7 m. While experience with similar drops indicates that only minor damage to a fuel assembly would result, the calculations assumed that all the fuel rods in four PWR fuel bundles would rupture and that all the plenum gases would be released to the pool water. The release was calculated to be about 6000 Ci of Kr-85 and 0.00008 Ci of I-129.
Several other types of accidents were also analyzed for the GE-Morris facility. A loss of basin water was considered to be not credible, an earth-quake was estimated to cause minimal offsite radiological consequences, a
_ tornado-driven missile was estimated to cause the same release as the fuel-basket drop, and a critica'ity was estimated to cause minimal offsite doses.
a -.
Dry cask storage: The accident assumed for this analysis is the removal of the lid of a dry cask in which all the fuel rods have been damaged. The gaseous activity in the gap between the fuel and cladding is assumed to be released. From NUREG-0575** 10% of the krypton-85 and 1% of the iodine-129 activities are assumed to be in the gap. The cask is assumed to hold 24 PWR spent fuel assemblies. The fuel is assumed to be less than 5% by weight uranium-235.
The fuel burnup for this analysis is assumed to be 33,000 megawatt-days per metric ton of uranium. The fuel is assumed to have been removed from the reactor core 5 years earlier. Using these assumptions the activity released -
from a cask would be 8,000 curies of krypton-85 and 0.004 curies of iodine-129.
Drywell and dry vault storage: While the number of fuel rods may be larger than assumed for dry cask storage above, it is reasonable to assume that a single accident would not damage a larger number of fuel rods than assumed above for dry cask storage. Therefore, the dry cask storage source term is also appropriate for drywell and dry vault storage.
"NUREG-0709, " Safety Evaluation Report related to the Renewal of Materials License SNM-1265 for the Receipt, Storage, and Transfer of Spent Fuel Pursuant to 10 CFR Part 72 - Morris Operation - General Electric Company -
Docket Nos. 70-1308 and 72-1," July, 1981, Chapter 7.
- NUREG-0575, op. cit. , Volume I, p. 4-18.
l 58
,__ _ . = . __
w 3.-- ,
I h
A 2.2.7.3 Calculations of Doses Dose estimates previously published by the NRC staff for the pool releases described above are given in Table 10.
Doses for the dry cask storage accident described above calculated in this analysis are also shown in Table 10. The effective dose equivalent for F, 1 m/s meteorology would be 0.003 rem and the child's thyroid dose would be 0.04 rem.
For D, 4.5 m/s meteorology, the child's thyroid dose would be 0.005 rem.
J l
2.2.7.4 Implications for Emergency Preparedness l
The doses shown in Table 10 are below the EPA's protective action guides for taking protective action after an accident. Therefore offsite emergency preparedness is not necessary for spent fuel storage either in dry casks or in pools.
2.2.8 New Fuel Storage New fuel will at times be stored prior to being loaded into a nuclear power plant core. Stored new fuel does not require any offsite emergency preparedness because of its minimal hazard. By comparison with spent fuel storage just discussed, no fission products are present. Thus no volatile radioactive materials are present, and no driving force, such as decay heat, is present to cause the uranium fuel to escape its cladding and become airborne.
2.2.9 Reprocessina of Spent Fuel Spent fuel reprocessing is the mechanical and chemical processing of spent nuclear fuel to extract enriched uranium and plutonium from the fuel elements so they can be used in new fuel elements. Radioactive fission products are removed from the spent fuel and processed into high-level radioactive waste.
Currently, no reprocessing plants are licensed by NRC to operate in the U.S. , nor are there any near term prospects for licensing any reprocessing plants. However, the Nuclear Fuel Services reprocessing plant in West Valley, New York, operated as a commercial plant under NRC license for many years, and 59
_---.-- - _ _:-===....
i ,
n,sogn+l(
g "!
Table 10. Calculated Releases and Doses from Spent Fuel Storage Accidents Kr-85 Skin Effective Dose Thyroid i Accident Release Dose Equivalent 1-129 Release Dose !
Reference l
Storage in pools: Tornado driven 19,000 Ci 0.06 rem Not calculated 0.00006 Ci 0.03 rem Generic Environmental missile followed at 275 m at 275 m Impact Statement, by calm l l NUREG-0575 ,
i Storage in pools: Drop of a fuel 6,000 Ci Not 0.016 rem 0.00008 Ci 0.0004 res GE-Morris SER, storage basket calculated .at 150 m at 150 m :
Dry cask, drywell, Removal of cask 8,000 Ci Not 0.003 rem 0.004 Ci 0.005 to- !
or dry vault lid with all fuel calculated at 100 m 0.04 rest ;
storage: NUREG-1140 elements ruptured within 100 m (child) 8
__ __ _ _ _ . ~ ~ _ . . __ __ _ _ .
ji reprocessing plants have been operating in the U.S. weapons program for over i 40 years. In addition, reprocessing plants are operating in several foreign countries.
i 2.2.9.1 Accident History The Nuclear Fuel Services reprocessing plant was plagued by many small releases into ground water, surface water, and air as well as unusually high occupational radiation exposures. However, the plant never had an accident of significance for offsite emergency preparedness.
Several criticality accidents, as listed in Table 5, have occurred in
, spent fuel reprocessing or in processes similar to those that would be used in spent fuel reprocessing plants.
'4 No other accidents 1of significance offsite are known to have happened in spent fuel reprocessing.
G.-
2.2.9.2 Accident Source Terms
- Accident source terms for a reprocessing plant were analyzed in GESMO, and are quoted below.
i
" Upper level accidents that may occur at separations facilities or Pu02 conversion facilities include:
Criticality High level radioactive waste concentrator or calciner explosion -
Plutonium product concentrator explosions Criticality Accident "A criticality accident is unlikely in a separations facility or Pu02 conversion facility, because equipment and process limitations are designed to prevent such incidents. Safe spacing is assured in storage basins by physically spacing the fuel elements in storage racks in a safe array. Process systems and controls are designed to prevent an unsafe condition. Nevertheless, a
- From GESMO, pages IV E-39 to IV E-42.
61
--y, - -. - -
--...-.-.,. m. ~_ e -+ - -- -.y -.-----.__ ,- - - _ -
s.. -
, -w.
- criticality accident of 101' fissions is assumed. This yield is approximately
[. an order of magnitude greater than the yield that has been experienced for Pu 4 systems in past accidents. It is further assumed that all noble gases and 50%
of the halogens (or halides) are discharged from the plant stack. -The dose commitments would be essentially the same for 002 fuel or MOX fuel.
Waste Concentrator Explosion Accident "During operation of the separation facility solvent extraction process, solvent degradation products are generated and may be carried over into the waste streams. Under extreme conditions in early pilot plant operations, these nitrated degradation products (red oil) have caused concentrator explo-sions. However, red oil explosions can be prevented by installing equipment I to eliminate the accumulation of organic materials in the waste, and by con-trolling the process temperature in the concentrator.
" Concentrators are installed in highly shielded cells, having a volume of about 100,000 cu ft (3,000 m8 ). In the unlikely event of an accident, the explosion is estimated to disperse about 150 gallons (600 liters) of high level radioactive waste solution into the cell in the form of a finely divided mist. A substantial portion of the mist would rain out or plate out on the cell surfaces. Droplets remaining in the air (10 mg/m8) would be carried i through the ventilation ducts to the high efficiency filters. Moisture sepa-
! rators upstream of the filters would knock out most of the mist.
1 "The plant ventilation filters are located some distance from the separa- -
tion plant process cells. Most of the explosive energy would be expended in destruction of the concentrator. Pressures developed by the explosion would
{ be dampened by expansion into the cell and would be further attenuated in the ductwork. The final filters are not expected to be affected.
"It has been estimated that plateout of the droplets on the cell walls and floors and removal by the filtration system will result in a reduction in l
l the fraction of material released to 3.6 x 10 s. Material leaving the final filter has been estimated to be 30.5 mg of high level radioactive waste solution in the form of an aerosol.
62 L - -- - - .
.-._7 _
f:.
y Table IV E-16 identifies those nuclides that would contribute significantly to the offsite dose, and summarizes the offsite bone dose commitment that might result from this hypothetical acc'ident. The maximum offsite dose commitment to an individual is estimated to be about 2.6 arem (bone) for 00 fuel, and about 6.9 arem (bone) for MOX fuels.
" Table IV E-16 WASTE CONCENTRATION EXPLOSION EFFECTS Radioactivity Released Accident Bone in Accident Dose Contribution Nuclide Half Life mci arem UO2 Fuel M0X Fuel UO2 Fuel M0X Fuel
- Pu 0.02 0.15 0.01 0.06
[ 241Am 458y 0.007 0.05 0.02 0.17 242Cm 162d 0.76 12.3 0.04 0.60 i -
844Cm 18y 0.05 3.25 0.07 4.38 80Sr 29y 2.80 1.62 1.92 1.14 mosRu ly 2000. 3400. 0.02 0.04 144Ce 284d 27. 23. 0.04 0.03 Other F.P. 1.5 1.5 0.48 0.48 Total 2.6 6.9 "Jable IV E-17 shows the radionuclide releases and the bone dose commit-ment to the maximally exposed offsite individual....
Table IV E-17 ~
" PLUTONIUM PRODUCT EVAPORATOR EXPLOSION EFFECTS Radioactivity Released Accident Bone in Accident Dose Contribution Plutonium mci mrem l
l Isotope Half Life UO2 Fuel M0X Fuel U02 Fuel M0X Fuel 238 86y 1.02 2.11 5.94 12.27 239 2.4 x 104y 0.08 0.04 0.51 0.28
! 240 6,540y 0.11 0.13 0.76 0.88 241 13y 2.94 4.01 3.98 5.42 Total 11.2 18.9 End of Quote
(
63 t
i
?
3 t
- Plutonium Concentrator Explosion Accident \
~~
"The postulated explosion of a plutonium concentrator in the reprocessing plant is typical of upper level accidents by which plutonium could be released to a cell or glovebox area. Typically, the plutonium processin2 equipment tends to be smaller, and installed in smaller rooms (cells or gloveboxes) than the waste concentrator previously discussed. The release rate is derived by assuming that the room (cell or glovebox) atmosphere contains the same mass of aerosol (10 mg/m 3 ) as the atmosphere of the waste concentrator cell. For a 1,000 m 3 plutonium concentrator cell volume, the postulated accident would release about 2.2 mg of plutonium.
2.2.9.3 Calculations of Doses 4
The doses below for these accidents are taken directly from GESMO, page
~
l IV E-40.
" Maximum Offsite Individual Dose Commitment (rem)
Accident PWR MOX Fuel Criticality 0.056 (thyroid)
- Waste Concentrator Explosion 0.0069 (bone)
Pu Evaporator Explosion 0.019 (bone)
Fire 0.0135 (bone)
End of Quote j 2.2.9.4 Implications for Emergency Preparedness -
According to the GESMO analysis accidents at reprocessing plants would l
not cause doses in excess of protective action guides. This is primarily due to lack of strong driving forces and extensive containment systems. Thus special emergency preparedness is not needed offsite.
2.2.10 Research with Nuclear Fuels These facilities perform research and development related to nuclear l power plant fuel manufacturing and testing. They use special nuclear materials l
64 ww% -
-_.----,.,,.c... _.---. ,,-,.. ,..-.- , - - . , - - , . , - _ . .
[
'E
?
in forms ranging from powders to solutions, although larger quantities are usually in the form of fuel pellets. The work takes place in laboratories and glove box trains. Processes such as blending, crushing, milling, sintering, grinding, and solvent extraction may take place.
2.2.10.1 Accident History A number of the accidents previously discussed for other parts ofa the fuel cycle are relevant to research with nuclear fuels. For example, if the facility handles large quantities of enriched uranium, criticalities as listed in Table 5 could occur. In addition, fires and other types of accidents such as those listed in Tables 6 and 7 could occur. Since these types of accidents have been discussed previously, they will not be discussed further here.
2.2.10.2 Accident Source Terms Sutter* has analyzed nuclear fuel research facilities and concluded that the potential accidents are criticality accidents, spills and leaks, tornados, earthquakes, fires outside the facility, fires inside the facility, explosions, and fuel handling accidents.
If large quantities of material are handled a criticality accident may be a possibility. If this is the case, the releases and offsite doses would be the same as those discussed in Section 2.2.5.2 for criticalities at fuel fabrication plants.
