ML23156A080
| ML23156A080 | |
| Person / Time | |
|---|---|
| Issue date: | 04/01/1970 |
| From: | NRC/SECY |
| To: | |
| References | |
| PR-020, PR-050, 35FR05414 | |
| Download: ML23156A080 (1) | |
Text
{{#Wiki_filter:ADAMS Template: SECY-067 DOCUMENT DATE: 04/01/1970 TITLE: PR-020,050 - 35FR05414 - CONTROL OF RELEASES OF RADIOACTIVITY TO THE ENVIRONMENT CASE
REFERENCE:
PR-020,050 35FR05414 KEYWORD: RULEMAKING COMMENTS Document Sensitivity: Non-sensitive - SUNSI Review Complete I I :, I
STATUS OF RULEMAKING PROPOSED RULE: PR-020 1 050 RULE NAME: CON'l'ROL OF RELEASES OF RADIOACTIVITY TO THE ENVIRONMENT PROPOSED RULE FED REG CITE: 35FR05414 PROPOSED RULE PUBLICATION DATE: 04/01/70 NUMBER OF COMMENTS: 87 ORIGINAL DATE FOR COMMENTS: I I EXTENSION DATE: I I FINAL RULE FED. REG. CITE: 35FR18385 FINAL RULE PUBLICATION DATE: 12/03/70 NOTES ON VOLUME 1 (3/19/71 - 4/19/71). STATUS OF RULE TO FIND THE STAFF CONTACT OR VIEW THE RULEMAKING HISTORY PRESS PAGE DOWN KEY HISTORY OF THE RULE PART AFFECTED: PR-020 1 050 RULE TITLE: CONTROL OF RELEASES OF RADIOACTIVITY TO THE ENVIRONMENT PROPOSED RULE PROPOSED RULE DATE PROPOSED RULE SECY PAPER: SRM DATE: I I SIGNED BY SECRETARY: 03/07/70 FINAL RULE FINAL RULE DATE FINAL RULE SECY PAPER: SRM DATE: I I SIGNED BY SECRETARY: 11/27/70 STAFF CONTACTS ON THE RULE CONTACTl: MAIL STOP: PHONE: CONTACT2: MAIL STOP: PHONE:
DOCKET NO. PR-020,050 (35FR05414) In the Matter of CONTROL OF RELEASES OF RADIOACTIVITY TO .THE ENVIRONMENT DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 11/27 /70 11/27/70 FINAL RULE PUBLISHED AT 35 FR 18385 ON 11/27/70. 03/19/71 03/09/71 COMMENT OF SOUTHERN CALIFORNIA EDISON COMPANY (J. B. MOORE) ( 1) 03/26/71 03/22/71 COMMENT OF STATE OF NEW YORK ATOMIC ENERGY COUNCIL (MOYLAN) ( 2) 04/05/71 04/01/71 COMMENT OF GULF GENERAL ATOMIC COMPANY (0 RORKE) ( 1 3) 04/05/71 03/26/71 COMMENT OF BABCOCK & WILSON JMAXMILLAN) ( 4) 04/07/71 04/05/71 COMMENT OF AMERICAN ELECTRIC POWER SERVICE CORP (HUNTER) ( 5) 04/07/71 03/22/71 COMMENT OF VIRGINIA ELECTRIC AND POWER COMPANY (RAGONE) ( 6) 04/07/71 04/05/71 COMMENT OF COMMONWEALTH EDISON COMPANY (STIEDE) ( 7) 04/19/71 04/13/71 COMMENT OF WESTINGHOUSE (RENGEL) ( 8)
7 ;.'()CJ\ET NO
- PR 20, 50 55 F'{:._5 41 L{
TIOCIIBT FILE DIJVENTORY In t11e Matter of': ! control of Releases of Radioactivity I i Date Docket Entries Volume 1 -------*, i 4/6/70 PR ~ 3 7 -;o Pl ~ L 1 7D Copies of let ers fDm. DRL to Mr. Bauser (JC.AE) dtd 3/23/70
----J copy of letter from Mr. Price to University of Wisconsin dtd 3/26 70 1
copy of memo to agreement states dtd 3/26/70 tmtg copies of proposed amendment . copy of .ltr 3/26/70 from Mr. Johnson to Governor ofMinnesota dtd
. 3/26/70 tmtg copy of proposed FR notice.
copy of ltr from Acting Chairman Johnson to National Academy of Sciences qtd 3/26/$0 tmtg copy. of _proposed amendments copy of ltr Mr. Price to FRC dtd ~/26/70 1tmtg copy of proposed amendments "---*
- copy of ltr from *Eber Price to Wisconsin Department of Health and Social Services*dtd 3/26/CpO tmtg copy of proposed
- amendments with attached list of other recepients copy of ltr from Acting Chairman -Johnson dtd 3/26/70 to Secretary .of HEW Finch tmtg copy of proposed amendments copy of ltr from Mr. Price to Senator Gravel et al dtd 3/26/70 tmtg copy of proposed amendments
- copy of ltr from Mr. Price to Allied Chemical dtd 3/26/70 tmtg copy of proposed amendments 4/6/70 Ltr frm. John C** Doyle, Secretary, to Attorney Gneral of Illinois dtd 3/30/70 re transmittal of material for forwarding I 1
to various interested persons l 4/8/70 Ltr from H. Ellis Simmons, Director, State of Nebraska, dtd 3/31/io V supporting amendments I Ltr from Robert R. Garvey, Jr., Exec. Secy; Advisory Council on Historic Preservation_ dtd 4/3/70
- commenting on proposed
- amendments Ltr frm J. N. Stannard, President, Health Physics Society, dtd
! 4/6/70 - cornment I
j .j 4/22/70 , Ltr frm 0RNL dtd 4/17/70 - comment and criticism of public relatipns I program (NOT IN FDR) I 4/23/70 Ltr frm J. Steward eorbett, Health Physicist dtd 4/20/70 - comment 4/2-3/70 Ltr frm Lawrence Ruby, Prof. of Nuc. Engipeerint dtd l+/'20/70 - comment
* .-_*.. * ***;*_-~*... *.'*. ':- *:* -:/*' \ .' i'..:..t~-;-.'"4~*~**~:. T ~-*-.* ~;v,- ,.:.\.* ':.:*~....i~* --.*<., .. ,.-..;;'.fr~>~* ...:."'~-:-.,;,: ** , * *,. , * -* * * * :*.. **
- T:IOGJillT NO
- PR 20 and 50 In the Matter of': Control of Releases of Radioactivity Date Docket Entries Volume 1 (continued)
List of comments receiv~d on proposed amendments from Marge. / 4/28/70 Ltr from Unjversity of Pittsburgh dtd 4/2-0/70 - comment 5/1/70 Letter f'rom Holmes & Narver, Inc. dtd 4/29/70 - connnent 5/6/70 Ltr from Portland General Electric Coo, dtd 4/29/70 - comment I I 5/6/70 Ltr frm HEW, PHS, dtd 4/30/70 - comment . i 5/6/70 Ltr drm Dept. of Water & Power of Los Angeles dtd 4/17/70 l
-comm.en!
5/6/70 Ltr frm .Ameri.can Nuclear Society dtd 4/16/70 - comment ! i 5/6/70 Ltr from Lulejian & Associates, Inc.. dtd 4/16/70 - comment I 5/6/70 Ltr frm Dept. of Public Health, State of Calif, dtd 4/13/70 -comment I 5/6/70 Ltr frm U.s. Confernce of Mayors dtd 4/10/70 - comment-* I J /6/70 Ltr frm Western Interstate Nuclear Board dtd 4/8/70 - c~ent 5/6/70 ~tr frm FederaJ_ Power Commission,~ i.mdated, comment 5/6/70 Ltr frm Battelle Northwest dtd 4/1/70 - comment 5/6/70 Ltr f'rm Florida P~wer & Light dtd 4/9/70 - coxmnent 5/6/70 Ltr from Sport Fishing Institute dtd 5/4/70 - comment 5/6/70 . Ltr frm State of Minnesota dtd 4/15/70 - comment* 5/7/70 Ltr frm VEPCO dtd 5/5/70 - comment
- 5/7/70 Ltr from Depto of Commerce dtd b 5/4/70 - comment 5/11/70 !tr from Western Interstate Nuclear Board dtd 5/5/70 - commenmt 5/11/70 Ltr frm. G.E. Co, San Jose,. Califo, dtd 5/4/70 - comment 5/14/70 Ltr fron.Margaret Weede dtd 5/10/70 - comment 5/15/70 :t.tr froni Office of Vice President (Robert P. Janes) dtd 4/9/70 comment
DOCF.ET l\TO
- 20 & 50
- r)l)CIIBT FILE TIITVENTORY
--------1 In tl1e Matter of': Control o:f Releases of Radioactivy I t-----:-----~-~-----,--~----------1I Date Docket Entries . llolume 1 (cont 1d) 5/15/70 Ltr Price to Mr., Janes; Office of Vice President.,_ dtd 5/ll/70 re tmtl of copies of pr~sed rule 5/18/70 Ltr frm Sargent & Lundy dtd 5/12/70 - comment 5/ro/70 Ltr from Fran~ine Achbas dtd 5/3/70 - comment 5/22/70 Ltr from American Electric Power Service Corporation dtd 5/18/70 comm.ant 5/25/70 Ltr f'rm John s. Coleman, Nat 'l Academy of Sciences, dtd 5/13/fiim 1970, - ColID'.llent 5/25/70 Ltr :from EB.ASCO Services Inc., dtd 5/20/70 - comm.ent 5/26/70 Ltr Price to u. s. Conference of' Mayors dtd 5/25/70 aclm'g comment
- 5/26/70 Ltr Price to General Electric Co., dtd 5/25/70 ack'ng comment 5/26/70 Ltr Nuclear Fuel Services, Inc. dtd 5/21/70 - comment 5/26/70 Omaha Public Power District dtd 5/19/70 - comm.ent 5/26/70 State of Michigan Dept. of Public Health dtd 5/6/70 - comment 5/27/70 Price to Gibbs & Hill, Inc. ackn 'g cannnent 5/27/70 Gibbs & Hill, Inc. dtd 5/ll/70 - comment 5/27/70 David Schurman A!A Architect - dtd 5/19/70 - comment t5/27/70 Stone & Webster dtd 5/21/70 - comment 5/27/70 NIB Corporation dtd 5/22/70 - comment 6/1/70 Ltr from Atomic Industrial Forum, Inc., dtd 5/28/70 - comment 6/1/70 TWX frm Lincoln County Cultur~l Historical Association, Inc.,
(Margurtiye Rafter, Director) - comment *
- OCFET NO. 20 & 50
.---********----------------------*------*---*-**-----***1 I l In tl1e r-I-3.tter 0:£': Control of Releases of Radioactivity ! i
----1I Date Dod:.et Entries Volume 1 (continued)
I
-----*- *--*---- iI I
f6/1/70 Ltr from Combustion Enginering, Inc., dtd 5/25/70 - connnent Ii i 6/1/70 Ltr from Health Physics Society dtd 5/28/70 - comment I 6/1/70 Ltr frm Duke Power Company - dtd 5/26/70 - comment 6/1/70 Public Service Company of Hew Hampshire (Priest), dtd 5/27/70 connnent 6/1/70 University of California, Berkeley, frm Pigford) dtd 5/27/70 connnent NOT FDR - from consultant) 6/'2/70 Ltr from Pacific Gas and Electric* Company dtd 5/28/70 - connnent 6/2/70 Ltr frm Citizens for Environmental Improvement dtd 5/26/70 - comment 6/2/70 Ltr from Mrs. Nannie Dale Glidden dtd 5/27/70 - comment 6/2/70 Ltr from Frederick Rhoades for the Environmental Offensive, ' dtd 5/28/70 - c01IUI1ent i 1 6/2/70 Ltr fromHEW, Environmental Health Service, dtd 5/26/70 - comm.ent 6/2/70 Ltr frm American Public Power Association dtd 5/25/70 - comment i l 6/2/70 Ltr from Price to American Public power* Association ackng comment: i 6/2/70 Ltr from Price to congressman Donald M. Fraser dtd 6/2/70 - ackng, comment and providing information 6/2/70 Ltr from Fraser to Price dtd 4/14/~o - comment and asking question~ i 6/2/70 Ltr frm Duquesne Light (Willaam A. Conwell) dtd 5/28/70 - commentj 6/2/70 Ltr from Yankee Atomic Electric Company dtd 5/26/70 - comment 6/3/70 Ltr from General Dynamics dtd 5/28/70 - comment 6/3/70 Ltr from Dept. of Interior, Geological Survey, dtd 5/28/70 - connnent *-------*-*******-- l.
**------------***--*--. -** ***1 I
In tl1e :Matter 0 f: Control of Releases of Radioactivity i
-----i !
Date Dod:et :;:sntries l Volume 1 (cont'd) I Ltr from Dept of Interiof, Fed. Water Pollution Control Admin., dtd 5/29/70 - connnent
TJ0CFET NO
- 20 & 50 Control of Releases of Radioactivity
. Date l I Docl1:et Entries Volume 2 i ! 6/4/70 I 7 Letter from Southern California Edison Company (Moore) dtd 5/12/79 comment I I 6/4/70 Letter from Bechtel Corporation (Bo'WI!lan) dtd 5/21/70 - comment ! 6/4/70 Letter from Nebraska Public Power District dtd 5/20/70 (Reder) comment j 6/4/70 Letter from Niagara Mohawk Power Corporation dtd 5/19/70 (Pratt) connnent
- 6/4/70 Letter from N.Yo State Electric~ Gas Corporation (Tuttle) dtd 4/6/70 - comment 6/4/70 Letter from Westinghouse (Rengel) dtd 5/28/70 - connnent 6/5/70 Ltr from Mr. William H. Soule dtd 5/29/70 - connnent 6/5/70 Ltr from Consolidated Ed. Co. of N.Y. (Cahill) dtd 6/1/70 - connnent' 6/5/70 Ltr from Lois M. Thurston undated - comment 6/5/70 Ltr frm National Science Foundated (McElroy) dtd 4/21/70 comment 6/5/70 Ltr from u.s. Department of Interi~, Fish and Wildlife Service (Meacham) dtd 5/25/70 - comment 6/5/70 . Ltr from u.s. Dept. of.Interioj,, Fed. Water Pollution Control Admin (Dominick) dtd 5/29/70 - comment 6/9/70 Ltr from Carolina Power & Light Co. dtd 5/29/70 (Colby) - comment:
1 6/n/70 Ltr from Mrs. J. Raymond Dyer dtd 5/27/70 - comment 6/12/70 Ltr :from Dr. Seaborg to Eberline dated 5/2/70 re April 8 ltr
- from Eberline referred to Mr. Price with incoming letter from Eberline 6/16/70 Letter from Stuart and Chouteau Chapin dated May 27, 1970 -
_:_ comment
,)OCKET NO
- PR 20, 50
!'OCK.F.~: FILE TIITVEJIITORY
------------------------'---'-~~ ~so__ ~(o c::_-: . 0 () =* lu J n '.o iJ;.~J I:n tl1e r-Iatter of: Control of Releases of Radioactivity 1 Date Docket. Entries Volume 2 (~ontinued) l 6/16/70 Ltr from State of Washington Dept. of Health (Mr. Lane) dtd 6/12/70 - comment
- 7/10/70 Ltr from Chairman Seaborg to (Senator Edward Kennedy dtd 7/ 2/70 regarding Mfcy' 19 ltr from Mr. David Schurman, tm.tg copy of letter from Commissioner Ramey dtd 4/t/70 to Schurman and other attachments ~
7/10/70 I.etter from Chairman Seaborg to Speaker McCormack dtd 7/2/70 regarding correspondence with Mr. and Mrs. Schurman with incoming material, etc., 7/22/70 I.etter from Senator Randolph dtd ~/23/70 - conunent I 7/22/70 Letter frm Mr. Price to Senator Randolph dtd 7/+7/70 tm.tg documents on im.plementation*of NEPA and Notice of Proposed I; 8/3/70 rul.e making Letter from Mr. Price to Senator Edward W. Brooke dtd 7/29/70 II regarding letter from Mr. and Mrs. David Schurman (with i attachments
'i 12/16/70 Ltr from Louisiana Board of Nuclear Enegy dtd 12/14/70 (Parker) comment 12/24/70 Ltr from Dept. of Water and Power, City of L.A., (Goss) dtd 12/14/70 - comment _
12/24/70 Ltr from Northern States Power (Ewald) dtd 12/21/70 - comment* 1/25/71 Ltr :from Russell z. Baron dtd 1/21/71, - Motion and connn.ent 2/8/71 Comment from Kross-Reference Laboratories (Kross} dtd 2/3/71 2/12/71. Comment from Consumers Powr Co. (Youngdahl) dtd 2/5/71 2/22/71 Comment from Univ. of Minnesota (Abrahamson) dtd 2/17/71 i p,'n at 4< l,d-e, 8. 6 F 12- IB 335
' cl*td. 11 /;J.7 /70
-p Uk>. J 'J-/3)_-'--7D_----*-------**--
e ATCMIC ENERGY COMMISSION (10 CFR PARTS 20 AND 50) ** STANDARDS FOR PROTECTION AGAINST RADIATION LICENSING OF PRODUCTION AND UTILIZATION FACILITIES Control of Releases of Radioa ctivit y to the Environment STATEMENT OF CONSIDER~TIONS The Atomic Energy Commission* has under consideration amendments to its regulation, 10 CFR Part 20, "Standards for Protection Against Radiation", to improve the framework for assuring that reasonable efforts are made by all Commission licensees to continue to keep ex-posures to radiation and releases of ~adioactivity in effluents as low as pract:1.cable and amendments t.o 10 CFR Part SO, 11 Licensing of Production and Utilization Facilities", to specify design and operat-ing requirements to minimize quantities of radioactivity released in gaseous and liquid effluents from light water cooled nuclear power reactors. The proposed amendments to Part SO would be applicable only to light water cooled nuclear power reactors as discussed below. Basis for AEC Standards Releases of radioactive materials in effluents by Commission licensees are currently regulated under the provisions of 10 CFR S 20.106 which apply to all uses of byproduct, source, and special nuclear material licensed by the Commis~ion. These provisions are based on radiation protection guides recommended by the Federal Radia-tion Council (FRC) and approved by tre President. The Commission main-tains close consultation, and will continue to cons ult, with the FRC, the National Council on Radiation Protection and Measurements, and che International Commis sion on Radiological Protection .
Since 1959 official guidance for control of exposures to radia-tion has been provided to Federal agencies through recommendations of the FRC, approved by the President. The FRC was established in 1959 by Executiv~ Order and by an amendment to the Atomic Energy Act of 1954 (42 use 202l(h)). The FRC is directed to advise the President"*** with respect to radiation matters, directly or in- .directly affecting health, including guidance for all Federal agen-cies in the formulation of radiation standards and in the establish-ment and execution of programs of cooperation with States". The basic recommendations of the FRC are generally consistent with those of the National Council on Radiation Protection and Measurements (NCRP) and the International Commission on Radiological Protection (ICRP). The FRC recommendations include a radiation protection guide for the genetic exposure of the entire population at a level not quite twice the average natural background radiation level and for a whole body exposure of individuals in the population at a level about five times the average natural background radiation. The guides are set well below the level at which detectable biological effects from exposure to radiation are expected to occur. The FRC states in Report No. 1 dated May 13, 1960, that the guides give appropriate consideration to the requirements of health protection and the bene-ficial uses of radiation and atomic energy. Guidance on Low Radiat i on Dose s The FRC added to the numerical guidance on maximum limits the
further guidance that "every effort should be made to encourage the maintenance of radiation doses as far below this guide as practicable". Similar statements are also included in NCRP and ICRP recommendations. The Commission has always subscribed to the general principle that, within radiation protection guides, radiation exposure*s to the public should be kept as low as practicable. This general principle has been a central one in the field of radiation protection for many years. Current revi~s of reactor licensing applications include reviews of provisions to limit *and control radioactive effluents from the plants. Experience has shown that licensees have generally kept exposures to radiation and releases of radioactivity in effluents to levels well below the Part 20 limits. Specifically, experience with licensed light water cooled nuclear power reactors to date shows that radio-activity in water and air effluents has been kept at low levels - for the most part less than a few percent of the limits specified in 10 CFR Part 20. Resultant exposures to the public living in the immediate vicinity of operating power reactors have usually been small fractions of FRC . guides. The Commission believes that, in general, the releases of radioactivity in effluents from the light water cooled power reactors now in operation have been within ranges that may be considered "as low as practicable." The Commission ~lso beli~ves that, as a result of advances in reactor technology, further reduction of those releases
can be achieved. The results to date are attributable, in part, to steps to assure the integrity of the nuclear fuel, to the design of waste treatment systems to control and contain radioactivity, and to procedures and methods to limit releases of radioactive material to unrestricted areas in effluent water and air. The AEC's total regulatory program includes not only the standards and limits in 10 CFR Part 20, but other regulations as well, various restrictions on plant design, and restrictions on operation included in individual operating licenses. In connection with the proposed amendments set out below and in the light of progress in fuel element technology and in waste treat-ment and handling systems, the Commission plans to consult with the nuclear power industry, persons engaged in applicable research and development programs, and other competent groups to determine the feasibility of developing more definite criteria for design objec-tives and means for keeping releases of radioactivity in effluents from light water cooled power reactors during normal operations, in-cluding expected operational occurrences, "as low as practicable". Control of Exposures from Several Different Sources The Commission expects that releases of radioactive material in effluents from light water cooled nuclear power reactors under the present system of regulation will continue to be low. At the same
- time, the Commission recognizes that there will be a marked increase in the number and size of nuclear power reactors in operation in the future, and that other activities that contribute radiation exposure to the public can be expected to increase.
Design Objectives for Light Water Cooled Power Reactors The proposed amendments to Part 50 set out below are intended to give appropriate regulatory effect, with respect to radioactivity in effluents from light water cooled power reactors, to the guidance of the FRC that radiation doses should be kept as far below the radia-tion protection guides as practicable. As in the past, an applica-tion for a permit to construct a light water cooled power reactor would be required to include a description of equipment to be installed to maintain control over radioactive materials in effluents during normal reactor operations, including expected operational occurrences. In addition, in the case of an application filed on or after the effec-tive date of the proposed amendments, the application would be required to identify the design objectives, and the means to be employed, for keeping levels of radioactive material released in effluents as low as practicable. As in current practice the Commission would review the proposed design of the reactor, including the waste treatment equipment and the description of procedures for the maintenance and use of the equipment, to determine whether the required design objec-tives are met. Each license authorizing operation of a light water cooled power
6 reactor would include technical specifications which would require adherence to operating procedures for control of effluents and the maintenance and use of equipment installed in the waste treatment system, and the submission of semi-annual reports containing informa-tion on quantities of radioactive material released. If quantities released during the reporting period are unusual for normal reactor operations, including expected operational occurrences, the licensee would be required to cover this specifically in its report. The effluent release data submitted by licensees would be compiled by the Commission and made available to the public. The Commission would review in its inspection and enforcement program the effective-ness of the maintenance and operating procedures used by licensees in meeting the objective of reducing, to the extent practicable, the quantities of radioactivity released in air and water effluents. On the basis of existing technology and past operating experience the Commission expects that 'light water cooled power reactor waste treatment systems designed and operated in accordance with the require-ments set forth in the proposed amendments to Part 50 will help to
\
assure that releases from light water cooled nuclear power reactors will generally not exceed a few percent of the annual maximum limits specified in Part 20 and in license conditions, and that radiation exposures to the public resulting from the normal operations of light water cooled power reactors will not exceed small fr actions of expo&ures from na tural background radiation and of FRC radiation pr otection guides .
- l
*
- Need for Flexibility of Operation It is necessary that light water cooled power reactors designed for generation of electricity have a very high degree of reliability.
Operating flexibility is necessary to take into account some varia-tion in the small quantities of radioactivity, as a result of expected operational occurrences, which may temporarily result in levels of radioactive effluents in excess of the low levels normally released, but still within the maximum limits specified in Part 20. Monitoring The Commission will continue to evaluate exposures to the public from releases of radioactivity in effluents from nuclear power reactors. Reactor licensees are presently required to carry out monitoring pro-grams des~gned not only to determine levels of radioact_jvity in efflu-ents released from the plant but also to detect significant increases in levels of radioactivity in th~ environment. The licensee is re-quired to report these data to the Commission on a periodic basis. In addition, the Corrmission, the U.S. Public Health Service and several States carry out independent environmental surveillance programs. These programs are designed to detect and evaluate increases in en-vironmental levels that may be s~gnificant to human exposure. Research and Development The Commission and the nuclear power industry have for many years carried out research and development programs in the development of
waste treatment and handling systems for limiting radioactive mate-rial in effluent air and water. The Commission will continue to encourage and support research and development programs which con-tribute to the ability of the nuclear power industry to minimize re-leases of radioactivity to the environment. Pursuant to the Atomic Energy Act of 1954, as amended, and section 553 of title 5 of the United States Code, notice is hereby given that adoption of the following .amendments to 10 CFR Parts 20 and 50 is contemplated. All interested persons who desire to submit written comments or suggestions for consideration in connection with the proposed amendments should send them to the Secretary, U.S. Atomic Energy Commis*sion, Washington, D. C. 20545, Attention: Chief, Public Proceedings Branch, within 60 days after publication of this notice in the FEDERAL REGISTER. Comments and suggestions received after that period will be considered if it is practicable to do so, but assurance of consideration cannot be given except as to comments filed within the period specified. Copies of comments received may be examined in the Commission's Public Document Room at 1717 H Street, N.W., Washington, D. c.
- 1. A new paragr'aph (c) is added to § 20.1 of 10 CFR Part 20 to read as follows:
5 20.l Purpose (c) In accordance with recommendations of the Federal Radia-tion Council, approved by the President, persons engaged in activities under licenses issued by the Atomic Energy _Co!Xlmission pursuant to the Atomic Energy Act of 1954, as amended, should, in addition to comply-1 ing with the requirements set forth in this part, make every reason-able effort to maintain radiation exposures and releases of radio-active materials in effluents to unrestricted areas as far below the limits specified in this part as practicable.
- 2. A new 5 50.34a is added to 10 CFR Part 50 to read as follows:
I 50.34a Design objectives for equipment to control releases of radioactive material in effluents - light water cooled
,29wer reactors.
(a) An application for a permit to construct a light water cooled power reactor shall include a description of the equipment to be in-stalled to maintain control over radioactive materials in gaseous and liquid effluents produced during normal reactor operations, including expected operational occurrences. In the case of an application filed on or after ___________ ,* the application shall also identify the design objectives, and the means to be employed, for keeping levels of radioactive material in effluents to unrestricted areas as low as practicable. 'lcEffective date of this amendment.
(b) Each application for a permit to construct a light water cooled power reactor shall include: (1) a description of the equipment to be installed pursuant to paragraph (a) of this section; (2) an estimate of: (i) curie quantities of
- radionuclides expected to be released annually to unrestricted areas in liquid effluents produced during normal reactor operations; and (ii) curie quantities of radioactive noble gases, halides and particulates expected to be released annually to unrestricted areas in gaseous effluents produced during normal reactor operatidns; (3) a description of the provisions for packaging, storage, and shipment offsite of solid waste containing radioactive mate-rials resulting from treatment of gaseous and liquid effluents and from other sources.
(c) Each application for a license to operate a light water cooled power reactor shall include a description of procedures for the control of gaseous and liquid effluents and for the maintenance and use of equipment installed in radioactive waste systems pursuant to para* graph (a) of this section.
- 3. A new§ 50.36a is added to 10 CFR Part 50 to read as follows:
§ 50.36a ' Technica l specifications on effluents from light wa ter cooled power reactor s.
(a) In order to keep releases of radioactive material to unre-stricted areas during normal reactor operations, including expected operational occurrences, as low as practicable, each license authoriz-ing operation of a light water cooled power reactor will include technical specifications that, in addition to requiring compliance ~ith applicable provisions of§ 20.106 of this chapter, require: (1) that operating procedures developed pursuant to
§ 50.34a(c) for the control of effluents be established and followed and that equipment installed in the radioactive waste system, pursuant to§ 50.34a(a), be maintained and used.
(2) the submission of a report to the Commission within 30 days after January 1 and July l of each year specifying total quantities of radioactive material released to unrestricted areas in liquid and gaseous effluents during the previous six months of operation and such other information on releases as may be required to estimate exposures to the public resulting . from effluent releases. If quantities of radioactive materials released during the reporting period are unusual for normal reactor operations, including expected operational occurrences, the report shall cover this specifically. On the basis of such reports and any additional information the Commission may obtain from the licensee or others. the Commission may from time to
time require the licensee to take such action as the Commis-sion deems appropriate. (b) In establishing and implementing the operating procedures described in paragraph (a) of this section, the licensee shall be guided by the following considerations. Experience with the design, construction and operation of light water cooled power reactors indicates that compliance with the techni-cal specifications described in this section wilJ keep releases of radioactive material in effluents at small fractions of the limits specified in g 20.106 of this chapter and in the operating license. At the same time, the licensee is permitted the flexibility of opera-tion, compatible with considerations of health and safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such small fractions, but still within the limits specified in§ 20.106 of this chapter and the operating licens e. It is expected that in using this operational flexibility under unusual operating conditions, the licensee will exert his best efforts to keep levels of radioactive material in effluents as low as practicable. (Sec. 161, 68 Stat. 948; 42 u.s.c. 2201) Dated at Germantow, Md. this 27th day of March , 1970. For the Atomic Ener gy Commission F. T. Robbs Acting Sec~ et ary
A eROP.OSfD R J.---- ~O
., . ~,.,,C UNITED STATES - \
DEPARTMENT OF THE INTERIOR FEDERAL WATER POLLUTION CONTROL ADMINISTRATION WASHINGTON, D .C . 20242. oocn1ED USllEC AY 2 9 1970 JUN 31970~ omce e1 t11e sevetUJ PUbllC l'tUC~dtngl Bl'lllt"
~
Dear Mr. McCool:
Pursuant to the Notice of Proposed Rule Making pertaining to proposed amendm.ents to 10 CFR 20 and 10 CFR 50 as published in the Federal Register, Volume 35, Number 63, we have the following comments. The proposed amendm.ents are designed to encourage AEC licensees to maintain releases of radioactive materials into the environment as low as possible and to further encourage the iinplementation of this objective in the design of light water cooled power reactors. We recognize that these amendm.ents will strengthen the existing regulations of the Com-mission, but we believe that they stop short of what can and should be done to achieve maximum protection of the environment. We note that the waste treatment and control technology presently practiced by the nuclear power industry is achieving radiological re-leases on the order of a few percent of those allowed by 10 CFR 20. We compliment the Commission for the substantial role it has played through reactor design review and other means in making for this accom-plishrn.ent. We further note that the guidance of the Federal Radiation Council states: 11 There can be no single permissible or acceptable level of exposure without regard to the reason for permitting the ex-posure. It should be general practice to reduce exposure to radiation, and positive effort should be carried out to fulfill the sense of this recommendation. It is basic that exposure to radiation should result from a real determination of its necessity. Finally, we point to purpose and policy of the National Environmental Policy Act of 1969 to provide Federal leadership in protecting and enhancing the quality of the Nation's environment. On the basis of these factors we believe there is ample justification and even a mandate to prescribe specific quantitative limits to achieve the
------~-----.
ok)l .. a' , *~ .
.y _Dr~ 1 L-g.J).!l&!:S-,
2 minimization of radioactive releases propounded by the proposed regulations. Accordingly, we do not concur in the proposed amend-ments and recommend that the Commission take a more definitive and positive approach by prescribing for light water cooled power reactors, at least, more restrictive release limits than now pro-vided by 1 0 CFR 50. More specifically, we recommend that specific limits on radioactive releases from nuclear power plants be established in terms of quantities of radioactive material (not concentrations) per unit time per megawatt of installed capacity; these limits being based on the best available waste treatment and control technology. We believe that such an approach would be positive and well received by the public as demonstrating the Commis sion 1 s determined purpose to minimize environmental impacts. Such an approach would further provide for definite and ready enforcement of violations, eliminating the problems of lengthy and potentially unresolvable interpretations of whether minimization of releases is, in fact, being achieved. In short, we believe that any meaningful and effective regulation of effluent quality, including radiological quality, can best be accomplished with specific, numerical effluent criteria. We note that the Commission has tended to avoid more restrictive release limits than incorporated in 10 CFR 20 in order to permit operational flexibility. It is recognized that there are those occa-sional incidents where operating or equipment malfunctions result in higher than normal releases (but still within the 10 CFR 20 limits) which are not readily or conveniently corrected for several days, weeks or months without jeopardizing operation schedules. We believe these situations should be treated by specifically granted ex-ceptions from "tight" regulations. To do otherwise would surely invite less than the best effort of the industry to achieve truely mini-mized re.leases. We further believe that the Commission should continue to lessen these situations through tighter design specifications, which is an objective of the proposed amendments to 10 CFR 5 0. The foregoing comments reflect the policy we are applying to all aspects of water quality control. We are looking to all segments of industry, as well as other sources of pollution, to provide the best practicable degree of treatment on a continuous basis. We do not
., . ) 3 believe that sources of radioactive wastes should be treated any differently, and we call on the Commission to adopt definitive and stringent regulation amendments to this end. We appreciate t h is opportunity to comment. Sincerely yours, Conunis sioner Mr. W . B. McCool Secretary U.S. Atomic Energy Commission Washington, D. C . 20545 Attachment
UNITED STATES DEPARTMENT OF THE INTERIOR GEOLOGICAL SURVEY WASHINGTON , O . C . 20242 MAY 2 1970 Mr. Harold Price Director of Regulation U.S . Atomic Energy Connnission 7920 Norfolk Avenue Bethesda, Maryland 20545
Dear Mr. Price:
Transmitted herewith are our comments on the proposed amendments published in the Federal Register on April 1, 1970. We appreciate your invitation of our comments . Sincerely yours,
~ r ~oo.,p.,.)_ _ _
Actingoirector Enclosure OCHTEO U&l£C UN 31970 Office of 111, seera1117 Publlc l'rvc,edfap Brar~
DOCl<.fT [>iUM BER PR eRQP.OSUl BUI. - ,. 0 I 5 0
~
Comments on the amendments proposed by AEC on April 1, 1970 to 10 CFR 20 and 50 concerning the control of releases of radioactivity to the environment particularly by light water cooled nuclear power reactors. The U.S. Geological Survey is in full accord with the recommendation set forth in the new para. 20.l(c) that licensee should make every reasonable effort to keep radioactive effluents released in unrestricted areas as far below the specified limits as possible. We are also in full accord with the provision of the new para. 50.36a(2) that "total quantities" of radioactive materials in effluents from nuclear power reactors must be reported periodically. Radioactive materials in effluents are currently restricted by concentration alone as set forth in 10 CFR 20.106, and the permissible total quantities are therefore dependent on effluent volume which is not restricted. However, the effects of the radio-active releases to the environment must also be assessed in terms of total quantities released at one location. This becomes particularly important for those nuclear power reactors which release radioactive liquids together with steam condenser cooling water. At sites where once-through cooling is used, cooling water flow rates range from several hundred to several thousand cfs (cubic feet per second) and thus permit, according to the provisions of 10 CFR 20.106, the release of large quantities of radionuclides. Some of these radionuclides can be reconcentrated in the hydrologic environment, as for example cesium-137 which can be sorbed by fluvial sediments and accumulate in the river or lake bottom near the cooling water outlet. If a nuclear reactor that discharges cooling water at a rate of several thousand cfs were to release cesium-137 at the limit set forth in 10 CFR 20.106 it appears BOCIETED QEC 31970 ..
possible that radiation hazards to the public could develop in the hydrologic environment near the discharge point. The requirement of reporting radioactive effluents in terms of total quantities is a desirable concept to be introduced by the new amendments. However, it also appears that the new amendments do not change the permissible limits as currently set forth in 10 CFR 20.106. Although large releases of cesium-137 referred to above may be highly improbable there appears to be no reason why they should be permitted by the current radiation guides. The release of radioactive material in liquid effluents to the en-vironment by nuclear power reactors should be limited by total quantity in addition to concentration, and we recommend that such limitations be taken under consideration for inclusion in the proposed amendments.
GENERAL DYNAMICS DOCKff NUMBER PR e&oP.OSto RULE * - UJ, 5o Fort Worth Division P. 0 . Box 748, Fort Worth, Texas 76101
- 817-732-4811 OCKETED OOA£~
~1 28 May 1970 WTW :mo Misc , -FW#ll-38134 31970 Office el tile SnretlllJ Public P~QII Br.men Atomic Energy Commission Washington, D. C. 20545 Subject : Proposed Regulation Change Gentlemen:
The Fort Worth division of General Dynamics respectfully submits its comments to the proposed addition to 10 CFR 20 which reads as follows:
"Sec . 20 . 1 Purpose. -
(c) In accordance with recommendations of the Federal Radiation Council, approved by the President, persons engaged in activities under licenses issued by the Atomic Energy Commission pursuant to the Atomic Energy Act of 1954, as amended, should, in addition to complying with the requirements set forth in this part, make every reasonable effort to maintain radiation exposures and releases of radioactive materials in effluents to unrestricted areas as far below the limits specified in this part as practicable . " Our corporation is concerned over man ' s impact on his env i ronment, in-cluding the artifical introductions therein of radiation and radioactive materials . We also concur in the thesis that it is desirable to minimize such artifical introductions . However, it is our opinion that the pro-posed addition is ambiguious and will fail to serve the intended purpose of this regulation change. Such language as " .** should .. make ... "; 11 . . . every reasonable effort ... 11 ;
" ** . as far below the limits .. . as practicable," is susceptable to differing interpretations and is vague and indefinite . Therefore, we doubt that the proposed addition will serve as a meaningful or useful guide to those responsible for its i mplementation.
It is our opinion that a general statement of policy such as the proposed change would be more appropriate in the "Statements of Consideration" pertinent to Part 20 . i!,r7yo;- B, a.r/lt~I ------ - Contract Administration Supervisor
ec ff/ ir.. of eg. Date i' ' ' ) Time ,* ,,,
OOC1* */ l! MKR eROlll!D RUI.E I DR--~D,5"0
~:p YANKEE ATOMIC ELECTRIC COMPANY
-=======G~)========-
20 TURNPIKE ROAD, WESTBORO, MASSACHUSETTS 01581 TELEPHONE 617 366-9011 May 26, 1970 YA-2863 DOCKEiED Mr. Harold L. Price USIAEC Director of Regulation U.S. Atomic Energy Commission JUN Washington, D. C. 20545
Dear Mr. Price :
I appreciate the opportunity extended in your letter of March 26, 1970 to comment on the proposed amendments to AN:: regulations concerning the con-trol of releases of radioactivity to the environment. We feel that the Commission's approach as described in the Statement of Considerations and as implemented in the amendments to the regulations represents a reasonable and probably the best available compromise of a difficult problem. We agree that nuclear plants should be designed and routinely operated in such a way that the releases of radioactivity to the environment are for the most part, substantially below those levels speci-fied as limits in 10CFR20. We also concur that it is quite practical to do so and are gratified that the record developed at the Yankee plant in Rowe, Massachusetts, over a period of nearly ten years of operation confirms this. We also agree completely, however, that it is essential that the industry must have a reasonable margin available between normal and routine operation and the limits beyond which it is in violation of the regulations. This margin is adequately maintained in the proposed amendments while at the same time it is more effectively defined and administered so as to increase assurance that the lowest practicable average release over the long term will actually be achieved. We anticipate, as do many others I'm sure, some difficulties in arriving at a definition, acceptable to all, as to plant equipment and procedures which will result in the lowest practicable release. These difficulties should not be and we feel will not be excessive, as long as a reasonable attitude such as that in the "Statement of Considerations" is the basic approach employed.
Rec'd Off. ir. of ~e~. Date c;;;/4 ?ZJ Time !f*L/ ~-
YA-2863 Harold L. Price ABX:: May 26, 1970 We are convinced that this is an area in which the law of diminishing returns can very easily become governing and further that the total penalty of indefinitely continuing effor ts to further reduce radioactive releases beyond a reasonable and practicable level would be much more serious than economics alone . Already some proposals have been heralded which might reduce slightly already minimal effects on the public but at the expense of significantly increased exposures to plant personnel . It is also more than probable that an indefinite escalation in attempts to unreasonably reduce releases will result in a complexity and proliferation of equipnent to the point where its true effectiveness is marginal . In summary we are convinced that radioactive releases from nuclear plants can be reasonably held to a very small fraction of the natural radio - activity to which human beings have always been exposed and that the proposed amendments to the regulations will assist in assuring that this is the case . Very truly yours, L. E. Minnick Vice President LEM/aj
~~ ~~
Duquesne Ug,t (412) 471-4300 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 May 28, 19 70 Mr. H.arold L. Price Director of Regulation U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Mr. Price:
This is in response to your letter dated March 26, 19 70 which transmitted the proposed amendments to the AEC regulations concerning the releases of radioactivity to the environment which the Commission plans to issue. The Commission's subscription to the general principle of keeping the radiation exposures to the public as low as prac-ticable is a sound objective; however, it will be difficult for both the engineer to design a radioactive waste disposal system and a plant operator to operate a nuclear plant without having more firm guidelines than those outlined in the proposed changes to 10 CFR 20 and 10 CFR 50. ecy truly yours,
~ William A. Conwell UN 2 1970 Vice President Offlc~ rtf the S~tretary F11bit'. ~r- * 'i'gs i, r~' r,1
.. . DOCKET NUMBER PR
. DONALD_..M. FRASER A fROP.U" D RUI.E -a(!) 1,'f() A FOREIGN AFFAIRS COMMITTEE 51'M b1 STR1~. MINNESOTA
. ., ~tJ. ~ ~ O ~.t(l ~ ., SU8C0MM11TEES:
Congress~~b ~tates
~ STATE DEPARTMENT ORGANIZATION 332 Hausa,: 0FFICE,:3IJILDIHG AND FOREIGN OPERATl0NS . 2Dt-225-47sl° INTERNATIONAL ORGANIZATIONS ANO MOVEMENTS DALE M ACIVER ADMINISTRATIVE ASSIS1'ANT l,oust of nepresrntatibts NATIONAL SECURITY POLICY AND SclENTtl'lC DEVELOPMENTS Rila~bfngton, 11.<d:. 20515 DISTRICT OF COLUMBI A COMMITTEE April 14, 1970 DOCKETED tJSAm Mr. Harold L. Price Director of Regulation 2 1970
- United States Atomic Energy Commission Office ef tlle Seeretay Public Proceedings Washington, D. C. 20545 Braach
Dear Mr. Price:
I am happy to comment on the proposed amendments to the AEC regulations concerning the control of releases of radioactivity to the environment. The acknowledgement of concern inherent in these proposed amendments is important and entirely welcome. It seems to me, however, that we have advanced far beyond the stage when simple acknowledgements of concern will accomplish any useful purpose, as the continuing controversy over the licensing standards for the Monticello reactor in Minnesota well demonstrates. We are all pleased to hear that it is the goal of the Commission to keep radioactive emissions as low as is practicable, we are all delighted to know that this general principle has been operative for years, and we are all comforted to know that "licensees have generally kept exposures to radiation and releases of radioactivity in effluents to levels well below the Part 20 limits." The problem is one of credibility. If the Atomic Energy Commission really is making an effort to keep emissions at the lowest practicable levels, and if experience really has demonstrated that, especially in the case of light water reactors, emissions actually can be limited to a fraction of the allowable levels, then why can't the allowable levels be readily lowered? Rec'd Off Dir of Reg. vale / //, ?C
I Letter to Mr. Harold L. Price, April 14, 1970 Page Two - There would appear, on the surface, at least, to be two possible reasons for maintaining the present allowable emissions standards. Either experience hasn't demonstrated that lower levels are practicable. Or maintaining the lowest practicable levels isn't (or shouldn't be) a primary goal of the AEC. In the absence of an adequate alternative explanation, the currently proposed amendments would appear to be nothing more than a proforma ratification of the present rules and pro-cedures of the Commission. Such an elaborate endorsement of the status quo would seem to me to serve no useful purpose, and carries with it the serious danger of creating the illusion of action where none has, in fact, been taken. I oppose the proposed amendments as being misleading, without real substance and beside the point. With best wishes.
~ ** \~*~
I '
. StAN ROBINSON, SECY .. - UNITED STATES -
ATOMIC ENERGY COMMISSION WASHINGTON. D .C. 20545 DOCKET NUMBER PROPOSED RULE PR ...~~ SD
~eR ~ ~
JUN 2 1970 ~ Honorable Donald M. Fraser House of Representatives
Dear Mr. Fraser:
Thank you for your letter of Apri 1 14, 1970, comrrenting on our proposed amendrrents to Parts 20 and 50 published in the Federal Register on Ap ri 1 1 , 19 70. The numerical limits in Part 20, 11 Standards for Protection Against Radiation", are upper limits that- are designed to *provide reasonable assurance that exposures of the genera 1 p*ubl i c from i oni zing radiation from the cumulative effects of all licensed activities are
- well within the Federal Radiation Council (FRC) radiation protection guides. The Part 20 limits are based on the numerical radiation protection guides recommended by the FRC and approved by the President , for the guidance of all Federal agencies in the formulation of radiation
- standards. The FRC guidance is COIJl)atible with the recommendations of the National Council on Radiation Protection and Measurements (NCRP) and the International Commission on Radiological Protection (ICRP) and takes into account comprehens ive studies and reports on the biological effects of ionizing radiation that have been issued by the Committee on the Biologic.al Effects of Atomic Radiation of the National Academy of Sciences in the United States, the Medi cal Research Council in the United Kingdom, and by the U. N. Scientific Cammi ttee on the Effects of Atomic Radiation. Any future changes the FRC may make in their guides will, of course, be reflected in changes in Part 20.
As stated in the Notice of Proposed Rule Making, the purpose of the proposed arrendments to Part 50 is to. give appropriate regulatory effect with respect to radioactivity in effluents from light water cooled power reactors to the further guidance of the FRC that "every effort should be made to encourage the maintenance of radiation doses as far below this guide as practicable ". The FRC guidance wi ll be implemented by provisions in the proposed amendme.n ts that would require _: DOCH : C:D tJ&AEC
Honorable Donald M. Fraser (1) that available waste treatment and handling technology and equipment be incorporated in the design of light water cooled power reactors; (2) that waste treatment equipment installed in the reactor be maintained and used during operation of the reactor; and ( 3) that the licensee re port on a semi-annual basis the quantities of radioactivity released in air and liquid effluents and specifically cover in the report any unusual releases. These new requirements are much more than an endorsement of the status quo. As noted above, the present regulations establish upper l imits on levels of radioactivity that may be released in effluents. The new requirements wo uld for the first time provide a strong regulatory frame~*rnrk for assuring that radioactivity in effluent releas es is indeed maintained as low as practicable with available procedure and equipment technology. It wou ld assure further i mprovemen ts in radioactivity control as advances in technology are made. I At the same ti me, the proposed amendments provide the necessary flexibility of operation, compatib le with considerations of health and safety , to take into account unusual operating conditions, such as fuel element clad failures, that may temporarily result in levels of radioactivity somewhat higher than the design objectives, but still wel l within Part 20 limits and FRC radiation protection gui des. .
- As i ndicated i n the Statement of Considerations published with th e propose d amendments , the Commission plans to consult wi th the nucl ear powe r i ndustry and other competent groups to determine the feasibility of developing more deffoite cr iteria for design objectives and means f or keeping releases of radioactivity i n e f fl uents f r om l ight wat er cooled power reactors as low as practicable .
..l Honorable Donald M. Fraser r We believe that the implementation of the proposed amendments which assure the use of advances in waste treatment technology wi 11 be an important step in the effective con trol of radiation exposures and wi 11 help to assure that releases of radioactive material in effluents are generally small fractions of the upper limits specified in Part 20.
