p.1 

PICK-UP DATE: 

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(PART A_ of_B ) 

EPA DOCKET ID: 102RQ-RN 

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45) 102RQ-RN-5-7 

47) 102RQ-RN-5-9 

49) 102RQ-RN-5-11 

51) 102RQ-RN-5-13 

53) 102RQ-RN-5-15 

55) 102RQ-RN-3-4 

57) 

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61) 

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Step 3: FOR ASRC INTERNAL USE 

ONLY 

CD: 

OA: / 

42) 102RQ-RN-5-4 

44) 102RQ-RN-5-6 

46) 102RQ-RN-5-8 

48) 102RQrRNil0 

50)(l02RQ-RN-5-12 3 

52) 102RQ-RN-5-14 

54) 102RQ-RN-5-31 

56) 102RQ-RN-2-5-1 

58) 

60) 

62) 

64) 

66) 

68) 

70) 

72) 

74) 

76) 

78) 

80) 

Step 1: FOR ASRC INTERNAL USE ONLY 

Are there more documents for this Docket in another box?(*YES// NO 

"'Fill out Continuation Sheet and go to Step 2 

Internal SFUND Box Number 35 OF 283 

Initials/Date: LDS / 3-8-2007 
PJ. 

SFu*b-t9$l-0O0*fTECHNICAL BACKGROUND DOCUMENT TO SUPPORT 

PROPOSED RULEMAKING PURSUANT TO SECTION 102 OF THE 

COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, 

AND LIABILITY ACT: RADIONUCLIDES 

A Report to the 

EMERGENCY RESPONSE DIVISION 

Office of Emergency and Remedial Response 

U.S. Environmental Protection Agency 

December 1986 

Prepared by 

ICF INCORPORATED and 

ENVIRONMENTAL MONITORING AND SERVICES, INC 

EPA Contract 68-03-3182 

y 
_P. 3 

(02RQ)~RN-5-(2 

? 

TECHNICAL BACKGROUND DOCUMENT TO SUPPORT 

PROPOSED RULEMAKING PURSUANT TO SECTION 102 OF THE 

COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, 

AND LIABILITY ACT: RADIONUCLIDES 

A Report to the 

EMERGENCY RESPONSE DIVISION 

Office of Emergency and Remedial Response 

U.S. Environmental Protection Agency 

December 1986 

Prepared by 

ICF INCORPORATED and 

ENVIRONMENTAL MONITORING AND SERVICES, INC. 

EPA Contract 68-03-3182 
P.4 

TABLE OF CONTENTS 

Page 

CHAPTER 1: BACKGROUND AND INTRODUCTION 1-1 

1.1 Background on CERCLA and RQ Notification Requirements 1-1 

1.2 RQ Adjustments for Radionuclides 1-2 

1.3 The Scope of the Radionuclide Release Problem 1-5 

1.3.1 The Affected Community 1-6 

1.3.2 Radionuclide Release History 1-9 

1.4 Organization of This Report 1-10 

CHAPTER 2: OPTIONS FOR THE ADJUSTMENT OF RADIONUCLIDE RQs 2-1 

2.1 Option 1: Allowing the Radionuclide RQ to Remain at 

One Pound 2-1 

2.2 Option 2: Considering Radionuclides as a Generic Class 

of Substances, Without an RQ and Not Subject to CERCLA 

Reporting Requirements 2-2 

2.3 Option 3: Establishing a Dose-Equivalent Level as the 

Radionuclide RQ 2-3 

2.4 0ption-4: Considering Radionuclides as a Class With a 

Single Activity Level 2-5 

2.5 Option 5: Grouping Radionuclides into Categories With 

an Activity Level Assigned to Each of the Separate 

Categories 2-5 

2.6 Option 6: Establishing an Activity Level RQ for 

Individual Radionuclides 2-7 

CHAPTER 3: IDENTIFICATION OF A LIST OF RADIONUCLIDES 3-1 

3.1 Rare Radionuclides 3-2 

3.2 Short-Lived Radionuclides 3-3 
P.5 

TABLE OF CONTENTS 

(continued) 

Pa^e 

CHAPTER 4: METHODOLOGY FOR PROPOSED RQ ADJUSTMENTS 4-1 

4.1 Methods Considered for Relating Radiation Damage to 

Releases in Units of Curies 4-1 

4.2 Method for Determining RQs Based on Inhalation, 

Ingestion, and Direct Exposure 4-2 

4.2.1 Release Values for the Inhalation Pathway 4-3 

4.2.2 Release Values for the Ingestion Pathway 4-5 

4.2.3 Release Values for the Direct Exposure Pathway 4-12 

4.3 Assignment of Radionuclides to Proposed RQ Groups 4-18 

4.4 Reporting Requirements for Mixtures of Radionuclides 4-20 

4.4.1 Mixtures of Known Composition 4-20 

4.4.2 Mixtures of Unknown Composition 4-21 

4.4.3 Common Radionuclide Mixtures 4-22 

APPENDIX A: Existing Reporting Requirements A-1 

APPENDIX B: Affected Facilities B-l 

APPENDIX C: Other Methods for Calculating RQs C-l 

APPENDIX D: Release Fractions for Inhalation D-l 

APPENDIX E: Derivation of the Atmospheric Relative Concentration 

Value E-l 

APPENDIX F: Routes for Ingestion of Radionuclides F-1 

APPENDIX G: Calculation of Direct Exposure Release Values G-1 
P.6 

CHAPTER 1 

BACKGROUND AND INTRODUCTION 

This report discusses the options that were considered by the 

Environmental Protection Agency (EPA) for adjusting the one-pound statutory 

reportable quantity (RQ) for radionuclides, and presents in detail the option 

and method the Agency has selected. 

This chapter outlines the general reporting requirements under Sections 

103(a) and (b) of the Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA) and the specific reporting requirements for 

radionuclides. Section 1.1 describes CERCLA reporting requirements and the 

types of potential response activities triggered by CERCLA reporting; Section 

1.2 describes the statutory authority for and the intended purpose of the RQ 

adjustment for radionuclides; Section 1.3 explains the scope of the 

radionuclide release problem; and Section 1.4 introduces the remaining 

chapters of this report. 

1.1 BACKGROUND ON CERCLA AND RQ NOTIFICATION REQUIREMENTS 

The Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 (CERCLA) establishes broad federal authority to respond to releases or 

threats of releases of hazardous substances from vessels and facilities. The 

Act requires immediate notification to the National Response Center when a 

hazardous substance designated under CERCLA is released into the environment 

in an amount equal to or greater than the RQ for that substance. 

Section 101(14) of CERCLA defines as a CERCLA hazardous substance any 

substance designated under: 

• Sections 307 and 311 of the Clean Water Act; 

• Section 3001 of the Resource Conservation and Recovery 

Act; 

• Section 112 of the Clean Air Act; and 

• Section 7 of the Toxic Substances Control Act. 

In addition, EPA has the authority under Section 102(a) of CERCLA to designate 

additional hazardous substances. Currently, there are 717 CERCLA hazardous 

substances if "radionuclides" are considered one hazardous substance. 

Radionuclides are considered hazardous substances under CERCLA because they 

were designated generically as a hazardous air pollutant pursuant to Section 

112 of the Clean Air Act. Section 102(b) of CERCLA establishes a one-pound RQ 

for all designated substances, except those for which an RQ was established 
P.7 

1-: 

pursuant to Section 311 of the Clean Water Act. Section 102(a) of CERCLA 

authorizes EPA to adjust statutory RQs by regulation.1 

Under regulations implementing the general reporting requirements of 

Sections 103(a) and (b) of CERCLA, a person in charge of a vessel or facility 

is required to notify the National Response Center immediately when there is a 

release of a designated hazardous substance in an amount that equals or 

exceeds the RQ for that substance (40 CFR Section 302.6(a)). Those persons 

required to notify but who fail to report immediately to the National Response 

Center are subject to criminal penalties under CERCLA Section 103(b). 

Releases that are federally permitted, as defined by Section 101(10), are 

exempt from the Section 103 notification requirements. 

The purpose of RQ notification is to alert the federal government to 

releases of hazardous substances that may require rapid response to protect 

public health and welfare and the environment. Under Section 104 of CERCLA, 

the federal government may take response action whenever there is a release or 

a substantial threat of a release of a hazardous substance or of any pollutant 

or contaminant which may present an imminent and substantial danger to public 

health or welfare.2 Notification based on RQs serves to inform the 

government of a release, thereby enabling an evaluation of the situation and a 

timely field response should one be deemed necessary. Notification does not 

necessarily mean that a federal field response will occur, nor does it 

eliminate liability or responsibility for response costs or natural resource 

damages associated with the release. 

1.2 RQ ADJUSTMENTS FOR RADIONUCLIDES 

There are approximately 1800 known radionuclides. A radionuclide is an 

isotope with an unstable combination of protons and neutrons in its nucleus. 

Instability is the result of an imbalance in repulsive and adhesive forces 

between these two types of nuclear particles. To achieve a more stable 

configuration, the nucleus releases energy in the form of particles or rays by 

a process of decay called radioactivity. The energy level of the resulting 

nucleus (i.e., the daughter) differs from the original nuclear energy level by 

the sum of the energies emitted. Each radionuclide decays by a specific 

lThe RQs for 340 hazardous substances were adjusted by EPA on April 4, 

1965 (50 FR 13456). RQ adjustments for an additional 102 substances were 

promulgated in a final rulemaking published on September 29, 1986 (51 FR 

34534). The radionuclide RQ was not adjusted nor proposed for adjustment in 

either of these rulemakings. 

Notification to the National Response Center pursuant to CERCLA Section 

103 is limited to releases of designated hazardous substances in amounts that 

equal or exceed the applicable RQ. Releases consisting solely of pollutants 

or contaminants that are not designated as hazardous substances under CERCLA 

need not be reported to the National Response Center. 
P.8 

l-J 

mechanism and at a specific rate and, as a result, a pound of two different 

radionuclides could represent significantly different levels of radioactivity. 

There are three types of radioactive emissions from radionuclides during[ 

the decay process: alpha particles, beta particles, and gamma rays. The

 : 

particles and rays differ in their mass, charge, energy content, and range of 

penetration in surrounding media. ! 

Alpha particles consist of two protons and two neutrons and have a j 

positive charge of +2. Alpha particles possess energies in the range of 2 to 

12 million electron volts (MeV), with typical values falling between 4 and 9; 

MeV. The alpha rays travel by short, straight paths, and are highly ] 

disruptive in tissue because of their high momentum and charge. ; 

Beta particles are either electrons or positrons, but are most often 

electrons. The energy range of beta particles is 0.02 MeV and 14 MeV, with \ 

typical values falling between 0.04 and 6 MeV. Beta particles are more 

penetrating (i.e., have a longer range in matter) than alpha particles, and 

are more easily scattered and are less disruptive than alpha particles. 

Gamma rays are photons that have no mass and no charge, and possess 

energies in the range of 0.01 to 10 MeV. Gamma rays are not scattered easily 

and can be very penetrating. , 

i 

As noted previously, radionuclides are designated as hazardous air ' 

pollutants under Section 112 of the Clean Air Act and are, therefore, I 

designated CERCLA hazardous substances. Section 102 of CERCLA establishes a1 

one-pound reportable quantity for radionuclides, as a generic class of 

substances, but authorizes EPA to adjust this RQ by regulation. EPA 

recognizes that an RQ of one pound for radionuclides is not appropriate in 

most cases because releases of less than one pound of a radionuclide may 

present a substantial danger to public health and welfare and to the 

environment. In addition, "pound" units are not commonly used for measuring 

radionuclides. 

CERCLA hazardous substances other than radionuclides have reportable j 

quantities ranging from one pound to 5000 pounds. For these substances, the 

principal health concerns are chemical toxicity, ignitability, reactivity, or 

potential carcinogenicity. These criteria may be related to a specific number 

of pounds of the hazardous substance released. Radionuclides are very 

different from other CERCLA hazardous substances because the principal health 

hazard associated with exposure to radionuclides is radioactivity, not 

chemical toxicity or the other concerns mentioned above. Although the level 

of radioactivity for a given radionuclide is directly proportional to its 

mass, equal masses of different radionuclides will not produce equal adverse^ 

health and environmental effects. For this reason, activity levels are most ; 

generally used as indicators of radiation intensity and potential hazard. The 

quantity of radioactivity is measured in units of curies3 (Ci) and, for 

3The curie is a measure of the rate of radioactive decay, with one curie 

equal to 3.7 x 1010 disintegrations per second. 
P.9 

1-4 

different radionuclides, the same number of pounds translates into a different 

number of curies. Thus, the statutory one-pound RQ translates into a wide ] 

range of curies for different radionuclides, covering twenty orders of 

magnitude. 

In addition to curies, another widely used unit for measurement of 

radiation hazard is the rem (originally Roentgen Equivalent Man). The rem is 

a unit of measure for radiation dose-equivalent and is often expressed as some 

number of rem delivered to a specific organ such as the lungs, thyroid, or 

whole body. Whereas the curie is a measure of the quantity of radiation 

emitted, the dose-equivalent in rem considers the routes of exposure and types 

of radiation encountered and therefore directly reflects the level of tissue' 

damage. Curies can be converted into rem by identifying the radionuclide, 

route and duration of exposure, quantity of intake, tissues most affected, 

type of radiation, and other factors that determine the hazardous effects of; 

the radiation. 

The nuclear industry generally uses units of curies and rem and, in fact, 

most existing reporting triggers for radionuclide releases are expressed in 

terms of one or the other, or both, of these two units.* In addition, 

essentially all existing regulations and controls established by the Nuclear 

Regulatory Commission and the Department of Energy, which govern a major 

portion of the nuclear industry, are based on units of curies or rem. 

Therefore, for the RQ under CERCLA to be consistent and meaningful, and to 

ensure that the radionuclide RQ allows for timely reporting and timely field 

response, if necessary, the statutory one-pound RQ is being adjusted in a 

proposed regulation. The proposed RQ adjustments are in units of curies. 

The Agency is proposing specific RQ adjustments for the 757 radionuclides 

for which the International Commission on Radiation Protection (ICRP) has 

provided metabolic data and recommended intake limits in ICRP Publication 

30.s All radionuclides not listed by the ICRP are grouped into a generic 

class of "Radionuclides," with one proposed RQ for the entire class. Chapters 

3 and 4 of this report discuss the numerous types of radionuclides and the RQ 

adjustment process in more detail. 

The harmful effects of radiation on humans has been the focus of most of 

the research efforts concerning radiation exposure in the past. EPA's .mandate 

under CERCLA is, of course, concerned with the broader problem of potentially 

deleterious effects to the environment as well as to humans. In proposing 

''Radiation measurements can also be expressed in international metric 

units of becquerels or sieverts; however, these terms are less common in the 

United States. 

5International Commission on Radiation Protection, Annals of the ICRP: 

Limits for Intakes of Radionuclides by Workers, ICRP Publication 30, Part 2, 

1980. 

I 
P.10 

1-3 

adjustments to the radionuclide RQ, the Agency's goal is to ensure, to the 

extent possible, ample protection for the most sensitive species of flora and 

fauna. The Agency reviewed the existing literature and determined that 

present information indicates that protection of human health would be 

sufficiently protective of the environment as well. The National Academy of 

Science states: 

The principal potential impact of radioactive effluents on 

the biosphere is the induction of deleterious health effects 

in man. Comparable levels of impact undoubtedly exist in 

other biota, but there is no present evidence that there is 

any biological species whose sensitivity is sufficiently 

high to warrant a greater level of protection than that 

adequate for man.6 

In addition, the International Commission on Radiation Protection (ICRP) has 

stated as part of its recommended objectives that: 

Although the principal objective of radiation protection is 

the achievement and maintenance of appropriately safe 

conditions for activities involving human exposure, the 

level of safety required for the protection of all human 

individuals is thought likely to be adequate to protect 

other species, although not necessarily individual members 

of those species. The Commission therefore believes that if 

man is adequately protected then other living things are 

also likely to be sufficiently protected.7 

The Agency has determined, therefore, that RQ adjustments for 

radionuclides developed with the goal of protecting public health will protect 

the environment as well. The Agency is, however, soliciting comments on this 

issue in the proposed rule and will consider any data on this subject 

submitted during the public comment period. 

1.3 THE SCOPE OF THE RADIONUCLIDE RELEASE PROBLEM 

Radionuclide emissions are most closely identified with the nuclear power 

industry, but are commonly released from other activities as well. The 

Nuclear Regulatory Commission, agreement states, and the Department of Energy' 

6National Academy of Sciences, The Effects on Population of Exposure to 

Low Levels of Ionizing Radiation, Report of the Advisory Committee on the 

Biological Effects of Ionizing Radiation, National Research Council, November! 

1972, p.11. j 

international Commission on Radiation Protection, Recommendations of ! 

the International Commission on Radiation Protection (ICRP), Publication 26, ; 

January 1977, p. 3. j 
P.11 

1-6 

(DOE) all license or oversee a variety of industrial facilities and 

non-industrial operations that emit radionuclides. In addition, several 

industrial categories not licensed by the Commission or an agreement state ' 

could potentially release radionuclides. Coal-fired utilities and industrial 

boilers, and mineral extraction industries such as uranium, aluminum, zinc, i 

copper, lead, and phosphorous mining all release certain amounts of ! 

radionuclides during their operations. This section discusses the types of ; 

facilities most likely to be affected by the proposed RQ adjustments and j 

reviews briefly the available data on past radionuclide releases. j 

1.3.1 The Affected Community 

The Nuclear Regulatory Commission has authority under the Atomic Energy ; 

Act to license source, byproduct, and special nuclear materials, Agreement, 

states are those which, after entering into an agreement with the Commission; 

have the authority to license source, byproduct, and special nuclear materials 

for facilities within their boundaries (see Appendix A, Exhibit A-1, for a 

list of agreement and non-agreement states). As of 1984, there were 8,900 

Commission licensees and 13,000 agreement state licensees.9 Both state and ! 

federal licensees are subject to the radioactive material release limits > 

specified in 10 CFR Part 20, as well as other controls specified by the [ 

license. Licensees can be divided into the following five general categories: 

• power reactors; 

• research and test reactors; 

• radiopharmaceuticals; 

• radiation source manufacturers; and 

other licensees, including laboratories, low-level 

waste disposal sites, mineral and metal processing • 

facilities, uranium mills, fuel cycle facilities, and 

Department of Defense facilities, including the Armed 

Forces Radiobiology Research Institute and nine naval 

shipyards. 

8These terms are defined in Section 11(e) of the Atomic Energy Act. 

Source material is defined as natural uranium (comprised of 99.27 percent 

U

238 , 0.72 percent U235 , and 0.0057 percent U 2 3 * ) , natural thorium 

(Th232 ), and any combination of natural uranium and thorium. Special 

nuclear material is defined as plutonium or any combination of uranium 

isotopes in which U2 3 5 is enriched (i.e., makes up more than 0.72 percent by 

weight). Byproduct material is defined as any radionuclide which is yielded 

in or made radioactive by exposure to radiation incident to the process of 

producing or utilizing special nuclear material. 

9U.S. Nuclear Regulatory Commission, 1984 Annual Report, p. 73. 
P.12 

The Atomic Energy Act of 1954 (Section 161 of Public Law 83-703) 

authorizes DOE "to protect the public health and safety" with respect to the 

operation of so-called "GOCO" facilities -- facilities which are "government I 

owned, contractor operated." As of 1980, 78 GOCO facilities in 24 states were 

subject to the health and safety requirements contained in DOE Order 5484.1. 

Although radionuclide releases in compliance with DOE Orders are considered 

federally permitted, these facilities are not Commission licensees. Major DOE 

facilities include national laboratories, facilities associated with the 

Formerly Utilized Sites Remedial Action Program (FUSRAP), the Uranium Mill 

Tailings Remedial Action Program (UMTRAP), the Grand Junction Remedial Action 

Program (GJRAP), the Surplus Facilities Management Program (SFMP), and . 

facilities involved in specific research and development programs.10 DOE is 

also responsible for operating uranium enrichment facilities, a step in the ! 

nuclear fuel cycle. Other DOE operations involving radionuclides include ' 

nuclear weapons research, development, and production; medical and biological 

research; and industrial applications and development. In 1982, there were j 

thirty "active" DOE complexes, many of which have several operating 

facilities A1 

Over 70 percent of the facilities that use or generate radionuclides are j 

not licensed by the Nuclear Regulatory Commission, an agreement state, or by ; 

the Department of Energy. These facilities are discussed briefly below. ' 

Large coal-fired boilers are used to generate electricity for public and 

industrial use and to provide process steam, process hot water, and space 

heat. More than 600 million tons of coal are burned each year in utility and 

industrial boilers. Coal contains mineral matter including trace quantities 

of naturally occurring radionuclides. Uranium-238 and thorium-232 and their 

decay products are found in relatively large quantities in coal,12 however, 

based on sample results for five utility boilers,13 less than three percent ' 

of the total quantity of radionuclides input from coal is usually released toj 

the air. \ 

1"Rogers and Associates Engineering Corporation, Radioactive 

Contamination at Federally Owned Facilities, June 1982, pp. 3-2, 3-3. 

11"Active" is defined to mean facilities currently generating 

radioactive waste. 

1 2U.S. Environmental Protection Agency, Radionuclides Background 

Information Document for Final Rules, Volume II, October 1984, p. 4.0-1. 

1 3U.S. Environmental Protection Agency, Survey of Five Utility Boilers 

for Radionuclide Emissions, Final Report, Office of Radiation Programs, 

Washington, D.C, December 1983, p. 3. 
P.13 

i-0 

In early 1985, there were 1,281 coal-fired units operating in the utility 

industry, with a total generating capacity of 281 gigawatts.

 ll> Major users 

of coal-fired industrial boilers (producing process steam and hot water, 

generating electricity for the producers' own use, and providing space heat); 

include the steel, aluminum, chemical, and paper industries. There are an 

estimated 51,187 coal-fired industrial boilers operating in the United States. 

Radionuclide emission levels from large utility boilers are generally in thei 

range of 0.0001 curies per day; radionuclide emission levels from the smaller 

industrial boilers are generally in the range of 0.00001 curies per day.15 ; 

Almost all mineral extraction industries that involve the removal and 

processing of ores to recover metal release some radionuclides. The Agency ' 

has identified the following mineral extraction industries as having potential 

for release of radionuclides: the uranium mining industry, the aluminum > 

industry, the copper industry, the zinc industry, the lead industry, and the ' 

phosphate industry. These industries were identified because of the large i 

quantity of ore mined domestically and because the mining processes used ! 

create a likelihood of radionuclide emissions. Individual radionuclide 

emission levels are generally in the range of 0.00001 curies to 0.000001 

curies per day from these facilities.16 [ 

These industries include the following facilities which use or produce 

radionuclides: 

Category of Facility Number of Facilities17 

Uranium Mines 181 (21 active) 

Aluminum Smelters 32 

Copper Smelters 15 

Zinc Smelters 5 

Lead Smelters 5 

Phosphate Rock Processing 31 

Elemental Phosphorus Plants 6 

l*ICF Energy Service, Summer/Fall 1985 Coal and Electric Utilities 

Market Assessment, p. 1-2 (1985). 

1 SU.S. Environmental Protection Agency, The Radiological Impact of 

Coal-Fired Industrial Boilers (Draft), Office of Radiation Programs, 

Washington, D.C, October 1981, p. 4.2-7. ! 

1 6U.S. Environmental Protection Agency, Radionuclide Background 

Information Document for Final Rules, Volume II, October 1984, p. 7.1-1, 

7.1-8, 7.2-6, 7.3-4, 7.4-4, 6.1-11. 

17U.S. Department of Energy, Statistical Data of the Uranium Industry, ] 

GJ0-100(83), Grand Junction, Colorado, January 1983, p. 9. Schroeder, H.J., 

Mineral Commodity Profiles -- Copper, U.S. Department of the Interior, Bureau' 

of Mines, Washington, D.C, 1979. U.S. Environmental Protection Agency, > 

Phosphate Rock Plants, Background Information for Proposed Standards, EPA 

450/3-79-017, Office of Air Quality Planning and Standards, 1979, p. 7-5. i 

U.S. Environmental Protection Agency, Radionuclides Background Information ; 

Document for Final Rules, Volume II, October 1984, p. 6.3-1. 
P.14 

1-9 

Appendix B in this report summarizes the regulated community by source ', 

category, number of facilities, major radionuclide of concern, and existing [ 

regulations. See also Appendix A of the Economic Impact Analysis for the 

Proposed Reportable Quantity Adjustments for Radionuclides under Section 102; 

of CERCLA for an expanded discussion of the regulated community. 

1.3.2 Radionuclide Release History 

As part of this regulatory development process, release data were i 

collected from the major federal agencies licensing, regulating, and ' 

controlling radionuclide releases: the Nuclear Regulatory Commission, the 

Department of Transportation, the Department of Energy, and EPA. The data 

were examined to understand the scope of the radionuclide release problem. [ 

The following release data were collected: | 

i 

• Reports maintained by the Nuclear Regulatory ! 

Commission's Office for Analysis and Evaluation of 

Operational Data (AEOD), 1981 through 1985; 

• Reports maintained by the Transportation Technology 

Center (TTC) of Sandia National Laboratory in ' 

Albuquerque, New Mexico, 19 71 through 1985; ; 

• Data provided by the Department of Energy's Office of | 

Environment and Health, Emergency Operations Center 

(EOC), March 1983 through April 1986; 

• Reports to the National Response Center, 1982 through 

1985; ; 

• Reports to the EPA's Office of Radiation Programs 

(ORP), October 1981 through September 1983; and 

• Reports to the Nuclear Regulatory Commission's ! 

Operations Center, January 1983 through January 1986. ', 

The availability and quality of data varied from source to source, but 

duplication among the six sources appears to be relatively limited. 

The AEOD data include some 300 reports annually, although about two thirds 

of the reports are incidents involving monitoring compliance or some other 

technical infraction which does not involve radionuclide releases. The TTC 

data include between 1 and 12 reports annually of transportation incidents 

involving radionuclide releases. These events are already required to be 

reported to the National Response Center under Department of Transportation 

regulations (49 CFR Parts 171-177). The Department of Energy EOC data include 

52 release events over a 3-1/2 year period (between 11 and 22 events annually) 

and include releases that are reportable under DOE Order 5484.1. The National 

Response Center data include approximately 80 reports (about 30 reports 

annually) and the ORP data include approximately 60 reports (about 30 reports. 
P.15 

annually). The National Response Center data include little detail on the 

radionuclide identity and the quantity released. The ORP data reflect mostly 

releases from power reactors. The final data source, the Nuclear Regulatory 

Commission Operations Center, include data on 26 events (about 8 events 

annually). 

Although the six data sources include a total of about 400 events 

annually, at least 200 of these annual events are not releases to the 

environment. We have data, therefore, on approximately 200 release events 

annually. These data sources, however, do not cover releases from all 

facilities that handle and that are, therefore, likely to release : 

radionuclides. For example, releases from unlicensed facilities and releases 

from facilities in agreement states would not be expected to be well 

represented in the data sets. In addition, not all types of radioactive 

material is well represented. One particular type of radioactive material 

that is not well represented in the data sets is naturally occurring and 

accelerator-produced radioactive material (NARM). While the Nuclear 

Regulatory Commission does address naturally occurring source material in its 

licensing when such material is used in conjunction with source, byproduct, , 

and special nuclear material, there are no other uniform regulatory or i 

reporting requirements for NARM (other than, of course, reporting of releases 

to the National Response Center). Virtually all states, both agreement and i 

non-agreement, have NARM regulatory programs; however, the data collected 

under these programs have not been gathered because they were too diffuse. We 

are, therefore, unable to analyze NARM production and release. 

1.4 ORGANIZATION OF THIS REPORT ! 

This report discusses the various options considered for adjusting the 

one-pound RQ for radionuclides and examines in detail the selected option. 

The remainder of this report is organized as follows: 

Chapter 2: Options for the Adjustment of Radionuclide RQs 

- -a review of the regulatory approaches considered and the 

one selected; ; 

Chapter 3: Identification of a List of Radionuclides -- a 

discussion of the universe of radionuclides to be regulated 

by this rulemaking; 

Chapter 4: Methodology for Proposed RQ Development -- the 

technical analysis and establishment of proposed RQ values; 

Appendix A 

Appendix B 

Appendix C 

Appendix D 

Existing reporting requirements; 

Affected facilities; 

Other methods for calculating RQs; 

Release fractions for inhalation; 
P.16 

1-11 

Appendix E: Derivation of the atmospheric relative 

concentration value (X/Q); 

Appendix F: Ground water transport of radionuclides; and 

Appendix G: Calculation of direct exposure release values. 
P.17 

CHAPTER 2 

OPTIONS FOR THE ADJUSTMENT CF RADIONUCLIDE RQs 

Several options for adjusting radionuclide RQs were carefully examined 

during the development of the proposed regulation. Each option presented 

certain advantages and disadvantages but each of the rejected options was 

determined to be inferior to the selected approach. This chapter discusses 

the following regulatory options and explains the Agency's position and 

rationale for selecting Option 6, the approach used to develop the proposed 

RQs: ; 

• Option 1: Allowing the radionuclide RQ to remain at 

one pound; ' 

• Option 2: Considering radionuclides as a generic 

class of substances, without an RQ and not subject to 

CERCLA reporting requirements; ' 

• Option 3: Establishing a dose-equivalent level as 

the radionuclide RQ; \ 

• Option 4: Considering radionuclides as a class with 

a single activity level; j 

• Option 5: Grouping radionuclides into categories 

with an activity level assigned to each of the separate i 

categories; and 

• Option 6: Establishing an activity level RQ for 

individual radionuclides. 

2.1 OPTION 1: ALLOWING THE RADIONUCLIDE RQ TO REMAIN AT ONE POUND 

Section 102(b) of CERCLA establishes the RQ for radionuclides at one 

pound. While a one-pound RQ might be useful to ensure reporting of very large 

radionuclide releases, the Agency does not believe that this RQ level is 

appropriate to trigger timely reporting or timely field responses, if 

necessary, for releases of many radionuclides because releases of 

radionuclides that are several orders of magnitude smaller than one pound may 

represent a serious health and environmental threat. In addition, a one-pound 

RQ does not conform to commonly accepted units of measurement for 

radionuclides. Most radiation measurements in the United States are in terms 
P.18 

of curies or rem,1 not pounds. A one-pound RQ level would, therefore, 

differ markedly from reporting requirements under other radionuclide 

regulations developed by EPA and other agencies. | 

A one-pound RQ for the entire class of radionuclides would also not take | 

into account the variety of hazards posed by different radionuclides. Because 

each radionuclide has a unique specific activity (i.e., a certain number of 

curies for one pound), a single one-pound RQ would relate to different numbers 

of curies -- and different radiation emission levels -- for each 

radionuclide. The Agency, therefore, concluded that a one-pound RQ was not 

sufficiently protective of public health and welfare and the environment. 

2.2 OPTION 2: CONSIDERING RADIONUCLIDES AS A GENERIC CLASS OF 

SUBSTANCES, WITHOUT AN RQ AND NOT SUBJECT TO CERCLA REPORTING 

REQUIREMENTS. 

In the April 4, 1985 final rule establishing notification requirements and 

adjusting RQs for certain hazardous substances (50 FR 13456), EPA decided not1 

to establish RQs for broad generic classes of organic and metallic compounds 

even though they are designated as toxic pollutants under Section 307(a) of 

the Clean Water Act and thus included in CERCLA's hazardous substance list. 

The reasoning for this decision, as stated in the preamble to that rule, was: 

Many of the generic classes of compounds encompass hundreds , 

or even thousands of specific compounds. It would be 

virtually impossible for the Agency to develop a reportable 

quantity that would take into account the varying 

characteristics of all the specific compounds in the class 

(50 FR 13461). ; 

Because there are over 1800 known radionuclides, the Agency considered using a 

similar approach for radionuclides, that is, not establishing an RQ for 

radionuclides and not requiring radionuclide releases to be reported to the 

National Response Center. In considering this approach, however, the Agency 

determined that the same technical argument could not be used to support a 

decision not to establish an RQ for radionuclides. Although the term ; 

radionuclides encompasses hundreds of radioactive isotopes and countless \ 

chemical compounds involving these isotopes, it i^ possible to set a single 

RQ in terms of dose-equivalent (rem) for the generic class of radionuclides ' 

and still take into account some of the unique characteristics of individual : 

radionuclides. It is also possible to set an RQ in terms of activity levels ; 

(curies) for groups of radionuclides based on a predetermined acceptable 

exposure level. The argument used for the generic classes of organic and

 : 

metallic compounds was, therefore, not applicable to radionuclides. 

1Radiation measurements can also be expressed in international units of 

becquerels or sieverts, however, these terms are less common in the United 

States. 
P.19 

2-3 

The Agency also considered establishing no RQ for radionuclides based on' 

the finding that existing reporting mechanisms for radionuclide releases were 

adequate and that any additional reporting pursuant to CERCLA would provide ho 

additional benefit. Under this approach, even without an RQ and therefore 

without a requirement to report releases of radionuclides under CERCLA, i 

radionuclides would remain listed as a hazardous substance and would be 

subject to CERCLA response and liability provisions. Elimination of an RQ for 

radionuclides would rely on existing reporting requirements of other 

agencies.2 This approach would minimize duplication of and conflicts with 

other federal and state reporting requirements. 

The Agency determined, however, that this option would not be sufficiently 

protective of public health and welfare and the environment. Less than one 

third of facilities that handle or produce radionuclides are licensed by the ' 

Nuclear Regulatory Commission, an agreement state, or the Department of ' 

Energy. NARM are only licensed by the Nuclear Regulatory Commission if they , 

are used by a licensee in conjunction with source, byproduct, or special ' 

nuclear material. Facilities using only NARM, therefore, are not subject to 

federal control and licensing. Releases from these facilities could go | 

unreported if no RQ were to be established. The Agency concluded, therefore,1 

that it would not be fulfilling its mandate under CERCLA if no RQ was 

established for radionuclides. i 

i 

2.3 OPTION 3: ESTABLISHING A DOSE-EQUIVALENT LEVEL AS THE 

RADIONUCLIDE RQ 

A dose-equivalent level is a direct measurement of the amount of 

biological damage resulting from exposure to ionizing radiation. Doseequivalent is generally measured in terms of rem or sieverts and is equal to ' 

the product of the absorbed dose, in units of rads or grays, and a quality 

factor (Q) assigned to the type of radiation being emitted.3 

2See Appendix B of this report for further detail on existing reporting 

requirements. 

3The gray is a unit of absorbed dose. One gray is equal to an absorbed 

dose of 1 joule/kilogram or 100 rads. The rad is a unit of absorbed dose. 

One rad is equal to an absorbed dose of 100 ergs/gram or 0.01 joule/kilogram.; 

The sievert is a unit of dose-equivalent. One sievert is equal to a doseequivalent of 1 joule/kilogram or 100 rem. Originally "Roentgen Equivalent 

Man," the rem is a unit of dose-equivalent. The dose-equivalent in rem is 

numerically equal to the absorbed dose in rads multiplied by the quality 

factor (Q). Q is equal to 1 for X-rays, gamma rays, and beta particles; Q is; 

equal to 10 for fast neutrons from fission, for example, and for protons; and 

Q is equal to 20 for alpha particles and fission fragments. 
2-4 

P.20 

Dose-equivalent, unlike activity, is not a measure of the emitted 

radiation, but is a method of normalizing the effectiveness of an absorbed ; 

dose of radiation in damaging tissue, regardless of the type of radiation. It 

must also be understood that activity is a physical phenomenon, whereas dose-; 

equivalent is a description of the biological effectiveness of a given 

exposure circumstance. Nevertheless, using standard assumptions regarding 

such factors as route and duration of exposure, quantity of intake, and 

determination of the tissues most affected, a dose-equivalent level may be 

related directly to a level of activity for particular radionuclides. 

The Agency considered establishing an RQ for radionuclides in terms of 

dose-equivalent (rem) because rem is an acceptable unit of measurement for 

radionuclide releases and, in fact, most existing reporting requirements are 

in units of rem. In addition, different exposure scenarios (e.g., different 

radionuclide forms, routes of exposure, and age and locations of receptors) 

will yield a different number of rem. Therefore, an RQ in terms of a rem 

level that is deemed to be acceptable could be independent of the exposure 

scenario -- it would apply to any release which, under existing circumstances 

(whatever they may be), could result in the specified number of rem. 

There are several important disadvantages to this option, however. First, 

dose-equivalent limits typically specify acceptable exposures for certain 

situations, such as a period of exposure and a particular target organ. A 

radionuclide RQ in units of dose-equivalent, therefore, would have to specify 

the sensitive organs of concern. This would represent a complicated reporting 

trigger. 