The other possible accidents of significance would be a major fire in the facility such as a fire in a glove box train. If the fire does not break the -
glove box filters and the final HEPA filters, the release to the environment would be negligible. However, if both sets of filters are breached a consider-able release is plausible. Assuming 13 glove boxes are in the train, 2 kg of material is present in each, and 0.1% becomes airborne due to the fire, a release of 0.026 kg would be calculated. This would be uranium or plutonium, whichever was being processed, although at this time no licensees are handling such quantities of plutonium.
- Sutter, Op. cit.
65
3
- . . . = -
y g
2.2.10.3 Calculations of Doses Doses due to a criticality would be the same as discussed previously. A fire involving low enriched uranium (solubility class Y) would result in an effective dose equivalent within 100 m of 0.007 rem for F, 1 m/s meteorology I and 0.001 rem for more typical D, 4.5 m/s meteorology. Inhaled quantities are well below levels where chemical toxicity is observed. The dose calculations assumed that the building size was 25 m x 10 m, the release was at ground level, and the release duration was 30 minutes.
If plutonium-239 were the fuel rather than uranium, the effective dose equivalent from the fire would be about 67 rems for typical D, 4.5 m/s meteor-
- ology and 500 rems for conservative F, 1 m/s meteorology. The dose calculations
- r for uranium and plutonium consider an insoluble class Y compound. However, the S plutonium dose was calculated assuming that plutonium facility would have the same containment capability as uranium facilities would be expected to have.
~
Since superior containment is provided for plutonium, the offsite doses presented here are probably larger that could actually be by quite a large i
margin. For example, we assume 0.1% release for the involved plutonium. By comparison the actual release for the Rocky Flats fire discussed previously was 10 s, a hundred-thousand times lower.
i 2.2.10.4 Implications for Emergency Preparedness l
Criticality, as discussed previously, may require some emergency prepared-l l ness. Other accidents at facilities handling uranium would not seem to require
! emergency preparedness. Plutonium processing, on the other hand could cause -
large doses offsite if not contained. We therefore conclude that for plutonium research and development activities the need for offsite emergency preparedness l
should be evaluated on a case by case basis.
2.3 Byproduct Material Facilities There are six types of byproduct material licensees that handle large enough quantities of radioactive material not in sealed form so that need for offsite emergency preparedness should be considered. These are: radio-pharmaceutical manufacturing, radiopharmacies, sealed source manufacturing,
- 66 l
l
1[
LH-
- m.
W i~ university research laboratories, waste warehousing, and fabrication of depleted uranium products.
2
? 2.3.1 A Generic Overview We will consider each of these types of facilities separately rather than as a single group. The reason is that we wish to determine whether accident scenarios and release fractions developed for each type can be generalized into a single set of. accident scenarios and release fractions. But first, we
~
will consider certain common or generic characteristics of byproduct material licensees.
Y
[ 2.3.1.1 Accident History The accidents involving release of byproduct material from all types of
~
facilities handling byproduct material are listed below in. Tables 11 and 12.
The reason for combining all types of facilities in these tables is that the experience of one type of facility may be relevant to other types of facilities.
For example, a fire or explosion in a glovebox or hot cell is an accident that could happen at almost any type of major byproduct handling facility. The rele-vant accidents listed in Tables 11 and 12 will be discussed in later sections.
Overall, accidents involving byproduct material have led to small offsite doses. Releases have always been below the EPA's protective action guide lower limit of 1 rem. Thus, no emergency protective actions have ever been necessary to protect people offsite from airborne releases of radioactivity.
2.3.1.2 Release Fractions for Accident Source Terms
- l The release fractions selected are given below along with the reasons for selecting them.
Noble cases (1.0): Kr and Xe were assigned a release fraction of 1 because they are always gases at room temperature, they do not plate out, they are not retained by filters, and they do not react chemically to form less volatile compounds.
"This section prepared with the assistance of Mark Halverson, Pacific North-west Laboratory, who compiled the references upon which the release fractions are based.
67
! ~ ___ _ _ _ _ _ _ _ L _T _ _ f ~~ X:_ -~ X _ _ . __ ___ -__.. . - _ - _ _-___ _
y lC 7
Table 11. Fires and Explosions Involving Release of Byproduct Materials Date Facility Release Description 4-23-50 Lawrence Radiation Minor Multistory research build-Lab, S.F., CA ing destroyed by fire.
2-21-55 AEC Contractor Minor Spontaneous ignition fire broke out in nitric acid saturated rags and paper in a contaminated waste storage area of a chemical process laboratory.
10-8-59 Mound Laboratory, Po-210 Explosion in drybox Miamisburg, OH contamination disperses Po-210. Lab tech (Fuel R&D) in laboratory, combined acetone wash with 39 Ci released nitric acid solution.
onsite 11-10-60 Laboratory at None An overheated oil both
-~
Univ. of Calif., started a fire in a process-Berkeley, CA ing cave handling curium.
No exposures and no contami-nation outside cave.
12-29-60 University of Some Fire caused loss of some Alabama radioactive materials.
(Laboratory) 4-5-61 U.S. (location 1 mC1. Minor Radiochemistry building unspecified) contamination fire.
i 9-25-64 AEC 2.5 g of Shipping container contractor americium explosion.
4-20-69 Babcock and Co-60 A bag of Co-60 contaminated .
Wilcox contamination paper was put in nonradio-of incinerator active trash and burned in of 10 mR/hr incinerator.
8-30-76 Hanford Site - 300 Ci Am-241 Explosion of an ion Plutonium Worker seriously exchange column containing Plant contaminated. 100 g (300 Ci) of Am-241.
Negligible 1 to 5 Ci deposited on a release to worker's skin and clothing.
environment. 5 mci remained on body after initial washing.
Inhalation uptake by lung estimated at 0.05 mci.
68
E.
Table 12. Accidental Releases of Byproduct Material Except Fires and Explosions
(
Date Facility )elease Description 7-25-58 Los Alamos H-3, minor H-3 gas escaped.
Scientific Lab.,
- Los Alamos, NM 8-24-62 Phillips Petroleum I-131 leaked Leaky shipping cask contaminated Co., Idaho Reactor from cask. truck and cask.
Test Site, Idaho Dose of 5 R/hr Falls, ID on surface 1-23-64 Hanford Laboratory, Sr-90 While workers were replacing
- an agitator on a waste storage Richland, WA i
tank, convection currents carried contaminated vapor from
'2 - the open top of the tank to the environment.
~
1-15-67 Babcock and Wilcox, Ir-192 onsite Technicians cut into an Ir-192 Apollo, PA pellet in hot cell. Ventilation tion imbalance allowed Ir-192 to escape to working area.
L 4-4-67 Savannah River H-3 released An electric welder malfunctioned Laboratory, through stack. causirg the failure of a seal Aiken, SC Minor tube which released H-3 tostack.
9-27-68 U.S. (location Low level A cask of canned waste was not reported) waste dumped into an underground contamination caisson. Radioactive dust escaped contaminating the cask, its truck, and workers.
i 5-5-69 U.S. Naval Ammuni- Minor quantity Released to atmosphere tion Facility of Kr-85 -
8-6-70 Lawrence Radiation H-3 acci- Automatic safety devices Laboratory, dentally failed.
Berkeley, CA discharged through 100-ft stack I
9-17-73 Rocky Flats, H-3 released Water not known to be contam-Golden, CO to water inated with H-3 released to plant waste stream.
Savannah River H-3, 50 g Failure of a pipe fitting 5-2-74 allowed H-3 to be discharged i Laboratory, Ailen, SC through stack.
l i
! 69
y t tr I
Table 12. (continued)
, Date Facility Release Description 1978 American Atemics 287,000 Ci " Normal operating losses," Some calendar Corp, Phoenix, AZ of H-3 food prepared nearby contained year H-3 in concentrations above EPA drinking water standard of 0.02 uCi/1 (4 mrem /yr for 2 liter / day consumption). (This was not an accidental release,
- but is included because of the large quantity of material released.)
9-1-80 New England Nuclear, Am-241 inside Airborne Am-241 while renovating N. Billerica, MA plant contaminated gloveboxes.
i- 7-24-81 New England Nuclear, 3.2 Ci of S-35 Released during opening of N. Billerica, MA 2 capsules containing 30 Ci of S-35.
11-19-81 Tech / Ops, Ir-192 Ir-192 surface contamination 12-12-81 Burlington, MA surface found in lab. Escape path from hot cells not discovered.
8-27-82 Consolidation Coal Up to 0.5 Ci A stuck well logging source Company, Library, of Am-241 in was cut by a drill bit during PA drilling mud recovery operations. Because the leak went unrecognized, some Am-241 activity was tracked into homes and businesses.
2-8-83 Gulf Nuclear, Inc. Am-241 inside A 20 Ci Am-241 sealed source was Webster, TX plant accidentally cut open on a cut open on a lathe during machining, i
Six employees were exposed.
9-13-83 Shelwell Services, Cs-137 on 2 Ci Cs-137 sealed source cut Inc., Hebron, OH workers shoes open on lathe. Some CsC1 powder and clothing spilled out. Shop contaminated.
15 homes contaminated by Cs-137 from workers shoes and clothing.
70
E Y.'
t Volatile and combustible compounds (0.5): A release fraction of 0.5 was
_ assigned to compounds of hydrogen, carbon, phosphorous, sulfur, and iodine.
Compounds of these elements would be expected to be less than 100% due to these factors: (1) some of the compounds of the elements may form some novolatile compounds (ash) in a fire, (2) some of the compounds of the elements vill plate out and deposit on internal surfaces, (3) some of compounds of the elements will be subject to retention by filters, (4) not all containers possessed by a licensee would be likely to be breached in an accident,6,(5) at any particular time the actual inventory may be below the licensed possession limit, and (6) some particles formed may not be respirable. Consideration of site specific factors could cause considerable reductions in the release fractions for specific facilities.
With respect to I-131, experimental releases from a fire with the I-131 in a flammable solvent were 65%. If the container was subsequently heated afterwords with a propane torch the release reached 83%.* Other factors as i
mentioned above would reduce the quantity that would actually escape the building.
Semi-volatile compounds (0.01): These include compounds of the elements ielenium, mercury, cesium, polonium, bromine, tellurium, and ruthenium.
Releases of Cs-137 at 1000*C have been measured at 1%/hr,* 1.5%/hr,** and 4.2%/hr.f Additional removal by filter retention and condensation was i
measured at 35 tc, 93% removal, and an additional 30% removal by deposition
! was measured.tt Based on the assumption of a 30-minute fire, an assumed release fraction of 0.01 is believed to be reasonable for cesium and selenium compounds.
~
Unknown form (but not generally volatile or combustible) (0.01): For use in screening analyses in which the chemical form of a radioactive material is not known, a release fraction of 0.01 is assumed. This value does not apply
- A. E. Albrethsen and L. C. Schendiman, " Volatilization of Fission Products from High-Level Wastes," BNWL338, Pacific Northwest Laboratory,1967.
- W. J. Gray, " Volatility of a Zinc Borosilicate Glass Containing Simulated High-Level Radioactive Waste," BNWL-2111, Pacific Northwest Laboratory,1969.
- 10. Walmsley et al, " Volatility Studies of Glasses for the Fingal Process, AERE-R-5779, England,1969.
ttR. K. Hilliard, " Fission Product Release from Uranium Heated in Air," HW-60689, Hanford Atomic Products Operation, 1959.
i 71
y Y
~
to Kr, Xe, H, C, P, or S, which were assigned different values above. It does not apply to U, Pu, Am, or Ca, which are assigned a release fraction of 0.001 on the basis of their general form as nonvolatile powders as explained below.
It also does not apply to Co, Ta, and Ir, which are assigned a release fraction
, of 0.001, as explained below.
The 0.01 release factor for unknown form should be used only for screening.
For specific facilities, the actual chemical form of the radioactive material could be used to determine an appropriate (generally lower) release fraction.
Nonvolatile powders (0.001): Release fractions for nonvolatile compounds are given as the fraction of material released which is of respirable size.
Most experiments report total release fraction. To convert these to respirable release fraction, the release of particles larger than 10 microns was excluded from the respirable release fraction. Most reported experiments provide enough information to allow this determination, but some do not. For experi-ments providing no information on particle size, it is necessary to estimate respirable release fractions from total release fractions by assuming that the respirable proportion will be similar to that reported in similar experiments.