If you feel that it would be helpful, I would be glad to rreet with you to discuss in more detail the intent and expected effect of imp l errenting the proposed amendments . Sincerely, ( signed ) ~arold L. Price Haro 1d L. Price Director of Regulation bee: Hr . Edward J. Ba user Executi w~ Di r~ctor Joint Cammi ttce 0 ,1 Atolili c Energy Congre ss of th2 United Statas Distributi~n: HLPri ce, DR SA/GMEA LRogers , RP DBM Secretaria and Public Operational Safety Document Room (2) OGC Attn: Stan Robinson Cong. Rel. (2) HKShapar, OGC Docket Files, RPS CLHenderson, ADRA Pr_og ram Assistance Branch, RPS GErtter, DR Chairman Seaborg Commissioner Ramey Commissioner Johnson Commissioner Thompson Commi ss io ner Larson GM DGM AGM DR-2551 AG 0 GM-1 4469 EAGM AG~RD DR CON G. REL. OFFICE SURNAME HLPri ce
-- --------- ---- . **-------------~, - ---------- ......
~ATE 5- -70 I 5- - 70
JUN 2 1970
- t. Price l'SrQC~(IN) 111hn ft
. . . . . . . . .~ f -
..u. ~1b~W$ INII DOCffL,O Atha 1taaliN1IIIIOII U&AEC
....._,. efft.a, hear* 4Mutw* *aw11, an Ul11'AS UlsDD.
llll'ltdlltnek* . .., GUllllt~oa , ....... IILPrice
,,.,.,. S/ /70 I /10
OOCI{ET NUMBER
- sEo RULE PR -l.o, s;o
°r~<>f AMERICAN PUBLIC POWER ASSOCIATION 2600 VIRGINIA AVENUE NW WASHINGTON DC 20037
- 202 / 333 - 9200 OFFICERS Pll'lidtnt, JOHN M. NELSON P1esidenl**-'<<rJOHN R. KELLY Vice P1t1id*nt, DURWOOD W . HILL May 25, 1970 Tre11urer. WALTER R, WOIROL Genera/Counsel, NORTHCUTT ELY Ganer*! Man*ger, ALEX RADIN DOCKE I DIRECTORS UQAEC 8.G.ADKINS Su,,.rlntMd*nl Electric Department Mr. Harold L. Price Danville, Virginia Director of Regulation JOHN T. BUTTS Su~rlntendent Electric Plant Board U. S. Atomic Energy Commission Franklin, Kentucky Washington, D. C. 20545 R. E. CANNARD Eueutl'le D;rector Virgin l.. *nd* Water and Power Authority S< Thomn. V.I.
Dear Mr. Price:
STANLEY R. CASE Dlr.ctor of UtHlt/N Fort Collins, Colorado MARVIN CASTLEBERRY In connection with your letter of March 26, 1970, by Gen.r,/ M*n*g*r CltyUtilltles which you transmitted a copy of proposed amendments to Sp1ingti.ld, MIU<MJri COWAR D E. COBB AEC regulations concerning the control of releases of radio-G,n.,*I Manag11r Hunt1vMl1 Utilitiet activity to the environment, APPA has canvassed its members Huntsvllle, Al1b1ma MICHAEL F. COLLINS actively involved in the planning, construction, or opera-M1n11g11r Munlclpal Light Department tion of nuclear power plants, and has received comments Wakefield, M11Hchusetts J. G. CREE which may be summarized as f ollows: M,n.11., of Utiliflt,s Chambersburg. Pennaylvanl F. D. OIEHL G,n,11I M1nag1r
- 1. Some APPA members find the regulations to merely Water & Electdc Depertment McPheraon, Kana 1 "formalize present practices", although requiring more de-CLAUD R. ERICKSON G.n.nl Manager tailed reporting, and do not believe that their implementa-Board of Water and Light Lansing, Mich.gin tion would be unreasonable or create difficulties for C. C. HARGIS Manager utilities. These respondents have no objection to the Udlltloo Syatom Lafay,ett., Louiliiana regulations or find them in the public interest.
OURWOOD W. Hill G1M11/ M1mg111 Consumers Public Power District Columbus, Nebraska
- 2. A second view endorses the objective of the regu-W. G. HULBERT, Jr. lations, believes that that goal is presently being ful-At.n*11*r PUO 11 of Snohomish County Everett. W11hlngt0n filled, suggests that if the proposed amendments are OWENW. HURD adopted "in a place of quantitative limits which have IMMglng Dlrfftor Ww,ington Public Poww Supply Syatom been generally accepted we will have subjective goals KMlnewlck. WMhl"9t(>n EDGAR L KANOUSE highly conducive to controversy", and recommends no changes GeMr*I Menage, end Ch#f Engineer Deplftment of Water and Power in existing regulations.
Loa Ana-J.., Cellfornia JOHN R. KELLY Director of PubHc Wit/., GIIONvtlle, Florida 3. It was pointed out in a third assessment that the C. M. MATHEWS Menager regulations would be difficult to administer because of Greenwood Utllhlff Greenwood. Mluiulppi possible disagreements over what constitutes releases which R. A. MUENCH. Jr. Admlnl1tr*tor are "as low as practicable", and that the Commission should Public Worts Commlnlon Fayet teville, North Carolina first develop definite criteria for design objectives so JOHN M. NELSON Superlntfflfl,rtt that manufacturers and utilities would have something to Department of Lighting Suttle. Wethington measure against and the Commission could then determine LEE E, NICKELSON ChMf UtH/ti., Engineer whether the "yardstick" criteria had been met in a given City Water, Ught end Power Sprlngfleld, Illinois plant design. NORBERT D. RHINERSON M,neger Electric and Weta, Department Kau1taun1, Wltc0nlfn Sincerely, W. J. SCHLAGEL Director Electric Utility Ama, lowe PAULE. SHMD Gen,r,J Menage, c:..a~~ Sacramento Municipal Utility Dl1trlct Sacramento, CelHornle Alex Radin WALTER R. WOIRO L TTH1urer PUO #1 of Chelan County WenetchN, Wash. AR:jb
c'd Off. ~r. of.1/Re". te_ SI:; 'J -,~ e -* r ,, i t.,
DOCKET NUMBER p
- - eR0P0SE0 RULE R-W,5"t?
~./)('O~~~ ~*~ .
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 1 f\~ ' ' PUBLIC HEALTH SERVICE ENVIRONMENTAL HEALTH SERVICE ROCKVILLE, MARYLAND 20852 ENVIRONMENTAL CONTROL MAY 2 6 1970 ADMINISTRATION DOCKE f ED OOlEC Mr. Harold L. Price Director of Regulation U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Mr. Price:
This is in reference to your three letters of March 26, 1970, to officials of the Department of Health, Education, and Welfare, requesting comments on the proposed amendments to AEC regulations concerning the control of releases of radioactivity to the environ-ment and the interim reply of April 30, 1970, from Mr. Charles C. Johnson, Jr., Administrator of the Environmental Health Service. We strongly support the objectives the Commission has set forth in these proposed amendments and believe their adoption would contribute significantly toward continued protection of the public's health and safety during a period when the nuclear power industry is in an expansion stage. It is noted under "Guidance on low radiation doses" that the Commission plans to determine the feasibility of developing more definite criteria for design objectives and means for 11 keeping releases of radioactivity in effluents from light-water-cooled power reactors during normal operations, including expected operational occurrences, 'as low as practicable.'" Early action by the Commission on this is encouraged. The amendment to Part 50 by the addition of Section 50.34a should not be limited to light-water-cooled power reactors. Fuel reprocessing facilities should be included in this amendment since this type of facility may well discharge greater quantities of radioactivity to the environment than nuclear power reactors. The addition of Section 50.36a provides new requirements for technical specifications regarding utilization of radioactive waste system equipment and submission of reports to the Commission. The reporting requirement should possibly include information on the efficiency of operation of the radioactive waste treatment system. Without such information, confirmation of compliance with Section 50.36a (1) pertaining to the requirement for maintaining and using waste treat-ment equipment will be difficult. In addition, this Section does not provide specific information on the technical data that should
Page 2 - Mr. Harold L. Price be submitted in the January and July reports. We believe these reports should include, in addition to the total quantities of radioactive materials released to the unrestricted areas for periods of actual release, data on radionuclide release rates or concentra-tions, flow rates, and the length of those periods. Data for individual radionuclides comprising the major components of the gross activity also should be included. In order to fully utilize this information from a public health standpoint, it is essential that sufficient information be available upon which to make estimations of dose to the population. If it is not appropriate for this amendment to specify the details on the reporting requirements, they should be contained in the standard reporting requirements for licensed power reactors. Our Division of Environmental Radiation has had discussions with the Division of Radiation Protection Standards concerning these report-ing requirements. Our comments on the most recent draft of these reporting requirements were transmitted to the Commission by the Director, Division of Environmental Radiation, on March 6, 1970. I believe that a standard reporting procedure for licensed power reactors should receive high priority consideration as the data obtained from nuclear facility operators are used by the Bureau staff in the public health evaluation of nuclear power reactors. Sincerely yours, John C. Villforth Director Bureau of Radiological Health
THE DOCKET NUMBER PR 550 eROP.OSED RULE -W,5"0 NEW HAVE , CO * . 06520
~~ . . o ~~ PHONE 777-5317 - 777-53..,
"~~~ -,
May 28, 1970 Secretary of the Atomic Inergy Commis.ai.:an Washingtfm, D.C. 20545
Dear Mr. Secretary:
We of the New Haven Rnvironmental Offensive are concerned with all !ac~ts of ecological deterioration, particul rly that o! the urban enrlrorment. We are aware ot th present rapid increase in demands !or electric power (h&Te been active in crit-iciSll o! th local electric power utility - United Illumin ting of Connecticut - tor their large part in adding to Bew Haven's air pollution) the growth of Nuclear Power as an answer to supplying this power. We !eel there has not been enough research into the possible effects to the environment resulting from the planned exp sion into nuclear g nerated electric power. Such !actors as thermal pollution !rom cooling water, possible nuclear accidents in hea'Yil.y populated areas, radioactive leakage, and r dioactive waste removal all pose an immediate aggrevation to probl s which already exist in our cities, particularly when one considers the numbers of Nuclear Power Plants planned for construction in this country- during this decade. We would therefore like to add our support to those who suggest that in the upcoming hearings r Tiew;ing proposed amend-ments to Parts 20 and 50 of the Federal Regulations on Radioactive Effluents from light water cooled Nuclear Power Reactors, the Commission support revi s which would set radiation limits from such nuclear power plants at zero in relation to background emissions. Sincerely yours,
- f~~ .-..,i;..--r,,."-.t'.l Frederick Rhoades tor the Environmental Offensive I CKETED U&AEC UN 2 1970
DOCKET NUMBER fROP.OSEI LE PR-i1D,5"0
~ ~fkttj;!~
~l\'~~
Montsweag Road Wiscasset, Maine May 27, 1970 Secretary U. S. Atomic Energy Commission Washington, D.C.
Dear Mr. Secretary:
In regard to the regulation 10 CFR Part 20 -- as a very concerned citizen living one half mile below the Yankee Atomic Plant in Wiscasset , Maine, in the light of the fact that there is still so much controversy among scientists as to what is the safe amount of disc~arge of effluence into the water from atomic plants -- not only for ecology but for human beings~ ~urge the commission to change their "Standards of Protection" to read "no radiation permissible", instead of "as far as practicable" , as recommended by the Federal Radiation Council -- which obviously is leaning toward the interest of the industry and not the safety of the individual. We have a nasty situation on the Sheepscott River because Yankee Atomic chose a spot where the water does not have free passage and we already have pollution . What will happen when the plant is opened God only knows . Very truly yours , NDG/mwc
~le::~~
uocu ,c.n
*EC JUN 21970~
Offl* If flle S"""'7 Pullljt) PrvtredlnP uranc'l
DOCKETED ue.Et Secretary- JUN 21970~ Atomic Energy Commission *office of tile searetarJ Washington, n.c. PubllC proceedlll.P srancll e)(A
Dear Sir:
This is in reply to your invitation for public comment on the proposed amendments to regulation 10 CFR Part 20 , "Standards for Protection Against Radiation" . In view of the fact that many new nuclear power plants are now in operation any many more are being built or are in planning stages , the necessity for assuring that radiation levels in effluents of these plants remain low is of paramount importance to the increasing number of Americans who will be in areas where these plants are to be located. Since no one can be sure that the accumulation of radiation from these plants will remain at a safe level under the present regulations we would urge you to revise your standards for radiation limits from nuclear power plants to require ZERO radioactive emissions from such plants . The Member3 CITIZENS FOR ENVIRONMENTAL IMPROVEMENT 333 N. 14 St. Lincoln, Nebraska l,g50B'
*
- t 11 t
.._, ~
Law Depa~tment - PAC PACIFIC GAS AND ELECTR.IO OOM~A~V
,... - ~ ~ ,... ~
PACIFIC GAS AND ELECTRIC COMPANY
+ 245 MARKET STREET
- SAN FRANCISCO, CALIFORNIA 94106 (415) 781-4211 RICHARD H. PETERSON May 28, 1970 WILLIAM 8. KUDER WILLIAM£. JOHNS
.JOHN C. M Rf:IISSEY MALCOLM H. FURBUSH SENIOR VICE PRESIDENT CHARLES T. VAN DEUS EN JOHN A. SPROUL MALCOLM A. MACKILLOP PHILIP A, CRANE, JR.
AND GENERAL COUNSEL NOEL Ki::LLY HENRY J. LAPLANTE RICHARD A, CLARKE GILBERT L, HARRI CK FREDERICK T. SEARLS EDWARD J. MCGANNEY JOHNS. COOPl'.:R VICE PRESIDENT .JOHN 8. GIBSON GLENN WEST, JR, AND GENERAL ATTORNEY DOCKETED ARTHUR L. HILLMAN, JR, ROBERT HLBACH CHARLES W, THISSELL SANFORD M. 5KA0135 STANLEY T. SKINNER DANIELE. GIBSON U~EC J. BRADLEY 8UNNIN JACK F. FALLIN, JR. Secretary
- u. S. Atomic Energy Commission Washington, D. C. 20545 Attention: Chief, Branch Gentlemen:
This concerns the Notice of Proposed Rule Making dealing with the control of releases of radioactivity to the environment, which was published in the Federal Register on April 1, 1970 (35 F.R. 5414). Our principal concern arises from use of the term "as low as practicable" in reference to radiation releases. Although we have no quarrel with the concept as we interpret it, the term is sufficiently ambiguous to be a potential source of trouble. This arises from the fact that people may differ over the meaning of the word "practicable." Webster's (Third New International Dictionary, Unabridged, 1961) de-fines "practicable" as
" . possible to practice or perform; capable of being put into practice, done, or accomplished . "
Thus, in attempting to apply the proposed regulation a potential licen-see could conclude (i) that present practice, under which releases during normal operation run a few percent of 10 CFR 20 limits, is all that is required, or (ii) that regardless of the circumstances he must install whatever equipment and follow whatever procedures are available to re-duce releases to as near absolute zero as possible (i.e., reduce re-leases to as low an amount as is capable of being accomplished). We believe this latter interpretation is unduly restrictive. Although the language quoted below from the Statement of Considerations accom-panying the Notice of Proposed Rule Making appears to indicate that AEC believes present practice is adequate, "The Commission believes that, in general, the releases of radioactivity in effluents from the light water cooled power reactors now in operation have been within ranges '1111-11 ..,, ~ that may be considered 'as low as practicable' . " ~ - 0, ,10ied b
~
~-----.!~
-'1 Jliltd 6- ;i , ?O
Secretary U.S. Atomic Energy Commission 2 May 28, 1970 there is no guarantee that an Atomic Safety and Licensing Board or a court would so interpret the phrase in question. If anything must be said in this regard, we suggest the concept be that licensees will use their best efforts to keep radiation releases "low" or "below the limits specified in 10 CFR 20. 11 Subject to this general comment we have the following specific comments on various portions of the release:
- 1. In proposed§§ S0.34a(a) and 50.36a(a) the term "expected operational occurrences" is used. We believe this is ambiguous and at the very least some examples should be presented to clarify the meaning of the phrase.
- 2. Section S0.34a(a) requires applicants to identify "design objectives" for keeping releases "as low as practicable." It would ap-pear that the design objective would be to keep releases "as low as practicable." It is not clear what other "design objectives" there are to be specified.
- 3. In§ 50.36a(a) (2) the phrase "such other information on releases as may be required" also is ambiguous and should be clarified by specification of examples. Also the conclusion to this paragraph provides that on the basis of information received from the licensee and others 11 (who are unnamed)
" * *
- the Commission may from time to time require the licensee to take such action as the Commission deems appropriate."
The danger inherent in use of the ambiguous phrase "as low as practicable 11 is emphasized by the broad sweep of the language quoted above. To take an admittedly extreme but nonetheless plausible interpretation, the Commission under the regulation proposed could shut down a reactor if, in the Commission's opinion, the licensee's radioactive releases were not "as low as practicable" even though the licensee were not in viola-tion of 10 CFR 20. This injects a subjective element into Commission proceedings which could be most undesirable. The Statement of Considerations accompanying the Notice of Proposed Rule Making states that the Commission plans to consult with various "competent 11 groups 11
- to determine the feasibility of develop-ing more definite criteria for design objectives and means for keeping releases of radioactivity
* * * 'as low as practicable'
- 11
Secretary U.S. Atomic Energy Commission 3 May 28, 1970 We believe such consultations would be valuable, and we strongly urge that in view of the ambiguity of the regulations proposed these con-sultations be conducted before the proposed regulations are issued in final form. Respectfully submitted,
*
- DOCKET NUMBERPR
., ., fROPOSiO RULE - "JI) , !i'l)
UNIVERSITY OF CALIFOR IA, BERKELEY ~ I) .{) _ _ _ _ _ _ _ _ ,. . *, R ~ . , , BERKELEY
- DAVIS
- IBVJNE
- LOS ANGELES
- RIVERSIDE
- SAN DIEGO
- SAN FRANCISCO . ,_ - ; \ sANTABARBARA-sANRuz
, l,!----------
~..,.
COLLEGE OF ENGINEERING BERKELEY,CALIFORNIA DEPARTMENT OF NUCLEAR ENGINEERING May 27, DOClEtED ualBl U. s. Atomic Energy Commission JUN 11970
- Washington, D. c. 20545 OfflOI If ttlt Seeret1rJ Public l'ffllJedllP Attention: Chief, Public Proceedings Branch BnDcll
Dear Sir:
The Atomic Energy Commission has invited public comments on a proposed amendment to 10 CFR Parts 20 and 50 entitled "Control of Releases of Radioactivity to the Environment". I recommend your reconsideration of these proposed amendments for the following reasons:
- 1. A need for incorporating these changes has not been properly established.
- 2. If these changes are incorporated they will impose new regulations which are not amenable to fa.ir, objective, and competent implementation by the regulatory agency.
The nuclear industry, the public, and the Atomic Energy Commission will all suffer from this situation. I recommend that the present regulations be maintained until such time as a real need for changes becomes apparent. In that event, the changes should be in more specific and quantitative terms, which do not have the deficiencies noted in (2) above. An explanation for these recommendations follows.
- 1. Need Fo*r The Propos*e a Changes .
The principle argument given for the proposed changes appears to be that of conforming the AEC regulations with *the statement of the Federal Radiation Council (FRC):
"every effort should be made to encourage the maintenance of radiation doses as far below this guide as practicable".
However, i t seems in error to interpret this as a statement by the FRC that those operations which involve radioactivity and radiation in some beneficial way cannot operate safely at or near the radiation-protection-guide levels specified by the FRC (and by NCRP and ICRP).
U
- S
- Atonu.c E nergy
- C ommission
' . May 27, 1970 2
FRC appears to be saying that they do not offer their RPG as a free license that any source of radiation can indiscriminantly expose the public to these specified doses. They appear to be saying that they do not condone any exposures unless there is some beneficial need for carrying out those operations which result in such exposures. There-fore, where there is a public benefit from operations such as nuclear power plants, these plants should be afforded the opportunity of operating within the radiation protection guides which have been prescribed on the basis of acceptable safety. The Commission's statement also recites the present experience with most of the light-water-cooled power reactors now in operation. It appears that the proposed change is, in part, to formalize the present practice, whereby the radioactivity in water and air effluents has been kept at levels lower than would be necessary under the present Part 20 limits. However, the need or justification for incorporating such practices into a regulation, which must be complied with, has not been given. Some individuals in government have suggested that the present release levels are low because technological uncertainties require a cushion between the planned releases and the allowable. If this be so, there are far better ways to provide for the proper and necessary factors of safety due to technological uncertainty. There are many other safety margins incorporated in nuclear power plants, and the magnitude of each margin is determined by the state of the art at that time. Plants are still designed to meet quantitative performance goals, and release to the allowable and safe RPG is one of these goals that can be and is being adequately achieved without legislating "cushions" whose need has not been established. Further, the "cushion" or "safety margin" implied in the present change ultimately deals with an entirely different question of economics, as will be seen below, and has little to do with the technological uncertainties which may be thought to be present in terms of compliance with the Radiation Protection Guides. The proposed change is also discriminatory. The proposed amendments to Part 50 would apparently require only water applicants for water-reactor licenses to describe the means, etc. of "keeping levels of radioactive material re l eased in effluents as low as practicable". Why not similar attention to fuel reprocessing plants? Why not other types of power reactors and research and test reactors? Is this not introducing a double standard for public protection? With the premise that the radiation protection guides listed in the current FRC publications are founded upon proper interpretation of the data on the biological effects of low level radiation, that the radiation protection guides represent a reasonably acceptable public risk, and that the benefits of nuclear power outweigh the risks incurred
U.S. Atomic Enerf comrnission May 27 1 1970 3 when operating under these RPG limits, there appears to be neither need nor useful benefit in incorporating into these regulations the additional and unworkable criterion that the releases should be as low as practicable.
- 2. Interpretating and Implementing the Cri*teria The meaning and criteria for what is "as low as practicable" are far from clear. Dictionaries provide little help here, but the usual interpretation in the engineering profession is that a system or device is practicable if:
(a) it is based upon established and reliable technology (b) it is economical. One of the two important considerations in determining practicability is economics, and this is the kind of economics that a regulatory agency will have great difficulty in judging on objective grounds. For example, let us assume that there are two utilities, A and B, which are building nuclear plants of essentially the same design but in different locations. Utility A has available a large body of cooling water, such as a river or ocean. Because of the large flow of water to and from his plant, utility A is able to dispose of sizable quantities of liquid radioactive wastes without closely approaching the MPC concentration limits in his plant discharge. Utility B has no naturally occurring cooling water available, and a cooling tower is erected to dispose of the waste heat to the atmosphere. Therefore 1 Utility B must incorporate special waste-handling equipment to reduce the release of liquid radioactive wastes far below the total releases allowed for utility A. Let us assume that the two utilities are similar in rate structure, cost of financing, and all other aspects which might otherwise account for some differences in economics between the two utilities. Therefore, if Utility B finds it economical to reduce his liquid wastes to the very samll quantities, and if he finds it possible with available and reliable technology, then such small releases are practicable for B. They are also practicable for A, and under the pro-posed new rule A would have to incorporate such additional waste disposal equipment. One might reasonably argue that Utility A has no need to reduce his releases further because they are already within the MPC guidelines. However, the issue of need does not appear in the proposed ainendments. This is one example of the unfairness that can result. There are, of course, real instances close to the example outlined above. There are also examples of similar differences in approach between utilities with regard to the control of gaseous effluents, even for the same type of reactor.
- u. s. Atomic Ener. Commission May 27, 1970 4
The next part of the question relates to how the regulatory authority -- the AEC -- might make a proper and independent deter-mination of what is practicable. They can deal with the question of what constitutes reliable and available technology, but they are in no position to evaluate the question of economics to the degree necessary for this determination. Only the utility itself can make that determination properly. What is economical in one instance may not be economical in another because of the variability in utility economics from one company to another. It depends upon so many factors which are not readily subject to independent evaluation, such as the problem of raising new capital, the rate structure, the cost of public relations, load-demand statistics, the utility's tax situation, and the spectrum of other generating stations in the utility's network. One might say that worrying about such variable factors is cutting i t too fine, but we know that economics of power generation operate on small margins. In a situation such as this the regulatory agency will either have to take the word of the individual utility as to what may or may not be practicable, or the agency will ultimately have to make a decision which is likely to be in large part arbitrary. Neither situation would appear desirable for a regulatory body. The public interest would also be compromised in this situation. This country's experience to date in atomic energy regulation must surely indicate that all parties profit when there are regulations that are clear in intent, clear in meaning, and amenable to clear interpretation and implementation. What may seem practicable to one of the parties may not appear to be so to another, and it will become very difficult for some interested parties to be convinced on grounds of fact that what they understand is supposed to be "as low as practicable" is actually occurring. It will also be difficult to resolve challenges as to whether or not a particular plant is operating with releases that are "as low as practicable". As an example, in the STATEMENT OF CONSIDERATIONS there appears the statement that:
"The Commission believes that, in general, the releases of radioactivity in effluents from the light water cooled reactors now in operation have been within ranges that may be considered as low as practicable."
Whether the present releases are in fact "as low as practicable" is very doubtful. There are several existing plants which come into the categories of Cases A and Bin the example cited above. Has it been shown that the internal economic structure of the Case B companies is so different from that of the Case A companies that the very low
, ~. S. Atomic Ener. Commission May 27 1 1970 5
releases of the Case B companies would not be practicable for all? Has the AEC made economic evaluations of available technology which could further reduce the releases in many of these plants?
- Further, announcements in the trade literature of the nuclear industry since the publication of these proposed changes would indicate that what is "as low as practicable" is a rapidly moving target.
I urge that the Atomic Energy Commission reconsider these proposed changes in the light of the above comments. The nuclear power industry 1 the Atomic Energy Commission as a regulatory body, and the public all deserve clearer and more workable rules than the one proposed here. Sincerely yours, 3'A~t_jJ Thomas H. Pigf~ /Y THP:gme
- DOCl'ET rwr1i5. i:)l PR PROP.OSED RULE -J. O 1.5D 1
PUBLIC SERVICE Company
~!rl:115;- f '
1087 Elm Street, Manchester, N. H. 03105 May 27, 1970 Secretary U.S. Atomic Energy Commission Washington, D. C. 20545 Attention: Chief, Public Proceedings Branch
Dear Sir:
We appreciate the opportuni t y to comment on the proposed amend-ments to 10CFR20 and 10CFR50 and have specific comments as follows:
- 1. We are in agreement with the proposed new paragraph (c) to part 20.1. This paragraph formalizes a philosophy that has been adopted within the civilian nuclear power industry as evidenced by the excellent performance record of existing reactors. One problem area that we foresee with this para-graph as presently written is the use of highly qualitative terms such as "every reasonable effort" and "as far below as practicable". The determination of what is reasonable and practicable requires judgements to be made on a case by case basis which could lead to unnecessary licensing delays.
While fully recognizing the difficulties involved in trans-lating the intent of this language into a quantitative guide-line we believe an effort in this direction is justified.
- 2. We s t rongly agree that the licensee be permitted the flexi-bility of operation compatible with health and safety consi-dera t ions to assure t hat the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than the small frac-tions of limits specified in part 20.106 which would result from normal operation.
DOCKETED U&AEC Vice President EP:DMF:dpz
D U KE POWER G OMPA.NY
- DOCKET llUMSER f.R0P0~E0 RULE pR
-;J.O I rso P o w,,n BUILDING , Box 2 178, GHAHLOTTE, N. G. 20201 1~~
WILLIAM S , LEE VIC£ PRESIDENT, ENGINEERING May 26, 1970 Secretary US Atomic Energy Commission Washington, DC 20545 Attention: Chief Public Proceedings Branch
Dear Sir:
This letter is to comment on the proposed amendments to the Commission's regulations, 10CFR Parts 20 and 50 as published in the Federal Register on April 1, 1970. Current regulations prescribe numerical limits for radioactive releases and exposures that have heretofore been established as adequate to protect public health and safety by the Federal Radiation Council, by the National Council on Radiation Pro-tection and Measurements, by the International Commission on Radiological Protection, and by the Commission. We agree that releases and exposures should be as low as practicable, and actual operating experience demonstrates that this has been so. This successful experience is due to the margins provided in the design of faci lities to control radioactivity. The design objective has been to provide sufficient margins so that the limits are not exceeded even in the event of a series of postulated and near-incredible events. We suggest that the record shows that the present regulations have been effective in limiting radioactivity to levels far below the allowable limits. However, it is now proposed to superimpose on such numerical limits the further requirement that facilities be designed to cover levels of radioactive releases and exposures "as low as practicable. 11 The indefiniteness of this proposed la nguage does not give a designer specific guidance as to what limits will be imposed in regulatory proceedings and therefore what further margins he must attempt to prov ide. The proposed amendment will tend to raise more questions than it settles thereby further complicating licensing proceedings, and it is unlikely that such criteria can be appli~d uniformly to all applicants and licensees. In other areas of eng ineering design, specific codes and standards have been developed to protect public health and safety. For example, specific working stresses and safety factors are applied to the design of a bridge. If those codes and standards should further require that the working stresses in bridge materials be lowered to values 11 as low as pract icable11 , no objective and uniformly acceptable criteria for bridge design would exist.
Page 2 May 26, 1970 In addition to technical considerations, we are concerned that the proposed amendment may change the legal burden of proof that an applicant must meet to justify issuance of a permit or license. In the face of legal intervention by those who oppose nuclear power, proceedings could conceivably revolve around the phrase 11 as low as practicable" ad infinitum, with the burden of proof continuing to rest on the applicant. We also note that the proposed amendment is with respect to desig, objectives for light-water-cooled power reactors. Any regulation to protect public health should apply equally to all nuclear facilities irregardless of type or ownership and not singularly apply to power reactors. To do otherwise infers to some that power reactors present ha zards not found in other nuclear facilities, whereas operating experience has clearly refuted such an inference. We feel the superimposition of the nebulous 11 as-low-as-practicable11 requirerrent on specific design criteria for nuclear facilities will result in confusion, inconsistency and unnecessary delays. Meantime, we agree that research should continue on the effects of radioactivity on health, and if, as a result of such research, lower limits are deemed necessary in their entirety or for specific isotopes, then the revised limits should be specifically quantified. We appreciate the opportunity to express our views. Yours very truly, W S Lee WSL/s
CAB LE ADDR ESS, COA L BURN TEL. 203-688-1 9 11 W I NDSOR. C ONN
- COMBUSTION WINDSOR , C ONNEC TI CUT 06095 May 25 , 1970 00¥. U uet.Et The Secretary UN 11970 U. S. Atomic Energy Commission o111ce o1 tl\8 sevetarr Washington, D. C. 20545 P1tll1I~ free*~ \v.gs
\I<*
Attention: Chief, Public Proceedings Branch
Dear Sir:
We are submitting herewith our comments in response to proposed amendments to the regulations in 10 CFR Parts 20 and 50 concerning "Control of Releases of Radioactivity to the Environment", as published in the Federal Register on March 28, 1970.
- 1. Combustion Engineering approves the Commission's ob-jectives in the proposed amendments that light water-cooled power reactors be so designed and operated that radioactive material in effluents to unrestricted areas be kept "as low as practicable".
The term "as low as practicable", however, introduces a new and substantial ambiguity into the Commission 1 s regu-lations . We do not believe that a regulatory provision which is so ambiguous can, by itself, be a useful guideline to the nuclear industry, to the AEC regulatory staff, or to members of the public. Accordingly, we recommend that the Commis-sion reeva l uate the proposed regulations with a view to adding numerical guidelines for designing and operating light water-cooled reactors. Such guides might take the form of guideline dose val ues to individuals outside the plant site. Since many operating utilities may prefer a simpler, although perhaps more conser-vative, method of determining compliance with the proposed regulations, we believe it would also be desirable to include a l ternative optional guideline values based upon radioactive material in plant effluents. The incorporation in the proposed regulations of such alternative optional guideline values would enable utilitie*s to avoid the necessity of complex and expensive calculations of estimated dose to offsite i:l1a~~~~il.{],y !I.Ir~ _6-Lf.LJ!J-~
Secretary, U.S. Atomic Energy Connnission May 28, 1970 Att: Chief, Public Proceedings Branch (2) Will averaging times be specified and will they be different depending on the distances below the Part 20-50 levels? (3) Why state this general policy matter only in the context of regulations for light water cooled reactors? Why not include related installations, including fuel processing plants? (4) The proposed wording of the 10 CFR 20.t(c) 11 * * * * * *
- m.aintain radioactive exposures and releases of radioactive materials ******* " (underlining mine), is more general than the stated purpose. Should this not read 11 * * * * * *
- to maintain exposures from releases of radioactive materials in effluents ******* "?
I view item 1 as important only if there is no room for the exercise of professional judgment in the relationship between licensees and the Connnission. Since "as low as practicable" may not be the same figure at different installations and since professional judgment does function in the relations at issue, any attempt to quantify regulations unduly at the low end of the potential exposure range may engender more serious problems than lack of quantitation. This is, however, my personal opinion. The point is naturally of concern to some who may be required to take varying actions under different interpretations of the proposed regulations. Item 2 is of interest and importance to the operator and might well be made more explicit in the regulations. Obviously, however, flexibility is of great importance in any consideration of averaging times and our Society would consider this flexibility coupled with professional judgment as the factor of primary import-ance. Finding these broad statements only in connection with proposed regulations for a specific reactor type is presumably an accident of the current scene. Howewr, it may be misunderstood and even defeating to the purposes at hand. On the assumption that maintenance of the lowest possible radiation levels is general policy of the Connnission, as we know it to be, it is suggested that other regulations be similarly modified as soon as convenient or alternatively a general statement be inserted in the CFR. The writing of this response has awaited communications from several Board members who have been away and is thus very close to the deadline for connnents. I hope they are useful and in time. We do appreciate the opportunity to review this proposal specifically. Sincerely yours,
/rs J.
CC: Mr. Harold Price President, Health Physics Society Director of Regulation, AEC Members of Board of Directors, HPS R. Alexander, Public Relations Connnittee, RPS
- 001 NUMBER P R PJW . SED RULE .-':)..[), 5"t)
~f~U~ rn~~ L~ ~~L H~ Incorporated 1961 c~i~f.a
~~ ~
A PRESIDENT: J. NEWELL STANNARD UNIVERSITY OF ROCHESTER SCHOOL OF MEDICINE HEAL TH PHYSICS SOCIETY May 28, 1970 260 CRITTENDEN BLVD. ROCHESTER, N. Y. 14620
.... **j:*;i;;;:ii.s;;~~*;;d* ..... PRESIDENT-ELECT: CLA IRE C. PALMITER Univ. of Rochester FEDERAL RADIATION COUNCIL WASHINGTON, D.C. 20449 School of Medicine, Sta . 3 r .................................
Rochester, N. Y. 1 620 O' t\li.E D PAST PRES IDENT : WRIGHT H. LANGHAM LOS ALAMOS SC IENTIF IC LAB. Secretary u~c LOS ALAMOS, NEW MEXICO 87544 U.S. Atomic Energy Commission SECRETARY: ROBERTSON J. AUGUSTINE Washington, D.C. 20545 11970 BUREAU OF RADIOLOGICAL HEALTH 12720 TWINBROOK PARKWAY Office of 1he s,oratary ROCKVILLE, MARYLAND 20852 Att: Chief, Public Proceedings Branch Public Proc~dings TREASURER : ROBERT L. ZIMMERMAN NUCLEAR RESEARCH CENTER L GEORGIA INSTITUTE OF TECHNOLOGY ATLANTA, GEORGIA 30332
Dear Sir:
This concerns the proposed amendents to regulations on radioactive effluents from light water cooled power reactors proposed on March 28, 1970 and published in the ~ederal Register. I write as president of the Health Physics Society in specific response to the request of Mr. Harold Price, Director of Regulation, AEC. The opinions stated represent a composite of written and verbal replies from several members of the Board of Directors of that Society and other Society members but should be regarded as strictly my own in terms of responsibility, language and format since there has been no opportunity for a formal meeting of the Board on this matter. Although it has been the tacit understanding of all concerned that normal levels of discharge of radioactive effluents should be well below those stated in Part 20 and 50 regulations and ICRP and NCRP policies to maintain all radiation exposures "as low as practicable" applied to these Federal regulations and the FRC guides as well, the clear iteration that this is indeed so is probably needed and desirable at this time. Some . Society members felt it to be an unfortunate and ill-timed sop to current critics of nuclear power programs and licensing procedures and not a change in technical criteria . While it may be so inte~p~eted, this cannot overide the need for an overt statement of policy. Indeed we approve, in general terms, the plan to include in the pertinent Federal regulations both general language inform-ing all licensees of the need to operate at the lowest possible levels and the request for a description of the specific means planned for achievm.g this objective. As might be expected, there were many points raised concerning language and specifics. They group themselves around the following topics: (1) The introduction of a non-quantitative criterion which is really more admonition than regulation puts the potential licensee at the mercy of individual interpretations of such phrases as "lo"(.T as practicable" (e.g., how much below Part 20 or 50 is "far below"?). br .l.? ~ tN.}.._ cl ~ ., 1 ltk~owlei~~by Jar *~ - FIFTEENTH ANNUAL MEETING, JUNE 7-11, 1970 SIXTEENTH ANNUAL MEETING, JUNE 21-25, 1971 PALMER HOUSE, CHICAGO, ILLINOIS SEVENTEENTH ANNUAL MEETING, JUNE 12-17, 1972 WALDORF ASTORIA, NEW YORK, N EW YORK STARDUST, LAS VEGAS, NEVADA EIGHTEENTH ANNUAL MEETING, JUNE 17-21, 1973 OEAUVILLE, MIAMI BEACH, FLORIDA EXECUTIVE SECRETARY: RUSSELL f. COWING 194 PILGRIM ROAD, BOSTON, MASS. 02215 TEL. 617-734-7000 EXT. 458
The Secretary
- May 25, I 970
- 2. The Commission has announced plans to consult with the nuclear power industry in an effort to develop more definitive criteria for radioactive releases. We are in agreement with this approach, and in line with our recommendation above, would like to urge that the Commission implement this plan at the earliest possible time.
- 3. The proposed new paragraph 50. 36a calls for specific reporting of radioactive releases which 1'are unusual for normal operation". We believe it would be desirable for the Commission to furnish additional guidance as to what kinds of releases would be considered ' 1unusual for normal operation".
- 4. The "semi-annual" reports called for by proposed new paragraph 50. 369 would contain, in addition to quantities of radioactive material released during the period, 11 such other information on releases as may be required to estimate expo-sures to the public resulting from effluent releases". We are uncertain as to whether this provision would require utilities to perform exposure calculations or to merely submit infor-mation needed by AEC for that purpose. Even in the latter case, there is considerable ambiguity in the proposed require-ment because methods of calculations, kinds of data needed (e.g., meteorological, radiological), and the size and com-position of the "public" to be considered are not specified.
If the proposed amendment would require utilities to perform and report calculations of exposures to the public, the require-ments would be even more burdensome and complex. In addition to our own comments above, we also support the views on this matter expressed by the Atomic Industrial Forum in its recent letter to the Commission. Combustion Engineering will be happy to participate in the Commis-sion's planned program of consultation with industry in connection with the further development and review of the proposed amendments. Very truly yours, Vice President Nuclear Power Department JMW:mes
1910 USAEC HQ LPD T PD dATH 1E 30 ATOMIC ~NERGY C01~ 1.-1 ASH DC THE LI COL'II COU'IITY CULTURAL 0~ HI TORICAL ASSOCIATIO~ l'IIC , AS CO'IICERNED CITilE~ OF LI'IICOL~ COU'II Y ~E URUi YOU I'll REGARD 0 10 cs PART 20 TO CHA~G TH£ wuROl'iG [~ REuARO TO RADIATIO~ FR01.., ATOMIC PLA'IITS TO REAi) "'IIJ KE:AOIATIO~ PC:Rl'1ISSABLE" F'RO1 Tti£ PRii:Si:NT .-IOROl-.,G ,.AS F'AK AS PRACTAdLI!'. " /JtUCH OBVIOUSLY IS WORDED TO LET T~E PLA'II 00 S THEY s-E rr . A~D ~OT .-JrlAT IS S FE FOR HUMANS AND TH£ EC LOGY
~ARGUERITE RAFTER DIRECTOR 710? EDT +
USAEC QS li Tw i'i Office of tile SltAtarJ Pllbllc: Prnc*~dl!IP
"!"r: '
WU wSrl
U"
- A c.C £ C
I INC. 850 THIRD AVENUE* NEW YORK , N.Y. 10022
- PLAZA 4-1075 May 28, 1970 oocH.1EO USiEC The Secretary 11970 U. S. Atomic Energy Commission omce of th! seriretao Public p~*i 'l*~s Washington, D. C. 20545 Br.~*
Attention: Chief; Public Proceedings Branch
Dear Sir:
This letter is submitted in response to the Commission's invitation for comments
- on its notice of proposed rulemaking entitled 11 Control of Releases of
- Radioactivity to .the Environment, 11 as published in the Federal Register on April 1, 1970, The comments contained
- herein represent a consensus of the v-tews of the following members of an ad hoc Committee of the Atomic Industrial Forum:
John L. Allen Philadelphia Electric Company Roy Denham NUS Corporation Frank J, Gottlich Boston Edison Company R. Michael Hartman Ebasco Services Incorporated Stanley Koutz Gulf General Atomic Incorporated G. Bill Matheney Consumers Power Company Donald A. Minner The Babcock and Wilcox Company Joseph A. Mohrbacher Allied Chemical Nuclear Products, Inc . Porter E. Noble Central Vermont Public Service Corporation John W. Utegaard Bechtel Corporation Edward J. Walsh Long Island Lighting Company C. H. Waugaman Tennessee Valley Authority In essence, the Commission's proposal seeks to provide a framework for assuring that all reasonable efforts continue to be made by Corrmission l icen-sees to keep exposure to radiation and release of radioactivity in effluents as low as practicable . To accomplish, this Parts 20 and 50 would be amended to reflect this policy and to incorporate additional reporting requirements to assure compliance with it. The proposed amendments to Part 50 are limited to light water cooled power reactors. The thrust .of the proposal is to recognize in a formal way the sound operating practices of licensees which have been designed to maintain the lowest practicable discharge
- levels consistent with good operating practices and the public health and safety ~ The additional information which the
~-~k-~!!ie~1*U~d. -~J!../2!,_~
I NC. The Secretary U. S. Ato~ic Energy Commission May 28, 1970 Commission will secure pursuant to the new reporting requirements should demonstrate this in a tangible way. There are some aspects of the proposed rules upon which we would like to comment specifically: ( l) There is some concern that the term 11as 1ow as practicable" is not sufficiently definitive as to give guidance as to just what operating circumstances are permissible. We recognize, however, that the proposed amendment is in the nature of a statement of Commission policy which will be applied in follow-ing the existing requirements of Part 20, rather than a strict regulatory standard and as such is not in-tended to impose new or additional regulatory criteria. Furthermore, the Commission's statement accompanying the proposed amendments indicates that the intention is to reflect present operating practices under which releases from reactors now in operation are considered to be -well within the acceptable range. The Commis-sion also specitically recognizes that the standard must be applied in a flexible manner. If the Commis-sion indeed takes these factors into account in apply-ing the "as low as .practicable 11 polJcy, it can provide some guidance in implementing the present regulatory requirements. (2) The reporting rules proposed in Section S0.36a(a) (2) would benefit from further clarification as to their precise requirements. This paragraph states in part that "if quantities of radioactive materials re leased during the reporting period are unusual for normal reactor operations, incl.uding expected operational occur-ences, the report shall cover this specifically." Neither "unusual" nor "expected operational occurences 11 are defined and no additional guidance is provided as to what must be specifically reported. For example, expected operational occurences could include operating at or close to maximum limits for varied periods of time if necessary to maintain reactor operating sta-bility or for reasons of power system reliability;
- ~1~ MI~ I~ ~ ~ ~ l ~ I~ l te ~ M IN C.
The Secretary U. S. Atomic Energy Commission May 28~ 1970 conversely, unusual operating conditions might be restricted to situations requiring a substantial reduction in power output or complete shutdown of the reactor. Presumab ly the terms of the 1 icense and the technical specifications would serve to indicate what might be considered unusual or ex-pected operationa l occurences, but since the para-graph imposes additional reporting burdens on 1 icensees, it would be desirable to clarify just what must be specifically reported. (3) The last sentence of proposed Section 50.36a states that 11 0n the basis of such reports and any additional information the Commission may obtain from the licensee or others, the Commission may from time to time require the licensee to take such action as the Commission deems appropriate. 11 Of course, licensees would be anxious to comply with any requirements found to be necessary for safety reasons, but there is concern that the language, broadly interpreted, could permit ,substantial, unilateral changes in the terms of a license. This concern could be eliminated by incorporating in this section language explaining that any action taken by the Commission would be in accordance with applicable regulatory requirements, including the recently promulgated backfitting rules. In conclusion, we note that ~he Commission has expressed an intention to consult with industry representatives and groups to determine the feasi-bility of developing more definite criteria for design objectives and means for minimizing radioactive effluent releases. The Forum would be pleased to cooperate with the Commission in any effort it may undertake to trans* late the objectives of the policy statement into amendments or modifications of existing requirements. Sincerely yours,
~ ll)J ~et>~
George . Gleason Legal rojects Manager GLG/cp
NUS CORPORATION Secretary U. S. Atomic Energy Commission Washington, D.C.
Dear Sir:
This letter contains our comments on the proposed amend.ments to Parts 20 and 50 of the Commission's regulations in respect to releases of radioactivity from light water cooled nuclear power reactors. At the outset, we are pleased to see the formal adoption by the Commission in Part 2 0 of the FRC, ICRP, and NCRP injunction to minimize radiation exposures as much as practicable. All those of us who have been in-timately concerned with the radiological aspects of the nuclear energy program recognize this as a somewhat belated formalization of what has been the regulatory philosophy of the Commission since its inception, as reflected in the excellent performance in this area of licensed nuclear reactors. We find relatively little to comment on in respect to much of the proposed Part 50 amendments since in large measure they again reflect practices which have been in effect for some time, and also since they appear quite similar in intent to the recommendations made by the writer in testimony before the Joint Committee on Atomic Energy in January of this year. Nevertheless, there are several areas in which we feel some further consideration may be desirable. The desirability of minimizing radioactive effluents is recognized, and has been demonstrated by the excellent operating record compiled to date. However, the definition of "as low as practicable" is fraught with difficulty in a regulatory proceeding, in which such definitions may be different not only between applicant and staff, but possibly as defined by Atomic Safety and Licensing Board members, or by concerned members of the public. Since "practicable" necessarily implies economic as well as technical feasibility, the definition of "as low as practicable" deserves more support than the reference in the Statement of Considerations to the present acceptability of presently operating plants in terms of this criterion. ,ENVIRONMENTAL SAFEGUARDS DIVISION 2351 RESEARCH BOULEVARD, ROCKVILLE, MARYLAND 20850, U.S.A. TELEPHONE (301) 948-7010 CABLE : NUSWASH
Secretary, U.S. Atomic Energy Commission May 22, 1.970 Page Two Considering the fact that, in general, presently operating power plants . have created no significant changes in the environmental radiation levels from those pre-existing these installations, some could question if any benefits at all are to be derived from any further reduction in releases. On the other hand, some have proclaimed the "feasibility" of total waste containment within a plant for shipment off site-a II zero release" concept-and have called for its incorporation in all nuclear plants. Between these limits lie a wide range of possible "as low as practicable" values, depend-ing upon the individual or organization making the judgment. It is for this reason that the writer suggested to the Joint Committee on Atomic Energy, and suggests now to the Commission, that some design numerical dose objectives be incorporated in the Part 50 amendments when issued, even
- if these are identified as interim values subject to future revision as needs and technical feasibility are indicated.