Second, the Agency determined that an RQ in terms of dose-equivalent (rem) 

would leave a significant amount of judgment to the person in charge of the 

facility or vessel. This person would have been required to estimate or judge 

the quantity released, the potential routes of exposure, the period of 

exposure, and the most vulnerable organ of the body potentially affected by 

the release. In essence, if the RQ were to be established in units of rem, 

the person in charge of the vessel or facility would be placed in a position 

of determining whether the release posed a threat to public health or welfare; 

or the environment. CERCLA establishes that role for the federal government, 

not for the person in charge of the vessel or facility. i 

In addition, the calculation (or estimation) of dose-equivalent is not 

straightforward. It could preclude a timely report and, therefore, a timely ; 

response should one be deemed appropriate. Finally, because of all the | 

judgments and assumptions required to estimate dose-equivalent, the estimated) 

dose-equivalent for two different releases with the same level of activity of 

the same radionuclide may vary drastically under different assumptions. This 

potential variability, even with a standardized calculation methodology, makes 

it difficult to (1) assure that the government will be notified of all 

radionuclide releases that it deems necessary; and (2) enforce an RQ in doseequivalent units. 
P.21 

2-5 

2.4 OPTION 4: CONSIDERING RADIONUCLIDES AS A CLASS WITH A SINGLE 

ACTIVITY LEVEL 

Because activity levels are easy to measure quickly during a release event 

through the use of available survey instruments, the Agency considered i 

establishing an RQ for radionuclides, as a generic class, in units of curies;. 

A level of activity, in units of curies (or becquerels), is a measure of the; 

rate of radioactive decay and thus the amount of radiation given off by a 

substance. However, an RQ in units of curies applicable to all radionuclides 

does not account for varying degrees of hazard posed by different 

radionuclides. Exhibit 2-1 shows the range of different dose-equivalent 

levels (reflecting relative levels of damage to the body) which may result 

from the inhalation of one microcurie of different radionuclides. 

While simplicity in reporting must be sought, the Agency does not believe 

that it should be accomplished by ignoring substantial differences among \ 

individual radionuclides. It would be extremely difficult to derive an RQ in 

terms of a single level of activity that would provide timely reporting of the 

most hazardous radionuclides while not being overly protective for others. 

2.5 OPTION 5: GROUPING RADIONUCLIDES INTO CATEGORIES WITH AN : 

ACTIVITY LEVEL ASSIGNED TO EACH OF THE SEPARATE CATEGORIES 

Radionuclides may be segregated into various groups in such a way that a1 

single level of activity may be an appropriate RQ for all the radionuclides \ 

within a given group. One RQ, which would assure timely reporting for < 

releases of the most hazardous radionuclides, could be assigned to each 

group. For example, the Agency considered grouping radionuclides into ; 

"half-life categories" with progressively higher RQs for those categories 

having shorter half lives. Another option considered was to separate 

radionuclides into groups of alpha, beta, and gamma emitters with 

progressively higher RQs for each of these categories. The RQs for 

non-radioactive substances have been established in this fashion, with 

different RQs for different groups of chemicals having similar chemical and 

toxicological properties. 

The Agency chose not to adopt the two methods of categorizing 

radionuclides mentioned above. The Agency believes that radionuclides grouped 

into half-life categories with progressively higher RQs for those categories 

having shorter half lives may not be protective of public health and the 

environment because radionuclides with relatively short half lives (e.g., ten 

days) could emit high energy radiation at a high rate for which the federal ' 

government may wish to receive notification to determine whether a response : 

action is necessary. With regard to categorizing radionuclides on the basis 

of whether they are primarily alpha, beta, or gamma emitters, the actual

 ; 

threat to public health and welfare and the environment is often less 

dependent on the type of emission than on the energy of the radiation (i.e., a 

high energy beta particle might be more harmful than a low energy alpha ! 

particle). [ 

\ 
1 

1 

1 

I 

I 

I 

I 

I 

1 

I 

I 

I 

I 

I 

I 

1 

1 

1 

2-6 

EXHIBIT 2-1 

DOSE-EQUIVALENTS RESULTING FROM THE INHALATION OF 

ONE MICROCURIE OF DIFFERENT RADIONUCLIDES 

Radionuclide 

Dose-Equivalent to adult 

lungs if one microcurie 

is inhaled (rem) a/ 

Tritium (H ) 

Technetium-99 

Uranium-238 

Radium-226 

Plutonium-238 

.0001 

.05 

49 

56 

64 

P.22 

a/ The number of rem to the lungs resulting from the intake of a 

radionuclide depends on, among other factors, the particle size and solubility 

of the radionuclide involved. To facilitate comparison of the hazard levels ' 

associated with each of the above radionuclides, the dose-equivalent levels 

are based on each radionuclide (except for tritium) having the same solubility 

(a "W" compound) and particle size (an activity median aerodynamic diameter of 

1 ym). : 

Source: Dunning, et.al., Estimates of Internal Dose-Equivalents to 22 Target 

Organs for Radionuclides Occurring in Routine Releases From Nuclear Fuel-Cycle 

Facilities, Vol. Ill, NUREG-0150, 1981. 

\ 
P.23 

2-7 

The Agency did not select this option because it could not determine 

appropriate groups or categories for radionuclides prior to examining each 

individual radionuclide and estimating the effect of a release of each. 

2.6 OPTION 6: ESTABLISHING AN ACTIVITY LEVEL RQ FOR INDIVIDUAL 

RADIONUCLIDES 

The Agency ultimately decided to propose RQ adjustments for individual 

radionuclides based on levels of activity. There are several advantages to [ 

basing radionuclide RQs on activity levels. For example, a level of 

radioactivity is much easier to estimate than a dose-equivalent. Survey 

instruments are readily available and widely used to measure directly the [ 

ionizing radiation. The Agency believes that setting RQs in terms of activity 

would, therefore, provide more timely reporting than an RQ expressed in terms 

of dose-equivalent. ! 

A second advantage of using activity levels is that establishing RQs for' 

radionuclides individually would allow consideration of individual 

radionuclide characteristics including the type and strength of ionizing > 

radiation produced during a release. An RQ in terms of dose-equivalent (rem) 

would also (by definition) have considered type and strength of ionizing ; 

radiation, but would have left much greater judgment to the person in charge: 

of the vessel or facility. Activity-level RQs (curies) also consider each ; 

radionuclide individually, but minimize judgments by the person in charge of, 

the vessel or facility. The option to establish RQs in terms of curies, 

therefore, was considered advantageous. ! 

The Agency recognizes that the nuclide-specific RQ approach also has 

disadvantages. Primarily, unlike a dose-equivalent value, a level of activity 

by itself does not necessarily reflect a level of danger to human health. As 

is presently the case for RQs for non-radioactive substances, a case-by-case; 

evaluation by the On-Scene Coordinator will be necessary to estimate the human 

health and welfare and environmental hazards associated with a radionuclide 

release, and to determine if a federal response is warranted. 

EPA began its development of the individual RQs by first identifying the[ 

universe of radionuclides to be analyzed individually and the universe of 

radionuclides to be covered by the proposed regulation. Chapter 3 of this 

report discusses how the Agency identified these universes. 
P.24 

prepared infrequently or a few atoms at a time to determine properties or 

confirm the predicted mode of decay. Other radionuclides included in the 75;7 

have extremely short half lives, like chlorine-34 (half life of 1.6 seconds)!, 

that fully self-decontaminate within 24 hours. Therefore, the Agency 

considered reducing the number of radionuclides with proposed RQs. 

The Agency considered two general categories of radionuclides for 

elimination from CERCLA notification requirements: radionuclides that are so 

rare that it is extremely unlikely they would be released in quantities of an 

RQ or more, and radionuclides that are very short lived. Each of these 

categories is discussed below. 

3.1 RARE RADIONUCLIDES 

The Agency considered the following types of radionuclides to be so rare! 

that the likelihood of a release of one of these radionuclides, at levels ofi 

an RQ or more is extremely low. ' 

• Radionuclides that are naturally occurring, but found ' 

in extremely low abundance; 

• Radionuclides that are produced through fission or 

activation, but with low probability production schemes; | 

and 

I 

• Radionuclides that are expected to occur only in 

limited quantities as a result of experimental studies. ! 

i 

A brief explanation of the types of radionuclides the Agency expected to| 

fall within each of these groups follows below. , 

Some radionuclides are naturally occurring and are not normally produced 

through any artificial process. Because the natural element contains an [ 

extremely small percent of the radionuclide, isotopic separation for these 

radionuclides would be expensive and difficult and, therefore, unexpected. ! 

Further, they appear in nature in such low abundance that a release of one of 

these radionuclides at levels of an RQ or more is extremely unlikely. 

Many radionuclides are produced in nuclear reactors through fission, 

although some radionuclides have a very low probability of being produced. 

Fission involves the splitting of an atom (usually uranium or plutonium) into 

two parts, with a concommitant release of energy. Each of these two parts is 

an isotope of a specific element with a well-defined number of protons and 

neutrons in its nucleus. About 97 percent of the isotopes formed through the 

fission process fall into two groups: (1) a "light" group whose mass numbers., 

the sum of neutrons and protons in the nucleus, lie between 85 and 104, and 
P.25 

i-3 

(2) a "heavy" group whose mass numbers lie between 130 and 149.3 

Radionuclides produced through the fission process that are not in the light 

or heavy group might be considered to be sufficiently rare that a release at ; 

levels of an RQ or more is extremely unlikely. ! 

Similarly, many radionuclides are produced only in nuclear reactors by 

processes known as neutron or charged-particle activation. The process ' 

involves the absorption of one or more particles by the target nucleus, ; 

producing either an isotope of the original element or a new element. After 

the first absorption, the probability that additional neutrons will be 

absorbed and new isotopes formed decreases. Charged particle reactions occur, 

only rarely in nuclear reactors. 

Other rare radionuclides are expected to occur only in small quantities in 

special laboratory studies. These are mostly transuranics, members of the 

neptunium chain, or isotopes of members of the uranium, thorium, and actiniumi 

chains. Many of these elements are produced only a few atoms at a time for 

purposes of investigating their decay pathways or for other laboratory or 

research purposes. 

The Agency decided to propose RQs for these rare radionuclides because 

rarity is not a relevant consideration in RQ adjustments. Just because a 

release of a particular radionuclide is expected to be rare, it does not mean 

the isotope should have no proposed RQ. If a release does occur at levels 

equalling or exceeding an RQ, the National Response Center should be notified^ 

so that it can assess the necessity for a federal response. Establishing RQs 

for rare radionuclides will not be a burden to the regulated community or to 

the government because releases at levels of an RQ or more are expected to 

occur very infrequently. Therefore, the reporting burden to the regulated 

community and the report processing/response burden to the federal government 

should be minimal. ' 

3.2 SHORT-LIVED RADIONUCLIDES 

Of the 757 radionuclides for which ALIs have been developed, 224 have 

half lives of less than or equal to 0.1 day. These isotopes virtually decay 

fully within a twenty-four hour period. Because these short- lived 

radionuclides virtually self-decontaminate within 24 hours, the Agency

 ] 

considered establishing no proposed RQ for these radionuclides because a 

federal cleanup response would not be necessary and the potential hazard is sd 

short-lived that for the most part, a timely federal response would be 

unlikely. 

However, the Agency decided to establish proposed RQs for these very 

short-lived radionuclides because 24 hours is a relatively long period of time 

from a federal response perspective. Short-lived radionuclides give off 

3Kaplan, I., Nuclear Physics, Addison-Wesley Publishing Company, 

Reading, Massachusetts, 1958, p.496. 
P.26 

high-energy radiation, albeit for a short period of time. Without the 

requirement to report such releases, response activities such as evacuations 

may be foreclosed. 

To be most protective, therefore, the Agency is proposing RQs for all 

radionuclides, including rare and short-lived radionuclides. Chapter 4 of 

this report describes the methodology used to calculate the proposed RQs for 

the 757 individually analyzed radionuclides. 
CHAPTER 4 

METHODOLOGY FOR PROPOSED RQ ADJUSTMENTS 

P.27 

EPA is proposing to adjust the statutory one-pound RQ for all 

radionuclides and has analyzed individually the 757 radionuclides listed in 

ICRP's Publication 30.

 l This chapter discusses several methods considered '< 

by the Agency for calculating the proposed RQs. Section 4.1 describes ' 

alternative methods considered for relating radiation damage to releases of 

radionuclides in units of curies; Section 4.2 describes the selected RQ 

adjustment methodology, which considers exposure to radionuclide releases 

through inhalation, ingestion, and direct exposure pathways; Section 4.3 ' 

describes the assignment of radionuclides to proposed RQ groups; and Section 

4.4 discusses proposed reporting requirements for mixtures of radionuclides. , 

4.1 METHODS CONSIDERED FOR RELATING RADIATION DAMAGE TO 

RELEASES IN UNITS OF CURIES 

The Agency considered three methods for relating radiation damage to ; 

releases of radionuclides in units of curies: Maximum Permissible 

Concentrations (MPCs), Limiting Possession Limits (LPLs), and Annual Limits of 

Intake (ALIs). 

Maximum Permissible Concentrations were originally developed in 1959 by 

the International Commission on Radiation Protection (ICRP) and are currently. 

used by the Nuclear Regulatory Commission in 10 CFR Part 20 to limit exposures 

for nuclear facility workers and members of the general public. Two sets of 

MPCs are used, one for restricted areas and the other for unrestricted areas. 

The restricted area MPCs represent the maximum permissible concentrations of a 

radionuclide in air and water to which a worker is allowed to be exposed. The 

unrestricted area MPCs represent the maximum concentrations of radionuclides 

that are acceptable for release into unrestricted areas. A method for 

calculating RQs based on MPCs is shown in Appendix C of this report. 

Another mechanism used by the Nuclear Regulatory Commission for assuring 

safe operations at some of its licensed facilities is the LPL. This value 

represents the maximum quantity of a given radionuclide that a licensee may 

possess without being required by the Commission to have a Radiological 

Contingency Plan -- a formalized plan for responding to releases and 

emergencies involving radioactive material. A method for developing RQs using 

these LPLs can also be found in Appendix C. 

1International Commission on Radiation Protection, Annals of the ICRP: 

Limits for Intakes of Radionuclides by Workers, ICRP Publication 30, Part 2, 

1980. 
P.28 

4-2 

ICRP has developed a third measure designed to protect nuclear facility 

workers from radionuclide exposure hazards: ALIs. The ALIs are the annual 

intakes of given radionuclides by "Reference Man"2 which would result in 

either (1) a committed effective dose-equivalent3 of 5 rem to the whole body 

(stochastic ALI), or (2) a committed dose-equivalent1* of 50 rem to any organ 

or tissue (non-stochastic ALI). In the proposed revision of 10 CFR Part 20, 

the Nuclear Regulatory Commission proposes the adoption of ALIs instead of 

MPCs because: "the revision improves radiation protection standards by 

reflecting developments in the principles that underlie radiation protection 

and advances in related sciences that have occurred since the promulgation o 

10 CFR Part 20 nearly thirty years ago" (50 FR 1092, January 9, 1986). In 

short, the proposed ALIs are health risk-based standards; they are designed to 

limit an "effective" whole body dose and, thus, the estimated risk of health 

damage. Use of this effective whole body risk concept is a major departure 

from the MPCs in the present Part 20 which are based on the concept of 

protecting a single, "critical" organ (50 FR 1093, January 9, 1986). 

EPA has decided to use the ALIs developed by the ICRP for the calculation 

of the proposed RQs because the ALIs represent the most recent scientific 

advances and because these ALIs have been calculated for both oral ingestion 

and inhalation. Proposed RQs, therefore, can be derived based on transport 

through different environmental media. 

The Agency developed Release Values for specific radionuclides based on 

three different routes of exposure: inhalation, ingestion, and direct 

exposure. The most sensitive route of exposure varies with each radionuclide 

depending upon the effect the radionuclide has on sensitive organs, as well as 

the different chemical and physical forms (e.g., solubility) of a ! 

radionuclide. For each radionuclide to which an individual RQ has been 

assigned, the Agency based its proposed RQ on the most sensitive exposure ! 

route for that particular radionuclide. The following section of this report 

discusses the methodology used by the Agency to calculate the radionuclide 

Release Values based on exposure through inhalation, ingestion, and direct ! 

exposure. 

4.2 METHOD FOR DETERMINING RQs BASED ON INHALATION, INGESTION,! 

AND DIRECT EXPOSURE 

Radionuclides are considered dangerous because of the potential for 

delivering ionizing radiation to organisms. This ionizing radiation 

2Reference man is a hypothetical individual possessing "average" 

characteristics of humans (such as body weight, dietary intake, and inhalation 

rate) to serve as a common biological basis for calculating MPC and ALI values. 

3The total whole body dose-equivalent resulting from intakes of 

radionuclides in one year. 

""The total dose-equivalent averaged throughout a tissue in the 50 years 

after intake of a radionuclide into the body. 
EXHIBIT 4-1 

SCHEMATIC OF ASSUMPTIONS USED IN INHALATION SCENARIO 

Wind Spood (u): 1 m/aoc 

Qround lovol 

\ 

30m 
P.30 

H - / 

as exemplified by the Chernobyl incident in Russia. In the case of drinking' 

water, radionuclides may be ingested from contaminated surface waters, such as 

rivers and lakes, or from contaminated ground water (i.e., a contaminated 

well). Because ingestion of radionuclides via food crops, surface water, and 

ground water are considered equally likely sources of exposure, the Agency 

examined models for each of these ingestion pathways to determine which is, in 

general, the most critical exposure pathway. Based on this review, the Agency 

has chosen to model the ingestion pathway based on the consumption of 

contaminated ground water from a drinking water well. The models for the food 

crop and surface-water ingestion pathways, and the Agency's rationale for 

excluding them as a basis for determining Release Values, are described 

briefly in the following paragraphs and in greater detail in Appendix F. 

In general, there are three types of food which can result in human 

ingestion of radionuclides: vegetables, milk, and meat. Of these three, j 

contaminated vegetables (i.e., food crops) are expected to be the most 

dangerous to humans because radionuclides deposited on vegetables are ingeste'd 

directly. For milk and meat, humans are expected to consume smaller 

quantities of radioactive material because only a fraction of the i 

radionuclides ingested by cows are transferred to milk and meat. The Agency 

believes, therefore, that considering only the consumption of contaminated 

food crops provides a good approximation of the total radioactivity ingested , 

by humans through food intake. 

To determine the concentration in and on food crops resulting from the 

deposition of radionuclides after an airborne release, the Agency considered 

models developed by the Nuclear Regulatory Commission11 and the National 

Council on Radiation Protection and Measurements (NCRP).12 Both models were . 

similar and each accounted for radionuclide deposition from the air, \ 

weathering and radioactive decay, radionuclide buildup in the soil, and uptake 

from the soil. After comparing the two models, the Agency concluded that the1 

NCRP model was too conservative in its treatment of radionuclide deposition; 

therefore, the Agency derived invgestion Release Values using the Commission '• 

model. The Agency then compared these ingestion Release Values (derived for 

the ingestion of contaminated food crops) to Release Values derived for 

ingestion of contaminated ground water, and found that ingestion of 

contaminated ground water was the more critical exposure pathway for a large 

majority of radionuclides. In addition, the Agency found that in the vast 

majority of cases where the ingestion of contaminated food crops was the more; 

critical of the ingestion pathways, either the inhalation or direct exposure 

X1U.S. Nuclear Regulatory Commission, "Calculation of Annual Doses to 

Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating 

Compliance with 10 CFR Part 50, Appendix I," Regulatory Guide 1.109, 1977. 

12National Council on Radiation Protection and Measurements, "Screening 

for Determining Compliance with Environmental Standards: Releases of 

Radionuclides to the Atmosphere," NCRP Commentary No. 3, 1986. 
P.31 

scenarios were even more critical resulting in even lower Release Values. 

Therefore, the Agency chose to base the ingestion scenario on the intake of 

contaminated drinking water. 

As stated above, drinking water is obtained from either surface waters 

(i.e., rivers and lakes) or from ground water (i.e., underground wells). To; 

compare directly the ingestion pathways of surface waters and ground waters,

 : 

the Agency examined the surface-water transport model used in the RCRA Risk 

Cost Analysis Model13 (see Appendix F). In comparison, contaminant 

transport in rivers happens on a much faster scale due to the greater 

velocities of rivers compared to aquifers. The higher velocity of a river ; 

will reduce the contact time between the contaminated plume and the source of 

drinking water to such a small period that for only very large releases could 

a significant amount of the release be pumped from the river and consumed in 

drinking water. In addition, the larger flow volume of most rivers compared ' 

to aquifers will result in a much greater dilution of the release. A similar^ 

situation exists for lakes. The plume volume calculated for the ground-water 

model used in the analysis of Release Values is about 13,300 cubic meters 

which corresponds to a pond about 50 meters long, 50 meters wide, and 5 meters 

deep. Typically, lakes used for drinking water supplies are very much larger 

and would result in a much larger dilution of released radionuclides. 

Therefore, the ingestion of radionuclides based on consumption of contaminated 

ground water will, based on the scenarios examined (see Appendix F) , be a more 

critical exposure pathway than an ingestion scenario based on the consumption! 

of contaminated surface water. Hence, to be most protective, the Agency has 

chosen to model the ingestion of radionuclides based on the consumption of 

contaminated well water. 

The ingestion Release Value is directly proportional to the ingestion ALI 

and inversely proportional to the dilution factor, contact time, and water 

consumption of "Reference Man." The method which the Agency has adopted for : 

the calculation of Release Values based on consumption of contaminated ground! 

water is summarized in equation (3) below: 

(3) Ingestion Release Value = ALI/((10)*(DF)*(CT)*(WC)*(1 x IO6)) ; 

where: 

ALI = Annual Limits of Intake for ingestion (microcuries); 

DF = Dilution Factor (liter" ); 

CT = Contact Time (days); 

WC = Water Consumption of "Reference Man" (2 liters/day); and 

1x10 = conversion factor between microcuries and curies. 

1 3U.S. Environmental Protection Agency, Office of Solid Waste, "The RCRA 

Risk-Cost Analysis Model Phase III Report," prepared by ICF Inc., 1984. 
h-9 

P.32 

The ingestion ALIs used in the calculations are taken from ICRP's 

Publication 30.1U Where more than one ingestion ALI was available for a 

particular radionuclide, the lowest ALI was used for the calculations. The 

factor 10 converts the 5 rem annual occupational dose limit to the 500 

millirem (0.5 rem) annual limit for members of the general public, as 

discussed for the inhalation pathway. 

The dilution factor (DF) is derived by considering the maximum 

concentration in a contaminant plume 30 meters downgradient from a point 

source release, as calculated by use of standard equations modeling ' 

ground-water transport (this ground-water exposure scenario is illustrated ih 

Exhibit 4-2). The maximum concentration is assumed to be uniformly i 

distributed throughout the plume.15 Thirty meters is chosen for consistency 

with the atmospheric model and leads to higher concentrations and lower \ 

Release Values than would be the case for a greater distance. ' 

The Agency considered two dilution models during the RQ development ' 

process: a simple dilution model and an advection-dispersion model. The 

simple dilution model relies on the estimate that the practical need for water 

of a single person living in a rural area is 7,700 cubic meters per year.16 ' 

This represents a dilution factor of 1.3 x 10 per liter. The model assumes 

the flow rate of the aquifer is sufficiently slow that the contact time is an 

entire year (365 days) and the entire quantity released is pumped from the 

well over a period of one year. ' 

Use of the advection-dispersion model for determination of radionuclide 

concentration in drinking water relies on estimates of longitudinal and j 

transverse coefficients of dispersion, bulk density of the aquifer, sorption, 

coefficients for individual radionuclides, and aquifer flow rate. The Agency 

luInternational Commission on Radiation Protection, Annals of the ICRP: , 

Limits for Intakes of Radionuclides by Workers, ICRP Publication 30, Part 2, 

1980. 

15This is a conservative approximation because concentrations are 

usually distributed in a Gaussian fashion within a plume, with smaller 

concentrations toward the edges of the plume and higher concentrations near , 

the plume's center line. 

16The Nuclear Regulatory Commission uses the simple dilution model for 

the purposes of determining allowable onsite disposal concentrations for ' 

radioactive waste. Oztunali, 0.1., Roles, G.W., De Minimis Waste Impacts 

Analysis Methodology, NUREG/CR-3585, February 1984. While water supplies in 

suburban or urban areas may be from ground water, the ground water is likely, 

to be pumped through several high-capacity wells and then distributed through 

several interconnecting pipes to individual homes. This type of system will 

result in much greater dilution than a simple rural system where water is 

obtained from a backyard well and taken directly to a tap. 
P.33 

Exhibit 4-2 

Scenario for Calculation of Ground-Water Transport 

SIDE VIEW 

1m 

s 

Well 

'""'* ' ,,,,,,.,,.,,,. . 

Oirectlon of Qround-watar Flow 

XMMMII * 

•''''' ' 

)lli)MMM)H)| l 

Point of release 

30m 

Olfaction of 

Qround-watar Flow 

/ 

Plume at time 

y greater than zero 

Point / 

of release-^ 

( 

Wen 
P.34 

4-11 

believes that, for the purpose of developing RQs, the advection-dispersion 

model is more appropriate than the simple dilution model. The simple dilution 

model assumes that all of the release will be pumped from the well and all of 

the polluted water will be consumed by an individual. Although the simple 

dilution model appears appropriate for determining concentration levels for , 

purposes of risk assessment, the advection-dispersion model is based on the 

somewhat less conservative but more likely assumption that only a fraction of 

the release will be pumped from the well and consumed by an individual. The : 

Agency, therefore, based its ingestion exposure calculations on the 

advection-dispersion model. 

The Agency also considered use of several ground-water models used by 

EPA's Office of Solid Waste to support analyses under the Resource 

Conservation and Recovery Act (RCRA). The equations used in the RCRA models 

are similar to the equations used in the advection-dispersion model; however,, 

because the RCRA analyses are risk based, some parameters used in the ' 

equations in the RCRA models are much more conservative than those used for ; 

purposes of RQ adjustment in the advection-dispersion model. Further 

discussion of the advection-dispersion model, the simple dilution model, and ' 

the four RCRA models can be found in Appendix F of this report. [ 

i 

The ground-water advection-dispersion modeling equations utilize a 

retardation factor for estimating the amount of a release that could be pumped 

from an affected well located 30 meters from the source. Retardation factors 

for each radionuclide differ because different radionuclides are adsorbed ! 

differently onto the sand or soil in an aquifer. Because of their chemical 

nature, some radionuclides are adsorbed only weakly or not at all (e.g., 

technetium), while others are adsorbed strongly (e.g., cesium). A table of 

sorption coefficients can be found in Appendix F. The retardation factor used 

in the model takes into account the soil bulk density, porosity, and the 

sorption coefficient, K,. When the sorption coefficient is equal to zero, 

the retardation factor, R ,, is equal to one; that is, there is no 

retardation. When the sorption coefficient is greater than zero, the 

retardation factor is greater than one and nuclide retardation has occurred. 

The dilution factor is related directly to the sorption coefficient. The 

greater the sorption coefficient, the greater is the nuclide retardation in 

the aquifer, and the greater is the dilution factor. 

The retardation factor also affects the estimation of the contact time, 

the total time a contaminant plume will be in contact with an affected well. 

If the retardation factor is equal to one, the advection-dispersion model ! 

assumes that the contamination is moving at the same velocity as the water in 

the aquifer (i.e., no retardation occurs), and the well is in contact with the 

contamination for nine days. If the retardation factor is greater than one, 

the advection-dispersion model assumes that the contamination is being i 

retarded and is moving at a slower rate than the water in the aquifer. The 

contact time, therefore, will be longer than nine days. Appendix F describes 

further the relationship between the sorption coefficients and retardation 

factors, and their affects on the dilution factors and contact times for 

different radionuclides. 
P.35 

In calculating the ingestion Release Values, when the sorption coefficient 

is greater than or equal to 4 for a particular radionuclide, the contact time 

is assumed to be 365 days. In reality, it could take significantly longer 

than 365 days for the contaminant plume to pass the well head, but because 

ALIs reflect annual intake levels, the contact time in the advection-dispersion 

model is constrained not to exceed 365 days. The dilution factor, however, 

will also reflect the sorption coefficient; the dilution factor is very large 

when the sorption coefficient is significantly above 4. > 

Finally, the daily water consumption of "Reference Man" is assumed to be'•2 

liters.17 The Release Values calculated for the ingestion pathway are 

presented at the end of this chapter in Exhibit 4-5. 

4.2.3 Release Values for the Direct Exposure Pathway 

The methodology for determining Release Values for direct exposure to '< 

radiation depends on the form of the radionuclide released. For noble gas 

isotopes, the Release Values are based on exposure due to total body ; 

submersion in a radioactive gas cloud. For all other radionuclides, Release 

Values are based on the quantity of radioactivity received by an individual 

exposed to a point source of radiation. The calculation of Release Values for 

point source and noble gas releases are discussed further below; the values 

are presented at the end of this chapter in Exhibit 4-5. , 

Direct Exposure From a Point Source 

As with the inhalation and ingestion scenarios, direct exposure Release ' 

Values are based on a 500 millirem exposure limit. The release is assumed to 

occur in the center of a hemisphere with a 30 meter radius, and an exposed 

individual is assumed to be tangent to this hemisphere (see Exhibit 4-3). The 

method used by the Agency for calculating direct exposure Release Values from 

a fixed point source is adapted from from the Health Physics and Radiological 

Health Handbook

 18 and includes gamma ray attenuation in air between the 

source and the receptor. It reflects the effects of gamma radiation and can i 

be simplified, as shown in Appendix G, to yield the following equation: 

(5) Direct Exposure Release Value = 

where: 

(6.41xl0"5)'KDn)*(S2)/((E1)^(u )*(T)*(exp(-u S))) 

± a a. 

Dn = Dose equivalent in rem; 

S = Distance from the release (30 m) ; 

17This intake rate is generally used as the average water consumption 

level for man. For example, 2 liters/day was used by EPA in developing the 

National Interim Primary Drinking Water Regulations. 

18Nucleon Lectern Associates, The Health Physics and Radiological 

Health Handbook, 1984, p. 41. 
EXHIBIT 4-3 

SCHEMATIC OF ASSUMPTION USED IN DERMAL EXPOSURE PATHWAY 

Ground Laval 

Polnl ol Release 

T l 

CO 
P.37 

•14 

E = The sum of the products of the gamma ray energies (MeV) and , 

the gamma ray fractions; i 

u = Linear energy absorption coefficient for gamma rays in air , 

3. 

(cm ); and 

T = Duration of exposure (24 hours). 

exp(-u S) = Attenuation factor 

The direct exposure Release Value represents the quantity of radionuclide, 

in curies, necessary to provide a gamma ray exposure of 500 milliroentgen (the 

same as a dose-equivalent of 500 millirem), over a 24-hour exposure period, to 

an individual 30 meters (S) from a point source release of radioactive 

material.19 Gamma rays alone are considered in this equation because the 

mean range of alpha and beta particles with energies lower than 10 MeV is less 

than 30 meters.20 

The Agency is aware that other approaches can be taken to calculate direct 

exposure Release Values. In particular, it has been suggested that specific' 

gamma ray constants be applied to this calculation. The specific gamma ray 

constant is defined as the product of the exposure rate at a given distance , 

from a point source and the square of that distance divided by the activity of 

the source, neglecting attenuation. Tables are available that list the 

specific gamma ray constant for a limited number (approximately 90) of the 757 

radionuclides for which specific RQs are proposed. Because these values were 

not readily available for all of the radionuclides of interest, the Agency has 

chosen to use Equation (5) to calculate direct exposure Release Values. 

The direct exposure Release Value was calculated using Equation (5) for 

every radionuclide of interest that emits a gamma ray. For many of these 

radionuclides, gamma rays are not emitted every time that the nuclide decays 

(i.e., disintegrates). In addition, a gamma ray that is emitted from a given 

19A rad (radiation absorbed dose) is a measure of the amount of energy 

absorbed in a gram of tissue, whereas a rem is a measure that accounts for the 

biological response of that absorbed dose. Multiplying rads times a "quality 

factor" yields rems and, for gamma rays, the quality factor equals one. 

2 0A 10 MeV alpha or beta particle would be an extremely energetic particle. The mean range of a 10 MeV alpha particle in air is less than 15 • 

centimeters. Beta particles typically range in energy between 0.04 and 6 MeV, 

although there are a few radionuclides which emit beta particles with higher; 

energies (e.g., the maximum beta particle energy for carbon-15 and bromine-87 

is about 10 and 8 MeV, respectively). The mean range of a 6 MeV beta particle 

in air is only about 20 meters and these high energy beta particles are very' 

rare. Therefore, although there are one or two nuclides for which beta ; 

particles can conceivably travel approximately 30 meters in air, exposures at 

this distance are for the most part only a concern for gamma rays. 
P.38 

H- L~> 

radionuclide does not necessarily always have the same energy level. This 

phenomenon is illustrated in Exhibit 4-4. As shown in this exhibit, every 

time argon-41 disintegrates, it emits a gamma ray with an energy level of 1.3 

MeV. Krypton-85 emits a gamma ray for only a small fraction of its 

disintegrations (0.4 percent), while several different gammas with different 

energies are emitted by molybdenum-99. [ 

i 

To account for these various gamma ray energies and fractions when using 

Equation (5), the energy level (E ) for a given radionuclide was derived by 

taking the sum of the products of the gamma ray energies and the gamma ray , 

fractions. For example, the E value used for argon-41 was 1.3 MeV and the 

E value used for molybdenum-99 was 0.14. This approach considers all of 

the gamma rays for a given radionuclide and accounts for the fraction of time 

that such a gamma ray is actually emitted. 

The linear energy absorption coefficient for gamma rays in air (u ) 

3. 

varies with the gamma ray energy. When the gamma ray energy is 1 MeV, the [ 

linear energy absorption coefficient is 3.7 x 10 /cm.21 For gamma rays 

with energies between 0.07 MeV and 2 MeV, the absorption coefficient will vary 

from 3.7 x 10 by plus or minus 15 percent. Because the variation is so 

slight, for purposes of calculating the direct exposure Release Values, we ; 

have assumed the absorption coefficient is 3.7 x 10 /cm for all ' 

radionuclides of concern. 

The duration of exposure, T, is assumed to be 24 hours. This time period 

is selected because, without notification, it is possible for a person to be 

exposed to a radionuclide release for an extended period of time. However, it 

is unlikely that exposure will occur over more than a 24-hour period without a 

person moving outside of the radiation range. Assuming the duration of 

exposure is 24 hours is conservative, therefore, but allows for a maximum 

exposure time for a release. In order to account for attenuation of gamma 

rays in air between the source on the receptor, the exponential term 

exp(-u S) is used. Incorporation of a term for gamma ray attenuation 

a. 

results in a slight increase in the direct exposure Release Value because 

approximately 10 percent of the gamma rays emitted will be absorbed in the 30 

meters of air between the source and the receptor. 

The expression, shown in Equation (5), for determining the Release Value 

for the direct exposure pathway from a fixed point source can be simplified ;by 

substituting the following values into the equation: 

Dn = 0.5; 

S = 30; 

• u = 3.7x10" ; and a 

T = 24. 

21Nucleon Lectern Associates, The Health Physics and Radiological Health 

Handbook, 1984, p.41. 
P.39 

EXHIBIT 4-4 

GAMMA RAY ENERGIES, GAMMA RAY 

FRACTIONS, AND ENERGY LEVELS FOR SELECTED RADIONUCLIDES 

Radionuclide 

Argon-41 

Krypton-85 

Molybdenum-99 

Gamma Ray 

Energy, E 

(MeV) 

1.3 

0.513 

0.041 

0.141 

0.181 

0.366 

0.740 

0.777 

0.822 

Source: National Council on 

Handbook of Radioact 

Gamma Ray 

Fraction 

(percent) 

100 

0.43 

1 

5 

6 

1 

12 

4 

0.1 

Gamma Ray 

Fraction 

Times E 

(MeV) 

1.3 

2.2xl0"3 

4.1xl0'4 

70.5xl0"4 

108.6xl0"4 

36.6xl0"4 

88.8xl0"3 

310.8xl0~4 

8.2xl0-4 

Radionuclide 

Energy Level, 

Ei : 

(MeV) j 

1.3 

2.2 x 10"3 

1 

| 0.14 

| ; 

| 

J 

Radiation Protection and Measurements, A 

ivity Measurement Procedures . NCRP Report No.; 

58. Washington, D.C. November 1978. 
P.40 

•17 

Equation (5) simplifies to: ! 

(6) Direct Exposure Release Value = 36.3/E.. 