A release fraction of 0.001 was assigned to nonvolatile compounds in powder form. The mechanism is not volatilization. Rather it is entrainment of the particles in an airstream. Even finely ground powders will generally contain less than a few percent of the powder in respirable size. The frac-tion of particles of respirable size is kept small by the difficulty in pro-ducing all small particles and subsequently by agglomeration and weathering, l processes which cause micron-sized particles to stick to surfaces, to larger particles, and to themselves. Particles larger than respirable size (>10
~
microns aerodynamic median diameter) quickly settle out of the air, and if inhaled seldom are deposited in the lungs.
The release fraction of 0.001 is suggested by a number of experiments generally designed to maximize the release.* The experiments usually found
- J. Mishima, L. Schwendiman, and Radasch, " Plutonium Release Studies III.
Release from Heated Plutonium Bearing Powers," BNWL-786, Pacific Northwest Laboratory, Richland, WA, 1968.
J. Mishima and L. Schwendiman, " Fractional Airborne Release of Uranium (Representing Plutonium) During the Burning of Contaminated Wastes," BNWL-1730, Pacific Northwest Laboratory, Richland, WA, 1973.
S. Sutter, Johnson, and J. Mishima, " Aerosols Generated by Free Fall Spills of Powders and Solutions in Static Air," NUREG/CR-3093, 1981.
72
p, f
a releases of respirable size particles of about 0.001 or less. In a few special
, cases designed to produce maximum releases, values above 0.001 were found.
) These conditions were for highly ground powders on certain flammable surfaces such as rubber or plexiglass, for high velocity air flow, or for highly pres-surized releases in which all the material is violently thrown into the air, which is then sampled before significant settling can occur. Such conditions
~
are not considered representative of realistic accident conditions.
Uranium metal and plutonium metal (0.001): These materials are pyrophoric.
The release fraction of 0.001 is representative of experimental measurements described in Section 2.3.7.2.
Nonvolatile solids (0.0001): For nonvolatile compounds in solid form
, rather than powder form, a release fraction of 0.0001 was assumed to reflect the lower amount of. material that would be of respirable size. This value i could be applied to cobalt, iridium, and tanalum in solid form on a case by
., case basis.
Nonvolatile elements in flammable liquids (0.005). A release fraction of 0.005 was assigned to nonvolatile compounds in flammable liquids.
Experiments with strontium in a flammable solvent yielded a release fraction of 0.002 from a fire.*
Releases of uranium in flammable solvent averaged 0.00025, releases of
- cesium averaged 0.0024, releases of cerium averaged 0.0065, and releases of zirconium also averaged 0.0065.** When the container in those experiments were subsequently heated with a propane torch uranium releases were 0.003, cesium releases averaged 0.006, cerium releases averaged 0.0074, and zirconium averaged 0.004.** ,
For UO2 powder in gasoline, release fractions were 0.0012 when airflow was 1.8 m/s.t Of this, 66% was less than 10 micron AEDtt for a respirable release fraction of 0.0008. When airflow increased to 8.9 m/s, the release fraction increased to 0.013,t but only 7%tt was smaller than 10 microns, thus
- S. L. Sutter et al, " Fractional Airborne Release of Strontium During the Combustion of 30% Normal Tributyl Phosphage in a Kerosine Type Diluent,"
BNWL-B-358, Pacific Northwest Laboratory,1974.
- J. Mishima and L. C. Schwendiman, BNWL-B-274,1973, op. cit.
tJ. Mishima and L. C. Schwendiman, BNWL-1730.
l ftJ. Mishima and L. C. Schwendiman, BNWL-1732.
73 l
'_~._ _ .__ _ ___
- - - - ~ -
v_ _ _ _ _ _.
9-p..
k
$ the respirable release fraction was 0.0009, about the same as with the lower
. . . airflow. 8 In other experiments on burning of kerosene-based solvent releases of Ru-106 were below 0.1% and releases of uranium and plutonium were much l ower.*
Nonvolatile compounds in nonflammable liquids (0.001): Nonvolatile compounds in nonflammable liquids are assigned a release fraction of 0.001.
In general, Several studies have measured releases in these circumstances.
' release of these compounds can be expectea to be small until the liquid is dried. After drying release fractions generally remain small because the material normally cakes on the substrate or binds into particles too large to be respirable.
3 2.3.1.3 Quantities Requiring Consideration of Emergency Preparedness
~
Table 13 lists the quantities requiring consideration of emergency preparedness based on the quantities needed to deliver a 1-rem effective dose equivalent offsite. The quantities Q9 in Table 13 were calculated using the following equation:
Oi " RF j(Hyg + Ci + HCSi) where Qg = the quantity of material 1, curies
~
RF 9
= release fraction of material 1. (Release fractions are for a severe facility fire, which has been identified as the accident with the largest plausible release fractions.)
H yg = the effective dose equivalent from material i for the inhalation pathway, rems / curie released.
- D. Whitney 'Tharin, Jr. , " Burning of Radioactive Process Solvent, Savannah River Laboratory Report DP-942, Aiken, South Carolina, 1965.
74 1
l I -- - _- . - . _ _ _ _ _ . _
1
$b
\]
r Y Table 13. Quantities of Radioactive Materials Requiring Evaluation of the Need for Offsite Emergency Preparedness. (Based y
on 1 rem effective'hbse equivalent outside the building.)
s Dose conver-sion factor Solubility Release Quantity Quantity Radioactive (rems /uCi (weight) (curie) material inhaled)* class ** fraction 0.5 20,000 H-3 .00012 -
1,000 C-14 .0021 -
0.5 0.01 9,000 '
Na-22 .0076 D 0 0.01 10,000 Na-24 .0012 W 0.5 100 P-32 .015 1,000 P-33 .0023 W 0.5 0.5 900 S-35 .0025 -
W 0.01 5,000 Cl-36 .022 50,000 K-40 .012 0 0.01 0 0.01 9,000 7 K-42 .0014 W 0.01 20,000 Ca-45 .0065 0.01 3,000
- Sc-46 .029 Y 0.01 100 Ti-44 1.0 Y 7,000 V-48 .010 W 0.01 0.01 300,000 Cr-51 .00033 Y W 0.01 10,000 Mn-54 .0067 0.01 60,000 Mn-56 .00037 D 0.01 40,000 Fe-55 .0027 D D, 0.01 7,000 Fe-59 .015 5,000 Co-60 .22 Y 0.001
- 0.01 20,000 Ni-63 .0063 0.01 200,000 Cu-64 .00027 Y 0.01 5,000 i Zn-65 .02 Y 2,000 l Ge-68 .051 W 0.01 W 0.01 10,000 Se-75 .0084 1.0 6,000,000 Kr-85 -
20,000 Rb-86 .0066 D 0.01 Y 0.01 3,000 .
Sr-89 .041 90 Sr-90 1.3 Y 0.01 Y 0.01 2,000 Y-91 .048 400 Zr-93 .32 D 0.01 0.01 5,000 Zr-95 .024 D
- This column is also roughly equal to the maximum dose in rems per curie released because the maximum intercept fraction is 10 s and the inhalation pathway dominates the dose for most materials.
- Solubility classes for materials in the lung as defined in ICRP Publica-tion 30. D = days, W = weeks, and Y = years.
l 75
t
} Table 13. (continued)
'I '
Dose conver-sion factor Radioactive (rems /uci Solubility Release Quantity Quantity material inhaled) class fraction (weight) (curie)
Nb-94 .41 Y 0.01 300 Nb-95 .0057 Y 0.01 10,000 Mo-99 .0039 Y 0.01 30,000 Tc-99 .0082 W 0.01 10,000 Tc-99m .000032 0 0.01 400,000 Ru-103 .0089 Y 0.01 10,000 Ru-105 .00045 Y 0.01 70,000 Ru-106 .47 Y 0.01 200 Ag-110m .08 Y 0.01 1,000
. Cd-109 .11 D 0.01 1,000 Cd-113m 1.5 0 0.01 80 In-114m .088 0 0.01 1,000 Sn-113 .011 W 0.01 10,000 Sn-123 .032 W 0.01 3,000 3- -- Sn-126 .087 W 0.01 1,000 Sb-124 .025 W 0.01 4,000 Sb-126 .012 W 0.01 6,000 Te-127m .021 W 0.01 5,000 Te-129m .024 W 0.01 5,000 I-125* .79 D 0.5 7 I-129* saturates -
0.5 infinite I-131* 1.1 D 0.5 5 Xe-133 - -
1.0 900,000 Cs-134 .046 D 0.01 2,000 Cs-137 .032 0 0.01 3,000 Ba-133 .0078 0 0.01 10,000 Ba-140 .0037 0 0.01 30,000 Ce-141 .0089 Y 0.01 10,000 Ce-144 .37 Y 0.01 300 Pm-145 .025 W 0.01 4,000 -
Pm-147 .026 W 0.01 4,000 Sm-151 .03 W 0.01 4,000 Eu-152 .22 W 0.01 500 Eu-154 .28 W 0.01 400 Eu-155 .041 W 0.01 3,000 Gd-153 .024 D 0.01 5,000 Tb-160 .025 W 0.01 4,000 Ho-166m
.77 W 0.01 100 Tm-170 .026 W 0.01 4,000 Yb-169 .008 Y 0.01 10,000 Hf-172 .32 D 0.01 400 Hf-181 .015 D 0.01 7,000 Ta-182 .044 Y 0.001 20,000
- Child's thyroid.
76
~w ,- - ew-- -- - - - _ r--w-- - . ---------ew---- -em-- - -
. - ,i,---- gn---iry,- - - - * - w_,,.x--9 -+e---ww 9 - e%
- !7'
^~ ~
t
- i Table 13. (continued)
~
Dose conver-sion factor Radioactive (rems /uti Solubility Release Quantity Quantity material inhaled) class fraction (weight) (curie)
W-187 .0006 D 0.01 70,000 Ir-192 .0028 Y 0.001 40,000 Au-198 .0032 Y 0.01 30,000 Hg-203 .0073 W 0.01 n0,000 T1-204 .0024 D 0.01 $0,000 Pb-210 14. D 0.01 8 Bi-207 .02 W 0.01 5,000 Bi-210 .19 W 0.01 600 Po-210 8.5 W 0.01 10 Ra-226 8.5 W 0.001 100 Ac-227 6600. D 0.001 0.2 Ac-228 .3 D 0.001 4,000 Th-227 16. Y 0.001 700 250. W 0.001 5 Th-228 320. W 0.001 3
-- Th-230 Th-232 1600. W 0.001 0.7 Pa-231 1300. W 0.001 0.9 U-232 15. W 0.001 8 U-233 140. Y 0.001 8 130. Y 0.001 8 U-234 U-235 120. Y 0.001 (4100 kg) 9 U-238 120. Y 0.001 (30,000 kg) 10 490. W 0.001 2 Np-237 160. W 0.001 7 Pu-236 Pu-238 460. W 0.001 (0.12 g) 2 Pu-239 510. W 0.001 (32 g) 2 510. W 0.001 2 Pu-240 Pu-241 10. W 0.001 100 490. W 0.001 2 Pu-242 W 0.001 2 Am-241 530. ~
W 0.001 2 Am-242m 510.
520. W 0.001 2 Am-243
- 18. W 0.001 60 Cm-242 W 0.001 3 Cm-243 350.
W 0.001 4
! Cm-244 280.
W 0.001 2 l Cm-245 540.
W 0.001 9
! Cf-252 120.
Any other beta gamma emitter -
0.01 10,000 Mixed fission products -
0.01 1,000 Mixed corrosion products -
0.001 10,000 Contaminated equipment,
- 0.001 10,000 beta-Gamma Irradiated material, 0.01 1,000 any form -
77
g L
Table 13. (continued)
Y Dose conver-
! sion factor Radioactive (rems /uti Solubility Release Quantity Quantity material inhaled) class fraction (weight) (curie)
Irradiated material-solid, noncombustible -
0.001 10,000 Mixed radioactive waste, beta gamma except I-125 and I-131 -
0.01 1,000 Packaged waste, beta gamma * -
0.001 10,000 Any other alpha emitter -
0.001 2 Contaminated equipment, alpha -
0.0001 20 Packaged waste, alpha -
0.0001 20 4
- Type B packages assumed to have no release and no need for emergency preparedness.
the effective dose equivalent from material i for the ground HGCi =
contamination pathway, rems / curie released.
the effective dose equivalent from material i for the cloudshine
- HCSi =
pathway, rems / curie released.