A second comment is directed at Section 50. 3 6a (a) (2) requiring 11 * *
- such other information on releases as may be required to estimate exposures to 'the public ... " This specification can be interpreted in a variety of ways, and -might benefit from some additional clarification. For example, a .rigorous basis for estimation of exposure to the public would require:
- for gaseous emissions, a knowledge of the identity and quantity of all significant nuclides in the emitted mixture (and measurement of the beta and gamma energy spectra) and correlation of release rates with the meteorological conditions at the time of release for prediction of dose increments due to external exposure and inhalation; knowledge of the location and feeding practices of cattle, dairy cows and such wildlife species as deer, rabbit, etc. , for prediction of uptake of radionuclides potentially deposited on vegetation; the concentration or transfer of deposited radionuclides by each species; and the amount of meat or milk product used by the public to permit an estimate of ingestion doses from these sources.
- for liquid discharges, a knowledge of the identity and quantity of all significant nuclides in the discharge mix-ture; correlation of the release rate with available dilution flow in a river or dispersion conditions in a receiving lake, estuary or ocean area at the time of release; for fresh water, the number of people and volume of water ingested by them;
[1j
Secretary, U.S. Atomic Energy Comm is sio n May 22, 1970 Page Three knowledge of the kind and number of edible aquatic or marine species in the affected water volume and their radionuclide reconcentration capabilities for each of the released radionuclides; the number of individuals eating each of these species and their intake quantities over the time interval reported, to permit an estimate of ingestion doses via the water environment. We would submit that, at the very low discharge levels experienced in presently operating reactors and expected in those presently under con-struction or design, the measurements and knowledge suggested by this specification cannot feasibly be obtained and their relevance to assuring
- adequate public health and safety approaches the ridiculous.
On this basis, we would suggest an alternative wording to this speci-fication as follows: " ... such other information on releases as may be required to estimate maximum potential exposures to the public .*. " This modification would (1) permit the plant operator to continue his present option, with respect to emission analyses, of a conservative assumption of waste mixture composition in lieu of specific radionuclide identification, (2) permit the assumption of conservative environmental transfer and uptake parameters to arrive at maximum potential exposures, yet (3) allow the plant operator the flexibility of deciding if a more de-tailed a nalysis is warranted in a particular time period, or for particular operating circumstances. Without this or a similar change in wording which would reflect the technical infeasibility of exact compliance with this specification as written at the low discharge levels contemplated, all plant operators would be exposed to a claim of non-compliance. We appreciate the opportunity to provide these comments for your consideration. Very truly yours ,
~~
Morton I. Goldman, Sc. D . Vice President & General Manager Environmental Safeguards Division NUS Corporation
1 - o,rro e OtJnU 1 &{ ~~~~ STONE 6 WEBSTER ENGINEERING CORPORATION 225 F RA NKLIN S T REET, BOSTON , M A S SACHUSETTS NEW YORK Dl!'S I GN IIOSTON C O NS TR U CT I ON C H ICA GO R E P O RTS GARDEN C I TY A P P'ftAI S A L S H O USTON OCKEH9 E XAM I NA TI O N S C O NSULT I N G LOS A NGEL ES SAN FRA NC ISCO US:AEG ENG I NEERI NG AY 2 7 1970 Office of the SecretarJ Public Frtlt"..adl8'1 Secretary ~ l!r b U. S. Atomic :Energy Commission Washington , D. C. 20545
Dear Sir :
We offer the following comments and suggestions on the proposed amendment to 10CFR20 published for comments on March 28 , 1970 . ~ Our chief obj ection is that the pr oposed change to 10CFR20 would require licensees to 11 * * *
- make every reasonable effort to maintain radiation exposures and releases of radioactive materials in effluents t o unrestricted areas as far below*
the limits specified in this part as practicable ." Use of such words as "every reasonable effort" and "practicable" in the statement of intent should be avoided . We, as engineers , are presently unable to predict what future release rates might be acceptable over even a few months' time . The revised w*o rding does not help matters . Unless some specific guidelines are given, no firm design basis exists . This kind of statement assures countless hour s of discussion by conscientious people as to what constitutes every reasonable effort to get radiation as low as practicable . We note that the Commission , in proposed changes to 10CFR50, specifically singles out light water cooled pow-er reactors as having consistently attained low releases of radioactivity . This suggests a solution to the vagueness of the proposed change to 10CFR20 . Through the media of 10CFR20, levels of radioactivity release or radiation dose in unrestricted areas which are designated normal operating release by specific types of reactors could be published periodically. Releases during abnormal operating occurrences should be allowed to exceed these values for a specific time compatible with present guidelines .
US AEC 2 May 21, 1970 The present concern over the 10CFR20 guidelines indicates little general understanding of how such guidelines are used. No professional engineer uses such guidelines as targets for normal design; the records of operating plants establish this fact. The Commission has always required applicants to state the precautions they, the applicants, have incorporated to ensure that the dose levels in 10CFR20 are not exceeded even under abnormal conditions. Yours very truly,
- w. J. L. Kennedy Chief Nuclear Engineer WJLK:RMR
OCKETED USIAEC AY 2 71970 offlc* of the S2:retary PIIL
- rf"'~* ~lnp
°1)QQ..r~J) f:r-+ tL..Q.. ~ ~ K~ ~ ~~c_ ~
('.by-nf"'l1$g:~ (}..xu,u,c..vtcsuf< P~D~ ~~ '"\--D
~ 6¥\. ~ ( C ) Q . G ~ ~~ ~ \ ~ ~
G.o\.Q& C\-U..c.Q..Q_.e..,<- ~~ ~~, fu.J.o\,c.. ~~ ~
~~-~ ~ (S\L/' Cb'Ml~.
l.)e_ ~ ~ ~~ ~ - ~ ~'~
.Asw c/2 ~d't~{ .L-6 ~ ~ * -r~ ~ ~
k ~ ~ ~ ~-~ ~r- hz. l..\.o ~cc.,~ ~l~~~ ~ ~ f ~
- P-Qe}p-.le
~~ a..6 X. -:S~ G-oF°mQ.h / ~ ~ - - , - ~ ~ o1
~ U ~ , hJ oj ~ i -r ':t.....-- 1S ~ C., ~
'j l..Xurk,~ 1-,,,,, J ~ , I::) ej St-. 1... ~ ~ ~
~ ~t,*c Ro..k- ~ Vj hl) ~ ~ ~
r~Q_~ ; ~ ~ kn ~ ~ + - 6j r~a..c..hil*~ ~ ~& {s:, ~ 0 ~ . LJ.r;_ lo~ ~ WlLl KWW ~ ~
~ ~~ QU ~ ,,~Q~ ~~s~~ ~
~~ ~ ~ .
G~1-es +o~ v~ ~ j s~~~ ~':Bfbofz.R ~ kc.Ce:;y-Mc..ch.
~
~
. - fts ~ ' Uc~R ~~
1 I j) -Av , 1) S'Cih/r<M 'AN V ?\ Lf:n..1 E S'C-HUf?.Nflt,J
I DO CKLE D Gibbs B. Hill., Inc. tl&AEC ENGINEERS DESIGNERS CONSTRUCTORS Office of the Se~retary 11 May 1970 Public rr:c*~*11ngs
~I \
- Mr. Harold L. Price Director of Regulation U.S. Atomic Energy Commission Washington, D. C.
20545
Dear Mr. Price:
Proposed amendments to 10 CFR Parts 20 and 50 regarding "Control of Releases of Radioactivity to the Environment 11 fully reflect the criterion which the partners of the nuclear power industry had adopted many years ago. This criterion, namely keeping the levels of radioactive material in effluents to unrestricted areas as low as practicable, has been met as witnessed by the recorded annual release rates from the many unit years of operation. Further, the United States nuclear power industry has carried this design criterion around the world in those U.S. designed nuclear power plants located in over ten countries. As such, it is ex-pected that intent of the proposed amendments will be graciously accepted by the nuclear power industry. There are, however, several comments which we offer for your considera-tion: (a) The phrase "as low as practicable 11 (50. 34a(a)) does not establish realistic design guidelines which can be employed during PSAR preparation and the design and engineering of the station. Considering the elapsed time between commencing PSAR preparation and re-ceipt of construction license, we believe that better defined guidelines are necessary to maintain orderly design progress and project schedule. As plant designers, as well as members of the public, we would prefer to see MPG' s reduced selectively for those nuclides characteristically produced by power water reactors that are of prime concern. Concen-tration of effort on the controlling nuclides in the present areas of greatest concern would accomplish the desired result, but on the basis of MPC's closer to actual concentration working levels, and therefore less subject to interpretation and judgment of what safety factors are 11 practicable 11
- 393 SEVENTH AVENUE NEW YORK , N,Y, 10001 PHONE: 212-565-4300 CABLE : G I BBSHILL, NEW YORK
Rec'd Off.
.r. of Reg.
Da te 5 ;15 Time
'I ? ,, 4 **
r r
! r r r
! T r 1
r r J
*1 r ~J r ! r
! ! r r ! r I !
r J - r r T r-r ! r *r 1
I I (b) Paragraph 50. 36a(a) (2) might encourage the USAEC to impose further backfitting on plants presently in opera-tion and operating well below the 10 CFR 20 limits. This we believe would impose an undue hardship on plants which were designed to the intent of this amend-ment many years ago and are operating accordingly. This comment also applies to stations for which con-struction permits have been issued. These comments are offered with intent of ever reducing the effects of our society 1 s progress on the environment and yet achieving a sense of economic balance. Very truly yours., PHS/pm LI P. H. Smith President
. I.
i: i: i i I .i
.i .i i:
i .i I .i i 1 i
.i i i i r j i
.i
\
MAY 2 6 1970 ar. ** L 1111.a!l. lnllil** t . . . . . .,1..... a.nab Ml 1 . . . . . . . . . . . ~10001 ftlall ,-a lllr ,._ J.-W' ef IIQ l.l* l.tJQ, I die ..., **** 11** *** ,.10 ............. ...... 11 . . . . . . -c..&191 . .J.11111 - , * *. .***tWU7 b C'lla ~ . * . . . . . . . . . . . . . . . . . . . . . . . . . .11....t,,. ................. .ratiN ,..._. c* **** _ . _._. ..,._
- dNt ,.,,ndl .,.._
.....1.7.
(Signed) H. L. Price D1.t5gllpaU..., . Dockat ftle (UI) lecntarla w/*1 ,_ Mllc DN--t . . _ Atta, - - ......... a1.nct*** oro.... us ILi. DO"KETED Jlftllr* Aaauc .... Ir__., an US!AEC an,PD an:au Ill lllft.tdatrleka .., GLllllttoa UIOlffa IIJ.llric* S/11/70 J/ /10 / /70
UNITED STATES ATOMIC ENERGY COMMISSION WASHINGTON , O .C . 20 545 MAY 2 5 1970 W. B. McCool Secretary LETIER FROM MICHIGAN DEPARTMENT OF PUBLIC HEALTH The enclosed information is sent to you for your possible use, inasmuch as the second paragraph refers to proposed changes in AEC regulations.
;J, R. ~
~(}!~er R. Price, Director Division of State and Licensee Relations
Enclosure:
Letter from D.E. Van Farowe,Chief Radiation Section, Michigan Depart-ment of Public Health, dated 5/6/70 OCKETED EC AY 2 61970
ooc:::: :**1.,: :n R-~ o 5 o 1
,,. - P..ROP0.- Ult
- O STATE OF MICHIGAN ~~ &-\ ~
DEPARTMENT OF PUBLIC HEALTH JraJLio 3500 N. LOGAN, LANSING, MICHIGAN 48914 WILLIAM G. MILLIKEN, Governor MAURICE S. REIZEN , M.D ., Director May 6, 1970 Mr. Eber R. Price, Director Division of State and Licensee Relations U. s. Atomic Energy Conmission Washington, D.C. 20545
Dear Mr. Price:
In reply to your letter of April 27, 1970, with regard to the scheduling of the ten-week course in Health Physics and Radiation Protection at Oak Ridge Associated Universities, we have felt that this is a valuable training course. All of my staff has attended. Until such time as we have a change in personnel we have run out of live applicants. I have also reviewed the proposed amendments to the Atomic Energy regulations concerning the control of releases of radioactivity to the environment. These amendments are an improvement in that the total quantities of radioactive materials must be reported. It seems that it would be advantageous to add a requirement that another agency such as the state or a licensed quality control laboratory police the radioactive effluents to provide better regulatory control. Very truly yours, DIVISION OF OCCUPATIONAL HEALTH
£}-Cd::?~
D. E. Van Farowe, Chief Radiation Section DEV/ja IJ&AEC AY 2 61970 Office of the Se::reta,y Publlt Pretceolngs Bra:ch M ~1N THE GREAT . "Equal Health Opportunity for All" LAKE STATE
UNITED STATES ATOMIC ENERGY COMMISSION WASHINGTON , O.C. 20545 MAY 2 5 1970 W. B. McCool Secretary LETrER FROM MICHIGAN DEPARTMENT OF PUBLIC HEALTH The enclosed information is sent to you for your possible use, inasmuch as the second paragraph refers to proposed changes in AEC regulations.
;J, I<.~
fvi (/!~er R. Pr i ce, Director Division of State and Licensee Relations
Enclosure:
Letter from D.E. Van Farowe,Chief Radiation Section, Michigan Depart-ment of Public Health , dated 5/6/70 OCKETED EC AY 261970
WILLIAM G. MILLIKEN, Governor MAURICE S. REIZEN, M .D ., Director May 6, 1970 Mr. Eber R. Price, Director Division of State and Licensee Relations U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Mr. Price:
In reply to your letter of April 27, 1970, with regard to the scheduling of the ten-week course in Health Physics and Radiation Protection at Oak Ridge Associated Universities, we have felt that this is a valuable training course. All of my staff has attended. Until such time as we have a change in personnel we have run out of live applicants. I have also reviewed the proposed amendments to the Atomic Energy regulations concerning the control of releases of radioactivity to the environment. These amendments are an improvement in that the total quantities of radioactive materials must be reported. It seems that it would be advantageous to add a requirement that another agency such as the state or a licensed quality control laboratory police the radioactive effluents to provide better regulatory control. Very truly yours, DIVISION OF OCCUPATIONAL HEALTH j)-Cd ::f~ D. E. Van Farowe, Chief Radiation Section DEV/ja ocn,:o tl&AEC AY2 61970 Office of the Sei:retary Publl& Proese~lags Bra~cll M~N THE GREAT * "Equal Health Opportunity for All" LAKE STATE
RECEi 0 1970 M Y 26 AM 9 5 2
PR1.*1 w- J 'JLL i) -
.... ~'7,15 c:w ..
"!A.~
()m~ ~ ~~
...a
, . _ I PPD *
- UNO R~
Omaha Public Power District 1623 HARNEY OMAHA, NEBRASKA 68102 TELEPHONE 341-3100 AREA CODE 402 OFFICE OF THE GENERAL MANAGER M a y 1 9 , 1970 Mr . H a ro l d L . Price Director of Regulation United States Atomic Energy Commission Washington., D. C . 20545 De a r Mr . P r ice: Thank you for your letter of March 26 , with which you enclosed a copy of proposed amendments to AEC regulations concerning the control of releases of radio-activity to the envir onment, a nd a pre ss announcement. You invited comments , within a 60-day period. This is to inform you that we have reviewed the material which you sent, and have nothing constructive to offer . Sincerely yours , D0Cl,1U ll&AEG MAY 26 1970* Office of the Secretary A . L . Monroe Public Proceedings Branch General Manager ALM:ap P . S. Mr . E . E . Schwalm, to whom your letter was addressed, retired from the District last year .
Rec' J 0, eg_ Date ~ Time. _ _,___ .
~ ~*.
NF"S WHEATON PLAZA BU I LD I NG, SU I TE 9 0 6 WHEATON , MARYLAND 2 0 9 0 2 AREA CODE 3 0 1- TELEPHONE 9 3 3 - 5 4 4 0 DOCKETED tl&\EC May 21, 1970 Mr. Woodford B. McCool Secretary United States Atomic Energy Commission Washington, D. C. 20545 Attention: Chief, Public Proceedings Branch
Dear Mr. McCool:
Re: Comments on Proposed Amendments to 10 CFR Part 20 and 10 CFR Part 50 Concerning Control of Releases of Radioactivity to the Environment On behalf of Nuc lear Fuel Services, Inc., I am submitting certain comments concerning the above described proposed rule-making. NFS fully supports the Commission objective of keeping exposures to radiation and releases of radioactivity in effluents as low as practicable. However, NFS doubts whether it would be advisable to incorporate such an objective in a regulation in the manner suggested in the proposed rule-making. The specific provisions on which NFS is commenting are expressed as follows in the proposed Regulation: Section 20.l(c) . . . . persons engaged in activities under licenses issued by the Atomic Energy Commission pursuant to the Atomic Energy Act of 1954, as amended, should, in addition to complying with the requirements set forth in this part, make every reasonable effort to maintain radiation exposures and releases of radioactive materials in effluents to unrestricted areas as far below the limits specified in this part as practicable. Section 50.36a(2) * . .
- On the basis of such reports and any addi-tional information the Commission may obtain from the licensee or others, the Commission may from time to time require the licensee to take such action as the Commission deems appropriate.
Mr. McCool May 21, 1970 NFS is concerned that the above regulations set up a subjective rather than an objective standard for compliance with the principle expressed in Section 20.l(c). Under the proposed rule, there can be no assurance that 1i censees wi 11 be subject to uni form requirements i.n reducing their radio-active discharges to the lowest feasible amounts. It is recognized that because of varying ecological conditions the exact steps which would be reasonable for the licensee to take will vary somewhat depending upon the location and type of the facility. To the extent that variations in the Commission's specific requirements would serve merely to require each fa-cility to confonn to a general standard this seems appropriate. However, the proposed rule goes further and permits the Commission, in imposing requirements below the 10 CFR 20 limits, to establish a dif-ferent limit for each facility without relation to established radiation protection standards. This confonns to the approach of some conservation groups which seek to limit radioactive effluents without relating such limitations to genuine public health and safety considerations but merely on the sunnise that any radioactivity beyond that normally present in the environment should be avoided. The 11 Colorado Open Space Coordinating Council, 11 a conservation group, as well as local Colorado residents recently challenged "Project Rulison" on a number of grounds, one of which was that the present AEC standards as set forth in 10 CFR 20 are too high and should be reduced by a factor of ten. The U.S. District Court in Colorado recently declined to review the adequacy of the standards, holding that the Commission need only establish the reasonableness of the standard which it has established under its statutory directive to protect the public. If the Commission should limit radioactive discharges without applying a standard, a course which would be permitted under the proposed regulation, it is suggested that the door would be wide open for extended hearings not only in the Corrmission but also in the courts to establish limitations based on political pressures rather than on established health and safety stand-ards. The development of a pattern of lack of uniformity in health and safety requirements might cause considerable prejudice to reactor operators located in those states where political pressures were greatest. Reactor operators, however, do have a method of compensating themselves for such additional re-quirements. Presumably the rate structures in such states would be adjusted upwards to permit a higher rate to the utility company operating the reactor to compensate for the increased costs resulting from such stringent stand-ards. While lack of uniformity of requirements among reactors might prejudice some reactor operations, if this principle were applied to chemical reprocess-ing plants the results would be catastrophic. The reason for this is that chemical reprocessing plants, unlike reactors, have no assurance that their charges will be determined in such a manner as to permit a fair return on investment. A chemical reprocessing plant can compete solely on the basis
Mr. McCool May 21, 1970 of controlling its costs so that its charges wi ll not exceed those of its competitors. If the requirements applicable to one chemical reprocessing plant were substantially more stringent than those applicable to its com-petitors, almost certainly the plant with the more stringent requirements could not meet its competition and would have to terminate its operations. Furthermore, popular pressures, no matter how unjustifiable, would become an important criterion in siting future chemical reprocessing plants. In short, the application of the proposed rule to licensed facilities, and in particular to reprocessing plants, might make more difficult the achievement of one of the primary purposes of the Atomic Energy Commission: - "the encouragement of wide spread parti ci pati on in the development and uti 1i zati on of atomic energy for peaceful purposes . . 11 President RNM/jt
~
MAY 2 5 Mr. A. E. Schubert Vice President General Electrfc Ccnpany 175 Curtner Avenue San Jose, California 95125
Dear Mr. Schubert:
Thank you for your letter of M-, 4. 1970, COlllfflefttf ng on the Colll1ss1on 1 s proposal to amend 10 ~ Parts 20 and 50, regarding the control of releases of rad1oact1v1ty to the environment. Your connents have been noted and will receive careful ams1dera-t1on prior to taking further action on the proposecl n1le. We apprecfate your offer to participate 1n the develop11911t of more def1n1t1ve criteria for design objectives and means for k-.,fng rad1oact1v1ty 1n affluents fran poMer ructon as low as pnct1c1ble. We shall keep your offer 1n 11fnd as we arrange for meetings with the nuclear po,r,er industry and other caapetent groups to discuss this matter. Sincerely, ( signfJd ) Harold l, Price Harold l. Price Director of Regulation DISTRIBUTION:
- - Docket *fi1e (RPS) Program Assistance
~ Secretariat w/cy for Branch, RPS Public Document Room SLR Attn: Stan Robinson Director of Regulation Director's Office, RPS RPS:PAB RPS:DIR DIR7REG MBFftzPatrick:seg GLHutton LRogers HLPrice 5/ /70 6/ /70 5/ /70
MAY 25 DOCKEfED EC
....,. AY 2 61970 Office _of the Socratary Public Froc:;idings 6ra.,ciJ
( sign"' ) Haroltf L Price M&rP,tioas
..... I.at.,
Docket ftle (UI)
,-lie DN 11t 1ec:a
.ktas ltaabW_..
Knct* . , ....
.......,,.offtee, 111
,.u...
' - * - ....iatw* .......
lllft.t&Patdasat./-, Cll.lllatt. . an DR S/U/10 SI /71 I 110
-EBASCO INCORPORATED SERVICES
- /(. f' ( ~n~ Gs e1fr A Boise Cascade Company Jf d,(,eJn(" ft r.-, f'f UTILITY CONSULTANTS - ENGINEERS -
TWO RECTOR STREET NEW YORK, N.Y. 10006 CABLE AOOReBB "EBASCOE" LEONARD F. C. REICHLE VICE PRESIDENT The Secretary U.S. Atomic Energy Commission Washington, D.C. 20545 Attention: Chief, Public Proceedings Branch
Dear Sir:
This letter is submitted in response to the Commission ' s invitation for corranents on its proposed rulemaking entitled "Control of Releases of Radioactivity to the Environment," as published in the Federal Register on March 28, 1970. Ebasco understands the announced bases and considerations behind the proposed amendments to 10CFR20 and 50 regarding the releases of radio-activity to the environment. It believes, however, that these bases and considerations are not such as to warrant the proposed amendments to the regulations. The nuclear industry has made every effort to "encourage the main-tenance of radiation doses as far below this guide as practicable." The nuclear industry has and will continue to lead other industries in consider-ations of public safety. This has occurred and we believe will continue to occur without the proposed amendments. We feel that the AEC should wait until the radiation standards groups (ICRP, NCRP and FR.C) have completed their reviews of the current scientific evidence of low level, long term radiation effects and make recom-mendations for possible standard modifications before AEC proposes any modi-fication to the regulations in this area. Clearly, there is no present danger to the public from current levels of releases of radioactive effluents to the environment. As new technical developments are made to further reduce these releases, AEC should continue, as it has, to encourage applicants and licen-sees to adopt these technical developments through the informal licensing process. To add vague, general wording impossible of definite interpretation, such as has been proposed for 10CFR20, will accomplish nothing and risk con-troversy and legal actions, further delaying nuclear projects. The basic philosophy of keeping radiation doses as low below the current limits as
EB ASCO SERVICES INCOI\PORJ\TED practicable has already been well engrained in the nuclear industry. The professional pride and the economic and public relations incentives of in-dustry will assure that this philosophy will remain in force without the necessity of any new regulations. Besides, legal enforcement of releases below the standards of 10CFR20 might be difficult unless the Commission could make a showing that public health and safety were significantly endangered. To do this would be equivalent to saying the 10CFR20 standards are not pro-perly set. In addition to these basic comments, Ebasco has many additional comments relating to interpreting the specific wording of the proposed 10CFR50 amendments. We understand that AEC intends to invite members of the nuclear industry to meet with AEC officials to discuss in detail these proposed amendments as a group. We would welcome this approach and would be happy to send a participant outselves. Nevertheless, it might be helpful at this time to outline the basic comments and questions we have on these sections so that such comments and questions would be on the record prior to the meeting, or would be available in case the meeting is not called. The following is a summary of these conunents and questions: I. 50. 34 (2)
- 1) How is the new information requested different from what is currently supplied in PSARs and FSARs?
- 2) "Design objectives" as used in this subsection should either be compatable with the term "design bases" as used in AEC's Guide to the Organization and Content of Safety Analysis Reports or else the difference made clearer.
II. 50.34 (b) (2) (i) & (ii)
- 1) Currie quantities of radionuclides could be interpreted to mean either the total quantity of each potential radio-nuclide or the total curries for all radionuclides combined.
- 2) The type of station operation (i , e. normal operation, 1%
failed fuel, etc.) upon which there estimates should be made needs to be defined.
- 3) The AEC should realize that it is difficult to give any-thing but approximate numbers here because of all the variables involved and the preliminary stage the design may be in.
- 4) What action does the Commission intend to take if the estimates given in the FSAR are exceeded during operation?
- 5) The compliance of multiunit stations to these regulations needs to be better defined. For example, it is unclear whether the estimates required to be made should be on a per unit basis or per station basis or both.
./ EBASCO SERVICES INCORPORATED III. 50.34 (c)
- 1) The information requested appears compatable with the information currently contained in the 11 design des-cription11 part of current PSARs and FSARs and, there-fore, may be redundant.
IV. 50.36 (a)
- 1) Since the provisions of subparagraph (1) are included in 50.34 a (c), its addition here appears unnecessary.
- 2) Operation of the liquid and gaseous waste dis posal systems when the input of radionuclides to these systems are so low as to approach natural background, would do little to improve public health and safety, and yet, may increase maintainance problems.
- 3) The information required in the reports mentioned under subparagraph (2) is vage and general. A specific format listing all the information required including sampling frequency, type of instrumentation used, instrument sensitivity and so forth, would be necessary to obtain any usual information and be able to compare results among different stations. AEC should prepare a standard report form for this purpose and in-clude it as an appendix to 10CFR50.
- 4) What is meant by 11 *** If quantities of radioactive materials released during the reporting period are unusual for normal operations?"
- 5) The results of the station 1 s enviromnental monitoring program should be included in the reports and compared with what would be projected based upon measured station releases.
- 6) The phrase, 11 *.* the Connnission may from time to time require the licensee to take such action as the Commission deems appropriate," is quite a broad statement. We believe it would be appropriate to spell out what the Commission con-ceives its authority to be under this provision.
We are happy to supply these comments and questions and hope they will be of constructive use to you. Sincerely yours,
~~ R~
. J2.. fL l r_,c:s ~ E' ~ d , -'
IC..ct(flclrtc- n ,,,,-1-,
~
** ,;ULL. 2 " +~-tJ NATIONAL ACADEMY OF SCIENCES 2101 CONSTITUTION AVENUE fl r~ I {i',tJ' '""S ~ctdr~rirfiv,Jc, WASHINGTON . 0. C. 20418 May 13, 1970 Mr . Harold L. Price Director of Regulation U. S. Atomic Energy Commission Washington , D. C. 20545
Dear Mr. Price :
The National Academy of Sciences acknowledges and expresses appreciation for your invitation to comment on proposed amendments to the Atomic Energy Commission regulations concerning the control of releases of radio-activity to the environment, which the Commission plans to issue. Please be advised that the National Academy of Sciences has no comment to make with respect to these proposed regulation amendments . Sincerely yours, f-S.&...._ John S. Coleman Executive Officer
Rec'd Of f Reg, D te ,c, Time // .s:: :;;-
roe 't. 1 * '-i
*
- Q~t' I -0.0,'50 AMERICAN ELECTRIC POWER R~J:::lF Service Corporation Z
2 Broadway, New York, N. Y. 10004 (212) 422- 4800 May 18 , 1970 Mr . w. B. McCool , Secretary U. 8. Atomic Energy Commission Washington, D. c. 20545
Dear Mr . Mc Cool :
This is in response to the Commission' s invitation for public comment on a proposed amendment to 10 CFR 20. We support the Commission's objective of keeping radiation doses from light water cooled reactor effluents as far below the radiation protection guides as practicable. We have also noted that the Commission intends to consult the industry and other competent groups to determine the feasibility of developing more definitive criteria in connection with the proposed amendments . It is our judgment that such guidelines are not only feasible but vital to the implementation of the intent of the subj ect amendments . Without amplification the proposed amendments are vague and invite inconsistent inter-pretation by applicants and variable application by AEC Staff . We would be pleased to participate in any program established by the Commission and others to develop the requisite criteria *
. We concur with the Commission's view that "the releases of radioactivity in effluents from the light water cooled power reactors now in operation have been within ranges that may be considered 1 as low as practicable ' 11 and that advances in reactor technology will permit a further re4uction in the current ly very low levels of discharged radiation.
The requirement for specification of release design objectives in the construction permit application is reasonable as long as it is understood that accompanying design of equipment and systems, as well as development of procedures cannot be in substantive detail at the time of applicat ion for a construction permit. PD mem ( -~ ~r Assistant Vice President and Chief Nuclear Engineer
-c:::~~~-~*
/ 0 / c, C.
~~~ ~
7
.::::z~
<....,)
,'-?-~
c_ -
~
~ ~
PARTNERS SARGENT & K . W . HAMMING ENGINEERS W . R STEUR FO U NDED B Y FRE D ERI C K SAR G ENT -1 89 1 R . W . PATTERSON M . ZAR 140 SOUTH DEARBORN STREET L. E . ACKMANN R . N . BERGST RO M CHICAGO, ILLINOIS 60603 W. A . CHITTENDEN TELEPHONE - FI NANC IAL 6 - 7600 T. 0 . KOLF L AT R. I. G AV IN C ABLE ADDRESS - S AR L UN-CHICAGO
- 0. C. McCLI NTOC K CONSULTANT A . N . ELIASEN May 12, 1970 H.J. SLA G T E R H .G. S OUO EN L. R . STENS LA ND E . R. WEAVE R L.M. WHIT M ORE E.J. WO L N IA K Secretary u.s. Atomic Energy Commission Washington, D. c. 20545 Attention: Chief, Public Proceedings Branch
Dear Sir:
The proposed change to Title 10 Code of Federal Regulations, Parts 20 and 50, concerning the control of releases of radio-activity to the environment have been reviewed with interest and concern by those within our Firm who are engaged in the design and licensing of nuclear powered generating stations. Our comments follow.
- 1. New paragraph added to Section 20.1 of 10 CFR 20 - This is a general statement similar to that in the recommenda-tions of the FRC and ICRP. However, to *** " ~ every reasonable effort to maintain *** release of radioactive materials in effluents *** as far below the limits specified in this part!:.§. practicable"isso vague a requirement, that it can be the cause of grave delays in the licensing pro-cess. It is easy to envision the litigation made possible by the terms "reasonable effort" and "as far below *** as possible . " If the nuclear plant licensing process is to be maintained as an objective rather than sub j ective quasi-legal process, the applicant must have some definite criteria for the design of the radioactive waste handling system. The present wording appears to imply that some doubt does, in fact, exist as to the safety of the limits now published in this part. Every statement made recently by authoritative sci entists, including Dr. Lauriston Taylor, has stressed that the present standards for radiation pro-tection are perhaps the best founded standards in use today .
Why then is it necessary to i nsist on lowering these standards without some real basi s?
- . r,.
SARGENT & LUNDY - ENGINEERS CHICAGO Chief, Public Proceedings Branch May 12, 1970 Page 2.
- 1. (Contd . )
The present wording leaves the path open for an unnecessary, and possibly court required, insistance upon no radioactive effluent at all .
- 2. New Section 50 . 34a added to 10 CFR 50 - The information re-quired by this section is similar to that already supplied in most PSAR ' s except that this new requirement asks for more detail . This means that much more of a design effort must be made before the radwaste systems are described in the PS.AR . The statement made in paragraph (b) (3) as to 11 a description of the provisions for *** shipment offsite of solid waste 11 is not clear . Is the applicant supposed to describe the shipping casks, trucks, etc . , or just the drum that he will use to package the waste?
- 3. New Section 50 . 36a added to 10 CFR 50 - In paragraph (a) (2) it is required that reports be submitted to the Commission on January 1 and July l of each year 11 specifying total quantities of radioactive material released to unrestricted areas" during the previous six months . This statement does not make clear the extent to which the actual isotopes re-leased must be identified. The operating license for a plant usually specifies limits on the release rate for noble gases , halogens and particulates . Customary practice has been to record the total number of curies of tritium and unidentified radioisotopes released with the liquid effluent each year . Does this break.down of isotopes; noble gases, halogens and particulates, tritium, and un-identified mixture still hold for this new requirement or does the Commission want a more complete list? The answer to this will have a great effect on future plant operating practice .
Further, this section states that, 11 0n the basis of such reports *** the Commission may from time to time require the licensee to take such action as the Commission deems appropriate . 11 This statement allows the Commission to unilaterally take any action it deems appropriate, without any apparent bound. It would seem proper that whatever action is required by the Commission be limited to that required to comply with the limits of 10 CFR 20 or 10 CFR 100 as appropriate .
SARGENT 8c LUNDY - ENGINEERS CHICAGO Chief, Public Proceedings Branch May 12, 1970 Page 3. We appreciate the opportunity to comment upon these proposed changes. It is hoped that you will give careful consideration to these comments and to the final wording of these changes, so that the licensing process will not be placed in jeopardy. Very truly yours, J.
- Ward clear Licensing JEW/ph In Duplicate cc: Messrs. WRS RWP WAC
(
r~ \ ~ . ::~ \ F,WrOSED ,-{Ult: I -'J.fJ, 5{}
~ l
.:f 01 *r ut1on:
HLPrtc:e
- DR Miladi 119 Fi le MAt l 11970 Docket ffle. RPS Sa~Ntari at and Publtc: DoCUlllnt Room (2)
Attn: Stan Robinson Cong. 1. (2) 01 rector* s Offl ce
- kPS Protru Assistuca Branch. RPS A.ORA GLHuttan ssaf eutendlnon HLPrt ce
-70 s- -70 5- .. 70 -70
f
,J
""~.fcr.T NU:;;0£R
. Of'LJ~EO RULE R-~'9,5'{)
Q~ ef ~ -::I) DOCKETED
)?~~\
OOlEt OFFICE OF THE VICE PRESIDENT MAY 151970 ~ WASHING T ON Olilt'lOftlle S&UatlrJ rut!lc FraetrlllP smc* April 9, 1970
Dear Mr. Price:
Governor Boe has asked me to respond to your recent letter requesting comments concerning the proposed amendments to AEC regulations. The subject matter for which you requested comments is beyond the capabilities and resources of this immediate office. Nevertheless, we would like to suggest that your office make every effort to obtain recommendations and comments from the various states. There are several methods by which this could be accom-plished. One would be to solicit comments directly from the office of the Governor of states such as Minnesota. Another approach would be to contact Mr. Charles Byrley of the ational Governors' Conference for assistance. By way of seeking additional comment, the Office of Science and Technology might be helpful as a reviewing agency. Similarly, the review procedures outlined in BOB Circular A-85 have been most helpful in many instances. Thank you for bringing this matter to our attentipn. I hope this has been of some assistance to you. Sincerely, Assistant Director Office of Intergovernmental Relations Mr. Harold L. Price Director of Regulation Atomic Energy Commission Washington, D. C. 20545 Rec'd Of :.1Dir. f Reg.
,J./,f ., . A, 0ate-----=-.,_,_----
Ti e /.Lh.
Mr. Harold L . Price Director of Regulation Atomic Energy Conrmission Washington, D. C. 20545
po - ~ (s,rs* :i* ~7 kt\
DOCKE TED tl&AEC c d Ot Reg_ te 7iJ L
*rn J ~~--
. ,;. *~*, ,ii(,,:;,: ,:,;; ~*{.~ ~-'S'/J.:1./2t2,.~
- r. . lB. ,****-
, 00~\f#UHffiflJfJ
~ lkilU - ,ZJl)*** yr-s-r-1 G ERAL - C lc.v./* ii-ttaSPS ,d-*( ll11J,11 -
N U C L E A R E N E R G Y c1 f I vi' COMPANY ""-"~',j I DIVISION l!S CURTNER AVE., SAN JOSE, CALIF. 9S12S ** AREA CODE 408, TEL. 297*3000, TWX NO. 910*338-0116 May 4, 1970 Mr. Harold L. Price Director of Regulation United States Atomic Energy Commission Washington, O. C. 20545 Otf/e, rt ttle Prb//c~~ IErE
'.LIY l l 1970 Branch Ill
Subject:
Comments on Proposed Amendments to 10 CFR Part 20. and 10 CFR Part 50
Dear Mr. Price:
This is in response to your letter of March 26, 1970, forwarding copies
. of proposed cha_nges in Parts 20 and 50 of the Commission's regulations.
I understand that these amendments were published in the Federai Register~ Volume 35, No. 63 , of April 1, 1970. We agree with the principle proposed by the Commission of continuing to base the permissible limits of Part 20 on the recommendations of the Federal Radiation Council and of encouraging the industry to maintain radiation doses as low as practicable. We are pleased to note in its Statement of Considerations to the proposed amendments , that the Colffllission has affinned that the releases of radioactive materials in effluents ~ from power reactors now in operation have been within ranges that may be considered II as low as practi cab 1e."
*
- Further, in our analysis of these proposed regulations two threshold premi ses are important. In implementing the objective of maintaining the doses as "low as practicable," serious and objective consideration must be given to the availability and operability of nuclear power facilities. We believe that it is important not to jeopardize the availability of nuclear plants for which an application was filed prior to the effective date of the proposed amendment; for examples by requiring the installation of new systems or the modification of existing designs which might seriously alter the plant construction schedule or power
'production. We also believe that in seeking to be 11 as low as practicable 11 for plants for which an application is to *be filed after the effective date of the proposed amendment, it would not be in the best interest of
- r ,
Mr. Harold L. Price May 4, 1970 the country to select so low a value that economic el ectrical power production would no longer be attainable, or that plant reliability would be lost to frequent power outages (interruptions) which would be r required to meet such a value. Thus, it is important that the regulation be written in a manner which reflects the combined best interests of all aspects of the country's needs. In addition, it is important that the radiological effects of nuclear plants be kept in perspective with other potential sources of exposure. We believe that control of radiation exposure to individuals is a matter of total national concern on .a broad scope, and not a consideration for nuclear facilities only. Thus, regulatory agencies should utilize all methods of maintaining radiation exposure to individuals as low as practicable without placing that burden solely on the nuclear industry. For example, the use of diagnostic X-rays and certain building materials contribute to the accumulation of radiation doses to large segments of the population, and proper precautions in such areas could result in substantial exposure reductions. With regard to these proposed regulations, because. many of the aspects of radioactive releases are technical in nature and are subject to mis-interpretation and misunderstanding, it is important that they be drafted A so as to place the regulatory limitations upon radioactive releases in a meaningful and therefore proper perspective as a public safety matter. We believe that in large measure this could be accomplished if the regulations and their implementation specify dose limitations to persons in unrestricted areas along with the collateral information concerning quantity releases of radioactive material. This approach should prevail throughout the Commission's regulatory process and should obtain with respect to the design objective, the operating limitations, and the reporting of informa-tion to the Conmission and to the public. The Commission has proposed to consult with the nuclear power industry and *others for the purpose of developing definitive design objectives for keeping .radioactive materials in effluents as low as practicable. General Electric Company would be pleased to work with the Commission in develop-ing such definitive criteria for use within the industry. In this connection, the design guidance utilized by General Electric Company is that the incre-mental dose from a nuclear plant should not exceed five mrems to any off-plant person. Thi.s was selected as being small as compared with the Commission's permissible limiting dose of 500 mrems and is comparable to variations in natural background radiation dose at a specific location. We believe that a design objective such as this represents a value "as low as practicable." Further technical discussions with the Corrmission are desirable and needed to develop unambiguous working definitions of the ,design objective and of
GENERAL~ ELECTRIC Mr. Harold L. Price May 4, 1970 related operational limits. We would encourage the Commission at this time to consider a design objective of five mrems/yr to individuals as the dose which satisfies the "as low as practicable" concept for long-term dose to off-site individuals. Present AEC calculational methods result in doses to a location or position, and thus are misleading if
*not. accanpanied by doses to individuals under realistic , 1ong-tenn circum-
_stances. Thus, using AEC analytical practices we would recommend a design objective of 25 mrem/yr to any location off-site, and si milarly we would
. recommend an operating limit of 100 mrem/yr. While it might be necessary to temper such objectives with specific site considerations, it does not detract from the need for the AEC to translate the concept of "as low as practicable" into quantitative design and operating objectives. Only by doing so will it be possible to avoid a decision on a project-by-project review.
We observe in the Commission's proposed amendments that additional effort will be required by the applicant (a) when the construction permit is pre-pared to present operating and mainte~ance procedures for the radwaste system and (b) semiannually to report on doses and releases resulting from plant operation. These additional efforts are justifiable if they contribute to the public understanding of the smal1 impact that the nuclear power plant has on the environment.
*We have more detailed comments on both the proposed amendments to 10 CFR 20 and 10 CFR 50 and the Cornnission's Statement of Considerations which preface
.the amendments. Those comments are included as Attachment A and Attachment B to this letter. We will be pleased to meet with you at any time to par-
. ticipate in development of the design objectives, to discuss any of our comment~, and to explore implementation of the proposed ~egulations.
Sincerely,
/7//u~
V.~J:~~tt Vice President djc Attachments cc: Secretar~ U. S. Atomic Energy Conmission I,_
ATTACHMENT A .,f- J(.at:lt 1Mr 1-, r,,(' Jl,ln ~rut> I' Suggested Changes By General Electric Company to Proposed AEC Amendments to Its Regulations in 10 CFR Part 20 and in 10 CFR Part 50 Item I Y20. 1 C AEC Proposed Wording 11 make every reasonable effort to maintain radiation exposures and releases of radioactive material in effluents to unrestricted areas as far below the limits specified in this part as practicable. 11 GE Proposed Wording 11 make every reasonable effort to maintain radiation exposures from releases of radioactive materials _in effluents to unrestricted areas as far below the limits specified in this part as practicable. 11 GE Comment This will clarify that the prime control limit is dose to individuals in unrestricted areas from releases from radioactive material. ltem II f 50. 34a (b) AEG Proposed Wording 11 (b) Each application for a permit to construct a light water cooled power reactor shall include: (1) a description of the equipment to be installed pursuant to paragraph (a) of this section; (2) an estimate of (i) curie quantities of radionuclides expected to be released annually to unrestricted areas in liquid
. effluents produced during normal reactor oper-ations; and
(ii) curie quantities of radioactive noble gases, halides and particulates expected to be released annually to unrestricted areas in gaseous ef-fluents produced during normal operations; 11 (3) a description *** and from other sources . GE Proposed Wording 11 (b) Each application for a permit to construct a light water cooled power reactor shall include: (1) a .description of the equipment to be installed pursuant to paragraph (a) of this section; (2) an estimate of (i) quantities of radionuclides in appropriate emission rate or concentration units expected to be released annually to unrestricted *areas in liquid effluents produced during normal operation, and the range of the radiation doses expected to be received
*annually by persons in unrestricted areas from such quantities .
(ii) quantities of radionuclides in appropriate emission rate or concentration units expected to be released annually to unrestricted areas in gaseous effluents produced during normal operation, and the range of the radiation doses expected to be received annually by persons in unrestricted areas from such quantities . 11 (3) a description *** and from other sources. GE Comment As noted in Comments 2, 3, 4, 5 , 7, 8 , and 9 in Attachment B, the proper measurement for evaluation of plant performance re - garding radioactive effluents is consideration of the dose received by persons off-site developed from an examination of the various exposure pathways and th~ estimated releases in any calendar year period. The wording suggested by GE would require the applicant to provide an estimate of the range of the doses to persons offsite resulting from radionuclides released from the facility in both the
liquid and gaseous effluents, as well as the quantities of such radionuclides, from which comparison with established dose limitations could easily be made.
...... Item III Y50 .3 6a GE Comment In paragraphs (a) and (b) the provisions of Paragraph 20. 105 of 10 CFR Part 20 should be included also for the reasons noted in Comment 1 of Attachment B .
Item IV 150. 3 6a (a) (2) AEC Proposed Wording 11 (2) The submission of a report to the Commission within 30 days after January 1 and July 1 of each year specifying total quantities of radioactive material released to unrestricted areas in liquid and gaseous effluents during the previous six months of operation and such other information on releases as may be re-quired to estimate exposures to the public resulting from effluent releases. If quantities of radioactive materials released during the reporting period are unusual for normal reactor operations , including expected operational occurrences, the report shall cover this specifically. On the basis of such reports and any additional information the Commission may obtain from the licensee or others, the Commission may from time to time re-quire the licensee to take such action as the Commission deems appropriate. 11 GE Proposed Wording 11 (2) The submission of a report to the Commission within 30 days after January 1 and July 1 of each year specifying total quantities of radioactive material, expressed in appropriate exnission rate or concentration units, released to unrestricted areas in liquid and gaseous effluents during the previous six
months of operation and which provides an estimate of the radiation dose received by persons in unrestricted areas from such releases from the facility. If quantities of radioactive materials released during the period, and the resulting doses to persons in unrestricted areas, are unusual for normal reac-tor operations, including expected operational occurrences, the report shall cover this specifically. On the basis of such re-ports and any additional information the Commission may obtain from the licensee or others, the Commission may, in accordance with these regulations, from time to time require the licensee to take such action as the Commission deems appropriate." GE Comment As noted in Comment 7 of Attachment B and Item II above, evalu-ation of facility performance should properly be based upon doses to people rather than simply on releases of radionuclides to the site boundary. Similarly, decisions by the Commission to require remedial actions should be based on dose considerations . Item V --~ YSO. 36a (b) No comment except as noted in Item III. Item VI Add the following paragraph 50 . 36a (c):
"(c) The Commission may issue semi-annual reports which summarize the dose contributions to persons in unrestricted areas resulting from operation of all reactors in the United States licensed under this part. The reports shall also sum-marize remedial actions deemed appropriate by the Commission with respect to release of radionuclides and the resultant doses . 11 GE Comment It is suggested that the Commission foster a program of pro-viding timely, composite information to the public and industry regarding doses from radioactive e_ffluents to persons in
...... unrestricted areas arising from operation of the nuclear facili t ies
- Such information could contribute to improved public understanding and would serve as reliable source information for those making independent judgments regarding plant impact upon the environ-ment.
ATTACHMENT B Comments on the St atement of Considerations Prefacing the Proposed AEC Amendments to 10 CFR Part 20 and 10 CFR Part 50 GD.&iE , ED iaAE~ MAY l 11970*
- 1. Basis for AEC St andards Offlct It th SGr.nbrJ Nae,~ -~
AEC St atement 11 Releases of radioactive materials in effluents by Commission licensees are currently regulated under the provisions of 10 CFR § 20 . 106 which apply to all uses of byproduct, source, and special nuclear material licensed by the Commission. 11 Comment l Section 20 . 106 considers concentration in unrestricted areas, and therefore, is not valid where the limiting mode of exposure is not due to the concentration at the point of exposure . The principal example of this deficiency is the emission of radio - gases to atmosphere from an elevated release point, whereby a principal contributor to dose in the immediate environs may be from the overhead plume which has not yet diffused to produce a significant concentration at the point of exposure near the ground surface. The values in Appendix B of 10 CFR Part 20 are inadequat e for any radioisotope where the limiting mode of exposure is indicated as being from 11 submer s ion 11 in the cloud. This is generally the case from the radiogases such as krypton and xenon. The limits listed are the concentration required to deliver a dose of 500 mrems if one stood at the center of an 11 infinite 1 1 hemisphere on the ground all year . For the cloud to be "infinite" in size re-quires a radius of the order of a thousand feet. When the cloud radius is a few hundred feet, the dose rate based on concentration is overestimated by a fac t or of 2 to 3 . In the practical case of a stack plume, concentrations will vary in all three dimensions, so a part1cular concentration at a point is not indicative of actual dose rate . With the usual case of radiogas emission from an elevated release point such as a stack, and with site boundaries in the 1/3 to 1/2 mile range , most of the time the radiogas p l ume is still well overhead
as it passes off- site. Thus the matter of particular interest is dose rate from the overhead or surrounding plume wherever it may be, rather than concentration. The dose in any period can be measured directly, so there is no need to measure concentration. Thus for this aspect of waste disposal, it is necessary {and proper) to use the permissible dose of para-graph 20. 105. _2. Guidance on Low Radiation Doses AEC Statement 11 The Commission believes that, in general, the releases of radioactivity in effluents from the light water cooled power reactors now in operation have been within ranges that may be considered *as low as practicable. 1 The Commission also be - lieves that, as a result of advances in reactor technology, further reduction of those releases can be achieved. 11 Comment 2 The continued use and reference to the amount of radioactivity in effluents, rather than the resultant radiation dose to any actual person, causes public misunderstanding. It is recom-mended that all considerations be in units of 11 mrems per year, 11
-=--- so that a proper comparison to 10 CFR 20 dose limits can be made . An obvious example of the need for proper units, is the case of equal emission rates, from stacks of significantly different height, where certainly the taller stack will be a closer approach to 11 as low as practicable, 11 but not for reason of re-
. duced radioactivity in effluents, but because a lower dose to any per son will result.