Direct exposure Release Values calculated for the radionuclides that emit ; 

gamma rays are presented at the end of this chapter in Exhibit 4-5. 

Submersion in a Radioactive Cloud of Noble Gas 

Because the noble gases argon, krypton, and xenon are chemically very 

stable, they are not likely to form solid or liquid compounds which can be 

ingested. Also, because they are relatively insoluble in blood and are easily 

displaced by more common gases such as oxygen and nitrogen, noble gases are i 

not incorporated readily into the body after inhalation. As a result of this 

inertness, ingestion and inhalation are not significant exposure pathways and 

ALIs for ingestion and inhalation were not developed by the ICRP for most | 

noble gases. However, submersion in a radioactive cloud can cause a I 

significant whole body dose due to direct exposure. Therefore, direct 

exposure Release Values for argon, krypton, and xenon were derived assuming ' 

that an exposed individual is submerged in a cloud of the gas 30 meters from! 

the release point.22 

A different equation for the calculation of direct exposure Release Values 

is appropriate for radioactive noble gases because submersion in a cloud 

results in an integrated dose from all directions at varying distances from ! 

the body. The direct exposure Release Values for submersion in a radioactive 

cloud of a noble gas are derived through the following equation:23 

(7) Direct Exposure Release Value = ((83)*(DAC)*(T))/((10)*(X/Q)*(lxl06)|) 

where: '• 

DAC = Derived Airborne Concentration (microcuries/cm3); j 

T = Duration of Exposure (1 day) 

22Argon, krypton, and xenon are the only noble gases whose Release 

Values are calculated based on total submersion in a cloud. The noble gases 

helium and neon do not form isotopes with half lives longer than a few 

seconds. ALIs for these isotopes have not been developed and, therefore, no 

Release Values have been calculated. The noble gas radon has two isotopes 

(radon-220 and radon-222) with inhalation ALIs. Because these two isotopes , 

emit alpha particles, inhalation is a more critical exposure pathway than ' 

submersion in a radioactive cloud and the lowest of the proposed ALIs in each 

case was used to calculate inhalation Release Values for these radionuclides!. 

23This equation is derived from an equation found in the Annals of the 

ICRP, Publication No. 30, Part 1, Volume 2, No. 3/4, 1979, pp. 10 and 47. 
P.41 

4-18 

X/Q = Atmospheric Relative Concentration Value at 30 meters 

(8.4xl0_13 day/cm3); and 

1x10 = Conversion factor between microcuries and curies. 

The DAC value specifies the airborne concentration that would result in a 5 

rem whole body dose equivalent for a 2000 hour exposure period. To adjust the 

airborne concentration from a 2000 hour to a 24 hour exposure period, the DAC 

value in Equation (7) is multipled by 83 (i.e., 2000 hours * 24 hours). The 

factor of 10 in the denominator of Equation (7) converts the 5 rem whole bodylimit for occupational exposure to the 0.5 rem (500 millirem) limit for 

exposure to the general public. X/Q is the ground-level concentration value; 

30 meters from the release point (see Section 4.2.1 above and Appendix E for 

further discussion of X/Q). 

The expression, shown in Equation (7), for determining the Release Value; 

for the direct exposure pathway due to submersion in a cloud of radioactive '• 

noble gas can be simplified by multiplying the numbers in the denominator. 

Equation (7) simplifies to: 

(7) Direct Exposure Release Value = DAC/(lxl0 ) 

The direct exposure Release Values for argon, krypton, and xenon can be found 

at the end of this chapter in Exhibit 4-5. 

4.3 ASSIGNMENT OF RADIONUCLIDES TO PROPOSED RQ GROUPS \ 

Exhibit 4-5 at the end of this chapter displays the three Release Values; 

calculated for each radionuclide. The lowest Release Value for each 

radionuclide has an asterisk beside it. The lowest Release Values range in : 

value from over 10,000 curies to approximately 0.001 curie. For 

administrative feasibility and simplicity, the Agency decided to assign the ; 

radionuclides to one of seven distinct groups identified by specific proposed 

RQs. Each radionuclide is assigned a proposed RQ of 0.001 curie, 0.01 curiei 

0.1 curie, 1 curie, 10 curies, 100 curies, or 1000 curies. Assignment of a | 

proposed RQ to a particular radionuclide was made by examining the lowest j 

Release Value for each radionuclide and rounding that value down to the 

nearest proposed RQ group. ! 

The 757 radionuclides with proposed RQs are represented as follows: i 

• 6 radionuclides (0.8%) have lowest Release Values less 

than 0.01 curie and, therefore, have a proposed RQ of 

0.001 curie; ; 

• 25 radionuclides (3.3%) have lowest Release Values ; 

greater than or equal to 0.01 curie but less than 0.1 

curie and, therefore, have a proposed RQ of 0.01 curie; ; 
P.42 

4-19 

• 24 radionuclides (3.2%) have lowest Release Values 

greater than or equal to 0.1 curie but less than 1 curie 

and, therefore, have a proposed RQ of 0.1 curie; 

e 35 radionuclides (4.6%) have lowest Release Values 

greater than or equal to 1 curie but less than 10 curies 

and, therefore, have a proposed RQ of 1 curie; 

• 342 radionuclides (45.2%) have lowest Release Values 

greater than or equal to 10 curies but less than 100 

curies and, therefore have a proposed RQ of 10 curies; 

• 236 radionuclides (31.2%) have lowest Release Values 

greater than or equal to 100 curies but less than 1000 | 

curies and, therefore, have a proposed RQ of 100 curies; 

and 

• 89 radionuclides (11.7%) have lowest Release Values 

greater than or equal to 1000 curies and, therefore, ' 

have a proposed RQ of 1000 curies. 

To accommodate for unusual release events that are not foreseen currently 

by the Agency, an RQ of 1 curie is also assigned to all known radionuclides 

not listed in ICRP's Publication 30.24 The Agency believes that by 

establishing an RQ for the broad generic class "Radionuclides," it is ( 

fulfilling the CERCLA mandate to protect public health, welfare, and the 

environment. As seen above, the 1 curie RQ is the middle RQ level and the 

majority (93%) of the radionuclides with proposed RQs have minimum Release 

Values greater than or equal to 1 curie. Therefore, the generic RQ of 1 curie 

for all other radionuclides is a conservative value. 

Two or more radionuclides with the same proposed RQ do not reflect a 

determination that a release of one will be as hazardous as the release of 

another, or even that the release of one will be hazardous at the proposed RQ 

level and not hazardous below that level. The Agency has found that the 

actual hazard will vary with the unique circumstances of the release, and '< 

extensive scientific data and analysis would be necessary to determine the 

hazard presented by each substance under a number of possible circumstances. '< 

Instead, the RQs are designed to be a trigger for notification and reflect the 

Agency's judgment that the federal government should be notified of certain 

releases to which a federal response might be necessary. The reportable 

quantities represent a determination only of possible or potential harm, not 

that releases of a particular amount of a hazardous substance necessarily will 

be harmful to public health or welfare or the environment. 

2 * International Commission on Radiation Protection, Annals of the ICRP: 

Limits for Intakes of Radionuclides by Workers, ICRP Publication 30, Part 2, 

1980. 
P.43 

4-20 

The Agency is soliciting comments on the selected methodology and the 

proposed RQs for individual radionuclides that may be too low or too high. 

EPA would be interested in suggestions and data regarding what criteria the 

Agency should consider in adjusting technically or administratively a proposed 

RQ for an individual radionuclide. 

The Agency is aware that reporting requirements similar to those presented 

here have been developed previously. The Nuclear Regulatory Commission has 

established content limits (A and A„ values), presented in 10 CFR Part * 

71, Appendix A. The content limits are applicable to Type A packaging which 

is intended to provide safe and economical transportation packaging for a 

large number of smaller activity consignments. The content limits listed in 

10 CFR Part 71 are based on a dose-equivalent level of 5 rem and are based on ! 

exposure pathways similar to those developed for the proposed RQs. However, 

the content limits are based on different calculational assumptions and, more 

importantly, are designed to limit the exposure and health risks resulting 

from an accident occurring during the transportation of radionuclides. In a 

transportation accident situation, immediate response (i.e., fire and police 

departments) is expected and the general public will be removed from danger 

quickly. Contamination is, therefore, likely to be isolated in a short period 

of time and exposure of the public will be limited. In this situation, the 

individuals most likely to be affected by the contamination are those involved 

in the accident and in the resulting isolation and cleanup activities. On the 

other hand, the proposed RQs presented here are designed to protect the 

unsuspecting public who are not aware immediately of a release. The proposed i 

RQ values reflect more general release and exposure scenarios and are based on 

situations where response times are expected to be longer. While the content 

limits and proposed RQs are based on similar methodologies, and sometimes are 

equivalent values, the RQs proposed here are designed to protect the public 

health and welfare and the environment in a broader fashion. 

4.4 REPORTING REQUIREMENTS FOR MIXTURES OF RADIONUCLIDES 

Some releases of radioactive substances are likely to consist of mixtures 

of radionuclides. These releases will be one of two general types: mixtures 

of known composition or mixtures of unknown composition. The conventions 

adopted by the Agency in establishing reporting requirements for mixtures and 

the proposed RQs for two common radionuclide mixtures are presented below. 

4.4.1 Mixtures of Known Composition 

i 

Reporting requirements for releases involving mixtures of known 

composition can be obtained directly from the proposed RQs for individual 

constituents of the mixture. If the identity and quantity of each 

radionuclide involved in a release event is known, the decision to report a 

release must be made in the following manner: for each radionuclide in the 

mixture, the ratio between the quantity released (in curies) and the proposed 

RQ for the radionuclide must be determined. If the sum of the ratios for all 

radionuclides is less than 1, the release need not be reported. If the sum is 

equal to or greater than 1, the release must be reported to the National ! 

Response Center. ; 
P.44 

•21 

For example, if radionuclides a , b , and c are released in quantities 

of Qa, Qb, and Qc curies in a mixture, and if the proposed RQs are RQa, RQb,1 

and RQc, respectively, then the quantity released for the mixture does not : 

exceed the proposed RQ and the release need not be reported to the National 

Response Center if (Qa/RQa + Qb/RQb + Qc/RQc) is less than 1. This convention 

for handling releases of radionuclide mixtures is recommended by the ICRP. ! 

4.4.2 Mixtures of Unknown Composition 

Reporting requirements for mixtures of unknown composition cannot be based 

on the determination of quantities released. For mixtures of unknown 

composition, there are three possibilities: (1) the identity of the 

radionuclides involved is known, but the amounts released of each is unknown, 

(2) the identity of the radionuclides (or one of the radionuclides) in the 

mixture is unknown, but the amount released is known in total curies per unit 

volume or weight, or (3) the identity of the radionuclides involved is unknown 

and the amount of radionuclides released in the mixture is unknown. For these 

cases, the decision to report a release is made as follows: : 

(1) Identity known, but concentration unknown. , 

If the identity of each radionuclide in the mixture is 

known but the concentration of one or more of the 

radionuclides is unknown, the RQ for the mixture shall ' 

be the lowest RQ of any radionuclide in the mixture. ; 

This method for determining the RQ of a mixture assures a report to the 

National Response Center if the total number of curies involved in a release 

is equal to or greater than the RQ in curies of the substance with the lowest 

RQ in the mixture. 

(2) and (3) Identity of radionuclide(s) in the release 

is unknown. 

If the identity of a radionuclide in a release is 

unknown or if the identity of one or more radionuclides 

in the release of a mixture of radionuclides is unknown, 

the release must be reported to the National Response 

Center if the total release is equal to or greater than 

1 curie, or if the total release is equal to or greater 

than the lowest RQ of any known radionuclide in the 

mixture, which ever is lower. 

Establishing an RQ of 1 curie for a release in which the identity of the 

radionuclide or radionuclides involved is unkown is consistent with the 1 

curie RQ for the class of radionuclides for which insufficient data exist to 

extablish individual RQs. The mixture rule requires reporting if the release 

equals or exceeds 1 curie, or, if some component of the mixture is know and 

its RQ is less than 1 curie, then the total release must be reported if it 

equals or exceeds the RQ of the known component. The Agency is considering 

and soliciting comment on an RQ of 0.001 for mixtures where the identity of 

the radionuclides is unknown. An RQ of 0.001 for this class of mixtures 

corresponds to the lowest RQ category developed in this report and would be 

more conservative than an RQ of 1 curie. 
P.45 

• -2 2 

4.4.3 Common Radionuclide Mixtures 

Proposed RQs have been developed for two common radionuclide mixtures: 

radium-226 in equilibrium with its daughters, and natural uranium. Mixed 

fission products are also recognized by the Agency as an important and common 

radionuclide mixture. However, the Agency is proposing RQs currently only for 

the individual radionuclide components within this latter mixture because an ! 

RQ for mixed fission products would have to be time dependent. That is, at 

different time intervals, the concentration of the different components of ' 

this mixture will be different. In addition, the components of the mixed 

fission product will differ, depending on the type of reactor involved. 

Therefore, several different mixed fission product RQs would need to be [ 

presented. 

Radium-226 has a half life of about 1600 years, substantially greater than 

the half lives of its eleven daughters. After a sufficient period of time, 

however, a state of equilibrium is established in the mixture, such that the \ 

activity present for each daughter product and the parent radium is 

equal.25 For example, if one curie of radium-226 is released, when j 

equilibrium is reached, the activity level of the mixture will be 12 curies. \ 

When radium and its daughters reach this state of equilibrium, its RQ is 0.43 

curies. : 

i ' 

Natural uranium is composed of the isotopes U-238 (99.27 percent by 

weight), U-234 (0.0057 percent by weight), and U-235 (0.72 percent by weight). 

Because the composition by weight of natural uranium is known, we can derive 

the activity levels of each of its components. The proposed rule results inj 

an RQ for natural uranium, derived through the mixture rule, of 0.1 curies. 

2SKaplan, I., Nuclear Physics, Addison-Wesley Publishing Company, 

Reading, Massachusetts, 1958, p. 202. Using the mixture rule, the RQ for 

radium in equilibrium with its daughters was calculated from the following 

formula: 

1 12 1 

RQ . = — I 

mix 

12 i=l RQ. 

I 

where: 

RQ. is the reportable quantity of radium or the daughter of concern. 
EXHIBIT 4-5 - RADIONUCLIDES WITH PROPOSED RQs 

Release Values (Ci) 

P.46 

Radionuclide 

Actinium-224 

Actinium-225 

Actinium-226 

Actinium-227 

Actinium-228 

Aluminum-26 

Americium-237 

Americium-238 

Americium-239 

Americium-240 

Americium-241 

Americium-242m 

Americium-242 

Americium-243 

Americium-244m 

Americium-244 

Americium-245 

Americium-246m 

Americium-246 

Antimony-115 

Antimony-116m 

Antimony-116 

Antimony-117 

Antimony-118m 

Atom. 

No. 

89 

89 

89 

89 

89 

13 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

51 

51 

51 

51 

51 

Half-Life 

2.9 hr 

10.0 day 

1.2 day 

21.77 yr 

6.13 hr 

7.2E 5 yr 

1.22 hr 

1.63 hr 

11.901 hr 

50.9 hr 

432.2 yr 

141 yr 

16.01 hr 

7.37E 3 yr 

26 min 

10.1 hr 

2.05 hr 

25.0 min 

39 min 

32.1 min 

60 min 

16 min 

2.80 hr 

5.00 hr 

Ingestion 

(water) 

5.4E 

1.3E 

2.7E 

5.4E 

5.4E 

3. IE 

2. IE 

LIE 

1.3E 

5.4E 

2.7E 

2.7E 

1.3E 

2.7E 

1.6E 

8. IE 

8. IE 

1.3E 

8. IE 

2.3E 

5.7E 

2.3E 

2.0E 

1.4E 

4 

3 

3 

0 

4 

1 # 

6 

6 

5 

4 

1 

1 

5 

1 

6 

4 

5 

6 

5 

3 

2 

3 

3 

2 

Inhalation 

1.6E 2* 

1.6E 0* 

1.6E 1* 

2.1E-3* 

4.7E 1* 

3. IE 1 

1.6E 6 

1.6E 4 

5.2E 4 

1.6E 4 

2.6E-2* 

2.6E-2* 

4.IE 2* 

2.6E-2* 

2.IE 4* 

1.0E 3 

4.IE 5 

1.0E 6 

5.2E 5 

1.0E 5 

3.6E 4 

1.6E 5 

1.0E 5 

1.0E 4 

Direct 

Exposure 

2.9E 

1.3E 

2.6E 

5.3E 

4.9E 

2.0E 

1.6E 

5.2E 

4.3E 

3.8E 

--

3.2E 

--

7.9E 

--

4.6E 

2. IE 

4.2E 

5.7E 

7.2E 

1.2E 

2.IE 

2.5E 

1.4E 

2 

3 

2 

5 

1 

1* 

2* 

1* 

2* 

1* 

5 

2 

1* 

3* 

1* 

1* 

1* 

1* 

1* 

2* 

1* 

Proposed 

RQ (Ci) 

100 

1 

;

 1 0 

:

 0.001 

10 

10 

100 

i 10 

, 100 

10 

: 0.01 

0.01 

100 

0.01 

iooo 

; 10 

iooo 

' 10 

:

 1 0 

' 10 

! io 

: io 

100 

: io 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) -• 

P.47 

Radionuclide 

Antimony-119 

Antimony-120 

(16 min) 

Antimony-120 

(5.76 day) 

Antimony-122 

Antimony-124m 

Antimony-124 

Antimony-125 

Antimony-126m 

Antimony-126 

Antimony-127 

Antimony-128 

(10.4 min) 

Antimony-128 

(9.01 hr) 

Antimony-129 

Antimony-130 

Antimony-131 

Argon-39 

Argon-41 

Arsenic-69 

Arsenic-70 

Arsenic-71 

Arsenic-72 

Arsenic-73 

Atom. 

No. 

51 

51 

51 

51 

51 

51 

51 

51 

51 

51 

51 

51 

51 

51 

51 

18 

18 

33 

33 

33 

33 

33 

Half-Life 

36.1 hr 

15.9 min 

5.76 day 

2.71 day 

20.3 min 

60.20 day 

2.76 yr 

19.0 min 

12.4 day 

3.84 day 

10 min 

9.1 hr 

4.4 hr 

38.4 min 

23.0 min 

269 yr 

1.83 hr 

15.1 min 

52.6 min 

62 hr 

26.0 hr 

78 day 

Ingestion 

(water) 

2.9E 

2.9E 

2.6E 

2.0E 

5.7E 

1.4E 

5.7E 

1.4E 

1.4E 

2.0E 

2.3E 

2.9E 

8.6E 

5.7E 

2.9E 

na 

na 

2.3E 

7.7E 

3. IE 

6.9E 

6. IE 

2* 

3 

1 

1* 

3* 

1* 

1* 

3 

1 

1* 

3 

1 

1 

2 

2 

3 

2 

2 

1 

2* 

Inhalation 

1.6E 4 

2. IE 5 

5.2E 2 

5.2E 2 

3. IE 5 

1.0E 2 

2.6E 2 

1.0E 5 

2.6E 2 

4.7E 2 

2. IE 5 

1.6E 3 

4.7E 3 

3. IE 4 

1.0E 4 

na 

na 

5.2E 4 

2.6E 4 

2.6E 3 

5.2E 2 

1.0E 3 

Direct 

Exposure 

1.7E 3* 

1.5E 1* 

8.2E 1 

--

2.0E 1 

8.9E 1 

2.3E 1* 

1.4E 1* 

6. IE 1 

1.9E 1* 

1.3E 1* 

3.0E 1* 

1.3E 1* 

2.7E 1* 

2.0E 3*+ 

3.0E 1*+ 

1.5E 3* 

1.5E 1* 

1.6E 2* 

4.IE 1* 

[Proposed 

RQ (Ci) 

100 

1000 

10 

:

 1 0 

1 

iooo 

10 

! io 

!

 1 0 

: 10 

: io 

10 

'• 1 0 

; io 

| 10 

: 10 

1000 

: io 

1000 

10 

100 

:

 1 0 

100 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) — 

P.48 

Radionuclide 

Arsenic-74 

Arsenic-76 

Arsenic-77 

Arsenic-78 

Astatine-207 

Astatine-211 

Barium-126 

Barium-128 

Barium-131m 

Barium-131 

Barium-133m 

Barium-133 

Barium-135m 

Barium-139 

Barium-140 

Barium-141 

Barium-142 

Berkelium-245 

Berkelium-246 

Berkelium-247 

Berkelium-249 

Berkelium-250 

Beryllium-7 

Beryllium-10 

Atom. 

No. 

33 

33 

33 

33 

85 

85 

56 

56 

56 

56 

56 

56 

56 

56 

56 

56 

56 

97 

97 

97 

97 

97 

4 

4 

Half-Life 

17.78 day 

26.3 hr 

38.8 hr 

1.515 hr 

1.81 hr 

7.21 hr 

99 min 

2.43 day 

14.6 min 

11.8 day 

38.9 hr 

10.53 yr 

28.7 hr 

83.31 min 

12.76 day 

18.3 min 

10.7 min 

4.94 day 

1.8 day 

1.4E 3 yr 

320 day 

3.22 hr 

53.29 day 

2.7E 6 yr 

Ingestion 

(water) 

7.7E 

7.7E 

3. IE 

6.IE 

4.6E 

7.7E 

1.6E 

1.3E 

LIE 

8. IE 

5.4E 

5.4E 

8. IE 

2.7E 

1.3E 

5.4E 

1.3E 

3.8E 

5.6E 

1.9E 

9.4E 

1.9E 

8. IE 

2.0E 

1* 

1* 

2* 

2 

2 # 

0*# 

4 

3 

6 

3 

3 

3 

3 

4 

3 

4 

5 

4 

4 

1 

3 

5 

4 

3 

Inhalation 

4. IE 2 

5.2E 2 

2.6E 3 

1.0E 4 

1.0E 4 

2.6E 2 

1.0E 4 

1.0E 3 

5.2E 5 

4. IE 3 

4.7E 3 

3.6E 2 

5.2E 3 

1.6E 4 

5.2E 2 

3.6E 4 

5.2E 4 

5.2E 3 

1.6E 4 

2.6E-2* 

1.0E 0* 

2. IE 2 

1.0E 4 

5.2E 0* 

Direct 

Exposure 

7.9E 

9.9E 

5.0E 

3.5E 

4.0E 

2. IE 

1.0E 

9.5E 

6.0E 

9.0E 

7.7E 

1.0E 

8.5E 

8.3E 

2.0E 

6.5E 

3.6E 

4.3E 

4.9E 

3.2E 

--

4. IE 

7.4E 

1 

1 

3 

1* 

1* 

4 

2* 

2* 

2* 

1* 

2* 

2* 

2* 

2* 

2* 

1* 

1* 

2* 

1* 

2 

1* 

2* 

Proposed 

!RQ (Ci) 

1 

! i° 

!

 1 0 

! ioo 

: 1 0 

• 1 0 

1 

• 10 0 

100 

100 

10 

! ioo 

i 

: 100 

1 

; 100 

, 100 

: 100 

; 

10 

10 

100 

1° 

0.01 

1 

10 

,100 

1 
EXHIBIT 4-5 (Continued) 

-- Release Values (Ci) 

P.49 

Radionuclide 

Bismuth-200 

Bismuth-201 

Bismuth-202 

Bismuth-203 

Bismuth-205 

Bismuth-206 

Bismuth-207 

Bismuth-210m 

Bismuth-210 

Bismuth-212 

Bismuth-213 

Bismuth-214 

Bromine-74m 

Bromine-74 

Bromine-75 

Bromine-76 

Bromine-77 

Bromine-80m 

Bromine-80 

Bromine-82 

Bromine-83 

Bromine-84 

Cadmium-104 

Cadmium-107 

Atom. 

No. 

83 

83 

83 

83 

83 

83 

83 

83 

83 

83 

83 

83 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

48 

48 

Half-1 

36 

1.80 

1.72 

11.76 

15.31 

6.243 

32.2 

3.0E 6 

5.01 

60.6 

45.6 

19.9 

41.5 

25.3 

98 

16.1 

57.0 

4.42 

17.6 

35.3 

2.39 

31.8 

58 

6.5 

Life 

min 

hr 

hr 

hr 

day 

day 

yr 

yr 

day 

min 

min 

min 

min 

min 

min 

hr 

hr 

hr 

min 

hr 

hr 

min 

min 

hr 

Ingestion 

(water) 

8. IE 

2.7E 

2.7E 

5.4E 

2.7E 

1.6E 

2.7E 

1.1E 

2.2E 

1.4E 

1.9E 

5.4E 

7.7E 

1.5E 

2.3E 

3. IE 

1.5E 

1.5E 

3.8E 

2.3E 

3.8E 

1.5E 

2.7E 

2.7E 

3 

3 

3 

2 

2 

2 

2 

1 

2 

3 

3 

3 

2 

3 

3 

2 

3 

# 

# 

# 

# 

# 

3*# 

3 

2 

# 

# 

3*# 

3 

4 

4 

# 

Inhalation 

4. IE 

1.6E 

2. IE 

3. IE 

5.2E 

4.7E 

2. IE 

3.6E1.6E 

1.0E 

1.6E 

4.IE 

2. IE 

3.6E 

2.6E 

2. IE 

1.0E 

5.2E 

1.0E 

2. IE 

3. IE 

3. IE 

3.6E 

2.6E 

4 

4 

4 

3 

2 

2 

2 

•1* 

1* 

2* 

2* 

2 

4 

4 

4 

3 

4 

3 

5 

3 

4 

4 

4 

4 

Direct 

Exposure 

1.7E 

5.IE 

LIE 

2.2E 

4.3E 

1.2E 

2.5E 

1.5E 

1.3E 

3.5E 

--

2.7E 

1.3E 

2.4E 

3.2E 

1.8E 

1.3E 

--

7.0E 

1.4E 

5.0E 

2.2E 

1.6E 

5.6E 

1* 

1* 

2* 

1* 

1* 

1* 

1* 

2 

8 

2 

1* 

1* 

1* 

1* 

1* 

2* 

2* 

1* 

3 

1* 

2* 

3* 

Proposed 

RQ (Ci) 

10 

10 

100 

10 

10 

10 

10 

0.1 

10 

100 

100 

10 

10 

10 

10 

10 

100 

1000 

100 

10 

1000 

10 

100 

1000 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.50 

Radionuclide 

Cadmium-109 

Cadmium-113m 

Cadmium-113 

Cadmium-115m 

Cadmium-115 

Cadmium-117m 

Cadmium-117 

Calcium-41 

Calcium-45 

Calcium-47 

Californium-244 

Californium-246 

Californium-248 

Californium-249 

Californium-250 

Californium-251 

Californium-252 

Californium-253 

Californium-254 

Carbon-11 

Carbon-14 

Cerium-134 

Cerium-135 

Cerium-137m 

Atom. 

No. 

48 

48 

48 

48 

48 

48 

48 

20 

20 

20 

98 

98 

98 

98 

98 

98 

98 

98 

98 

6 

6 

58 

58 

58 

Half-Life 

462.3 day 

13.7 yr 

1.3E 15 yr 

44.6 day 

53.5 hr 

3.4 hr 

2.49 hr 

IE 5 yr 

163.8 day 

4.536 day 

19.4 min 

36 hr 

334 day 

351 yr 

13.1 yr 

890 yr 

2.64 yr 

17.8 day 

60.5 day 

20.3 min 

5730 yr 

76 hr 

17.8 hr 

34.4 hr 

Ingestion 

(water) 

4.0E 

2.7E 

2.7E 

4.0E 

1.2E 

6.7E 

6.7E 

1.2E 

8. IE 

3.2E 

2.3E 

3. IE 

1.5E 

7.7E 

2.3E 

7.7E 

4.6E 

4.6E 

2.3E 

3.8E 

1.5E 

2.7E 

LIE 

1.1E 

2 

1 

1 

2 

3 

3 

3 

3* 

2 

2 

3*# 

1*# 

0 # 

2 # 

•1 # 

•2 # 

-1 # 

1 # 

•1 # 

4 

2 

4 

5 

5 

Inhalation 

2.IE 1* 

l'.OE 0* 

1.0E 0* 

2.6E 1* 

5.2E 2 

5.2E 3 

5.2E 3 

2. IE 3 

4.IE 2* 

4.7E 2 

3. IE 3 

4.7E 1 

4.7E-1* 

2.6E-2* 

5.2E-2* 

2.6E-2* 

1.6E-1* 

1.0E 1* 

1.0E-1* 

4. IE 3 

2.IE 1* 

3.6E 2* 

2. IE 3 

2. IE 3 

Direct 

Exposure 

LIE 4 

6.9E 5 

--

LIE 3 

9.8E 1* 

1.4E 1* 

4.2E 1* 

--

--

3.3E 1* 

--

2.7E 6 

--

1.2E 2 

--

--

3.6E 6 

--

--

3.6E 1* 

--

1.2E 3 

5.IE 1* 

1.1E 3* 

Proposed 

RQ (Ci) 

10 

1 

1 

10 

10 

10 

10 

1000 

100 

10 

1000 

10 

0.1 

0.01 

0.01 

0.01 

o.i 

10 

0.1 

10 

10 

100 

10 

1000 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.51 

Radionuclide 

Cerium-137 

Cerium-139 

Cerium-141 

Cerium-143 

Cerium-144 

Cesium-125 

Cesium-127 

Cesium-129 

Cesium-130 

Cesium-131 

Cesium-132 

Cesium-134 

Cesium-134 

Cesium-135ra 

Cesium-135 

Cesium-136 

Cesium-137 

Cesium-138 

Chlorine-36 

Chlorine-38 

Chlorine-39 

Chromium-48 

Chromium-49 

Chromium-51 

Atom. 

No. 

58 

58 

58 

58 

58 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

17 

17 

17 

24 

24 

24 

Half-Life 

9.0 hr 

140 day 

32.5 day 

33.0 hr 

284.4 day 

45 min 

6.2 hr 

32.3 hr 

29.2 min 

9.69 day 

6.47 day 

2.91 hr 

2.065 yr 

53 min 

3E 6 yr 

13.1 day 

, 30.17 yr 

32.2 min 

3E 5 yr 

37.2 min 

55.7 min 

21.6 hr 

42.1 min 

27.70 day 

Ingestion 

(water) 

2.7E 

2.7E 

LIE 

5.4E 

LIE 

2.7E 

3.2E 

1.1E 

3.2E 

LIE 

1.6E 

5.4E 

3.8E 

5.4E 

3.8E 

2.2E 

5.4E 

1.1E 

1.5E 

1.5E 

1.5E 

4.6E 

2.3E 

3.. IE 

6 

5 

5 

4 

4 

6 

6 

6 

6 

6 

5 

6 

3 

6 

4 

4 

3 

6 

2 

3 

3 

2 # 

3 # 

3 # 

Inhalation 

5.2E 

3.6E 

3. IE 

1.0E 

5.2E 

5.2E 

4.7E 

1.6E 

1.0E 

1.6E 

2.IE 

5.2E 

5.2E 

1.0E 

5.2E 

3.6E 

1.0E 

3. IE 

1.0E 

2. IE 

2.6E 

3.6E 

4. IE 

1.0E 

4 

2 

2 

3 

0* 

4 

4 

4 

5 

4* 

3 

4 

1 

5 

2* 

2 

2 

4 

2* 

4 

4 

3 

4 

4 

Direct 

Exposure 

3. IE 

2.7E 

5.2E 

1.5E 

2.3E 

1.4E 

1.2E 

1.5E 

8.7E 

--

5.4E 

2.2E 

2.3E 

2.3E 

--

1.9E 

6.5E 

1.6E 

--

2.6E 

2.5E 

8.7E 

4.IE 

1.1E 

3* 

2* 

1* 

2* 

3 

2* 

2* 

2* 

2* 

1* 

3* 

1* 

1* 

1* 

1* 

1* 

1* 

1* 

1* 

2* 

3* 

Proposed 

RQ (Ci) 

1000 

100 

10 

100 

1 

100 

100 

100 

100 

1000 

10 

1000 

10 

10 

100 

10 

10 

10 

100 

10 

10 

10 

100 

1000 
EXHIBIT 4-5 (Continued) 

- Release Values (Ci) 

P.52 

Radionuclide 

Cobalt-55 

Cobalt-56 

Cobalt-57 

Cobalt-58m 

Cobalt-58 

Cobalt-60m 

Cobalt-60 

Cobalt-61 

Cobalt-62m 

Copper-60 

Copper-61 

Copper-64 

Copper-67 

Curium-238 

Curium-240 

Curium-241 

Curium-242 

Curium-243 

Curium-244 

Curium-245 

Curium-246 

Curium-247 

Curium-248 

Curium-249 

Atom. 

No. 

27 

27 

27 

27 

27 

27 

27 

27 

27 

29 

29 

29 

29 

96 

96 

96 

96 

96 

96 

96 

96 

96 

96 

96 

Half-Life 

17.5 hr 

77.7 day 

271 day 

9.1 hr 

70.91 day 

10.48 min 

5.272 yr 

1.65 hr 

13.9 min 

23.2 min 

3.41 hr 

12.701 hr 

61.9 hr 

2.4 hr 

27 day 

32.8 day 

162.5 day 

28.5 yr 

18.11 yr 

8.5E 3 yr 

4.78E 3 yr 

1.56E 7 yr 

3.4E 5 yr 

64.15 min 

Ingestion 

(water) 

5.4E 

2.2E 

2.2E 

3.2E 

5.4E 

5.4E 

1.1E 

1.1E 

2.2E 

2.3E 

7.7E 

7.7E 

3.8E 

2.7E 

1.3E 

1.3E 

8. IE 

2.7E 

2.7E 

1.3E 

1.3E 

1.3E 

5.4E 

6.7E 

4 

4 

5 

6 

4 

7 

4 

6 

6 

3 # 

2 # 

2*# 

2 # 

5 

3 

4 

2 

1 

1 

1 

1 

1 

0 

5 

Inhalation 

1.6E 

1.0E 

3.6E 

3. IE 

3.6E 

1.6E 

1.6E 

3. IE 

1.0E 

4.7E 

1.6E 

1.0E 

2.6E 

5.2E 

2.6E 

1.0E 

1.6E 

4.1E5.2E2.6E2.6E3.1E5.2E1.0E 

4 

3 

3 

5* 

3 

7 

2 

5 

6 

4 

4 

4 

3 

3* 

0* 

2 

0* 

• 2 * 

•2* 

• 2 * 

•2* 

•2* 

• 3 * 

5 

Direct 

Exposure 

3. IE 

1.1E 

3.0E 

4.2E 

4.4E 

3. IE 

1.4E 

4.0E 

1.4E 

2.3E 

1.7E 

4.5E 

3.2E 

--

--

9.4E 

1.0E 

5.0E 

1.4E 

1.7E 

--

1.2E 

--

2.0E 

1* 

1* 

2* 

6 

1* 

4* 

1* 

2* 

1* 

1* 

2* 

3 

2* 

1* 

7 

2 

7 

3 

2 

3* 

Proposed 

RQ (Ci) 

10 

10 

100 

1000 

10 

1000 

10 

100 

10 

10 

100 

100 

100 

1000 

1 

10 

1 

0.01 

0.01 

0.01 

0.01 

0.01 

0.001 

1000 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) -• 

P.53 

Radionuclide 

Dysprosium-155 

Dysprosium-157 

Dysprosium-159 

Dysprosium-165 

Dysprosium-166 

Einsteinium-250 

Einsteinium-251 

Einsteinium-253 

Einsteinium-254m 

Einsteinium-254 

Erbium-161 

Erbium-165 

Erbium-169 

Erbium-171 

Erbium-172 

Europium-145 

Europium-146 

Europium-147 

Europium-148 

Europium-149 

Europium-150 

(12.6 hr) 

Europium-150 

(34.2 yr) 

Europium-152m 

Atom. 

No. 