I For all materials of greatest interest for fuel cycle and other radio-l active material licensees, the dose from the inhalation pathway Hgj will dominate the dose.
~
H yg was calculated by assuming a maximum plausible intercept fraction for non-depositing (non particulate) materials of 10.s. Thus, l
l Hyj = 10 s x DCF l~
where DCF = dose conversion factor, rems / curie inhaled. This intercept frac-l tion was found to be the intercept fraction that would be calculated a Gaussian
- plume dispersion model, a distance of 100 meters on the plume centerline, atmospheric stability class F, 1 m/s wind speed, release duration of 30 minutes, building size of 10 m by 25 m, no other obstructions to spread the plume, and no plume rise due to buoyancy.
t 78
.~ . - - . : =- = .,__- _-_. ==- ... .. . _ - - - .
m - _ - - - _. __ _
9 According to this model intercept fractions would exceed 10.s at distances y closer than 100 meters from the release point. Such larger intercept fractions 5 are not used because they are not considered physically realistic. Larger intercept fractions require the assumption that the smoke from a fire will not
- rise over the heads of people closer than 100 meters and that the people would stand in dense smoke for the full duration of the release. These assumptions are not considered realistic.
Next, a deposition model was added to the meteorological model described abcve. A deposition velocity of 1 cm/sec was assumed. This reduces the intercept fraction at 100 meters to 0.9 x 10 s, but adds a dose contribution i
from ground shine. Exposure to ground shine for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> was assumed.
T Table 13 includes all radionuclides listed on 20 or more of NRC's approxi-mately 9,000 licenses. A quantity for I-129 is not included because satura-tion would prevent the thyroid from absorbing enough I-129 to reach the 5-rem 2 - protective action guide dose. Table 13 also includes all beta gamma emitters listed on more than one but less than 20 licenses if the quantity that might deliver an effectice dose equivalent exceeding 1 rem is less than 10,000 curies.
l Table 13 also includes all alpha emitters listed on more than one but less than 20 licenses if the quantity that might deliver an effective dose equivalent exceeding 1 rem is less than 2 curies.
The quantities in Table 13 are different from quantities previously pub-lished in NUREG-0767, "C/iteria for Selection of Fuel Cycle and Major Materials Licensecs Needing Radiological Contingency Plans," and Federal Register Notices with orders (45 FR 12566) and an Advance Notice of Rulemaking (46 FR 29712).
The main reasons are: (1) dosimetric models from ICRP Publications 26 and 30 .
have been used instead of the older models from ICRP Publication.2 and (2) release fractions have changed as a result of further study. Meteorological models are slightly different, but this has a small effect in most cases. The intercept fraction for inhalation of a material that does not deposit on the ground is 10.s in both cases. For particulates, which do deposit on the ground, the dose per curie released can be as much as 11% lower for radionuclides with negligible external dose to about 5 times higher for radionuclides whose major dose pathway is groundshine from material deposited on the ground.* The values in Table 13 include consideration of groundshine.
- See Table 5.5 of NUREG/CR-3657 for contributions of each pathway.
79
- = = = = - - _
- - - - - - _ _ =
Y t
jr yr y
7
[ Quantities are also given for certain frequently occurring mixtures of r radionuclides.
Mixed fission products are assigned the generally applicable release frac-tion of 0.01 and a quantity of 1000 curies. This value is typical for fission products, assumes that short-lived iodines will not be present, and assumes that no single nuclide will account for more than perhaps 5 to 10% of the activity. In particular, Sr-90 is likely to be the dominant contributor to dose and is assumed to be no more than 5 to 10% of the activity.
Mixed corrosion products are assumed to be bound to surfaces and thus assigned the smaller release fraction of 0.001. Cobalt-60 is likely to be the dominant nuclide. The quantity assigned is 10,000 curies.
Contaminated equipment, beta-camma is likewise assumed to have a lower e release fraction of 0.001 due to bonding to surfaces. The activity assigned is 10,000 curies. Sr-90 is assumed to be less than 10% of the activity.
Irradiated material is assigned the same values as mixed fission products because the forms and nuclides are likely to be similar. However, solid noncom-bustible irradiated material is assigned a lower release fraction of 0.001 and an activity of 10,000 curies.
Mixed radioactive waste, beta-aamma, except I-131 and I-125 is assigned an activity of 1000 curies. Iodine-131 and iodine-125 are assumed not to dominate the hazard due to their short half-lives. If significant quantities of iodine would be in the waste, their quantities should be calculated separately.
Packaged waste, beta-camma is assumed to have one-tenth the release fraction of unpackaged material due to an assumed protection provided by the ,
packaging. The quantity assigned is 10,000 curies.
Contaminated equipment, alpha is assumed to have one-tenth the release fraction of alpha emitters in general due to bonding onto surfaces. An activity is 20 curies is assigned.
Packaged waste, alpha is assigned an activity of 20 curies because the packages are assumed to provide some protection against release.
Type B packaged waste is assumed to be a sealed source and assumed to have no significant release.
80
y -
7 y
p
{ \
2.3.2 Radiopharmaceutical Manufacturino l
?
I !
E These plants produce radionuclide-labeled compounds for medical diagnosis and treatment. Some handle only one or two radionuclides, while others handle many. The radionuclides of most significance are: H-3, C-14, P-32, S-35, Sr-90, Mo-99, I-125, I-131, and Cs-137.
2.3.2.1 Accident History Of the accidents listed in Tables 11 and 12, two were at radiopharma-cautical manufacturing plants. Those are the 1980 inplant contamination with An-241 and the 1981 release of 3.2 curies of sulfur-35. Both occurred at New England Nuclear in N'. Billerica, Mass. Doses offsite in both cases would be well below EPA's protective action guides.
2.3.2.2 Accident Source Terms Sutter analyzed potential accidents at radiopharmaceutical manufacturing facilities, including loading dock fires, major facility fires, tornadoes, earthquakes, spills and leaks, explosions, cyclotron accidents, and fires in waste storage areas.
Fires were seen to have the largest potential releases, and in particular a major facility fire involving all the radioactive material in a building was seen theoretically to yield the largest potential release. Release fractions for radioactive materials are based on the assumption that almost all the -
licensed material is involved in the fire, that storage containers (except sealed sources) are ineffective in protecting the material and limiting releases, l
and that the fire burns long and intensely. For these conditions to be met it is likely that the building containing the material would be woodframe or some other combustible material, that no automatic sprinkler system or other fire prevention system would operate, and that the local fire department would be f
i ineffective in fighting the fire. The entire building and its contents are assumed to be consumed in the fire. Table 14 lists the maximum quantity auth-orized for possession by any licensee and the release fraction for each radio-nuclide involved in a major facility fire.
l l
81
L
~
_.~ l E . ~ =__. -
1 1
- Table 14. Radiopharmaceutical Manufacturing: Maximum Possession Limits, Release Fractions, and Doses Due to a Major Facility Fire I -Maximum licensed
, Radioactive possession Release Effective dose material limit (Ci) Licensee fraction equivalent, rem **
H-3 150,000 NEN* 0.5 0.1 to 10.
C-14 500 NEN-Boston 0.5 0.005 to 0.5 P-32 500 NEN 0.5 0.04 to 4.
S-35 1,000 NEN 0.5 0.01 to 1.
Ca-45 50 NEN 0.01 0 to 0.003 Cr-51 100 NEN 0.01 0 Fe-55 200 NEN 0.01 0 to 0.005 Ni-63 1,000 NEN 0.01 0.001 to 0.06 e Se-75 100 NEN 0.01 0 to 0.008 Kr-85 10,000 NEN 1.0 0 to 0.002
} 0.01 0 to 0.003 a Rb-86 50 NEN Sr-90 500 NEN 0.01 0.05 to 5.
Mo-99 2,000 NEN/Squibb 0.01 0.001 to 0.08
~~
Ru-103 25 NEN 0.01 0 to 0.002 Sn-113 100 NEN 0.01 0 to 0.01
^; I-125 100 NEN/Mallinckrokt 0.5 0.3 to 30. (child's thyroid)
I-131 500 Mallinckrokt 0.5 5 to 500. (child's thyroid)
Xe-133 1,000 NEN 1.0 0 to 0.001 Cs-134 25 NEN 0.01 0 to 0.01 Cs-137 500 NEN 0.01 0.002 to 0.2 Ce-141 50 NEN 0.01 0 to 0.004 Yb-169 50 NEN 0.01 0 to 0.004 Tm-170 25 NEN 0.01 0 to 0.006 Au-198 200 NEN 0.01 0 to 0.008
- NEN = New England Nuclear, North Billerica, Mass.
- zero in the dose column indicates a dose of less than one millirem.
I 2.3.2.3 Calculations of Doses A range of doses due to release of radionuclides in a major facility fire was calculated to reflect uncertainty in the doses calculated. The upper end of the range represents the worst-case conditions - maximum release fractions, F, 1 m/s weather, and no plume buoyancy. From Figure 1 it can be seen that more typical weather (D, 4.5 m/s) reduces doses by a factor of almost 8, that assum-ing buoyancy during F, 1 m/s weather reduces doses by a factor of 37, and that assuming both D, 4.5 m/s weather and buoyancy reduces doses by a factor of 68.
Furthermore releases was smaller than assumed because of many possible mitigating factors.
82
~
[
[ We therefore present in Table 14 a range of doses to reflect these uncer-
- tainties. The upper end of the range is the worst-case described above and the lower end of the range is that value divided by 100. The range is considered likely to encompass the dose likely to be received by a person on the plume f centerline due to a severe accident.
From Table 14 it can be seen that in only one case is the potential dose significantly larger than the upper end of the EPA's protective action guide range - I-131 at Mallinckrodt.
l 2.3.2.4 Implications for Emergency Preparedness The radioactive materials possessed by radiopharmaceutical manufacturers 1 might present a potential hazard from H-3, P-32, S-35, Sr-90, I-125, and I-131.
1-131 exceeds the EPA's protective action guides by the largest margin with a
- dose of 5 to 500 rems to a child's thyroid within 100 m and 0.2 to 20 rems at 1000 m. All other materials would drop below the lower end of the protective
~
action guide range within 350 to 400 m.
2.3.3 Radiopharmacies and Hospitals i
Radiopharmacies act as receivers and distributors of radiopharmaceuticals for use by hospitals and medical research facilities. They are not production facilities, and thus minimal handling of radioactive materials takes place. In general, either a hospital will have its own radiopharmacy, or, as is currently taking place in the industry, a large metropolitan area will have one or more ,
private radiopharmacy firms serving as central distribution points for the
< hospitals and research facilities in the area.
j A radiopharmacy receives shipments of radiopharmaceuticals from vendors either as bulk quantities or as prepackaged diagnostic kits. With prepackaged j kits, the pharmacy merely holds the material until it is required for use by the hospital. For bulk quantities, the primary bulk material consists of Mo-99/Tc-99m generators. The radiopharmacy prepares individual doses by pipetting dose size aliquots into a syringe, which is then transported te its final destination. This loading of Tc-99m is usually conducted in a fume j hood. If other bulk materials are handled, such as iodine-labeled compounds, they may be dispensed in glove boxes.
I 83
't
,~ , , _ _ _ - , . _ . . . . , _ - . __
____,,.m____ ..__._-,-,-m_ . , _ ,
?-
h T r; 1
- 2.3.3.1 Accident History l l
There are no known accidents at radiopharmacies or hospitals with any offsite significance. The events that have been reported are small spills in the laboratory that were cleaned up in a routine manner or surface contamination on packages.
\
2.3.3.2 Accident Source Terms I
Sutter considered several classes of accidents and concluded that a major facility fire would result in the largest releases. The fire is assumed to consume the entire building and the roof is assumed to be breached providing a direct path to the atmosphere for airborne cont uination.
1 Table 15 lists the maximum quantity licensed for possession by any licensee
- and release fractions for a major facility fire.
2.3.3.3 Calculations of Doses Doses for a major fire at a radiopharmacy or hospital are shown in Table 15.
Doses from all radionuclides are far below the EPA's protective action guides.
A zero for the effective dose equivalent indicates that dose is less than 1 millirem.
2.3.3.4 Implications for Emeraency Preparedness No offsite radiological emergency preparedness is needed for radiopharmacies
- and hospitals because doses outside the buildings are far below the 1-rem lower limit protective action guide.