Further reduction in any emission rate can always be achieved by retention for additional radioactive decay. An important consideration for "further reduction of these releases" will be the actual reduction in radiation dose delivered to any person, and the significance of that reduction compared to natural back-ground dose and the natural variation of background. It is not simply a matter of deciding whether the technology exists to further reduce the 11 releases of radioactivity in
,. I effluents. 11 It is also important to evaluate the effect of such systems on plant operability and availability versus the re-duction in doses they may produce.
- 3. Guidance on Low Radiat ion Dose AEC Statement "In connection with the proposed amendments set out below and in the light of progress in fuel element technology and in waste treatment and handling systems, the *commission plans to con-sult with the nuclear power industry, per sons engaged in appli -
cable research and development programs, and other competent groups to determine the feasibility of developing more definite criteria for design objectives and means for keeping releases of radioactivity in effluents from light water cooled power reactors during normal operations, including expected operational occurrences, 'as low as practicable' . 11 Comment 3 The Nuclear Energy Division of the General Electric Company will be pleased to contribute to the adoption of ' :definite criteria. 11 Our recommendations will be based on the relationship between "as low as practicable" and the incremental radiation dose from plant operation to any actual off- site per son. One valid bench-ma:rk for reference is natural background radiation of about 140 mrems per year, with wide variations by locality. Also that for any location, variations with time of a few percent of the average may be expected. Thus a natural variation of perhaps ten mrems per year would not be unusual. As you know, General Electric's Nuclear Energy Division has been using for design guidance for about five years, and has previously proposed, that the incremental dose from the nuclear plant should not exceed the order of five mrems per year to any actual off-plant person. This was selected as being small compared to the per-missible dose of 500, the natural background of 140, and even the background variation of perhaps 10 mrems per year. We believe that a design objective substantially lower than five mrems per year will make contributions insignificant to "public health and safety, 11 and any criterion based on substantially less than five mrems
per year is clearly without discernible social value, and has clearly reached the limit of 11 as low as practicable. 11 Any valid criterion should be based on a radiation dose objective in units of mrems per year . We find that much of the public misunderstanding arises by confusion on the technical significance of "concentrations" and 11 quantities 11 of radioactive material.
- 4. Control of Exposures from Several Different Sources AEC Stat'ement 11 The Commission expects that releases of radioactive material in effluents from light water cooled nuclear power reactors under the present system of regulation will continue to be low.
At the same time , the Commission recognizes that there will be a marked increa se in the number a nd si z e of nuclear power reactors in operation in the future , and that other activities that contribute radiation exposure t o the public can be ex-pected to increase *. " Comment 4 Regulation 10 CFR 20 covers radiation dose to any 11 individual 11 (defined as a human being) from licensed sources or other sources under the control of the licensee. Therefore , any proper design criterion in terms of radiation dose per year to any individual would apply across the board to any individual neighbor of licensed facilities whether they be single, multiple under one licensee, or multiple under different licensees . The anal yses of the extent to which neighboring facilities may have an additive effect is straight - forward for either atmosphere or waterway. If the design criteria are based on an incremental radiation dose objective which is insignificant compared to either per missible or n atural background dose, there will be no problem with inte r fe r e n ce with dose contri - butions from "other activities . 11
- s. Design Objectives for LWCPR AEC Statement 11 * *
- In addition, in the case of an application filed on o r after the effective date of the proposed amendments , the application
would be required to identify the design objectives, and the means to be employed, for keeping levels of radioactive material released in effluents as low as practicable. As in current practice the Commission would review the proposed design of the reactor, including the waste treatment equipment arid the description of procedures for the maintenance and use of the equipment., to determine whether the required design objectives are met. 11 Comment 5 As abov~, we recommend that "design objectives II be in units of radiation dose in mrems per year . With regard to provision of waste treatment equipment, and plans for its operation and maintenance, such should be in line with achieving 11 des1gn objectives" with reasonable margins pro - vided for "expected operational occurrences . 11 The oper.ation of the equipment provided should be such as normally to achieve the "design objectives . 11 Any connotation that equipment should always be operated merely because it had been provided., would be detrimental, and would have the effect of inhibiting the desir-able provision of facilities with ample margins and of facilities necessitated for infrequent but expected operational occurrences .
- 6. Technical Specifications, pages 5 and 6 AEC Statement 11 Each license authorizing operation of a light water cooled power reactor would include technical specifications which would require adherence to operating procedures for control of effluents and the maintenance and use of equipment installed in the waste treatment system~ *** * "
Comment 6 Such operating procedures called for in technical specifications should include requirements for operating waste treatment to meet the off-plant "design objective" radiation doses., and any requirement to operate equipment to further minimize releases would seem to be unnecessary.
- 7. Technical Specifications AEC Statement 11 * *
- and the submission of semi-annual reports containing information on quantities of radioactive material released.
If quantities released during the reporting period are unusual for normal reactor operations, including expected operational occurrences, the licensee would be required to cover this specifically in its report. The effluent release data submitted by licensees would be compiled by the Commission and made available to the public. 11 Comment 7 We have noted considerable public misunderstanding arising from the simple reporting of 11 quantites of radioactive material released. 11 Without proper statement of the radioisotopes in-volved, their half-lives, their method of dilution or diffusion into the environment, and the protection afforded by the ex-clusion area, the proper significance of the release in terms of dose to man via the critical exposure pathways is not evident. The practice of reporting 11 quantities 1I is particularly mis - leading when summaries of such data report quantities discharged per year, when in many cases the radioisotopes involved have half-lives short compared to the year, and thus the quantities re - ported have no relationship to reality. This practice is additionally troublesome when a comparison is made to 11 permissible 1I quantities specified in Technical Specifications. Our experience over the pas,t eleven years in attempting to establish emission limit s which are truly equivalent to the permissible doses of 10 CFR 20 has been that the safety evaluation document requires that many factors of conservatism be included in such evaluations. This has the effect that published summaries by the AEC make the emissions from operating plants appear more significant than is truly the case. This, we believe, is a disservice to industry, the regulatory agen-cies, and the public. Such hidden conservatism in Technical Speci-fication limits will become even more improper, when 11 design objectives" are formally established at some small fraction of 10 CFR 20 permissible dose .
It is recommended that licensee reports be required to include sufficient information concerning releases to permit estimation of dose via any exposure pathway at off - site locations and to off- site individuals, and that such estimates be required. Also it is recommended that such reports include the actual environs monitoring data to show actual measurement of such doses, and such interpretation as may be needed to estimate dose to any actual person. The principle should be established that the results of environs monitoring should feedback to adjust permissible emission rates as appropriate . There appears to be a reluctance to consider such modifications . For example, on Humboldt Bay the initial calculation was that an emission of 200, 000 pc/ sec was equal to a fence post dose of 500 mrems per year . Due to a lack of on-site wind data, this was reduced to 50, 000 ;ic/ sec in the Technical Specifications . After two years operation, data were presented which showed the relationship to be 210,000;ic/sec for 500 mrems/yr, but a corresponding adjustment in the Technical Specifications limit was not approved. Environs monitoring in subsequent years has consistently indicated that the 50,000 pc/ sec limit is low by a factor of 2 to 3 relative to the radiation dose to any off- site point. So the plant performance and its public image are viewed against an unrealistically low limit. Indeed, the August 1969 JCAE review on pages 116- 117 says that Humboldt Bay operated at 57% of its permissible gas release for all of 1967 and 1968 . Based on measure - ments in the environs, a better estimate would be that at any point the actual dose was in the range of 20-30%, and that actual dose to any person was about 5% of permissible. To overestimate the environmental effects of the plant by a factor of ten is undesirable from any reasonable viewpoint. It is noted that AEC Commissioner Thompson, in his testimony presented to the JCAE on October 30 , 1969 , had this to say about Humboldt Bay:
"While one reactor, Humboldt Bay, released 57% of the authorized limit for noble gases in 1968, actual measure -
ments of radiation levels offsite show that maximum potential exposures near the site boundary were only about 10%-20% of FRC radiation protection guides for individuals in the population. 11
- 8. Technical Specifications AEC Statement 11 On the basis of existing technology and past operating experience the Commission expects that light water cooled power reactor waste treatment systems designed and operated in accordance with the requirements set forth in the proposed amendments to Part 50 will help to assure that releases from light water cooled nuclear power reactors will generally not exceed a few percent of the annual maximum limits specified in Part 20 and in license con-ditions, and that radiation exposures to the public resulting from the normal operations of light water cooled power reactors will not exceed small fractions of exposures from natural background radiation and of FRC radiation protection guides . 11 Comment 8 Our interpretation of this semi - quantitative definition of 11 as low as practicable 11 is given in terms of 11 radiation exposure to the public . 11 Natural background radiation is about 140 mrems per year . The FRC radiation protection guides are basically exposure of individuals of the general public to not more than 500 mrems per year, with the long-term average to large population groups not greater than one - third of this for genetic considerations. Our position has been that an increment of 5 mrems per year actual dose to any person is a 11 small fraction" and is 11 as low as practicable. 11 It has been the custom that "license conditions" are written in terms of emission rates or concentrations which are related to
,, radiation dose to any off-site location without consideration of whether actual exposure is received at that location all year .
For emissions to atmosphere, we find that Technical Specifications limits based on dose to the least favorably located fence post at the plant boundary are probably 3 to 10 times higher than that received over the year by any actual person. Factors involved in this differ-
- ence include: more favorable location of the actually occupied point~
fractions of time when an individual is actually present, and shielding provided by structures, etc . For releases to a waterway, we find that Technical Specifications limits based on concentration in the plant discharge canal are c_o nservative by a factor of five minimum, considering the dilution available in the waterway, even where this
- s a river used as a domestic water source.
'"( . ... If the practice of basing Technical Specificat ions limits on fence posts and discharge canals continues, it is our recommendat ion that the difference from people dose be recognized by a factor of five . Thus a 11 few percent" of 11 license conditions" should be about 5% of IO CFR 20 limits, or 25 mrems per year based on 10 CFR 20 permissible dose of 500 mrems per year . Usually any variations in actu~l emission during 11expected operational occurrences" will be for periods short compared to the calendar year permissible dose period, so it is recommended that limits include a factor of 3 to 4 for such occasions .
- 9. Monitoring AEC Statement 11 The Commission will continue to evaluate exposures to the public from releases of radioactivity in effluents from nuclea r power reactors . Reactor licensees are presently required to carry out monitoring programs designed not only to determine levels of radioactivity in effluents released from the plant but also to detect significant increases in levels of radio-activity in the environment. The licensee is required t o r eport these data to the Commission on a periodic basis .*** 11 Comment 9 It is recommended that the Com.mission's evaluation of "exposures to the public" be published routinel y, in terms of mrems per year to individuals and large population groups for the various potential exposure pathways . The present reporting of curies per year re -
leased compared to Technical Specifications limits, which in many
-. cases are not related to the permissible dose of 10 CFR 20, is insufficient for proper judgment of the propriety of waste disposal operations .
We would strongly support the concept that adequate environs monitoring and reporting of results is of basic importance in judging conformance to permissible dose requirements . We also find that proper analysis of such data would be of great value for use in public understanding programs . Too often, environs monitoring data, if available for public use, is uninspired tabula-tion of raw data, with interpretive conversion to estimates of people dose usually lacking. The present and past environs monitoring effort has been adequat~, based on the 11 close to zero 11 results found
in most programs, but the continual proof of the insignificance of the insignificant has* proved essential for public understanding . Research and Development AEC Statement 11
***
- The Commission will continue to encourage and support research and development programs which contribute to the ability of the nuclear power industry to minimize releases of radioactivity to the environment. 11 Comment 10 Goals for such research and development should be established in terms of a low dose in mrems per year to any neighbor .
Expenditures to achieve an objective less than a few mrems per year should be evaluated carefully. Such a dose objective, of course, would result in a small incremental exposure to only the closest of the neighbors . Average exposures to large popu-lation groups would be lower by a factor of a hundred or more from releases to atmosphere, and lower by a factor of ten or more from releases to a waterway even if used as a domestic water source .
,-, If it is considered important to control dose contributions to large populations of less than a mrem per year , such R&D funds could achieve vastly greater returns if applied other than to nu -
clear power plants . Better control of diagnostic X-ray dose with no sacrifice to medical requirements , as repeatedly recom-mended by K . Z . Morgan of ORNL, would seem the most productive . Proper columnation of the beam alone would reduce the gonadal dose of. the entire population by several tens of mrems per year . Restriction on the use of building material s of high n atu r al radio - isotope content, it is guesstimated would reduce the radiation d os e to the entire population by 5 to 10 m r ems pe r y ear . Restriction on occupancy on those portions of the nation above, say, the 4000 foot elevation, would reduce the average cosmic ray dose to the entire population by perhaps o ne m r em per year , and for the i ndividual s cur r ently a t high e leva t ions would r educe their d os e by _s evera l t e n s o f m rems p er yea r.
' Due to the additional cosmic ray dose received in commercial airplane flights, it is estimated that the elimination of air traffic delays would shorten time aloft to the extent that the incremental radiation dose per flight per passenger would be reduced about O. 1 mrems .
Al~ such other possibilities to reduce radiation effects need t o be weighed on a national basis against the single premise of just decreasing releases from nuclear powe r plants below a n already low design obje c tive .
r
- I
' ~~
.
- WESTERN INTERSTATE P. O.
NUCLEAR BOX 1!5!509 BOARD LAKEWOOD. COLORADO 8021!5
~ 4 R DR. ALFRED T . WHATLEY EXECUTIVE DIRECTOR May 5, 1970 OCKETED ff&AEC Mr. Harold L. Price AY 111970 Director of Regulation Office of Ille Santa,y United States Atomic Energy Connnission Public Pl'OC?edlnp Washington, D. c. 20545 Branch
Dear Mr. Price:
On behalf of the Western Interstate Nuclear Board , I wish to thank you for asking us to connnent on the AEC's proposed changes to 10 CFR 20 and 10 CFR 50. We are more than pleased to do this and have two comments that we would wish to make . The first connnent * *
- We feel the same set of standards that are applied to light water reactors can also be applied to processing plants and to other types of reactors. We would , therefore , encourage you to broaden the scope of the amendments to include all reactors and fuel processing plants.
Secondly * *
- It is our feeling that every effort should be made to arrive at numerical recommendations which would provide reactor manufacturers and utilities with goals towards which to work . I am personally confident that much can be done at a reasonable cost to reduce radioactive effluents from those plants now being designed. In addition, we hope you will encourage those people now operating reactors to study what could be done in a practical sense to lower their radio-active effluents . We feel that voluntary action ~n the part of the i ndustry would add considerably to their image in the eyes of conservation and environmentally concerned citizens .
A.
- Whatley Executive Director ATW/dls WESTERN INTERSTATE NUCLEAR BOARD P , O . BOX 1!5!509 e LAKEWOOD . COLORADO 8021!5 e ( 303 ) 238- 8383
Rec'd Off. ~~ o/ Reg.
,.* L .ry Date Slfh..!.
lime_ , * ~ i Mt IL 1 ._.,v, L,;, ..,[Ci\ON
/Q~1,,1 o
f d tcrs r< r.. I tt,. ~ ,,s oft U.S. DEPARTMENT OF COMMERCE
' I H, ~" R/(_ d t<, d ~ /, ,,,-(,_,
ENVIRONMENTAL SCIENCE SERVICES ADMINISTRATl6¥: US,:'i. ,(Ulf - Z cJ f- ~ - p ROCKVILLE, MO. 20852 AY 4 1970 Mr . Harold L. Price Director of Regulation U. S. Atomic Energy Commission Washington, D. c. 20545
Dear Mr . Price:
Thank you for your letter of March 26 , 1970, and the opportunity to comment on the proposed amendments to AEC regulations concerning the releases of radioactivity to the environment. We completely agree with the intent of these amendments as an important step in the preservation of environmental quality . We note in particular the Statement of Considerations , "Monitoring" and the proposed news 50. 36a Technical. Specification **** require-ments for documenting and reporting on radioactivity release . Research on atmospheric transport and diffusion of material performed for many years by ESSA under the sponsorship of the AEC, and more recently by the National. Air Pollution Control Administration, DHEW, has shown the value of meteorological. measurements of wind to analyses of emitted material and their role in increasing the efficiency of monitoring networks . You may therefore wish to consider the specification of meteorological. instrumentation as a necessary part of the monitoring system . We would be happy to work with your staff on such specifications if they are considered necessary . Sincere1y,
~0-~c:lL bert M. White dministr ator COAST AND GEODETIC SURVEY ENVIRONMENTAL DATA SERVICE WEATHER BUREAU INSTITUTES FOR ENVIRONMENTAL RESEARCH NATIONAL ENVIRONMENTAL SATEL LITE CENTER
*J
- J.
- A uiJf;l{ET NUMBER PROPOSED RUlE PR- d..D/SD
~,J~
- VIRGINIA ELECTRIC AND POWER COMP.ANY R. .;i_~ . . .'1__ 1'
+/-:.:.;
RICHMOND, VIRGINIA 23209 May 5, 1970 OCUJ£a UMR Secretary U. S. Atomic Energy Commission AY 71970 Washington, D. C. 20545 Office of 1h .....,
,.ftcfllcect1111 Attention: Chief, Public Proceedings Branch
Dear Sir:
This is in response to the invitation to conment upon the proposed amendments to the AEC regulations concerning the control of releases of radioactivity to the environment, as publi~hed in the Federal Register of April 1, 1970. We have reviewed the proposed amendments and conclude that we are in agreement with them. While not previously codified in the regulations, we would like to acknowledge the fact that this Commission policy relative to radiological releases to the environment has been one of their foremost admin-istrative objectives for as long as we have been concerned with AEC regulatory practices; which covers a period of some twelve years. In tne proposed paragraph (c) for 10CFR20.1, the last eleven words in the paragraph, 11 as far below the limits specified in this part as practicable, may be subject to arbitrary or emotional interpretation, producing substantial delays and perhaps increasing costs, unless it is closely affiliated with further interpretive language. The "Statement of Considerations" associated with this proposed amendment essentially serves this purpose at this time; how-ever, since it is not proposed to be embodied in the regulations, its value as a reference may tend to become remote. To resolve this situation, it is suggested that the substance of the " Statement of Considerations" be added to 10CFR8 as an interpretation of Section 3d of the Atomic Energy Act of 1954, as amended, thereby bringing this material into closer affi.liation with 10CFR20 and other applicable parts of the regulations. It is suggested that the form could be improved if the proposed additions to 10CFR50 were restructured so as to avoid the potential confusion between the serial designations 50.34a and 50.34(a) , and 50,36a and 50,36{a). We appreciate the opportunity to comment on the proposed amendments and it is hoped that the above comments will be of assistance to you in finalizing this amendment. Very trul y your* ~ .,.,_ ..._
S ATE O F MINNESOTA DEPARTM ENT OF' HEALTH DOCKE,ED 717 DELAWARE STREET S. E. IJQlEC MI NNEAPOLIS 55440 April 15, 1970 Eber R. Price , Director Division of State and Licensee Relations United States Atomic Energy Commission Washington , D. C. 20545
Dear Mr. Price :
In regard to t he proposed amendments to A.E.C. regulations concerning control of releases of radioactivity to the environment , paragraph 50.34a(b)(3) requires "description of provisions for packaging, storage and shipment offsite." Howevez: , no provision for measurement for curie quantity estimates or reference to other Parts (e . g ., 10 CFR Part 70 or Part 73 ) which may be applicable are noted. Paragraph 50. 36 refers to "operational occurrences." No definition of this term is stated to clarify its meaning or distinguish it from "normal reactor operations . " We would appreciate your consideration of these comments concerning t he proposed amendments . Yours very truly , Frederick F. Heisel, Director Division of Environmental Health
,-,tp_ /2 J
DOCKET NUMBER lll)D.u~EO \.\.f.; ~ R-;;).~ 50 719 1HIRTEENTH STREET, N.W. (SUITE 503) WASHINGTON, D. C 20005 (202) 737-0668 May 4, 1970 OFFICERS Secretary H . G. SHAKESPEARE U.S. Atomic Energy C0111Dission Prendem Kalamazoo, Mich. Washington, D. C. 20545 A. GITILESON PimViuPmidenl Hicksville, N. Y.
~= Chief, Public Proceedings Branch H .F. I.ARSON
Dear Sir:
Second Vice Pre!itlenl Milwaukee, Wis. A. R. BENSON I am writing pursuant to your Notice of Proposed Rule Making, Atomic Energy Third Vice Pre1iden1 Commission (10 CFR Parts 20, SO], Control of Releases of Radio-Activity to East Berlin , Conn. the Environment, that appeared in the Federal Register, Vol. 35, No. 63: T. C. LUND Tr,,u,wer 5414-5, Wednesday , April 1, 1970. Kansas City, Mo. Please accept my support and endorsement in principle for the proposed changes, EXECUTIVE STAFF which seek to keep exposures to radiation and releases of radioactivity in R. H . STROUD water and air effluents from light-water-cooled nuclear power reactors" as Execuli11e Vice Pre1iden1 low as practicable." R.G. MARTIN A111. Exec. Vice Pre1iden1 At the same time, it seems to me that it would be helpful to set numerical P.A. DOUGLAS criteria as guidelines for minimum performance, based on the encouraging Executive Secr,tary operations record of experience. This would have the benefit, it seems to me, of enhancing public acceptance of nuclear power generation and add to DIRECTORS public confidence in the safety of this relatively new technology. A .]. BoEHM Chicago, Ill. I therefore respectfully recommend and urge that the proposed operational
] . L. CHANDLER criterion, "as low as practicable," be defined to mean "generally less than Cortland, N. Y. one percent of permissible releases of Noble and activation gases, and of L. W. CUMMINS halogens and particulates in gaseous effluents, and less than one percent Walla Walla, Wash.
of permissible releases of mixed fission and corrosion products and of R. F. LAPPERTY Tulsa, Okla tritium in liquid effluents released from power reactors." Under this definition, such special problem situations as may exist from time to time T. T. LENK Teaneck, N. J. would come under close scrutiny by the AEC, when such releases may temporarily C. E. LIND be greater than one percent, with every effort made to reduce same below the Chicago, Ill. one percent level within a reasonable period, hopefully by the second year J. G. MAYER of operation. South Otselic, N. Y. D . S. MORRISON Lititz, Pa. ~ urs, R. B. MORTENSEN Highland Park, Ill. H. G. WILLIAMS DOU£ ~i.3 Morgan, Ulllh Richard H. Stroud t!SA£C Executive Vice President L. WOLFRAM Dowagiac, Mich. RHS : k 61970~ ot11ce 8' tile seeratVJ Public f'nC'!~dllP Brantll
DOCKET NUM'SER PR P.O. BOX 3100 MIAMI, FLORIDA 33101 eRoP.osEo RULE - aO 150 e 1 P..s 1~~ . S::1=11! FLORIDA POWER & LIGHT COMPANY April 9, 1970 Mr. Harold L. Price Director of Regulation
- u. S. Atomic Energy Commission Washington, D. c. 20545
Dear Mr. Price:
Thank you for your letter of March 26 enclosing copy of proposed amendments to AEC Regulations concerning the control of releases of radioactivity to the environment. Very truly yours, George Senior GK: std DOCUTE D UatEC MAY 61970 OfflCe tf-flle SehtwJ Pulte MeielllllCI 1nnc!I' a.J'C4..,_
- I Timi:. _ lj HE L P I NG B U I L D F L ORIDA
P O BOX 999 , RICHLAND , WASHINGTON 99352 / TELEPHONE 509-942-1111 April 1, 1970 Mr. Harold L. Price Director of Regulation United States Atomic Energy Commission Washington, D. c. 20545
Dear Mr. Price:
Thank you very much for your letter of March 26, 1970, and the copy of the proposed amendments to AEC regulations concerning the control of releases of radioactivity to the environment. In addition, your colleague, Les Rogers, was kind enough to review a copy of these proposals with Dr. L. s. Taylor, of the NCRP, and myself when I was in Wash-ington last week. It is my belief that the changes are well conceived and are highly responsive to what relatively conservative pro-tectionists have been shooting for. There has been a long-standing difficulty in interpreting the qualitative intent to hold releases to the lowest practicable level in a manner that would satisfy the rigor of the legal mind. I feel that the new version is a decided victory for the side of common sense in this issue. It is perhaps unfortunate that these changes were not voluntarily made some years ago. The Commission's critics will undoubtedly claim that these changes are a victory for such forces as Drs. Gofman and Tamplin, even though this is not really the case. Consultant to the HM Parker:np OPERATING THE PACIFIC NORTHWEST LABORATORY FOR THE UNITED STATES ATOMIC ENERGY COMMISSION
.. WASHINGTON, D.C. 20426 IN REPLY REFER TO: IGCUJED fJltiC Mr. Harold L. Price MAY 61970* Office of Ille _..., Director of Regulation l'nllC~fll U.S. Atomic Energy Commission lrUCI ch.4 Was hington, D. C. 20545
Dear Mr. Price:
This letter is in response to your communication of March 26, 1970, inviting comments on the recent publication in the Federal Register of proposed revisions in 10 CFR Parts 20 and 50, related to "control of releases of radio-activity to the environment." We have given consideration to the subject matter of the proposed amendment and the reasons behind it. In general, it appears to us that there is a worthwhile objective in the AEC's undertaking to modify the use of existing radiation standards in the direction of minimizing actual releases of radioactivity from light water cooled nuclear power plants. With respect to the specific regulations proposed, we have the following comments:
- 1. We make the general observation that the basic objective of all standards for controlling the release to the environment of any deleterious effluents is to minimize harmful biological effects in the biosphere. Consequently, we believe that ideally the preferred method of administer-ing standards with respect to the re lease of any such effluents would be measurement of biological damage. Varying biological effects can be presumed to result from chemical, thermal and radiological qualities of air and water effluents.
"Meeting Today's Challenges Providing for Tomorrow's Goals" 1920 1970 50th ANNIVERSARY
J
Mr. Harold L. Price Page 2 Apparently, it is difficult, if not impossible, at this time to establish clear and measurable biological effects with respect to a number of such effluents, especially at low levels. As pointed out in the next-to-the-last sentence of the section entitled, "Basis for AEC Standards," the radio-logical guides are "set well below the level at which detect-able biological effects from exposure to radiation are expected to occur." Since we believe that it is desirable wherever possible to place quality standards on a basis of relationship to determined biological effects, we believe it would be useful to recognize this point in the intro-ductory phases of the proposed modified regulation. In short, we think it would be advisable to add to this section of the AEC's statement a sentence to the following general effect:
"Since the guide limitations herein are generally below the level at which detectable biological effects occur, it is necessary to express the limitations as emission control levels."
- 2. In the proposed amendment, Section 50.34a (b)(2)(ii),
reference is made to "curie quantities of radioactive noble gases, halides and particulates .... " The question is raised as to whether this definition is inclusive of all the types of gaseous effluents which might be released. Perhaps the termi-nology should be broadened to include "activation gases" or "other gaseous effluents," particularly as the provision might eventually be applied to other types of reactors and fuels.
- 3. The principal concern we raise has to do with inter-pretation of the language "as low as practicable." It appears to us that there is need to make clear in the text that the limitation "as low as practicable" is measured over a signifi-cant period of time. Otherwise, it would seem that one inter-pretation could be that if a plant operates for a limited period of time, for example, with zero effluent, this could be construed as the lowest practicable standard for the plant
Mr. Harold L. Price Page 3 and therefore such performance would be called for on a continuing basis. We assume, however, that the Connnission intends that the limits be averages measured over a period such as a year or six months. This, we believe, should be expressed more clearly. We trust these connnents are helpful to you in your further consideration of action on this matter. Yours sincerely, John N. Nassikas Chairman
c' 0 te -~ ~_,_,_~ I
- OOCKET NUMBER PR . . ~ /Z Ps.
/J' 5 r
fROA D BUU .O
~ 6f~6f R~~
WESTERN INTERSTATE P, 0 . LAKEWOOD , BOX NUCLEAR 151509 COLORADO 8021 s BOARD DR . ALFRED T . WHATLEY EXECUTIVE DIRECTOR April 8 , 1970 Mr . Harold L. Price Director of Regulation Uni ted States Atomi c Energy Commission Washi ngton , D. c. 20545
Dear Mr . Price :
Thank you very much for your invitation to comment on the proposed amendments to the AEC Regulations concerning the control of releases of r adioactivity to the environment . We are most pleased to do so and wil l have s everal comments to sub-mit , a s soon as I have cleared them wi th the Board Members . Yours v ~ uly, f~tl~d~ Executive Di rector DOCKETED USAEC ATW/dls WESTERN INTERSTATE NUCLEAR BOARD P . O . BOX 15509
- LAKEWOOD . COLORADO 80215 * ( 303 ) 238-8383
NATIONAL LEAGUE OF CITIES @ UNITED STATES CONFERENCE OF MAYORS NATIONAL LEAGUE OF CITIES and UNITED STATES CONFERENCE OF MA YOU 1812 K STREET, N.W. WASHINGTON, D. C. 20008 April 10, 1970 Mr. Harold L . Price Director of Regulation Atomic Energy Commission Washington, D. C. 20445
Dear Mr. Price:
We appreciate your giving us the opportunity to comment on your proposed regulations regarding control of releases of radioactivity to the environment. We have reviewed the regulations and believe that they will aid in improving release control procedures at the facilities using atomic energy. We hope that you will continue to afford us the opportunity to work with you in commenting on policies and regulations developed by the Atomic Energy Commission. Municipalities are becoming increasing concerned about the impact of nuclear facilities in their communities, particularly as these facilities may create problems of radioactivity or thermal pollution. Affording us the opportunity to become involved in your policy and regulation development process will greatly improve our ability to work with our municipalities to improve understanding of and support for development of nuclear facilities within the nation's cities . Sincerely,
~~
Alan Beals, Di~ or CONGRESSIONAL RELATIONS oaeuua awe MAY 61970a. emc, ff lllt ......, (? "G'd " . Re&.; Mk,,__ Oaie--1~--..-- _I Time_.:-........"'- 1 1612 K STREET, NORTHWEST WASHINGTON , D. C. 20006 TELEPHONE (202) 293-7300
DOCKET NUMBER p lROP.osfO RULE STATE OF CALIFORNIA-HEALTH AND WELFARE AGENCY
~<f~.
DEPARTMENT OF PUBLIC HEALTH 2151 BERKELEY WAY BERKELEY 94704 April 13, 1970 DOCKETED Mt: Mr. Harold L. Price 61970* Director of Regulation OUll:aOJIIIIIA'IIIIJ U.S. Atomic Energy Commission ~bllc ProcaedllP hell Washington, D. c. 20545 ~
Dear Harold:
This is in informal comment on the proposal to amend your Parts 20 and 50 relative to minimizing radiation exposures and effluent releases to the environment. I am delighted? Over the years, as an Agreement State representative and as a member of the Trowbridge Panel, I have been a friendly critic of the Commission for what has seemed to me to be a legalistic over-reliance on specific numbers. The proposed amendments represent a refreshing change from that notion. I have only one caveat. In 20.1 (c), I recommend changing should to shall. Why not? Best regards. John M. Heslep, Ph.D. Deputy Director for Environmental Health and Consumer Protection JMH:cl
DOCKET NUMBER p
* ~ ~LE R-io, Lulejian & Associates, Inc.
ANALYTICAL SYSTEMS PLANN I NG ENVIRONMENTAL ACTIVITIES Lulejian & Associates, Inc. April 16, 1970 A N ALYT I C A L SYSTEMS PLA N NI N G ENVIRONMENTAL ACTIVITIES DIJCHHO SUITE 920 ' POMPONIO PLAZA EAST BLDG.
- 1800 N. KENT ST.
- ARLINGTON, VA. 22209 UMEG Mr. Harold L. Price Director of Regulation U. S. Atomic Energy Com.mission Washington, D. C. 20545
Dear Mr. Price:
It was a pleasure to receive a copy of the proposed amendments to the AEC regulations concerning the Control of the Releases of Radioactivity to the Environment as a member of the National Council on Radiation, Pro-tection and Measurements. First, I want to compliment you and your staff for the development of your statement of considerations which very precisely and coherently describes those factors that I believe to be of major significance in this particular area of technology and law . As you well know, I have been troubled for a number of years because the AEC had not formally given sufficient recognition to the matter of keeping the radiation levels as low as practicable even though it had in fact, both through regulation and development, created an excellent nuclear power industry from the stand-point of radiation releases to the environment . Moreover, since more stringent numerical standards might result in technological changes that would, in fact, increase the releases to the environment, it is probably best at this t ime to issue a flexible regulation of the type you have drafted. I think the greatest need in the regulatory and related areas at this time is to assure that all appropriate administrative and environmental groups have an early opportunity to review the conceptual plans for reactors so the Commission may know of unusual conditions or attitudes which ar e beyond the norms on which the regulations are based. In many instances, by encouraging dialogue between these groups the professional organizations related to the Atomic Energy program and the Commission itself it will probably be possible to evolve changes in plans at the con-ceptual stage which will in turn obviate the need for legal confrontation. As I have observed the effects of so-called 30 day notices not only with regard to Atomic Energy Commission regulatory actions, but with regard to the construction programs of the Department of Transportation and the regulatory activities of the Food and Drug Administration, I am impressed by the number of times when the dissenting group could not hope to gather sufficient evidence for a logical presentation in the allotted time. As an alternative, therefore, they often seek the route of a demonstration or an injunction which immediately reduces the opportunity for effective compromise . SUITE 920
- POMPONIO PLAZA EAST EIUILDING
- 1800 N. KEN T STREET
- ARLI N GTON, VA. 22209 * (703) 52 7 -5923
Mr. Harold L. Price April 16, 1970 Apparently the Atomic Energy Commission is working on this facet of their regulatory effort since I have seen notices of hearings which suggest some changes in this area. In any case, it gives me a great deal of satisfaction to see the Connnission taking these steps because I think it will not only improve the public image of the AEC, but in many cases, it will accelerate the approval and construction activities. With personal regards. Sincerely, LULEJIAN & ASSOCIATES, INC.
~
I
/
~z&Jr.
Senior Vice President
~
Environmental Activities JGT:pb
Rec'd o;~ Dir.of Reg. Date 1 f/?2 'J?J ime II'. ;$:j) ,/
* ., ,, fl r:. '
"\ A I l. i I ' r- .v C". M. I
$E.GTION
DOCKET NUMBER f.ROP.OSfD RULE
~~ ~~
244 EAST OGDEN AVENUE / HINSDALE, ILLINOIS 605 21 USA / AMER I CAN NU CL EAR SOCIETY OCTAV[ J . DU HMPL[ ( X(CU IIV( S(CR( !ARY IHEPHON( 31 1 315 -1!191 April 16
- 1970 Mr. Harold L. Price Director of Regulation United States Atomic Energy Counnission Washington , D. C. 20545
Dear Mr. Price:
Thank you for a copy of your proposed amendments to AEC regulations concerning the control of releases of radio-activity to the environment. Personally, I do not feel technically qualified to conunent, but will call the regulations to the attention of the ANS members, all of whom receive NUCLEAR NEWS . Sincerely, Octave J. Du Temple OJDT:rg cc: Chris FitzGerald DOClE H D IIM£t
SAM YORTY MA 'l'OR DEPARTMENT EDGAR L . KANOUSE GENERAL MANAGER OF ANO CHIEF' l!.NGINl!.ER
-W-ATERAND POW-ER JOHN G . COWAN ASSISTANT GENERAL MANAGER AND CHIEF ENGINEER THE CITY OF LOS ANGELES FLOYD L. GOSS CHIEF ELECTRICAL ENGINEER ANO ASSISTANT MANAGER WATER AND POWER SQUARE COMMISSION 111 NORTH HOPE STREET ROBERT V . PHILLIPS FRANK R . PALMIERI. PRESIDENT CHIEF ENGINE.ER OF HENRY G . BODKIN MAILING ADDRESS : P . O . BOX 111 WATER WORKS AND ASSISTANT MANAGER NATHAN O , FREEDMAN LOS ANGELES , CALIFORNIA 90054 MIKE HOLLANDER WILLIAM D . SACHAU JOHN W . LUHRING CHIEF FINANCIAL OFFICER TELEPHONE 1 213 1 481 - 4211 MARY J . BORN , SE C RETARY CABLE ADDRESS: DEWAPOLA April 17, a*ocurEO Mr. Harold L. Price
-EC Director of Regulation MAY 61970~
Office tf lb S...,,.
- u. S. Atomic Energy Commission Pbt,lfc Pncedlap Washington, D. c. 20545 Braneh
~
Dear Mr. Price:
Thank you for your letter dated March 26, 1970, and the enclosed copy of the proposed amendments to Atomic Energy Commission {AEC) regulations concerning the control of releases of radioactivity to the environment which the Commission plans to issue. Of particu-lar interest to us is the change being proposed to 10 CFR Part 20. We are in full agreement that radiation exposures to the public should be kept "as low as practicable". In your Statement of Considerations you state that, " *** experience with licensed light water cooled nuclear power reactors to date shows that radio-activity in water and air effluents has been kept at low levels - for the most part less than a few percent of the limits specified in 10 CFR Part 20". This factual condition demonstrates that utilities have been consistently practicing the "as low as practicable" approach. In light of this highly successful experience, we question the need to change 10 CFR 20. The main problem that we foresee with the proposed change is that it could seriously delay construction and operation of nuclear plants because of the difficulty of establishing in a contested hearing what is "as low as practicable". It seems to us that in a place of quantitative limits which have been generally accepted we will have subjective goals highly conducive to controversy. We concur with your Assistant General Counsel, Mr. H. Shapar, that:"The basic balancing or risk vs. benet:it is not made, and should not be made, in individual licensing proceedings. The balancing is of such importance that it is made, in the first instance, by the Congress - after public hearings and debate in which all points of view can be represented - and reflected in the Atomic Energy Act. W A T E R F O R L I F E 1D~1 P O W E R F O R P R O G R E S S
Mr. Harold L. Price April 17, 1970 "It is made, in the second instance, by refinement of the generalized legislative determinations, through rulemaking proceed-ings where substantial public input is again obtained. The Commission's rules are where the essential elements of the risk vs. benefit balance may be found.
"This, by the way, is very much in line with the currently favored administrat ve law co ept of handl ng general issues by rulemaking, rather than in individual quasi-adjudicatory proceedings.
After all when you are talking about reactors of the same general types, how many times do you need to perform the basic balancing exercise?" - Nuclear Industry, December 1969. A great need in the nuclear industry has been for quantita-tive regulations, standards, criteria and guidelines. We think the present 10 CFR Part 20 regulation is such a regulation and has been extremely useful. We recommend, therefore, that no changes be made in 10 CFR Part 20. Thank you for the opportunity to comment. Very truly yours,
~~~~
F YD L. GOSS Chief E ectrical Engineer and Assistant Manager cc: 1-Mr. Alex Radin American Public Power Association 2600 Virginia Avenue NW Washington, D. c. 20037
DOCKET NUMBER pR
- l'JIOlllSEQ ~LE -:;i_e, '5 0
- DEPARTMENT OF H ~ D U ~ i ~ ~
PUBLIC HEAL TH SERVICE ENVIRONMENTAL HEAL TH SERVICE ROCKVILLE, MARYLAND 20852 OFFICE OF THE ADMINISTRATOR APR 3 0 1970 Mr. Harold L. Price Director of Regulation U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Mr. Price:
Thank you for your letters of March 26, 1970, addressed to Dr. Roger o. Egeberg, Assistant Secretary for Health and Scientific Affairs, and to me requesting comments on proposed amendments to AEC regulations concerning the control of releases of radioactivity to the environment which the Commission plans to issue. I appreciate having the opportunity of reviewing the materials you have sent. Mr. John C. Villforth, Director, Bureau of Radiological Health, and his staff are developing . connnents to be forwarded to AEC. The comments will also express our views on the subject. Sincerely yours, DOC KE!E D UIAEC Ch~ ~ rft'JJ Assistant Surgeon General Administrator
Rec'd O g. Date~..,..............,_-- Time ____ .J
t PORTLAND GENERAL ELECTRIC COMP.ANY ELECTRIC BUILDING PORTLAND, ORE0ON 97205 E. C. ITSCHNER VI C I: PRl!!!IIDl!.NT April 29, 1970 PORTLAND GENERAL ELECTRIC COMP.ANY DOCKE,ED ELECTRI C BUILDING, 621 S . W. ALOER STREET U&IEC PORTLAND, OREGON 97205 Mr. Harold L. Price MAY 61970 ~ Director of Regulation fllce 11 the S Atomic Energy Commission Washington, D. C. 20545
Dear Mr. Price,
We appreciate having the opportunity to comment on the proposed amendments to AEC regulations concerning the control of releases of radioactivity to the environment. We agree that it is good policy to make every reasonable effort to reduce radiation exposures to low limits. This could be accomplished in Section
- 20. 1 (c) by changing the last part to read:
11
* * * , make every reasonable effort to minimize radiation exposure and releases of radioactive materials in effluents to unrestricted areas."
Left as it is expressed in the draft there always would be a question as to what is practicable. Also, what consideration may be given to economics is not clear. Interpretation of the meaning of "practical" is a matter of judgment which undoubtedly would be interpreted differently by various interests. If the AEC feels that this term must be used, we suggest that the last word of the sentence ("practical 11 ) be eliminated and the following substituted:
"is technically feasible and economically practicable. 11 With respect to Section 50.34 a, we see no reason why these provisions should be limited to Iight water cooled reactors. At the time the PSAR is submitted detailed design has not progressed very far and the identification of equipment to be installed to control gaseous and liquid radwaste would be premature and
PORTLAND GENERAL ELECTRIC COMPANY Mr. Harold L. Price April 29, 1970 Page two somewhat meaningless. It could, in many instances, result in freezing upon certain types which may not be as effective as others which may be developed or improved after submittal of the PSAR. It appears that a statement of design objectives would fully serve the intended purposes, leaving the selection of specific types of equipment for resolution after the design of the integrated systems has been determined. The same comments apply to the provisions for packaging, storage and shipment offsite of solid radioactive waste. With respect to Section 50.36 (a), we feel that this paragraph adds little of value to existing regulations. Experience to date has been excellent and the results obtained wil I be applied to the newer plants, but past achievements must be interpreted correctly - under the same conditions. We believe that 60 rather than 30 days after the end of each semi-annual period should be allowed for submission of a report on releases of radioactive materials to the Commission. We understand the need to amend 10 CFR 20 and 50 and believe that if the above comments are accepted the regulations will be improved. Sincerely,
Reg.
---=~~~ &.
-----"~---- )
r ..4
- I I HO LMES 8 NA R VER, INC.
- DOCKET NU MBER P..ROP,OS£0 BUI..E PR
- 'J..O I SO OFFICE OF THE ENGINEERS*CONSTRUCTORS 828 SOUTH FIGUEROA LOS ANGELES , CALIF. 90017 STREET ~~~
T E LEPHON E 627- 43 77 PRESIDENT April 29, 1970 O~Kf.1E U&A~ Mr. Harold L . Price 11970 Director of Regulation OlflCI of tbe SeenllfJ PubllC l'flC,tdl111 U. s . Atomic Energy Commission 81'1!:C Washington, D. C. 20545
Dear Mr . Price:
The proposed amendments to AEC regulations concerning the control of releases of radioactivity to the environment., a copy of which was enclosed in your letter of Ma r ch 26, 1970, a r e most timely. Holmes &: Narver , Inc * ., agrees that releases of radioactivity in effluents from light water power reacto r s now in operation, particu-larly pressurized water reactors, have been within ranges that may be consid ered "as low as practicabl e., " and we encourage the Com - mission continually to review and upgrade its procedures and methods to limit releases of radioactive material to unrestricted areas. We believe the proposed amendments to regulations 10 CFR Part 20 and Par t 50 t o be both desirabl e and workable . With these as a basis ., it would be our recommendation that the Commission should determine, as soon as practicable., the feasibility of developing more d efinitive criteria for design objectives and means for keeping releases of radioactivity in effluents to a minimum . Based on operating experience to date and the state of the art, the proposed amendments are, in our judgment, the right, but only the first, steps towards improvement of environmental quality. V e ry truly yours,
~ -
Holmes cc: Secretary U . s. Atomic Energy Commission W ashington., D . C . 20545 Attention: Chief, Public Procee ding s Branch A SUB SI DIARY OF W!Ll!AMS BRO T HER S COMPA NY , TULSA, OKLAHOMA
~acl.,o nrf,v, 'f ~ ~
GRADUATE
- SCHOOL OF PUBLIC r
I HEALTH UNIVERSITY OF PITTSBURGH ,* PITTSBURGH, PENNSYLVANIA 15213 P- r, ,-aq JIJ., ~
--zo '( -c1
~ RADIATION HE.urn L-401 PRESBYTERIAN-UNIVERSITY HOSPITAL Apr 11 20, 1970 l' Dr. J. Newe 11 Stannard President, Hea1th Physics Society University of Rochester Schoo) of Medicine 260 Crittenden Bou1evard Rochester, New York 14620
Dear Newe11:
The proposed amendments to regu1ations on radioactive eff1uents from light water cooled nuclear power reactors, as genera11y de-scribed in AEC News Re1ease N-48, appear appropriate in view of the projected increase in use of nuc1ear reactors and radionuc1ides in industry. However. I sha 11 write for copies of the proposed amendments to distribute to the Standards Committee for fur t her review.
- As you know, I have long believed we must look forward to a systematic accounting and 1imiti~g of population exposures from all ma~-made* sources of radiation, whil~ at the same time avoiding steps that wou1d make the present overall permissible levels and present state of radioactive affairs appear Ill-conceived or dan-gerous to the public, (See enclosed reprint, American Journa1 of Publlc Health ~. No, 12, pp. 1971-1992, December, 1965.)
Sincerely,
~
A11 en Brodsky, Sc. D. , C. H. P. Chairman,
- Standards Committee Health *~ysics Society AB:ch C. C. Pa 1mi t er T. Rozze 11 Secretary, U.S.~ L~
lh*pii1111*,I h11m i\UI.H - .llll *UNAI, ll t' 1'1111111: lh.,11.1.11, Vul. r,h, Nu. I:!, lh:* *
- 111 :1, l'Jlif,
. Co1*,*ri11hl hr 1l11, A1111*1*il'n1- liu lll*nhh AM"tll'irll iun, l1111,, 171J\l llrondw11y, New
, N. Y. 10019 In order to ensure a conti,11101i.s ancl cumulative net humari bcncftJ. from, the commercial zt.scs of radioactive materials, specific guidclirics arc required for the accounting and control of population radiatiori exposure from all byproducts of our growing nuclear criergy industry and other man-made sources of radiation. In an attempt to encourage the development and use of such guidelines, a systematic procedure for apportioning the radiation exposure f ram con.sumer iterru according to some prior estimation of benefit and risk is presented:
- BALANCING BENEFIT VERSUS RISK IN THE CONTROL OF CONSUMER ITEMS CONTAINING RADIOACTIVE MATERIAL AUen Brod$ky, B.E.. M..4. * ' *,
I. Introduction *' exercise of good professional judgment in other health programs. , HE primary objective of this paper Radioactive materials utilized within T will be the development of a sys* the federal atomic energy facilities are tematic procedure for determining ' *. controlled .according to written admin-whcthcr or not a product containing *. istrative policies of the Atomic Energy radioactive material should be permitted Commission in order to protect the general distribution to the public. A . health and safety 0£ the public, a; di-secondary but broader objective will -rected by Congress.' Radioactive by- i be to illustrate how the available knowl- . product materials of the atomic energy edge !!£ radiobiologic effects (however prograiq, which have been distributed incomplete), together , with available
- to licensed users in industry, medical ,.
t'. population statistics, may be applied in I institutions, private institutions, private r; ~
, balancing the human benefits versus , practice, and various research labora- . . . . ..