66 

66 

66 

66 

66 

99 

99 

99 

99 

99 

68 

68 

68 

68 

68 

63 

63 

63 

63 

63 

63 

63 

63 

Half-Life 

10 

8.1 

144 

2.33 

81.6 

8.6 

1.38 

20.47 

1.64 

275 

3.24 

10.36 

9.4 

7.52 

2.05 

5.93 

4.58 

24.3 

54.5 

93.1 

12.6 

36 

9.3 

hr 

hr 

day 

hr 

hr 

hr 

day 

day 

day 

day 

hr 

hr 

day 

hr 

day 

day 

day 

day 

day 

day 

hr 

yr 

hr 

Ingestion 

(water) 

6.9E 

1.5E 

7.7E 

7.7E 

4.6E 

3.8E 

5.4E 

1.5E 

2.3E 

1.5E 

1.5E 

4.6E 

2.3E 

3. IE 

7.7E 

2.7E 

1.3E 

4.0E 

1.3E 

1.3E 

4.0E 

LIE 

4.0E 

2 # 

3 # 

2 # 

2*# 

1*# 

3 # 

2*# 

1 # 

1 # 

0 # 

3 # 

3*# 

2*# 

2 # 

1 # 

4 

4 

4 

4 

5 

4 

4 

4 

Inhalation 

1.6E 

3.IE 

1.0E 

•2.6E 

3.6E 

3.6E 

5.2E 

1.0E 

5.2E 

5.2E 

3. IE 

1.0E 

1.6E 

5.2E 

5.2E 

1.0E 

5.2E 

1.0E 

2. IE 

1.6E 

4. IE 

1.0E 

3. IE 

4 

4 

3 

4 

2 

3 

3 

1* 

0* 

-1* 

4 

5 

3 

3 

2 

3 

2 

3 

2 

3 

3 

1* 

3 

Direct 

Exposure 

9.8E 

1.2E 

1.2E 

2.3E 

2.5E 

3.6E 

--

2. IE 

7.9E 

7.6E 

6.3E 

--

2.3E 

LIE 

7.2E 

3.0E 

1.9E 

8.7E 

1.9E 

1.2E 

LIE 

2.8E 

1.3E 

1* 

2* 

2* 

3 

3 

1* 

5 

1 

4 

1* 

7 

2* 

1* 

1* 

1* 

1* 

1* 

3* 

3* 

1 

2* 

Proposed 

RQ (Ci) 

10 

100 

100 

100 

10 

10 

100 

10 

1 

0.1 

10 

1000 

100 

100 

10 

10 

10 

10 

10 

1000 

1000 

10 

100 
P.54 

EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

Radionuclide 

Europium-152 

Europium-154 

Europium-155 

Europium-156 

Europium-157 

Europium-158 

Fermium-252 

Fermium-253 

Fermium-254 

Fermium-255 

Fermium-257 

Fluorine-18 

Francium-222 

Francium-223 

Gadolinium-145 

Gadolinium-146 

Gadolinium-147 

Gadolinium-148 

Gadolinium-149 

Gadolinium-151 

Gadolinium-152 

Gadolinium-153 

Gadolinium-159 

Gallium-65 

Atom. 

No. 

63 

63 

63 

63 

63 

63 

100 

100 

100 

100 

100 

9 

87 

87 

64 

64 

64 

64 

64 

64 

64 

64 

64 

31 

Half-Life 

13.4 

8.5 

4.73 

15.2 

15.15 

46 

25.4 

3 

3.24 

20.1 

100.5 

109.8 

14.4 

21.8 

23 

48.3 

38.1 

75 

9.3 

120 

LIE 14 

241.6 

18.6 

15.2 

yr 

yr 

yr 

day 

hr 

min 

hr 

day 

hr 

hr 

day 

min 

min 

min 

min 

day 

hr 

yr 

day 

day 

yr 

day 

hr 

min 

Ingestion 

(water) 

LIE 

6.7E 

5.4E 

8. IE 

2.7E 

2.7E 

3.8E 

7.7E 

2.3E 

3.8E 

3.8E 

3.8E 

LIE 

3.2E 

6.7E 

1.3E 

2.7E 

1.3E 

4.0E 

8. IE 

2.7E 

6.7E 

4.0E 

3.8E 

4 

3 

4 

3 

4 

5 

1*# 

1 # 

2*# 

1*# 

0 # 

3*# 

4 

3 

5 

4 

4 

2 

4 

4 

2 

4 

4 

3 # 

Inhalation 

1.0E 

1.0E 

4.7E 

2.6E 

2.6E 

3. IE 

5.2E 

5.2E 

5.2E 

1.0E 

1.0E 

3.6E 

2.6E 

4. IE 

1.0E 

5.2E 

2. IE 

4.1E1.0E 

2. IE 

5.2E5.2E 

3. IE 

1.0E 

1* 

1* 

1* 

2 

3 

4 

1 

1* 

2 

2 

0* 

4 

2* 

2* 

5 

1 * • 

3 

3* 

3 

2* 

3* 

1* 

3 

5 

Direct 

Exposure 

3.5E 1 

4.2E 1 

7.0E 2 

2.3E 1* 

3.0E 1* 

4.6E 1* 

--

4.9E 3 

--

--

8.6E 2 

--

--

1.2E 3 

1.9E 1* 

2. IE 2 

3.5E 1* 

--

LIE 2* 

1.4E 3 

--

7.0E 2 

9.3E 2* 

8.7E 1* 

Proposed 

RQ (Ci) 

10 

10 

10 

10 

10 

10 

10 

10 

100 

10 

1 

1000 

100 

100 

10 

10 

10 

0.001 

100 

100 

0.001 

10 

100 

10 

K 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.55 

Radionuclide 

Gallium-66 

Gallium-67 

Gallium-68 

Gallium-70 

Gallium-72 

Gallium-73 

Germanium-66 

Germanium-67 

Germanium-68 

Germanium-69 

Germanium-71 

Germanium-75 

Germanium-77 

Germanium-78 

Gold-193 

Gold-194 

Gold-195 

Gold-198m 

Gold-198 

Gold-199 

Gold-200m 

Gold-200 

Gold-201 

Hafnium-170 

Atom. 

No. 

31 

31 

31 

31 

31 

31 

32 

32 

32 

32 

32 

32 

32 

32 

79 

79 

79 

79 

79 

79 

79 

79 

79 

72 

Half-Life 

9.4 hr 

78.25 hr 

68.1 min 

21.1 min 

13.95 hr 

4.87 hr 

2.27 hr 

19.0 min 

288 day 

39.1 hr 

11.2 day 

82.8 min 

11.30 hr 

1.45 hr 

17.6 hr 

39.5 hr 

186.1 day 

2.30 day 

2.693 day 

3.14 day 

18.7 hr 

48.4 min 

26 min 

16.0 hr 

Ingestion 

(water) 

7.7E 

5.4E 

1.5E 

3.8E 

7.7E 

3.8E 

1.5E 

2.3E 

3.8E 

7.7E 

3.8E 

3. IE 

6.9E 

1.5E 

6.9E 

2.3E 

3.8E 

7.7E 

7.7E 

2.3E 

7.7E 

2.3E 

5.4E 

2.3E 

1 

2 

3 

# 

# 

# 

3*# 

1 

2 

3 

3 

2 

2 

4 

3 

2 

3 

2 

2 

2 

1 

# 

# 

# 

# 

# 

# 

# 

# 

# 

# 

# 

# 

# 

# 

1*# 

2*# 

1 

3 

3 

2 

# 

# 

# 

# 

Inhalation 

1.6E 

5.2E 

2.IE 

1.0E 

1.6E 

1.0E 

1.0E 

4.7E 

5.2E 

4.IE 

2. IE 

4. IE 

3. IE 

1.0E 

1.0E 

2.6E 

2. IE 

5.2E 

1..0E 

2. IE 

1.0E 

3. IE 

1.0E 

2.6E 

3 

3 

4 

5 

3 

4 

4 

4 

1* 

3 

4* 

4 

3 

4 

4 

3 

2* 

2 

3 

3 

3 

4 

5 

3 

Direct 

Exposure 

2.6E 

2.2E 

LIE 

6.9E 

2. IE 

2.0E 

LIE 

1.0E 

--

4.IE 

--

1.2E 

5.0E 

1.3E 

5.6E 

4.7E 

--

7.6E 

9.0E 

4.8E 

1.8E 

1.5E 

LIE 

8.7E 

1* 

2* 

3* 

3 

1* 

2* 

2* 

2* 

1* 

3* 

1* 

2* 

2* 

1* 

1* 

1 

2 

1* 

2* 

3* 

1* 

Proposed 

RQ (Ci) 

10 

100 

1000 

1000 

10 

100 

100 

100 

10 

10 

1000 

1000 

10 

100 

100 

10 

100 

10 

10 

100 

10 

100 

1000 

10 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) -• 

P.56 

Radionuclide 

Hafnium-172 

Hafnium-173 

Hafnium-175 

Hafnium-177m 

Hafnium-178m 

Hafnium-179m 

Hafnium-180m 

Hafnium-181 

Hafnium-182m 

Hafnium-182 

Hafnium-183 

Hafnium-184 

Holmium-155 

Holmium-157 

Holmium-159 

Holmium-161 

Holmium-162m 

Holmium-162 

Holmium-164m 

Holmium-164 

Holmium-166m 

Holmium-166 

Holmium-167 

Hydrogen-3 

Atom. 

No. 

72 

72 

72 

72 

72 

72 

72 

72 

72 

72 

72 

72 

67 

67 

67 

67 

67 

67 

67 

67 

67 

67 

67 

1 

Half-Life 

1.87 yr 

23.6 hr 

70 day 

1.08 sec 

4.0 sec 

18.7 sec 

5.519 hr 

42.4 day 

62 min 

9E 6 yr 

64 min 

4.1 hr 

48 min 

12.6 min 

33 min 

2.5 hr 

68 min 

15 min 

37.5 min 

29 min 

1.2E 3 yr 

1.117 day 

3.1 hr 

12.26 yr 

Ingestion 

(water) 

7.7E 

3.8E 

2.3E 

1.5E 

2.3E 

7.7E 

5.4E 

7.7E 

3. IE 

1.5E 

1.5E 

1.5E 

6.5E 

4.8E 

3.2E 

1.6E 

8. IE 

8. IE 

1.6E 

3.2E 

9.7E 

1.5E 

3.2E 

6. IE 

1 # 

2 # 

2 # 

3 # 

1 # 

1*# 

2 # 

1 # 

3 # 

1 # 

3 # 

2*# 

5 

6 

6 

6 

5 

6 

6 

6 

3 

4 

5 

3 

Inhalation 

4.7E 

5.2E 

4.7E 

3. IE 

5.2E1.6E 

1.0E 

1.0E 

4.7E 

4.1E2.6E 

3. IE 

1.0E 

5.2E 

5.2E 

2.IE 

1.6E 

1.0E 

1.6E 

3. IE 

3.6E 

1.0E 

3. IE 

8.3E 

0* 

3 

2 

4 

1* 

2 

4 

2 

4 

1* 

4 

3 

5 

5 

5 

5 

5 

6 

5* 

5 

0* 

3* 

4 

2* 

Direct 

Exposure 

1.5E 

1.2E 

1.2E 

3.8E 

3.8E 

1.7E 

3.8E 

7.3E 

4. IE 

1.6E 

5. IE 

1.6E 

3.7E 

1.2E 

1.8E 

6.8E 

7.6E 

5.5E 

2.6E 

1.0E 

2.2E 

1.6E 

LIE 

3 

2* 

2* 

1* 

1 

2 

1* 

1* 

1* 

2 

1* 

2 

2* 

2* 

2* 

3* 

1* 

2* 

5 

4* 

1 

3 

2* 

Proposed 

RQ (Ci) 

1 

100 

100 

10 

0.1 

10 

10 

10 

10 

0.1 

10 

100 

100 

100 

100 

1000 

10 

100 

1000 

1000 

1 

1000 

100 

100 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.57 

Radionuclide 

Indium-109 

Indium-110 

(69.1 min) 

Indium-110 

(4.9 hr) 

Indium-111 

Indium-112 

Indium-113m 

Indium-114m 

Indium-115m 

Indium-115 

Indium-116m 

Indium-117m 

Indium-117 

Indium-119m 

Iodine-120m 

Iodine-120 

Iodine-121 

Iodine-123 

Iodine-124 

Iodine-125 

Iodine-126 

Iodine-128 

Iodine-129 

Iodine-130 

Atom. 

No. 

49 

49 

49 

49 

49 

49 

49 

49 

49 

49 

49 

49 

49 

53 

53 

53 

53 

53 

53 

53 

53 

53 

53 

Half-Life 

4.2 hr 

69 min 

4.9 hr 

2.806 day 

14.4 min 

1.657 hr 

49.51 day 

4.486 hr 

4.4E 14 yr 

54.1 min 

1.933 hr 

43.1 min 

18.0 rain 

53 min 

1.35 hr 

1.8 hr 

13.1 hr 

4.17 day 

59.9 day 

13 day 

25.00 min 

1.6E 7 yr 

12.36 hr 

Ingestion 

(water) 

1.5E 

1.5E 

3.8E 

3. IE 

1.5E 

3.8E 

2.3E 

7.7E 

3. IE 

1.5E 

7.7E 

4.6E 

3. IE 

8,2E 

3.3E 

8.2E 

2.5E 

4. IE 

3.3E 

1.6E 

3.3E 

4.1E3.3E 

3 

3 

2 

2 

4 

3 

# 

# 

# 

# 

# 

# 

1*# 

2 

0 

3 

2 

3 

3 

2 

2 

2 

2 

0 

0 

0 

3 

1 

1 

# 

# 

# 

# 

# 

# 

Inhalation 

2. IE 4 

2.IE 4 

1.0E 4 

3. IE 3 

3. IE 5 

5.2E 4 

3. IE 1 

2. IE 4 

5.2E-1* 

4.IE 4 

1.6E 4 

1.0E 5 

5.2E 4 

2. IE 2 

9.3E 1 

2. IE 2 

6.2E 1* 

8.3E-1* 

6.2E-1* 

4.1E-1* 

1.0E 3 

9.3E-2* 

7.2E 0* 

Direct 

Exposure 

LIE 

4.7E 

1.3E 

9.5E 

8.6E 

1.4E 

4.8E 

2.3E 

--

1.8E 

6.0E 

5.3E 

1.6E 

1.3E 

4.0E 

1.7E 

2.5E 

4.9E 

--

9.8E 

4.3E 

--

1.7E 

2* 

1* 

1* 

1* 

2* 

2* 

2 

2* 

1* 

1* 

1* 

3* 

1* 

1* 

2* 

2 

1 

1 

2* 

1 

Proposed 

RQ (Ci) 

100 

10 

10 

10 

100 

100 

10 

100 

0.1 

10 

10 

10 

1000 

10 

10 

100 

10 

0.1 

0.1 

0.1 

100 

0.01 

1 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.58 

Radionuclide 

Iodine-131 

Iodine-132m 

Iodine-132 

Iodine-133 

Iodine-134 

Iodine-135 

Iridium-182 

Iridium-184 

Iridium-185 

Iridium-186 

Iridium-187 

Iridium-188 

Iridium-189 

Iridium-190m 

Iridium-190 

Iridium-192m 

Iridium-192 

Iridium-194m 

Iridium-194 

Iridium-195m 

Iridium-195 

Iron-52 

Iron-55 

Iron-59 

Atom. 

No. 

53 

53 

53 

53 

53 

53 

77 

77 

77 

77 

77 

77 

77 

77 

77 

77 

77 

77 

77 

77 

77 

26 

26 

26 

Half-Life 

8.040 day 

83 min 

2.4 hr 

20.8 hr 

52.5 min 

6.585 hr 

15 min 

3.0 hr 

14 hr 

15.7 hr 

10.5 hr 

41.4 hr 

13.2 day 

1.2 hr 

11.8 day 

1.44 min 

73.83 day 

171 day 

19.2 hr 

3.9 hr 

2.8 hr 

8.28 hr 

2.7 yr 

44.51 day 

Ingestion 

(water) 

2.5E 

3.3E 

3.3E 

8.2E 

1.6E 

6.6E 

3. IE 

6. IE 

3.8E 

1.5E 

7.7E 

1.5E 

3.8E 

1.5E 

7.7E 

2.3E 

6.9E 

4.6E 

7.7E 

6. IE 

7.7E 

3.6E 

3.6E 

3.2E 

0 

2 

2 

0 

3 

1 

3 # 

2 # 

2 # 

2 # 

2 # 

2 # 

2*# 

4*# 

1 # 

2 # 

1 # 

1 # 

1*# 

2 # 

2*# 

3 

4 

3 

Inhalation 

5.2E8.3E 

8.3E 

3. IE 

5.2E 

2. IE 

5.2E 

1.0E 

5.2E 

3. IE 

1.6E 

1.6E 

2. IE 

1.0E 

4.7E 

1.0E 

1.0E 

4.7E 

1.0E 

1.0E 

2. IE 

1.0E 

1.0E 

1.6E 

1* 

1 

1* 

0* 

2 

1* 

5 

5 

4 

4 

5 

4 

4 

6 

3 

2* 

3 

2 

4 

5 

5 

3 

3* 

2 

Direct 

Exposure 

9.6E 

1.7E 

2. IE 

3.8E 

1.5E 

2.4E 

7.IE 

2.9E 

7.8E 

3.3E 

1.8E 

2.2E 

1.8E 

--

3.3E 

9.7E 

4.7E 

1.6E 

4.7E 

1.3E 

2.5E 

2.2E 

--

' 3. IE 

1 

1* 

2 

1 

1* 

1 

1* 

1* 

1* 

1* 

2* 

1* 

3 

1* 

5 

1* 

1* 

2 

2* 

3 

2* 

1* 

Proposed 

RQ (Ci) 

0.1 

10 

10 

1 

10 

10 

10 

10 

10 

10 

100 

10 

100 

1000 

10 

100 

10 

10 

10 

100 

100 

100 

1000 

10 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.59 

Radionuclide 

Iron-60 

Krypton-74 

Krypton-76 

Krypton-77 

Krypton-79 

Krypton-81 

Krypton-83m 

Krypton-85m 

Krypton-85 

Krypton-87 

Krypton-88 

Lanthanum-131 

Lanthanum-132 

Lanthanum-13 5 

Lanthanum-137 

Lanthanum-138 

Lanthanum-140 

Lanthanum-141 

Lanthanum-142 

Lanthanum-143 

Lead-195m 

Lead-198 

Lead-199 

Lead-200 

Atom. 

No. 

26 

36 

36 

36 

36 

36 

36 

36 

36 

36 

36 

57 

57 

57 

57 

57 

57 

57 

57 

57 

82 

82 

82 

82 

Half-Life 

3E 5 yr 

11.5 min 

14.8 hr 

1.24 hr 

35.0 hr 

2.IE 5 yr 

1.86 hr 

4.48 hr 

10.72 yr 

76.3 min 

2.84 hr 

59 min 

4.8 hr 

19.5 hr 

6E 4 yr 

1.06E 11 yr 

40.28 hr 

3.93 hr 

92 min 

14.1 min 

15 min 

2.4 hr 

1.5 hr 

21.5 hr 

Ingestion 

(water) 

1.2E 2 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

3.8E 3 

2.3E 2 

# 

# 

3.IE 3*# 

7.7E 2 

6.9E 1 

4.6E 1 

# 

# 

# 

3.IE 2*# 

6. IE 2 

3. IE 3 

6.5E 6 

3.2E 6 

2.2E 6 

3.2E 5 

# 

# 

Inhalation 

3.IE 0* 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

5.2E 4 

5.2E 3 

4.7E 4 

3.IE 1* 

2.IE 0* 

5.2E 2 

4.7E 3 

1.0E 4 

4.7E 4 

1.0E 5 

3. IE 4 

3.6E 4 

3. IE 3 

Direct 

Exposure 

6.2E 

3.0E 

8.9E 

4.0E 

2.0E 

6.9E 

9.9E 

2.0E 

9.9E 

5.0E 

2.0E 

1.5E 

2.9E 

3.9E 

--

3.0E 

1.6E 

1.5E 

2. IE 

6.6E 

3.3E 

LIE 

4.8E 

3.3E 

2 

1*4-

1*4-

1*+ 

2*+ 

3*4-

4*4-

2*4-

2*4-

1*4-

1*4-

2* 

1* 

3 

1 

1* 

3 

1* 

2* 

1* 

2* 

1* 

2* 

Proposed 

RQ (Ci) 

1 

10 

10 

10 

100 

1000 

1000 

100 

100 

10 

10 

100 

10 

1000 

10 

1 

10 

100 

10 

100 

10 

100 

10 

100 
P.60 

I 

8 

1 

EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

Radionuclide 

Lead-201 

Lead-202m 

Lead-202 

Lead-203 

Lead-205 

Lead-209 

Lead-210 

Lead-211 

Lead-212 

Lead-214 

Lutetium-169 

Lutetium-170 

Lutetium-171 

Lutetium-172 

Lutetium-173 

Lutetium-174m 

Lutetium-174 

Lutetium-176m 

Lutetium-176 

Lutetium-177m 

Lutetium-177 

Lutetium-178m 

Lutetium-178 

Lutetium-179 

Atom. 

No. 

82 

82 

82 

82 

82 

82 

82 

82 

82 

82 

71 

71 

71 

71 

71 

71 

71 

71 

71 

71 

71 

71 

71 

71 

Half-Life 

9.33 hr 

3.62 hr 

5.3E 4 yr 

52.1 hr 

1.51E 7 yr 

3.25 hr 

22.3 yr 

36.1 min 

10.64 hr 

26.8 min 

1.419 day . 

2.01 day 

8.24 day 

6.70 day 

1.37 yr 

142 day 

3.31 yr 

3.63 hr 

3.6E 10 yr 

160 day 

6.71 day 

23 min 

28.5 min 

4.6 hr 

Ingestion 

(water) 

7.5E 

9.7E 

LIE 

5.4E 

4.3E 

2.2E 

6.5E 

LIE 

8.6E 

9.7E 

2.3E 

7.7E 

1.5E 

7.7E 

3.8E 

1.5E 

3.8E 

6. IE 

5.4E 

5.4E 

1.5E 

3.8E 

3. IE 

4.6E 

5 

5 

4 

5 

5 

6 

1 

6 

3 

5 

2 # 

1 # 

2 # 

1 # 

2 # 

2 # 

2 # 

2*# 

1 # 

1 # 

2*# 

3 # 

3 # 

2*# 

Inhalation 

1.0E 

1.6E 

2.6E 

4.7E 

5.2E 

3. IE 

1.0E 

3. IE 

1.6E 

4.IE 

2. IE 

1.0E 

1.0E 

5.2E 

1.6E 

1.0E 

5.2E 

1.0E 

2.6E 

4.IE 

1.0E 

1.0E 

5.2E 

1.0E 

4 

4 

1* 

3 

2* 

4* 

•1* 

2* 

1* 

2 

3 

3 

3 

2 

2* 

2* 

1* 

4 

0* 

1 

3 

5 

4 

4 

Direct 

Exposure 

6.4E 

1.9E 

--

1.5E 

--

--

--

6.7E 

3.2E 

1.7E 

6. IE 

2. IE 

6.7E 

2.2E 

6.8E 

4.3E 

4.3E 

4.6E 

7.8E 

4.0E 

1.2E 

8.3E 

3.6E 

1.4E 

1* 

1* 

2* 

2 

2 

2* 

1* 

1* 

1* 

1* 

2 

3 

2 

3 

1 

1* 

3 

2* 

2* 

3 

Proposed 

RQ (Ci) 

10 

10 

10 

100 

100 

1000 

0.1 

100 

10 

100 

10 

io 

10 

10 

100 

100 

10 

100 

1 

10 

100 

100 

100 

100 

\ 
P.61 

Page No. 

12/19/86 

16 

Release Values (Ci) 

Radionuclide 

Magnesium-28 

Manganese-51 

Manganese-52m 

Manganese-52 

Manganese-53 

Manganese-54 

Manganese-56 

Mendelevium-257 

Mendelevium-258 

Mercury-193m 

Mercury-193 

Mercury-194 

Mercury-195m 

Mercury-195 

Mercury-197m 

Mercury-197 

Mercury-199m 

Mercury-203 

Molybdenum-90 

Molybdenum-93m 

Molybdenum-93 

Molybdenum-99 

Molybdenum-101 

Neodymium-136 

Atom. 

No. Half-Life 

12 

25 

25 

25 

25 

25 

25 

101 

101 

80 

80 

80 

80 

80 

80 

80 

80 

80 

42 

42 

42 

42 

42 

60 

21.0 hr 

46.2 min 

21.1 min 

5.59 day 

3.7E 6 yr 

312 day 

2.579 hr 

5.2 hr 

56 day 

11.8 hr 

3.8 hr 

520 yr 

40.0 hr 

9.5 hr 

23.8 hr 

64.1 hr 

42.6 min 

46.6 day 

5.67 hr 

6.9 hr 

3.5E 3 yr 

65.94 hr 

14.6 min 

50.7 min 

Ingestion 

(water) 

5.4E 1 # 

1.5E 3*# 

2.3E 3 # 

5.4E 1 # 

3.8E 3*# 

1.5E 2 # 

3.8E 2 # 

6.9E 2 # 

5.4E 0 # 

2.3E 2 # 

1.5E 3 # 

1.5E 0*# 

1.5E 2*# 

7.7E 2 # 

2.3E 2*# 

4.6E 2*# 

4.6E 3 # 

3.8E 1*# 

2.7E 2 

5.5E 2 

5.5E 2 

1.4E 2* 

5.5E 3 

1.3E 5 

Inhalation 

5.2E 2 

2.6E 4 

4.7E 4 

4.7E 2 

5.2E 3 

4. IE 2 

1.0E 4 

5.2E 2* 

1.6E 0* 

4. IE 3 

1.6E 4 

1.6E 1 

2.IE 3 

1.6E 4 

2.6E 3 

4. IE 3 

4. IE 4 

4. IE 2 

2.6E 3 

5.2E 3 

1.0E 2* 

5.2E 2 

5.2E 4 

2.6E 4 

Direct 

Exposure 

2.6E 1* 

6.9E 3 

2.6E 1* 

1.6E 1* 

4.4E 1* 

2.2E 1* 

2.9E 1* 

5.IE 1* 

2. IE 2 

3.0E 2* 

7.9E 2 

2.4E 3 

2.7E 2* 

1.6E 2 

4.7E 1* 

1.6E 1* 

1.5E 2 

6.5E 1* 

2.6E 2* 

Proposed 

RQ (Ci) 

10 

1000 

10 

10 

1000 

10 

10 

100 

1 

10 

10 

1 

100 

100 

100 

100 

100 

10 

10 

10 

100 

100 

10 

100 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.62 

Radionuclide 

Neodymium-138 

Neodymium-139m 

Neodymium-139 

Neodymium-141 

Neodymium-147 

Neodymium-149 

Neodymium-151 

Neptunium-232 

Neptunium-233 

Neptunium-234 

Neptunium-235 

Neptunium-236 

(1.2 E 5 yr) 

Neptunium-236 

(22.5 hr) 

Neptunium-237 

Neptunium-238 

Neptunium-239 

Neptunium-240 

Nickel-56 

Nickel-57 

Nickel-59 

Nickel-63 

Nickel-65 

Nickel-66 

Atom 

No. 

60 

60 

60 

60 

60 

60 

60 

93 

93 

93 

93 

93 

93 

93 

93 

93 

93 

28 

28 

28 

28 

28 

28 

Half-Life 

22 min 

5.1 hr 

30 min 

2.5 hr 

10.99 day 

1.73 hr 

12.4 min 

14.7 min 

36.2 min 

4.4 day 

1.08 yr 

1.2E 5 yr 

22.5 hr 

2.14E 6 yr 

2.117 day 

2.35 day 

1.03 hr 

6.10 day 

36.1 hr 

9E 4 yr 

100 yr 

2.52 hr 

54.8 hr 

Ingestion 

(water) 

2.7E 4 

6.7E 4 

1.2E 6 

2.7E 6 

1.3E 4 

1.3E 5 

9.4E 5 

8. IE 3 

2.2E 5 

5.4E 2 

2.7E 3* 

1.1E-1* 

1.4E 2* 

1.9E-2* 

2.2E 2 

5.4E 2 

5.4E 3 

2.7E 3 

5.4E 3 

5.4E 4 

2.4E 4 

2.2E 4 

1.1E 3 

Inhalation 

2.6E 3* 

5.2E 3 

1.6E 5 

3. IE 5 

4. IE 2 

1.0E 4 

1.0E 5 

1.0E 4 

1.6E 7 

1.6E 4 

5.2E 3 

1.6E-1 

2. IE 2 

3.1E-2 

4.7E 2 

1.0E 4 

4.IE 5 

5.2E 2 

1.6E 3 

2.IE 3* 

1.0E 3* 

1.0E 4 

3.IE 2* 

Direct 

Exposure 

3.3E 3 

3.2E 1* 

3.8E 2* 

1.7E 3* 

3.0E 2* 

8.IE 1* 

5.8E 1* 

3.6E 1* 

5.3E 3* 

3.6E 1* 

--

6.9E 2 

4.8E 3 

2.6E 3 

5.8E 1* 

3.4E 2* 

3.3E 1* 

2.IE 1* 

2.4E 1* 

--

--

6.8E 1* 

_ _ 

Proposed 

RQ (Ci) 

1000 

10 

100 

1000 

100 

10 

10 

10 

1000 

10 

1000 

0.1 

100 

0.01 

10 

100 

10 

10 

10 

1000 

1000 

10 

100 
EXHIBIT 4-5 (Continued) 

-- Release Values (Ci) 

P.63 

Radionuclide 

Niobium-88 

Niobium-89 

(66 min) 

Niobium-89 

(122 min) 

Niobium-90 

Niobium-93m 

Niobium-94 

Niobium-95m 

Niobium-95 

Niobium-96 

Niobium-97 

Niobium-98 

Osmium-180 

Osmium-181 

Osmium-182 

Osmium-185 

Osmium-189m 

Osmium-191m 

Osmium-191 

Osmium-193 

Osmium-194 

Palladium-100 

Palladium-101 

Palladium-103 

Atom. 

No. 

41 

41 

41 

41 

41 

41 

41 

41 

41 

41 

41 

76 

76 

76 

76 

76 

76 

76 

76 

76 

46 

46 

46 

Half-Life 

14.3 

66 

122 

14.6 

13.6 

2.4E 4 

3.61 

34.98 

23.4 

73.6 

2.8 

21.7 

1.75 

21.5 

93.6 

5.8 

13.1 

15.4 

31.1 

6.0 

3.6 

8.4 

16.97 

min 

min 

min 

hr 

yr 

yr 

day 

day 

hr 

min 

sec 

min 

hr 

hr 

day 

hr 

hr 

day 

hr 

yr 

day 

hr 

day 

Ingestion 

(water) 

2.7E 

5.4E 

2.7E 

5.4E 

4.8E 

4.8E 

1.1E 

1.1E 

5.4E 

1.1E 

5.4E 

7.7E 

7.7E 

1.5E 

1.5E 

6. IE 

7.7E 

1.5E 

1.5E 

3. IE 

1.3E 

1.3E 

8. IE 

6 

5 

5 

4 

5 

4 

5 

5 

4 

6 

5 

3*# 

2 # 

2 # 

2 # 

3*# 

2*# 

2*# 

2*# 

1 # 

3 

4 

3 

Inhalation 

1.0E 

2. IE 

1.0E 

1.0E 

1.0E 

1.0E 

1.0E 

5.2E 

1.0E 

3.6E 

2.6E 

2. IE 

2. IE 

2. IE 

2.6E 

1.0E 

1.0E 

5.2E 

1.6E 

4.IE 

5.2E 

1.6E 

2. IE 

5 

4 

4 

3 

2* 

1* 

3 

2 

3 

4 

4 

5 

4 

3 

2 

5 

4 

2 

3 

0* 

2 

4 

3* 

Direct 

Exposure 

LIE 

2.0E 

9.9E 

9. IE 

--

2.3E 

5.5E 

4.8E 

1.6E 

5.5E 

5.5E 

--

4.7E 

9.7E 

5.5E 

--

7.0E 

LIE 

8.6E 

--

2. IE 

1.6E 

4.0E 

1* 

1* 

1* 

0* 

1 

2* 

1* 

1* 

1* 

2* 

1* 

1* 

1* 

5 

3 

2 

2* 

2* 

5 

Proposed 

RQ (Ci) 

10 

10 

10 

1 

100 

10 

100 

10 

10 

10 

100 

1000 

10 

10 

10 

1000 

100 

100 

100 

1 

100 

100 

1000 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.64 

Radionuclide 

Palladium-107 

Palladium-109 

Phosphorus-32 

Phosphorus-33 

Platinum-186 

Platinum-188 

Platinum-189 

Platinum-191 

Platinum-193m 

Platinum-193 

Platinum-195m 

Platinum-197m 

Platinum-197 

Platinum-199 

Platinum-200 

Plutonium-234 

Plutonium-235 

Plutonium-236 

Plutonium-237 

Plutonium-238 

Plutonium-239 . 

Plutonium-240 

Plutonium-241 

Plutonium-242 

Atom. 

No. 

46 

46 

15 

15 

78 

78 

78 

78 

78 

78 

78 

78 

78 

78 

78 

94 

94 

94 

94 

94 

94 

94 

94 

94 

Half-Life 

6.5E 6 yr 

13.47 hr 

14.28 day 

25.3 day 

2.0 hr 

10.2 day 

10.9 hr 

2.96 day 

4.33 day 

50 yr 

4.02 day 

95.4 min 

18.3 hr 

30.8 min 

12.5 hr 

8.8 hr 

25.6 min 

2.85 yr 

45.1 day 

87.74 yr 

2.411E 4 yr 

6.537E 3 yr 

14.4 yr 

3.76E 5 yr 

Ingestion 

(water) 

4.0E 

2.7E 

4.6E 

4.6E 

7.7E 

1.5E 

7.7E 

3. IE 

2.3E 

3. IE 

1.5E 

1.5E 

2.3E 

3.8E 

7.7E 

2.4E 

2.4E 

5.4E 

2.7E 

1.9E 

1.6E 

1.6E 

8. IE 

1.9E 

4 

3 

1 # 

2 # 

2 # 

2*# 

2 # 

2 # 

2*# 

3*# 

2*# 

3 # 

2*# 

3 # 

1*# 

4 

6* 

1 

4 

1 

1 

1 

2 

1 

Inhalation 

2.IE 2* 

2.6E 3* 

4.IE 0* 

3.IE 1* 

2. IE 4 

1.0E 3 

1.6E 4 

4. IE 3 

3. IE 3 

1.0E 4 

2. IE 3 

2. IE 4 

4.7E 3 

5.2E 4 

1.6E 3 

1.0E 3* 

1.6E 7 

1.0E-1* 

1.6E 4* 

3.1E-2* 

2.6E-2* 

2.6E-2* 

1.6E 0* 

3.1E-2* 

Direct 

Exposure 

9.0E 3 

--

--

4.8E 1* 

3.0E 2 

2.2E 2* 

1.9E 2* 

2.4E 5 

--

2.5E 3 

9.5E 2* 

4.8E 3 

2.IE 2* 

1.9E 3 

--

--

--

--

--

1.7E 6 

5.0E 6 

1.4E 8 

4. IE 6 

Proposed 

RQ (Ci) 

100 

1000 

1 

10 

10 

100 

100 

100 

100 

1000 

100 

100 

100 

100 

10 

1000 

1000 

0.1 

1000 

0.01 

0.01 

0.01 

1 

0.01 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.65 

Radionuclide 

Plutonium-243 

Plutonium-244 

Plutonium-245 

Polonium-203 

Polonium-205 

Polonium-207 

Polonium-210 

Potassium-40 

Potassium-42 

Potassium-43 

Potassium-44 

Potassium-45 

Praseodymium-136 

Praseodymium-137 

Praseodymium-138m 

Praseodymium-139 

Praseodymium-142m 

Praseodymium-142 

Praseodymium-143 

Praseodymium-144 

Praseodymium-145 

Praseodymium-147 

Promethium-141 

Promethium-143 

Atom. 

No. 