2.3.4 Sealed Source Manufacturing l
Sealed source manufacturers produce encapsulate radioactive materials into sources of alpha, beta, or gamma radiation or self-luminous devices for i use in watches, compasses, and aircraft instrumentation.
l Means of producing sealed sources vary, but in general consist of receiving the bulk radioactive material in a shipping container, dispensing the material 84 l
l
, . - , - - , , - - . . , , - ~ . . - - , , , -
, , . . - ..,...-n
s EL t
- Radiopharmacy: Maximum Possession Limits, Release Fractions, Table 15.
and Doses Due to a jor Facility Fire 9
Maximum licensed Dose Radioactive possession Chemical Release equivalent, material limit (C1) forms fraction rem H-3 0.05 Ci In vitro test kits 0.5 0 C-14 0.05 In vitro test kits 0.5 0 Cr-51 0.15 Labeled serum, 0.01 0 sodium chromate Co-58 0.15 Cyanocobalamin 0.001 0 (vitamin B12)
Fe-59 0.15 Chloride, citrate, 0.01 0 sulfate Se-75 0.1 Labeled compound 0.01 0 Sr-90 0.5 Nitrate, chloride 0.01 0 to 0.006
'~
Mo-99/Tc-99m 75. Mo-99/Tc-99m 0.01 0 to 0.004
- , generators (liquid) i 1-125 0.15 Na I, fibrogen, 0.5 0.001 to diagnostic kits 0.1 (child's thyroid) 1-131 0.75 Na I, labeled 0.5 0.007 to organic compounds 0.7 (child's thyroid)
Xe-133 1. Gas or saline 1.0 0 Note: sealed sources are not included.
Reference:
Sutter report.
in an appropriate containment in the required amounts, and placing the material -
in a capsule which is welded or brazed. Thus, little actual chemical processing
{ occurs; rather, the operations are more of a redistribution and repackaging process. In some cases the radioactive material is put through a series of l
steps to convert it to microspheres prior to encapsulation, and this operation ,
does involve some chemical processing. The production of tritium light source j usually requires that the gaseous tritium be transferred to a glass ampule,
- although in some cases a tritiated paint is produced for application to watch j or compass dials.
The majority of the time, the radioactive materials are in a form not readily airborne. These could be pellets, metallic wafers or foils, platinum 85
w . . - - .
mp - -
3r-5CJ 0-Plastic microspheres of controlled particle size encase some
{ gauzes, etc.
isotopes. These are generally spherical, 10 to 250 microns in diameter.
2.3.4.1 Accident History Several of the accidents listed in Tables 11 and 12 are relevant to sealed source manufacturing. They are: the 1959 drybox explosion involving Po-210 at Mound Laboratory, the 1960 processing cave fire involving curium at the Univer-sity of California-Berkeley, the 1967 cutting of an Ir-192 pellet in a hot cell at Babcock and Wilcox, the 1981 escape of Ir-192 from a hot cell at Tech / Ops, the 1983 accidental cutting open of an Am-241 sealed source at Gulf Nuclear, and the 1983 accidental cutting open of a Cs-137 sealed source at Shelwell Services, Inc. None of these accidents involved a large proportion of the radioactive material at the facility. All except the Gulf Nuclear and Shelwell Services accidents involved filtered hot cells. In all cases the airborne
~~
release to the environment was small.
~
2.3.4.2 Accident Source Terms Sutter analyzed a number of types of accidents including glove box or hot cell fires, container or piping leaks, spills, explosions, tornadoes, and major facility fires burning down the entire building. The major facility fire produced by far the largest releases.
Table 16 lists the maximum licensed possession limits for any licensee and release fractions for each radionuclide. The release fractions shown in Table 16 can be assumed for an intense fire of 30 minutes duration in which the building.
is breached.
2.3.4.3 Calculations of Doses As discussed previously a range of doses is presented in Table 16 due to a major facility fire. The highest doses represent a conservative worst case.
The lower end of the dose range (a factor of 100 lower) represent a severe but not worst-case accident during typical meteorology with some consideration given to plume buoyancy. It is clear that a few radionuclides are of signifi-cant concern: Po-210, plutonium, Am-241, and Cm-244. Doses exceeding the upper end of the protective action guide range seem plausible. All of these 86
E ti eg .
{
~ 1
' Table 16. Sealed Source Manufacturing: Maximum Possession Limits, Release Fractions, and Dos,es Due to a Major Facility Fire i Maximum Effective licensed dose Radioactive posession Release equivalent, material limit (C1) Form Licensee fraction rems H-3 100,000 Ci volatile Safety Light 0.5 0.06 to 6.5 C-14 50 Amersham 0.5 0 to 0.05 Co-60 20,000 75% metallic Automation 0.0001 0.004 to pellets Ind. 0.4 25% sealed sources Kr-85 1,500 noble gas 3M 1.0 0 Sr-90 3,000 1000 Ci in 3M 0.01 0.3 to 33.
solution in 0.1 liter of 0.1 N hcl
~~
also, sealed sources Sb-124 50 Monsanto 0.01 0 to 0.01 1-125 100 5 Ci in KOH 3M 0.5 0.7 to 70.
liquid (child's 5 Ci on resin thyroid) beads Cs-137 10,000 Tech / Ops 0.01 0.03 to 3.
Pm-147 3,500 800 Ci in 3M 0.01 0.008 to solution in 0.8 0.1 liter of 0.1 N hcl also, sealed sources .
Yb-169 100 5 Ci liquid 3M 0.5 0.004 to Yb chelate 0.4 Tm-170 5,000 Tech / Ops 0.01 0.01 to 1.
Ta-182 200 metallic or Tech / Ops 0.01 0 to 0.001 carbide Ta-183 2,000 metallic or Tech / Ops 0.01 0 to 0.001 carbide Ir-192 50,000 solid metal Tech / Ops 0.0001 0.001 to or sealed 0.1 source T1-204 50 Monsanto 0.01 0 to 0.001 87
- y. .. --
l e" l
'& ... n n -
f.- 1 I Table 16. (continued)
Maximum Effective I licensed dose 1 Radioactive posession Release equivalent, material limit (C1) Form Licensee fraction rems Bi-210 200 metal slugs 3M 0.001 0 to 0.03 Po-210 4,000 up to 1500 Ci 3M 0.01 1. to 100.
in 40 liters (per of 2M HNO3 ; 1500 Ci) up to 2500 Ci 0.001 0.2 to 20.
in waste (per primarily as 2500 Ci) nicrospheres Np-237 0.1 Monsanto 0.001 0 to 0.04 Pu-238, 236, 199 g 250 Ci as Monsanto 0.001 0.75 to 75.
239, 240, unsealed (per 241, 242 powder oxide 250 C1)
Am-241 6,000 250 Ci as Monsanto 0.001 1.2 to 120. l unsealed (per powder oxide; 250 Ci) remainer as sealed sources Cm-242 600 Monsanto 0.001 0.1 to 10.
Cm-243 10 Monsanto 0.001 0.03 to 3.0 Cm-244 600 Monsanto 0.001 1.5 to 150.
Cf-252 10 mg solid pellet Monsanto 0.001 0.006 to 0.6 are alphs emitters for which inhalation is the exposure pathway. Tritium, -
strontium-90, I-125, Cs-137, Tm-170, Cm-242 and Cm-243 might also be able to exceed the lower end of the protective action guide range.
2.3.4.4 Implications for Emeroency Preparedness Emergency preparedness should be considered for certain sealed source manufacturing facilities handling large quantities of materials. Those facili-ties potentially exceeding 1 rem are: 3M, Monsanto, Tech / Ops, and Safety Light.
In addition, it may be possible for effective dose equivalents to exceed the protective action guide value of 5 rems at distances as great as 1000 m.
88
1 L
Tais could potentially occur for Po-210 at 3M and plutonium, Am-241, and Cm-244
! at Monsanto. It is possible that these two plants would need more emergency
- preparedness than the others.
2 2.3.5 University Research Laboratories At university research laboratories, radioactive materials are received generally from radiopharmaceutical manufacturers and used in many labdratories covered under one license. They are received at and distributed from a central
~
receiving area. Solid waste is usally stored at a central location prior to disposal. Thus, the central receiving and waste storage areas have the largest s radioactive material inventories. License limits are low, and actual inven-
,' tories are usually fractions of the limit.
" The laboratories are scattered in different locations on a campus; up to 500 locations can handle radioactive materials at a single licensed facility.
Several laboratories may be located in one building. The generally low quantities of material licensed and the diffuse operations reduces the risks associated with these facilities.
2.3.5.1 Accident History 4
There have been no accidents at facilities of this type with significance
- for offsite protective actions. Releases have generally been very small.
2.3.5.2 Accident Source Terms l
i The accidents considered by Sutter are spills and leaks, tornadoes, explo-sions, fires, waste incinerator error, and patient related accidents. Again, fires are seen to yield the greatest releases. However a major facility fire involving the entire inventory is not reasonable because of the diffuseness of the operations. The fire with the maximum potential release is seen as being t
a major fire at the shipping and receiving department of the University. Sutter concluded on the basis of information submitted to NRC by licensees that, at most, 10% of the authorized possession limits would be involved. Table 17 lists the maximum possession limits for any licensee and the release fractions for a major fire at the shipping and receiving area.
89 1
_ . _ . _ ._. __~ ._._
w.
I g- .- - -
g 5 Table 17. University Research Laboratories: Maximum Possession Limits Release Fractions, and Doses Due to a Major Fire Radioactive Maximum licensed Release Effective dose material possession limit (Ci) fraction equivalent, rems H-3 3000 0.5 0.002 to 0.2 C-14 10 0.5 0 to 0.01 P-32 5 0.5 0 to 0.04 S-35 5 0.5 0 to 0.01 Ni-63 1 0.01 0 Sr-90 0.5 0.01 0 to 0.005 Mo-99/Tc-99m 10 0.01 0 1-125 8 0.5 0.06 to 5.5 (child's thyroid)
I-131 1 0.5 0.01 to 1. (child's thyroid)
Xe-133 10 1. O Po-210 10 0.01 0.009 to 0.9 Am-241 0.5 0.001 0.003 to 0.3 e Cm-244 1 0.001 0.003 to 0.3 Cf-252 0.1 0.001 0 to 0.01 2.3.5.3 Calculations of Doses A range of calculated effective dose equivalents is shown in Table 17.
The largest potential doses are from I-125, Po-210, and Am-241. The range reflects the likelihood that release fractions will be considerably below those shown in the table and a range of possible meteorology.
2.3.5.4 Implications for Emergency Preparedness I
Offsite emergency preparedness does not appear necessary for university .
research laboratories because potential effective dose equivalents are low.
l 2.3.6 Waste Warehousing and Burial In waste warehousing, radioactive material in containers (drums) is stored for a period of generally not more than six months. Drums may be opened in the waste warehousing operation. They are stored and then transported to a licensed waste burial ground.
90
- -- - ~-
___._._n.- _._ _ _ _ _ _ , _ . _ , _ _ _ _ _ _ _
t:.
e 2.3.6.1 Accident History Accidents involving waste darehousing and burial have been minor, such as very small releases, leaking containers, and containers having surface contami-nation above regulatory limits. There have been no offsite airborne releases of significance.
2.3.6.2 Accident Source Terms Warehousing. Since most radioactive waste is in metal drums, the potential for accidental releases is low. An event of significant magnitude to breach the drum _s would be required to make material airborne. Accidents
. considered are tornadoes, earthquakes, fires, and explosions.
A major facility fire is seen as yielding the largest releases. The activities of radioactive materials becoming airborne were estimated by Sutter.
These activities are listed in Table 18.
Table 18. Waste Warehousing Airborne Releases and Doses Due to a Major Facility Fire Radioactive Quantity Release Effective dose material present (C1) fraction equivalent, rem H-3 6200 0.5 0.004 to 0.4
, C-14 160 0.5 0.002 to 0.2
- P-32 160 0.5 0.01 to 1.
l S-35 120 0.5 0.002 to 0.2 Cr-51 60 0.01 0 I-125 280 0.5 4 to 400. (child's thyroid) 1-131 20 0.5 0.4 to 40. (child's thyroid) 91
^- r -___---
- ~
T Y
Burial. Accidents during waste burial were analyzed in a draft environ-mentalimpactstatement.kAmajortrenchfireoftwohoursdurationwasdeter-mined to be the accident with the largest potential airborne release. Dropped and ruptured containers were determined to cause smaller releases. The reader is referred to the referenced environmental staterrent for the details of the assumed releases.