. **' the human risks (or costs) of particular . tories11 are contro11ed by federal, state, .*
\ -1 1 uses of radioactive material. These * .. and local regulatory *programs. Small ~ ,
*
- primary and secondary objectives ac- . amounts of radioactive material are *'
- r** ......
tually are parts of the general problem *, . distri.bute~ as waste efiluents by these of continuously evaluating and bal* * : private AEC- or state-licensed users, but * ** ancing the human benefits versus the ' the contributlon of these sources to the * * -' * *
. ** ~* - ~
- I.
human costs (or even risks) of pub." general population exposure is limited lie health measures.1* 1 Thus, the quan- ,
- to very low levels* by federal and state
' /
I tilative approach illustrated in this license conditions and specific regula-
I' paper might indicate, also, how *numer* .,. lions. .
- ical logic can be use4 ~...enhance .the* ** . ' ~ur:~ to 'indus~rial ~ployees is 1.
l ' : *. *.. ,*r_.',l , .....\1 ;,*. "', :*:\~.* .': " \Ii. ' . ***,,l*/f' )l lJ *:* . I l
.,,,~-. ~i:.-.: ~r,* / .: i.tV.~.._\ ... . ~ f,.'~ ~~: : 1 ~~<
1 1 u _ ' ' *.(,*;.....
' . : t..'. , .. *.:. r *.: <. <~ ,'*,
- 1 **~. * *" :
- l I. " * ~~ t " . ; * * "~ ~ ,J ;\(\ *..' * ' ' (. . t.
DICIMIER. 1965 , ***. *1'*\*' ;,.*,.';,; ,: .:* **"' '1. ,.* . . *1. ' 7' ,, *.,.,*,#~ 1.,* ....- *.~ * .. 1971 * , t.
*_~;:;-;--;::~-\i*_:. '.:-: -*:.r*..:.::'-* *,;(:. /:'** * .:; .-?:.f:,::* ....::* .:* ~:,, . . * ..\ . /t
* *., *~,*. ... ~ ... #_J., .. . , * ,, *: . i, 11 *. " *, .. # ),.I ~ ... _,,, i' * . .... - . .* \ I i 4-... -**-~ .............. . .. J t q 1
,* . . .. :.;;.~. ~ .. ,.,. ~ ' / ;'< i/ .*.* "* ¢Jl0( . ,. . . . ~~ i... :...; .**. h..;ci:.;..;;;, 1
. . ... r::¥;.;-.-::*,. i7 '>>..) .
~ './ .
- . I I
I
* *.1\ *****
' r I
*r I ,
... i
** 1,
I
- lim it.-,! liy r,*gulation; ulM1, tllc 1*x* 11111ho1 i1n1ivc pro rc ...~ill1111 I nnd governm cnlal p,1:-nrc is pn~nmal,ly hal.mc *,l within ar.:l'nric~, I O, ti wl,ich would n~*ure that the thl':'C limits ti) the sa ti:-fo ctil1n of the M11 11 nlic risk lo nny sin i;lc individual woul<.I be wc*ll 1,olow lhc risks that he eneou11tcra from 1'mpll)ycc and the 1*mploycr by the cm* 01 hc r ordinMy linz:irdi~ of the en vironment.
pll)p~c*s job benefits, the 1*,mployer's 3. ~incc there is no regnlntory control over prolits, an,l contril>utic;ms to national the d i~roMl of these items hy the user, there pro,lucti,*ity or n'scarch. Di:ignostic or mny ho n pcrmnnent eonlrilmtion to the en* viron mcnlnl radionct ivity over a wide area of thl'ntpcutic cxp,1sun*s or ' individual:1 by tho r.ountry, particularly for the long hall-life licl'nsc,l physicians arc assumed to be nuelidcs, m,1rc than halancc,l hy contributions to the indi\*idual's health, and arc not Thus, the relative hazards of a par-limited by regulation, but by the pro* ticular consumer item containing radio- {c~ ional judgmrnt of the physician. aclive material must be estimated sta* These medic., ! exposures contribute an Listically by multiplying low probabili-appreciable fraction of the exposure re* ties of somatic or genetic effects per Cl"iwd by the ,l\'crngc individual from ' year per individual by a large number natural background sourcc~.7 Nuclear of individuals. at risk in the population reactor locations and construction are and, perhaps, by a large number of suhjcct to detailed revicw 8 by the years of "chronic" radiation exposure. Atomic Energr Commission and its Ad- Although the incidence of chronic dis-
,*isory Committee on Reactor Safe- eases produced in the population by such guards prior to licensing, so that even low-level chronic irradiation may not be the highly improbable "maximum distinguishable for many years, if at creJible accident" would not ordinarily
- all, from similar diseases produced by contribute a serious exposure to the other agents, a large number of indi-public. A considerable amount of viduals may ultimately be affected.
methodology has been developed for the Therefore, some kind of quantitative e,*aluation of reactor hazards. 9 At pres- estimate of the total risk to human ent, reactors are generally located and health, as well as an estimate of the I , constructed with enough factors of benefit 'to human health, must he made f. I
~!ety, so that even the worst possible in advance* for each cons~mer item to accident would not be likely to result in be exempted from regulatory control. '\
I I a significant hazard to the public. Estimates of the balance point be-i The specific guidelines developed in tween benefit and risk have already been this paper will be limited to consumer made by the Atomic Energy Commission items containing radioactive material in judging iijdustry proposals to exempt distributed in the United States. The certain consumer items containing radio- I
- problems of consumer items released to active* materials.12*H For these earliest " *.'
the public warrant consideration as a items, an estimate of the balance of *
- f. ':,_ .
separate category from the above types benefit versus risk was perhaps easier of nuclear installations for the following to assess than it might be for future I* . l reasons: items petitioned by industry. As an
- 1. To make it cconomicallr fcuiblo to example, a discussion of the quantita-
- tive studies published11 by the AEC, r
market useful items to lari;e numben of per- I sons, the ultimate users must be free of regu- prior to the exemption of tritium for ! 1* latory controls. use in luminous timepieces, is presented
- 2. To make these hems generally acceptable in Appendix A. These studies are a l:
to the public and to tho health authorities, tho
, striking example of the value that quan* !* "'
level of radiation espoeuro from tho item in or,Jinuy uec muat be below tha limita of e1po, titativc estimation may have in assuring I,:. ure to tho aeneral public recommended bJ tho a net benefit' to human health. In this Il ... ~: .. \
\ . \
1t72
>___________________________...,,_.....~ - - -*-*- - - - - - - - - - -... **
- VOL. 5&. NO. '12. A.J.P.H. :l:*_. . .,
.,
- f I
- RADIOA. E MATERIAL partkular ra:,.r, the nnnlr:,.is 1li111:11:<.,1'1l l11h*rnalio11nl Com1nill1*c for l::uliol<,~-
in Apprnllix A se1,*c1l to romplrtdy i,:nl Proteclion ( JCHI')
- tl11: Na1io11al rt*wn-,~ tht* nuthor's prior opinion thal Aeacl,*my oC Sci,*nccs (N AS), an,I the:
the ri~ks of t'xrmpting tritium might F1!1l1*ral Hnclinlion Coundl ( FHC) l'Xl't'l'1l the b1mdits. wonltl not he cxccedc11. 10* 11
- 17 *1t The lfow,*,*rr, 1lrdsions n*gnr1ling rxrmpt Fr,lrral Haclialion Council limit for consumer itrms will become incn*nsingly the whole bo1ly ,lose to the average in*
,liffirult a:,. more numerous proposals ,lividual in the population woultl he arc made by industry for exempt prod- 0.17 rem per capita per yrar ("which ucts, nnd as more stnll*s take o,*cr from shoulcl be modified 1
lo meet special 11itua* the AEC the rrgulatory control o( by- lions")* or 5 rem lo the gonacls of nny product materinls. 11 Therefore, the re- person in 30 ycars. 11 Doses of less I' maining sc~tions of the paper will be thnn 1 rem. per day 20 are not likely devoted to the devclopm<'nt of a sys- to result in acute illnesses of an indi-lt'matic procedure for evaluating exempt vidual that arc directly traceable to the itrms, in order to ,msure a continuous rncliation exposure. and cumulath*c net benefit to human Thus, the estimation of disease inci-welfare, objective and ronsistent treat- dence or human impairment from radia-
- I ment to all petitioners of exempt itrms, tion exposure by consumer items must and minimum delay in evaluating those be accomplished using limited data on common aspects of human risk or hcne* the incidence of certaiq chronic dis-fit that can he agreed upon in advance. eases in humans ' and animals as pro-Of course, any standard procedure of duced hy larger doses of radiation. 21
- 23 such scope nnd importance to public Althou~h present evidence is insufficient henlth should not be the product of .to justify precise conclusions regarding any single individual, but should be sub- either the somatic or the genetic effects l.
I
*I ject to the widest possible professional at low-dose levels. it is generally agreed and public scrutiny. Therefore, the en- that the assumption of linear dose-effect I tire content of this paper should be relationships down to zero dose will considered an example and plea for the conservatively overestimate the haz-further development of quantitative and ard.18*19*11 Accordingly, the following objective aids to decision-making in numerical estimates of the upper limits programs aflecting the public health of disease incidence associated with low-and welfare. level rncliation exposure will be used in II.
- Human Risks of Low-Level Radiation
' this pnpcr:
Sliortening of Lile Span-The short* 1 ening of life span for the lmmnn has Exposure \
*, ~cen estimated at from one to four days A. Radiation-Produced Chronic Disease per roentgen of exposure early in life, Incidence
- I
- but this estimate is not agreed upon by
- Before any consumer item containing, all authorities.23 The extent to which radioactive mate{'.ial would be approved repeated small exposures to x-rays may lI by any government agency for distribu- shorten life expectancy is not yet wcll-tion to the public, the design and con- established.
I struction of the item and the quantity Cancer-I£ natural background radia-I I of radioactive material contained would tion is assumed to be responsible for 10 I undoubtedly be restricted. Therefore, ' per cent of the spontaneous incidence t the limits of . population exposure ', rec* , of bone tumors among the general . ommended by the National Committee United States population, the frequency
- j on Radiation Protection (NCRP), the
- of tumor production by radiation might i
DECEMIER. 1HS 1973 .,t
- I I I *
, I I I
be a bout four to eight case& per 70-ycar lion) below the genetically based limit period per million individuals per rem for the individual. 16 of c,\'p<J,tttrc received over a 70-ycar life Genetic E(Iccts--Eslima tcs of the spa11. 23 *n It has *not Leen proved thnt mugnitudc of genetic elTccts arc un*
' nny incrrnse in tumor incitlcncc in hu~ certain, nnd some aulhorili c.'i even oh*
mnns wouM be produced ns a resull of jcct to the making of such c.stimalcll, such chronic low-level exposure. However, the averngc considered 011in* The inciilcnce of leukemia has hccn ion of gcnrlicisls participati ng in the t'slimatcd lo he 1.5 X JO* G per
- person National Academy of Scicnet*R Report18 per year nt risk per accumulated rocnl* was that" ** . if 10,000 in<li vi ,lu al. \' c gen as an upper limit, with zero as *a ex )Oscd to . . , . on l 1c order of 0 1
lower limit at small dose ratcs. 21 "23 As- rocnt ncns r rems t 1cn there would be ( suming a mean age of 35 £or individuals perhaps 100 handicappc children of , t I .* I l r1.-* I j in the populntion, the upper limit rate would mean that the leukemia mortalily of a population ex.posed to 1 rem in 70 years would he 1.5 X 35 or 52 radia-I these ex osed individuals, in addi tion to the number rcsu ting rom other causes." However, since a harmful mu tant gene survives an average of 40 generations, tion-induccd cases per millio~n$ . many more failures at rcpraduciiao Q.[ p f per 70 years. 23 ,61 , liindicappcd individuals rni~ht he ex-
' .. If we assume that 10 per cent of the' pcctcd in future enerations.3 Thus a 1961 United States mortality rate32 of " oub ing dose o 40 roent*TDS pee
- 149.5 deaths per year per 100,000 popu* gcn"eration 24 to every member of,,a popu*
lation due to all malignant neoplasms l:rtion might cause one out of every 200 is caused by a natural background births in the next eneration to result radiation exposure of 9 rem per 70 in eat or a1 ure to reproduce. I years, then l rem in 70 years would ! The total number of induced extinc- 1 ! produce ~o X 149.5=1,160 tlis from tions in all future generations would he . cancer per million pulation per 70* 20 million for a constant population f year period. Comparison of the increases size of 100 million. 0£ course, if the ! in neoplasms23 in Hiroshima survivors with the radiation doses at various dis-40 rem dose were delivered to the
- populati~n each generation continuously r
.,. .r tances from the hypoccnter would yield
- for much longer than the average life I*
1. an average estimated incidence of about of a mutant gene, i.e., much longer
.. . 250 cases in 70 years per million popu*
- than 40 generations, or 1,200 years, 1: lation exposed to 1 rem in 70 years, if then at equilibrium, there would be an \
. adaitionar 20 m1ll10n abortive concc -
*I ,*.. the incidence rates £or acute exposures are assumed to apply *to chronic ex- hons, st1 trt 1s, neonata eat s, or ai
- posure. urcs t e roduce er enerat1on er 100 Cataracts-More than 1,000 rads of X mmion £0,PUlation. n a 1t1on, t 1e or gamma radiation, and more than 100 surviving population would presum-rads of neutron radiation, would be re- ably2 4 carry a large pool of radia tion-quired to produce an appreciable proba- caused mutants which might have vary,
- bilily of cataract production. Any con- ing degrees of health impairment,20 as
- I sumer items that might contain enough well as a possible small but increasing beta-emitting radioactive material to
- percentage of individuals evolving in produce a localized dose of this \ order the population with uperior character* 1 of magnitude would most certaiqly be iatica. aa a result of selection in favor '
shielded to negligible levels by the re* of. the beneficial, long-surviving mutan~ quirement for keeping the gonadal ex* fraction. (Muller's estimatesH based on posure from BremsatrahJung (x radia* Ruuell'* ' mutation doubling dose for I, j 6 7 YOL. SS. NO. 12, A.J,P.H.
RADIOACTIVE MATERIAL mice am ,*~.;cnlially in agrccmrnl with Tahto 1-Mortnlity Rates by Cau1c, U. S., the ,*:::timnte
- of the NAS n*port. A. 1961*
,loublin .. ,h,~l' or ,10 r is l' 11i,*al,*11t lo Deaths per Index 100,000 in N Cau~o o( Dcmth 1961-DH u:::e a~ an irnli*x 1 Major ,*11nliov11~culnr and of g,*m*ti<' t'IT,*cti; the cmwcr11ion foctor 1~11:1 l , liscu~c~ Sll.7 that L . . .. . . rnd111*ti1*c 2 l\foHgnanl nco11la~m11 (includ-
~otaat i11g ly11111ha1ic and hema*
in :my topoiclic) 149.5 3 Acci,lcnts 50.4 3/4!fl.l\t l 4 Certain discnscs of early 8.000 . If inlancy 35.9 rem /;,0 years were ddiYcrcd for 5- -Innucn1.n and pneumonia 30.2 many generations to a population of 6 Dinbctes mcllilus 16.5 constant size, the result might be an 7 Congenital mnlformationa 12.0 c o 500,000 per 8 Cirrhosis of liver 11.3 1 -year pc* 9 Symploms, scnilily, and ill* no . For the purposes o us paper, defined conditions 10.4 I-1c 1
- o,*erconservallve assumption
- t I1at 10 Suicide 10.4 each failure at conception or reproduc- 11 Ulcer of slomnch and tion is as serious as a death, and the duodenum 6.3 disregarding of the possible evolutionary .' 12 Tu~crcu losis, all forms 5.4 value of the few beneficial mutations, . .13 Hernia and intestinal obstruction 5.0 will be considered to balance the addi- 14 Homicide 4.7 tional morbidity load tliat may result t, from a large pool of mutant genes in 15
- l ~fections of kidney u .,
the population. (After all, the world , 16 ,Gastritis, duodenitis, enteritis. population seems to have been evolving / :and colitis (except diarrhea
' of newborn) 4.3 to better levels of health in the presence 11 }Other in(ectivo and.paraailic
~£ a natural background radiation level *, diseases 3.1 of about 3 rem per 30 years.) We .
- 18' Aslhma _. 2.7 shall also neglect Russell's more rcccpt 1 , /
, 19, Cholclithiasis, cholccystitis, fi°iiding that mutation rates at lower . ,
dose rates were one-fourth of those and cholangilis 20 Hyperplasia of prostate 2'1' Bronchitis
- 2.6 2.3 2.2 ex ccted from a linear extrapolation I
of 11s* rev10us t 1c osc-
/l2 Sypl1ilis and its sequclae 1.6 and .. 123 ,Meningitis (except mcnin*
W 050 J i.ococcnll and tuherculoais 1.2 for females nt hi gh do5e ratcs.2:, .,' 24; Acute nephritis, and nephritis Other Radiation Eficcts-ln addition with edema including
.nephrosis 0.9 to the genetic efiects and . cancerogenic 1:- '
25 *Deliveries and complicatiom effects, some additional health impair- of pregmmcy, childbirth, *: ment or loss of vitality might result 1md the puerperium * *
- 0.9 from cell loss following somatic muta* 1 26 Infectious hepatitis 0.5 lions, although if the destruction of 27 Meningococcal infectiont 0.3 cells is at a low rate, regeneration may * . 28 Acute poliomyelitis o.o increase so that no cell deficit or organ
,* failure is observed.20 In deriving an
- Total 930.0
,,!t index oE radiation risk in !he' following * ,*
- S..rcei Rden*e* U.
I .....
- l 1*
t' DICIMIER. 1965 1975
*. I I
.. ,*.J 1 ,, ~, ..
.... .. i ; ~
*' j ** .t.
*
- t It I I '\ f I
- ro TOTAL MOR~ALITY R~( E =
L 512 N- 1*75 ~ f 512 N~1.75 dN =*1,023 N*I Q5 , N =I MA~OR CARDIOVA~CULAR AND RENAL DISitASES 1000 N=2 *MALIGNANT NE91 PLASMS 500 ** ' '*! ETC. I '
' I*
- ON= 512 N.:.'1*75 100 / 0 TOTAL ' MORTALITY PRODUCED I BY NTH 50 DISE'ASE .-" CATEGORY m ., ; ... I v .. 1 10
. \
*s
,. i ** *' I '
. ' . *.... .., .* \
I t , I 6.
. ..' * . '1
' .,. I r
RADIOACTIVE MATERIAL Sl'Ctions of this paper, nn allowance will of r.ascs of di!-.r:ts<', the (finite) numher be mn,le for nd,litional morbillity in of ,lays of disnhility in each nge grrmp,as l I I the population from somatic mutations. giving 87,321 <<lays of ,Jisahility per 1,000 population in the Unite,I States Ii , B. Ratios Betwoon Mortality from Corfein "in rlic yenr 1950. I Disoem end Total Mortality and Morbidity Tims, for every 950 deaths per Table 1 presents the estimated mor- 100,000, an a,l<litional 87.3 days of tality rates by _cause of death for the Jis:1bility arc assumed to occur per per-United States population in 1961.32 son; or for every death, there are an These rates were not very different from additional 87.3/0.00!)5=9,200 days or rates estimated using the 1960 ngc dis- 9,200/365=25 years of disability. r
~ tribution and 1950 1lcath rates listed for "
- Probably most people would agree that I the 12 most frcqu<'nt causes of death it would he conservative (safer) to as- ,. I in each age group by Dunn.33 In Fig- sumc that each person-day loss of life '!
i ure 1, the cause-specific mortality rate, by disability is as tragic on the average D, has been plotted versus the numer- as a day of life lost by death.
- Since ical index, N, of the cause (taking a the expected life span is about 70 years,
**cause" to he a major category in the' / n conservative estimate of the numhcr of mortality tables) .82 The most frequent years of .life lost for each death would
=
cause of death has been assigned N 1; ' be 35. Therefore, an index of 25 + 35 = the second most frequent cause has 60 years equivalent life lost per death been assigned N=2; and so 1 pn. For N occurring in the population should be a greater than 20, the mortality rate in conservative measure of total annual Figure l falls off much more rapidly than the rates intersected by the straight human loss from death, illness, and acci-dent; and this index should vary only 1 1 ,* line. Moreover, the rates intersected by slowly with time , in the United States 1
*** : : ;* the straight line sum up to a finite num- ,
- population111 over the 1950-1970 period.
- ( _*.*, ; * * ,: her dose to the actual total mort~lity *
] rate. Thus, Figure l gives some C. Deri-,ation of en Interim lndn of H11men
; t /, heuristic confidence that the major Risk from Radiation Exposure jI causes of death have been accounted '* One method of arriving at a conserva- f.
. ! j -~ for in Tahl~ 1, and that the ratios of t1"ve index of risk from radiation ex* {
. r:?'..***,
t t ' '
- t 1., mortality from specific major causes to
- posure at low levels is to determine I.
/. total mortality are probably within},the which chronic syndrome of radiation t
- I :. correct order of magnitude.
- exposure has an estimated maximum in-
- lI ' ../." ,*,
1* .:-. , . ,. ~ , I,
- A plot similar to Figure 1 was at*
templed for Dunn's33 morbidity data.
- However, the exponent of N (see Figure cidence that is highest in proportion' to' the "natural" incidence of the same *
- syndrome. Then, to obtain an upper*
I *
- 1) in this case was very close to -1, so limit estimate of the total loss of per* ..
[ that the sum of total morbidity. repre* ,
- son-years due to radiation exposure, the I'I'
; . ,
- sented by the straight line gave either an *.
- estimated maximum loss of life from
' * ~ * * '* infinite or an extremely large number of : this syndrome due to radiation is multi-t
.I;*_. ,* ' **.,
, l! * ,\ **.,
cases. (Perhaps this is indicative of the ' plied by: the ratio of total "equivalent" extremely large number of potentially loss of life from other causes of mortality Il l pathogenic organisms in nature, or the . and morbidity to the loss of life from large ,number of unreported cases of ill- other causes of this syndrome, as given
,. . ness or subclinical infcction.) 14 Thus, in Section 11B and Figure 1. In other I 1 *: * *. a conservative index of the total tangible words, a given radiation dose is assumed t'
*1 l ** * *, ,, *,* health impairment in .addition to mor-I i *
. I .* . **,
to increase mortality and morbidity
- tality ,was obtained _by ,totalling, instead
- 1 irom all known diseases in the same pro-I * . I lI DICEMIEI, 1'61
~
i ;
.. I
' *I J* I r
1'77 II
~
,t
? . . '
~
f -_.*r ~ ****t' 1 0
~
. ,f I**
,. 1 ..i '*
'I .
* * ~ I
~- ...:~~~-:r.~
- r, f
r Por11.., ns It i,.;..,.:... that dl,~~lt. ,* ing the highest estimated increase *per unit radiation dose'. fi* or t~e Aze ol the ml~lmum market a given consumer item will achieve. Nevertheless, certain items will be de* I i r
,.\ . To determine which chronic radio, velopcd (see £or example, Appendix A),
. tion syndrome is most frequent in pro, where it will be relatively easy to show portion to its natural incidence, upper* that under certain conditions of manu*
limit estimates of "loss of life" .result* facture the release of these items for
. *.' ing from a continuous irradiation of the entire population at a rate , of 1 public sale would tend to reduce, rather than increase, the net risks to human roentgen (or rem)
- per year arc pre* . health; or, equivalently, they would scnted in Table 2. The radiation-in* tend to increase the net human benefits.
Il
'I duced disease rates arc based on the rates estimated in Section IIA, and are One major difficulty in selecting a suitable index of benefit for appliea*
- compared with the rates of similar dis* *,
- tion to the widespread use of radioactive cases as they occ1,1r naturally.
1 materials is the requirement that a con* L I. ! The comparisons of Table 2 show
- sumer item may be allotted no more i I'*
I that leukemia would give the highest than some previously defined . upper estimated Joss of life in proportion to , , limit of population exposure-no matter I corresponding natural rates for any*
- how mu.ch more benefit than risk may
, radiation exposure that would .include .' 1 be expected from the single item. This t
~
J the bone marrow. *However, after many is necessary, so that future useful or , I generations of exposure, genetic effects *
- necessary items will always have some . "
would produce considerably greater ab-
- additional allotment of radiation ex*
solute mortality rates, under the as* posure that can be assigned. This as* r t*: .
. sumplions outlined in Section IIA. Thus, signment must be made in such a man*
assuming all causes of mortality and morbidity (including ge~etic) increase ncr that the cumulative exposure to the population from aU uses of radioactive I *:.-:.*, . . under irradiation by as larg*e a multiple ' material does not exceed (at roost) the .f .
- l
.. . . as leukemia, we obtain the foUowing interim radiation protection guides.ST
- conservative index of risk:
Human Risk ~ (5.2 leukemia cases per rem/ While the Federal Radiation Council ~,, guides do specify certain limits for ! ' I 1.47 leukemia cases naturally) X \ population exposure, and generally rec-ommend that "Every reasonable effort l l. (930 total deaths per year per t should be made to keep exposures be-100,000 population) X ' (25 pcrson-ye11 rs disability+ low any level selected," they also imply 35 person-years life, per de11th)
- ii 200,000 per.1011-ycars of life that " *** it is obviously appropriate to exceed the level if careful study indi-cates thnt the probable bmefits will out*
1-*.
"21JUIVC1lcnl er Cllr er 10/J,uutf pu ' ion, per rocn ge weigh the potential risk."38 The re*
sponsibility for making the "careful l' , I 10 1e enlLre popu a11on. stu dy,, is delegated to wl1atever agency
._ may have a specific problem at any tI .*
Ill. Human Benefih of Consumer Items time, without provi ion for any o,*er-all Although the human risks of popu* 1 centralized accounting or measurement I .. lation radiation exposures are difficult enough to quantitate, at least some reasonable upper limit of risk can be of the total radiation exposure received by the population from all sourc~s. This policy implies, contrary to the evidence { estimated !or sufficiently low dose-rates. and assumptions adopted by the council However, it is often much more difficult , itsclf,111 thnt the populnlion expo un's to c11timntc, n priori, tho minimum bcnc* Crom various items or l.'ffiUl'nts .contnin*
/.
.I ....
. ,, ,,. 1t71 VOL, H, NO. U, A,J,P,H, I
~~- - --
I
- .;, I I
- DIOACTIYE MATERIAL
,I I ing rallioactivc matcrinl may be as- example: There arc 11 finite numl,c:r of
~11nml to be imlc.[K'mlcnt of encl&.' other peo11l1J in the worlcl population. When i
or noncunmlntivc in their diccls, This we reach the r*<;int where another in* ft
,, polic)' implk11 further ( 1111i111t*ntio11ully1 crcnwnt u( rucliution cxpo:1urc proc*
'I o( l'oursc) that nn unlimited 11111011nt of tically climinntcs tlic entire population, J>l'Pllla1ion rn,liution cxpo:mrc may ho II ., nllowc\1 ns long as the benefit of cnch the ltcncr.t of auy gadget or 11rocci,s woultl have lo be measure,) in terms item is "balnnccd0 asainst its in<li- of ils uhiHty lo recreate the human vhlunl risk. population.
No pro,*ision is nmlle to account for The need for furlher guidance from the interaction between risks or 1he foet the Federal Ua1liation Council in con*
- 1 that as total cumulative exposure in- . trolling the apportionment of popu]a.
crca~s above the limit& specified in tion radiation exposures from multiple the radiation protection guides, the sources has already been alluded to by measure of risk may no lonser be as- Wcstern* 0 in his' testimony before Con* sumed to increase proportionately. W c grcss. Some geneticists believe that an illustrate our point with an extreme increase in radiation exposure to th~ Table 2-Comparison of (Maximum) Chronic Rndinlion-Induccd Loss of Life at 1 r/-rr witlt Loae of Life at Nom10.l U. S. lncidcncc'Y lor Certain Categories of Mortality Loss of Life (Person-Yrs/Yr per 100,000 Population) 1-:Stimntcd maximum ndditional rate that Present rate for U. S. population would result from irradiation a.l l rem/ Category (npproximnte) yr Ior many year& Shortening * * ~ot estimable separatt;ly; , ~ut wcz may 400,000 days 1,100 person years of useful
- compare 87,321 dnys d1sab1hty per' yeor 365 per year per human life. (19S0) per 1,000, which is 87,321 X 100 ,
** -24,000 person-years
. -w . 100,000 population
- per yr per 100,000 population All ca~* * ;
\ ..
- I 150 cases/yr per 100,000 X SS -,r .1 16x35
, I.
=S,200 person-years per year per S4,100 person-years per year per 100,000.
I 100,000 population population, after a period of years
- I long compared to that required for cancer induction I i
.....t ,... f I t:*
Leukemia -~* 1.47 cases per year per 100,000X3S yrs, . 5.2X35 i I * -s1 person-years per year * , ~ *, Sl80 person-years per year per 100,000 I -. { !
\
' . per 100,000 after many years of exposure 1.
l Genetic .' Possibly up to 20,000 "deaths" per _15.000 "deaths"/~eneration X 35 iI I
\
mutations _. generation per 100,000 population; or about 20,000x 35 30
=- 23.000 person-years per year 30 years/generation S17.500 person-years per year per 100,000 population (after many gen* .
er;itions of producing about 1S.000 per 100,000 population. (This 670 mutants per . generation per 100,000 deaths per year per 100,000 could population at l r/yr) I amount to a considerable fraction of the total ~ortality rate. of 930) j . i t. .. . 1t7t
- t I *'
i ,.
- I
. ,,'*** *r '
* ,I
... I, I'**,.
' \
I
' t fl\lirc population of 011ly 40 r 1>cr gen* 'to be internationally accepted as posi*
T cration ( which, as illustrated in Section tivc indicators of health: I I* II, would probably not produce a large 1. Physical he11hh, including demographic l ,, increase in somatic dnmage to health) conditions
~
I,
- might induce a mutational load that 2. Food 11nd nutrition f '1 ... could seriously impair the population's 1 3. Education, including literacy and 1kil11
.l **. 4. Conditions of work hl'alth or ability to sur\'ivc. u The csti- , S. }:mploymcnt situation 1* matcJ genetically significant tlo:;c from '6, A~grc~atc consumption and aa*inge all man-made sources, not including en* *1. Transportation
' I vironmental contamination, is already 8. Iloui;ing, including household facilities up to about 8 r per gcncrntion.42 Dis* 9. Clothing 10, Recreation and entertainment regarding this contribution, only 8 11. Social security
*"carefully., but individually studied uses -12. Human freedom of radiation, approaching the 0.17 rem
- per year average population exposure However, attempts to arrive at in*
limit to a "suitable sample of the popu* *dexes of hcalth2 ,8, 2MMG have not pro* lation," 43 might he needed to exceed the duccd an index that can be specifically 40 r per generation level. related to the benefits of consumer I.
\Ve are thus obligated to select a items. '
I scale for measuring benefit that will It might in some cases he possible to ex*
, :. permit beneficial applications of radio* * ' press human benefit in terms of dollars 4
~ isotopes, but the exposure limits for .' by considering the personal expenditure
, each item must be selected by some for public health and medical care, the
, I* : *. scheme to ensure that the cumulative increase in this expenditure versus time, r1
,_E*. ,.... ** . , risk will never exceed a level at which
- and the decrease in human suffering the over-all benefits of nuclear energy . ~nd disease over some comparable time i *;: ,.' ,. *_; <* may no longer balance the over-all risks. period.415 Weishrodn points out that bet* ,,I l *l_ :: ** *. Therefore, the measure of benefit must - ter health is purchasable. "Society is r..1 * ~ * * *
- essentially vary within upper and lower not now making the fullest possible 1
~; ** * * *. ' : *.', limits for each class of consumer items -use of existing medical knowledge nor I * : \* .*. .. ,:.' .. to be considered, Further, the amount *is the rate of increase of our medical I
I. t.
, *:*; i ' ' * * /. of benefit assumed for each consecu-F*:* *:- .. .**.
1
~
., ,knowledge at the maximum possible."
live item in a class must be Jimite~ i~ ,' , '~hus, consciously o~ ~~advertently, ~o-
* **
- r * * . ; a manner that prevents the upper hmit ciety does place a hmitmg dollar pnce 1
I
/
- I! * ! : * * -- *
- _ .:* * *' of benefit from ever being exceeded for ' > "on human life and health. Weisbrod I*
; * * *. ' * * . ,: :. that class. * .
- would favor that this limiting price be . *,*
; : ' ~ * * * * **'." . The needs for numerical measures of ' .1
- selected rationally (and consciously), so l ,. *. ~ .the he~lth or , ".level of living" of a j *: )that t~e maximum ~ver-all benefit to
' ,* ... , population are discussed by Swaroop.4~ , humanity may be achieved. ,,
*>. Conferences sponsored by the World 5*: Any number of factors may enter into .' '
- -* :._ (,: . . Health Organization have conclud1rd an over-all benefit or health index. In '
* ," : .*
- that there is no single index of "level
- fact, the derivation of such an index
* - of living 0 that can be applied intei;na*
- may be made as complicated as one tionnlly. Most numerical indexes *, de- wishes-to make it. Henshaw 20 concludes vclopcd and used by henlth 11lnti11ticinns
- thnt separating tho elements affecting
, have been designed to dingnosc ' nnd human health and placing o value on*
. i *. , measure specific community ills. ; How* . each cannot be done with o t1ib'1lilicant
' : : * * , . ~-
- ever, the World Health Organization . degree of accuracy at the present time.
' *., *: :,-'
- has concluded that the following com* ** Yet, we must still devise at least an in*
I ponenta of lhe .level of Ii-ring are likely * 'terim index of benefit that will fit the ~,.___ I,
- j' ~* :* .. * . .
- I
***~ I * <O .. , , . .
\
, .... <0 a
- 1
*., ., VOL IS, NO. 12. A.J.P.H*
< )
.-\--------------------------------**"'*'~* ""*"'"'"-""""'*'-lrPl':".<<4~.....
I'
.,...._..Al"l'f'"**-
I ' *
, J
I
- 1*
l I I I
'1 I *
* ., ..._:_,....,,-----~L
~
RADIOACTIVE MATERIAL
- ~ requirrmenl!I o f objectivity, consistency, the pr~ductivity and employment of t>ffidenc)*, simplicity, and sprcificity.1 ' the population ultimately may con*
* ,*. This index must also provide for some ' tribute to improvements in health. Time*
degree of balancing between benefit and , savin'g devices may to some extent he risk, and some degree o( flexibility in considered as life-saving devices, since
- ju,lging indh-idual consumer items, ** each individual lrn.s only a finite time while at the same time ensuring that the- available for carrying out the various total risk does not exceed acceptable. pursuits of life. Small amounts 0£ short*
levds. 48 lived radionucliclcs may be usc!ul as The index of benefit proposed here is tracers in agricultural studies. f:mply a "quantized,, index constructed E. Social Benefits-Items useful in with the a,ssnmption that the best con*** crime detection; items indirectly im* l [, ' . .. S<'nsus_of pro(essional and public judg- port:mt to national security, such as f l* * * ,. ment has accepted that the
- following emergency radiation meaauring devices;
,,
- classifications of consumer 'items arc other items valuable in protecting man's listed in order of decreasing benefit to .society, improving his mental and so**_',
the United States population: *cial environmtnt, or promoting human *
, freedom. . ,.
Classifications of Benefit
*11. Items of Possible Benefit fa HHlth or I. Useful Items of *obvious Benefit to ' HHlth ~*
- Well-Being
- or Well-Being * */ A. Any of the physical, economic, edu-This category includes all items or : ,_ cational, or social benefits listed in Cate*
uses of radioactfve material in which
- gory I, where the item is not certain to
- a direct benefit to the health or well*
- have a positive value, or where it might .
being of the population can he pre~ .: be possible to replace the item with t ,: : **., *i-,;,; dieted prior to their commercial dis- .' anolher item of equal value that does . .' 1
, ' * *, tribution. This category may include *. not contain added radioactivity or other
~*: .~: .' .. :\,' .items that offer obvious enhancements' .: potentially toxic materials. .
to the following aspects of health: -,* B. Items 0£ Recreational or Cultural * ' A. Physical Health or Demographic
- Value, Except Toys for Children-Some
' Conditions--ltems that directly or in- *.*. i' benefits to health 'may be assumed for directly contribute to the lessening of , these items, although there are abun-
.: morbidity or mortality by prevention * , dant substitutes in our society*
, _: * . ., . of disease; prevention of accidents; pro* .*::. .
- 1*., *~ ~ : * .,
- motion of health; improvements in en* ' . Ill. Items Obviously of Small Value to Health * . ,
1
* '.:; ** * ** vironmental sanitation; improvements .'* or Well-Being 1
.* * * * * 'in production, or consumption of more* r. , This category could include decora*
!_. * , : -**" nutritive foods, and the like. ' ,.
- tive items that can easily be replaced ,
* * - - ,* *.' B. Educatio1'-Itcms or uses of radio- ,
- with, nonradioactive 5ubstitutes, toys
-, , :.* nuclidca that *are obviously contributory that will be handled by children ( unless to improvements in the literacy or skilla. . the small amount of radioactivity serves
- of the population. that might. in tum, some demonstrnhle safcty function), or lead to further improvements in health other items that might have minor hene*
or levels of Jiving. . . fits. Almost any item might be given C. R carch-Those quantities of nu* . some consideration within this C4tegory, elides that may aafcly contribute to the ,'* aa a result of _its po55ible stimulation of
**t I betterment of humanity through public,. productivity and employment.
or private research,
- If. additional criteria could be found 0,. Productivity-Items that ' intl'ettae
,1 I I for better discrimination between cate**
I
.t
gori<'s of benefit, the nbove number ol
- to nny other ilem as long as its dose was cal<'gorics might be incr<'nscd or sub*. hclow some "guide" level or balanced divided into a lnrgcr number of groups by the benefit to be accrued. However, in order that initial screening, ncconl* nvailable evidence 11 *11* 20, 22* 2 G indicates
- ing to benefit, may be more precise. , that we mu~t assume that the somatic
- Howe,*er, the above classification will and the genetic effects of chronic ir*
serve to illustrate
- the methods sug* *
- radiation arc cumulative, as well as in-gested here. teracting. Constant probabilities of risk Having selected the above categories 'per roentgen, based upon linear ex-in order of decreasing benefit, we as- ,* trnpolation (to zero dose-zero effect) of sign the following numerical indexes to measured or estimated effects at higher represent the maximum fractions of dose levels, may he assumed to be con*
*.1 :*;, " benefit that max he assumed !or the servativc estimates of risk only up to '
. '. j,, 'total of all items in each category:. ' some limiting cumulative dose value . ..
* / Catepl'J' Bene6t Index Aaip~ ' Thus, tl1e upper limit of assumed hcnc*
; ** , 1 fit, imposed in Section III by the finite
, 1 n '* 0.900 *size of the population, must be equated
; * , 1 m 0.090 to /~he upper limit of risk produced hy I , *t 1 .* *
- I O*009 *some level o£ ra diation considered to
.. *~
I ;, f*l. *
- j" ,.. .-
be "acceptable" as the total dose-rate from all consumer items. 1
, . *i * *'. * / Table 3 illustrates a scheme by which Total
- 0.999
'I :'l' *,
- tpe total risk may be maintained below
! 1 iii' ** ,'a 'selected limit. An upper exposure limit j ! jl * *, Th~ practi~I application ~£ these bene* of 0.01 roentgens per year averaged
- i; I~ ., ' * *' fit mdex~ m the balancing of. bc;n~fit *, bver the population at risk (i.e., 1,000
/ f i*i .,.'. i.,_ ** ** versus nsk for pr~posed rad~oacti~e 1
inan-rem per year per 100,000 popu* t d *~ , , \ . : * , ) consumer produc~ will be descnbed m ,, :/ lation) has been selected. The equiva* f.Y :'..r .:-,- . ' the following seelion. '.'/,* lent risk is obtained by multiplying the
, 1 r,1, * ~ * * , , . )/ value of 0.01 by the index of risk de*
J' I i\.. *.: IV. Procedures for Balancing Benefit n,,', rived at the end _of Section IIC: 200,000 I, 1l * -=,1, t-- "* * * *: , . Versus Risk * ' 11,1 person-yearsoflf 1eperyearper 100000 , i .1* i~f'. *. i'/ .* population per roentgen/year. The l f 1
*. L. "I
>I/ . .~!if:.*
.r: , ***_,,*_'\ .
l~;i;;ta~~t~~rr:~m~w;:n!~;!:t*, !:;:;t:~t:f:k :r ;,bg~r pei::;~.;ea:: the risks to the population from radia,,' * ,' life per year per 100,000 population.
- r 1 \
* ,:, ~**1;
',, '. ,I l
~. ! ~ l- * *
,
- r* , , lion exposure by separate items coul~ 1 The upper limit of 0.01 r/ycar at be considered noncumulative or nonin-. first may seem unduly restrictive com*
teracting, or if each radioactive **.cm ' pared to the Radiation Protection Guide
- were to be distributed to a completely , of 0.17 rem/year suggested by the Fed* * *
- separate population, then the quantity ' eral Radiation Council.11 However, as of radioactive material used in each .. Morgan has pointed out,48 the *Radia* .
item could be limited purely on the : tiQn Protection Guide is several times . basis of whether or not the equivalent , ' the ICRP limit2M 8 of 2.0 rem in 30 i ,: i-~ *, :.~ ..,.: .* ' amount of human life saved by that*, years from man-made, nonmedical f }/'~ .,:~. , .
' item were greater than the equivalent . sources of gontl<lnl imt*lintion o( the t/ .:,~.~
amount of life that might be lost, as a , general populntion. The 0.5 rem per
... result of the quantity .o f radioactivity . . 30-year limit recommended for internal '17:., \, ,:,
,: l '," *
',*:*t*,* *, ..
in that item alone. In this *case, *each *, 1 * .1sources is not *much greater than 0.01 . * ,, ...-1** , ."')**
*'\
- j .*
I .** it~m could *be treated: without reference !/year. Thu.a, .the eel~tion of the con* l/ .
; i 1-.!.
* * ' i
*t'
** ,1
~
. *I ltlZ .. VOL H, . NO. IZ. A.J.P.H* .
~
- I t *.
~ - p 4 f.
.j. '.: .*, i ," '*
,, *
- t r
- I
*- --. I *
- ~--- ....... ---:----*--*-------*----------*-
. --.:.,.~ --
a .Tabie 3-Fr:maework for Alloc11li;.4: Risk Accordin&; lo Dcneflt n s:
'I" Benefit Upper 'Limit
, of Benefit Assigned* Upper Limit of Population Aalgned <rerson-yr . Exposure Assigned ton*" Item ** Upe_er Limit of Total Numerical o life/105 Approved in Each Catego~ Radiation Exposure :Maintained Risk Assigned*
Fraction of popul.ation (rem/year averaged over in Reserve a[ter Approval of nu, (person-years of life Benefit per year) entire population) Item in Category (rem/year) per 100,000 per year) 6 200,000 X 0.01 X 0.~~- 1r:t X Cl+(i/2)~+(1/312+. **.J
- 200,000 X 0.009
-1.soo
- _.
-180 . ... * - where R.. is limited ,,as above 18 m "* 0.009 y *- ..
Total o.m* *
- 2,000 2,000 w
.* C\!!llia ,.. th.al lllU1m11m pop11lal1011 c1po1ura from all coo111mer Items will 1101 exceed an avera,o or 1,000 maa*rerQ per 7ear per 100,000 populstlon (e,c., aa av0<*&* close
,-r peuo11 of 0.01 1cm/7ear--onc-lifth of the 1.5 rem per 30 7car1 allouted for man-made eateraal 1ourcc1 b7 the lCRr). Ono roeat,eo per year a,eu,<1I c,vcr &ho ootlro poplll*ti* o
,...Jucco
- rlok of 200,000 ecr1911-~**r1 or ll_f* per 100,000 popul&tlou (Seclivo IIC) . . . C - *
, *I .'
.... ' I Table 4--Riak from Population Exposure to 0.01 Rem/Year Compared Over Wide Land Areas
- I Item r All radioactive products (if , <2.000 person-years of life lost per year per total exposure is kept leu 100,000 population (estimated upper limits
than the proposed 0.0l .r/yr) , ** after many generations, Table 3) !or 0.01 . rem/yr average dose to the entire U. S. * *
- population. '
.,
- Automobil~ (U.' S.) *, , ." *. ', t , 35°1000.40,000 dcaths/yr,20 equivalent to about , .
*' .. ; **
- 40,000 X 35 years X 100,000
. ',. 180,000,000
~
'* 1 r \
~ 2"
~
a
.. 780 person-years of life lost per year per 100,000 population, not including loss from injuriea .'
\'
I
- I I
I
..... ,. 0.1 [ ~~ ~] X 100,000X 30
-10,000 person-years of life lost per year per 100,000 heavy amokera of age 35*
- Eetlmoted from Medical Bulletin o* To**-* Vol, I, No, 1, J962,196S, p, J. New Ytd:, '
N. ,T. 1 A*erlcH Pultllo Hnlth A*oel ll***
. .. venient value of 0.01 r/yea.r allows the '\ *,aulomobilcs (deaths only-not including '.I .
- same simple schcm~ to be applied to
* '* ~ . internal as well as external sources. Ex-
' , *injuries) to the United States popula- '
- _tion, and with the risk of smoking to
- l I
,. posure limited to organs other than the : heavy smokers. Thus, it can be seen I gonads may also be included if sim* _. I that the risks from radioactive con*
r plicity justifies additional conservatism. sumer products may not be a negligible
~ : The 0.01 r/year leaves a balance of 1.7 .' a,ddition to the risks from other con-r out of the 2.0 r per 30 years for ex* .. sumer products, particularly if the co*
I v. . posure to weapons fallout ( which pres* : . orclination between the various regula-I j I I 1.-*. .; ,, ently uses an appreciable fraction of ; . tory agencies is loose. I i J*.if'. ,.' ** ., , this,63 ) radioactive waste disposal, TV- '* The 0.01 r/ycar dose-rate is appor-t ** 1 ,::, . . scts, radium-dinl watches, and so on.11 . tionccl among the various categories of I , . *;.
, . *1 f *r* . Moreover, if 50 separate stale or na* ~cncfit in Ta Lie 3 by multiplying the ' * *, J* I ** :
t I ~ i tional agencies were each to administer . ,0.01 r/ycar by the selected index of
, **
- If their own licensing programs without
- benefit for each category. Then, the
.,
- any over-all regulation or accounting of corresponding levels of risk are calcu-the total quantities to be exempted, then lated by multiplying by the index of perhaps each agency should limit itself risk, 200,000 ( column 6, Table 3). The I
- to 1/SOth of an average national (or world) dose rate of 0.01 r/year, or 2
' corresponding upper limits of benefit in
*
- each category arc then simply equated X 10*4 r /year averaged over the total
- to tlie upper limits of risk in the same population at risk.