94 

94 

94 

84 

84 

84 

84 

19 

19 

19 

19 

19 

59 

59 

59 

59 

59 

59 

59 

59 

59 

59 

61 

61 

Half-Life 

4.95 

8.2E 7 

10.5 

34.8 

1.8 

5.83 

138.4 

1.25E 9 

12.36 

22.3 

22.1 

17.3 

13.1 

77 

2.1 

4.41 

14.6 

19.13 

13.58 

17.3 

5.98 

13.4 

20.9 

265 

hr 

yr 

hr 

min 

hr 

hr 

day 

yr 

hr 

hr 

min 

min 

min 

min 

hr 

hr 

min 

hr 

day 

min 

hr 

min 

min 

day 

Ingestion 

(water) 

5.4E 

1.9E 

5.4E 

2.0E 

1.3E 

5.4E 

2.0E 

2.8E 

4.7E 

5.7E 

1.9E 

2.8E 

6.7E 

5.4E 

1.3E 

5.4E 

1.1E 

1.3E 

1.2E 

4.0E 

4.0E 

6.7E 

8. IE 

8. IE 

4 

1 

3 

4 

4 

3 

0 

2 

3 

3 

4 

4 

5 

5 

5 

5 

6 

4 

4 

5 

4 

5 

5 

4 

Inhalation 

2. IE 5 

3.1E-2* 

2. IE 4 

3. IE 4 

2. IE 4 

1.6E 4 

3.1E-1* 

2.IE 2* 

2.6E 3 

4.7E 3 

3.6E 4 

5.2E 4 

1.0E 5 

5.2E 4 

2. IE 4 

5.2E 4 

5.2E 4* 

1.0E 3 

3.6E 2* 

5.2E 4 

4.IE 3 

1.0E 5 

1.0E 5 

3. IE 2 

Direct 

Exposure 

1.6E 

--

1.6E 

3. IE 

3.0E 

3.IE 

4.5E 

2.4E 

1.3E 

4. IE 

1.5E 

2.0E 

3.0E 

1.2E 

1.7E 

3.9E 

--

6.2E 

4.9E 

1.3E 

3. IE 

6.2E 

5.6E 

1.3E 

3* 

2* 

1* 

1* 

1* 

6 

2 

2* 

1* 

1* 

1* 

1* 

3* 

1* 

2* 

2* 

8 

3* 

3* 

1* 

1* 

2* 

Proposed 

RQ (Ci) 

1000 

0.01 

100 

10 

10 

10 

0.1 

100 

100 

10 

10 

10 

10 

1000 

10 

100 

1000 

100 

100 

1000 

1000 

10 

10 

100 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) -• 

P.66 

Radionuclide 

Atom. Ingestion Inha- Direct Proposed 

No. Half-Life (water) lation Exposure RQ (Ci) 

Promethium-144 

Promethium-145 

Promethium-146 

Promethium-147 

Promethium-148m 

Promethium-148 

Promethium-149 

Promethium-150 

Promethium-151 

Protactinium-227 

Protactinium-228 

Protactinium-230 

Protactinium-231 

Protactinium-232 

Protactinium-233 

Protactinium-234 

Radium-223 

Radium-224 

Radium-225 

Radium-226 

Radium-227 

Radium-228 

Radon-220 

Radon-222 

61 

61 

61 

61 

61 

61 

61 

61 

61 

91 

91 

91 

91 

91 

91 

91 

88 

88 

88 

88 

88 

88 

86 

86 

363 

17.7 

5.53 

2.623 

41.3 

5.37 

53.1 

2.69 

28.4 

38.3 

22 

17.4 

3.27E 4 

1.31 

27.0 

6.70 

11.43 

3.66 

14.8 

1600 

42.2 

5.75 

55.6 

3.82 

day 

yr 

yr 

yr 

day 

day 

hr 

hr 

hr 

min 

hr 

day 

yr 

day 

day 

hr 

day 

day 

day 

yr 

min 

yr 

sec 

day 

1.6E 

1.6E 

3.2E 

6.5E 

1.1E 

6.5E 

1.6E 

8. IE 

3.2E 

4.3E 

1.1E 

6.5E 

2.2E 

1.1E 

1.1E 

2.2E 

1.3E 

2.2E 

2.2E 

5.4E 

5.4E 

5.4E 

na 

na 

4 

5 

4 

4 

4 

3 

4 

4 

4 

5 

5 

4 

1 

5 

5 

5 

1 

1 

1 

0 

4 

0 

5.2E 

1.0E 

2. IE 

5.2E 

1.6E 

2.6E 

1.0E 

1.0E 

1.6E 

5.2E 

5.2E 

2. IE 

1.0E1.0E 

3. IE 

3.6E 

3.6E 

1.0E 

3.6E 

3. IE 

5.2E 

5.2E 

1.0E5.2E1 

2* 

1* 

1* 

2 

2 

3* 

4 

3 

2* 

1 

1* 

2* 

2 

3 

4 

0* 

1* 

0* 

0* 

4 

0* 

1* 

1* 

2.4E 

2.8E 

5.0E 

9.5E 

1.8E 

6.5E 

3.4E 

3.0E 

1.6E 

1.9E 

4.8E 

6.3E 

1.8E 

4.0E 

2.3E 

2.8E 

4.5E 

3.8E 

--

5.9E 

3.2E 

--

--

1.0E 

1* 

4 

1 

6 

1* 

1* 

3 

1* 

2* 

4 

1* 

1 

3 

1* 

2* 

1* 

2 

3 

3 

2* 

5 

10 

100 

10 

10 

10 

10 

1000 

10 

100 

100 

10 

10 

0.01 

10 

100 

10 

1 

10 

1 

1 

100 

1 

0.1 

0.1 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.67 

Radionuclide 

Rhenium-177 

Rhenium-178 

Rhenium-181 

Rhenium-182 

(12.7 hr) 

Rhenium-182 

(64.0 hr) 

Rhenium-184m 

Rhenium-184 

Rhenium-186m 

Rhenium-186 

Rhenium-187 

Rhenium-188m 

Rhenium-188 

Rhenium-189 

Rhodium-99m 

Rhodium-99 

Rhodium-100 

Rhodium-101m 

Rhodium-101 

Rhodium-102m 

Rhodium-102 

Rhodium-103m 

Rhodium-105 

Rhodium-106m 

Atom. 

No. 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

Half-Life 

14 min 

13.2 min 

20 hr 

12.7 hr 

64.0 hr 

165 day 

38 day 

2.0E 5 hr 

90 hr 

4.5E 10 yr 

18.7 min 

16.98 hr 

24 hr 

4.7 hr 

16.1 day 

20.8 hr 

4.34 day 

3.3 yr 

206 day 

2.9 yr 

56.12 min 

35.4 hr 

2.18 hr 

Ingestion 

(water) 

6.9E 

5.4E 

3.8E 

5.4E 

7.7E 

1.5E 

1.5E 

7.7E 

1.5E 

4.6E 

6. IE 

1.5E 

2.3E 

1.5E 

1.5E 

1.5E 

4.6E 

1.5E 

7.7E 

4.6E 

3. IE 

3. IE 

6. IE 

3 # 

3 # 

2 # 

2 # 

1 # 

2*# 

2 # 

1*# 

2*# 

4*# 

3 # 

2*# 

2*# 

3 # 

2 # 

2 # 

2 # 

2 # 

1 # 

1 # 

4*# 

2*# 

2 # 

Inhalation 

1.6E 

1.6E 

4.7E 

5.2E 

1.0E 

2. IE 

5.2E 

1.0E 

1.0E 

5.2E 

5.2E 

1.6E 

2. IE 

3. IE 

1.0E 

2. IE 

4. IE 

1.0E 

5.2E 

3. IE 

5.2E 

3. IE 

1.6E 

5 

5 

3 

3 

3 

2 

2 

2 

3 

4 

4 

3 

3 

4 

3 

3 

3 

2* 

1* 

1 

5 

3 

4 

Direct 

Exposure 

8.5E 

6.0E 

7.2E 

3.8E 

2.2E 

2.IE 

4.4E 

3.3E 

2.7E 

--

2. IE 

8.2E 

8.4E 

6.4E 

8.5E 

1.4E 

1.3E 

1.3E 

8.4E 

1.4E 

--

4.7E 

1.3E 

1* 

1* 

1* 

1* 

1* 

2 

1* 

3 

3 

3* 

2 

2 

1* 

1* 

1* 

2* 

2 

1 

1* 

2 

1* 

Proposed 

RQ (Ci) 

10 

10 

10 

10 

10 

100 

10 

10 

100 

1000 

1000 

100 

100 

10 

10 

10 

100 

100 

10 

10 

1000 

100 

10 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.68 

Radionuclide 

Rhodium-107 

Rubidium-79 

Rubidium-81m 

Rubidium-81 

Rubidium-82m 

Rubidium-83 

Rubidium-84 

Rubidium-86 

Rubidium-88 

Rubidium-89 

Rubidium-87 

Ruthenium-94 

Ruthenium-97 

Ruthenium-103 

Ruthenium-105 

Ruthenium-106 

Samarium-141m 

Samarium-141 

Samarium-142 

Samarium-145 

Samarium-146 

Samarium-147 

Samarium-151 

Samarium-153 

Atom. 

No. 

45 

37 

37 

37 

37 

37 

37 

37 

37 

37 

37 

44 

44 

44 

44 

44 

62 

62 

62 

62 

62 

62 

62 

62 

Half-Life 

21.7 min 

23 min 

32 min 

4.58 hr 

6.47 hr 

86.2 day 

32.9 day 

18.63 day 

17.7 min 

15.3 min 

4.9E 10 yr 

52 min 

2.89 day 

39.24 day 

4.44 hr 

372.6 day 

22.6 min 

10.2 min 

72.5 rain 

340 day 

1.03E 8 yr 

1.08E 11 yr 

90 yr 

46.7 hr 

Ingestion 

(water) 

5.4E 

1.3E 

6.7E 

1.3E 

3.4E 

2.0E 

1.7E 

1.7E 

6.7E 

1.3E 

3.4E 

1.5E 

6. IE 

1.5E 

3.8E 

1.5E 

4.8E 

8. IE 

1.3E 

9.7E 

1.6E 

3.2E 

1.6E 

3.2E 

3 # 

5 

5 

5 

4 

3 

3 

3 

4 

5 

3 

3 

2 

2 

2 

1 

5 

5 

5 

4 

2 

2 

5 

4 

Inhalation 

1.0E 

5.2E 

1.6E 

2.6E 

1.0E 

5.2E 

4.IE 

4. IE 

3. IE 

5.2E 

1.0E 

2. IE 

5.2E 

3. IE 

5.2E 

5.2E 

5.2E 

1.0E 

1.6E 

2.6E 

2.1E2.1E5.2E 

1.6E 

5 

4 

5 

4 

4 

2 

2 

2 

4 

4 

3* 

4 

3 

2 

3 

0* 

4 

5 

4 

2* 

2* 

2* 

1* 

3 

Direct 

Exposure 

1.2E 2* 

2.9E 1* 

1.5E 2* 

7.8E 1* 

1.4E 1* 

7.3E 1* 

5.4E 1* 

3.8E 2* 

5.IE 1* 

2.0E 1* 

--

7.5E 1* 

1.0E 2* 

7.8E 1* 

5.2E 1* 

--

2.4E 1* 

3.5E 1* 

5.9E 2* 

2.5E 6 

--

--

--

LIE 3* 

Proposed 

RQ (Ci) 

100 

10 

100 

10 

10 

10 

10 

100 

10 

10 

1000 

10 

100 

10 

10 

1 

10 

10 

100 

100 

0.01 

0.01 

10 

1000 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.69 

Radionuclide 

Samarium-155 

Samarium-156 

Scandium-43 

Scandium-44m 

Scandium-44 

Scandium-46 

Scandium-47 

Scandium-48 

Scandium-49 

Selenium-70 

Selenium-73m 

Selenium-73 

Selenium-75 

Selenium-79 

Selenium-81m 

Selenium-81 

Selenium-83 

Silicon-31 

Silicon-32 

Silver-102 

Silver-103 

Silver-104ra 

Silver-104 

Silver-105 

Atom. 

No. 

62 

62 

21 

21 

21 

21 

21 

21 

21 

34 

34 

34 

34 

34 

34 

34 

34 

14 

14 

47 

47 . 

47 

47 

47 

Half-Life 

22.2 

9.4 

3.89 

58.6 

3.93 

83.8 

3.42 

43.7 

57.3 

41.1 

8.4 

7.1 

118.5 

6E 4 

57.3 

18.5 

22.3 

2.62 

680 

13 

66 

33 

69 

41.3 

min 

hr 

hr 

hr 

hr 

day 

day 

hr 

min 

min 

day 

hr 

day 

yr 

min 

min 

min 

hr 

yr 

min 

min 

rain 

min 

day 

Ingestion 

(water) 

9.7E 

8. IE 

5.4E 

3.8E 

3. IE 

6.9E 

1.5E 

6.IE 

1.5E 

2.7E 

8. IE 

8. IE 

1.4E 

1.6E 

5.4E 

1.6E 

8. IE 

6.9E 

1.5E 

6.7E 

5.4E 

4.0E 

2.7E 

4.0E 

5 

4 

2 # 

1*# 

2 # 

1 # 

2*# 

1 # 

3*# 

3 

3 

2 

2 

2* 

3 

4 

3 

2*# 

2 # 

4 

4 

4 

4 

3 

Inhalation 

1.0E 

4.7E 

1.0E 

3.6E 

5.2E 

1.0E 

1.6E 

5.2E 

2.6E 

2. IE 

5.2E 

5.2E 

3. IE 

3. IE 

3.6E 

1.0E 

5.2E 

1.6E 

2.6E 

1.0E 

5.2E 

4.7E 

3.6E 

5.2E 

5 

3 

4 

2 

3 

2 

3 

2 

4 

4 

4 

3 

2 

2 

4 

5 

4 

4 

0* 

5 

4 

4 

4 

2 

Direct 

Exposure 

4.0E 

3.3E 

4.4E 

1.2E 

3.IE 

1.8E 

3.4E 

LIE 

4. IE 

1.9E 

1.7E 

3.7E 

1.0E 

--

3.5E 

3.3E 

2.3E 

4. IE 

t? 

LIE 

10E 

3.6E 

2.0E 

8.2E 

2* 

2* 

2* 

2 

1* 

1* 

2 

1* 

4 

2* 

2* 

1* 

2* 

3* 

3* 

1* 

4 

1* 

1* 

1* 

2* 

1* 

Proposed 

RQ (Ci) 

100 

100 

100 

10 

10 

10 

100 

10 

1000 

100 

100 

10 

100 

100 

1000 

1000 

10 

100 

1 

10 

10 

10 

100 

10 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.70 

Radionuclide 

Silver-106m 

Silver-106 

Silver-108m 

Silver-llOm 

Silver-Ill 

Silver-112 

Silver-115 

Sodium-22 

Sodium-24 

Strontium-80 

Strontium-81 

Strontium-83 

Strontium-85m 

Strontium-85 

Strontium-87m 

Strontium-89 

Strontium-90 

Strontium-91 

Strontium-92 

Sulfur-35 

Tantalum-172 

Tantalum-173 

Tantalum-174 

Tantalum-175 

Atom. 

No. 

47 

47 

47 

47 

47 

47 

47 

11 

11 

38 

38 

38 

38 

38 

38 

38 

38 

38 

38 

16 

73 

73 

73 

73 

Half-Life 

8.5 

24.0 

1.3E 2 

249.8 

7.47 

3.14 

20.0 

2.605 

14.97 

106 

22.2 

32.4 

67.6 

64.8 

2.80 

50.52 

29 

9.5 

2.71 

87.2 

36.8 

3.65 

1.18 

10.5 

day 

min 

yr 

day 

day 

hr 

min 

yr 

hr 

min 

min 

hr 

min 

day 

hr 

day 

yr 

hr 

hr 

day 

min 

hr 

hr 

hr 

Ingestion 

(water) 

LIE 

8. IE 

8. IE 

6.7E 

1.2E 

4.0E 

4.0E 

LIE 

LIE 

LIE 

5.4E 

5.4E 

5.4E 

8. IE 

1.1E 

1.3E 

8. IE 

5.4E 

8. IE 

4.6E 

3. IE 

5.4E 

2.3E 

4.6E 

3 

4 

2 

2 

3 

3 

4 

2* 

3 

4 

4 

3 

5 

3 

5 

3 

1 

3 

3 

2 # 

3 # 

2 # 

3 # 

2 # 

Inhalation 

3.6E 

1.0E 

1.0E 

4.7E 

4.7E 

4. IE 

4. IE 

3. IE 

2.6E 

5.2E 

4. IE 

2. IE 

3. IE 

1.0E 

5.2E 

5.2E 

2. IE 

2. IE 

3.6E 

2. IE 

5.2E 

1.0E 

4.7E 

5.2E 

2 

5 

1* 

1 

2* 

3 

4 

2 

3 

3 

4 

3 

5 

3 

4 

1* 

0* 

3 

3 

1* 

5 

5 

5 

4 

Direct 

Exposure 

1.4E 

5.IE 

2.2E 

1.3E 

1.4E 

7. IE 

1.4E 

--

8.8E 

4.4E 

2.9E 

1.0E 

1.9E 

7. IE 

LIE 

4.4E 

--

3.7E 

2.7E 

--

2.9E 

LIE 

6.8E 

9.3E 

1* 

1* 

1 

1* 

3 

1* 

2* 

0* 

1* 

1* 

2* 

2* 

1* 

2* 

6 

1* 

1* 

1* 

2* 

1* 

1* 

Proposed 

RQ (Ci) 

10 

10 

10 

10 

100 

10 

100 

100 

1 

10 

10 

100 

100 

10 

100 

10 

1 

10 

10 

10 

10 

100 

10 

10 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.71 

Radionuclide 

Tantalum-176 

Tantalum-177 

Tantalum-178 

Tantalum-179 

Tantalum-180m 

Tantalum-180 

Tantalum-182m 

Tantalum-182 

Tantalum-183 

Tantalum-184 

Tantalum-185 

Tantalum-186 

Technetium-93m 

Technetium-93 

Technetium-94m 

Technetium-94 

Technetium-96m 

Technetium-96 

Technetium-97m 

Technetium-97 

Technetium-98 

Technetium-99m 

Technetium-99 

Technetium-101 

Atom. 

No. 

73 

73 

73 

73 

73 

73 

73 

73 

73 

73 

73 

73 

43 

43 

43 

43 

43 

43 

43 

43 

43 

43 

43 

43 

Half-Life 

8.08 hr 

2.36 day 

9.3 min 

1.82 yr 

8.15 hr 

IE 13 yr 

15.9 min 

114.5 day 

5.1 day 

8.7 hr 

49 min 

10.5 min 

43 min 

2.83 hr 

52 min 

4.88 hr 

52 min 

4.3 day 

90 day 

2.6E 6 yr 

4.2E 6 yr 

6.01 hr 

2.13E 5 yr 

14.2 min 

Ingestion 

(water) 

3. IE 

7.7E 

1.5E 

1.5E 

1.5E 

7.7E 

1.5E 

6. IE 

6.9E 

1.5E 

2.3E 

3.8E 

5.4E 

2.3E 

1.5E 

6.9E 

1.5E 

1.5E 

3.8E 

3. IE 

7.7E 

6. IE 

3. IE 

6.9E 

2 # 

2*# 

3 # 

3*# 

3*# 

1*# 

4 # 

1 # 

1*# 

2 # 

3 # 

3 # 

3 

3 

3 

2 

4 

2 

2* 

3* 

1 

3 

2* 

3 

Inhalation 

5.2E 

1.0E 

3.6E 

4.7E 

3. IE 

1.0E 

2. IE 

5.2E 

5.2E 

2.6E 

3. IE 

1.0E 

1.0E 

3.6E 

2. IE 

1.0E 

1.0E 

1.0E 

5.2E 

3. IE 

• 1.6E 

1.0E 

3.6E 

1.6E 

4 

5 

5 

3 

5 

2 

6 

2 

3 

4 

5 

6 

5 

4 

4 

4 

5 

3 

2 

3 

2 

5 

2 

5 

Direct 

Exposure 

2.6E 

2.4E 

5.3E 

--

6.7E 

--

1.8E 

3.0E 

1.7E 

2.4E 

3.3E 

2.9E 

5.0E 

2.4E 

1.9E 

1.4E 

2.5E 

1.5E 

1.2E 

--

2.6E 

2.9E 

--

1.1E 

1* 

3 

2* 

3 

2* 

1* 

2 

1* 

2* 

1* 

1* 

1* 

1* 

1* 

3* 

1* 

5 

1* 

2* 

2* 

Proposed 

RQ (Ci) 

10 

100 

100 

1000 

1000 

10 

100 

10 

10 

10 

100 

10 

10 

10 

10 

10 

1000 

10 

100 

1000 

10 

100 

100 

100 
EXHIBIT 4-5 (Continued) 

- Release Values (Ci) 

Radionuclide 

Technetium-104 

Tellurium-116 

Tellurium-121m 

Tellurium-121 

Tellurium-123m 

Tellurium-123 

Tellurium-125m 

Tellurium-127m 

Tellurium-127 

Tellurium-129m 

Tellurium-129 

Tellurium-131m 

Tellurium-131 

Tellurium-132 

Tellurium-133m 

Tellurium-133 

Tellurium-134 

Terbium-147 

Terbium-149 

Terbium-150 

Terbium-151 

Terbium-153 

Terbium-154 

Terbium-155 

Atom. 

. No. 

43 

52 

52 

52 

52 

52 

52 

52 

52 

52 

52 

52 

52 

52 

52 

52 

52 

65 

65 

65 

65 

65 

65 

65 

Half-Life 

18.3 min 

2.5 hr 

154 day 

16.8 day 

119.7 day 

1.3E 13 yr 

58 day 

109 day 

9.5 hr 

33.4 day 

69.5 min 

32.4 hr 

25.0 min 

78.2 hr 

55.4 min 

12.5 min 

42 min 

1.8 hr 

4.15 hr 

3.3 hr 

17.6 hr 

2.34 day 

22 hr 

5.3 day 

Ingestion 

(water) 

1.5E, 3 

LIE 4 

6.7E 2 

4.0E 3 

8. IE 2" 

6.7E 2 

1.3E 3 

8. IE 2 

9.4E 3* 

6.7E 2 

4.0E 4 

4.0E 2 

4.0E 3 

2.7E 2 

4.0E 3 

1.3E 4 

2.7E 4 

1.2E 5 

6.7E 4 

6.7E 4 

5.4E 4 

6.7E 4 

2.7E 4 

8. IE 4 

Inhalation 

3.6E 

1.0E 

1.0E 

1.6E 

1.0E 

1.0E 

2.IE 

1.6E 

1.0E 

1.0E 

3. IE 

2. IE 

2.6E 

1.0E 

2.6E 

1.0E 

1.0E 

1.6E 

3.6E 

1.0E 

4.7E 

3.6E 

2. IE 

4. IE 

4 

4 

2* 

3 

2* 

2* 

2* 

2* 

4 

2* 

4 

2 

3 

2* 

3 

4 

4 

4 

2 

4 

3 

3 

3 

3 

Direct 

Exposure 

2.4E 

6.IE 

1.8E 

6.5E 

2.7E 

--

LIE 

5.IE 

1.0E 

7.8E 

7.6E 

3. IE 

1.0E 

1.8E 

3.6E 

4.3E 

4.4E 

2. IE 

4.2E 

4.4E 

5.5E 

2.6E 

2.2E 

4.2E 

1* 

2* 

2 

1* 

2 

5 

5 

5 

2 

2* 

1* 

2* 

2 

2* 

1* 

1* 

1* 

1* 

1* 

1* 

2* 

1* 

2* 

Proposed 

RQ (Ci) 

10 

100 

100 

10 

100 

100 

100 

100 

1000 

100 

100 

10 

100 

100 

100 

10 

10 

10 

10 

10 

10 

100 

10 

100 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.73 

Radionuclide 

Terbium-156m 

(5.0 hr) 

Terbium-156m 

(24.4 hr) 

Terbium-156 

Terbium-157 

Terbium-158 

Terbium-160 

Terbium-161 

Thallium-194m 

Thallium-194 

Thallium-195 

Thallium-197 

Thallium-198m 

Thallium-198 

Thallium-199 

Thallium-200 

Thallium-201 

Thallium-202 

Thallium-204 

Thorium-226 

Thorium-227 

Thorium-228 

Thoriiim-229 

Thorium-230 

Atom. 

No. 

65 

65 

65 

65 

65 

65 

65 

81 

81 

81 

81 

81 

81 

81 

81 

81 

81 

81 

90 

90 

90 

90 

90 

Half-Life 

5.0 hr 

24 hr 

5.3 day 

150 yr 

1.2E 3 yr 

72.4 day 

6.91 day 

32.8 min 

33 min 

1.13 hr 

2.83 hr 

1.87 hr 

5.3 hr 

7.4 hr 

1.09 day 

3.05 day 

12.23 day 

3.78 yr 

31 min 

18.72 day 

1.913 yr 

7300 yr 

7.54E 4 yr 

Ingestion 

(water) 

2.7E 

9.4E 

1.3E 

6.7E 

1.3E 

LIE 

2.7E 

2.8E 

1.7E 

3.3E 

3.9E 

1.7E 

1.1E 

3.3E 

4.4E 

LIE 

2.2E 

LIE 

1.3E 

2.7E 

1.6E 

1.6E 

1.1E 

5 

4 

4 

5 

4 

4 

4 

3 

4 

3 

3 

3 

3 

3 

2 

3* 

2 

2* 

5 

3 

2 

1 

2 

Inhalation 

1.6E 4* 

4.IE 3* 

5.2E 2 

1.6E 2* 

1.0E 1* 

1.0E 2 

1.0E 3* 

1.0E 5 

3. IE 5 

5.2E 4 

5.2E 4 

2.6E 4 

1.6E 4 

4. IE 4 

5.2E 3 

1.0E 4 

2.6E 3 

1.0E 3 

5.2E 2* 

1.6E 0* 

5.2E-2* 

4.7E-3* 

3.1E-2* 

Direct 

Exposure 

4. IE 4 

--

2.3E 1* 

--

4.9E 1 

3.4E 1* 

4.9E 3 

1.8E 1* 

5.IE 1* 

5.6E 1* 

1.4E 2* 

3.4E 1* 

2.5E 1* 

2.3E 2* 

3.4E 1* 

1.8E 3 

9.0E 1* 

--

5.4E 3 

4.4E 2 

--

--

_ _ 

Proposed 

RQ (Ci) 

1000 

1000 

10 

100 

10 

10 

1000 

10 

10 

10 

100 

10 

10 

100 

10 

1000 

10 

100 

100 

1 

0.01 

0.001 

0.01 
P.74 

I 

t 

EXHIBIT 4-5 (Continued) 

•- Release Values (Ci) 

Radionuclide 

Thorium-231 

Thorium-232 

Thorium-234 

Thulium-162 

Thulium-166 

Thulium-167 

Thulium-170 

Thulium-X171 

Thulium-172 

Thulium-173 

Thulium-175 

Tin-110 

Tin-Ill 

Tin-113 

Tin-117m 

Tin-119m 

Tin-121ra 

Tin-121 

Tin-123m 

Tin-123 

Tin-125 

Tin-126 

Tin-127 

Tin-128 

Atom. 

No. 

90 

90 

90 

69 

69 

69 

69 

69 

69 

69 

69 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

Half-Life 

25.2 hr 

1.4E 10 yr 

24.10 

21.7 

7.70 

9.25 

128.6 

1.92 

63.6 

8.24 

15.2 

4.0 

35.3 

115.1 

13.6 

293 

55 

27.0 

40.1 

129.2 

9.4 

IE 5 

2.1 

59.1 

day 

min 

hr 

day 

day 

yr 

hr 

hr 

min 

hr 

min 

day 

day 

day 

yr 

hr 

min 

day 

day 

yr 

hr 

min 

Ingestion 

(water) 

LIE 

1.9E 

8. IE 

5.4E 

3. IE 

1.5E 

6. IE 

7.7E 

5.4E 

3. IE 

5.4E 

5.4E 

9.4E 

2.7E 

2.7E 

4.0E 

4.0E 

8. IE 

6.7E 

6.7E 

5.4E 

4.0E 

9.4E 

1.2E 

5 

1 

3 

3 # 

2 # 

2*# 

1*# 

2 # 

1*# 

2 # 

3 # 

3 

4 

3 

3 

3 

3 

3 

4 

2 

2 

2 

3 

4 

Inhalation 

3. IE 

5.2E1.0E 

1.6E 

5.2E 

1.0E 

1.0E 

1.6E 

5.2E 

5.2E 

1.6E 

5.2E 

1.0E 

2.6E 

5.2E 

5.2E 

2.6E 

5.2E 

5.2E 

1.0E 

2. IE 

3. IE 

1.0E 

1.6E 

4 

3* 

3* 

5 

3 

3 

2 

2* 

2 

3 

5 

3 

5 

2 

2 

2* 

2* 

3* 

4 

2* 

2 

1 

4 

4 

Direct 

Exposure 

4.4E 

7.3E 

6.9E 

4.7E 

1.9E 

3.9E 

1.3E 

--

LIE 

9.5E 

4.5E 

1.3E 

3.0E 

1.4E 

2.6E 

--

--

--

2.6E 

5.3E 

1.3E 

2.0E 

2.5E 

6.8E 

2* 

5 

3 

1* 

1* 

2 

4 

2 

1* 

1* 

2* 

2* 

2* 

2* 

2* 

3 

2* 

1* 

1* 

1* 

Proposed 

RQ (Ci) 

100 

0.001 

1000 

10 

10 

100 

10 

100 

10 

10 

10 

100 

100 

100 

100 

100 

100 

1000 

100 

100 

100 

10 

10 

10 
EXHIBIT 4-5 (Continued) 

•- Release Values (Ci) 

P.75 

Radionuclide 

Titanium-44 

Titanium-45 

Tungsten-176 

Tungsten-177 

Tungsten-178 

Tungsten-179 

Tungsten-181 

Tungsten-185 

Tungsten-187 

Tungsten-188 

Uranium-230 

Uranium-231 

Uranium-232 

Uranium-233 

Uranium-234 

Uranium-235 

Uranium-236 

Uranium-237 

Uranium-238 

Uranium-239 

Uranium-240 

Vanadium-47 

Vanadium-48 

Vanadium-49 

Atom. 

No. 

22 

22 

74 

74 

74 

74 

74 

74 

74 

74 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

23 

23 

23 

Half-Life 

47 yr 

3.078 hr 

2.5 hr 

2.21 hr 

21.5 day 

37.5 min 

121 day 

74.8 day 

23.9 hr 

69.4 day 

20.8 day 

4.2 day 

68.9 yr 

1.59E 5 yr 

2.45E 5 yr 

7.08E 8 yr 

2.34E 7 yr 

6.75 day 

4.46E 9 yr 

23.54 min 

14.1 hr 

31.3 min 

15.98 day 

331 day 

Ingestion 

(water) 

2.3E 1 # 

6.9E 2*# 

7.7E 2 # 

1.5E 3 # 

3.8E 2*# 

3.8E 4*# 

1.5E 3*# 

1.5E 2*# 

1.5E 2 # 

3.IE 1*# 

1.2E-1* 

1.2E 2* 

5.8E-2 

2.9E-1 

2.9E-1 

2.9E-1 

2.9E-1 

5.8E 1* 

2.9E-1 

2.0E 3* 

2.9E 1* 

2.3E 3*# 

4.6E 1 # 

5.4E 3*# 

Inhalation 

3.IE 0* 

1.6E 4 

2.6E 4 

4.7E 4 

1.0E 4 

1.0E 6 

1.6E 4 

3.6E 3 

4.7E 3 

5.2E 2 

1.6E 0 

2.6E 4 

4.1E-2* 

2.1E-1* 

2.1E-1* 

2.1E-1* 

2.1E-1* 

5.2E 3 

2.1E-1* 

1.0E 6 

1.0E 4 

4. IE 4 

3. IE 2 

1.0E 4 

Direct 

Exposure 

2.7E 2 

--

3.2E 2* 

7.6E 1* 

--

--

2.2E 5 

1.5E 6 

7.6E 1* 

2.2E 4 

4. IE 4 

4.9E 3 

--

1.9E 6 

7.5E 5 

2.7E 2 

1.6E 6 

6.8E 2 

--

8.3E 3 

--

LIE 4 

3.4E 1* 

Proposed 

RQ (Ci) 

1 

100 

100 

10 

100 

1000 

1000 

100 

10 

10 

0.1 

100 

0.01 

0.1 

0.1 

0.1 

0.1 

10 

0.1 

1000 

10 

1000 

10 

1000 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.76 

Radionuclide 

Xenon-120 

Xenon-121 

Xenon-122 

Xenon-123 

Xenon-125 

Xenon-127 

Xenon-129m 

Xenon-131m 

Xenon-133m 

Xenon-133 

Xenon-135ra 

Xenon-135 

Xenon-138 

Ytterbium-162 

Ytterbium-166 

Ytterbium-167 

Ytterbium-169 

Ytterbium-175 

Ytterbium-177 

Ytterbium-178 

Yttrium-86m 

Yttrium-86 

Yttrium-87 

Yttrium-88 

Atom. ' Ingestion Inha- Direct Proposed 

No. Half-Life (water) lation Exposure RQ (Ci) 

54 

54 

54 

54 

54 

54 

54 

54 

54 

54 

54 

54 

54 

70 

70 

70 

70 

70 

70 

70 

39 

39 

39 

39 

40 

39 

20.0 

2.0 

17.1 

36.341 

8.88 

11.92 

2.19 

5.25 

15.3 

9.10 

14.1 

18.9 

2.36 

17.5 

32.02 

4.19 

1.9 

1.23 

48 

14.74 

80.3 

106.61 

min 

min 

hr 

hr 

hr 

day 

day 

day 

day 

day 

min 

hr 

min 

min 

day 

min 

day 

day 

hr 

hr 

min 

hr 

hr 

day 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

5.4E 3 

7.7E 1 

2.3E 4 

# 

# 

# 

1.5E 2*# 

2.3E 2*# 

1.5E 3 # 

7.7E 2*# 

2.7E 5 

1.3E 4 

2.7E 4 

1.3E 4 

1 

1 

3 

3 

1 

2 

2 

2 

1 

1 

1 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

na 

6E 

.0E 

.6E 

.6E 

.6E 

6E 

.IE 

6E 

6E 

6E 

0E 

5 

3 

5 

2 

3 

4 

4 

4 

3 

3 

2 

9.9E 

2.0E 

6.9E 

6.0E 

2.0E 

9.9E 

2.0E 

4.0E 

9.9E 

9.9E 

8.9E 

9.9E 

4.0E 

4. IE 

3.7E 

2.6E 

1.9E 

9.9E 

2.5E 

--

1.9E 

1.4E 

4.6E 

1.4E 

1*4-

1*4-

2*4-

1*4-

2*4-

1*4-

3*4-

3*4-

2*4-

2*4-

1*4-

1*4-

1*4-

2* 

1* 

2* 

2 

2 

2* 

2* 

1* 

1* 

1* 

10 

10 

100 

10 

100 

10 

1000 

1000 

100 

100 

10 

10 

10 

100 

10 

100 

100 

100 

100 

100 

100 

10 

10 

10 
EXHIBIT 4-5 (Continued) 

Release Values (Ci) 

P.77 

Radionuclide 

Yttrium-90m 

Yttrium-90 

Yttrium-91m 

Yttrium-91 

Yttrium-92 

Yttrium-93 

Yttrium-94 

Yttrium-95 

Zinc-62 

Zinc-63 

Zinc-65 

Zinc-69m 

Zinc-69 

Zinc-71m 

Zinc-72 

Zirconium-86 

Zirconium-88 

Zirconium-89 

Zirconium-93 

Zirconium-95 

Zirconium-97 

Atom. 

No. 

39 

39 

39 

39 

39 

39 

39 

39 

30 

30 

30 

30 

30 

30 

30 

40 

40 

40 

40 

40 

40 

Half-Life 

3.19 hr 

64.0 hr 

49.7 min 

58.5 day 

3.54 hr 

10.2 hr 

18.7 min 

10.3 min 

9.26 hr 

38.1 min 

243.8 day 

13.8 hr 

57 min 

3.97 hr 

44 hr 

16.5 hr 

85 day 

78.4 hr 

1.5E 6 yr 

64.03 day 

16.8 hr 

Ingestion 

(water) 

LIE 

5.4E 

1.3E 

6.7E 

4.0E 

1.3E 

2.7E 

5.4E 

7.7E 

1.5E 

3. IE 

3. IE 

4.6E 

4.6E 

7.7E 

5.4E 

2.2E 

LIE 

5.4E 

5.4E 

3.2E 

5 

3 

6 

3 

4 

4 

5 

5 

1*# 

3 # 

1*# 

2 # 

3*# 

2 # " 

1*# 

4 

5 

5 

4 

4 

4 

Inhalation 

5.2E 

3. IE 

1.0E 

5.2E 

4. IE 

1.0E 

4. IE 

5.2E 

1.6E 

3.6E 

1.6E 

3.6E 

5.2E 

1.0E 

5.2E 

1.0E 

1.0E 

1.0E 

3. IE 

5.2E 

5.2E 

3 

2* 

5 

1* 

3 

3 

4 

4 

3 

4 

2 

3 

4 

4 

2 

3 

2 

3 

0* 

1 

2 

Direct 

Exposure 

5.7E 

6.9E 

1.0E 

1.5E 

4.4E 

2.6E 

3.2E 

1.2E 

2.7E 

6.4E 

8.7E 

LIE 

2.6E 

2.6E 

1.4E 

9.5E 

1.5E 

--

4.9E 

4.4E 

1* 

1* 

4 

2* 

2* 

1* 

1* 

2 

2* 

1 

1* 

7 

1* 

2 

2* 

1* 

2* 

1* 

1* 

Proposed 

RQ (Ci) 

10 

100 

10 

10 

100 

100 

10 

10 

10 

100 

10 

10 

1000 

10 

10 

100 

10 

100 

1 

10 . 