2.3.6.3 Calculations of Doses Warehousing. A range of effective dose equivalents outside the building due to a major warehouse fire are also shown in Table 18. The range represents the uncertainty in doses that might result from a severe accident.
Burial. Doses . calculated for a major trench fire are given in NUREG-0782 as 0.006 rem whole body and 0.03 rem to the lungs. While these doses were not
- calculated by exactly the same calculational techniques as others in this report, they are so low that there seems to be no need to recalculate them.
2.3.6.4 Implications for Emergency Preparedness Since potential accident doses for waste burial are far below the EPA's protective action guides, burial does not seem to require special offsite emergency preparedness. For warehousing, the radioiodines I-125 and I-131 may make some special emergency preparedness appropriate.
- 0ffice of Nuclear Material Safety and Safeguards, Draft Environmental Impact Statement on 10 CFR Part 61 " Licensing Requirements for Land Disposal of Radioactive Waste," NRC Report NUREG-0782, Volume 2, Section 6.2.2, 1981.
l 92 l
l_.
.g su 7
- 2.3.7 Depleted Uranium Productsk l l
j
- Depleted uranium is used to make a number of products: radiation shields l for radioisotopes and x-ray machines, aircraft counterweights, armor-piercing
~
bullets, and artillery shells. Among the processing operations performed are:
reduction of " green salt" (uranium tetrafluoride) to metal; melting and casting I of the mets 1; welding; extrusion, cutting and etching; and machining. Since uranium metal turnings and powders will burn, fires are a potential ageident of concern.
2.3.7.1 Accident History Table 6 listed fires and explosions involving uranium and is relevant to fabrication of depleted uranium products. The releases and offsite contamina-tion that resulted were negligible in all cases.
2.3.7.2 Accident Source Terms Three potential scenarios during three operations suggest themselves as potentially resulting in the largest airborne releases of urantun.. First, a large quantity of molten uranium is handled during the malting ,ind casting operation. Second, moderate quantities of divided uranium scrap, which can be more readily ignited than bulk pieces, can be stored outdoors under water in containers. Finally, large quantities of uranium in the form of depleted uranium munitions are stored by the military. ~
Up to about 700 kg of molten uranium could be poured during a casting operation. If an operational or equipment failure resulted in the release of the molten uranium and the loss of the inert gas cover, the uranium would oxidize rapidly and a fraction would be made airborne. Carter and Stewart (1970) experimentally measured the airborne release from molten uranium and
- This section prepared with the assistance of Dr. Jofu Mishima, Pacific ,
Northwest Laboratories, t
93
- 1 = x.
c.
- esasured airborne release rates ranging from 0.005% to 0.3% clepending upon the p conditions - ignition and burning, melting, or partial disruption of liquid
{ into droplets.h The potential airborne release from this scenario range from 0.04 kg to 2 kg of uranium. Casting operations occur in enclosed facilities and some of the airborne material will be lost due to natural processes such as gravitational settling or deposition on surfaces during its transport to the release point from the facility. Many such facilities are equipped with particle removal devices such as filters which further reduce the emission.
Scrap metal such as turnings can be stored under water in metal cans.
Prezbindowski (1983) analysed such an event postulated to occur outdoors!**
190 kg of uranium turnings in a 30 gallon metal drum were assumed to ignite
- and oxidize to completion. The airborne release was estimated to be 0.1%
- resulting in 0.190 kg being released to the environment.
The potentially most serious accident would involve a fire in a munitions 2 - storage bunker (igloo) holding a large quantity of various types of munitions j (depleted uranium, high explosive, etc.). It is postulated that 12,000 rounds l of a 105 mm depleted uranium cartridge could be present. Each cartridge would hold 3.3 kg of uranium resulting in a total of 40,000 kg of uranium. Other l' types of combustibles such as wooden crates and pallets, paper based packing j- materials, etc. would also be present. If the material present were ignited, j the fire would initially spread slowly until sufficient flammable vapors could I
be generated and flashover occurs. Once flashover occurs, the entire contents i of the enclosure are involved. The fire soon becomes oxygen limited due to
- the limited accessibility of air. Eventually, the cartridges themselves would be ignited and, if containment is lost, the fire would burn more vigorously ,
due to the greater availability of oxygen.
Igloos are designed to vent in a perferred direction which does not involve adjacent structures. The flammable vapors released may well burn i
outside the facility due to the high vapor generation rate reducing radiant heat transfer to the materials inside.
- R. F. Carter and K. Stewart, "On the Oxide Fume Formed by the Combustion of Plutonium and Uranium," Inhaled Particles III, Unwin Brothers Limited, The Gresham Press, England, 1970.
i **D. L. Prezbtndowski, " Uranium 0xide Facility Safety Analysis Report,"
j UNI-M-157-DR, United Nuclear Industries, Richland, Washington, 1983.
i l 94 I
1
,- --. ...-_=: -:-m- : :_- ____ - =: - _ _ _ _ .
4 I There are two types of cartridges cases used for depleted uranium munitions -
, metal and combustible. The depleted uranium portion nf metal cased cartridges were ejected from and unaffected by the fire in a large-scale, outdoors test.*
Depleted uranium from combustible-cased munitions in similar tests were not ejected from the fire and were almost completely oxidized (83% and 85.2%).**
Collection and analysis of the residual material did not indicate a loss of uranium and air samples taken during part of the burning and all of the recovery period did not show any significant airborne release.***
Experimental studies measured the rate of oxidation and airborne release during oxidation at elevated temperatures (400 C to 1200 C) of the depleted uranium portion of large-caliber munitions in air and a 50% air-50% carbon dioxide mixture. The maximum airborne fractional release rate measured during the outdoor test using combustible materials as the heat source was 2.2 x 10 s/ min by weight. The material was primarily U 30s. About 50% of the material
, had a by weight aerodynamic equivalent diameter of 10 microns or less. The three depleted uranium specimens oxidized an average of 44% during the three hour test. The velocity of air passing around the samples was 2.23 m/s (5 mph).
Similar but lower rates were measured in laboratory studies at various tempera-tures and atmospheres.
For the worst case accident involving depleted uranium it is postulated that 40,000 kg of depleted uranium are involved in an igloo fire and that it is completely oxidized. It is also assumed that the material is combustible-cased although the igloo limit is for metal-cased. Based upon the experimental studies recorted by Elder and Tinkle,**** the material would be completely
- R. L. Gilchrist, G. B. Barker, and J. Mishima, " Radiological and Toxicological Assessment of an External Heat (Burn) Test of the 105 mm Cartridge, APFSDS-T, XM-774," PNL-2670, Pacific Northwest Laboratory, Richland, Washington, 1978.
- C. D. Hooker et al, " Hazards Classification Test of the Cartridge, 120 mm.
APFSDS-T, XM-829," PNL-4459, Pacific Northwest Laboratory, Richland, Washington, 1983.
- J. C. Elder and M. C. Tinkle, "0xidation of Depleted Uranium Penetrators and Aerosol Dispersion at High Temperatures," LA-8610-MS, Los Alamos Scientific Laboratory, Los Alamos, NM, 1980.
- J. C. Elder and M. C. Tinkle, " Oxidation of Depleted Uranium Penetrators and Aerosol Dispersion at High Temperatures," LA-8610-MS, Los Alamos Scientific Laboratory, Los Alamos, NM, 1980.
95
. _ _ _ _ .n -
- -.n v
. gyre .
i= -.
I
.. oxidized in 400 min. At the rate of 2.2 x 10.s/ min, 35 kg would be made air-borne of which half are respirable particles. The total airborne release of respirable depleted uranium thus would be 18 kg.
2.3.7.3 Calculations of Doses The effective dose equivalent for an 18 kg release of depleted uranium was calculated to be in the range from 0.001 to 0.06 rem. Heavy metal poisoning of the kidneys is not a factor because the uranium would not be in soluble form.
2.3.7.4 Implications for Emergency Preparedness No special offsite emergency preparedness is necessary for depleted uranium products because doses are below protective action guides.
2.4 Summary of Facilities to be Covered Fuel Cycle: The accident with the greatest potential hazard appears to be release of a large quantity of UFe. The release of a large quantity of UFs presents a chemical toxicity hazard. The greatest potential hazard is at UFs conversion plants where hot 14-ton cylinders are handled outside. NRC licenses l two such plants. The rupture of a hot cylinder is quite plausible and could lead to multi-ton releases of UFe. The release would begin instantly. In such a case evacuation to several kilometers downwind would be appropriate for very calm weather conditions. The plume is easily detectable by sight and by .
smell at levels well below levels likely to cause injury. Thus people downwind would be able to see the plume coming and would be able to judge for themselves when they have reached an area of safety. A protection action strategy is discussed in more detail in Section 2.5.
l In an actual accident the release could be greatly diminished by spraying the release point with water or carbon dioxide. This is probably the most effective action that can be taken to mitigate offsite consequences.
The release of low-enriched UFs could also occur from smaller 10-ton cylinders and could occur inside a building, which would prevent escape of 96
f 1- ~
re
[ much uranium. For the 9 such facilities licensed by NRC the appropriate
, response would be similar to tha,t above but would be limited to distances of perhaps about half as great.
The release of high-enriched UF. from hot cylinders may not require offsite response due'to the small cylinder size used.
The release of UFs from cold cylinders does not require a response because the quantities released would be quite small. With regard to the heating of cold cylinders in a fire and subsequent release, a response similar to that for hot cylinders may be appropriate, but additional warning time would generally be available.
For a criticality accident, the lower end of the protective action guide range could be exceeded for a person standing outside on the plume centerline out to a distance of about 250 meters from the release point assuming adverse
^
weather conditions. The calculated doses are based on the assumption of a pulsating criticality lasting 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and the person standing outside on the plume centerline for the entire 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Three additional licensees might be in this category.
An appropriate emergency response to a criticality accident during adverse meteorology would be immediate sheltering and closing windows up to a distance of 250 meters downwind. This response should be accomplished within about 3 or 4 minutes after the criticality occurs. The initial pulse is likely to be the largest one. Plume travel time to 250 meters would be about 4 minutes for low wind speeds and 1 minute for average wind speeds. There would be some added delay due to holdup in the liquid solution and the building atmosphere. After the immediate sheltering response, evacuation could be considered as an alter-
~
native to further sheltering.
Preparedness for such a response is recommended for the area within 200 to 250 meters from high-enriched uranium and plutonium processing.
Plutonium facilities (none currently operating) may also need special off-site emergency preparedness due to airborne releases of plutonium. However, the GESMO analysis discussed in Section 2.2.6 would indicate that extensive preparedness may not be appropriate.
Byproduct material and plutonium licensees: A total of about 48 Part 30 or Part 70 licensees were identified who were authorized to possess one or more radionuclides in unsealed form in excess of the quantities in Table 13 of this analysis (i.e., effective dose equivalent could exceed 1 rem offsite or j 97
m l g-E%:
t thyroid dose could exceed 5 ress). However, some of the licensees have little or no need to possess as much as they are authorized to and some can do an I evaluation to show releases would be smaller than assumed. We estimate that most of the licensees will elect to lower their authorized possession limits or perform an evaluation rather than submit a plan. Thus, the total number of affected licensees is likely to be about 10 exceeding the limit for plutonium and 7 exceeding the limit for other materials, specifically Am-241, Po-210, I-125, I-131, H-3, P-32, Sr-90, Cm-242, and Cm-244.
In all cases a fire would be the accident of concern. The appropriate emergency response would be to evacuate people from the immediate vicinity (at least 100 meters) so as not to interfere with firefighting and to shelter or evacuate everywhere else where smoke can be smelled. These actions should be taken within a few minutes.
2.5 A Protective Action Strategy The most important characteristic of the accidents discussed is that there is likely to be little or no warning time before releases start. The most important accidents, UFs releases and fires, are likely to be controlled within roughly half an hour in a majority of cases. Thus releases are often likely to stop or be greatly reduced within a half hour.
2.5.1 The Initial Response Quick decisions and prompt actions are necessary. The goal should be to
~
make decisions on protective actions and start implementing those decisions within 5 or 10 minutes of discovering the accident.