- Exempt items are , . quantitative units (column 3, Table 3).
not likely to
- remain within eaaily de* Then, as shown in the fourth column fined boundaries, of Table 3, tho upper limit of poputa-*
Also, the aclcctcd upper limit of ri11k lion exposure that may be as.,igncd to lrom consumer items is compared in tho n'" item to ho rcqucstc,t for oxcmp*
.** Table 4 with_the approximate risb from * ' lion in a given category is taken to be
"".i 4 * ~ I
* , 1 .f 1,
1, I *
- t
'\
RADIOACTIVE MATERIAL the (n-+ 1) th term of the series: 0.01 later ta he a poor selection, no extreme
- i r/y~ar X* (assigned fraction of benefit) . harm has been done since there is al* , *t 6 2 ways a considerable amount of expo- ,l,:
X -w2 Cl+ 1/2 + 1/4:, + * * .)
- Since th e . sure held in reserve in any or all ,'
sum of this series converges to 0.01
- of the categories. An infinite number of I~
r/year X (assigned fraction of benefit),
- subcategories, in addition to a reserve ,'
the total exposure from each category *, . bank category, are still available for {u. ./ is limited, and the total exposure from
- lure beneficial items;* The development
~
. all categories is limited to 0.01 r/year, , , of turther procedures for fitting use* t
*
- as intended. ,' ful itcpis into their proper categories *lI The above procedure holds the first . may he carried out by appropriate term of each series in reserve to allow agencies and professional organizations I" for possible accidents, errors in design in consideration of public needs and
* \ * ** .or manufacture, or ne,ver items that are , . desires. 1 found to be worthy of some additional C. Estimation of Radiation Exposure 1.
1
~
** exposure beyond the limit of the as* . and Risk-The estimation of external !
, . . signed term of the series. However, ordi- .*'radiation exposures may be carried out,
** \*
- narily each item should be approved only 1
1 for the minimum amount of radioactivity .
** ~ *. ... necessary to serve its purpose. The dif- * ; data using dose-rate constants obtained from the literature or calculated from nuclear tahles. 411 Consideration should be
,1,
.ll
. fcrence between the limiting amount of * . given to absorrtion of the radiation by I
** * -. .. : exposure allotted for the n'~ item and .* v~rious materials, average distances, and '
- i,
. .* '.t/ *"the actual amount approved should be *. other protective factors built into the !
... *. .. *. added to the reserve for that category. . .item or encountered in its normal use. I
.-~ l * .,
- Further, the petitioner for exemption .. Table 5 presents some specific dose-rates
; , ., '-, ~ *
- of the consumer product should be re* i, from external exposure to various radio-
.. ,. **. ; * . quired to submit a written analysis of
- quclides. These values are upper-limit *
* ,
- the benefits and exposures inherent in '* estimates and are subject in use to the
* ...,: **'
- the use of his product. The actual ex- *'
- qualifications listed in the Table 5
,. posure risk approved for
- each item , footnotes. Values more appropriate to
.* . ~.- should be balanced by an equal or ... the specific situation should be used
., greater amount of expected benefit : when available. Table 6 presents esti* ,*
- , ./:-; .; . within the limit assigned to the item. '
- mates of the average external dose-rates ! r
, . . ** _: The above procedure gives greater ad* . when some of the important gamma- I t
.. *::. _ , : vantage to the petitioner who develops emitting radionuclides arc spread over
' *' * \ :. his product sooner. However. this is a i wide areas of land. When items emit
* , *.. * , desirable aspect of the scheme, since it1\ . a consillerablc intensity of unshielded
, . . . , would tend to stimulate the earlier de* ', /, beta radiation, the beta dose-rate should.
*~ j;:
- velopment of more of the beneficial uses . 1 be measured or estimated from rules 0£ thumb,'10 and surface tissue doses should
' ' *** of atomic energy. "' ~ * , B. Determination of Category of be maintained less than the appropriate *, I :* : Benefit-Many items will not fall easily limits for members of lhe population into any one of lhe Categories I, II, or III . at larrre,26*21*11 I
I'
' fl ;. ~ * . ~
- i -; *
**' I suggested in the previous section. Thus, there is still room for the exercise of professional or human judgment in
, Dos~ to various body organs from radionuclidcs in drinking water may be ......
- estimated for single intake12 or con-making administrative decisions regard-* tinuous exposure.27 Internal radiation
. 1 ing specific items. Yet, even if a catc* exposure from radionuclidcs that may 1
t I I
*) gory o( benefit aclccte,1 for an item' enter food chains may lie C.'ltimated for
- by the above ,scheme should tum out , apccifio situations from ecological data
~' * . . ' t , . 'I_ ' .... ,* **:. <... ', ' . .. .
.J ;,, .;- DICIMl~I. 19'1 '. : .... .* \ ,~*1
- \ 1 1 ., . ;, * **. , .
1
... .e Table 5--Spn:ifac Doso-R111ea Crom lnlcrnul 1md External Exposure lo
, Variou* lladionuclidc Maximum External Dose-Rntc from Maximum Doso to Anr Point Sourcct
- Dody Organ* (r/hour at l meter Rndionuclide (rem per l!O in~&led) per µc}
11-3 (as HTO) 0.00038 nci:ligible C-14 (u C01 ) 0.00052 < 10** Tc-99 0.0030 <10**
\ Fc-5S 0.0069 <2x 10-*
Au-198 S-35
... *: 0.021 ,
0.021 2.5x 10-'
<10-*
Co-60 0.021 l .3X 10** La-140 .,.,.::: . . *, 0.035 9.5X 10-' Fe-S9 * ..~ .:.:.. 0.037 6.5xlO-' l\lixed gross fission * *.~** ., **.. o.04oi <7xlO"'
- products 180-day . . 1 I
irrndiation time -: * ." ' ,, '
- Ir-192 ,*t *, ' '
- 0.047 5.1 X 10** '
i,' Cs-137 ""'* \: *.:*-:.. , 0.058 3.6X 10"' ! Ba-140 Pm -147
~ ; (*? t '.-*~**
, 0.11
' : .*. ' 0* 17
' : *. ... , 1.54xIIH
<10**
~ * ' ** . ,
P-32 * .: .r., -:*. 0.17 ,-1 <10-' Tm-170 : !.', ; ' 1. ',.: 0.23 4.0x 10-*
*Ca-45 . ., ' :\*. '~ 0.35 <10**
.... Ce-144 II *
, ,. * * *: :. 1 09 2.0xlO-' "
J-131 ,:.**;,**, *1 1'25 j I *~,/. flt. ' , \1 * . 2.5 X 10-1 Po 210 .* , *.'. \ *.. U . <10-* Sr.90 . ' . , * *1/J 38 * <10**
~ * "1
- I \ 'i I U 233 (with 20 *-******., *f ~ 56 ' 2x10-u ppm U-232) ;. i !~,.....
Cm-242 57 : *.* *, <10**
.' ' , '. , U 238 U-235+1%
,**:*:~/,.':?:*
Y~~:. /:*.~:- U-natural ,
- _.. :*:._* , , .
- 80 (but \'ery low 88 specific ~etivhy) ,." '* *.
103 (but low speci.6.o
; <2x10-* *
<2x10**
- . -'t . *- <2x 10-*
activity)
.,. - Am-241 *
(I . .-,'*
, 2,280 3.9x10*
- I Th-230 5,320 9x10*
- Th-natural 6,600 "(but low apeci.6.c : <2xlO-"
activity) Pu-238 6,850 <2x10-* Pu-239 7,370 <10-u Pu-240 7,400 <10-* Kr-85 (See Reference 27) l.9x 10-'
.i ...
- E1tima1ed. for "11andord" iO*Ks m.,,,u Crom data In Reference 27, for the h<Ml1 orJH Ukelf to ree,1.. the hlrheot dote witbla SO yearo from a ainrle Intake of 1be 1111terial In Ila moil ba&&rdou1
- form. The e dn1e1 ,hould 1ener1ll1 e1tee1l 1110 1ho mas.lmum organ do,u to 111ndard man from
'. lfllf' tl nn or lhe m1trrlal , aln re
- lar,re frarllnn nf Inhaled materlal 11 au umed 10 rut throu,:h tho Cl trttt In th* ICIIP,Nt:nr reaplrttnry mn,l,I." It lo unll hly th11
- nr al th*** n h1t* wnul<I
- I I. h-' lnw hy mnre lliAn
- ful nr of 2 or l. r,, nr1lrr '" 1le 1r.r mln" tho rate n r lk, 1h,10 *"lu,, 11111 ho multlrll*,t hr 1h, rote nl 11p1ako In n,1,1rnr<ulr rrr un it li mo 1 ,llfl.,,n,e, In "*"* ,ll11rlh111l"n with llm*, due ** ,llflrrenl hll,11 ,u 1n,I l,ln,ln~i,ol ell,nln*tlnn lhnto, may b1 n*el<<ted tor r11rp11te1 el 1h11 r*r*** llowc*er, In c11u where t,l nlnclt*I and ehemieol tl111 are 1toll1ble f<>r a *pedr.c 1itu1tlon, better tlllmolu or actual do10-r11u m1y bo 1uballtuted !or the aboYO n luc,, Fur1hu,
-! ,. It ohould be kept In mind thll dose, to *mailer lndlYldual, or lrifonta may be Crom 10 10 100 l haeo
*r i,1; 1re1ter tll,1n tho,e for 1tand1rd ****
- 1 1*
.! t Estimated mulmum smma or Drem111rhlunc doaea lor . photon, ef enua l!fllOter thin 10
- K ... , nedeetlac 1btorptloa br tlao oouree llrolf or .,, otber 1bleldlt11 ( .. Inc data eomplled la ll*fenacu 49 aad SO)
- f H£,rlnleat" , _ ptt Jk from 1yer,t1tlc efftttl el ,.,. llenal d - ** ,..,1.,.. lledr <<sa**
' from **rfnl ll*lo**Pl'Net rodlocllde1, e,tlmated br tN Hlllw In* tiara of Jl.foruee Z7
)
' * *. C-.. ... It..... n4 II..,_,... .
1e *llaate ,...... 1,. arotl etl,e, - - Thh * - h ollo t
- lactw of S 1- lka ti. -,.mi. *ea*tltF 0111- .t n .,,
1916
... ... - 'I
. ' r
; '1 I
\
.e
*t 1,
RADIOACTIVE MATERIAL
- 1 I, ~l 1
in the liternturc. Rndialion exposure tion nllliation exposures, the conversion 1 I from inhaled materials may be esti- o{ these cxpm111rc!I inlo mrnsnres ol mnlc..l by the nll'lhmls of the ICHP::T . humnn rii.k, 11111:h n!I 1ho!I<: prrscnlccl in r!,, or from cxpNimcntnl clutn on the l'i)C* cific form, quantity, and ulili:.mlion of Scc,ion II, nncl the l,nlnncing o( ri11k vcri.u!I l,rnct.t 11houltl he cnrril'd 0111 l,y the raclionclivc malcrinl uncler con* ' prorr~..;ionnhi who must, however, l1avc l,! siclcration. Table 5 presents some upper- guidance in jll(lging human benefit as ,r limit cstimntes of radiation exposure well as specific guidelines, such as those .: from inhnling many of the more im* proposed in Section IVA (and Table i portnnt rndionuclides. These estimates 3). This guidance should come from
' I arc also based upon the data and melh*
ods of calculation of Reference 27, as-high levels of public responsibility and from a wide range of professional and j suming the radionuclides in each case scientific disciplines. Thus, the frame* i, to he in a chemical and physical form ... work becomes only a guideline that re* *f that would give the largest radiation I duces the need for repeated policy de* *r f. dose to the respective critical organ of
- cisions on population radiation exposure, '
~
re£erence. Again, data more specific to the actual conditions of manufacture allowing more professional effort to be directed toward the best possible estima* *
~.
and use 0£ the exempt item may be tion 0£ radiation risks, the most expedi-* .l I used when available and reliable. tious handling of exemption petitions, *I I t '.. . D. Balancing uitimated Risk Versus
- and * *he administration of programs £or
~
~
I
~ l Estimated Benefit Within the Allotted ,' controlling the total population exposure I
*I 1 Framework-The estimation of popula* from, nil man-made sources.
.,.1 .I J
l t Table 6-Camlnll Radiation LeYeJa 1~m Rodionclive Mnleriols Spread . ,,*
- over Wide Land Arai
'AcliYity in Curies per Square ... ., Milo to Produce 0.001 Roentgens per Hour at Three Feet
- -. I
- .., .. Radio- Physical Above Ground.
- f nuclides Hall-life Smooth Surface* Rough Soilt
- - ., Na24
' .. Fe51
, * ' C0 60
- J ,: * *
' , *
- Zr11 5.NbH
* ,,
- Ru103
", .. Ru 108
~~-- _'.. 1131 Cs13T Ba140.La1t0
! , , ., Ce144.prlH ,
J * * , Tm1TO
' ** .- *' ' Jr192 Ra22s+
daugbtera ' 1,620 years 263 Pu231 24,000 yun 1,310
, Am2U 470 )'Ul'I 5,660
\
l
'~'
I
.. , ---4 1
, I' ..
DICEMII .. 1HI 1 '
*II*
- I ,, \ I 1987 I
- I' I I*
- ...- - - - - - - - - - - * - - - *- -............_. _ ____ ,_....._.... - ~ ~ ~ .-....i-.i ..... .......
r0 f I \ 1; \. , :* '
- t. " V. Summary made on the basis 0£ a precise mathe-1 ,' ' '
- matical formula, but must be a matter I j
l'. . ?\Janyh recommcndati~rs ~,~ve bc~n of informed judgmcnt."11 No argument I ,
,' ~: ma c t at a rcasona e "- a ance ef is given to show why, as an "operational 1 .. .
- achieved between each bcncncial. use o tcchnic,"11 some kind of systematic
\
- 1. radiation and its corresponding risk.* formulation-mathematical or other*
For medical radiation exposures for wise--cannot be used to place popula-
\ diagnosis or therapy, the professional ' tion radiation exposure on a sounder
, ,' and regulatory communities have gen* accountability and control basis.
erally accepted that the physician should * , A framework for balancing and con* he allowed to weigh the benefits and . trolling the alloLments of radiation ex* risks of exposure, according to the needs posure from consumer items has been and desires of the individual patient. .
- presented here as an example of the
~
- Public opinion has generally accepted, possible application of specific quantita-i: /: *~ , : * ., 1 for the time being, the balance of risk 1 tive fonnulations in the administrative
, *." 1 *.(t~ * *
- from fallout (on the order of 10 per control of population radiation exposure.
- .:( i : * . : *~-- *.
cent of the radiation exposure from natural background118 ) weighed against The application of scientific or quanti* _ tative methods in deciding the accept* t' I i* ,
- i I * ** **
- the national needs for efficient defensive I ability of a particular consumer item r*
'. t;!' * '. **: -* :*:: * . weapons. However, further guidance is
- has been illustrated in Appendix A as
,. =.
- needed from a centralized national
- 1*. ~*
1
- * ._' * *. ' .:--~.~. group on how to balance and control the **
a further example. Thus, the principle aim of this paper has been to stimulate r 1 i: ,: - .. ' ** risk of individual commercial and con* the development of a centralized system
\*~'.! sumer uses of radioactive materials, so
- of controlling population radiation ex*
'? . ,*, that the total risk will never exceed posures that will have the following ad*
- 1t* * *' those guides already recommended by .* vantages: ,
1*p .' *--: r . ..:' the independent professional committees l. Provide a framework for ensuring a safe f:f' ,,'; *, \ *
- and by the Federal Radiation Council. *. upper limit to population radiation e:11posurea I*~!. , ' .*: * . The need for centralized control of all ,- from all man-made sources. .
Iii~ 1 f * *-~*. *r ~- sources of radiation was implied by the 2. ~{ovid~ a? ob!ective and ~onsist~~* basis
* ** *'1 t ** ** ":,\,,.; ." p ubl'1c HeaIth SeIVJ.ce* ,s a dVIsory
- com-
- for fairness
. in Judging consecutive pet1t1ons for
* *a1
* :. 1 . * ' ' ~~*,** * * * * . * *. e:11empt1on of consumer items or commerc1
* ;~ * ' *... * * *. * ;
- t ' f I : :.* * * * *.' .* t\
m1ttee on radiation m 1959. As a re* sult of Public Law 86-373, the Federal 1 products containing radioactive materials.
- 3. Promote the beneficial uses of atomic i1 .
1* i :* * *** ' Radiation Council (FRC) was estab- *' energy by (a) establishing a uniform policy
'
- t:;*_i i:;
- lished to provide guidance to the fed- .\ and basis within which the professional analy*
l ~ *.., -.. ,' l *
- h f 1
- f d'
- sis of benefit versus risk may proceed more i ' 1 ,'. ~. . era agencies mt e ormu ~hon o ra Ia* c' cditiously*1 (h) reducing tho chances thnt
- ~; * , . tion standards. The Federal Rndintion ~ 117! d~ks wil1 ho ovcrCt1tilnntcd, ns well as tho 1
,: ' ' , Council has performed a vnlunhlc func* chnnecs they will be unclcrcslimnted, by mak*
- lion in reexamining 8Cicnlific cviclcn~e ing !naximum u~ of_ availal'.lc data from the .
rc,.nrdinrr 0 0 biological effects of radiation phy_s1~al nnd. b1olog1cal sc,e~c~; and (c)
* * * * ' avo1d1ng puhhc fear and susp1c1on that may
... and m developing broad gu1dehnes that breed from the lack of consistent and reason-essentially reaffirm on a policy basis able procedures for ensuring public health previous recommendations of inde* and safety.
pe ndent professional groups. However 4. Increase. rather than decruse, the oppor* h'l 1 *
- th
- f b 1' tunities for the use of infonned professional
'If *e reoogmzmg e n~cessity O a
- judgment by reducing the need for re-estAb- .
ancing benefit versus nak, and t the lishing policy when each item comes up for same time limiting total risk, the , FRC ,. consideration. This would allow more profcs-usert.s: ..Such a balance, cannot be , aional time for obtaining better estimates o( radiation exposure, determining appropriate . quality control and inspection procedure-. and
,. *cateco,iling benelits to be obtained.
*I *
- t .........
... ,, RADIOACTIVE MATERIAL APPENDIX A Population E1po1ure Considerations in EHmpting Trith,m for Use in Luminous Timepieces In 1960, the Atomic Energy Commis* negligible radiation exposurcs, 1G but sion exempted from licensing control would lend to displace and reduce ra<lia* the possc..-.sion by members of the pub- lion exposures from timepieces contain* lie of luminous timepieces containing ing radium. no more than 25 millicurics of tritium In addition to the small potential per timcpiecc.H The composition and r adiation exposure from tritium, an* application of the tritiated luminous other special characteristic of tritium paint to these timepieces was subject to had to he considered in regard to its
.... . licensing control, however. Rigid quality possible effect upon the human mutation
,* control procedures were required by the
- rate. Tritium, an isotope of hydrogen, t
commission to ensure that the tritiated could become incorporated into the 14
. : ,. paint would be least likely to be dis-pcrsed from the watch to the general genetic structure (DNA) of reproductive cells. and cause mutations as tritium
- t. emironment, although the dispersal of atoms decay to Helium-3 atoms. Under
{
. the material to the environment was the conditions in which tritium would iI
~
still not expected to result in a signifi- , he used in timepieces, very little would
! cant population exposure. ,' he dispersed in soluble form into the bio*
- t . \ \. The radiation safety evaluation 111 pre* .. sphere. 111 However, under the assumption l
sented by the commission in support of , . that all the tritium being incorporated I
. \ the tritium exemption gave a detailed on timepieces yearly is dispersed into
' . comparison between internal and ex* ,, the environment yearly as tritiated temal dose rates from quantities of tri- .' 1 water (HTO), and ass.urning that every ,
tium and radium that would produce
- tritium *atom in DNA transmuting to equivalent luminosities. The radiation Hc-3 results in a mutation, even 50,000 characteristics of tritium and radium ' curies of tritium (from 2 million lime*
arc compared in Table 6. Radium . ' pieces) dispersed to the environment watches have been found to contain up yearly could produce no more than 2
, ' .. ~ to 2.2 microcuries of radium,G* with the millionths I
of l per cent of the muta* average watch containing about 1/4 to tion rate estimated from natural
..::, ' 1/4 of a microcurie.'111 The British Med- causes. 111
* ! .. ~ . . ical Research Council has estimated that .
- Thus, the AEC radiation safety evalu*
**: *.:
- luminous watches and clocks, contain- **. ation serves as an example
- of the use '
*.._ * ** ing an average of 1/4 microcurie of ..." of information available from the phys*
* *,: : Y. radium per timepiece, may increase '. .' ical and biological sciences to make im*
; *:
- the population gonadal dose by 1 per
- r portant public health decisions regarding
. * . . *
- cent of natural background.111 I£ . the control of population exposure from I
' , : **. watches or other items containing larger . 'j radioactive materials. ,
~; . amounts of radium (not under AEC> * ', In the case of tritium in timepieces,
*..
- control) should become popular with , the reduction in exposure from radium .
the public, man-made radium exposures _* served as a clear-cut index of benefit 1*,>,- ,
~*
- could contribute a considerable portion*.
- thnt could ensily be bnlnnced agninst of the 2 r ' per g<'ncrntion dose limit the equivalent ( rndialion plus lransmu* . .'01 1
recommended by the ICRP. From the
- tal ion) exposures .from tritiu.m, Fur* * . ,'_ ,, .
*/<
- r data of Table 7, the AEC determined * * :. thermore, the use in the calculations of , * '
l t that timepieces containing tritium-acti* * . what initially seemed to be ultracon- ' valed pabit wou~ ,... only '.'"'.~:~~ ;~dve ......~'"".:, ~*fred by lh* I ;', DECIMIH, 1HI . . . . * .._. . . ' :.
- i' i~ -.., .
' 1919
*t:.:,: ,, . ,**"* . ( .-
. *1
....,,"""--~-~,.,,.l!l!':'!'---Tw.-------"""'
---------=. . . --==::;;;.::=;:;:c=;;;:;;;:::= ;:::::-,;;::
~
I
~
j
... I r
j' I
. I~
I
." I
- e. I
.I I
I
/.
I I
- I Table 7-C.01111tAri11on o( l\1ulia1io11 Charactcrl11tic1 o( Rodium* and Tritium-Aeliva1cd Luminous 'l'imcpiecce* .I Characterialio Tritium Radium I
(1) Half.life 12.3 years 1,620 years (2) Radiationa emilted ' ' Bela particles only-0.018
- maximum energ, O.OOSS ,
- Me, average Alpha particlcs-24 Mcv per Ra disintegration; Ilcta particles
-about 4 per Ra220 disin-
, *. tegration with maximum
'! energies 0.65, 2.3, 0.017,
" and 1.17 Mcv; G:immo Raya
..:.about 2.29 photons per Rallllt disintegration, with energies ranging from 0.184-2.2 MeY.,
averaging 0.78 Mev, (3) Range of radiation 0.0006 cm-range of 0.5 cm-range of maximum in tissue maximum energy beta *energy beta particle; 10 particle in tissue inehe9-avcrago penetration of gamma ~ay~, range
. Is infinite. **
(4) External dose rate at Negligible-low energy
- About 0.009 mr/br at l foo&
1 foot from watch Bremsstrahlung ii per microcurie
',, absorbed in watch *
* *
- crystal
~
* - t' -
(5) Maximum permissible * ** 1 millicurie , 0.0001 millicurie continuous body burdea * ' (NBS handbook 69) * -* I' , . , (6) Effecti\*e half-life in ' ..* 15 daye ** , 1.6 X 104 days ( practically total body
- all of the radium is retained in bone)
... (7) l\laximum permissible 2 X 10** microcuries/~ .:
- 10-11 microcuries/cc (in concentrationinair *.* (asHTOorT110); ' . ;,* soluble form); 6 X 10**
for continuous :, ** 4X 10* 4 i'C/co (u / pc/cc (insoluble) occupational exposureff , , . hydrogen gaa) (8) Maximum permi.uible **;_ 0.03 microcuriea per cc 10-' microcuries/cc (sol.);,
; }, , , concentration in water * (u water) 8 X 10* 4 i'C/co (insoluble) for continuous , ,
occupational expo111reff** I' ' -**
~ :
- j (9) Dose from single intake 0.2 rem to body per 450 rem to bone in 70 years per by inhalationt millicurie soluble HI; microcurie soluble; 250 rem 6 rem to lung per to lung per microcurio millicurie in insoluble insoluble form ~ *
(10) Relative quantities to give
- 25 millicuries per , 6 microcuriea per timepiece same luminosity timepiece . ,
I \
.*,*,*. VOL. 51. NO. 12, A.J.P.H.
;;; 4 I ;; t
. ,*, * *L*
RADIOACTIVE MATERIAL limited knowledge of radiohiologic c£. 16. ltnr,,n, C. W, Currut Statu or AEC*Stare C.,. ' nprrall*o l'rn1r ra. A./.l',11, ~ldl7&-88I (June), J?Gl.
* {eels nnd cauH'S of mutation, ended in a liberal result. Defore exnmining tho
- 17. Mnr,tan. K*d Z. .. l',*lcclla* frftnl lantaJ111 Radl&*
tln11 ... fn Sele<lcd Material u R1di1litta Pro1ectica Crltrrla 11nd St* nd11d*a Their Dui1 and U1*. Wuh* calculations of genetic exposure from lnitnn, D, C.1 GOY, Pt&, Ollice, JCAE (Mat), 1"-0, i'I'* 2:-,0..31,. tritium, the author £cit that the dis* II, 'rho m~r..11,ol Elfe<to or Atorwle R dlallor,-Summarr
*r . pers.'\l of thousands 0£ curies 0£ tritium to the environment would probably llepnrlo, N tlnnal Audemr or Scleaceo-Natl<> ol Re*
11earch Counc:ll. 1956. lI . constitute an unacceptable hazard. How* 19, The Dioloalul Elfecta or Atomic lladiatlOfl. Nulooal AcademJ or Seloneeo-Natioaal llcaear<h Couneil,
,..I.'
1960. ever, after a detailed analysis of the 20, llcn*h w, Paul S. A11utlnr tho lmpac1 or ED*
*ironmcntal Radi lion oo Total llcahb. Health Pb71lca problem, the nutbor !eels that the pro; 1 :141-151, 1958.
motion of tritium as an activator of 21, Wald, Nici. Leukemia la Hiroahima Cltf Atomls
' luminous paints would be of negligible * &mb SuCYl*orr. Science J 27 :69!>-700, 19511,.
Au11ln M. " Somatic Elfccll," In Selttted Ma*
.
- risk and considerable benefit.
- 22. Drue,,
tcrial* on Radi*tioa rrotectloD Critnia *nd Srand*
'J
' ard11 Their Dula and Uac. Hearln,ra bdore tho Joint Commillee on Atomic Encrr7, Conrrc11 or tho REFERENCES United State,, Mor, 1960. W11bln11on, D. C.1 Co,,
\ ,,, . , rte. Olice, pp. 428-429.
- 1. Swuoop, Sty, lntroduetlo* t~ lluhh Stallotleo. U .' Report or the Uahod Natlou Commltr.. 011 tbo Edinbursh ancl Lo clo t L1Yln11to11e, L1tl., 1960, PP* Elfccll or Atomle Radiation, General Aoaemblr, 239-2-16. Uniled Nat1<,n1, Thirteenth St11lon Supplement No.
* ,, I. Dana, Halbc.1 L. Htallh aacl Domocraphr, Publlo 17 (A/3838), 19$8. New York. N. Y.1 l otornatloo,I
,. t . _ Health SeCYlce PubL No, 502. Wublostoa. D, C.t Document, SeCYlee, Columb ia UolYet1lt7 Pre11, p, 28
** , ., Co,, l'tJ. Ollice, pp. 7H4. ind pp, 162-1671 11 0 eo 1962 cdllloa, pp. l0(H0l
, * , J. Cloeco, Aatoalo. Oa ladlteo ror Appr la&I or Health nd pp. 14!>-ISO.
,* .*.,., Oepu1met1t ActiYill11. J. Chronic Die. ll :SO!>-S22 ,IC. Muller, H. J. Radiatl~* and Humao Matatluoa.
(May), 1960.
- Selcntlfic Amoriun (NOY.), 1955.
- t. Atomic Enern Atl of 19S4, 84th U. S.
- Concre11, 2S. n~rnrt on Dcc!1lon1 11
- the 1959 Meetlnr ot the SeetloD 3, Chapter 1. lnternalional Commlulon oo Radiolociul Prorulloo.
\ I. Atomic Eneru F,cta. U, S. Atomic Eaera Com* (ICRP Publlcatloa) Health Ph Join 2,3 :317-320
',
- 1 *. ; a,iuloa. Waahtnstoa, D. C.t COY, Ptc, Olice, 1956, (Feb.), 1960; and Am. J , Roenl, 83,2:372--375 (Felt.) ,
, * ,; .'** , p. 162. , 1960.
.. Title 10, Coda or FcderI Re1ulatlan,, Part 10.I . ' 26. Recommcnd1tlon1 or the International Coramlulon OD
. :: ~_.: ~ ' * "St1ndord1 ror Pro1ec1loa As1ln11 1ladlatlo1f' Waah* R1dlffloclnl Protection, Adopted September I, 19$$.
tn<<lon, D. C. t U, S. Atomic £ner11 Commlaoloa. New York, N. Y. t PerJamoa rre,a. elfec11.. ln orr, 1961, rt, ICRP Commlllco fl Report. Health Ph71lu Val. I
- ' 7. Morion, R. JI., et al. The Coatrol or RadlatiH .(J11no), 1%0.
Huarda la the Unltecl Stoica. Report to the Sursooa 28. Snrder, Walter S. Rnco or Uncertaltf ot MPC CenerI or tho United State* Pubilc He ltb SerYleo ltJ Value,. JCAE llcarlnp. U, S, Conirt1*, M11 1960,
... tho NatlonI Adrlaorr Commlllee oa Radlltloa op. ell,, pp. 338-381, (Mu.), 1959. 29, National Atademr c,( Sclencce-!'iatiollal Reaeud,
, ,- I. Sillnr ol Nuclear Power lleaetora-Ol1ea11loll aad Council l' ubl. No. 883, lnternal Emitlen, 1961,
/. , ~ *, , Commen11 on Sdctr Coaalderatloaa, (Atomic la~ \ : 30, Shield,, Warren, et 11. Pathological Elfecte of
, , * ~ **. du11ri1I Fonua, lac., 3 Eau 54th Street, Now York Th1rold rrrad larioa. NAS-NRC Commluce Rerort.
'.. . *,~1
- 22, N. Y ~ (Aus,). )959) . Waahln(lon, D. C.r Federal Rad iation Couneil (J,Jr),
* !, ~ * ** Reactor Safety a11cl Huardt Enlaatioa T .. hnlquct. 1962.
,-,~~
- Vol,. 1 and 2, lnteraatlonal Atomle Ener11 Ace*J'* , SI, Federal Radla1lo11 Council Report No. *:. Backcroaa&
* ' Vienna, 1962. MaterlI for th* DCYelop111Clll of Radiatloa Protectloa
-* :** '; -~ 10. l'ermlulble Doao from E,tcrnal Soarcea or font.Inc Standarda. w..hin1ton, 0, C.1 Co-,, Pts, Ol&c*
1
- .'
- Radiation. NCRP H1odboak 59, pvblialtccl l,7 Na* (Sept.), 1961.
1io111I Dure u of Standarda with addenda. 1954. , 32. St111,t1cal Altauacta of tho tlnitecl Si tet (14th ed.). 1
, .' '.:_. *.1.*.*,
1 ~
'\Va1hia1toa, D. C, 1 Superlnt.,.dent or Doeumeoll,
- 11. Radiotloa l'rotectloCaa Culdanco for Federal A1eaclea. ;. '
Federal Racllatlon uncil Memo to Prealdent, Federal W*1hln1ton, D. C.t Bureaa or tho Con,. Depart* ment or Commerce, 1963, pp. 6~.
- 33. Dunn, Halbert L. Heahb aad Dcmosnphr, Op
- cit..
':,, * , .1 Reclater, Mar 18, 196%: also, Feclesal Radlatloa rP* 7$-77, p. U.
- . ,'; ,,. Council Report No. I, Dackiro-.ad Material ror tho 34.
- Dora, Harold F. Method* of Mcaaurlns l11ddeac:e
*~ Dnelopme I or ll1dlatloa Protection S1 adard1, Map and Prenlcnce or 01,uao. AJ.P.H. 4112n (M11.),
-~ *,.. **~.t
..... \ -* ts. 1960. t95T *
*. *: .::. ., , , .12. Notieo or Propoeed Rulo Making, EumptlOll of
- 3S. Dunn, Halbert L. Op, cit.. pp. 81-81.
Lamlnou, Thaeplece Conralalns Hydroeo 3 (Tri* 36. llild~ p, 13, p. 8S.
',' ~,
tlum). U, S, Atomic Eaercr Comml lea, pabllahed lt1 the Federal Re1l1ter (July 2), 1960. 37, Federal Radlatloa Co11nell Report No. t. Op. dt..
, p. 14. *
* * ~1 ; , IS, Norlc of Receipt or Pctltlo11 rar Eumptlon, 10 18, Fedcr*l Radiation Connell Report ND. I, Back*
, * ,,, CFR Part 30. Loclr. lllu*lnatora C011t1lnln1 Trltlllm, ,round l!aterlal for tho Dorelopment or Ra41aUoa, l
~ ,,
- Federal Rerlater 3571. April 26, 1961, l'rnte,Uon S11ndardt, (Mar U), 1960. p, SO.
' , i .~
- 14. £u111ptk>a et L11111lnou1 Dial Tlmo*plecet Contois* , 39, Ibid, Pp, IHI, ,
Inc llydro,e* 3 (Trhlam). 10 CFR 30, F*doral , 40. Wcatern, Forrett, In Radlatloa Stanclorda, tnel1'dln1 Re1l1ter ZS. 12730.
- Deuabct 13, 1960, Fallo1't, Statomeat bctore the JCAE 8711, Co*in...
I " '* 1 ..
.~. ;., ' '
; IS. ll1dlatloa Salotr E*latlea of Trltla-Aetl*atN Dlala ta Laml110111 Walehoa &N ctecb. WMllt..-. ,
D. C.t U. I. Al..ie lwg C*u*hil-. Jw ,It,, IMO. . ' Waahln11a11, D. C.1 C... PIS, Otiee, lHZ,, *P. W-.1611, 41, Mtdltt, IL I, 0,. ck,. ala Natloaal AcH-r llf lda1..,....ttatlwl a-n~ C.UCU a.,. Op. dt.
. . ./ .. .'.,.
I DICIMIEI, HH ~ ..,,
.1
- u. F,Jrrol lhdiollea Co***II Rtrorl No, I, Op. cit ..
r, 21.
- u. ***r fnr t,:.,.1111,tfn<< lhe r11blfc Conaeq**ncee of C1t&1*
... F,,1.,.1 11*,tl*tloa C**ncll *t,.,o,.*d*,.,
106<*. Or. rlt, s ... .,,..r. S*tpa, Op, rlt., rp. 23._2'6*
- u. .\,ul,,.n", 0411* . ..., 111d l.f'r*t-r, ,1oeroe. ar~***rl111 11, trnphic Acclden t1 In Lar11 Nudeor rluto, Hult~
l'h11l,o I (June 1), 1958, St. Ve11r,1rr, J** anJ )li111kl. Ater,aret. Radl1llo D~ee* lrnm Admlni,tered llodlnnuclldeo, Drlt, J. R,diol
- IIHhh t.HI* 111 Ill. United St11eo, 1900-1958, Now 35,41C:372-387 (June), 1962.
l'Nl, N. Y,t lltolth laform*tloa Fouad*llo* Ser,
- 11. 1"60..... 31, , SJ. Cttl'tdenn, r. F. C:* m***R*1 D11ao front Short-Lf.,ed
- 41. 1-*11t11lon Prorlwtle hnrn Nut"'frer Wt'!1pttn 'fe1t1. JCAE o,..,h, h*n*I* 11', S...l*I end E,.,nnmlc Ceanr** la
- r.nn,:rtuinnl'I Jlerln,:1. Op, ell., p, IS7 J fta,
.,. E*ol.. 1in1 r,ottttlon A11in11 ll*urdo, JCAE llur- ,
'**** 106(!, rr, l:&-13Cl.
'If ,lohr,,d, nunoa A. E,onnMln ot rubllc lhollh, GH ldtnn, r. ..... en,I Brar. s. s. Health rh,1lc
,.6:6:9-634 (Juno), 1963.
I ,,
.. ... rhil,ltlrM, r *
- r v .. ,.....11, ., rcnn17IHni1 1061
- r,.... ' 54. lla1bl1tle, ]. L. llodlotlon 11...,d Iron, l,umlao"'
Wotehco. N11are Ill, No. 46:ZO (M11 17), 19$8. 11
,. ... s,...,.,,,,.,..,
M****** Ke,I Z. ruml11lble E*roeure to fonl1ln1 Radlollon, Selen,. 139,3SSS1S6S-,$71 (Feb. 1$), 1963. 0 .: Hollender, J, ~I.: and Seoltora. C, SS, Tho ll1urd1 lo Man or Nueleu and Allied Redla, lion,, Drltloh }ledlcol Reoeorcla C011ndl. Loadoa, Enrland, lier M0Je111'* St,Uoner, Olliee, 19$6, p. $3,
- 56. Fe,leral R1diotlon Council Repori No, 3. Heolth Im*
[:. T. Rno. Moder* rh11. 30, No. 2, rart II (Apr,), 1958. plication, nr F*llout fro19 Nuclear Weapono Teot1n1 f.
- 30. Rr.d,l7. Alloa, and Dea,d, C. Vietor, A Comrendlu,.
or l!ormallon !or VN In Con1rollln1 R1dla1lo thrnurh 1961. Waohln11on, D. C. t Co,,, P11. Olice (Mo7), 1962. -~* Eawr,en<1t1. TID,8:06 (Ro.) (Sept,) 1960, pp, 61, '2. ( AHllat.la ,,..,. Olliu or Tcehnlul Senlceo, 57, Chadwick, Donald R, A.J.P,11. Suppl. 114,1.U.T0 (Jon.), 1964. 'J, O.reN-n1 of Commoree, Wa1h1a,toa 2S. D. C.), SI. Terrr, r,uther L., ind Ch,dwlck, Don,ld R, Curroat ,. It.',~ . , F, r.. and Kuper, J, 8. Eapooaro Crlt11h Coacept1 ht Radlatina Protection, J.A .M,A, JI0,121 74-75 (Ju11e 23), 1962. f
. ;If I *
~
I* 1fU
.... VOL II~ NO. 12. A..I.P,H.
*-i:#;:i-1-t* a< * :t
- cc ;t;J::trs:r: C?tcr<zr'. -... l
.w cc;.;
I
- I,
** *I I
CO~'IS FECEI VED CN PIDPCSED AMENI::MENTS 'IO 10 CFR PARIS 20 AND 50 Co_-' of .1.etter from Yardl 30 , 19 70 O!-" c. .x,yle, . ccretru:y Dock~ted : April 6 , 19 70
~ ........ *aticnal A:... .-::.oc....cttion o f Attorneys General :Reply sent :
211 S;.1tter Street s~1 J."ranci..:,co, califomia 94108 to
-:. .. :villia"Tl J. Soott
.l,.~ ~1ey 08neral of Illinois 60 . 0rt1 LaSalle Street Cr0-~ :p , Illinoi s 60601
. :Llis, Simrrons, :)i.rcctor March 31 , 19 70 1£v:i....,ion o= Rad:iolo<;,ical Heal th Docketed : April 8, 19 70 t.auc. of . cbraska Reply sent:
.bpc-"i:rret1. _ 0f *calth s* c.t Hot....: ::ita-..:ion, Box 94757
!...il.l.'1c~ln, , 12..:,r~.i<:a 68509
""" , ~~rJ.., Pa!'.-<:er April 1, 19 70 w.tant to the Direcc:or Docxeted: lie '-;orth-west :Reply sent: _ lle .-errorial Institute I Bo*..: 999
.~c.1 ...ana, Washington 993:>2 Robert R. Garvey, Jr. April 3 , 1970 E}ieCUti vc Secretru:y Docketed : April 13, 1970 1-..dvisocy Council on Reply sent :
. *:.storic Preservation
..::.1ington, D. C. 20240
. " . Stannard, President April 6 , 19 70
.,-al th Physics Society Docxeted : April 13, 1970
,.U'\-..}rsity of Rodlester School of Ieply sent :
.~dicine
- 260 Crittenden Boulevard Rodlester , N. Y. 14620
A. T. Whatley Apri 8, 1970 Executive Director Docketed:
'Western Interstate Nuclear Board ~ply sent :
P. 0. Box 15509 Lakewood, Colorado 80215
- George Kinsman April 9, 1970 Senior Vice President Ix>cketed:
Florida PONcr & Light Corrpany I:eply sent: f-1 o y ~I'{, f P. 0. Box 3100 Miami Florida 33101 6 ., Robert P . Janes t/c le\ April 9, 1970 Assistant Director (' lt I I I
*a I Docketed:
Offi0:; of Intergovemrrental I
' .Ir Reply sent :
l/ Rel - Lions O==ice of t1e Vice President ' l*Jashir gton
,,, Alan Beals, Director April 10 , 19 70 I .,. Docketed :
Congressional Relations
.. 1.:a.ti0.'1al I..eagt:e of Cities Reply sent :
United States Conference of Mayors 1612 K Street, Northwest Washington, D. C. 20006 I John *-* Heslep, Ph. D. I:eputy Director for April 13, 1970 v Docketed: Environrrental Health and Reply sent: Consurrer Protection State of California Healt..'1. and Welfare Agency
~pa.rtrrent of Public Health 2151 Berkeley *way *
&:rkeley , california 94 704 I , Octave J . Du Terrple April 16, 1970 A-rerican 1 uclear Society Ibcketed:
244 East Ogden Ave..'1re
- Reply sent:
Hin.sdale , Illinois 60521
I William S. Johnson, Sr. April 8, 1970 Vice President Docketed : Eberline Instrurrent Corporation Reply sent: P . 0. Box 2108 Santa Fe , New r-Exi.co 87501
- Lawrence Ruby Professor of Nuclear Engineering April 20, 1970 Docketed: April 23, 1970 54 Co.vper Avenue Peply sent :
Berkeley , califomia 94707 I J . Stewart Corbett , Health Physicist April 20, 1970 P. 0. Box 486 Docketed: April 23, 1970 Streator , Illinois 61364 Peply sent: , / Jo m N. assiskas *Undated Chairman Cocketed: Federal Power Ccm:nission Reply sent: Washingtcn, D. C. 20426 Jarres G. Terrill, Jr. April 16, 1970 I Senior Vice President Docketed: Environrrental Activities Reply sent: Lulejian & Associates, Inc. Arlington, Va. 22209
.- Floyd L. Goss April 17, 1970 Chief Electrical Engineer Docketed:
and Assistant Ma.riager Reply sent:
~partrrent of Water and Power The City of Los Angeles P. 0 . Box 111 Los Angeles, California 90054 Frederick F. Heisel, Director Agr i l 15, 1970 Division of Environrren.'tal .iealth Cock.eted:
State of Minnesota - ~parc_rrent of Health Reply sent: 717 I:elaware Street Minneapolis, Minnesota 55440 Allen Brodsky, Olairman, Standards Comnittee Health Physics Society to J . Newell Starmard, President Health Physics Society
J 20 . Dr. W. D. McElroy April 21, 1970 Director Docketed:
~ational Science Foundation Reply sent:
- Wasnington, D. C. 20550
- 21. Mr. James T. olocs April 29, 1970 Holmes & Narver, Inc. Docketed: 5/1/70 828 South Figueroa Street Los Angeles, Cal"fornia 90017
- 22. Mr *
- C. ltschn r April 29, 1970 Vie .?resident Docketed:
Portl~nd General Electri Company Reply sent: Electric Buil~ing Portl~nd, Oregon 97: 5
- 23. Dr. C rlcs C. John on, Jr. April 30, 1970 Assi~tant Surgeon G neral Docketed:
De a ~.:nent of H alth, Educat on, Reply sent: n Je ~a::-e
- b. _ Heaith Service E1v*ronmental Health Service ockville, : ylanc 20852 onor~b le Do al
- raser (Minnesota) 0 April 14, 19 70
- u c of Represent tives Docketed:
Reply sent: f
~
- ro\,d. f- / Pt1S"l1.s /lei d, &1tfc /-,v,,.Y't
-Jt}
P. Doc,E,to il&4£i; APR2319 54 Cowper Avenue Dtt!t1 Of flt 70 Berkeley, California 94707
, .)'14' ,,./ I ~ April 20, 1970 Ir.* *1/
Secretary U.S. Atomic Energy Commission Washington, D.C. 20545
Dear Sir:
I wish in this letter to comment on the proposed amendments to 10 CFR 50 entitled "Control of Releases of Radioactivity to the Environment". I believe the proposed amendments will spawn a regulatory nightmare involving endless litigation, and which will not promote the public interest for the following reasons: (1) The amendments seek to impose a new limit on radioactive effluents, which is below the present limit, but which can by no stretch of the imagination be defined scientifically. Indeed, it is the arbitrariness of the definition which is cited as being one of the main aims of the change, as it allows for "flexibility". (2) The amendments deny to the operators of power reactors the equal protection of the laws, because the new limit is imposed only for the operators of light watercooled reactors, and even within that category, it is envisioned that different limits will be imposed on different operators in accordance with what is for each "practicable". (3) The amendments subject the operators of light water reactors to the investment of unnecessary time and expense in an effort to anticipate what, for them, is a "practicable" level for the emission of radioactive effluents, not only as will be judged at the time of original application, but as will be judged, perhaps . differently, at the time of initial operation. The purpose of these amendments appears to me abundantly clear. It is to extricate the Commission from the spot-light of criticism over the following question: Why does the Commission allow some power plants to operate with radioactive emissions near to their limit, while some others release only a few percent of their limit? The situation is grossly aggrevated by the repeated claim by the AEC (it even appears in the public announcement of these proposed amendments), that the power industry is
LETTER TO T- SECRETARY OF THE U.S. AT . ENERGY COMMISSION April 20, 1970 Page 2 characterized by plants which emit but a few percent of their limit. The unfortunate implication of the latter statement is that the high degree of safety connected with nuclear power production is associated only with such plants. Instead of endeavoring to dispel such an inter-pretation, the Commission seeks instead to lend the present situation a further aura of legality, and therefore, presumably of logic, by imposing a scale of practicality on radioactive emissions. The answer I would suggest that the Commission adopt to this question is that the limits for radioactive effluents, based on FRC standards, are safe even if all nuclear plants were to operate right at the limit and that, if and when evidence appears to contradict this conclusion, the limits will be changed accordingly. I do not mean to imply, with this suggestion, that power plant operators should not be required to make efforts aimed at reducing radioactive emissions. Indeed, the current concern for rehabilitation of the environment makes the reiteration of such requirements timely. Towards this end, I would recommend complete rewriting of the proposed amendments, starting by striking out the words 11 make every reasonable effort to maintain radiation exposures and releases to unrestricted areas as far below the limits specified in this part as practicable", and replace them by "endeavor to reduce still further all radioactive emissions towards the objective of no emissions whatsoever".
~ Lawrence Ruby Professor of Nuclear Engineering LR:ps
\
April 20, 1970 Mr. w. B. McCool, Secretary
- u. s. Atomic Energy Commission Washington, D. c. 20545
Dear Mr. McCool:
I respectfully submit the following comment in connection with the Commission's proposed amendments to regulations on radioactive effluents from light water cooled nuclear power reactors. I have been actively engaged in the profession of Health Physics since 1948. In my early days at Hanford it soon became apparent to me that caution and care were the bywords and bases for all decisions involving the real or potential exposure of the pop-ulation or the invironment to radioactive materials. During the past twenty years we have witnessed a truly marvelous evolution in the application of nuclear aterials. With this evolution we have developed rules, regulations, codes, MPL's etc. which continue to emphasize the caution and care of the early days. With the advent of commercial nuclear power in the 50's and the now rather explosive activity in this area, the public is becoming more and more aware of and more and more informed in matters of radiation protection. Recent publications, "The Careless Atom", and "Perils of the Peaceful Atom", which are being widely read and quoted, are serving, unfortunately, to give our citizenry a very distorted picture of the peaceful applications of the atom. The latter publi-cation, in particular, which is available in paper-back, really cloaks our industry with adjectives which imply death, destruction, dismay and desolation if we continue to generate electric power with the atom.