10 
P.78 

EXHIBIT 4-5 (Continued) 

FOOTNOTES 

* The asterisk indicates the lowest Release Value for the 

specific radionuclide; this value is used to determine the 

proposed RQ group. 

No gamma rays are emitted or the gamma rays which are 

emitted have gamma ray energies of less than 0.07 MeV and 

are strongly attenuated in air. No Release Value for the 

direct exposure pathway was calculated. 

+ The Release Value was calculated assuming submersion in a 

contaminated cloud. The Derived Air Concentration (DAC) is 

used to estimate the Release Value for the specific 

radionuclide. 

# The retardation factor, R>, is assumed to be equal to one 

(Rd = 1) . 

na An Annual Limit of Intake (ALI) for either ingestion or 

inhalation (or both) was unavailable for this radionuclide. 

E The exponent to the base 10. For example, 1.3E 2 is equal 

to 1.3 x 102 or 130. 

m Signifies a nuclear isomer which is a radionuclide in a 

higher energy metastable state relative to the parent 

isotope. 

SOURCES 

Handbook of Chemistry and Physics. Edition 67 (1986-1987), Weast, 

Robert c , CRC Press Inc., Boca Raton, Florida. 

Handbook of Chemistry and Physics. Edition 66 (1985-1986), Weast,-

Robert C., CRC Press Inc., Boca Raton, Florida. 

Handbook of Chemistry and Physics. Edition 63 (1982-1983), Weast, 

Robert C , CRC Press Inc., Boca Raton, Florida. 

"Table of Isotopes", Compiled by Russell L. Heath, Idaho National 

Engineering Laboratory, EG& G Idaho, Inc., Idaho Falls, Idaho. 
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The inhalation ALIs used in the calculations are taken directly from the 

ICRP's Publication 30.s Where more than one inhalation ALI was available 

for a particular radionuclide, the lowest value was used for the 

calculations. This approach assures that release of the radionuclide in its 

most hazardous chemical form is taken into consideration. The inhalation ALIs 

are derived for workers in nuclear facilities and are 10 times those 

recommended for adult members of the general public.6 To adjust the 

Commission's ALIs to reflect the more protective level of exposure to the 

general public, the Agency divided by 10. 

The release fraction, R, reflects the fraction of the radionuclide release 

that could become airborne and be of respirable size (10 microns in diameter 

or less). The Nuclear Regulatory Commission has developed methods for 

estimating release fractions for radionuclides under accident conditions.7 

A summary of these methods and a table of release fractions for those 

individual radionuclides with proposed RQs can be found in Appendix D of this 

report. 

The atmospheric relative concentration value (X/Q) used in the 

-13 calculations, 8.4 x 10 day/cubic cm, corresponds to the relative 

concentration, at ground level, 30 meters downwind from a ground-level release 

under stable (Class D) meteorological conditions. Class D meteorological 

conditions are considered "neutral."8 A ground-level release under Class D 

meteorological conditions leads to higher ground-level concentrations than 

would be the case for an above-ground release under more turbulent 

conditions. By using the higher, ground-level concentration, the derived 

Release Values are greater than would be the case if the Agency had used an 

above-ground concentration. Thus, the proposed RQs are based on a more 

protective release scenario. 

The Agency has chosen 30 meters as the distance from the release to the 

point of exposure because cordons around a release of a chemical hazardous 

5International Commission on Radiation Protection, Annals of the ICRP: 

Limits for Intakes of Radionuclides by Workers, ICRP Publication 30, Part 2, 

1980. 

6The ALIs developed by the ICRP are based on a dose-equivalent of 5 

rem. The Agency is developing the proposed RQs based on a dose-equivalent of 

0.5 rem or 500 millirem. The 500 millirem limit corresponds to the Federal 

Radiation Protection Guidance recommended annual exposure levels for the 

general public. 

7McGuire, S.A., A Regulatory Analysis on Emergency Preparedness for 

Fuel Cycle and Other Radioactive Materials Licenses, NUREG-1140, U.S. Nuclear 

Regulatory Commission. 

'Turner, D. Bruce, Workbook of Atmospheric Dispersion Estimates, EPA 

Office of Air Programs, 1970. 
P.81 

substance at a transportation incident are generally 30 meters in radius. At 

fixed facilities, the distance to unrestricted areas is likely to be greater 

than 30 meters, therefore, 30 meters will result in a conservative estimate 

for exposure. The Agency derived the value of X/Q for distances less than 100 

meters based on the dispersivity data presented in The Workbook of Atmospheric 

Dispersion Estimates. The X/Q values presented in the Workbook do not 

include data for distances less than 100 meters; therefore extrapolation is 

necessary. However, because the extrapolation from 100 meters to 30 meters 

may not be totally accurate, a more preferred method of determining a value 

for X/Q could not be identified. The Agency believes its evaluation of 

exposure via inhalation is conservative. A further explanation of atmospheric 

relative concentration values and its derivation can be found in Appendix E of 

this report and in the Workbook on Atmospheric Dispersion Estimates. 

The inhalation of toxic substances depends in an obvious manner on the 

breathing rate of individuals. For purposes of the Release Value 

calculations, the breathing rate of "Reference Man" is assumed to be 2.3 x 

10 cubic centimeters per day.' 

This exposure scenario is illustrated in Exhibit 4-1. The expression, 

shown in Equation (1), for determining the Release Value for the inhalation 

pathway can be simplified by substituting the following values into the 

equation: 

(X/Q) = 8.4 x IO"13; and 

BR = 2.3 x 107. 

By multipling the numbers in the denominator, Equation (1) simplifies to: 

(2) Inhalation Release Value = ALI (inhalation)/((193.2)*(R)) 

For each of the individual radionuclides for which the Agency is proposing RQ 

adjustments, the Release Values calculated for the inhalation pathway are 

presented at the end of this chapter in Exhibit 4-5. 

4.2.2 Release Values for the Ingestion Pathway 

Radionuclides can be ingested through the consumption of contaminated 

foodstuffs or contaminated drinking water. In the case of contaminated foodstuffs, radionuclides can reach humans through food crops, meat, and milk,10 

'Till, J.E., Meyer, H.R. (Editors), Radiological Assessment. A 

Textbook on Environmental Analysis, NUREG/CR-3332, U.S. Nuclear Regulatory 

Commission, 1983. 

10Nair, S., Models for the Evaluation of Ingestion Doses From the 

Consumption of Terrestrial Foods Following an Atmospheric Radioactive 

Release, Central Electricity Generating Board, Technology Planning and 

Research Division, Berkeley Nuclear Laboratories, England, 1984. 
P.82 

APPENDIX A 

EXISTING REQUIREMENTS TO REPORT RADIONUCLIDE RELEASES 

This appendix describes the radionuclide release reporting requirements 

and processes of the Nuclear Regulatory Commission, the Department of 

Transportation, the Department of Energy, and individual states. The Federal 

Radiological Emergency Response Plan is also briefly described. 

A . I NUCLEAR REGULATORY COMMISSION 

The Nuclear Regulatory Commission controls the handling of nuclear 

materials through an extensive licensing and regulatory program. This program 

includes several different requirements for responsible parties to immediately 

report releases of radionuclides. 

The extent of the Commission's regulatory jurisdiction is limited to 

certain types of nuclear materials and to certain parties who may handle these 

materials. First, the Commission only licenses source, byproduct, and special 

nuclear material as defined by the Atomic Energy Act. In general, the 

Commission does not license naturally occurring and accelerator-produced 

radioactive materials (NARM), although naturally occurring radioactive 

materials may be subject to Commission regulation when they are associated 

with source, byproduct or special nuclear material being used under an active 

license. Second, certain activities of the Department of Energy and the 

Department of Defense -- even though these activities involve source, 

byproduct, and special nuclear materials -- are exempt from Commission license 

requirements. 

Existing Commission requirements for licensees to report radionuclide 

releases immediately are described below. In addition to these requirements, 

the Commission has several other requirements to report within a specified 

time after a release, but not immediately (e.g., within 24 hours and within 30 

days). These "non-immediate" reporting requirements are not presented below 

because they are not substitutes for the immediate notification requirement in 

CERCLA's section 103. Once the Commission receives such release notifications 

it, among other things, oversees the licensee's response action, provides 

guidance and expertise, disseminates important information, and coordinates 

with other relevant agencies. The Commission does not have a budget to 

undertake active cleanup responses on its own. 

A. 1.1 Regulations 

Nuclear Regulatory Commission regulations in 10 CFR Part 20 set standards 

for protection against radiation and are applicable to all persons who 

receive, possess, use, or transfer any nuclear material licensed by the 

Commission. The following are immediate reporting requirements contained in 

the recently proposed revision of 10 CFR Part 20: 
P.83 

A-2 

• Each licensee shall report by telephone, immediately 

after its occurrence becomes known, any lost, stolen, or 

missing licensed material in such quantities and under 

such circumstances that it appears to the licensee that 

a substantial exposure could result to persons in 

unrestricted areas. Such reports shall be made either 

to the Commission's Operations Center or to the 

appropriate Commission Regional Office (10 CFR Section 

20.1201(a)). 

• Each licensee shall immediately report any event 

involving byproduct, source, or special nuclear material 

possessed by the licensee which may have caused or 

threatens to cause any of the following (10 CFR Section 

20.1202(a)): 

an individual to receive a deep dose-equivalent of 

25 rem or more, a dose-equivalent to the lens of the 

eye of 75 rem or more, or an absorbed dose to the 

skin or extremities of 250 rads or more; or 

the release of radioactive material, inside or 

outside of a restricted area, so that, had an 

individual been present for 24 hours: (1) the 

individual could have received an intake five times 

the occupational annual limit of intake; or (2) for 

certain licensees, the individual could have 

received an effective dose-equivalent of 5 rem in a 

year. 

Additional regulations of the Nuclear Regulatory Commission specifically 

applicable to the licensing of byproduct, source, and special nuclear material 

are given in 10 CFR Parts 30, 40, and 70, respectively. Each of these sets of 

regulations contain provisions for licensees to "promptly" report to the 

Commission any attempt to steal or unlawfully divert certain quantities of 

byproduct (tritium), source, or special nuclear material (10 CFR Sections 

30.55(c), 40.64(c), and 70.52(b)). Other immediate notification requirements 

in these regulations are: 

• When a well-logging source containing byproduct or 

special nuclear material becomes irretrievable in a 

well, the licensee shall notify the Commission of the 

circumstances of the loss by telephone (10 CFR Sections 

30.56(b) and 70.60(b)). 

• Each licensee shall report immediately by telephone 

and telegraph, mailgram or facsimile any case of 

accidental criticality1 and any loss, other than 

lAn unplanned, uncontrolled nuclear fission reaction. 

K 
A-3 

normal operating loss, of special nuclear material 

(Section 70.52(a)). 

A. 1.2 License Conditions 

The Nuclear Regulatory Commission has the authority to incorporate in any 

of its nuclear material licenses additional requirements and conditions as it 

deems necessary in order to protect public health and welfare and the 

environment. If appropriate, based on the particular circumstances involved, 

such license conditions may require additional reporting than explicitly 

called for in the regulations. Furthermore, because licensees are required 

(10 CFR Section 20.1(c)) to maintain radiation exposures and releases to the 

environment as low as reasonably achievable (ALARA), the Commission may 

establish reporting level triggers that are below those specified in 10 CFR 

Part 20. For example, 10 CFR Section 20.105(c) requires uranium fuel cycle 

facilities to comply with the offsite dose limit of 25 rem/year. If several 

years worth of monitoring data demonstrate, however, that a facility operates 

well below the 25 rem/year limit, the Commission typically imposes a license 

condition requiring notification of and response to environmental releases 

that may cause less than 25 rem/year. As another example, the Commission 

commonly requires a licensee to immediately report an environmental monitoring 

result that is some fraction of the release concentration allowed in the 

regulations. These additional reporting requirements specified through 

license conditions may vary substantially from one licensee to the next. 

A. 1.3" Radiological Contingency Plans 

The Nuclear Regulatory Commission has taken special steps to assure 

adequate accident response preparedness at licensed facilities that have the 

potential for accidents which could result in (1) offsite doses exceeding 1 

rem to the whole body, 5 rem to the thyroid or 3 rem to other critical 

organs,2 or (2) potentially serious radiation overexposures of workers from 

a nuclear criticality incident or from release of radioactive materials, or 

(3) chemical exposures which could impact radiological safety. The Commission 

identified 62 fuel cycle and radioactive materials licensees that meet these 

criteria, and required them to either submit radiological contingency plans or 

to lower the amount of nuclear material kept under their possession. About 

half the licensees submitted plans which, after meeting Commission approval, 

have been incorporated as a license requirement. The other half lowered their 

possession limit or surrendered their license. 

Radiological Contingency Plans incorporate specific provisions to be 

followed in the event of an accident, including steps to assure (1) that 

notifications are promptly made to federal, state, and local agencies, and (2) 

2Radiation doses of 1 rem to the whole body and 5 rem to the thyroid are 

the lowest protective action guides established by the EPA for triggering 

protective action in public areas following a radiation accident. See 

EPA-520/1-75-001, Draft Revision of June, 1980. 
P.85 

A-4 

that necessary recovery actions are taken in a timely fashion to return a 

plant to a safe condition following an accident. The plans specify what 

reports will be made to keep various government agencies, corporate 

management, and the public informed. Formal agreements between the licensee 

and offsite support organizations are also incorporated into the plans. 

The Commission is also in the process of evaluating the need for a new 

proposed rule to require additional emergency preparedness for certain 

licensees. The purpose of the rule, if proposed, would be to require those 

licensees who possess radioactive materials in large quantities to have 

additional emergency procedures for offsite releases. These procedures would 

include steps for notifying offsite authorities and the Commission in the 

event of emergency situations. 

A.2 DEPARTMENT OF TRANSPORTATION 

The Department of Transportation (DOT) is responsible for regulating 

safety in the transportation of all hazardous materials. Accordingly, DOT has 

promulgated the Hazardous Materials Regulations (49 CFR Parts 171-177) to 

govern the transportation of hazardous materials, including radioactive 

materials. DOT defines radioactive material as any material having a specific 

activity greater than 0.002 microcuries per gram. This broad definition 

includes source, byproduct, and special nuclear materials licensed by the 

Nuclear Regulatory Commission, as well as NARM which is outside of the 

Commission's regulatory jurisdiction. 

The DOT regulations are organized with requirements applicable to all 

modes of transportation in 49 CFR Part 171 and requirements applicable to 

specific transportation modes (e.g., rail, aircraft, ship, and highway) in 

subsequent parts. DOT's release reporting requirements applicable to all 

modes of transportation are: 

• At the earliest practicable moment, each carrier who 

transports hazardous materials shall give notice after 

each transportation incident involving the shipment of 

radioactive material in which fire, breakage, spillage, 

or suspected radioactive contamination occurs. This 

notice shall be given to the National Response Center by 

telephone, and each notice must provide information 

spelled out in the regulations (49 CFR Sections 

171.51(a) and (b)). 

• Each carrier making an immediate report in accordance 

with Section 171.15, just discussed, shall also submit 

to DOT (the Materials Transportation Bureau) a detailed 

incident report. This written report must be submitted 

within 15 days from the date of discovery of the 

incident (49 CFR Section 171.16). 

Additional reporting requirements specific to different transportation 

modes include requirements for carriers to immediately notify shippers of an 
P.86 

A-5 

incident in which there has been breakage, spillage, or suspected radioactive 

contamination. If an accident occurs during the shipment of radioactive 

materials by aircraft, the carrier is required to immediately notify the 

nearest FAA Civil Aviation Security Office by telephone (as specified in 49 

CFR Section 175.45). Fulfillment of this notification requirement exempts the 

carrier from having to notify the National Response Center. Additionally, in 

cases of obvious leakage of radioactive material aboard the aircraft, DOT 

regulations state the carrier should notify the Regional Office of the U.S. 

Department of Energy or the appropriate State or local radiological 

authorities (49 CFR Section 175.700(b)). For accidents involving radioactive 

materials onboard a vessel, the captain of the vessel is required to 

immediately notify the nearest Coast Guard Captain of the Port (49 CFR 

Sections 176.48(a) and (b)). 

According to a Memorandum of Understanding (MOU, 44 FR 38690-2) between 

DOT and the Nuclear Regulatory Commission, DOT will promptly notify the 

Commission of any accidents, incidents, and instances of actual or suspected 

leakage involving radioactive material packages if such an event occurs in 

transit. Also, DOT has the responsibility of encouraging the non-agreement 

states3 to impose incident reporting requirements for radioactive materials 

on shippers and receivers subject to the states' jurisdiction. 

A.3 DEPARTMENT OF ENERGY 

The Department of Energy (DOE) plays two entirely different roles in the 

area of radionuclide release reporting. First, DOE may be a releaser of 

radionuclides subject to reporting requirements. DOE controls many 

government-owned, contractor-operated facilities that may release 

radionuclides to the environment, including facilities engaged in research and 

development, nuclear weapons production, enrichment of uranium for nuclear 

reactors, and facilities that process, store, and dispose of radioactive 

waste. Many of the research facilities controlled by DOE are accelerators, 

which generate accelerator-produced radioisotopes (included under "NARM"). 

There are many established requirements for DOE to immediately report 

radionuclide releases. Many of these requirements are self-imposed, being 

spelled out in several different internal orders. DOE Order 5000.3 spells out 

the Department's system for reporting unusual occurrences, and Order 5484.1 

specifies DOE's reporting requirements for environmental and health protection 

information. These requirements typically call for individual facilities to 

report releases to a regional operations office, which may in turn report the 

release to DOE headquarters. Several different criteria for a variety of 

'Agreement states are those states which have entered into an agreement 

with the Atomic Energy Commission or the Nuclear Regulatory Commission 

pursuant to Section 274 of the Atomic Energy Act of 1954, as amended, under 

which the Commission has relinquished to such states the majority of its 

regulatory authority over source, byproduct and special nuclear material in 

quantities not sufficient to form a critical mass. 

i 
P.87 

A-6 

"occurrences" and "unusual occurrences" have been established to specify when 

reporting is required immediately. As a matter of policy, DOE also requires 

reporting to external organizations to keep them apprised of important events 

at DOE facilities. Externally-imposed reporting requirements include any of 

those specified by EPA and possibly state agencies. DOE is generally exempt 

from licensing by the Nuclear Regulatory Commission and is thus exempt from 

the Commission's reporting requirements highlighted above. 

The other role played by DOE in the event of radionuclide releases is to 

provide expertise, guidance, and assistance in response to radiological 

hazards created by others. In accordance with the Federal Radiological 

Monitoring and Assessment Plan (FRMAP), other parties requiring radiological 

assistance may contact DOE. The Department in turn will work with appropriate 

State and local agencies to coordinate offsite radiological monitoring and 

assessment data. DOE will assess radiological monitoring data and present 

them, along with recommendations, to the parties responsible for taking 

emergency or remedial action. 

A.4 STATE PROGRAMS 

States may be classified as either agreement states or non-agreement 

states. Agreement states are those who have entered into an agreement with 

the Nuclear Regulatory Commission giving the state most of the Commission's 

authority to license certain quantities of source, byproduct, and special 

nuclear material. There are presently 26 agreement states. Lists of 

Agreement and non-agreement states are contained in Exhibit A-1. 

Non-agreement states have not entered into such agreements with the 

Commission. Regulatory programs for radioactive material are not necessarily 

void in non-agreement states, but these states rely on the Commission to carry 

out its licensing program for source, byproduct, and special nuclear material 

within the state. 

State programs for regulating radioactive material, including requirements 

to report releases of radionuclides, differ greatly. All 26 agreement states 

have licensing programs covering NARM. In addition, the Commission has 

reported that out of the 24 non-agreement states, all but three have 

regulatory programs for NARM that are reported to be at least as stringent as 

the Nuclear Regulatory Commission's regulations in 10 CFR Part 20.k 

A.5 THE FEDERAL RADIOLOGICAL EMERGENCY RESPONSE PLAN 

On December 7, 1979, the President directed that the Federal Emergency 

Management Agency (FEMA) assume lead responsibility for all federal off-site 

nuclear emergency planning and response. Additionally, the President 

^Telephone communication between Barbara Hostage, EPA, and Lidia Roche, 

Nuclear Regulatory Commission. February 1985. There may actually only be two 

states which have no regulatory program covering NARM --no information has 

yet been obtained on the regulatory program in South Dakota. 
P.88 

A-7 

EXHIBIT A-1 

AGREEMENT STATES AND NON-AGREEMENT STATES 

NRC Agreement States 

Alabama 

Arizona 

Arkansas 

California 

Colorado 

Florida 

Georgia 

Idaho 

Kansas 

Kentucky 

Louisiana 

Maryland 

Mississippi 

Nebraska 

Nevada 

New Hampshire 

New Mexico 

New York 

. North Carolina 

North Dakota 

Oregon 

Rhode Island 

South Carolina 

Tennessee 

Texas 

Washington 

NRC Non-Agreement States 

Alaska 

Connecticut 

Delaware 

Hawaii 

Illinois 

Indiana 

Iowa 

Maine 

Massachusetts 

Michigan 

Minnesota 

Missouri 

Montana 

New Jersey 

Ohio 

Oklahoma 

Pennsylvania 

South Dakota 

Utah 

Vermont 

Virginia 

West Virginia 

Wisconsin 

Wyoming 

Source: U.S. Department of Energy, Radioactive Waste Management: 

of State Laws and Administration, December 1985. 

A Summary 
P.89 

A-8 

delegated to FEMA the responsibility for the development and promulgation of 

the National Radiological Emergency Preparedness/Response Plan for Commercial 

Nuclear Power Plant Accidents, also known as the Master Plan (45 FR 84910). 

This Master Plan has been superseded by the Federal Radiological Emergency 

Response Plan, or FRERP (50 FR 46542). The FRERP establishes formal roles and 

responsibilities for federal agencies in response to a wide range of peacetime 

radiological emergencies (e.g., fixed nuclear facility incidents, 

transportation incidents, and other types of events involving radionuclide 

releases). FEMA is responsible for coordinating non-technical responses under 

the FRERP, providing assistance to state and local governments, and providing 

logistic support to federal agencies. 

There are at least three important features of the FRERP that should be 

noted. First, the FRERP spells out a pre-established system for notifying all 

appropriate federal agencies of a radiological emergency. In general, the 

owner or operator of the facility (or vehicle) involved in an emergency is 

responsible for notifying the appropriate federal and state agencies. The 

federal agency that owns, regulates, or is otherwise responsible for the 

radiological activity is responsible for notifying FEMA headquarters which, in 

turn, verifies that the state has been notified and notifies other appropriate 

federal agencies. DOE is required to notify those agencies with monitoring 

and assessment responsibilities under the FRERP. In addition, the FRERP urges 

a continuous flow of information between federal and state authorities, and 

provides a mechanism for keeping the public informed. 

A second important- feature is that a radiological emergency initiating 

response under the FRERP is defined as any "type of radiological incident that 

poses an actual or potential hazard to public health or safety or loss of 

property." Therefore, action under the FRERP can be taken for releases of 

NARM as well as for releases of source, byproduct, and special nuclear 

material. Additionally, there is not a quantitative trigger level which must 

be met in order for the FRERP to be initiated. Third, the FRERP charges that 

owners or operators of an affected nuclear facility have primary 

responsibility for actions within the facility's boundaries, and that state 

and local governments have primary responsibility for action in areas outside 

of those boundaries. In general, federal resources are used to support state 

and local measures if requested. 
APPENDIX B 

SUMMARY OF COMMUNITY POTENTIALLY SUBJECT TO RADIONUCLIDE RQs 

Source Categories Number of Facilities 

Major Radionuclide 

of Concern Existing Regulations 

NRC Licensed Facilities 

- Power reactors ±/ 

- Research and Test Reactors 

Radiopharmaceutical Manufacturing 

Radiation Source Manufacturing 

Laboratories 

Waste Disposal Sites 

Mineral and Metal Processing 

Sites 

Fuel Cycle Facilities 

80 reactors 

70 reactors (as of 1983) 

argon-41, tritium 

argon-41, tritium 

26 industrial suppliers (in 1979) technetium-99m 

10,000 medical facilities (in 1977) iodine-131 

iod ine-125 

xenon-133 

NA 2/ 

1400 laboratorie s (estimated , 

1983) 

6 licensed (3 operational) 

10 licensed facilitie s 

varie s from sit e to 

sit e 

tritium , carbon-14 

xenon-133, iodine-125, 

iodine-131 

essentiall y al l except 

transuranic s and specia l nuclear material 

uranium and thorium 

2 operating UF6 conversion 

faci I itie s 

uranium 

16 uranium fue l fabricatio n plant s enriched uranium 

NRC, limit s fo r airborn e 

and liqui d discharges 

under 10 CFR Part 20, 

Appendix B, Table II . 

NRC, limit s fo r airborn e 

and liqui d discharges 

under 10 CFR Part 20, 

Appendix B, Table II . 

NRC or agreement states ; 

10 CFR sectio n 20.303 

governs releases to sanitar y sewage systems. 

NRC, 10 CFR Part 20. 

NRC, 10 CFR Part 20, 

Appendix B, Table II and 

release reporting requirements of Part 20. 

NRC, 10 CFR Parts 20 and 

61 

NRC, 10 CFR Parts 40 and 

20 

NRC, 10 CFR Parts 40 and 

20 

NRC, 10 CFR Parts 70 and 

20 

2/ Section 101(22)(c) of CERCLA excludes from the definition of release any releases of "source, byproduct, or 

special nuclear material from a nuclear incident, as those terms are defined in the Atomic Energy Act of 1954, if such 

release is subject to requirements with respect to financial protection established by the Nuclear Regulatory Commission 

under Section 170 of such Act .,.". 

2/ No information available. 

Source: ICF Incorporated, Economic Impact Analysis for the Proposed Reportable Quantity Adjustments for Radionuclides 

Under Section 102 of the Comprehensive Environmental Response. Compensation, and Liability Act. Appendix A, June 

1986. 
APPENDIX B (continued) 

SUMMARY OF COMMUNITY POTENTIALLY SUBJECT TO RADIONUCLIDE RQs 

Source Categories Number of Facilities 

Major Radionuclide 

of Concern Existing Regulations 

- DOD FaciI ities 

- Uranium Mi I Iing 

DOE FaciI ities 

- Weapons Production and Testing 

- Nuclear Materials Production 

- Physical Research 

- Uranium Enrichment Plants 

CoaI — Fired Boilers 

- UtiIity Boilers 

- IndustriaI Boilers 

Mineral Extraction Industry 

- Uranium Mining 

- Aluminum Industry 

- Copper Industry 

- Zinc Industry 

- Lead Industry 

- Phosphate Industry 

-- Phosphate Rock Processing 

13 facilities (including 9 Naval 

shipyards) 

3 active mills 

78 facilities (as of 1980) 

30 "active" DOE complexes (1982) 

30 facilities (as of 1986) 

4 active facilities (as of 1982) 

4 active facilities (1982) 

2 active facilities (1986) 

1,881 units (1985) 

51,187 units (1981) 

argon-41, nitrogen-13 , 

oxygen-15, carbon-14 

uranium, radon-222, 

thorium 

essent iaIl y al l 

rad ionuclides 

uranium 

uranium-238 

thorium-232 

181 mines (21 activ e mines) (1985) radon-222, uranium, 

thorium 

32 operating smelters (1980) 

15 operating smelters 

5 operating facilitie s 

5 smelters/refinin g complexes 

20 firm s wit h 31 plant s (1983) 

radon-222 

radon-222 

radon-222 

uranium-238 

thorium-232 

uranium and thorium 

uranium and it s decay 

products phosphate 

rock dust, lead-210, 

and polonium-210 

NRC, Army Regulation 

385-11, Chapter 5; Army 

Technical Manual 3-261 

NRC, 10 CFR Part 20 

DOE Orders 5480.1 , 

5484.1 , 5000.3, 5820.2, 

5480.14 and othe r order s 

Not regulated under 

NESHAPs (50 FR 5190) 

NESHAPs (50 FR 15386) for 

underground mines 

NSPS and SIP Iim its for 

meeting Ambient Air 

Qua Iity Standards 

NSPS and SIPs 

NSPS and SIPs 

NSPS and SIPs 

NSPS and SIPs 

Elemental Phosphorus Plants 4 firms with 6 plants NESHAPs (50 FR 5190) 
P.92 _ 

APPENDIX C 

OTHER METHODS FOR CALCULATING RQs 

EPA has examined several methods for calculating RQs. These include 

using Maximum Permissible Concentrations (MPCs), Limiting Possession 

Limits (LPLs), and the perferred method using Annual Limits of Intake 

(ALIs). ALIs are examined in the body of this report, vhile the other 

methods using MPCs and LPLs are discussed here. 

C l MAXIMUM PERMISSIBLE CONCENTRATIONS (MPCs) 

The development of MPCs for the general public vas based on Maximum 

Permissible Body Burdens (MPBBs) set at one-tenth of the MPBBs for 

occupational exposure. MPCs and MPBBs are calculated folloving a 1959 

International Commission on Radiation Protection model. 

MPC tables vere prepared by the Nuclear Regulatory Commission (10 CFR 

Part 20) to establish guidelines for radionuclide exposure for both 

employees of nuclear facilities and for the general public. These MPCs, 

in units of microcuries per milliliter, can be related to RQs in curies 

by imposing a set of hypothetical release conditions and introducing a 

time factor. One possible equation is shovn belov: 

RQ(MPC) = ((MPC)*(T))/((R)*(X/Q)*(1 x IO6) 

vhere: 

T = Time factor (1 year) 

1.Report of Committee II on Permissible Dose for Internal Radiation, ICRP 

Publication 2, Pergammon Press, Oxford, 1959. 

C-l 
'.93 

The Release fraction. This relates the portions of inventories 

of radioactive materials that could become airborn in a release. 

,2 Release fractions have been reported in 

calculations done here, R is taken as unity. 

NUREG-1140* For 

X/Q = Atmospheric Relative Concentration Value (Chi over Q). This 

value corresponds to a ground level relative concentration at 30 

meters from a ground level release under stable (class D) 

-15 -3 atmospheric conditions (2.3 x 10 yr-cm ). A further 

explanation of this term can be found in Appendix E. 

1 x 10 is a factor of one-million to convert microcuries to curies. 

In the MPC approach outlined above, the doses are based on the critical 

organ only and no dose conversion factors for other organs are included. 

This approach considers only inhalation of radionuclides and does not 

consider ingestion or submersion in an airborne cloud. Other 

modifications taking ingestion and submersion into account could be 

developed. Exhibit C-l presents a fev RQs calculated by this method 

(RQ(MPC)). 

C.2 LIMITING POSSESSION LIMIT (LPLs) 

Limiting Possession Limits vere developed by the Nuclear Regulatory 

3 

Commission in NUREG-0767 to determine the maximum amount of a particular 

radionuclide that a facility regulated by the Nuclear Regulatory 

Commission could have on hand at any time that vould be subject to a 

release. Inhalation vas considered the critical pathvay except for those 

radionuclides in vhich submersion in an airborne cloud vas the acute 

2.McGuire, S.A., A Regulatory Analysis on Emergency Preparedness for Fuel 

Cycle and Other Radioactive Materials Licensees, NUREG-1140, U.S. 

Nuclear Regulatory Commission. 

3.Fisher, F.A., Criteria for Selection of Fuel Cycle and Major Materials 

Licensees Needing Radiological Contingency Plans, NUREG-0767, U.S. 

Nuclear Regulatory Commission. 

C-2 
P.94 

exposure pathvay. The original formula used by the Nuclear Regulatory 

Commission to calculate the LPLs is as follovs: 

LPL = (Dn)/((DCFn)*(R)*(I)) 

vhere: 

Dn = Doses requiring protective actions (rem). Set at 5 rem for 

employees at a nuclear facility and 500 millirem for members of 

the general public. 

DCFn = The inhalation dose conversion factor for the limiting body 

organ. 

R = Release Fraction. This relates the portion of inventories of 

radioactive materials that could become airborne in a release. 

For calculations done here, the release fraction is taken as 

unity. 

I = Intercept fraction. That portion of the release that could be 

inhaled by an individual. 

The limiting possession limits defined above can be converted to RQs by 

applying factors similar to those used for MPCs. These include 

developing a set of release conditions and determining an atmospheric 

relative concentration value based on them and applying a factor for 

vhole body submersion in an airborne cloud of radioactive material. An 

equation that has been used for calculating RQs based on LPLs is shovn 

belov: 

(Dn) RQ(LPL) = 

(lE9)*(R)*(X/Q)*[(DCFVBS)+(Z(Vt)*(DCFt)*(BR))J 

t 

vhere: 

DCFVBS = Dose conversion factor for vhole body submersion. 

Vt = Weighting factor for tissue. 

4.Background Document to Support the Notice of Proposed Rulemaking 

Pursuant to CERCLA Section 102(b). Supplementary Report: 

Radionuclides. Draft, 24 September 1982. Environmental Monitoring and 

Services Center. 

C-3 
P.95 

DCFt » Dose conversion factor for tissue. 

9 

BR = Breathing rate (8.4 x 10 cubic cm per year). 

9 

1E9 = 1 x 10 . A factor of one-billion composed of one-thousand 

for converting millirem to rem and one-million for 

conversion of microcuries to curies. 

This approach takes into account both submersion in an airborne cloud of 

radionuclide (DCFVBS) and a summation of effects for a variety of 

individual organs (Vt*DCFt). Exhibit C-l presents a fev RQs calculated 

by this method (RQ(LPL)). 

C-4 
EXHIBIT C-l 

RQs CALCULATED FROM MPCs AND LPLs 

P.96 

Radionuclide MPC"' 

(uCi/ml) 

LPL" 

(Ci) 

RQ(MPC) 

(Ci) 

RQ(LPL) 

(Ci) 

Tritium 

Argon-41 

Calcium-45 

Cobalt-60 

Krypton-85 

Strontium-90 

Iodine-131 

Xenon-133 

Cesium-137 

Uranium-235 

Uranium-238 

Plutonium-238 

Plutonium-239 

Americium-241 

2 x 10 

4 x 10 

1 x 10 

3 x 10 

3 x 10 

3 x 10 

1 x 10 

3 x 10 

5 x 10 

4 x 10 

3 x 10 

7 x 10 

6 x 10 

2 x 10 

-8 

-9 

-10 

-7 

-11 

-1 

-7 

-7 

-12 

-12 

-14 

-14 

-12 

6000 

a 

800 

4000 

7000 

25 

3.3 

10000 

600 

_a 

a 

0.1 

0.1 

0.3 

117.4 

17.4 

0.43 

0.13 

130.4 

0.013 

0.043 

130.4 

0.22 

0.002 

0.001 

0.00003 

0.00003 

0.0009 

345 

a 

4.5 

0.14 

17700 

0.027 

0.88 

1140 

0.81 

a 

a 

0.0001 

0.0001 

0.00005 

a) No LPL listed in NUREG-0767 

i>. 10 CFR Part 20. 

6. op. cit., NUREG 0767. 

C-5 
P.97 

APPENDIX D 

RELEASE FRACTIONS FOR INHALATION 

The releaes fraction, R, reflects the fraction of a radionuclide 

release that could become airborne and be of respirable size (10 

microns in diameter or less). The Nuclear Regulatory Commission 

has developed release fractions for radionuclides under accident 

conditions . 

Isotopes of the noble gases argon, krypton and xenon have have 

assigned release fractions of 1.0 because they are always gases 

at room temperature, remain mixed with air, and do not react 

chemically to form less volatile compounds. The Nuclear 

Regulatory Commission has assigned a release fraction of 0.5 to 

compounds of hydrogen, carbon, phosphorous, sulfur, and iodine. 

Compounds of these . elements would be expected to produce less 

than 100 percent volatilized and respirable particles or gases 

for the following reasons: (1) some of the compounds of the 

-elements will settle out on surfaces and not be released to 

atmosphere, and (2) some particles found in the release may not 

be respirable. 

Compounds of the elements selenium, mercury, cesium, polonium, 

bromine, tellurium, and ruthenium, among others are only 

semi-volatile and have been assigned release fractions of 0.01. 

Release fractions for non-volatile metals such as uranium, 

plutonium, tantalum, thorium, and americium, among others, have 

been set at 0.001. For these metals or compounds of these 

metals, the release pathway is not volatilization but entrainment 

1. McGuire, S.A. A Regulatory Analysis on Emergency 

Preparedness for Fuel Cycle and Other Radioactive Material 

Licensees. NUREG-1140, June 1985. 