The heart of an effective protective action strategy is predetermined protective action decisions. The decisions should be made, agreed upon, and written down prior to an accident because accidents of concern are likely to happen so quickly that decisions on protective actions must be immediate to be effective. Thus, the licensee's initial notification of police and fire officials should include a recommendation on what protective actions are appropriate and the distances to which the protective actions are appropriate.
l l
l l 98 l
'i r
Response distances can be calculated in advance based on how much material i
. is subject to release relative to the values in Table 13 and on simple meteoro-logical observables. Tha values in Table 13 are based on a meteorology of stability class F and wind speed of 1 m/s. Stability classes A through E and higher wind speeds would each cause doses to be reduced. The protective action strategy developed here accounts for that reduction.
The wind speeds at the time of an accident can be roughly estimated from simple observations. The correlation, called the Beaufort wind scale,is shown in Table 19.
Table 19. Beaufort Wind Scale (Simplified)
Mean Wind Speed at
. 10 meters height Description of wind 0.9 m/s Light air - direction of wind shown by smoke drift, but not by wind vanes.
2.4 m/s Light breeze - wind felt onface; leaves rustle; ordinary vane moved by wind.
4.4 m/s Gentle breeze - leaves and small twigs in constant motion; wind extends light flag.
6.7 m/s Moderate breeze raises dust and loose paper; small branches are moved.
9.3 m/s Fresh breeze - small trees in leaf begin to sway; crested wavelets form on inland waters.
In addition, atmospheric stability classes can be adequately determined from simple observations: whether it is day or night, the strength of the sun, cloud cover, and wind speed. The relationship, developed by Pasquill, is .
shown in Table 20.
It is now possible to relate doses compared to the dose for F, 1 m/s meteorology. This is done in Table 21. The comparison is based on 100 meters.
The table is slightly conservative for greater distances.
The next step is to develop response distances for different weather condi-tions. First, consider a licensee for which the quantity subject to release is 5 times the snount in Table 13. This represents a typical licensee to which the proposed rule would apply. The ma::imum potential effective dose equivalent off-site for F, 1 m/s weather is thus 5 rers. Protective actions should be considered 99
3-E . ~_
O L
b Table 20. Pasquill's Relation of Turbulence
- Types to Weather Conditions
?
E A-Extremely unstable sendiuons D-Neutral conditions *
- B-Moderstely unstable condations E-Slightly stable condations C-slightly unstable condations F-Moderately stable conditions
- Nighttime conditions Thin overcast yume insoladon ,, , ./, cloudi- s 8/ cloudi-Surface wind speed, m/see Strong Moderate Slight messt mess
<2 A A-B B 2 A-B B C E F s 4 B B-C C D E 6 C C-D D D D
>6 C D D D D
- Applicable to heavy overcast, day or night.
1The degree of cloudiness is defined as that fraction of the sky above thelocal apparent -
horizon that is covered by clouds.
l -
~ Table 21. Plume Centerline Dose for Different Meteorologia1 Conditions Relative to F, 1 m/s Nighttime conditions Surface wind Daytime insolation Thin overcast Day or Night speed, or ? 4/s 1 */s m/sec Strong Moderate Slight cloudiness cloudiness Heavy overcast
<2 0.03 0.04 0.05 1.00 1.00 0.23 2 0.02 0.03 0.05 0.21 0.50 0.12 4 0.01 0.02 0.03 0.06 0.11 0.06 6 0.02 0.03 0.04 0.04 0.04 0.04
>6 0.01 0.03 0.03 0.03 0.03 0.03 where the dose under actual meterological conditions could exceed 1 rem. Down-wind distances to which actions should be considered are shown in Table 22 below. Note that the table and its terminology has been simplied for use by night watchmen, firemen, and policemen. Figure 1 (page 11) has been used to l estimate distances. Distances are rounded off to the nearest 100 meters.
! Note that the only time that actions would be considered for more than the immediate vicinity of the plant (i.e., beyond 100 meters) occur at night during light breezes. We would therefore recommend the following protective actions.
l In general, the fire and police departments should evacuate to a radius of very 100 l
y
't?
[ Table 22. Downwind Distances to Which Piotective Actions should Be Considered for an Accident Involving Five Times the Quantity l of Material in Table 13 )
Day Night (except Thin overcast Day or Night ,
heavy or 50+% Less than 40% i Wind overcast) cloud cover cloud cover Heavy overcast Very light 0 400 400 X)0 breeze - direc- meters meters meters meters tion of wind
. shown by smoke drift.
Light breeze - 0 100 200 0 wind felt on meters meters meters meters face, leaves k rustle.
Gentle breeze - 0 0 0 0 leaves and twins in constant motion; wind extends light flag. Or any stronger wind.
roughly 100 meters. This would be an appropriate action for any large fire to prevent onlookers from interferring with firefighting efforts.
At night protective actions to 200 meters or 400 meters downwind would be recommended for light winds. Evacuation or sheltering are both appropriate responses. The local authorities should select one or the other based on their.
practicalities at the time. Sheltering has an advantage in that.most people would already be indoors at night. For sheltering to be effective, doors and windows should be closed and furnaces and air conditioners should be shut off.
Upon termination of the release, doors and windows should then be opened to allow any radioactive materials that have gotten in to blow out. Evacuation of the area is also an acceptable alternative, but if it cannot be done within a few minutes it may not be as effective as sheltering.
Downwind distances calculated in this manner should be taken as approxi-mate guidelines, not as rigid criteria. In an actual situation firemen and
. policemen should notice where smoke is blowing and take reasonable steps to 101
' fr
=
r.
- ~
Z 7
prevent anyone staying in dense smoke for an extended time. In addition, since 4 the upper range of the protective action guides is never exceeded, the protec-tive actions recomended above should be considered optional, not mandatory.
Now consider a licensee for which the quantity of material subject tb release is 50 times the quantity in Table 13. This size release probably represents a practical upper bound for an accident at any currently licensed facility. The following table of downwind distances can be calculated.
Note that in the daytime a rather modest response is appropriate, except for heavy overcast days with light breezes. At night with very light breezes, protective actions should be considered to 1500 meters downwind. The table also shows distances downwind to which doses might exceed the upper end of the protective action guide ranges.
G O
102
- w. _. .__. . ,
v f'
si \
J h Table 23. Downwind Distances to Which Protective Actions Should be Considered for an Accident Involving 50 Times the Quantity
+
of Material in Table 13
^
Night
. Day Day Thin or Night overcast Less Strong Moderate Slight or 50+% than 40% Heavy Wind Sun Sun Sun cloud cover cloud cover overcast Very light 100m 200m 200m 1500m 1500m 700m breeze - direc- (600m)* (600m) (200m) tion of smoke shown by smoke drift.
, Light breeze - 100m 100m 200m 600m 1000m 400m
~
wind felt on (200m) (400m) (100m)
, face, leaves
- ,, rustle.
Gentle breeze - 0 100m 100m 300m 400m 300m leaves and twigs (100m) in constant motion, wind extends light flag.
Moderate breeze - 100m 100m 200m 200m 200m 200m raises dust and loose paper, small branches are moved.
Moderately 0 100m 100m 100m 100m 100m ,
strong breeze -
small trees in l
i leaf begin to sway.
- Distances in parenthesis are distances to which the 5-rem upper end of the protective action guide range could be exceeded.
103
f L
?-
I We have not defined an emergency planning zone for either the plume expo-r sure pathway or the ingestion pathway as is done for nuclear power plant emergency planning. Instead we have calculated response distances.
The concept of the planning zone has no practical application for the smaller accidents that might occur for these types of facilities. In general, the response would be under the direction of the local fire and police depart-ments just as similar industrial accidents are handled. It is only necessary to identify the organizations that will be notified and will respond rather than a geographical area for which planning would take place.
2.5.2 The Relocation Phase
- After the initial evacuation or sheltering, the next step is to relocate people out of " hot spots" caused by deposition o" gamma ray emitters. The
- - initial response described above included the assumption of exposure to ground shine for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in determining the distances to which a person might receive a dose of 1 rem effective dose equivalent. The relocation phase is concerned with doses received from ground shine for longer periods of time.
Surveys should begin near the release point and work outward so that the highest dose levels are likely to be found earliest. There are only a limited number of radioactive materials with the potential to case doses exceeding 1 rem within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> outside the initial response area. These are: Na-22, Na-24, K-42, V-48, Mn-56, Cu-64, Tc-99m, Ru-105, Sb-126, and W-187. However, none of these materials is currently possessed by any licensee in quantities such that ground shine could exceed 1 rem within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ,
As a practical matter, ground shine would not be expected to exceed 40 mR/hr from any accident at a licensed facility, except possibly quite near 2
the release point where fallout of very large, heavy particles may occur.
"Hotspots" thus should be found within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inside the initial response area and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> outside. These times are believed to be practical and also adequate to allow taking protective actions in a timely manner.
Since there are no official guidelines on dose rates at which people should be relocated pending decontamination, we suggest here a value of about 2 mR/hr to be roughly consistent with NRC's concept of restricted areas and unrestricted areas. Under normal circumstances licensees must keep doses to people in unrestricted areas to less than 2 arem in any one hour. Lower or 104 n_ _ _ _
Y
\
?
I higher values could be used in specific circumstances. Lower values may be
~
appropriate for more sensitive members of the population, such as residences of preschool age children or pregnant women. Higher values could be used if occupancy factors would be low or there were other restraints to relocation.
For example, highways or parking lots could be used at higher dose levels based on low occupancy factors. Critical industrial processes could be maintained at higher dose levels based on economic needs, and the homes of people not wishing to relocate could be used based on the concept of informed consent.
2.5.3 The Assessment Phase Soon after the release has ended, usually within half an hour to an hour, the assessment phase of the emergency response should begin. The public will
-- be concerned about whether the danger is over, whether they were exposed, whether they are contaminated with radioactivity, whether their homes are contaminated with radioactivity, and what should they do. The news media will want to know what happened. Both the licensee and the NRC must be prepared to respond to such concerns promptly or suffer damaged reputations, ill-will, and possibly lawsuits.
As discussed above, field measurements to locate ground contamination will be underway.
The question of whether people were exposed can only be answered with abundant field measurements. Generally, direct measurements of radioactive material concentrations in the plume will not be possible because of a lack of .
time to prepare and a lack of ability to locate and follow the plume. Never-theless, plant personnel should attempt such measurements with available instru-mentation to the extent possible because if they are fortunate enough to get data, the data will be valuable.
The answers of whether or to what degree people were exposed are likely to be best answered by measurements of ground contamination and bioassay measure-ments. Ground contamination measurements will allow a direct determination of whether there was a release. They will also allow a quick rough order-of-magnitude estimates of the time-integrated exposure to people in the areas. The time-integrated exposure is equal to concentration X in uCi/cm3 times time t in seconds:
105
~ ~~
,- l y ,
V ,
1 T
is xxt=f d ,
where GC is the ground contamination in uC1/cm2 and the deposition velocity Vd may be taken to be 1 cm/s. This value for the deposition velocity should
, normally provide conservative estimates of concentrations and dose, especially for distances within a few hundred meters of the release point.
The effective dose equivalent H in rems to an individual during plume passage is:
H = DCF x B x X x t x 10 s
+ where H = effective dose equivalent from inhalation, rems 4 DCF = dose conversion factor from Table 13, rems / curie inhaled B = breathing rate, 266 cm 8/s X x t = concentration times time, uCi s/cm3 10 8 = a factor to convert uCi to curies.
At this point dose can be written directly in terms of the measured ground contamination GC. The dose conversion factor DCF for the specific radionuclide is given in Table 13:
- H = 2.66 x 10 4 x DCF x GC This equation provides a fast method to roughly approximate a person's l internal dose directly from measurements of ground contamination. -
l The quantity of material released can be roughly approximated from ground contamination measurements as well. The equation can be derived by similar means.
Admittedly, this approach will be subject to very large uncertainties.
However, there is not likely to be any better means to estimate the size of the release for at least several days.
In addition to the dose estimates described above, bioassay measurements may be desirable whether a release occurred or not because there may be no way to prove that there was no release. Nasal swipes and skin contaminations are 106
E I
^
f the easiest to obtain and help answer the question of whether a particular
- person was exposed. Urine samples can provide more sensitive and quantitative estimates of dose. Fecal sampling and in vivo counting can supplement the E
above methods.