W. B. McCool Page 2 April 20, 1970 The proposed amendments to the regulations are cer-tainly sound in principle and easily understood and appreciated by those who have had some training and experience in the field of radiation protection. When reviewed by individuals such as the authors of the above two publications, you are, in effect, adding fuel to the fire!! When they see the words, "as low as practicable", their reaction will prob-ably be to imply that the limits set forth in 10CFR20 are no longer valid and that some new, lower value should be established. Their desired value for all radioisotopes is obviously "Zero". Do you honestly feel that your proposal should be in the form of a published regulation?? I do not. Your intent to encourage reactor facility operators to keep releases "as low as practicable" is to be commended. I seriously question the appropriateness of "encouragement by regulation" in light of the present activities of the anti-nuclear power "crusaders". u~~ l 1 stewart Corbett, Health Physicist P. o. Box 486 Streator, Illinois 61364
1\/ qf- f- o
- f1 11$ Cf!-J , ,./
( *l-l f d fl _R. t< ( (J <f Sf> s
, fr YJocu,~,,,f~-
"1 _, .,
f'- 11 <1r-,:l t1 ~ Y (Y1 ' \ ,
*: . - 2.o (-S-O OAK RIDGE NATIONAL LABORATORY OPERAT E D BY UNION CARBIDE CORPORATION NU CLE AR DIVISION POST OFFICE BOXX OAK RIDGE, TENNESSEE 37830 Apri I 17, 1970 Secretary U. S. Atomic Energy Commission Washington, D. C. 20545
Dear Sir:
Several copies of the notice of proposed rule making regarding Title 10 of the AEC Rules and Regulations have come to my attention. Also, the President of the Health Physics Society, Professor Newell Stannard, has sent me a copy inviting me to submit my comments, and so I am enclosing a copy of this letter to him. I am pleased that the U. S. Atomic Energy Commission proposes amendments to Title 10 and, in particular, Parts 20 and 50. I feel rather strongly that some of the misunderstandings and criticisms regarding these rules and regulations have developed among the public because these rules and regu lotions need updating; they are not written with clarity, and I do not believe they provide the meaning and interpretation intended by the AEC. First of all, I believe the record of an organization speaks much louder than words. In this regard, I feel the AEC and the contractors with whom I am acquainted have done an excellent job in handling radioactive waste and providing protection from ionizing radiation through their health physics programs. I am pleased that the revision of these regulations will point out the importance of continuing this present policy of maintaining levels as low as practicable and, hopefully, far below the maximum limits specified in the regulations. I only wish other industries responsible for environmental pollution from fossil fuel products, detergents, pesticides, solvents, etc., approached this good record of staying for below the maximum permissible levels. Although I om a member of the International Commission on Radiological Protection, the National Council on Radiation Protection and President of the International Radiation Protection Association, the views expressed here are my own and are not necessarily shared by members of these organizations. I am pleased, however, to note that it w i II be emphasized in t he amendments to the regulations that an effort has been made to base these AEC rules and regulations on standards and recommenda-tions of such national and international bodies. Unfortunately, I believe Title 10, Part 20, is written in such a way that one cannot take it too Iiteral ly in interpreta-tion. Part 20 is correct in setting the basic standard for individuals of the population
Secretary April 17, 1970 at large at 10% of the total body occupational exposure values, namely, 0. 5 rem/yr. It is incorrect, however, in implying that this standard can be maintained provided the operator does not exceed the values given in Table 2 of Appendix B or, in some cases, 1/3 of these values. As Chairman of the Internal Dose Committees of ICRP and NCRP which prepared the present internal dose handbooks for the some-250 radionuclides for occupational exposure upon which these values in Table 2 are based, I think I am safe in saying that if a plant maintains the effluent at its boundary equal to or less than the values in Table 2, it in no wise guarantees it will not exceed the dose limits specified for the individuals or critical segments of the population. The values in Table 2 are essentially 10% of those given for continuous occupational exposure by the NCRP and ICRP and are provided to limit the dose to the standard man to not more than the specified dose rate limits to the critical body organs after 50 years of occupational exposure. This, of course, assumes the standard man, but in the population at large, there are chi I dren, pregnant women, individuals with ailments, etc., such that these limits would not necessarily apply. More importantly, there are factors of reconcentration in the environment of at least 1o5 such that by the food chain, for example, for iodine-131 (to grass, cow, milk, chi Id, child 1s thyroid), doses of thousands of rads per year could be reached in some coses if one did no more than assure these levels in Table 2 were not exceeded beyond the boundary. In other words, ICRP and NCRP emphasize that the MPC values are secondary or tertiary standards, and the primary standard is that one must not al low members or critical segments of the population to exceed 10% of the permissible dose rates to the body organs. These permissible dose rotes, as you know, are 0. 5 rem/yr to the total body, gonads or red bone marrow, 3 rem/yr to bone, skin and thyroid, and 1. 5 rem/yr to all other body organs of members of the population at large. In the revised publications of these organizations, the limit to the thyroid is now given as 1. 5 rem/ yr instead of 3 rem/yr. The MPC values at the boundary where the air or liquids leave the plant provide a useful guide, but of even greater importance is the maximum amount of curies of the various radioactive material discharged per year or per quarter. This is because the values in Table 2 could be far too conservative in most cases if the plant were to start discharging into a large river system such as the Mississippi River. On the other hand, they could be on the reckless side if the discharge were into a very smal I stream that might be used a few miles below as a community water system. It is because of these uncertainties that I set the environmental standards at Oak Ridge at what I consider to be very conservative values back in 1943 and 1944; namely, the levels at White Oak Lake should be such that a person swimming in this water 24 hours a day or using this water as a sole source of drinking water wou Id not exceed the permissible occupational dose rates in a Iifetime. A similar standard was set in reference to the air effluents. At that time, I received many criticisms because of what others considered were ridiculously low and conservative standards. Now, of course, the shoe is on the other foot. The permissible dose rates have been lowered several times through the years, and there are those who
Secretary Apri I 17, 1970 are wondering why I was so reckless in al lowing contamination in White Oak Lake. This system, as you know, is maintained under our control and has provided us with one of the countrls most usefu I research areas. We have not a II owed, however, the contamination into the Clinch River just below White Oak Lake to exceed more than at most a few percent of the MPC values as given in Table 2. Downstream a short distance the level of contamination contributed by the Laboratory is hardly detectible above the contributions from fallout of weapons. In spite of this situation, however, we and other contractors have always maintained a surveillance which determines directly whether members of the population are exceeding 10% of the occupational dose values. This is done by collecting grass and soil samples, samples of food such as milk and grain, checking thyroids, total body counting, etc. Only in this way can we convince the public and ourselves that no one has exceeded 10% of the occupational dose limits due to our environmental contamination or the total contamination by ourselves and other contributors. I hope the revised rules and regulations will make this clear to the layman as well as to the person with a legal background. Another item which has led to some misunderstanding is that the factor of 1/ 3 in Title 10, Part 20, when applied to 0. 5 rem/ yr gives us the fi~ure of 170 mrem/ yr which happens to be the same figure provided by ICRP for members of t he popu lotion as the average dose (5 rem/generation which is assumed on the average to be 30 years). Thus, I believe it has been assumed by some that the AEC would be quite willing for its power reactors and other operations to use the entire 170 mrem/yr averaged over the total population of the United States. I am sure that nothing cou Id be further from the truth or the intent of the AEC, but the implication is so strong that it does lend to what I believe is the focus of a great deal of public criticism. In the early period, ICRP divided this population dose of 170 mrem/ yr, but in more recent publications it indicated this is considered to be a responsibility of the national bodies because of their individual needs and social and economic problems. Unfortunately, the Federal Radiation Council has been sitting on its hands for years and done nothing about the problem. Had they divided or apportioned this 170 mrem/yr to various industries, as I suggested in the Congressional hearings (January 27, 1970), I believe much of the controversy might have been avoided. Certainly no one intends that nuclear power plants would eventually deliver the entire 170 mrem/ yr to the 200 million people in the United States. Finally, I, and I can assure you a large number of my associates, believe t he values of 25 rem to the total body or 300 rem to t he thyroid as used in Title 10, Part 100, for defining the dose for two hours at the boundary of an exclusion area are far too high and much larger than they need to be for purposes of calculation. I think if some more reasonable figures were used, most of the objections to this part of Title 10 would be removed. In closing, I would like to emphasize that I hope the new regu lotions will point up the conservative approach of the AEC throug h the years in trying to look ahead and
Secretary
- Apri I 17, 1970 anticipate the radiation risks rather than wait until damage results to the population and then lower the standards. I think the AEC has done a remarkable job in its health physics programs in providing radiation protection to the workers and the public, but I fear its public relations programs have not been equally successful.
Sincerely,
~ ~
c~~ 1v1s1on ;}:/ KZM:jc cc: J. L. Liverman Newell Stannard A. M. Weinberg
~fHU~- P~~~ L~ ~~L fl~
PRESIDENT: J. NEWELL STANNARD April 6, 1970 UNIVERSITY Of ROCHESTER SCHOOL Of MEDICINE 260 CRITTENDEN BLVD. ROCHESTER, N.Y. 14620 PRESIDENT-ELECT: CLAIRE C, PALMITER FEDERAL RADIATION COUNCIL WASHINGTON, D.C. 20449 r 7 PAST PRESIDENT: WRIGHT H. LANGHAM LOS ALAMOS SCIENTIFIC LAB. LOS ALAMOS, NEW MEXICO B7544 Mr. Harold L. Price SECRETARY: ROBERTSON J. AUGUSTINE Director of Regulation BUREAU OF RADIOLOGICAL HEALTH 12720 TWINBROOK PARKWAY U.S. Atomic Energy Conmission ROCKVILLE, MARYLAND 20852 Washington, D. C. 20545 TREASURER: ROBERT L. ZIMMERMAN NUCLEAR RESEARCH CENTER GEORGIA INSTITUTE Of TECHNOLOGY L _J ATLANTA, GEORGIA J0332
Dear Mr. Price:
Thank you very much for sending to me, as President of the Health Physics Society, a copy of the proposed amendments to AEC regu l ations concerning releases of radioactivity to the environment. I am forwarding copies of this to the members of the Board of Directors of the Society and also to the Standards Committee . We welcome this opportunity to coII1100nt on the proposed revisions and will respond either individually or collectively in the name of the Society or both as determined by the wishes of the Board. Sincerely,
) ~!1-t~
; Q sident JNS/bls Fi~eenth Annual Meeting, June 28 - July 2, 1970 SIXTEEN TH ANNUAL MEETING, JUNE 21-25, 1971 SEVENTEENTH ANNUAL MEETING, JUNE 12-17, 19n Palmer House, Chica go, Illinois WALDORF ASTORIA, NEW YORK, NEW YORK STARDUST, LAS VEGAS, NEVADA EIGHTEEN TH ANNUAL MEETING, JUNE 17-21, 1973 DEAUVILLE, MIAMI BEACH , FLORIDA EXECUTIVE SECRETARY: RUSSELL F, COWIN G 194 PILGRIM ROAD, BOSTON, MASS. 02215 TEL. 617-734-7000 EXT. 458 l_
( (
- r. "I ,
- t* I ADV I SORY CO UNC IL-ON HISTORIC PRESERVATION WASHINGTON, D.C. 20240 April 3, 1970 Mr. Harold L. Price Director of Regulation Atomic Energy Connnission Washington, D. C. 20545
Dear Mr. Price:
The Advisory Council on Historic Preservation appreciates being offered an opportunity to comment on the proposed amendments to the Atomic Energy Commission regulations concerning the control of releases of radioactivity to the environment. Under Public Law 89-665, the Advisory Council is concerned with the effect of Federal or federally assisted, including licensing, undertakings upon property listed in the National Register of Historic Places. Inasmuch as the proposed amendment has no bearing on the effect light water cooled nuclear power reactors might have upon historic properties, the Advisory Council on Historic Preservation has no comment either pro or con to make concerning the proposed amendments. Sincerely yours,
~:b(}
Executive Secretary D te _ i THE COUNCIL ;, clwu*oed bu the Act of October 15, 1966, 1vith lldviaing the President and Conorua in the field of Hiatoric Prnervation, recommending mfflBu1*es to coordinate govert1mentlu 111ith pri1111u activities, lldviaing on the diueminotiata of informa;tion, enc0Kr11ging public interest and pa;rticipation, ,-eco111mending 0.. conduct of apecial atudiea, lldviaino in the prepa;ra;tion of lflgi,lation, and encOKra;ging apecialized troi11ing a t1d education. Tlte C<>Knct1 ol,o hae the ruJ)Ofl8ibilit11 to comn,ent °" Federal or Federoll11-G88iated tindertokino* that hove on e/Ject on cultural p1-ope..t11 lilted in the N otiOt1ol Register.
1 DEPARTMENT OF HEALTH STATE HOUSE STATION, BOX e,757 LINCOLN, NEBRASKA ,811509 March 31 , 1970 Eber Price, Director Division of State and Licensee Relations
- u. s. Atomic Energy Commission Washington , D.c. 20545
Dear Mr . Price :
The Atomic Energy Commission's proposed amendments concerning the control of releases of radioactivity to the environment by light water power reactors is most timely . The public has been concerned about the numerous nuclear power plants and the effects they may have in the environment . I wholeheartedly support the amendments. Very truly yours , fr.~s~ctor Division of Radiological Health HES :jk 0CKEi£D tJ&AEC PR 81970 Office of the Secretary Publl,; Fr>c*~~lngs
- -r. .
THE NATI O NA, AsSOCIATION OF Arrcl.NEYS GENERAL SECRETARIAT: THE COUNCIL OF STATE GOVERNMENTS THE NATIONAL ASSOCIATION OF ATTORNEYS GENERAL 211 Suiter Street SAN FRANCISCO, CALIFORNIA 94108 March 30, 1970 Hon. William J. Scott Attorney General of Illinois 160 North LaSalle Street Chicago, Illinois 60601
Dear General Scott:
I am forwarding to your attention as Chairman of the Association's Corrmittee on Environmental Control, a letter and materials received this date from Harold L. Price, Director of Regulation with the U.S. Atomic Energy Corrmission, requesting convnents on proposed regulations concerning the control of releases of radioactivity to the environment .
- You may wish to refer this matter to the members of your corrmittee.
I am sending .a copy of the correspondence and material to President Head. Regards, JCD.vb John C. Doyle enc. Secretary cc: Attorney General Douglas M. Head President, NAAG Attorney General Francis B. Burch Vice President, NAAG Attorney General James E. Barrett Second Vice President, NAAG Mr. Harold L. Price Director of Regulation Atomic Energy Corrmission Rec'd Ott/ Di
- of Reg, Date L ;_::;, ,,_ t Time 7 *I" c'°)
MAR 2 B 1970 OCKElED U&tEC
.ir. R. I. i'.,cwnan, Project Dire ctor 61970 Allied 01elmical :iuclear Products, Inc . Office ef Hie secretary P. o. Box 35 Public ProceedlllP 11rancb
}'lorh ac: Park, i~cw Je n;ey 0.7932 I a~1 enclosinc f or your in formation a CO?'/ o f propose, m:u:m<.ln nts to AEC r eeul ations 10 CFR Par t s 20 and 50 c onccrnia::; th(? contro l of r c l ea::;es of radioacti.vlty to t hu cnvi.ronncnt Nhich the Comx:1ission pl.ms to is:;u~ . The pro. oscd ar~end1. ..ntn to Par" 20 arc a >p t.ct!lbla to all
- I-:C l icem;e~ *
- The ar.endr.ontr. to Part 0 are a~)!)licaolc only t ? li z .t ~.'.lter cooled nuclear po~~r r~actor~ .
These proposed ar,.en MC.nts l!i ll be pu1;linhcd in t;;,:2 Ft:'~t:cral I:c~is ter for pul>li c c onncnt . I ar:! also enclo~in,, a Coi,Y of a pv~1J le a1mow1ce-ment on t is ::.ubjcct \1hici1 is Gci1l1culcd for rel~ase on n1rch 27. 19 70 ,
.:it 2 : 30 P. :: .
We would ,c ple3.se to c onsider our cor,w,cnt~.; , aloni~ wi 1::1 otitcrs J being i. vitcd during the 60-day coni.1,~n t p riod follo,.,ing public.::itio. in the }'cdcra Pe~2;~~.E..* Sincerely. ( signed } Haroft! L Pric3
!!arold 1.. . P r ice Dire c tor of t*e.r,ul ation
- Cnclos urc~; ;
- 1. Pr opotieC: amcnurr,ents
- 2. Pr ea*1 announcei:...!nt (Identical letters sent to perso~s on attached list)
DISTRIBUTION : HLPrice DR Reading File F orm AEC*:H S (Ruv. 9-53) U.S. G0~ERNMENT PRINIING OFFICE, 1969-0-364-598
... FUEL REPROCESSING Mr . R. I. Nevnuan, Project Director Allied Chemical Nuclear Products, Inc .
P . O. Box 35 Florham Park, New Jersey 07932 Mr . G. R . Kiel Atlantic Richfield Hanford Company P . O. Box 370 Richland, Washingto~ 99352 Dr . L. S. Moody, General Manager Reactor Fuels and Reprocessing Department General Electric Company 175 Curtner Avenue San Jose , California 95125 Mr . T. C. Runion, President Nuclear Fuel Services, Inc . Wheaton Plaza O:ffice Building Suite 906 Wheaton, Maryland 20902 Mr . James G. Cline, General Manager New York State Atomic and Space Development Authority 230 Park Avenue New York, New York 10017 FUEL FABRICATORS
.ttir
- L. J
- Swallow, Manager Nuclear & Industrial Safety Commercial Products Division United Nuclear Corporation Route 21A Hematite, Missouri 63047 Mr . Karl R. Schendel, License Administrator Westinghouse Electric Corporation Gateway Center Box 2278 Pittsburgh, Pennsylvania 15230 Mr . Steven H. Brmm, Manager Nuclear Service Department National lead Company 111 Broadway New York, New York 10006
DOC!G" i i1U'..i ..
- DOCKETED U&AEt 61970~ J, AR 2 6 1970 omce of tile Sttrat10 PIIIIIIC PTOCeBdlllCI ncb Honont"ul:;? trike Grav~1*
United Stat~n Senate
Dear Sena to:
- Gravel; I am enclo inz for your infor .1ation a copy of propose amendments t o AEC resulntions conc e rning the control of r elca es of radioactivity to the e11viroru..1cnt , dch t he Co!'.llnission pla ns to i f:H.rnc. Thes pro:>os e a mend-ments will be publi"', ed in the Pcd er .:11 Re;ji s ter for public con1,1cnt. I ao also enclo.Jin2; a copy of a pu~lic nnounccmcnt on this subject hich is sclieduled for r elease on Harch 27, 1970, at 2:30 P. :t.
We would be pleased to cons der your co;_,n,1 ~nts, along with others bein invited dur n.,, the 60-day c01n.1cnt period folloui1g publication in the r'cdcral l'!.e gist:'lr . Sincerely 7 Harold 1.. Price Director of Regu ation Enclonures:
- 1. Proposed a mend~cnts
- 2. Press announccc;::mt Distribution :
HLPrice , DR DR Reading ( Identical i etters sent to people on atta ched lists)
- Form AEC- :HS (Rr v. 9 53) U.S. G0VERIIM£NT PRINTING OFFICE, 1"6)-,0-364-598
Honorable Mike Gravel
- Dear Senator Gravel United States Senate Honorable John E. Moss House of Representatives Dear J.'.'1r. rtDss Honorable George E. Bro\-m, Jr.
House of Representatives I Honorable Abraham A. Ribicoff United States Senate Honorabl e Emilio Q. Daddario H9use of Representatives Honorable Charles H. Percy United States Senate Honorable Allen J . Ellender United States Senate Honorable Edward M. Kennedy United States Senate Honorable Torbert H. Macdonald House of Representatives Honorable Edmund S. Muskie United States Senate Honorable Joseph D. Tydings United States Senate Honorable Edward A. Ganratz House of Representatives
Ii
~ssional Honorable George H. Fallon Honorabl e Rogers C. B. Morton House of Representatives House of Representatives Honorable Phi lip A. Hart Honorabl e Robert P. Griffin United States Senate
- Unit ed States Senate Honor abl e John D. Dingell Honorable Lucien N. Nedzi House of Representati ves House of Representatives Honorable Walter F. Mondale Honorable Eugene J . McCarthy United States Senate United States Senate Honorabl e Albert H. Quie Honorabl e Clark MacGregor House of Representatives House of Representatives Honorable Joseph E. Karth Honorabl e Donald M. Fraser House of Representat ives House of Representatives Honorable John A. Blatnik Honorable John M. Zwach House of Representatives House of Representatives Honorable Lee Metcalf Honorable Manuel Lujan , J r.
United States Senate House of Repre~entatives Honorable Jacob K. Javits Honorab~e Charles E. Goodell United States Senate United States Senate Honor able Lester L. Wol f f Honorabl e Joseph P. Addabbo . House of Representatives House of Representatives Honorable Wi l l iam P. Ryan Honorable Jonathan B. Bingham House of Representati ves House of Representatives Honorable Richard L. Ottinger Honorable Ogden R. Reid House of Representatives House of Representatives Honorabl e Howard W. Robison Honorable Samuel S. Stratton House of Representatives House of Representatives Honorable Frank Horton Honorable ErP.anuel Geller House of Representatives House of Representatives Honorable 'Ihomas L. .A.shley Honorable Hugh Scott House of Representatives United States Senate
~ Congressional ,. Honorable John P. Saylor Honorable Joh.~ H. Dent House of Representatives House of Representatives Honorable Winston L. Prouty Honorable Tnowas S. Foley United States Senate House of Representatives Honorable William Proxmire Honorable Gaylord Nelson United States Senate United States Senate Honorable Robert W. Kastenmeier Honorable David R. Obey House of Representatives House of Representatives Honorabl e Henr-y S. Reuss Honorable Jennings Randolph House of Representatives United States Senate
ORGANIZATIONS Brevard Crihfie l d , Executive Di rector Dr . Al fred L. Fre chette , Chairman Council of State Governments Assoc i ation of State and P.O . Box 5377 Terri torial Health Offi cers Lexington , Kentucky (Commissioner of Public Health ) Massachusetts Department of Brevard Crihfie l d , Secretary and Treasurer Public Health Nationa l Governors ' Conference 600 Washington Street P. O. Box 5377 Boston , N.assachusetts 021 11 Lexingt on, Kentucky John C. Doy l e , Secretary National Ass ociation of Attorneys General 211 Sutton Street San Fra ncisco, Califor nia Patrick Healy , Executive Director and Vice President Nationa l League of Cities 1612 K St r eet , N. W. Wa shington , D. C. J ohn Gunther , Executive Director U. S. Conf~ r ence of ,~yors 1612 K Street , N. W. Wa shing t on , D. C. Mark Keane , Executive Director Internat i ona l City Manageme nt Assoc i ation 1140 Connecticut Avenue , N. W.
- Washington ; D. C.
Bernar d Hi l lenbrand , Executive Director Na tional Association of Counties 1001 Connecticut Avenue , N. W. Wa shi ngton , D. C. Dr . Al fred T. Whatley , Executive Director West ern I n t erstate Nuclear Board Box 239 Wheat Ridge , Col orado 80033 Mr . Robert H. Gifford, Executive Dire ctor Southern Interstate Nucl ear Board Sui te 664 , 800 Peachtree Street , N. E. At l anta , Georgia 30308 2/24/70
ORGANIZATIONS Mr . Charles Robbins, Vice President Atomic Industrial Forum, Inc . 850 Tnird Avenue New York, ew York 10022 ?Ill' . Octave J . Du Temple Executive Secretary American Nucl ear Society 244 East Ogden Avenue Hinsdale, Illinois 60521 Mr . F . L. 1.aQue, President American Nuclear Standards Institute, Inc . 1430 Broadway New York, New York 10018
- Mr . Alex Radin, General ~.anager American Public Power Association 2600 Virginia Avenue , N. W.
Washington, D. C. 20036 Mr . John J . Ke8.!'ney, Director Power Systems Coordination Division Edison Electric Institute 750 Third Avenue New York, New York 10017 Mr . J . Newe ll Stannard, President Health Physics Society University of Rochester Medical Center 260 Crittenden Boulevard Roche ster , New York 14620
FEDERAL AG~~ IES AND/OR COii/J'iII'ITEES At\JD CO!Ji,~ uS Mr. Charles Meacham Comrrissioner Fish and Wi.lc'tJ.ife Service U. S. Departrr.ent of the Interior Washington, D. C. 20240 Mr. David D. fuminick Corrmissioner Federal Water Pollution Control Administration ff. S. Departrr.ent of the Interior Washington , D. C. 20240 Mr. William T. Pecora Director , Geological Survey U. S. D=partment of the Interior Washington, D. C. 20240 Mr. Robert R. Garvey, Jr . Executive Secrtar-y Advisory Council pn Historic Preservation U. S. Depart,nent *or the Interior . Washington , D. C. 20240
- Mr. Carl L. Klein, Assistant Secretary Water Quality and Research U. S. Department of the Interior Washington , D. C. 2Q2llQ Mr. Robert M. White , Administrator Environmental. Science Services Administration .:,. , . ; .
U. S. Departrrent of Corrrrerce Washington, D. C. 20230 Mr. John C. Villforth, Director Bureau of Radiological Health Consurrer Protecti.on & Environrr.ental Health Service U.S. Public Health Service U. S. Depru...trr.ent of Health , Education, and Welfare Rockville , r,,Tacyland 20852
Honorable John N. ~1itchell Honorable John N. Nassikas Attorney C-eneral Chairman, Federal Power Commission D::!partment of Justice General Accounting Office Building Washington, D. C. 20530 Washington, D. C. 20426 Honorable Nils A. Boe Director, Offi~e of Intergovernrr.ental Relations Executive Office Building Washington., D. C. 20510 Honorable William D. McElroy Honorable Philip Handler Director President National Science FotL~dation National Academy of Sciences 1800 G Street , N. W. 2101 Constitution Avenue , N. W. Washington., D. C. 20550 Washington , D. C. 20!118 C\ s.:.J~ "-'v f'\ "-1; * , *" , I.:;)~\ , ) * ,:_. ...,.!:-(' * . ,
* /),L.-V.1 /J,1, . .,--:,:'..(e,,.. (.(( V !
I ~ Mr*. ¢harles C. Johnson, Jr . . Admi¢strator , Consumer Protection and Enyiror:unental Health Service Pul;)lic Health Service U.S. ; Department Qf Health , Education, anr Welfare *' Washington, D. C. 20204 Mr. Roger 0. Egeberg Assi~tant Secretary for Health and Scientific Affairs U.S . Department of Health , Education , and Welfare - Washington, D. C. 20201
I
- ARCHITECT/ENGINEERS
. Mr. R. *A. BoW!Tl.an, Manager of Power
& Industrial Division Bechtel Corporation Fifty Beal Street San Francisco , California 94119 Mr. M. M. Fitch , Vice President Brown & Root , Inc .
P. O. Box 3 Houston , Texas 77001 Dr. S. Baron , Vice President , Engineering Burns and Roe , Inc . 700 Kinderkarnack Road Oradel l , New Jersey 07649 Mr. George Hovorka, Director Nuclear Services Division Comnonwealth Associates , Inc . 209 East Washington Avenue Jackson , Michigan 49201 Mr. L. F. C. Reichle , Vice President Nucl ear Engineering and Special Projects 2 Reactor Street New York, New York 10006 Mr. Peter H. Smith, President Gibbs , Hill , Durham &Richardson , Inc . 393 Seventh Avenue New York , New York 10001 Mr. J arres R. Stoudt , President Gil bert Associates , Inc . P. 0. Box 1498 Reading, Pennsylvania 19603
Architect Engineers Mr. J . T. Holmes , President Mr. Harold E. Vann
- Holres & Narver, Inc .
- Vice President-Power 828 South Figueroa Street United Engineers & Constructors , I Los Angel es , California 90017 1401 Arch Street Philadelphia , Pennsylvania 19105 Mr . Arthur Y. Taylor , President Jackson and Moreland Divisi on of United Engineers and Constructors , Inc .
600 Park Square Building Boston , Massachusetts 02116 Mr. J . A. Jones , Jr . Senior Vice President J . A. Jones Construction Company P. 0 . Box 966 Charlotte , North Carolina 28201 Mr. J . C. Smith, Vice President Maxon Construction 2600 Far Hills Avenue Dayton, Ohio 45419 Mr . Stanley Goldhaber , Vice President Ralph M. Parsons Corrpany 617 W. 7th Street Los Angeles , California 90017 Mr. C. R. Barthelemy , President Pi oneer Service &Engineering Corrpany 2 North Riverside Plaza Chicago , Illinois 60606 Mr. Fred W. McCloska, Partner Sargent & Lundy 140 South ~arbo~n Street Chicago , Illinois 60603 Mr. E. M. campbell , Sr . Nuclear Engineer Stone &Webster Engineering Corporation 225 Franklin Street Boston, Massachusetts 02107
*~ RESSES rn,, LICF'.NSF.£S A:*:D APPT f/rr . Alan R . Barton Mr . W. B. Behnke , Jr .
Senior Vice President Ass_stant to President Alabama Por.*:er Cc.i.p?. ny CCJIT1mom:ealth Edison Co:npany 600 North 18th Street 72 West Ad2.ms Street
- Binning.l-IB.rn, Alabama 35203 Chicago, Illinois 60690 Mr . J . D. Phi,llips Mr . D. C. Si*[itzer , Vice President Vice President a..~d Chief Engineer Co.r_mecticut Yankee Atomic Power Company Arl<ansas Po:1er and Light Company P. O.. Eox 270 Post Office Box 551
- Hart f ord, Connecticut 06101 Little Rock, Arkansas 72203 Mr . Them.as C* Duncan Mr: James P . Haywa...r'Cl , President Senior Vice President Atl antic City Electric Company Consol idated Edison Company of 1600 Pacific Avenue New York, Inc .
Atl antic c _ty , Nei*r Jersey 08t104 It Irving Place New York, New York 10003 Mr . J . W. Gore, Jr . , Vice President Engineering and Construction Jfir . R. D. Allen
*Baltimore Gas a..~d-Electric Company Senior Vice President Gas and Electric Buildin.g Consumers Power Cor.10any Baltimo~c , 1Ta.ryland 21203 212 West 1*,ichigan Avenue Jackson, ~lichigan 49201 Mr . Cla~de A. Pursel Assistant Vi ce President - Nuclear Mr . J ohn P . 1-!.~dzet t , . General 'M anager
- Boston Edison Corr.pany Dairyland Coo:oerative 800 Boylston Street 2615 East Avenue South Bost on, Massachusetts 02199 lacrosse , Wisconsin 54601 Mr . Paul S. Colby . Mr . W. J . McCarthy , Jr .
Seni or Vice President Assistant *ianaser of Engineedng Car9l ina Power and Light Company The Detroit Edison Company 336 Fayetteville Street 2000 Second Avenue Ralei gh , rorth Carolina 27602 Det roit , Michigan 48226 Mr . W. H. Zirrmer , Pres . & Ch . Exec . Mr . William S . Lee , Director Ci ncin.Ylati Gas and Electric Co . Vice President-Engineerit13: , 139 East Fourth Street Duke Power Co.1\oany Cincinnati , Ohio 45202 Post Office Box 2178 Charlotte , 1rorth Carolina 28201 Mr . Floyd L . Goss , Chie:' Electrical Engineer and Hr . Willia'TI A. Conw~ll Assistant M9.i.'12.[;er Vi ce President
'l'he City of Los Angeles Department Duquesne *Light Co.-npany of Water and Pm:er 1135 Sixth Avenue Post Office Box 111 Pi t tsburgh, Pennsylvania 15219
_. Los Angeles , Californi.a 90054
\
Mr: J ohn Tillinghast Mr. R. E. Neidig Executive Vice President Vice President-EP~ineering Engineering and Construction . MetropolHan Edi.son Co-;1p2.ny American .Electric Pov:er Service Coro . Post Office Box 542
- . 2 Broad\*ray , .dew York, N. Y. 10004
- Readjpg, Pennsylvania. l9b03 Mr, Byron Price , General r !arl9.ger Mr. R. Hicock, President .
Eugene Water arrl Electric Board The Millstone Point Company 500 E. Fourth Avenue P. o. P.ox 270 P. 0. Box 1112 Hartford, Connecticut 06101 Eugene , Oregon 97401 Mr. D. W. Hill, General Ma!'.ager Mr. J. T. Rodgers Nebraska Public Povrer District Nuclear Project ia.nager Post Office Box 499 Flor ida Power Corporation Columbus , Nebraska. 68601 Post Office Box lll042 St. Petersburg, F+orida 33733 Mr, Robert F. Krause , President New England Electric System Mr. George Kinsrr.an ~lll SttL;u*t Street Senior Vice President Boston, ~.ass~crusetts 02116 Flor ida Pm*rer and Light Co. Post Office Box 3100 Vrr, A. D. Tuttle , Vice President Miami, Florida 33101 ; Enginee:ri ng Planning *
- New York State Electric and Gas Mr. I. S. Mitchell , III . Coro .
Vice President and Secretary Post Office* Box 287
- Georgia Power Co1'.pany
- Ithaca , New York 14851 Post Office Box 11545 Atlanta , Georgia 30302 Mr . M. H. Pratt , Vice President and Executive Engineer Mr. Duane Arnold, President Niagara. Moh:'\\*.-< Pm*rer Corporation Iot*:a Electric Light and Power Co . 300 Eric fuulevaro , West Security BuildiP.g Syracuse , Neu Yor k 13202 Cedar ~pids , Iowa 53406 Mr , C. D. Rees , President Mr. John E. Logen, Vice President Northern Ir:dia..na Public Service Company Jersey Central POi'rer and Light Co.11pany 5265 Hohm2.n Avenue Madison Avenue -at Pu.l"lch Bmrl Road Hanmond , IndJ.ana
- l!6325 Morristm*m , New Jersey 07960 Mr. Arthur Sugden, Vice President Long Islarid .Lighting Company Mr. Earl Ewal~, Chairman 250 Old Cointry Road Northern States Po\*!er Co:7ipany Mineola , fl:e1*1 York 11501 lt1ll Nicollet Avenue
- Minneapolis , Airinesota *55401 Mr. John DeVincentis , Section Head Safety Analysis . Ilk' . E ~ E. S::!hr.-raJ1n, General Manager Maine Yankee Atcmic POi*rer Co:npany Or:al1--1. Publ:Lc Po*::er District 9 Green Street 1623 Harvey Street Augusta , ,13.ine 0L1330 Oma.ha , Nebraska 68102
Mr. R. *H'. Peterson 1*1r' . Francis E . Drake , Jr . , Cr_--:1 Vice President and General Rochester Gas and Electric Co~ Counselor 89 East Avenue
- Paci f i c Gas a..~d Electric Company ..Rocheste:i:*,
., NeN York 14604 2i15 Market Street
. *3an Francisco, California 94106 Mr. J. J. Mattimoe Assistant Chief E .gineer . Mr. Donald C. Frisbee, President S:icrarr:ento Nunicipal Utility D Pacifi c Power ar.d Li@;L>-it Company Pos t Office Box 2391 920 S. W. 6th Avenue Sacramento, California 95811 Portland, Oregon 97204 Mr. C
- L. *Bradeen, Power rtigr .
Mr. Jack K. Busby, President & City of Seattle , Department o Ch. Exec . Lighting Pen..11sylvania Poi.*rer and Light Co. 1015 Third Avenue 901 Ha~~lton St . Seattle , W2:shington 98104 Allentm-:n, Penna . 18101
- Mr . W. G. Hulber;t , Jr ., iVT..gr> .
ftir. Vincent P~ l1cDevitt , Vice Public Utility Dist . No . 1 of . President Snohomish County Philadelphia Electric Company 2320 Calif . Avenue 1000 Chestnut Street , Everett , Wa.shiri.gton 98201 Philadel ohia, Pennsyl vania 19105 I
- Mr . Wil lia11 R. Gould Mr. E 1
- C. I tscrmer , Vice President Seni or Vice Presidm1t Por t land General Electric Company Southern Calif. Edison Co*r1pany 621 Southwest Alder Street Post Office Box 351 .
Portland , Oregon 97205 I.os A.ngeles , California 90053
.,--, * ,4" ..., I,.:r.
Mr. WilU.arn S. Chapin, General Mr . ~e":°"' ,1e~enalier Manager Manager of Pm*rer Poi*rer Authority of the State of Tennessee Valley Authority New York 818 Power Building 1 10 .Columbus Circle Chattanooga , Tennessee 37401 New York, New York 10019 Mr. John K. Davis , President Mr. R. F' . W alker , Vice P-.cesident Toledo Edison Cornpany Engi neering & PlanniP.g 1120 Madison Avenue Electric Department Toledo , Ohio 43601 Public Service Company of Colorado 550 Fifteenth Street Mr . _G. C. Walkley , President
-Denver, Colorado 80201 Washington Public Power Supply System Mr. Eliot Priest , Vice President 130 Vista l:!ay Publk Service Company of Kennewick, Wash . 99336 New Hamoshire 1087 Elm Street ¥~ . J . G. Qaule , Presiaent Manchester , Nei*T Ham!)shire 03105 Wisconsin i* ichigan Po\*:er Gem.pa 231 \*!est Michige.n Street Mr . Robert I . Snti.. th Milt*rautee , t*liscons:i.n 53201 Vi ce President in ch~r~e of.
Elect ric Ooeration "Public SeF~ice Electric and Gas Co . Bo .Park Place Newark, Ne,*1 J ersey 07101
rrir*. E . W. James , t.3.nager Power Generation and En.gineering Wisconsin Public Service Corooration
*Post Office Box 751
- Mih,raukee, Wisconsin 53201 Mr. Stanley Ragone , Vice President Virginia Electric and Power
- Company Post Office Box 1194 Richmond , Virginia 23209 Mr-. Hm,ard S. Lewis , Vice President Vermont Yan.l<ee Nuclear Power Corporation
~41 Stuart Street Boston, Massachusetts 02116 I
Mr. }!yrori C. Beekvtan . General Manager ! Pow2r Reactor Development Company 1911 Fi rs t Street Detrott, Michigan 48226 Mr> . Fdward E . Walter . . General Manager Rural Cooperative Power Association Elk River, Minnesota 55330 Mr . L . E . Minnick Vi-oe Pres dent Yankee Atomic Electric Company 441 Stuart Street Boston, Massachusetts 02116
DOCKETED
- I tl&AEC APR trice of the Secretsy Public Proceedings lll'llnch MAR 2 6 1970 Honorable Robert Finch Secretar y of 1;calth , Education, an<l Welfare llear .~r . Finch:
l am plc cu to end to you, as Chairman of t l1e Fe eru :ta ation Counc il, a copy of propoGc a r.*cn<l~: nt.~ to i'C rct,u ations concern inz he contro of r ele;:i::.::e of rad oact vity t o t:1e env .ronrent wh ci1 the Co :-T! ,:rnion plans to issue . 'rae:-;c pr :-io.secl a..i~nm.1cuts will be 1! lfahcJ in t h* rcderal :,.c -;istcr for pu;)lic co .. 1.cnt . I J am also cnc l oa
- ui a copy or a t ui.>lic a nnom1ce*1c*nt on thl"' su!Jj.-.ct which i 9 ec:1cJul*., for r el(!.'lse on ::'lrc!, 27, l'.)7 0 , a.t 2:30 P . J .
Con ially, if. iE. JOHliSO Aoti 'hairiil<"l l.foclos ur~ :
- 1. Proposed atr,cn t*anti-1
- 2. Public annou.1cel.ii<!llt Identical letters , except first line readin 11
* *
- as a member * .. " sent to:
Honorable Walter J. Hickel, Secy. o t he Interior Honorable Helvin
- Laird , Secy . of Defense Honorable 1-:aurice H. Stuns , Secy. of Com.~erce Distribution : Honorable George P . Shultz, Secy . of Labor Chait"lll3n (2) Honorable Clifford M. Hardin, Sec , 0.1. A3ricultw*e HLPrice, DR DR Reading CRESS OFFICE ........DR ************* I******* DR ____________ ************************* ************************** ******************* ****** ..... ****************
suRNAME ~i!!~rn~~F.$..Qn.=.,1'tf ..ll.tJ'rJ.c;.~*-***** ................................................................................................ . DATE .... 'J/.~'J/.7.9..... .. .....'Jl.....1.7.0. ...... ***********************" ........ _............ ************************* ********************* Fo1*m , EC*318 (Rev. 9 53) U.S. G0VFRHMENT PRINTING OFFICE, 19Cl-O*36*l*SOO
DOC KEff D U&IEC APR 6 1970 Office Of lhe Secret#} Publfc Prre*edlnp llrnnc:; or. ~*i1H Sll~ !,. l.lt-~. C'!i1 r t~;-;tlat10\1
- rot.::ctSc*! ~;ir.c -\ .:1 J ,,cnr .., i :-t >.,L?~*arti ~*~i of Je ... l th atd ~~clal ~~ rvice~
;,SvJ r,i~l of : ~ '11t--:. 0
,r . ; J... i..0:; .})
r.<it l!.otl, i, t; co:..~ !.il 5 37'll I nM ci~(' '->:;t, ;; fer :_tli-;.:-r .in o~ .:-'ltlo1 e('\1 'f cf . *r *.i::c,-..-.
,a"1(1flr~,;,_.";:ll ~ t:J ;,.:..C :,.: ~ti t "ic!'\.. (".~ *,v.. !.'ll! * *,* t.r,,* t":r.,,t r ...
f r ..11,:'Elc~ :: r.1 : L':;ct1:vi t ~ 1:,-., t *10 .:.*r*._i ~*,1!:* :1t ~.:d.\.':, 1:o t:c-,t1*.,1 ,;.,
- o *, t l '. "l; t
- 1 ,;-., w. T:,c;,:,
- r* .... o* oJ n,*,~ i:11!-
o:c :it.:
- 111 tJll ;,\!~liH;1ad. t -, ...:.~ t"t:.dr. '11 .- ...... ~.. t: .'.! r c,:r
,i"'....v
...l-,li... . . . ,.. ......... t
, .. \,., ... _~,,,- *, "
..... "l , ....'-', ,.,,.,
' .-" ... ~ . * - ...
c-,.-.
***.., *>-... -r.-.. -c*,.~.~ c,f " ,,u'l ll*"
*,1 ..... <lo .. '
t.1.nn lU:., c*Ji'*,!ll on .*:., 1:1 ~c *1ch,l0,; -..,r cl\:.~.-H~ ot', ::~-::c , :;!,; ~*.
- wo tl b*... y r:, :-... \lt~ teJ ~ o,~:.--; i :it-1 f OUt" s:c~ .. 1.1.!~ti, a (1'f! '.:
t: ot:**c't~l ~>c £1~r- 1.:v .t t *!!! during t ~" i_.;'.)-tl.:i:* e <) ;;.,:-:11. p . r!.01o f oll~..-.,! ... r,u:,l. er.tic~, :il, *,: 1 f: * *: ~!... ~*. .,.i~* ..,........ t "'r .
"Signed" Eb11r R. Pric6 l.i.<;:- ?.. ?rlc.,J, **r... rr-{"~or Div1.r.iio;, of S , t t~ -1,:.
L1c~ti:'l"-*-:! \c 1 :l i :'\,W ( Ident .c tters sent to roons on o.ttc.c 1ed llot) c:' 1 :~ 5 1,' 7 , 12 El:Pri o .j li 3/ / 7'
Non-Agreement States In Which Power Reactors Are In Operation, Under Construction , Or For Which Construction Permit Applications Are Pending. CONNECTICUT Arthur
- T. Heubner , Radiation Health Physicist Occup~tional Health Section Connecticut State Department of Health 79 Elm Street .
Hartford, Connecticut 06115 ILLINOIS Leroy E. Stratton, Chief Bureau of Radiological Health Illinois Department of Public Health 525 West Jefferson Street Springfield, Illinois 62706 I NDIANA Hal Stocks , Acting Director Division of Radiological Health Indiana State Board of Health 1330 W. Michigan Street Ind ianapolis , Indiana 46206 IOWA Dr. C. --L. Campbell , Ac ting Director Radiation Protection Division Iowa State Department of Health State Office Building Des Moines , Iowa 50319 MAINE Earle W. Tibbetts, Director Sanitary Engineering Division Bureau of Health Main~ Department of Health and Welfare State House Augusta , Maine 04330 MARYLAND Rob ert E. Corcoran, Chi ef Div ision of Radiological Health Maryland State Department of Health 23 05 North Charles Street Baltimore , Maryland* 21218 MASSACHUSETTS Gerald S. Parker , Assistant to the Co1mnissioner (Radiological Health) Massachusetts Departmen t of Public Health 80 Boylston Street, Room 560
' Boston , Massachusetts 02116
MICHIGAN Donald E. Van Farowe., Chief Radiation Section Divis ion of Occupational Health Mich igan Department of Public Health 3500 N. Logan Street Lans ing , Michigan 48914 MINNESOTA Dr. W.R. Lawson , Deputy Executive Officer Minnesota Department of Health 717 Delaware Street , S. W. Minneapolis , Minnesota 55440 NEW J ERSEY William H. Aaroe, Chief Radio logical Health Program Divis ion of Environmental Health P.O. Box 1540 John Fitch Plaza Trenton, New J ersey 08625 OHIO James Wynd , Engineer-in-Charge Radiological Health Unit Ohio Department of Health P, O. Box 118 Columbus , Ohio 43216 PENNSYLVANIA Thomas H. Gerusky , Director Office of Radiological Health Pennsylvania Department of Health P. 0. Box 90 Harrisburg, Pennsylvania 17108 PUERTO RICO Miss Amalia Velez, Director Radiological Health Program Puerto Rico Dep_a rtment of Heal th 1306 Ponce De Leon Avenue Stop 19 Santurce , Pu erto Rico 00908 SOUTH DAKOTA Donald G. Kurvink, Chief Occupational and Radiological Health Section Sou th Dakota State Department of Health State Capitol Pierre , South Dakota 57501 VERNONT Raymond McCandless, Radiological Health Physicist Industrial Hygiene Division Vermont Department of Health P.O. Box 607 Barre, Vermont 05641
.. I VIRGINIA Bryce P . Schofield, Director Bureau of Industrial Hygiene and Radiological Health Supervisor Virginia Department of Health 109 Governor Street Richmqnd , Virginia 23219 WISCONSIN Dr . William L. Lea, Chief Radiation Protection Section Wisconsin Department of Health and Social Services Division of Health P, 0. Box 309 Madison , Wisconsin 53701
MAR 2 6 1970 DOCKETED tlSAEC Dr. Paul C. ToPp ns Executive Director Federal Radiation Council Washington, '!J . C. 20'*'*9
Dear Dr . Tot'lpki.ns:
I am enclosin for your i nforma tion a copy of pr.opo3cd amen ents to 0 AEC r egu ation concerning the control of rclcns~~ of radioactivity to th e environncnt uh ch t e Corr.m ission pl n s to i ssue . ,H'S propose nnc dnents will c pu lished in t 1e Fe era T>ef1intcr for pu lie cotDCn t. I an also enclosing a copyof 3 public announccnent on t i s u j cc t which is schedule for relcas on !farc 1 27, 1970, at 2:30 P . '*t . Sincerely, Harold L. Pr:J.cc Director of Ragu a tion nclosures :
- 1. Propo sed anendnent9
- 2. Press announc mcn t DISTRIBUTION : II HLPrice DR R/F OFFI CE a,.. .JUL .............. ... j. DR.~-j;?t************************ ..........................................................................