D-l 
P.98 

of the particles in an air stream. Even finely ground powders 

will generally contain less than a few percent of the powder in 

respirable size. The fraction of particles of respirable size is 

kept small by the difficulty in producing small particles and 

subsequently by agglomeration and weathering, processes which 

cause micron-sized particles to stick to surfaces, to larger 

particles and to themselves. 

Releae fractions for the various elements may be found in Exhibit 

D-l. The inhalation releaes fractions were taken from 

NUREG-1140. -Where release fractions for specific isotopes are 

shown in NUREG-1140, these were used for all isotopes of the 

element. Where NUREG-1140 does not show a release fraction for a 

specific element or isotope, the release fractions were derived 

by reference to statements at the end of the table recommending a 

release fraction of 0.01 for "any other beta-gamma emitter" and a 

release fraction of 0.001 for "any other alpha•emitter." Radon 

is the single exception to this rule. Radon is not only a noble 

gas falling immediately below xenon in the periodic table, but 

the isotopes considered by the ICRP in Publication 30, radon-220 

and radon-222, are alpha emitters. A release fraction of one was 

assigned to radon because of its similarity to argon, krypton and 

xenon even though it is not listed in NUREG-1140 and its isotopes 

are alpha emitters. This conservative assumption decreases the 

inhalation Releaes Value, and thus the RQ, by a factor of 

one-thousand below that which would have been calculated had the 

radon isotopes been assigned a release fraction of 0.001 based on 

alpha emission. 

D-2 
P.99 

EXHIBIT D-l 

INHALATION RELEASE FRACTIONS" 

Actinium 

Aluminum 

Americium 

Antimony 

Argon 

Arsenic 

Astatine 

Barium 

Berkelium 

(249 & 250) 

Beryllium 

Bismuth 

Bromine 

Cadmium 

Calcium 

Californium 

Carbon 

Cerium 

Cesium 

Chlorine 

Chromium 

Cobalt 

Copper 

Curium 

Dysprosium 

Einsteinium 

(254m) 

Erbium 

Europium 

Fermium 

Ac 

Al 

Am 

Sb 

Ar 

As 

At 

Ba 

Bk 

Be 

Bi 

Br 

Cd 

Ca 

Cf 

C 

Ce 

Cs 

Cl 

Cr 

Co 

Cu 

Cm 

Dy 

Es 

Er 

Eu 

Fm 

Rel. Frac. 

Inhalation 

0.00 1 

0.01 * 

0.00 1 

0.0 1 

1.0 

0.01 * 

0.001* * 

0.0 1 

0.001* * 

0.01 * 

0.01 * 

- 0.0 1 

0.01 * 

0.0 1 

0.0 1 

0.00 1 

0 . 5 

0.0 1 

0.0 1 

0.0 1 

0.0 1 

0.00 1 

0.0 1 

0.00 1 

0.01 * 

0.001 * 

0.01 * 

0.01 * 

0.0 1 

0.001* * 

D-3 
EXHIBIT D-l (Cont.) 

p.1 

Fluorine 

Francium 

Gadolinium 

Gallium 

Germanium 

Gold 

Hafnium 

Holmium 

Hydrogen 

Indium 

Iodine 

Iridium 

Iron 

Krypton 

Lanthanum 

Lead 

Lutetium 

Magnesium 

Manganese 

Mandelevium 

Mercury 

Molybdenum 

Neodymium 

Neptunium 

Nickel 

Niobium 

Osmium 

Palladium 

F 

Fr 

Gd 

Ga 

Ge 

Au 

Hf 

Ho 

H 

In 

I 

Ir 

Fe 

Kr 

La 

Pb 

Lu 

Mg 

Mn 

Md 

Hg 

Mo 

Nd 

Np 

Ni 

Nb 

Os 

Pd 

Rel . Frac. 

Inhalation 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

1 

0 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

0. 

.01* 

.01* 

.01 

.01* 

.01 

.01 

.01 

.01 

.5 

.01 

.5 

.001 

.01 

0 

.01* 

01 

01* 

01* 

01 

001** 

01 

01 

01* 

001 

01 

01 

01* 

01* 

D-4 
EXHIBIT D-l (Cont.) 

P.2 

Rel. Frac. 

Inhalation 

Phosphorus 

Platinum 

Plutonium 

Polonium 

Potassium 

Praseodymium 

Promethium 

Protactinium 

Radium 

Radon 

Rhenium 

Rhodium 

Rubidium 

Ruthenium 

Samarium 

Scandium 

Selenium 

Silicon 

Silver 

Sodium 

Strontium 

Sulfur 

Tantalum 

Technetium 

Tellurium 

Terbium 

Thallium 

Thorium 

Thulium 

P 

Pt 

Pu 

Po 

K 

Pr 

Pm 

Pa 

Ra 

Rn 

Re 

Rh 

Rb 

Ru 

Sm 

Sc 

Se 

Si 

Ag 

Na 

Sr 

S 

Ta 

Tc 

Te 

Tb 

Tl 

Th 

Tut 

0.5 

0.01* 

0.001 

0.01 

0.01 

0.01* 

0.01 

0.001 

0.001 

1.0 

0.-01* 

0.01* 

0.01 

0.01 

0.01 

0.01 

0.01 

0.01* 

0.01 

0.01 

0.01 

0.5 

0.001 

0.01 

0.01 

0.01 

0.01 

0.001 

0.01 

D-5 
EXHIBIT D-l (Cont.) 

P.3 

Rel. Frac. 

Inhalation 

Tin 

Titanium 

Tungsten 

Uranium 

Vanadium 

Xenon 

Ytterbium 

Yttrium 

Zinc 

Zirconium 

Sn 

Ti 

W 

U 

V 

Xe 

Yb 

Y 

Zn 

Zr 

0.01 

0.01 

0.01 

O.001 

0.01 

1.0 

0.01 

0.01 

o.oi 

0.01 

Indicates that the release fraction is based on 

NUREG-1140 statement "any other beta-gamma emitter." 

the 

** Indicates that the release fraction is based 

NUREG-1140 statement "any other alpha emitter." 

on the 

1. McGuire, S.A., A Regulatory Analysis on Emergency 

Preparedness for Fuel Cycle and Other Radioactive Material 

Liecensees, NUREG-1140. 

D-6 

J 
P.4 

APPENDIX E 

DERIVATION OF THE ATMOSPHERIC RELATIVE 

CONCENTRATION VALUE (X/Q) 

In the calculation of reportable quantities for radionuclides 

using ALIs, MPCs or LPLs and considering the inhalation route, it 

has been necessary to use the equations developed for atmospheric 

modeling, especially those involving atmospheric dispersion 

estimates, in order to estimate the fraction of a release which 

might be encountered by an individual. 

The information needed from atmospheric modeling in the 

calculation of RQs by the above methods is summarized in the 

atmospheric relative concentration value, Chi over Q (X/Q). The 

appropriate value for X/Q can be found from Exhibit E-l, which is 

an extrapolation of the graph in Exhibit E-2. Exhibit E-2 plots 

Xu/Q per square meter versus distance from the source in 

kilometers for releases varying in height from ground level (the 

uppermost line in the plot) to a height of 300 meters. The 

symbol u in Xu/Q stands for wind speed in meters per second. 

Xu/Q is plotted so that the plot can be applied to any wind speed 

simply by dividing the value found in the plot by the desired 

wind speed. In the present case, a wind speed of 1 meter per 

second is used and X/Q in seconds per cubic meter is found. 

For the purposes of calculating RQs, some conservative 

assumptions in deriving X/Q have been made. These assumptions 

include: 

1. Turner, D. Bruce, Workbook of Atmospheric Dispersion 

Estimates. EPA Office of Air Programs, 1970. 

E-l 
P.5 

•e.l 

— o.oi 

— o-.ooi 

1.0 o.i 

Distance Fran Source (tan.) 

0.01 

0.0001 

EXHIBIT E- l -

 X/Q Vs- Distance for a Ground Level Release, Stability Class D. 

E-2 
P.6 

Xu/Q m 

•? 

100 

DISTANCE, km 

EXHIBIT E-2 Xu/Q Vs. Distance at Various Heights (H) of Release (meters), 

Stability Class D. 

E-3 
P.7 

1. The distance from the release to the point of exposure 

is 3 0 meters (about 100 feet). This distance is chosen 

because cordons around a release of a chemical 

hazardous substance are generally 3 0 meters in radius. 

Therefore, barriers around a release of a radionuclide 

in a restricted area would likely be set up at least 

this distance from the release. In addition, it is 

assumed that a gaussian distribution of contaminant is 

established almost immediately within the plume and is 

fully developed at 30 meters. 

2. The release occurs at ground level. This approach 

gives the highest ground level concentrations and the 

lowest RQs. 

3. The point of exposure is directly downwind from the 

release in stable (Class D) atmospheric conditions and 

the wind speed (u) is 1 meter per second. 

4. The material evolved in the release is a stable gas or 

aerosol (less than 20 microns in diameter) which 

remains suspended in air for long periods of time. 

5. The gas or aerosol is continuously emitted from the 

source or the emission time is equal to or greater than 

the travel time to the point of exposure. In this 

case, it is possible to omit from consideration 

diffusion in the direction of transport. The equations 

used to produce the graphs in Exhibits E-l and E-2 are 

valid only if diffusion in this direction is assumed be 

be zero. This is a reasonable assumption because the 

rate of diffusion in this direction would be much 

smaller than the wind speed of 1 meter per second. 

6. None of the material emitted is removed from the plume 

as it moves downwind and there is complete reflection 

from the ground. 

Bearing this in mind and referring to Exhibit E-l, it is possible 

-2 to obtain a X/Q of 7.2 x 10 seconds per cubic meter. Because a 

breathing rate in units of cubic centimeters per day is being 

used it is necessary to convert X/Q to compatible units. This 

-13 leads to a value of 8.4 x 10 day per cubic centimeter, the 

value used in this report. 

E-4 

J 
P.8 

If, instead of extrapolating down to 30 meters, the value for one 

hundred meters (ground level release) is chosen, X/Q becomes 9.5 

x 10 day per cubic centimeter. This value is almost (but not 

quite) an order of magnitude smaller than the 30 meter value and 

would lead to RQs nearly a factor of ten higher. Exhibit E-2 

also shows values for plume heights greater than ground level (H 

= 10 to H = 3 00 meters). Plume heights are not necessarily the 

same as the stack height and are affected by phenomena such as 

inversion layers, wind speeds, and the velocity of stack ejecta. 

In any case, it is clear from Exhibit E-2 that if RQs were to be 

calculated on the basis of a release from above ground level, 

they would be much larger. For example, in the case of a release 

20 meters above ground, the calculated X/Q is approximately 1 x 

— 17 

10 day per cubic centimeter at one hundred meters, a factor 

nearly ten thousand times smaller than that for a ground level 

release. If calculated at 350 meters (the point of maximum 

concentration according to Exhibit E-2) the value would be 3.5 x 

10 day per cubic centimeter, a value more than 200 times 

smaller than the value in current use. 

The graphs shown in Exhibits E-l and E-2 and used for the 

determination of X/Q are generated from the equations for 

atmospheric modeling and are intended to simplify the task of 

determining X/Q. The generally accepted expression for the 

concentration, X (chi), of gas or aerosols at x,y,z from a 

continuous source with an effective emission height, H, is given 

in the equation below. The coordinate system referred to can be 

found in Exhibit E-3. 

X(x,y,z;H) = ; exp 

2 ir a O u 

y z mnyn-ym 

E-5 
i 

(0,0,0) 

tK-y,Z ) 

(x.-y,0) 

EXHIBIT l:-3. Coordinate System for Atmospheric Modeling Showing Gaussian Distributions 

in the Horizontal and Vertical. 
P.10 

where: 

3 X = chi, concentration (Curies/m ) ; 

x,y,z = positions in the coordinate system (see Exhibit 

E-3); 

Q = release rate (curies/sec); 

7r = pi (3.14159, approximately) ; 

a = horizontal dispersivity (meters); 

a = vertical dispersivity (meters); 

u = wind speed (meters per second); 

exp = exp (-a/b) = e^~ay ' where e is the base of 

natural logarithms and is approximately equal to 

2.7183; and 

H = the effective emission height (meters). 

Several assumptions are made concerning the hypothetical release 

which result in the simplification of Equation 1. These 

simplifications are shown below. 

For concentrations calculated at ground level for a ground levei 

release (i.e., z = 0) the equation simplifies to: 

Q 

X(x,y,0;H) = exp 

TT ayazu iyih KT)'] 'm 

Where the concentration is to be calculated along the centerline 

of the plume giving the maximum concentration (i.e., y = 0) 

further simplification results: 

X(x,0,0;H) = exp 

ir a a u 

y z 

["&-)'] 

(3) 

E-7 
P.11 

For ground level source with no effective plume rise (i.e., H = 

0 ) , the equation simplifies even further: 

Q 

X(x,0,0;0) = = r4v 

y z 

The values for dispersion in the y and z directions ( a and a ) 

vary with the turbulent structure of the atmosphere, height above 

the surface, surface roughness, sampling time over which the 

concentration is to be estimated, wind speed, and distance from 

the source. Values for a and a are estimated for each 

atmospheric stability class, which include an estimated wind 

speed. Stability class D, used here, assumes a light wind in 

overcast conditions during either day or night, using Stability 

Class D results in higher concentrations and lower RQs than would 

more turbulent stability classifications. The estimates for 

horizontal and vertical dispersion coefficients can be found in 

. . . 2 

the Workbook of Atmospheric Dispersion Estimates. Rearranging 

Equation 4, above, as shown, and applying.values for. o and a_ 

y *. 

from the graph in Exhibit E-4 yields, 

1 

7 

y z 

Xu/Q = = = 7.5x1 0 m 

TOO U"(2.6)(1.65) 

2 -2 (5 ) 

Division of both sides of the equation by a wind speed, u, of 1 

meter per second gives: 

X/Q = 7.5 x IO"2 sec m"3 (6) 

Considering the possibilities for error introduced in 

extrapolation, this value agrees very well with the value found 

-2 -3 

by reference to Exhibit E-l (7.2 x 10 sec m ) . 

2. Turner, D. Bruce, Workbook of Atmospheric Dispersion 

Estimates, EPA Office of Air Programs, 1970. 

E-8 
P.12 

100 

1000 100 

Distance Downwind, aeter s 

EXHIBIT E-4 - Horizontal and Vertical Dispersion Coefficient as a Function 

of Downwind Distance Frcm the Source. 

E-9 
P.13 

APPENDIX F 

ROUTES FOR INGESTION OF RADIONUCLIDES 

Two pathways are available for the ingestion of radionuclides 

leading to exposure to the gastrointestinal tract and, through 

transfer to the blood stream and deposition in other organs, 

exposure to the remainder of the body. These two pathways are 

consumption of contaminated drinking water and consumption of 

contaminated foodstuffs. Because each is a likely source of 

radionuclide ingestion, the Agency reviewed ground-water, 

surface-water, and foodstuff ingestion to determine which is the 

most critical pathway. The methods for modeling ground-water 

contamination are discussed in section F.l, while the methods for 

modeling surface-water contamination and food crop contamination 

are presented in sections F.2 and F.3, respectively. 

F.l GROUND-WATER TRANSPORT OF RADIONUCLIDES. 

Two ground-water models, the advection-dispersion model and the 

simple dilution model, were examined in some detail by the Agency 

while four other models developed for specialized purposes within 

the Resource Conservation and Recovery Act (RCRA) were reviewed. 

These models are described below. 

F.l.l The Advection-Dispersion Model. 

The calculation of a dilution factor for a radionuclide released 

to ground water can be accomplished by assuming a release 

scenario that is reasonably conservative. In this calculation 

F-1 
P.14 

it is assumed that the release is directly to ground water, which 

is a conservative assumption because it neglects migration 

through the unsaturated zone. The following assumptions are 

also made: 

1. Flow is uniform and steady (V =0.5 meter/day). 

2. The aquifer is homogeneous and isotropic. 

3. The release is an instantaneous point source to the 

saturated zone. 

4. At time zero, the concentration of radionuclide in the 

aquifer is zero. 

5. The aquifer is of finite thickness and infinite extent 

(there are no boundaries close enough to affect the 

transport). 

6. Radioactive decay is neglected (i.e., X= 0). 

7. The drinking water well is located 30 meters down 

gradient from the point of release. 

For an instantaneous point source located on the z axis in 

uniform steady flow (Exhibit F-1), the emalytical solution of 

the transport equation is : 

C= Ji exp -fixrUtl2 + y2 + z2 + \t" 

(4 t)3/2(ExEyE2)

1/2Rdn [ 4Ext 4Eyt 4Ezt 

where: M = magnitude of the instantaneous release (1 Ci); 

R. = retardation factor; 

n = effective porosity (0.1); 

(1) 

l.Carlsaw, H., Jaeger, J., Conduction of Heat in Solids. 

Oxford University Press, London, 1959. 

F-2 
P.15 

EXHIBIT F-1 

Scenario for Calculation of Ground-Wattr Transport 

sioc view 

s*.*,*..*,**.....***************..*.. 

y 

Well 

'''''"'-' ' 

19999999*9 999999999999999 "W* ^ • ^ ^ 

J0« 

P\JM Vlf W 

Point J 

tt rolotto ' 

/ 

Plum* •! time 

orottor than tare 

( 

Woll 

F-3 
P.16 

\ «= radioactive decay constant (0) ; 

t = time of travel from source to well 

, (t = 30/(Vx/(nRd)); 

C = maximum radionuclide concentration; 

and E , E , E , R,, and U are defined as: 

E x = Dxx/Rd; E y = D yy/ V Ez = D zZ /R d; 

U = Vx/nRd; Rd = 1 + (Pb)*(Kd/n); 

where: 

D = longitudinal coefficient of dispersion; 

D = Dz z = transverse coefficients of dispersion; 

Pb = bulk density of the aquifer (1.5 gm/cm3); 

V = flow of the aquifer (0.5 meters per day). This 

value was chosen as a conservative flow rate for 

sand containing aquifers2by comparison to Table B-2 

in the report referenced . This table lists 45 

different saturated zone layers that contain sand at 

varying concentrations. The smallest flow listed is 

0.7 meters/year, while the largest is greater -than 

10,000 meters/year. The average flow is 625 

meters/year or about 1.7 meter/day. A value of 0.5 

meters/day is conservative in that it prolongs 

contact time and leads to a lower (more 

conservative) Release Value; and 

Kd = the sorption coefficient in cm /g (see Exhibit F-2 

for a compilation of these values). 

Dispersion coefficients are defined by the following equations: 

Dxx " <a i)*(Vn >' Dyy - Dzz = (*t>*<Vn>' 

where: 

a, = longitudinal dispersivity (20 meters); 

at = transverse dispersivity (4 meters). 

2. Liner Location Risk and Cost Analysis Model. Draft Report 

under Contract No. 68-01-6621, Office of Solid Waste, EPA, 

January, 1985. 

F-4 
P.17 

^_w 

ELEMENT 

Actinium 

• Aluminum 

• Americium 

_ Antimony 

| Argon 

Arsenic 

• Astatine 

Barium 

• Berkelium 

• Beryllium 

— Bismuth 

| Bromine 

.Cadmium 

I Calcium 

Californium 

• Carbon 

• Cerium 

— Cesium 

| Chlorine 

Chromium 

• Cobalt 

Copper 

• Curium 

B Dysprosium 

• Einsteinium 

Erbium 

• Europium 

Ac 

Al 

Am 

Sb 

Ar 

As 

At 

Ba 

Bk 

Be 

Bi 

Br 

Cd 

Ca 

Cf 

C 

Ce 

Cs 

Cl 

Cr 

Co 

Cu 

Cm 

Dy 

Es 

Er 

Eu 

EXHIBIT F-2 

SORPTION COEFFICIENT VALUES 

SORPTION 

COEFFICIENT. K^* 

1000 

0 

1000 

1 

0 

0 

0 

100 

700 

75 

10 

0 

50-100 

15 

0 

0 

2000 

2000 

0 

0 

2000 

0 

500 

0 

0 

0 

500 

F-5 

SOURCE 

EPA 520/4-79-007C 

Assumption** 

Hajek(1966), Knoll(1965)(1969) 

EPA 520/6-78-007 

EPA 520/4-79-007C 

Assumption** 

EPA 520/4-79-007C 

Analogous to Sr (PNWL 8/2/86) 

EPA 520/4-79-007C 

EPA 520/4-79-007C 

EPA 520/4-79-007C 

Assumption** 

"Estimate (PNWL 8/18/86) 

EPA 520/4-79-007C 

Assumption** 

Estimate (PNWL, 8/18/86) 

Rhodes(1957) Benson(1960) 

Letter Report RJS-ARCHO 

EPA 520/4-79-007C 

Assumption** 

EPA 520/6-78-007 

Assumption** 

EPA 520/6-78-007, Sheppard 

(1976) 

Assumption** 

Assumption** 

Assumption** 

Seme & Rai (1976) 
P.18 

ELEMENT 

Fermium 

Fluorine 

Francium 

Gadolinium 

Gallium 

Germanium 

Gold 

Hafnium 

Holmium 

Hydrogen 

Indium 

Iodine 

Iridium 

Iron 

Krypton. 

Lanthanum 

Lead 

Lutetium 

Magnesium 

Manganese 

Mandelevium 

Mercury 

Molybdenum 

Neodymium 

Neptunium 

Nickel 

Niobium 

Osmium 

Palladium 

Phosphorus 

Fm 

F 

Fr 

Gd 

Ga 

Ge 

Au 

Hf 

Ho 

H 

In 

I 

Ir 

Fe 

Kr 

La 

Pb 

Lu 

Mg 

Mn 

Md 

Hg 

Mo 

Nd 

Np 

Ni 

Nb 

Os 

Pd 

P 

SORPTION 

COEFFICIENT. K^* 

0 

0 

200 

500-1000 

0 

0 

0 

0 

600 

0 

0 

3 

0 

150 

0 

0 

.4000 

0 

0 

0 

0 

0 

5 

500 

10 

100 

2000 

0 

50-100 

0 

SOURCE 

Assumption** 

Assumption** 

EPA 520/4-79-007C 

Chemical Analogy to Rare Earth 

(PNWL 8/18/86) 

Assumption** 

Assumption** 

Assumption** 

Assumption** 

EPA 520/4-79-007C 

EPA 520/6-78-007 

Assumption** 

Shallow Land Burial Program 

Assumption** 

EPA 520/4-79-007C 

Inert Gas (PNWL 8/18/86.) 

Assumption** 

EPA 520/4-79-007C 

Assumption** 

Assumption** 

Assumption** 

Assumption** 

Assumption** 

EPA 520/4-79-007C 

Chemical Analog to Rare Earth 

(PNWL 8/18/86) 

Routson et al 1975,76, Sheppard 

(1976) 

Estimate (PNWL 8/18/86) 

EPA 520/4-79-007C 

Assumption** 

Estimate (PNWL 8/18/86) 

Assumption** 

F-6 
P.19 

ELEMENT 

Platinum 

Plutonium 

Polonium 

Potassium 

Praseodymium 

Promethium 

Protactinium 

Radium 

Radon 

Rhenium 

Rhodium 

Rubidium 

Ruthenium 

Samarium 

Scandium 

Selenium 

Silicon 

Silver 

Sodium 

Strontium 

Sulfur 

Tantalum 

Technetium 

Tellurium 

Terbium 

Pt 

Pu 

Po 

K 

Pr 

Pm 

Pa 

Ra 

Rn 

Re 

Rh 

Rb 

Ru 

Sm 

Sc 

Se 

Si 

Ag 

Na 

Sr 

S 

Ta 

Tc 

Te 

Tb 

SORPTION 

COEFFICIENT. 

0 

100-10000 

25 

35 

500-1000 

1000-10000 

4000 

100-10000 

0 

0 

0 

500 

0-500 

500-1000 

0 

10 

0 

50-100 

10 

100 

0 

0 

0 

50-100 

500-1000 

V SOURCE 

Assumption** 

EPA 520/6-78-007, A Shallow Land 

Burial Program 

EPA 520/4-79-007C 

EPA 520/4-79-007C 

Chemical Analogy to Rare Earth 

(PNWL 8/18/86) 

Benson(1960) Rare Earth 

EPA 520/4-79-007C 

EPA 520/6-78-007 

EPA 520/4-79-007C 

Assumption** 

Assumption** 

Chemical Analogy to Cs 

(PNWL 8/18/86) 

Rhodes (1957) 

Chemical Analogy to Rare Earth 

(PNWL 8/18/86) 

Assumption** 

Shallow Land Burial Program 

Assumption** 

Estimate (PNWL 8/18/86) 

EPA 520/4-79-007C 

Shallow Land Burial Program 

Letter Report RJS-ARCHO 

Assumption** 

Assumption** 

Shallow Land Burial Program 

Estimate (PNWL 8/18/86) 

Chemical Analogy to Rare Earth 

(PNWL 8/18/86) 

F-7 
P.20 

SORPTION 

ELEMEN 

Thallium 

Thorium 

Thulium 

Tin 

Titanium 

Tungsten 

Uranium 

Vanadium 

Xenon 

Ytterbium 

Yttrium 

Zinc 

Zirconium 

T 

Tl 

Th 

Tm 

Sn 

Ti 

W 

U 

V 

Xe 

Yb 

Y 

Zn 

Zr 

COEFFICIENT. K 

2 

1000-10000 

0 

50-100 

0 

0 

1-50 

0 

0 

0 

500 

0 

2000 

SOURCE 

EPA 520/4-79-007C 

EPA 520/6-78-007 

Assumption** 

Estimate (PNWL 8/18/86) 

Assumption** 

Assumption** 

Estimate (PNWL 8/18/86) 

Assumption** 

Inert Gas (PNWL 8/18/86) 

Assumption** 

Estimate (PNWL 8/18/86) 

Assumption** 

Rhodes (1957) 

* For sorption coefficient values that are given in ranges, the 

lowest sorption coefficient was chosen for the ingestion 

Release Value calculation. 

** For these elements no K, value has been obtained and a 

sorption coefficient of zero (Kd=0) was assumed (no 

retardation). 

Bensen, D. W. 1960. 

Hanford. HW-67201. 

SOURCES 

Review of Soil Chemistry Research at 

Environmental Protection Agency Rep. EPA 520/6-78-007. Ames, L. 

L. and Dhanpat Rai, "Radionuclide Interactions with Soil and Rock 

Media. 

Environmental Protection Agency Rep. EPA 520/4-79-007C. 

Technical Support of Standards for High Level Radioactive Waste 

Management, Vol. C, Migration Pathways, 1979. 

F-8 
P.21 

Hajek, B. F. 1966. Plutonium and Americium Mobility in Soils. 

BNWL-CC-925. 

Knoll, K. C. 1965. Reaction of High Salt Aqueous Plus Organic 

Waste vith Soil. BNWL-CC-313. 

Knoll, K. C. 1969. Reactions of Organic Wastes in Soils. 

BNWL-860. 

Letter Report R. J. Seme - ARCHO 6/5/75, a letter written to 

Atlantic Richfield Hanford Company by W. Martin reporting some, 

at that time, new laboratory data. 

PNWL 8/18/86, Letter from Martin, W. to EMSI 8/18/86, reporting 

estimates of K, for a Generic Sandy Sediment. 

Rhodes, D. W. 1957. The Effect of pH on the Uptake of 

Radioactive Isotopes from Solution by a Soil. Soil Science 

Society of America Proceedings, 21:389-392. 

Routson, R. C , G. Jansen, and A. V. Robinson. 1976. 99 

237 Tc, 

No 241 *' and Am Sorption on Two Subsoils from Differing 

Weathering Intensity Areas. BNWL-2000. Pt. 2, pp. 50-52. 

Seme, R. J. and Dhanpat Rai. 1976. Adsorption-Precipitation 

Behavior of Eu in Soils and Standard Clays. Agronomy Abstracts, 

p. 132. 

Shallow Land Burial Program - as yet unpublished results obtained 

on an ongoing DOE sponsored program. 

Sheppard, J. C., J. A. Kittrick, T. L. Hart. 1976. 

"Determination of Distribution Ratios and Diffusion Coefficients 

of Neptunium, Americium, and Curium in Soil-Aquatic 

Environments," RL0-221-T-12-2. 

F-9 
P.22 

For afc = 20 meters, a, =» 4 meters, n = 0.1, and M = 1 curie, the 

maximum concentration at the well is: 

C = 1 (5) 

(120 7T)3/2(20)1/2(4)(0.1)(Rd)(lxlO3 liters/m3) 

C = 7.6 x 10"8Ci-liters"VRd. (6) 

Equation 6 gives the amount of dilution for a one curie release 

into an aquifer. The dilution factor (DF) for the aquifer is, 

therefore, defined as: 

DF = 7.6 x 10~8 liters"1/^* (7) 

The value of the retardation factor will affect not only the 

maximum concentration of the radionuclides found in the plume 

developed by the release but also the time required for the plume 

to reach and pass the well. 

For radionuclides with a sorption coefficient of zero (K. = 0) 

and a retardation factor of one (Rd=l), the concentration in the 

plume varies as a gaussian distribution along all three axes (two 

horizontal, one vertical) of the ellipsoidal plume. The total 

quantity of radionuclide released in the plume is 1 curie (which 

was the amount of the instantaneous release). The concentration 

in the well will increase from zero to a maximum of 7.6 x 10~8 

curies per liter then decrease to zero again as the plume passes. 

To arrive at the exact time it takes the plume to pass the well 

it is necessary to define the concentration at the boundary of 

the plume because, theoretically, the plume extends to infinity 

with an infinitely small concentration at that distance. The 

time that it takes for the plume to pass the well can be 

estimated in two ways. First, we can conclude that the maximum 

amount of time necessary for the plume to pass the well is twelve 

F-ll 
P.23 

days (assuming that the first arrival of the plume was 

instantaneous, 6 days to reach the centroid and another 6 days to 

reach the trailing edge). The second, and more accurate approach, 

is to use the ratio of dispersivities which must be the same as 

the ratio of the axes of the ellipsoidal plume. Assuming 

constant concentration in the plume and using the expression for 

the volume of an ellipsoid, it follows that: 

1 Ci - (4/3)*(7T)*(a)*(b)*(c)*(7.6 x io"5) (8) 

where: a, b and c are the major and minor axes of the ellipsoid 

and are related in the same ratio as the dispersivities: 

a/b = a/c =

 a i /a ^ = 20/4 =5 . 

Therefore, 

b = a/5, c = a/5, 

and 

1 •- (4/3)*(7T)*(a3/25)*(7.6 x io"5) . . - (9) 

Solving for a gives: 

a = 43 meters, 

and the time required for the ellipsoidal plume to pass the well 

is given by: 

Contact Time (CT) - a/(Vx/n) = 9 days. (10) 

It can therefore be assumed that a plume with a constant concentration of 7.6 x 10 ci/liter passes the well in approximately 9 

days. Using these figures, an ingestion Release Value (RV) in 

curies can be calculated from an ALI in microcuries. 

F-12 
P.24 

RV = ALI/((10)*(DF)*(WC)*(CT)*(lxl06)). (11) 

Where: 

ALI = Annual Limits of Intake for ingestion 

(microcuries); 

DF = dilution factor (liters ); 

WC = water consumption rate of "Reference Man" (2 

liters/day); 

CT = contact time (days); 

10 converts the 5 rem occupational exposure limit to 

the more conservative 0.5 rem exposure limit for 

the general public; and 

1 .x 10 converts microcuries to curies. 

Substituting the values for . DF, WC, and CT gives the following 

expression for the ingestion Release Value: 

RV = ALI/13.68. (12) 

As sorption coefficients rise above about 4 (Kd>4), the time 

necessary for a radionuclide to reach and pass a well 30 meters 

from the point of release becomes greater than 365 days, thus 

increasing the contact time. Because ALI's deal with annual 

limits of intake it is not necessary to use contact times greater 

than one year and the contact time for all radionuclides with 

sorption coefficients of 4 or greater were taken to be 3 65 days. 

Under these circumstances ingestion Release Values are calculated 

as follows: 

F-13 
P.25 

RV = ALI/((10)*(7.6 x IO"8 liters"1/^)* (2 liter/day) 

*(365 day)*(l x IO6 uCi/Ci)); 

(13) 

RV = ((ALI)*(Rd))/555. (14) 

It is important to note that the use of retardation factors (R.) 

in the calculation of the Release Value introduces some inherent 

uncertainties particularly with respect to the sorption 

coefficients (K.) used to calculate retardation factors. These 

uncertainties in K. values include: (1) the two test methods 

used to evaluate Kd for a given element in the laboratory often 

yield different values for the same soil material, (2) variations 

in the soil type affect K. values (the aquifer modelled assumed 

sandy soils and sorption coefficients for sandy soils were used 

here), (3) there appears to be no general agreement in the 

scientific community on the "correct" values for sorption 

coefficients regardless of the soil type. 

It has been brought to the Agency's attention that solubility 

data might be. used independent of or in conjunction with 

retardation factors in order to calculate ingestion Release 

Values. Although solubilities of nearly every compound of nearly 

every element in the periodic table are available in the 

literature, it does not appear possible to define a "typical" 

solubility for each radionuclide in their wide variety of 

chemical forms. Calculating a Release Value for each possible 

chemical form of each radionuclide would lead to a plethora of 

Release Values. Choosing the lowest Release Value among the 

different chemical forms of a particular radionuclide in order to 

be conservative would be equivalent to choosing the most soluble 

compound, and in the majority of cases, produce a Release Value 

unchanged from that found ignoring solubility considerations. 

Additionally, the solubility of most compounds in water 

(purified, pH = 7) is greater than the concentrations calculated 

by the ground-water transport equation leading to a situation in 

which the amount of material soluble in water would almost always 

F-14 
P.26 

be greater than the amount required to deliver an ALI. 

F.l.2 The Simple Dilution Model. 

The Nuclear Regulatory Commission has suggested a simple dilution 

model for the calculation of Release Values based on ground-water 

transport. This model was developed in order to determine the 

maximum concentrations for on-site disposal of low level nuclear 

waste and to identify sites suitable for the disposal of nuclear 

waste. The Commission's goal in both these cases is to minimize 

the risk to the public for exposure via the ground water to 

releases of radioactive material. Although this approach may be 

appropriate for the minimization of risk, it appears 

inappropriate for the determination of RQs which simply act as 

triggers for notification of a release of a hazardous substance. 

Some of the assumptions made by the Nuclear Regulatory Commission 

for their calculations using the simple dilution model are shown 

below. 

1. Ground-water flow rates are between 0.0005 and 0.03 

meters/day. 

2. Longitudinal dispersivities are between 0.05 and 0.1 

meter. 

3. Transverse dispersivities are zero. 

4. Pumping rates can vary between 7700 cubic meters/year and 

2,000,000 cubic meters/year. The former figure is 

preferred by the Commission because it represents the 

minimum practical needs of a single person in a rural 

area. 

. 5 

5. Water consumption is 2 liters/day for an individual . 

5. Oztunali, O.I., Roles, C.W., DeMinimis Waste Impacts 

Analysis Methodology. NUREG/CR-3585, February, 1984. 

F-15 
P.27 

Using these assumptions, the aquifer resembles a very slow 

flowing pipeline between the point of release and the well. The 

flow occurs at such a rate that the entirety of the release is 

pumped from the well over a period of one year. The contact time 

(CT) is, therefore, 365 days. The dilution factor (DF) is 

calculated below: 

DF = 1/7700 m3 - 1.3 x 10~4 m~3 = 1.3 x 10~7 liter"1 (15) 

Using these figures, a Release Value (RV) in curies can be 

calculated from an ALI in microcuries. 

RV • ALI/((10)*(1.3 x 10~7/liter)*(2 liter/day)*(365 day)* (16) 

(1 x 106uCi/Ci)). 

RV = ALI/949. (17) 

Release Values for ingestion calculated in this way would be 

about 70 times smaller than those calculated by the 

advection-dispersion model in the case where sorption 

coefficients (K.) are equal to zero. 

F.l.3 Other Ground-Water Models. 

The EPA's Office of Solid Waste has developed several 

ground-water models which have found application in analyses 

developed for the Resource Conservation and Recovery Act (RCRA). 

Although other models have been developed within RCRA, the 

following four have been analyzed and compared to those used for 

the development of RQs based on a ground-water ingestion 

model: 

o The Comparative Risk Assessment Model (CRAM) used to 

compare the human health risks and costs of various 

combinations of hazardous waste streams, environmental 

settings, and waste treatment technologies; 

o The Liner-Location Risk and Cost Analysis Model used to 

estimate the human health risks of land disposal 

F-16 
P.28 

facilities of different designs in different 

environmental settings; 

o The Threshold Model used in determining the need to ban 

or restrict hazardous waste from land disposal; and 

o The Vertical and Horizontal Spread (VHS) Model used in 

analyzing ground-water transport issues associated with 

delisting petitions (i.e., petitions to remove a 

substance from RCRA's hazardous substance list). 