2.5.4 The Food Pathway From experience we know that the contaminated area will be prima *rily near the plant and will rapidly drop off with distance. The job of a monitoring team would be to go wherever necessary. We can define the monitoring capability needed. We cannot define in advance an actual area that could be affected.
- 3. VALUE/ IMPACT l 3.1 Alternatives Three alternatives have been identified: (1) adopting a regulation containing the proposed requirements, (2) imposing the requirements by license condition rather than by regulation, and (3) imposed no new requirements with regard to emergency planning. The first two alternatives would have essentially i the same value and costs. Those values and costs are discussed below. The l third alternative, no new requirements, would have essentially no value or costs.
3.2 Value of the Proposed Action Value can be expressed in terms of risk reduction.
Consider a release in which the effective dose equivalent at a distance i of 100 meters is 5 rems, assuming Class F atmosphere stability and a wind speed l
l of 1 meter /sec. The area over which the 1 rem protective action guide would be l exceeded would be 0.006 square miles. If this area contained people at the average population density of the continental United States (72 people / square mile) it would contain on the average about half a person.
107
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a-&-' --T " w = - - - -
- t=
Fr
+
7 However, the facilities under consideration are usually located in built-up
- areas. A survey of potentially affected licensees shows that typical popula-7 tion densities are about 3,000 people / square mile.8 ~Thus perhaps about 20 people would typically be in the area. Generally about 80% of people are in the build-ings so about 4 people would be outdoors and 16 would be indoors.
The average dose to a person outdoors in the area was calculated to be about 3 rems. (This value was calculated for an open field; doses in urban areas would be less, but we ignore that factor.) In addition, doses to people in buildings would be half this dose because of protection provided by the building.
The total collective dose for the urban area thus might be 40 person-rems.
Protective actions that would be available to these people are primarily evacuation and sheltering. Evacuation would be the more effective if it could be done promptly before the plume arrived. Sheltering would often be more
.L - practical because it can be done faster and most people are already inside.
Very roughly the dose savings, due to protective actions for this adverse meteorology could be put at 20 person-rem, about half the potential dose.
Assuming that the chance of death due to cancer due to doses of several rems is in the range between zero to 10 4 cancer deaths / rem. The expected number of lives saved due to the protective actions would be less than 0.002 for adverse meteorology and roughly 0.00002 lives averaged over all meteorology.
Our estimate of the frequency of a major release is less than 10 4/ year.
Insurance statistics available from insurance companies dealing in commercial structures indicate fire losses in unsprinklered commercial and industrial facilities to be 0.006/ year. Sprinkler failure rates are estimated to be .
0.038 should a fire occur.E* The fire loss rate for a sprinklered facility should thus be roughly 2 x 10 4/ year. It is now assumed that additional site specific factors will reduce the probability of a release to roughly 10 4/ year.
'*J. P. McBride, " Economic Consequences of Accidental Releases from Fuel Fabrication and Radioisotope Processing Plants," NUREG/CR-0222, 1979, Appendix A.
- National Fire Protection Association, Fire Protection Handbook, 14th edition, Table 14-19, page 14-5. .
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i Examples of such factors would be: material kept in fireproof storage thus
- preventing significant release,,* filter system does not fail thus preventing release, or firemen extinguish fire before radioactive material is heated hot enough for a significant release, and many more. Thus protective actions could be expected to save 0.00000002 lives per year per facility.
If a life is given a value of ten-million dollars, the value of protective actions at a typical site in an urban area is $0.20 per facility per year or less.
Now consider a release in which the effective dose equivalent at a distance of 1000 meters is 5 rems assuming Class F atmospheric stability and wind speed of 1 meter /sec. At this level early injuries have still been avoided. The area over which the 1 rem protective action guide would be exceeded would be 0.15 square miles. For-a typical built up site this area would contain about 450 people.
-- The average dose to a person outdoors in the area was calculated to be about 3 rems and to a person indoors was calculated to be 1.5 rems. The total collective dose assuming some people are indoors as previously discussed might be 800 person-rem. The dose savings due to protective actions could be about half of this or 400 person-rem. Lives saved due to these protective actions could be up to 0.04 life for adverse meteorology and 0.04 life for average l meteorology.
l With the frequency of a major release at 10 4/ year, protective actions might perhaps save up to 0.000004 life per year per facility.
I If a life is given a value of ten-million dollars, the value of protective actions in a densely populated urban area is $4 or less per facility per year. .
l 3.3 Cost For the smaller class of accidents, those exceeding 1 rem offsite but not 5 rems at 1000 meters, the licensee is considered to have a 50 page plan telling what he would do in the event of emergencies such as fires.
Cost data were obtained from two radiopharmaceutical manufacturers. Both licensees calculated the cost of the onsite contingency plans required by order.
The manufacturer with a small program and limited facilities estimated the initial set-up cost $84,000. Annual operating costs were estimated to be 109 l
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$18,000. Labor accounted for 1/2 to 2/3 of the cost in each category. Labor was given a value of $30/ hour with no overhead charged. The main equipment costs were for radios, extra monitoring equipment for emergency use, and extra respirators. The largest annual expense is for training. Other operating expenses are for audits, drills, and equipment replacement and maintenance.
To place all expenses on an annual basis the initial set-up cost was divided by 10, assuming a ten year useful life of a plan. Thus annual costs are estimated to be $26,000/ year / facility for this radiopharmaceutical manufac-turer with a small program.
A second radiophr.rmaceutical manufacturer with one of the largest programs that would be covered by the regulation reported that the cost of establishing their on-site radiological contingency plan was more than $550,000. No annual operating costs were given.
Assuming a 10 year plan life and operating costs of $18,000/ year (the estimate of the other manufacturer) the total annual cost is $73,000/ year /
facility for large facilities. -
Costs to NRC to review and inspect plans have been estimated to be
$4,000/ year / facility.
3.4 Value/ Impact of Alternatives The costs of emergency preparedness are expected to exceed the benefits in terms of protecting public health and safety as M own 4elow.
Table 24. Comparison of Costs and Benefits of Special -
Emergency Preparedness Size of Licensee Cost Benefit Small - Possessing 5 times quantity in Table 13 $30,000/yr 40.20/yr Large - Possessing 50 times quantity in Table 13 $77,000/yr $4/yr 110
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4.0 STATUTORY CONSIDERATIONS n <
4.1 NRC Regulatory Authority The Atomic Energy Act gives NRC authority to adopt regulations for protec-ting public health and safety. This proposed rule would be justified under that authority.
4.2 Agreement State The question is whether NRC's Agreement States would adopt offsite emer-gency preparedness requirements similar to NRC's.
The NRC's Office of State Programs intends to make this requirement a matter requiring cor.patability. Thus, NRC would require that Agreement States
_ adopt requirements similar to NRC's.
4.3 Environmental Impact Appraisal The NRC's regulations [10 CFR $ 51.5(b)] require that substantive and significant amendments (from the standpoint of environmental impact).of regula-tions require an environmental impact statement.
To make the finding that amendments are not substantive and significant from the standpoint of environmental impact, NRC regulations [10 CFR S 51.5(c)(1)]
require the preparation of a negative declaration and an environmental impact
! appraisal. ,
l The environmental impact appraisal must include [10 CFR $ 51.7(b)]:
(1) A description of the proposed action.
(2) A summary description of the probable impacts of the proposed action on the environment.
(3) The basis for the conclusion that no environmental impact statement need be prepared.
111 l
l
C 5 The proposed action is a rule to require emergency procedures for off-
,, site releases. A description of the proposed requirements is contained in Section 1.1, " Description of the Proposed Action." )
A summary description of the probable impacts of the proposed action on the environment is contained in Section 3.2, "Value of the Proposed Action."
The basis for the conclusion that no environmental impact statement need be prepared is that the benefits to public safety are neither substantive por significant as described in Section 3.2, "Value of the Proposed Action,"
and summarized in Table 24.
- 5. CONCLUSIONS 9
The conclusion.of this Regulatory Analysis is that accidents at fuel cycle and other radioactive material licensees pose a very small risk to the public.
Serious accidents are infrequent and would generally involve relatively small radiation doses to few people located in small areas.
This is not to say that radiation doses large enough to exceed guides for taking protective actions cannot occur. It may be possible to have an. accident at some licensed facilities which would cause offsita doses exceeding protective action guides. However, offsite radiation doses large enough to cause acute fatality or even early injury from an airborne release are not considered 3 plausible.
For a licensee possessing 5 times the amount of material in Table 13, we conclude that protective actions in an urban area might save up to 0.00000002 lives per year per facility. Perhaps about 20 to 30 licensees have a possibil ,
ity of such an accident or worse. For these facilities we recommend there j should be notification of local authorities. However, no special facilities, equipment, or other resources for responding are considered necessary.
l For a licensee with 50 times as much releasable material as in Table 13, we l conclude that protective actions in a built up area might save up to 0.0000004 lives per year per facility. There may be 2 or 3 licensees with a capability of an accident this severe.
The cost of this preparedness may not be justified in terms of protecting public health and safety. Rather we would justify it in terms of the intangible benefit of being able to reassure the public that if an accident happens local
! authorities will be notified so they make take appropriate actions.
112
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.- g i Although emergency preparedness for fuel cycle and other radioactive
- material licensees cannot be shown to be cost effective, the NRC feels that such preparedness represents a prudent step which should be taken in line with the NRC's philosophy of defense-in-depth, to minimize the adverse effects which could result from a severe accident at one of its facilities.
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5 men USER OFFICE CONCURRENCE e
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y l Frent P. rillnpic DEC. 7 584 l
- 4. We believe the purpose of the rulemaking is more than to require l licensees "to notify governmental authorities in case of an accident and recommend protective actions that should be taken by the public" as suggested in SCREENING criteria "e. How the public, industry, and NRC would be affected." See Comments #1,
- 2, and #8 in nty memorandum of November 28, 1984.
R ngham, Director Division of Fuel Cycle and Material Safety, NMSS l' .
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.- . I UNtTED STATES
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- NUCLEAR REGULATORY COMMIS$10N y WAk4sNbT0N,0.G. 2065?
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(...../ DEC 41984 1 MEMORANDUM FOR: Edward L. Jordan, Director Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety & Safeguards FROM: Frank P. Gillespie Director Division of Risk Analysis and Operations y Office of Nuclear Regulatory Research
SUBJECT:
' DRAFT RECOMiENDATIONS TO EDO CONCERNING WHETHER AND HOW TO CONTINUE WITH ONG0ING RULEMAKING SPONSORED BY RES,
.j __ " EMERGENCY PREPAREDNESS FOR FUEL CYCLE AND OTHER RADIO-ACTIVE MATERIAL LICENSEES" 1
l l
Enclosed for your consideration are draft recomendations supported by a draft
- office review concerning whether and how to continue with an ongoing rulemaking sponsored by RES for which your office is identified as the user office. ,,
This memorandum constitutes my concurrence in the enclosed draft recomenda-tions. I plan to dispatch this memorandum with the enclosed draft recomenda-tions to the Director, RES, two weeks from the above date.
Please acknowledge receipt by returning this memorandum with or without com-ments on the draft recomendations as indicated below.
Under present EDO guidelines, the ED0 will not consider or transmit to the Comission any rulemaking which has not been subjected to an independent staff review to determine whether the rulemaking action should proceed. Therefore, once I have your agreement that the rulemaking should proceed, I plan to expedite dispatch of the enclosed memorandum to the EDO to avoid any unnecessary delay in processing of the rulemaking pa kage now in preparation.
l t O V rank P. Gillesp e, Director Division of Ris Analysis and Operations Office of Nuclear Regulatory Research
Enclosures:
- 1. Supporting Statements -
- 2. Draft Proposed Rule
- 3. Draft Regulatory Analysis
- . _ . . . - - . .-_ = . =. : = - a n _ __ _ _
T~~- fn& Os,.s.
g_ DEC 181984
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EMERGENCY PREPAREDNESS FOR FUEL CYCLE AND OTHER RADI0 ACTIVE MATERIAL LICENSEES Receipt acknowledged. No Comment.
/
Receipt acknowledged. Coninents follow.
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D f
Richard E. Cunningham, Director Division of Fuel Cycle & Material Safety Office of Nuclear Material Safety & Safeguards l
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NRC Form 8-C (4-79)
NRCM 0240 COVER SHEET FOR CORRESPONDENCE Use this Cover Sheet to Protect Originals of Multi-Page Correspondence.
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