C RESSsuRNAME ..C..Lll~ttde..r.s.o.n: lm..H~fri.ce..... ......................... ......................................................................... (rbw) R3 DATE ..'J.l)A/.7.0. ........... ..312£1.10.)?J.r! ............................................... ............................................... Form AEC*318 (Rev. !l- 53) U.S. GOVERNMENT PRINTING OFFICE , 1969-0*364*598
I DOCKET NUM3E" PRO'POS D RULE -J..<SJ. ?O
~R~f DOCKETE D
~oJt.o~
O&AEC
~ 2 6 tr/0 Ho orable LaurlGton S . L'aylor, Cha: r ".:tn
!lation:il C' c:!.l 0,1 ~ <liat on Prot:,.ct.io and .{c...10 ure.-.i~o 9 iational A.cado~.y of Scienc*?s 2101 Co,1.:. titutfon Avenuu, }: , W.
~ohin;ton, D.C. 20413 Dear Or. Taylor.
I ar.1 plcn'3. to t>Ct! to you, il, t11,1 i n1'.l nf he ;;atlonn .o nc il 0-:1 nadiation 'Pr t~ctio:i a~<l 'l'!:i.s ur e*_,.... nt, a C(* ~y of p Oi);} V* 0,:-r?'i, l :~l :1 to \CC r cgul atlon:, c ot, c ning t:1c conl'.ro o i: rel:- n*::; of ra;llo:1ct vlty to t he env rom:-.nnt *,1ilich t11c Co:: n:l,:., d-.m n ~1 3 to L1 c . I'v*sc ;- o-o.;c<l aracndc:1cnt:J vi 1 be publi:,;10 in t*1c ;: ~clcral __ ~..:*l'ltcr. f r l u;,lic CO l~'"'lcnt . I un al,:;o enclo-;in£ a COI y of o. ~lie r'1.nou:lcc; ~mt on t 1da subject wi lch is schc,lulc..l for l"1lc;1se on i..1rcn 'l.7 1~71 ; at 2:Jn p . *t. ordin lly, fl'} !B~--j- .:--.~gt*~ AotintJ.irnirr.:ari
!;nc o~ ure5:
L r r o~;o ,;cJ a!.~Cm,,_, _nt*;
- 2. 1~u:-,1tc c1nnouncc ..:cnt Distribution:
Chairman (2) HLPrice, DR DR Reading
.... D.R ****************- ' --*---DR ********-*--- **-******* ***********-*-- ,....*******-**--* *--*--** ***----*-* **-*. *--**-*---* . -**--* *****---** --**.
OFFICE l suR:::: _ c~~;~/;~s.Qn;.~ CRESS
.}~-*~~~J*~-~~*--**-_ -*********-**-**-******** -**********--*********-*** -****--*--*-********-***** *--***-*---*******~~~:
1 Porm AEC-318 (Rev. 9-53) U.S. GOV.RN!!ENT PRINTING OFFICE , 1969-0-364*598
DOCKET r-:ur..... tr; . P.Rorosw RU~E R- Je, 5D DOCKETED tl&lEO 61970~ WtJJ~~f
~c~~
office of !be secrehll'J PubllC Pracse~lnP nnc~
,.tAA 2 6 19"/0 Honorable liarolc.1 LnV.:indcr C1>" errtoT cf ~iinc so t .:t St . :,~ul, ' il nncch,'.:6. 55101
Dear Governor LcVac.dcr:
I on plcn!ic'1 to e;iclo!"'tc for your infon.:a.tion a cor,*;,' o:f p:?:"ot,oGc-,t aMcu~incntu t:, , f." r c~ul:..i.t.lmn CO!l:.:.l!raint~ t 1c co~ trol of relc.. ~ws of rad onct.f.**:tty t o *.*.! o *1:. o:1:1cnt \.,hid t: Le c .. ~*1i,,si.on p .::n~ t o i ~".!ua . 'r'.1coc p *;,, iSW a;11cn.b::;utr.: 1111 be pu:,:,.1~ni!J in tnc _!:n~-.11:._}~.!:,_~st.£_;_ f ::>r : u'.:.il-'-c. cor-,Kn.t. r a al8o cnc l u::ilu~ a co:)'J o .. a ~ubl c an-:;0~1i-:o:*:_:,t Ct!l t !ds su:,jl'lC t ~:dc.~1 G. sc1,ed uled fot r cl,~,e en ~*arch 27, D 7J , .:t 2::~* P . :1. ie uoul d be p ca:.~ to cons-t<ler your ccwT1unts , .:iloag *;i '1 ot\e *.1 being invit eJ <lurin -=> t ~ie GG-day cci:~.:~:- r; p~riod follo*,_ *t. puhlic.-itfor. i n tl-i~ 1=-eJ ral R':!i:;; :::t~t-Aot1D!?c* a:i.r;Jan f.uclosurca =
- 1. Pro~oucd amcnc~un t s
- 2. ruJl c r.mno\:.lCC: .ent cc ; }ir . !tobcrt Iuvi..::;on, hairr.:nn Hi11n0-,ot:.i Pollution Control .\:-;ency 717 .vclc.ni..r "' Str,1,:,t , s. ;.
HJ.nneapoli.s, '..'!iuncsot.a 554l~0 Distribution: Chairman {2) HLPrice, DR DR Reading OFFICE ________ DR **--*--*-*--**-*-*-* DR ______________ ----*-*--**-------------- ----------**-----****-*-*-**--*-*-*-*-***----**--- *. -------------------*** CRESS suRNAME BLHenderson ~ rhw. H1Pr:ice ____ ------------*-------**-*- *---------*-***------**--- *-*--*---------**----*---- _____________________ _ DATE __ 3/ 23 / 70 _______________ 31 ___ ./ 10 _______ ----------***--*-*-**-* _ --------------------*-*-* --------******-*---*****- ------*-**-**---****-* l*'orm AEC- 318 (Rev- 9-53) U,5. GOVT-"RNM£NT PRINTING OrFICE, 1169-0-364-598
UNITED STATES DOCKET NUMBER p f.ROP.OSED RULE -a.I), fJO
~1~rf ATOM IC ENERGY COMMISSION WASHI NGTON, D.C. 20545
~~
March 26, 1970 ALL AG&:."'lliIBHr SI1ATES . I am enclosing for your i nformation a copy of proposed aoend,~ents to AEC r egulations concerning the control of r eleases of radio-activity to the environment 1,:hich the Commission ple.ns to issue. These proposed amendments will be published in the Federal Register for public comrnent . I am also encl osing a copy of a public announcen.ent on this subject which is scheduled for release on Ma rch 27, 1970, at 2 :30 P. M. We "10uld be pJ.ea,s-ed to consider your comments , along with others being invited dtt.ring. the 60-day CO?;ll'llent period fo l lo1-ring publi-cation in the Federal Register .
*/7
~ .6~~ ~
~ , *' ,
/,' r.- ..
er R. Price , Director Division of State and
- Licensee Relations
Enclosures:
- 1. Proposed amendr:lcnts
- 2. Press announcement KETE D ll&AEC PR 61970 Ott/c, Of the Secret Pub/le Proceed/n,sar, Branch
l..,.1.tIBCTORS OF &.DIOI..OGIC/\ L ESP LT}! l nOGRAt*IB Ill AGREE:*IBNJ~* S:i:ATf;S Alaba:i;_a Fl orida Mr. William T. Willis , .Director Chester L. Nayfield, M. D. Division of Radiological Hc~lth Administrator Alabams State Department of Ba.diologica l & Occupational Publ ic Health Heal th Section state Office Building, Room 313 Florida Division of Hea lth
~bntgomery , Al abar::a 36104 P.O. Box 210 Jacksonville , Fl orida 32201 Arizona Georgia Mr. Don Gil bert , Director Arizona. Atomic Energy Conmiss ion Mr. Richard JI . Fetz , Director 40 East Thomas Road , Suite 107 Radiologica l Health Service P'noenix, Ar izona 85012
- Georgia lRp-.1.rtm.e nt of Public Hee.1th Arkansas State Health Building Atlanta, Georgi a 30303 Mr. Edwarcl F. Wils on, Director Di vision of R:1.dioloc;ical Health I daho Arkansas Sta t e Boa rd of HE::a.l th Litt l e Rock, Arkansa s 72201 Mr. Michael A . Christie , Chfo j Radiological Health s~ction California I daho . De_p.:.rt mcnt of Hea lth statehouse Dr. Simon Kins~an, Chief Boise, I daho 83707 Bureau of Radiologica l Health Department of Public Health Kansas
.... 2151 Ber'kel ey Hay Berkel ey, California. 9470!~ Mr. Robert C . Hill, Chief Radiologica l Health Section Colorado Ba.diologica l and Oc cu1xi.tionul Health Proera.m Mr. R. D. Siek, Chief EnvironrGenta.1 Hea lth Serv:i.ces Radiation Hygi ene Section Kansa s state Depa.r t~cnt of Colorado Depar tment of Heal th Public Health Topeka, Ke.nsas 66612 1i210 E:1.st 11th .4venue Denver, Color8.c1o 80220 Februa r.f 2l~, 1970
Kentucky New York cont . Mr. Ricli..n.rd l!. Fry, Director Mr. Sherwood D:tvies , Directo. Radiologica l Health Program New York State De:partnent Kentucky state Department of of Health Health , 845 Central Avenue
- 275 East J,ain Street Albany, New *York l220o
~ nkfort , Kentucky 40601
.Phillip Bourland, H.D., Chie*
Louisiana Radioloeical Health Section
- New York State Labor Dr. Roy A. Parker, Director Department Division of Radiation Control 80 Centre street Louisiana. Board of :Nuclear Neu York, New York 10013 Energy.
P. o. Box 44033, Ce.pitol Station }1r. Hanson Blatz , Director Ba.ton Rouge , Louisiana 70304 Office of Radiation Control New York Cit Dep:1.rt.ment of Mississiypi Health 325 Broadway Mr. Eddie S. Fuente , Supervisor New York, Neu Yorie 10007 R:tdiological Health Unit Mississippi State Board of Health Morch Carolina Jackson, Hississi:ppi 39205
}1r. Dayne H. Brmin, Director Nebraska state Radiation Protection
. Procrar.1 Mr. Ellis Simmons , m.rector Morth Carolina State Board Division of' Radiological Health of Health Mcbra ska state Department o:f.' Raleieh, .forth Carolina 2760 Health
.Lincoln , l!cbraska. 68509 lrorth DJ.kob.
New Hampshire Mr. Gene A . Christianson,
- ir Division of Environmental Nr. Forrest H. Btunforc1, Director Eneineer5.ng fu.dia t;ion Control Agency Radiological Health P-.cog1*ar.1 Division of Public Health Services state Dcpa.rtn:ent of Health
}lew Hampshire Departmcmt of Health ~isma.rck, !Torth To.kota 5850 1
and Welfa re 61 South Spring Street Concord, New Hampshire 03301 Dr. l,~rsh:111 Parrott, Di r ec., New York Radiological Health Sect5.o:-i Oregon State Eoarcl of Health Mr . :Neal L. l-!oylan P. 0. Boz 231 Commis s:i.0~1er
- Portland, Oree;on 9,.(20~(
Mew Yor~ State Departr:ient of Cor!l.r::i8rce 112 state Street Albany, !fow York 12207
/'
- South Carolina Mr. William G. Crosby, Director Division of F.adiologica l Hee.1th South Carolina state Boa rd of Health J. Marion Sims Build:L11g 2600 Bull Street ColumM.a, South Carolina 29201 Tennessee i1r. Francis P. Jung, Acting Director Division of R~diological Health Tennessee Depa rtment of PQblic Health 727 Cordell Hull State Office Building 1
Nashvi lle, Tennessee 37219 TeY.as i1r. Charle~ R. Parden, P. E., Director Division of Occupationa l Heal th and Radiation Control TeY.as sta tc Dcpe.ri;nent of Health Austin, '11exas 78 . (56. Mr . Arnold J . Moen , Hee.d Pia.diation Control Section ..... Division of Environmental Health Washin~ton State Department of Health 1510 Sm..i.th Tower Seattle, Wa shington 98104 New Yo:f-k l/ir
- T.nomas Cashman Director of Nuc.ea.r Engi neering Div . of General Engineering and Rad:i.ation Health
- New York State J?epartrnent of Health
- 8!~5 Central Avenue All;>any, New Yo:t*k 12206
Dr , Scynour Abra.1.imson Associat e Professor of Zoolo~y & Genetics University of Wiqconsin Zoolo y Re carch Bu 'lding 1117 t. est J ohnson Street Ha ison, ?isconsin 537 06
Dear Dr . 'raham*.30n:
I am pleased to send to you, as a n:e . er of t he ,T/ltionn l Council e,n Radiation Protection und **casurc:ucntH, 11 copy of pror,oscd ,:unrmc ncn t ~ t o A.EC rel"'u atio,~s co~cerning the control of re eage,.. of r d:J.oact v ty to the cuviron.wcmt 1,;hic l the ConnJ.O!lion plan9 to is:1ue. *r lC;,C proposed .:u:~enu,r.cnto will be pu lisbc, in t he Fe, crnl _Itcq c ; ~ for pu lie comment , I am nlso enc osing a copy of a pu lie announcer.cnt o~ t h "s subj ect which i s schc<lu e l for rclca3e on . arc~ 27, 1970 , at 2 : 30 P . r. Sincer~ly , lk.rold L. '>rice D:l.rcctor of r.er,u l ation Enc locurcs :
- 1. P ropo3 ed n::tendoents
- 2. Press nnouncement DISTRIBUTION :
HLPrica DR R/F See attached list - Identical l etters to
*r ornce tR................. *. .
- 1. .l)R. ;,*J;;;f *................................................................................................. *..
CRE oS ""'"' f!H=d"<son..m+ ****H~:i.ce***** ........................................ ****** **** -****** ****************** ***** ***** ********** *** T{rbv) R4 DATE 'rJJ2-4J7.0.............. __ 3/J/£/10.Jh'.ttJ_---*--*-***-----*--*** -- **----***-------*---*---- --*----****----*---*--*---*----***---*-***** Form AEC-31 8 (Hev. 9-53) U.S. GOVERNMENT PRINTING OFflCE, 1%9-0-364*598
+
. \
NATIONA. OL~CIL ON RADIATION PROl'ECTIO:. .m NEASUREHENTS l*'lQ 1 Connecticut Avenue , N . W. , S1* * .. e 402 Washington, D. C. 20003 MEMBERS OF THE COUNCIL
' /
Dr. Seymour Abtahamson' Col. Jar.ics T. Brennan/
'Ass ociate. Prof . of Zoology & Genetics ~ept. of Radiology University of Wisconsin University of Pennsylvania Zoology Research Building 3400 Spruce* Street 1117 West Johnson Street Ph iladelphia , Pennsylvania 19104 Mad ison , Wisconsin 537c6 PHONE : (215) 662-3C83 PH~NE : (6o3) 262-25C6 "t
Dr. Reynold F . Brown - Dr. Edward L . Alpen / Office of Environmenta l Health & Safety Manager , Environmental & Life Sciences Un iv . of Cal . San Francisco Med. Ctr. Division 1344 Third Avenue Battelle Northwest Laboratories * ~an Francisco , California 94122 P.O. Box 999 . PHONE :* (415) 433 - 1235 Richland , Washington 99352 PHONE : (509) 9t16.-2305 Dr. Aus tin H. Brues ~ Div. of Biological & Medical Research Mr. E.C. Barnes* ~ Argonne Nationa l Laboratory Director , Radi~tion Protection Argonne 1 I1 lino is 6o4t~o Wcst inghous Electric Corporation PHONE : (312) '(39-7711 Ext . 2000 3 Gateway Center , Box 2278 r Pittsburgh , Pennsylvania 15230 Dr . J ohn C. Bugher PHO~£: (412) 255-39o5 91.:6 Eve Street Delray Beach , Florida 33444 Dr. Merrill A. Bender ./ PHONE : (305) 278 4358 Chief , Dept. of Nuclear Medicine Ro swell Park Memorial Institute
- am W. Bur~/4.
- 666 Elm Street
- 1 ~earch Branch Buffalo , New York lt~203 and Hcdidnc PHONE : (716) 886-2700 Dr. Victor P. Bond / (20'2)
Ass ociate Director Brookhaven National Laboratory Dr. Leo K. Bustad,/' Upton, L. I. , New York 11973 Director, Radiobiology Laboratory PHO~"E: (516) 924-6262 Ext . 2860 University of California , Davis Davis , California 95Gl6 Dr. Frederick J. Bonte / PHONE : 916) 752-1340 Chainnan , Dep~ . of Radiology . Un iv. of Texas Southwestern Medical Sch. Dr. c *c orge W. Cas arctt / 5323 Han.--y Hines Blvd . Dept . of Radiation Biology Dallas , Texas 75235 Universit~ of Rochester School of Medici . ~ PHONE : (214) 638-1800 P.O. Box 287, Station 3
,* Roch ester , New York 14627 Dr: Carl B. Braes tr up -' PHONE: (716) GR 3-4~100 Box 4t*7 Guilford , Connecticut :6437 Dr. Randa 11 S. Caswc 11 I PHO~E: (203) h53-3:, ,*o Deputy Director of Center for Radiation Research Nation al Bureau of Standards Wash ington, n.c. 20234 PHOt-~E: (202) 921-2251
- Dr. Rich:ird H. Cha. rlain / Dr. - er t O. Corson .--
Director , Dept. of iology Ste" ' search Ce nte r Hospital of the u. or Pa . Dept . of Radiology 3400 Spruce Street Jefferson Medical College Philadelphia , Pennsylvania 19104 920 Chancelor Street PHONE : {215) 662 -3030 Phi ladelphia . Pennsylvania 19107
~ij0~1: : * (215) 829-7811 .
Dr. Cyril L. C~mar ,,... . Head, Dept. of Physical Biology Prof. Willi~m T. Hnm, Jr . ,-- New Yo rk State Veterinary College Dept . of Biophysics Cornell University Med ical College of Virginia Ithaca , New York l '-!850 *Health Sciences Division PHONE : (607) 256-2201 MCV Station Box 877 Richmond , Virginia 23219 Dr. Frederick P. Cowan PHONE : (703) 770-4041; lfead, Health Physics Division Brookhaven Nattonal Laboratory Dr. John W. Healy,,,.,- - Upton , L.I., ,New York 11973 H-1, Un~versity of California PHONE : . (516) 924-6262 Ext . 592 i Los *Al amos Scientific Laboratory
. .. *p .o *. Box* 1663- ** * ***
- Dr. Charles L. Dunham r Los Alamos , New Mexico 87544 Chairman of Div:. of Medical Sciences PHONE : (505) 667 - 4316 National Academy of ,Sciertees National Research Counci l Dr. John H. Heslep
*
- 2101 Constitutidn Av enu~, N.W. Chief , Environmental Health and Consu~er
~ash ington , D.C. 20418 Protection Program PHONE : (202) 961-1311 State Dept. of Public -Health
.,/ 2151 Berkeley Way ,,.
. Dr. M~rr il Eisenbud , Administrator Berkeley, Cali fornia 9tqo4.
- Environmental Protection Administration PHONE: (415) 843-7900 c/o Dept. of Water Supply , Gas & Electricity Room 2358 , Municipal Bldg .
- Dr. John S. ~aughlin ,,,..
New York, New York 10007 Dept . of Medical Physics PHONE :* (2 12 ). 566-4124 Memorial Hos pita 1 444 East 68th Street 1i~. Robley D. Evans r New York , New York 10021 Dept~ of . Physics PHONE:_ (212) TR 9-3000 Ext. 2991 Massachusetts Instit~te of Tcchn9logy Rm. 6209, 77 l-!assachusetts Avenue Dr. George V. LeRoy / Cambridge , Massachusetts 02139 Director of University Health Services PHONE : (617) 864-6900 Ext. 4831
- and Professor of Medicine Th e University of Chicago Dr. Titus *c. Evans ~ 950 East 59th Street Head , Radiation Research Laboratory Ch icago , Illinois 6c637 College 9f Medicine PHONE: (3 12) 86l~-6100 Universfry of Iowa Iowa City, Iowa 52240 Dr. Charles t,*. Mays /
PHONE: (319) 353-3747 College of Medicine Dept.- of Anatomy, Radiobiology Div . Mr . D.C. Fleckenstein' University of Utah Con~ultant , Industry Codes & Standa rds Salt u.ke City, Utah 84112 General Electric Company PHONE: (801) 322-7211 Ext. 6819 1 River Road 1 Bldg. 36-511 Schenectady , New York 12305 Dr. Richard F. Foster / Senior Research Associate Environnental and Life Sciences Division Batt lle Northwest P.O.- Box 999 Richlnnd 1 -~, shington J?352 . ____________ PH[)('B : _. (_r,l"':.9.LC1J6.::~S~ 1. ~-*.
.' : . *. Dr. i:>.1de W. Noc ll e - Dr. - oli n Raven os r Asso~iate Director Prof . Radiology Kresge Center for Environmental Health University of Pennsylvania Harvard Univ . School of Public Henlth Sc hool of Medicine -
665 Huntington Avenue 3400 Sprllce Street
.Bos ton , Massachusetts 02115 Ph ilad~lphia , Pennsylvania 19104 PHONE : (617) 734-3300 P~ONE : (215) 662-3000 V
Dr. Karl z. Morgan r Dr. Willaim C. Roesch Director, Health Physics Division Consulting Radiological Physicist Oak Ridge Nationa l Laboratory Battelle- Northwest Oak Ridge, Tennessee 37831 P.O. Box 999 PHONE : (615) 483-8611 Ext . 36786 Richland , Washington 99352
"' . . PHONE : (509) 942-11 11 Ext . 3369 Dr. Russell H. Morgan Depa rtment of Radiological Science Dr. HarAld H. Rossi Johns Hopkins School of Hygiene & Radiological Research Lab.
Public Health Columbia University 615 North t{olfe Street 630 West 168th Street Baltimorer Maryland 21205 New York, New York 10032 PHONE : (301) 955-3710 PHONE : {212) 579-3543 Dr. Robe rt D. Moseley I J-r: Dr. *william L. Russell / Dept. of Radiology Oak Ridge Nat;ional Lab o_ratory University of Chicago Biology Division J P.O. Box Y 950 East 59th Street Oak Ridge, Tennessee 37831 Chicago , Illinois 60537 . PHONE: (617' h81-86ll Ext . 37211 PHONE * (312) 684-6100 Ext . 6141
/
Dr. Jolm H. Rust r Dr. Robert J . Nelsen . University of Chicago American College of Dentists
- A.J. Carlson Animal Research Facility lt236 , Lindell Blvd . 950 East 59th Street St. Lo_u is, iissouri 63109 Chicago , Illinois 60$37 PHO~ : (314) OL 2-2825 PHONE:
Dr. Eugene F. Oakberg .- Biology Division Dr. Eugene L. Saenger Radioisotope Laboratory Oak Ridge National Laboratory Cincinnati General Hospital P.O. Box Y
- Cincinnati, Ohio 45229 Oak Ridge, Tennessee 37831 PHONE: (5 13) 872-4282 PHONE : (615) 483-8611 Ext. 37935 r Mr. HarryF . Schulte Dr. Herber*t H. Parker r Group Leader , Industrial Hygiene Group Battelle-North~est Los Alamos Scientific Laboratory P.O. Box 999 R-5, OHL Builaing Richland , Washington 99352 P,O. Box 1663 PHONE : ( 509) 942 - 1111 Ext. 64336 Los Alei.mos , New Mexico 87544 Dr. Edith H. Quimby " Dr.* F.i. Shore (
Radiology Depctrtment Dept. of Physics Col lege of Physicians and Surgeons Qu eens College Columbia University Flushing, New York 11367
- 630 West 168th S trect PHONE (212) HI 5-7500 Ext. l~53 I
New York, i:rew York 10032 * (Sun-mer : Broo *haven .'ationa 1 Lab . I PHONE: (212) 579-351}3 {516) YA 4-6262 Ext. 541) I 1 1 i
"*,.*. Dr . W.i:crenK . Sinc l "'i r ,,,. Dr . Arthur C. Up ton r
, .** .Argo.me N.!tional L~* atory Hea 1t9scienccs Center Div. of Biologic~l & d ical !foscarch State tversity of New York 9700 South Cass Avenue at Stony Brook Argonne , Il l inois 60440 Stony Brook , New York 11790 PHONE : (312 ) 739-7711 Ext . 2774 PHONE : (516 ) 246-5000 Dr. J. Newell Stannard Dr. Neil- Wa l d ,...
De pt. o f Radiation Biol ogy & Biophysics Di r ec t or , Radiation Health Division Univ . of Rochester , School of Hedicine University of Pittsburgh P.O. Box 287 , Station 3 Graduate School of Public Health Rochester , New York 14620 Pit t sburgh , Pennsylvania 15213 PHONE : (716) 275 -3893 PHONE :
"t Dr. J ohn B. Storer ~ Dr. Sh ie l ds Warren Oak Ridge National Laboratory Cancer Research Ins t i t ute Nuclear Divi sion New England Deaconess Hospital P.O. Box Y 185 Pi lgrim Road Oak Ridge , Tennessee 37831 Bos t on , Nassachusetts 02115 PHONE : (615 ) 483-8611 Ext . 35046 PHONE : (617) 734-7000
~ Laur.i ston S. Tay l ox- Dr. Edward w. Webster r Na UOA~ Acadey .o-r-Sciences Dept . of Radiology 2101 Const-i u t ~ Avenue, N . W. Massachusetts General Hospital Wash~ n , D *
- 20418 Fruit S t rcet
~ : (202) 96 ~ Bos t on , Nassachusctts 02114 PHONE : (617) 726 -3078 Dr. James G. Terrill , J r . /
I Asst . -to t he Administrator Dr--.-F..Q.rrcs t Wes tern~~.,.,
- Consun1er Protection and Environmen ta 1 Health Service (h'EW) . * . ~
U.S. Ato.n7 Ene"'tg~rrnnission Dircct~i-'l. oj>*Rad . Protection Sta Room 6804 - Federa l Office Bl dg . #8 Washing.t:<m , D. C. 20::,~5.... 200 C S treet , S. W. ~ ~or<: (202) 973 -7373 ' Washington , D. C. 20204 PHONE :* ( 202 ) 963-6958 Dr . Cl)'.de M. Williams r
. ,,,., Prof &Char:i.m:rn, Dept . of Radiology Mr. John H. Tolan Uni versity of Florid3 - Gainesville Teaed Ra diation s~fcty Officer Rospital and Clinics University of Missouri Gainesville, Florida 32601 Col umbia , Missouri 65201 PH0r-.1E : (904) 376-3211
- PHONE : (314) 449-9370 tir. Edwin G. Williams Dr . E. Dal e Trout/ 6560 Colgate Road X-Ray Science & Engineering Lab . ' J acksonville , Florida 32201 Oregon State UnivGrsity '.fllONE :
Corvallis , Oregon 97331 *
- J PHONE : (503) 754-1396 Dr . Marvin H, D. Williams .,
1013 Second Street, N.W. Dr . Bernard F. Trum < Roche~ter , Minnesota 559Jl Dir ,, New England Regional Primate PH0~1E : (50:: ) 289-6424 Research Center Harvard Medical School Dr. Harold O.
- i;.:yckoff 25 Shattuck Street Deputy Director Scientific Boston , Massachusetts 02115 Armed Forces Radiob i ology Resea:.:ch Ins PHONE: ( 617) RE 4-3300 Ext. 224 Defen~c Atomic Support Agency Bethesda, Na.ryla. ~d 20014
............ PHONE: (301) 295-1292
c*
, . DOCKET NUMBER f.ROP.OSED .RULE p -JlJ, 50
~f~J~n K:,.L.,.._~, l 2 t
'DOCKETED flS.EC
~~ . Edl~rd J. Bauser Executive Director APR 6 '1 970*
Joint Committee on tomic Energy Office or the Secretar, Pllllllc PrDCe3d/ngs Conzress of the United States Oran:.~ D~ar Hr . Bauser : Enclosed for t he information of the Join* Committee on Atomic Energy is a notice of proposed rule making to amend the Commission I s reeulations, 10 CF Part 20 , 11 Standards for Protection Aga inst Radiation", and 10 CF Part 50, "Licensing of Production and Utilization Facilities" . The proposed amendment to Part 20 "ould r:iprovc the frame*work for a~~uring that reasonable effor s are m:1de y all Commission licensees to l~ep c .~osurcs to radiation and releases of radioactivity in cf~lucnts as low as practicable . ~he proposed airendme ts to Part 50 would specify design and operating requirements to minimize ua titie s of radioactivity released in eascous aud liquid effluents from ligh t
\atcr cooled po't-~er reactors .
ndcr the proposed amendments to Part 50 1 applications for construction pcrr..its for light *water cooled po't-:er re.ictors ,-:ould be re uircd to include a description of equipm~nt to maintain control o er radioac t i ve rn3terials in effluents , means for achievinz the desi3n obj~ctive of kcepin3 levels of radioactive effluents as lo., as pr4cticable 1 and estimates of qu~mtities of radioactive rr.stcrial expected in effluent releases durinz normal reactor operation . Licenses to operate light "ater cooled po,:,*er re3ctors l,ould include technical specifications re iring adherence to operating procedures for control of effluents n d maintenance and use of equipment installed in the t*~a ste trcatrJent system, and *he submission of semi- annual reports containing informa tion on quantities of radioactive materia l released. The notice of proposed rule ~~king ,1 11 be filed with the Offi ce of he Federal Register and will allow 60 days for public comment after publication in the Feder~l Register . OFFICE ....................................................................................................................................................... SURNAME .................................................... ************************* **************************** *******--***********-** **********-****--***** DATE .............................................................................. *-*-******************-** ************--************ ******
- c. :ns CR v. 9-58) U.S. G0VE.RNMENT PRINTING OFFICE, 1169- 0*364-598 I
I
- Mr . Edward J. Bauser I am also enclosing a copy of an announcement we plan to issue on Fri~y. March 27. In this connection, we are planning to hold a press briefing at 10 A.M. 1 Friday, at our H Street offices . We would be pleased to have member of he Joint Comnittee staff ,,
present at the press briefing if thay are able to attend . Sincerely. Harold L. Price Director of Re ulation
Enclosures:
- 1. otice of Proposed R le Making
- 2. Public Announcement Distribution:
Chainnan Seaborg (2) Com. Ramey Com. Johnson Com. Thompson Com. Larson Director of Regulation GM (2) OCR (2) SFCY[3) RETYPED IN OFFICE _ RPS : DIR __________ ~-. --------------*-***-~ ------- --------*-***-*** ******************--***** ........**..*.....*....... -****--*----********. LROGERS O'Neill:aw
- SURNAME DATE _.. 3 I 19 / 7 o.......... _--*- 3 / 2 s/ 7 o****-* ***************-*****-**** ************************** .......................... **** ***********-*-
Form AEC-l18 (Rev. 9-53) AECM 02-'0
- u. s. GOVERNMENT PRINTING or,icE: 1Q68 O-320*507
ATOMIC ENE.lGY COZ.!HISSION (10 CFR PARTS 20 i\ND 50) STANDARDS F01. P:lOTECTION .i~GAINST R..-\ DL~TION LICENSING OF PRODUCTION ~\ND UTILIZ,\TION F,\CILITIES Control of Releases of Radioactivity to the Environment STATEMENT OF cm;sIDE?. \TIONS The Atomic Energy Co~.mission has under consideration amendments to its regulation, 10 CFR Part 20, 11 Standards for Protection Against Radiation", to improve the frai.1ework for assuring that reasonable efforts are made by all Commission licensees to continue to keep ex-posures to radiation and releases of radioactivity in. effluents as low as practicable and amendments to 10 CFR Part 50, 11 Licensing of Production and Utilization Facilities", to specify design and operat-ing requirements to r:1inimize quantities of radioactivity released in gaseous and liquid effluents from light water cooled nuclear power reactors. The proposed amendments to Part 50 would be applicable only to light *.-1ater cooled nuclear power reactors as discussed below. Basis for AEC Standards Releases of radio.ictive materials in effluents by Corr.miss5.on licensees are currently regulated under the provisions of 10 CFR S 20.106 which apply to all uses of byproduct, source, and special nuclear m.iterial licensed by the Commission. These provisions are based on radiation protection guides recom~ended by the Federal Radia-tion Council (FRC) and approved by the President. The Commission. main-. tains ~lose consultation,-~nd will continue to consult, with the FRC, the Nation.il Council on Radiation Protection and Me.isurements , and the Intern~tional Commission on Radiological Protection.
Since 1959 official guidance for control of exposures to radia-tion has be~n provided to Federal agencies through recommendations of the FRC, approved by the President. The FRC was established in 1959 by Executive Order and by an amendment to the Atomic Energy Act of 1954 (42 use 2021(h)). The FRC is directed to advise the President"*** with respect to radiation matters, directly or in-directly affecting health, including guidance for all Federal agen-cies in the formulation of radiation standards and in the establish-ment and execution of programs of cooperation with States". The basic recommendations of the FRC are generally consistent with those of the National Council on Radiation Protection and Measurements (NCRP) and the International Commission on Radiological Protection (ICRP). The FRC recommendations include a radiation protection guide for the genetic exposure of the entire population at a level not quite twice the average natural background radiation level and for a whole body exposure of individuals in the population at a level about five times the average natural background radiation. The guides are set well below the level at which detectable biological effects from exposure to radiation are expected to occur. The FRC states in Report No. 1 dated May 13, 1960, that the guides give appropriate consideration to the requirements of health protection and the bene-ficial uses of radiation and atomic energy~ Guidance on Low Radiation Doses The FRC added to the numerical guidance on maximum limits the
further guidance that "every effort should be made to encourage the maintenance of radiation doses as far below this guide as practicable". Similar statements are also included in NCRP and ICRP recommendations. The Commission has always subscribed to the general principle that, within radiation protection guides, radiation exposures to the public should be kept as low as practicable. This general principle has been a central one in the field of radiation protection for many I years. Current reviews of reactor licensing applications include reviews of provisions to limit and control radioactive effluents from the plants. Experience has shown that licensees have generally kept exposures to radiation and releases of radioactivity in effluents to levels well below the Part 20 limits. Specifically, experience with licensed light water cooled nuclear power reactors to date shows that radio-activity in water and air effluents has been kept at low levels - for the most part less than a few percent of the limits specified in 10 CFR Part 20. Resultant exposures to the public living in the immediate vicinity of operating power reactors have usually been small fractions of FRC guides. The Commission believes that, in general, the releases of radioactivity in effluents from the light water cooled power reactors now in operation have been within ranges that may be considered "as low as practicable." The Commission also believes that, as a result of advances in reactor technology, further reduction of those releases
can be achieved. The results to date are attributable, in part, to steps to assure the integrity of the nuclear fuel, to the design of waste treatment systems to control and contain radioactivity, and to procedures and methods to limit releases of radioactive material to unrestricted areas in effluent water and air. The AEC's total regulatory program includes not only the standards and limits in 10 CFR Part 20, but other regulations as well, various restrictions on plant design, and restrictions on operation included in individual operating licenses. In connection with the proposed an,endments set out below and in the light of progress in fuel element technology and in waste treat-ment and handling systems, the Commission plans to consult with the nuclear power industry, persons engaged in applicable research and development programs, and other competent groups to determine the feasibility of developing more definite criteria for design objec-tives and means for keeping releases of radioactivity in effluents from light water cooled power reactcrs during normal operations, in-cluding expected operational occurrences, "as low as practicable". Control of Exposures from Several Different Sources The Conunission expects that releases of radioactive material in effluents from light water cooled nuclear power reactors unde~ the present system of regulation will continue to be low. At the same
time, the Commission recognizes that there will be a marked increase in the number and size of nuclear power reactors in operation in the future, and that other activities that contribute radiation exposure to the public can be expected to increase. Design Objectives for Light Water Cooled Power Reactors The proposed amendments to Part 50 set out below are intended to give appropriate regulatory effect, with respect to radioactivity in effluents from light water cooled power reactors, to the guidance of the FRC that radiation doses should be kept as far below the radia-tion protection guides as practicable. As in the past, an applica-tion for a permit to construct a light water cooled power reactor would be required to include a description of equipment to be installed to maintain control over radioactive materials in effluents during normal reactor operations, including expected operational occurrences. In addition, in the case of an application filed on or after the effec-tive date of the proposed amendments, the application would be required to identify the design objectives, and the means to be employed, for keeping levels of radioactive material released in effluents as low as practicable. As in current practice the Commission would review the proposed design of the reactor, including the waste treatment equipment and the description of procedures for the maintenance and use of the equipment, to determine whether the required design objec-tives are met. Each license authorizing operation of a light water cooled power
reactor would include technical specifications which would require adherence to operating procedures for control of effluents and the maintenance and use of equipment installed in the waste treatment system, and the submission of semi-annual reports containing informa-tion on quantities of radioactive material released. If quantities released during the reporting period are unusual for normal reactor operations, including expected operational occurrences, the licensee would be required to cover this specifically in its report. The effluent release data submitted by licensees would be compiled by the Commission and made available to the public. The Commission would review in its inspection and enforcement program the effective-ness of the maintenance and operating procedures used by licensees in meeting the objective of reducing, to the extent practicable, the quantities of radioactivity released in air and water effluents. On the basis of existing technology and past operating experience the Commission expects that 'light water cooled power reactor waste treatment systems designed and operated in accordance with the require-ments set forth in the proposed amendments to Part 50 will help to assure that releases from light water cooled nuclear power reactors will generally not exceed a few percent of the annual maximum limits specifie:d in Part 20 and in license conditions, and that radiation exposures to the public resulting from the normal operations of light water cooled power reactors will not exceed small fractions of exposures from natural background radiation and of FRC radiation protection guides.
Need for Flexibility of Operation It is necessary that light water cooled power reactors designed for generation of electricity have a very high degree of reliability. Operating flexibility is necessary to take into account some varia-tion in the small quantities of radioactivity, as a result of expected operational occurrences, which may temporarily result in levels of radioactive effluents in excess of the low levels normally released, but still within the maximum limits specified in Part 20. Monitoring The Commission will continue to evaluate exposures to the public from releases of radioactivity in effluents from nuclear power reactors. Reactor licensees are presently required to carry out monitoring pro-grams designed not only to determine levels of radioactivity in efflu-ents released from the plant but also to detect significant increases in levels of radioactivity in the environment. The licensee is re-quired to report these data to the Commission on a periodic basis. In addition, the Commission, the U.S. Public Health Service and several States carry out independent environmental surveillance programs. These programs are designed to detect and evaluate increases in en-vironmental levels that may be significant to human exposure. Research and Development The Commission and the nuclear power industry have for many years carried out research and development programs in the development of
waste treatment and handling systems for limiting radioactive mate-rial in effluent air and water. The Commission will continue to encourage and support research and development programs which con-tribute to the ability of the nuclear power industry to minimize re-leases of radioactivity to the environment. Pursuant to the Atomic Energy Act of 1954, as amended, and section 553 of title 5 of the United States Code, notice is hereby given that adoption of the following amendments to 10 CFR Parts 20 and 50 is contemplated. All interested persons who desire to submit written comments or suggestions for consideration in connection with the proposed amendments should send them to the Secretary, U.S. Atomic Energy Commission, Washington, D. c. 20545, Attention: Chief, Public Proceedings Branch, within 60 days after publication of this notice in the FEDERAL REGISTER. Comments and suggestions received after that period will be considered if it is practicable to do so, but assurance of consideration cannot be given except as to comments filed within the period specified. Copies of comments received may be examined in the Commission's Public Document Room at 1717 H Street, N.W., Washington, D. C.
- 1. A new paragraph (c) is added to§ 20.1 of 10 CFR Part 20 to read as follows:
§ 20.1 Purpose (c) In accordance with recommendations of the Federal Radia-tion Council, approved by the President, persons engaged in activities under licenses issued by the Atomic Energy Commission pursuant to the Atomic Energy Act of 1954, as amended, should, in addition to comply* ing with the requirements set forth in this part, make every reason-able effort to maintain radiation exposures and releases of radio-active materials in effluents to unrestricted areas as far below the limits specified in this part as practicable.
- 2. A new§ 50.34a is added to 10 CFR Part 50 to read as follows:
§ 50.34a Design objectives for equipment to control releases of radioactive material in effluents - light water cooled Eower reactors. (a) An application for a permit to construct a light water cooled power reactor shall include a description of the equipment to be in-stalled to maintain control over radioactive materials in gaseous and liquid effluents produced during normal reactor operations, including expected operational occurrences. In the case of an application filed on or after ___________ ,* the application shall also identify the design objectives, and the means to be employed, for keeping levels of radioactive material in effluents to unrestricted areas as low as practicable. ~ffective date of this amendment.
- 10 -
(b) Each application for a permit to construct a light water cooled power reactor shall include: (1) a description of the equipment to be installed pursuant to paragraph (a) of this section; (2) an estimate of: (i) curie quantities of radionuclides expected to be released annually to unrestricted areas in liquid effluents produced during normal reactor operations; and (ii) curie quantities of radioactive noble gases, halides and particulates expected to be released annually to unr estricted areas in gaseous effluents produced during normal reactor operations; (3) a description of the provisions for packaging, storage, and shipment offsite of solid waste containing radioactive mate-rials resulting from treatment of gaseous and liquid effluents and from other sources. (c) Each application for a license to operate a light water cooled power reactor shall include a description of procedures for the control of gaseous and liquid effluents and for the maintenance and use of equipment installed in radioactive waste systems pursuant to para-graph (a) of this section.
- 3. A new§ 50.36a is added to 10 CFR Part 50 to read as follows:
§ 50.36a Technical specifications on effluents from light water cooled power reactors.
(a) In order to keep releases of radioactive material to unre-stricted areas during normal reactor operations, including expected operational occurrences, as low as practicable, each license authoriz-ing operation of a light water cooled power reactor will include technical specifications that, in addition to requiring compliance with applicable provisions of§ 20.106 of this chapter, require: (1) that operating procedures developed pursuant to
§ 50.34a(c) for the control of effluents be established and followed and that equipment installed in the radioactive waste system, pursuant to§ 50.34a(a), be maintained and used.
(2) the submission of a report. to the Commission within 30 days after January 1 and July 1 of each year specifying total quantities of radioactive material released to unrestricted areas in liquid and gaseous effluents during the previous six months of operation and such other information on releases as may be required to estimate exposures to the public resulting from effluent releases. If quantities of radioactive materials released during the reporting period are unusual for normal reactor operations, including expected operational occurrences, the report shall cover this specifically. On the basis of such reports and any additional information the Commission may obtain from the licensee or others, the Commission may from time to
time require the licensee to take such action as the Commis-sion deems appropriate. (b) In establishing and implementing the operating procedures described in paragraph (a) of this section, the licensee shall be guided by the following considerations. Experience with the design, construction and operation of light water cooled power reactors indicates that compliance with the techni-cal specifications described in this section wilJ keep releases of radioactive material in effluents at small fractions of the limits specified in§ 20.106 of this chapter and in the operating license. At the same time, the licensee is permitted the flexibility of opera-tion, compatible with considerations of heelth and safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such small fractions, but still within the limits specified in§ 20.106 of this chapter and the operating license. It is expected that in using this operational flexibility under unusual operating conditions, the licensee will exert his best efforts to keep levels of radioactive material in effluents as low as practicable. (Sec. 161, 68 Stat. 948; 42 u.s.c. 2201) Dated at this day of , 1970. For the Atomic Energy Commission W. B. McCool Secretary
No. N-48 FOR MORN ING NEWSPAPERS OF
- rel. 973-3446 (Info.) SATURDAY, MARCH 28, 1970 973-5371 ( Copies)
AEC PROPOSES AlVll:!:NDMEN'l'S 'ID REGULA'l'I ONS ON RADIOAC'l'IVE EFFLUENTS FHOM LIGlfr WA'l'ER COOlliD NUCLEAR PONER REACTORS The Atomic Energy Commission is proposing to amend its regulations to improve the framework for assuring that reasonable efforts are made to continue to keep exposures to radiation and releases of radioactivity in effluents from light water cooled power reactors as low as practicable. Releases of radioactivity from these plants have gener-ally been less than a few percent of the maximum limits set by ALC. In view of the rapid growth of nuclear power and increasing uses of radioactive materials and other sources of radiation, the Commission believes i t desirable to in-clude in its regulations additional provisions to help assure that total radiation exposures to the public from licensed atomic energy activities remain low.
'1'he Commission is inviting public comment on a proposed amendment to Part 20, tile regulation which sets general stand-ards for protection aqainst radiation and propos e d a mendments to l'art 5 0, the regulation which establishes dcsi<Jn criteri a an<l operating requirements for nuclear power plants.
~eleases of radioactive materials in effluents by all Commission licensees currently are regulated under provisions of its Part 20 regulation. These provisions are based on radiation protection guides recommended by the Federal Radia -
tion Council (FRC) and approved by the President. These guides take into account the recommendations of the National Counc i l on Radiation Protection and ~easurements an<l the In ternat i onal Commission on Radiological Protection. (r,tore)
- 2 -
Experience has shown that AEC licensees have generally kept exposures to radiation and releases of radioactivity in effluents to levels well below AEC limits. In particular, the nuclear power industry has generally held the discharge of radioactivity in effluents from reactor sites down to a small fraction (less than a few percent) of the maximum limits specified by the AEC. Thus, resultant exposures to the public living in the immediate vicinity of operating power reactors have generally been small fractions of the upper limits desig-nated in the FRC guides. The proposed amendments would not modify any of the maximum limits on radiation exposure set forth in Part 20. The Commission maintains close consultation with the FRC, as well as the NCRP and ICRP. The Part 20 limits will con-tinue to be based on the recommendations of the FRC as approved by the President. In addition to numerical radiati on protection guides on maximum limits the FRC has recommended that "every effort should be made to encourage the maintenance of radiation doses as far below this guide as practicable." This general prin-ciple has been a central one i n the field of radiation pro-tection for many years. The proposed amendments would specify additional measures in support of this general principle. Progress in fuel element technology and fabrication techniques and in waste treatment and handling systems has demonstrated increasingly that modern power reactors are capa-ble of normal operation at levels far below the limits spec-ified in Part 20. The proposed amendments are intended to encourage the utilization of this technological progress in the design, construction and operation of new light water cooled power reactors. In connection with the proposed amendments to Part SO, the Commission plans to consult with the nuclear power indus-try, persons engaged in applicable research and development programs, and other competent groups to determine the feasi-bility of *developing more definitive criteria for design objectives and means for keeping releases of radioactivity in effluents from light water cooled power reactors during normal operations, including expected operational occurrences, "as low as practicabl.e. " The Commission believes that, in general, the releases of radioactivity in effluents from the light water cooled power reactors now in operation have been (more)
within ranges that may be considered "as low as practicable." The Commission also believes that, as a result of advances in reactor technology, further reduction of those releases can be achieved. Under the proposed amendments to Part 50, each applica-tion for a permit to construct a light water cooled nuclear power reactor must include a description of equipment to maintain control over radioactive materials in effluents, means for achieving the design objective of keeping levels of radioactive effluents as low as practicable, and estimates of quantities of radioactive material expected in effluent releases during normal reactor operations. The Commission would evaluate the proposed design of the reactor, including the waste treatment equipment and the description of proce-dures for the maintenance and use of the equipment, to deter-mine whether design objectives would be met. Each license authorizing operation of a nuclear power reactor would include technical specifications requiring adherence to operating procedures for control of effluents and for maintenance and use of equipment installed in the waste treatment system. The license would require also the submission of a semi - annual report containing information on quantities of radioactive material released in effluents. Under the proposed regulations, the licensee would be permitted the flexibility of operation, compatible with con-siderations of health and safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than small fractions of Part 20 limits, but still within the limits specified in§ 20.106 and the operating license. Persons wishing to submit written comments for con-sideration in connection with these amendments should send them to the Secretary, U. s. Atomic Energy Commission, Washington, D. c. 20545, within 60 days after the Federal Register* publication date. Copies of the notice of proposed rule making may be obtained by writing to the Director of Regulation, u. s. Atomic Energy Commission, Washington, D. c. 2os1s.}}