The following discussion compares those four RCRA models to the 

RQ ground-water model in terms of: (1) the basic equations used 

in each model; and (2) values for the input variables used in the 

equations. 

F.l.3.1 Comparison of Model Equations. 

All simple ground-water transport models — including the 

transport models used in the RQ adjustment methodology, the CRAM, 

the Liner Location Model, the Threshold Model, and the VHS Model 

— are based on the same laws of physics and, as such, are based 

on transport Equation 1. The only difference in the models' 

equations is the release scenario used in developing the 

analytical solution to the transport equation. These release 

scenarios vary in two respects. First, the configuration of 

the contaminant source can vary; it can be a point source, a 

line source, or a plane source. Second, the 

contaminant that is being modeled can be released in different 

time frames; it can be released instantaneously, continuously, or 

at a variable rate. Everything else being equal, all of the 

ground-water models considered here will give different results 

only because their equations are based on different source 

configurations and different contaminant release rates. The 

source configuration and contaminant release rates assumed in 

each of the models are shown in Exhibit F-3. 

F-17 
P.29 

EXHIBIT F-3 

SOURCE CONFIGURATIONS AND CONTAMINANT RELEASE 

RATES ASSUMED IN THE RCRA AND RQ MODEL EQUATIONS 

Model 

Contaminant Source 

Configuration 

Contaminant 

Release Rates 

RQ Model 

CRAM 

Liner-Location Model 

Threshold Model 

VHS Model 

point source 

point source 

plane source 

plane source 

plane source 

instantaneous release 

continuous release 

time variable release 

time variable release 

(Gaussian) 

continuous release 

Source: ICF Analysis 

F-18 
P.30 

The selection of instantaneous release for the RQ model was based 

on the consideration that the highest ground-water concentration 

will be achieved when the source is released instantaneously 

rather than continuously or at some variable rate. For example, 

a well 30 meters downgradient from the point of release would 

experience a higher concentration of radioactivity if 1 curie was 

released all at once rather than a little bit at a time over a 

prolonged period. On the other hand, an instantaneous release 

versus a prolonged release will result in ground-water 

contamination that will pass beyond a well more quickly 

(i.e.. the contact time is shorter for an instantaneous released. 

For a prolonged release, the contamination will be found in 

smaller concentrations but will persist around a nearby well for 

a longer period of time. 

In comparing the different contaminant source configurations, 

neither a point nor a plane source is necessarily always more 

conservative than the other. A point source assumes that the 

entire release, assumed to be 1 curie in the RQ ground-water 

model, is at the outset concentrated into a single point and then 

allowed to disperse as it flows downgradient to the point of 

exposure. In contrast, a plane source assumes that the total 

release is distributed throughout a plane of a specified length 

and width. Whether one is more conservative than the other 

depends on the dimensions of the plane in relation to the 

dimensions of the aquifer, and on the distance from the point of 

release to the point of exposure. A point source is thought to 

be more appropriate for the purpose of developing an RQ because 

it best represents a sudden, episodic release or spill. A plane 

source is more appropriate for modeling chronic releases from a 

surface impoundment or landfill. 

F.l.3.2 Comparison of Values for Input Variables. 

The primary input variables in the RQ ground-water model are: 

F-19 
P.31 

o A retardation factor, which takes into account how much a 

contaminant is retarded (through sorption by soil and 

other mechanisms) relative to the transporting water 

mass; 

o Ground-water velocity; 

o Saturated zone thickness; 

o Porosity, which refers to the amount of openings or holes 

in a soil or rock; 

o Longitudinal dispersivity, which reflects the extent of 

dispersion of a contaminant at right angles to the 

direction of ground-water flow; and 

o The distance to the nearest water supply well. 

The values used for the variables in the RQ ground-water model, 

as well as the values used in the RCRA ground-water models, are 

presented in Exhibit F-4. As shown in this exhibit, out of the 

four RCRA models considered, all but one (the VHS model) take 

into account contaminant retardation. 

As shown in Exhibit F-4, the values used for velocity, aquifer 

thickness, and porosity in the RQ ground-water model are in the 

range of "those commonly used by the RCRA models. However, the 

values for dispersivity (both longitudinal and transverse) used 

in the RQ model are significantly higher than those used in the 

RCRA models. 

The values of longitudinal and transverse dispersivity reported 

in the literature vary widely. Dispersivity values have been 

obtained for different soil types through field measurements, 

laboratory experiments, and from the calibration of numerical 

models (i.e., calibration of models to match observed field 

data). In general, out of these three ways to determine values 

for dispersivity, values measured in the laboratory are the 

lowest, field measured values are generally intermediate in size, 

and the model derived values are usually the highest. Laboratory 

measured values of dispersivity are often so low that they are 

frequently considered unrealistic; model derived values are 

considered more realistic than those measured in the laboratory, 

F-20 
EXHIBIT F-4 

VALUES OF INPUT VARIABLES USED IN TNE RCRA AND 

RQ GROUND-WATER MODELS 

Model 

Retardation a/ 

Ground-Water 

Velocity 

(mday) 

Aqui fer 

Thickness 

(m) 

Porosity 

(dimensionless) 

Longitudinal 

Dispersivity 

(m) 

Transverse 

Dispersivity 

(m) 

Distance 

to Well 

(m) 

t 

ts) 

RQ Model 

CRAM 

Liner-Location 

Threshold Model 

VHS Model 

no 

yes 

yes 

yes 

no 

0.5 

<25 

0.003-28 

<25 

N/A d/ 

20 

53 b/ 

30 

3-560 

thick enough 

so as to 

impede dl 

not 

spers on 

0.1 

0.35-0.56 

0.01-0.3 

0.3-0.6 

N/A 61 

20 

1.8 

6 

5 

2 

2 .8 

4 

0.6-1 

0.6 

1.7 

0.2 

30 

50 c/ 

60 c/ 

50 c/ 

305 

a/ Values for retardation factors are not given; instead the table indicates whether the model considers retardation. 

b/ In CRAM, saturated aquifer thickness has an exponential probaility distribution with a mean of 53. 

c/ These are the shortest distances to wells used by the models: the dispersivity values reported, which are dependent on distance, are 

based on these minimum distances, 

d/ Not applicable; velocity and porosivity are not used in the VHS model. 
P.33 

but not as realistic as those measured in the field. Exhibit 

F-5 presents field measured values and model derived values of 

dispersivity for alluvial aquifers (i.e., deposits composed of 

particles of gravel, sand, silt, or clay that are not bound or 

hardened). 

In comparing the dispersivity values used in the RQ model to the 

values in Exhibit F-5, the RQ model's values are on the high side 

for field measured values and on the low side for model 

calibration values. EPA considers the dispersivity values used 

in the RQ model to be realistic for an alluvial aquifer. The 

dispersivity values used in the RCRA models are generally on the 

low side of the field measured values, and significantly lower 

than the values obtained from the"model calibrations. 

The models developed by the EPA Office of Solid Waste for 

application to RCRA are risk based and as such are believed to be 

more conservative than necessary for development of reportable 

quantities which act as a trigger for notification of - a release 

of a hazardous substance. For this reason, the . Agency has 

decided to use the advection-dispersion model for determination 

of Release Values based on a ground-water ingestion scenario. 

F.2 SURFACE WATER TRANSPORT OF RADIONUCLIDES. 

To model the ingestion of contaminated surface water, the Agency 

chose the surface-water transport model used in the RCRA 

Risk-Cost Analysis Model and presented for use in conducting 

7 

exposure assessments at Superfund sites : 

6. U.S. Environmental Protection Agency, Office of Solid Waste, 

"The RCRA Risk-Cost Analysis Model Phase III Report," 

prepared by ICF Inc., 1984. 

7. U.S. Environmental Protection Agency, Office of Emergency and 

Remedial Response, "Superfund Exposure Assessment Manual," 

Draft, prepared by Versar Inc., 1986. 

F-22 
P.34 

EXHIBIT F-5 

FIELD MEASUREMENT AND MODEL CALIBRATION VALUES 

FOR DISPERSIVITY FOR ALLUVIAL AQUIFERS 

Setting 

Field Measurements 

Longitudinal 

Dispersivity 

Transverse 

Dispersivity 

Cm) 

Model Calibration Values 

Longitudinal Transverse 

Dispersivity Dispersivity 

m ; rm) 

Chalk River, 

Ontario 

0.034-0.1 

Lyons, France 0.1-0.5 

Alsace, France 12 

Barstow, CA 

Rocky Mountain 

Arsenal 

15.2 

15 

61 

30.5 

18 

30.5 

Arkansas River 

Valley 

30.5 9.1 

California 30.5 9.1 

Sutter Basin, CA 80-200 8-20 

Source: Tables 4.1 and 4.2 in Codell, R. and Duigid, J., 

"Transport of Radionuclides in Groundwater," Chapter 4, 

Radiological Assessment. Till, J., and Meyer, H., eds., 

U.S. Nuclear Regulatory Commission, September 1983. 

F-23 
P.35 

C =

 Q exp(-Kx/u) (18) 

where: 

Q 

F 

K 

X 

u 

downstream contaminant concentration at position x 

(Ci/L) ; 

contaminant release rate (Ci/d); 

surface water flow rate (L/d); 

contaminant decay constant in surface water for 

physical and chemical processes (1/sec); 

downstream distance (m); and 

mean stream velocity (m/s). 

Equation 18 applies to rivers and lakes and assumes complete 

contaminant surface-water mixing, steady state conditions, and no 

longitudinal dispersion (i.e., no dispersion in the direction of 

flow). Because"of thie larger volumes typically associated with 

lakes used as sources of drinking water, the surface water flow 

rate, F, for a lake would generally be larger than that of a 

river, and the concentration at the point of exposure would be 

much smaller. Therefore, to be most conservative, the Agency 

based its surface-water ingestion scenario on a release into a 

river. 

To compare the surface-water model given in Equation 18 with the 

ground-water model given in Section F.l.l, the Agency considered 

a one curie release over a period of one day (Q = 1 Ci/d), and 

evaluated the downstream concentration at a distance of 30 

meters. The contaminant decay constant is determined from the 

relation K = (0.693)/(the radionuclide half-life). Because the 

ground-water model assumes no decay, the half-life is set equal 

to infinity in the surface-water analysis (i.e., no decay is 

considered). Using a shorter half-life results in a lower, hence 

less conservative, downstream concentration. Because an infinite 

F-24 
P.36 

half-life is used, the exponential term in Equation 18 equals 1 

and the downstream concentration is independent of the mean 

stream velocity and downstream distance (i.e., specifying values 

for u and x is not necessary). Finally, a conservative flow 

9 8 

rate for a small river of 1 x 10 liters per day is used . 

Substituting these values in Equation 18 yields: 

c = (1

 c Vd a y> * exp(-O) (19) 

(1 x 10s L/day) 

C = 1 x IO"9 Ci/L (20) 

As discussed in Section F.1.1, a one curie release into ground 

water with no retardation (i.e. K. = 0) results in a downgradient 

—8 

contaminant concentration of 7.6x10 Ci/L at 30 meters. This is 

the maximum concentration calculated by the ground-water model 

because introducing retardation (i.e., Kd > 0) results in smaller 

downgradient concentrations. In both the ground-water and 

surface-water scenarios, the amount of radioactive material 

ingested is the product of the contaminant concentration, the 

drinking water intake rate of "Reference Man," and the length of 

time over which an individual drinks the contaminated water (the 

contact time). The drinking water intake rate for "Reference 

Man" is 2 liters per day, independent of the source of the water. 

Assuming contact times are the same for both the surface-water 

and ground-water scenarios, the ground-water scenario with no 

retardation predicts a larger intake of radionuclides (because 

the ground water concentration is higher) and is therefore the 

more critical ingestion pathway. However, because ground-water 

9 

moves much more slowly than surface-water (0.5 m/day compared to 

4 

5.5 x 10 m/day), the contact time between the contaminated 

ground water and the well will be much longer than that between 

U.S. Environmental Protection Agency, Office of Solid Waste, 

"The RCRA Risk-Cost Analysis Model Phase III Report," 

prepared by ICF Inc., 1984. 

4 The surface-water velocity of 5.5x10 m/d for a small river 

is a conservative value taken from the RCRA Risk-Cost 

Analysis Model Phase III Report. 

F-25 
P.37 

the contaminated surface water and the point of intake from the 

river. Therefore, an individual is expected to be exposed to 

contaminated ground water for a longer period of time and, even 

if concentrations were equal, the ingestion of contaminated 

ground water would result in a significantly larger intake of 

radionuclides. Because the ground-water model, with no 

retardation, predicts both a larger concentration and a greater 

contact time than the surface-water model, the ingestion of 

radionuclides through contaminated ground water is a more 

critical pathway than the consumption of contaminated surface 

water. 

In the above example, retardation of radionuclides moving in 

ground water is assumed to be negligible. Refering to Exhibit 

F-2 indicates that the majority of radionuclides listed 

experience no retardation (i.e., Kd = 0). The ground-water 

scenario is, therefore, the more critical ingestion pathway for 

these radionuclides. For radionuclides which are retarded by 

soils, reviewing the ground-water transport equations of Section 

F.1.1 shows that the contact time increases and the downgradient 

concentration decreases with increasing radionuclide retardation. 

It can be shown that the contact time increases more than the 

concentration decreases, so that the total intake rises with an 

increase in retardation. However, because the ALI's are based on 

a one year intake, the total contact time for this analysis is 

limited to one year for large K, values and the total intake is 

reduced when retardation effects are pronounced (i.e., large 

K d ) . Including retardation effects results in a lowering of the 

total intake by an amount that is proportional to 1/K,. From 

Exhibit F-2, the largest (i.e., least conservative) radionuclide 

Kd value is 10,000 and the maximum concentration predicted by the 

ground-water model would be reduced to approximately 1 x 10 

Ci/L, which is two orders of magnitude smaller than the 

concentration predicted by the surface-water model, 1 x 10 

Ci/L. For the two models to predict equal ingestion of 

radionuclides, the contact time for the ground-water scenario 

F-2 6 
P.38 

would have to be approximately two orders of magnitude longer 

than that in the surface-water scenario. However, the 

approximate five order of magnitude larger surface-water 

4 velocity, compared to the ground-water velocity (5.5x10 m/d and 

0.5 m/d, respectively), indicates a several order of magnitude 

longer contact time for the ground-water scenario. It is 

therefore likely that the total radionuclide intake for the 

ground-water scenario will be larger than that for the 

surface-water scenario in every case, irrespective of the 

limitation placed on contact time. 

While retardation may reduce the net radionuclide intake 

predicted in the ground-water scenario, comparing the least 

conservative ground-water scenario to a conservative surfacewater scenario shows that the consumption of contaminated ground 

water is likely to be a more critical ingestion pathway than 

consumption of contaminated surface water, regardless of 

retardation effects. Therefore, an ingestion scenario based on 

the consumption of contaminated ground water will predict lower 

Release Values and is more protective to human health and welfare 

than a scenario based on the consumption of contaminated surface 

water. 

F.3 TRANSPORT OF RADIONUCLIDES TO FOOD CROPS. 

A number of models have been developed to describe the transfer 

of radionuclides to various foodstuffs after an atmospheric 

radioactive release . These models typically begin with an 

estimate of the radionuclide air concentration above the food 

10. Nair, S., Models for the Evaluation of Ingestion Doses From 

the Consumption of Terrestrial Foods Following an Atmospheric 

Radioactive Release. Central Electricity Generating Board, 

Berkeley Nuclear Laboratories, England, April, 1984. 

F-27 
P.39 

crop or pasture and subsequently calculate the radionuclide 

concentration in or on the food crop. The level of contamination 

depends upon many factors including the rate at which the 

radionuclide is deposited, the fraction retained by the plant 

leaf, the areal density of the crop, and the transfer rate 

between soil and crop. These equations generally include 

compartments describing mechanisms for removal of radionuclides 

from crops through weathering and radioactive decay. in 

addition, models have been developed which describe the transport 

of radionuclides to man through milk (the so-called 

air-grass-cow-milk-man route), meat, and vegetable crops. The 

Agency has decided to focus on the latter route; exposure of manthrough the consumption of contaminated vegetable crops because 

radionuclides deposited on vegetables are ingested directly. For 

milk and meat, only a fraction of the radionuclides consumed by 

cows are transfered to milk or meat and humans are expected to 

ingest a smaller quantity of radionuclides through these 

pathways. 

Two approaches for modeling the concentration of radionuclides on 

vegetable crops after an airborne release were evaluated. The 

first used an equation published by the National Council on 

Radiation Protection and Measurement (NCRP) and the second an 

equation developed by the Nuclear Regulatory Commission and 

recommended by them for calculation of doses to individuals and 

populations. 

F.3.1 The NCRP model.11 

The NCRP model was designed to address continuous or intermittent 

releases of radioactive material to the environment and, through 

11. Screening Techniques for Determining Compliance with 

Environmental Standards: Releases of Radionuclides to the 

Atmosphere. NCRP Commentary No. 3, National Council on Radiation 

Protection and Measurement, March 31, 1986. 

F-28 
P.40 

a series of screening calculations, aid in the design or redesign 

of facilities handling radionuclides so that their projected 

emissions can be compared with environmental standards. The 

model incorporates a term for deposition rate of radionuclides 

from air to crops that is very large compared to the Nuclear 

Regulatory Commission model (see below). Because of the highly 

conservative nature of the NCRP model the Agency believes that it 

is inappropriate for calculating Release Values and establishing 

proposed RQs. 

12 F.3.2 The Nuclear Regulatory Commission model. 

The Nuclear Regulatory Commission model is similar to the NCRP 

model in that it estimates the concentration of radionuclides in 

vegetation produced by deposition onto the plant foliage from air 

and by uptake from activity initially deposited on the ground. 

The model is valid for particulate radionuclides except tritium 

and carbon-14. Different values are given for the various 

parameters to allow the use of the equation for different 

purposes such as estimating concentrations in produce consumed by 

man; in leafy vegetables consumed by man; or in forage consumed 

by animals and" converted to meat or milk consumed by man. The 

equation allows for the time period that crops are exposed to 

contamination during the growing season and therefore can be 

applied to episodic releases. Several assumptions are made in 

applying this model to the specific circumstances of release 

considered here. They are: 

12. Calculation of Annual Doses to Man From Routine Releases of 

Reaction Effluent for the Purpose of Evaluating Compliance with 

10 CFR Part 50. Appendix I. Nuclear Regulatory Commission, 

Regulatory Guide 1.109, October, 1977. 

F-29 
P.41 

1. The release is an episodic release and all 

radionuclides which are going to become airborne and be 

subject to deposition on or near a crop are released in 

one day. 

2. The portion of the release that becomes airborne and is 

subject to deposition on the crop is specified by the 

release fraction, R (see appendix D for a discussion of 

release fractions). 

3. Radioactive decay as a mechanism for removal 

radionuclide from the crop is ignored. 

of 

4. The exposed vegetable crop is located 30 meters from 

the point of release and the contaminated food is 

consumed on a daily basis by an individual for 60 days 

(the length of the growing season). 

The equation used by the Nuclear Regulatory Commission along with 

a description of- the variables is shown below: 

C = d. 

IV 1 

r[l - exp(-XEite)] Biy[l - exp(- \.tb)]' 

YvXEi p\. 

exp(-\ith) (21) 

where: 

Civ 

the concentration of radionuclide i in the 

vegetation (Ci/kg); 

d

i the deposition rate of radionuclide i (1/m -day), 

this term is calculated from the equation below: 

di = (SiHQi) 

F-30 
P.42 

where b_ is the relative deposition of 

radionuclide i, considering depletion in transit 

~5 — 2 

to the point of deposition (1.7 x 10 m ) and Q. 

the total radionuclide emission rate (assumed to 

be 1 Ci/day); 

r = the fraction of deposited activity retained on 

crops (0.25, dimensionless); 

Y = the agricultural productivity (yield), in kg/m2 

v (wet weight); 

\-. - the effective removal rate constant for El 

radionuclide i from crops in l/day, where 

XEi = ^i + Xw? 

XJ = The radioactive decay constant (taken as zero); 

Xw = The removal rate constant for physical loss by 

weathering calculated on the basis of a weathering 

half-life of 14 days ( Xw = 0.693/14 days = 

0.0495/day), 

t = is the time period that the crops are exposed to 

contamination during the growing season (1 day); 

BJ = the concentration factor for uptake of 

radionuclide i from soil by edible parts of 

crops ; 

13. Baes III, C.F., Sharp, R.D. Sjoreen, A.L., Shor, R.W., A 

Review and Analvsis of Parameters for Assessing Transport of 

Environmentally Released Radionuclides Through Agriculture. 

ORNL-5786, Oak Ridge National Laboratory, September, 1984, 

Page 10. 

F-31 
P.43 

P - the effective surface density for soil (240 kg/m2, 

dry weight); 

tb = is the period of time which the soil is exposed to 

contamination (1 day); and 

tn = time interval between harvest and consumption of 

food (zero days). 

Assuming no radioactive decay (X^ • 0) Equation. 21 simplifies to: 

/r[l - exp(-Xwt )] B. \ 

c =d.( JL£_ + _LL ) (22) 

v w 

The relative deposition (£.,) of radionuclide is estimated from 

the relative deposition rate (see Exhibit F-6) by extrapolation 

to 30 meters and recognizing that the curve approaches 2.0 x 10~4 

per meter asymptotically. In order to complete the calculation 

of the relative deposition, it is necessary to calculate the 

length of the arc subtended by a 22.5 degree (2 7T/16 radians) 

angle 30 meters from the point of release of the radionuclide and 

divide the value recovered from extrapolation of Exhibit F-6 by 

this number. The angle of 22.5 degrees is chosen because wind 

direction for meteorological modeling purposes is determined by 

dividing the compass rose into 16 equal segments. Each of these 

segments has an internal angle of 22.5 degrees (16 times 22.5 

equals 360). Application of simple trigonometry as shown below 

14. Methods for Estimating Atmospheric Transport and Dispersion 

of Gaseous Effluents in Routine Releases from 

Light-Water-Cooled Reactors. Regulatory Guide 1.111, Nuclear 

Regulatory Commission, July, 1977, Page 1.111-21. 

F-32 
P.44 

10 -3 

10' 

ca 

UJ 

UJ 

S 

OS 

UJ 

CL 

UJ 

in 

O 

a. 

UJ 

Q 

u 

>. 

UJ 

za 

10 

10 

10 

• 1 a^ap •_ • »•«.••» • m —• • i — ii — i —— —« — — — - '• IM j w — — —•*> •_«_« « a^MMaaaaM^M 

0.1 1.0 10.0 

PLUME TRAVEL DISTANCE (KILOMETERS) 

100.0 

EXHIBIT F-6. Relative Deposition for Ground-Level Releases 

(All Atmospheric Stabilit y Classes) 

Source: Reference 14 

F-33 
P.45 

gives a value for this arc length of 11.8 meters. The term 61, 

-5 -2 therefore, has the value 1.7 x 10 m , and, for Q. = l/day, di = 

1.7 x 10"5/m2-dayS = rd 

S = (30 meters)*(2pi/16) 

S =11.8 meters 

Substituting the appropriate values into Equation 22 gives: 

civ = (2,0 7 x 10 "6 + 7 *0 8 x 10~8Biv)* (?3> 

Equation 2 3 describes the transfer of radionuclides from air to 

food crops. Dividing both sides of Equation 23 by the magnitude 

of the release (1 curie) defines the dilution factor (DF) for 

food crops< 

DF - (2.07 X IO"6 + 7.08 X 10~8Biv)kg"1. .. (24) 

Release Values for ingestion of contaminated drinking water have 

been"calculated by application of Equation 25 shown below (see 

section F.1.1, Equation 11): 

RV = ALI/((10)*(DF)*(CT)*(WC)*(1 X IO6)) (25) 

where: 

RV = Release Value (curie); 

ALI = annual limits of intake for ingestion (microcurie) 

found in ICRP Publication 30; 

DF = the dilution factor (1/kg); 

F-34 
P.46 

WC = the daily water consumption of reference man which 

is replaced here by the value for leafy vegetable 

consumption (FC) of the maximally exposed adult 

(reference 12, page 1.109-40, 0.175 kg/day); 

CT = contact time. This must be calculated in an 

entirely different manner than that used for the 

ingestion of contaminated water. An individual 

ingests contaminated vegetables over a period of 

60 days (the growing season) which were 

contaminated by an episodic release on day one. 

Ignoring radioactive decay as a method for 

"removing contamination and considering only 

removal by biophysical processes (weathering), 

contamination of vegetable crop declines 

exponentially during the 60 day period. The 

Nuclear Regulatory Commission gives a half-life 

for this weathering .process of 14 days (t = 14 

days). The expression for finding the 

concentration at any time, C. , is then: 

Ct = C0e"

 X w * 

where: 

Xw = ln2/tw = 0.0495/day, 

CQ = initial concentration. 

The daily intake is given by: 

Daily Intake = (FC)*CQe"^wt 

In order to determine the total intake over time 

T, the equation is integrated from zero to T 

giving: 

F-35 
P.47 

Total Intake = (FC)*CQ((1 - e" ^w T ) / \ ) . 

The equivalent contact time is, then: 

CT = (1 - e~^wT )/Xw 

CT = 19.0 days for T = 60 days. 

10 converts the 5 rem occupational exposure limit to 

the more conservative 0.5 rem limit for the 

general public; and 

1 x 10 converts microcuries to curies. 

In atmospheric modeling, a factor relating the amount of a 

release which will become airborne is often used. In order to 

account for the fraction oi the total release which may become 

airborne and for_. consistency . with the equation used for 

calculating Release Values for inhalation, the ALI must also be 

divided by a release fraction (R). The equation used for 

calculating Release Values based on the consumption of 

contaminated vegetables is shown below: 

RV = ALI/((10)*(DF)*(FC)*(CT)*(R)*(1 X IO6)). (26) 

Substituting the values for DF, FC and CT yields: 

RV = ALI/((68.8 +2.3Biv)*R). (27) 

In applying Equation 27 to the 757 radionuclides listed in ICRP 

Publication 30 and for which Release Values for the ground-water 

pathway have been calculated, it has been found that 

consumption of contaminated ground water is the more critical 

F-36 
P.48 

ingestion pathway for the majority of radionuclides. 

Furthermore, in the great majority of cases where the ingestion 

of contaminated food crops is the more critical of the ingestion 

pathways, either the inhalation or direct exposure scenarios are 

more critical exposure pathways than ingestion. Therefore, the 

Agency has chosen to base the ingestion scenario on intake of 

contaminated drinking water. 

F-37 
P.49 

APPENDIX G 

CALCULATION OF DIRECT EXPOSURE RELEASE VALUES 

G.l Fixed Point Sources 

The Radiological Health Handbook provides the following 

equations as exact solutions for gamma ray exposure and 

gamma ray absorption from a fixed point source of radiation. 

IQ = 0.156 n1 E (IO5 u & ) , and (1) 

R/hr - (n2 I)/S2 (2) 

I = T e~ua

S (3, 

o 

where: 

I = original radiation exposure rate in Roentgen per 

hour (R/hr), 

I = attenuated radiation exposure rate (R/hr), 

n, = gamma quanta per disintegration, 

E = energy of gamma quanta in MeV, 

u = linear energy absorption coefficient for gamma rays 

in air (at standard temperature (23°C) and pressure 

(1 atm)) in cm , 

n2 = number of curies, 

S = distance in meters, 

R/hr = exposure rate in Roentgen per hour. 

When combined, these three equations become: 

R/hr = ((1.56 x 104)*(n1)*(E)*(ua)*(n2)*(e"ua

S)/S2 (4) 

1. The Health Physics and Radiological Health Handbook. Nucleon 

Lectern Associates, Olney, MD, 1984, pages 41 and 45. 

G-1 
P.50 

The value for u_ is found in the Radiological Health 

-5- 1 Handbook to be 3.7 x 10 cm for gamma rays with an 

energy of 1 MeV. The value varies with the energy of the gamma 

ray involved but is approximately correct (+15%) for gamma 

rays with energies ranging from about 0.07 MeV to about 2 MeV. 

The distance, S, used for other exposure routes is 30 meters and 

is used here. Photon attenuation in air between the source and 

—u S receptor is represented by e a . Incorporation of a term for 

photon attenuation in the equation results in a slight increase 

in the direct exposure Release Value since approximately 10 

percent of the photons emitted from the source will be absorbed 

in 3 0 meters of air between the source and the receptor. A 24 

hour exposure duration (T) was chosen to provide a release 

value that would be low enough to inform individuals in a timely 

fashion that an exposure occurred. A shorter time period might 

raise the release value to such an extent that notification might 

not be given of a release that would be harmful if an 

individual were to be exposed for- twenty-four , hours. 

Multiplying by T (24 hours) tp convert Roentgen per hour to 

Roentgen, the equation becomes: 

R = ((1.56 x 104)*(ni)*(E)*(ua)*(n2)*(T)*(e"ua

s))/S2 (5) 

Roentgen is approximately equal to rem for gamma rays. 

1 Roentgen = 100 ergs/gram of soft tissue (approximately). 

1 rad = 100 ergs/gram. 

1 rem = 1 rad (for gamma rays). 

Substituting rem (Dn) for Roentgen (R) and rearranging 

Equation 4 to solve for n2 gives: 

n. 

,-5 -u_S, ((6.41 x 10 ")*(Dn)*(S'))/((n1)*(E)*(ua)*(T)*(e "a")).(6) 

The value for n2 is the direct exposure release value and the 

product of n, and E is the gamma ray fraction times the gamma ray 

energy. Many radionuclides emit more than one gamma ray per 

G-2 
P.51 

disintegration or they emit gamma rays of varying energies. 

Often each of these gamma rays are emitted only for a specific 

fraction of disintegration events. In order to account for 

this, the product of the energy of each gamma ray emitted (E.) 

and the fraction of time it is emitted (n.) is summed to 

produce a value, E,, which reflects the total gamma ray energy 

produced by each radionuclide. The method used for this 

calculation is shown in Equation 7. 

Ei = I t(ni)*(Ei)] (7) 

i 

Some radionuclides emit positively charged electrons (positrons) 

which, when they strike normal negatively charged electrons, 

annihilate one another and produce two gamma rays with an energy 

of 0.511 MeV each. Both annihilation gamma rays are considered 

in the calculations for those radionuclides which decay by 

positron emission. Substituting E, for the product of n..' and 

E and using "Direct Exposure £DE) Release Value (RV)" for n, 

yields: 

DE RV = ((6.41 x 10"5)*(Dn)*(S2))/((E1)*(ua)*(T)*(e"ua

S)). (8) 

Equation 8 above is identical to that shown as Equation 5 in 

section 4.2.3 of this report. Substituting numerical 

equivalents for Dn (0.5rem), S (30m), u (3.7 x 10 ), and T (24 

cl 

hours) in Equation 8 yields: 

DE Release Value = 36.3/E^ (9) 

G-3 
2 

G.2 Submersion In A Cloud of Noble Gas. 

The noble gases argon, krypton, and xenon are very resistant to 

combination with other elements to form solid or liquid 

derivatives. The radioactive forms of these elements are not 

likely to be found in compounds or in solid or liquid ingestible 

form. In addition, these gases have very low solubility in blood 

and are easily displaced from blood by the more common gases 

found in air such as oxygen and nitrogen. For these reasons, 

neither ingestion nor inhalation comprise a route of 

significant expsoure - for argon, krypton or xenon and ALI's 

for isotopes of these elements are not found in ICRP Publication 

30. The one route of potential exposure considered significant 

for radioactive forms of these elements is through direct 

exposure from submersion in an airborne cloud (known as 

"cloudshine"). The equation used for calculation of the 

Direct Exposure (DE) Release Value (RV) based on submersion in 

3 

such an.airborne cloud is shown below : 

DE RV - ((83)*(DAC)*(T))/((10)*(X/Q)*(1 x IO6)) (10) 

2. The noble gases helium and neon do not form isotopes with 

half-lives longer than a few seconds. None of these 

isotopes are listed in ICRP Publication 30 and no Release 

Values or proposed RQs have been calculated. The noble gas 

radon has two isotopes (radon-220 and radon-222) listed in 

ICRP Publication 30 with inhalation ALIs calculated 

with and without daughters present. Due to the fact that 

Radon-220 and Radon-222 emit alpha particles, inhalation 

becomes the critical exposure pathway, and submersion in an 

airborne cloud is not addressed by the ICRP for either 

isotope. The lowest of the ALIs in each case was 

used in the usual manner to calculate inhalation release 

values and, since submersion in an airborne cloud is not 

addressed for either radon isotope, Direct Exposure Release 

Values were calculated by summation of the product of gamma 

ray energy and gamma ray fraction. 

3. Annals of the ICRP, Publication 30, Part 1, Vol.2, No. 3/4, 

1979, Pergammon press, pages 10 and 47. 

G-4 
P.53 

where: 

DAC = derived air concentration (uCi/cubic centimeter) 

from ICRP Publication 30; 

T = time of exposure (1 day) ; 

. . —13 

X/Q = atmospheric relative concentration value (8.4 x 10 

day/cubic centimeter); 

.83 conversion factor to adjust airborne concentrations 

from a 2 000 hour work year (50 weeks times 4 hours 

per week) to a 24 hour exposure period (2000/24) ; and 

1 x 10 conversion factor from microcurie (uCi) to curie. 

The DAC is the airborne concentration to which an individual 

must be exposed for one work year (2000 hours) in order to 

receive an occupational dose-equivalent of 5 rem. The factor of 

10 converts this occupational dose-equivalent to.the 0.5 rem/yr 

limit applicable to the general public. For consistency with 

other exposure pathways the atmospheric relative 

concentration value (X/Q) is derived for exposure 30 meters 

from the release under stability class D conditions (see 

Appendix E). In order to convert the duration of exposure from a 

2000 hour work year to 24 hours (1 day), the DAC must be 

multiplied by a factor of 83 (2000 hours/24 hours). This is the 

airborne concentration that will deliver a 5 rem dose-equivalent 

in 24 hours. 

Substitution of time (T) and the atmospheric relative concentration value (X/Q) into Equation 10 leads to Equation 11 which 

was used for . calculation of the direct exposure release values 

for isotopes of the noble gases, where appropriate. 

DE Release Value = (DAC)'/(1.0 x IO-7) . (ll) 

G-5 
P.54 

CHAPTER 3 

DENTIFICATION OF A LIST OF RADIONUCLIDES 

EPA is proposing to adjust the statutory one-pound RQ for radionuclides. 

We discussed in Chapter 2 of this report the six regulatory options considered 

by the Agency during the development of the proposed regulation. The Agency 

selected Option 6, establishing a proposed RQ in units of curies for 

individual radionuclides. 

There are approximately 1800 radionuclides on the Chart of the 

Nuclides.1 However, only 757 radionuclides have sufficient metabolic data 

available to individually analyze and examine the effects of a radionuclide 

release. The available metabolic data were developed by the International 

Commission on Radiation Protection (ICRP) and were published in its 

Publication 30.2 This publication includes Annual Limitations of Intake 

(ALIs), in units of microcuries, for individual radionuclides. The ALIs for 

the 757 radionuclides have been developed for different modes of exposure, 

such as inhalation or ingestion, and represent the quantity of each 

radionuclide that corresponds to a dose-equivalent of 5 rem, the Federal 

Radiation Protection Guidance recommended limit for worker exposure in nuclear 

facilities. 

EPA relied heavily on the ALIs in its methodologies for developing 

proposed RQs. Without ALIs for a particular radionuclide, insufficient 

information exists for the Agency to determine the effects of exposure to the 

radionuclide. Therefore, although the Agency decided to establish an RQ for 

individual radionuclides in units of curies based on the particular isotopic 

characteristics of each radionuclide, sufficient information to perform the 

necessary analyses exists for only 757 radionuclides. These 757 radionuclides 

are listed in ICRP's Publication 30 and have ALIs available for different 

routes of exposure. Because there is insufficient metabolic data on the 

remaining radionuclides to develop individual RQs, the Agency is proposing to 

list as a class all radionuclides that are not listed in ICRP's Publication 

30, and to propose one RQ for the entire class. The 757 radionuclides for 

which ALIs have been developed would be analyzed individually to determine the 

appropriate RQ levels. 

The 757 radionuclides for which specific RQs are developed include 

radionuclides that are very rare and exist only as laboratory anomalies, 

1The Chart of the Nuclides is a graphic display of the number of 

neutrons and protons, radioactive half lives, modes of radioactive decay, and 

other data for known radioactive isotopes. 

international Commission on Radiation Protection, Annals of the ICRP: 

Limits for Intakes of Radionuclides by Workers, ICRP Publication 30, Part 2, 

1980.