Review and Assessment of the 

Technical Basis of 40CFR190

John E. KellySr Manager Advanced Nuclear Energy Programs Sr. Manager, Advanced Nuclear Energy ProgramsSandia National Laboratories

Sandia is a multiprogram operated by Sandia Corporation, a Lockheed Martin Company 

for the United States Department of Energy’s National Nuclear Security Administration 

under contract DE-AC04-94AL85000.
Outline

Why is 40CFR190 Important?Technical Bases for 40CFR190

– Dose and Health Effects

– Cost Analysis

– Risk Integration

Changes Since EPA’s 1976 Final Environmental StateObservationsSummary

July 2010 
40CFR190: Environmental Protec

Standards for Nuclear Power Op

Limits for Normal Operations - Subpart ADose Limit190.10(a): “...annual dose equivalent dose not exceed 25 mrem to wmrem to thyroid and 25 mrem to any other organ of any member of pmrem to thyroid and 25 mrem to any other organ of any member of p

EPA concerned that the previous standard was unnecessarily high an

reduced without burdening industry reduced without burdening industry. 

Historical evidence suggests that this standard will not be di

July 2010 
40CFR190: Environmental Protec

Standards for Nuclear Power Op

Limits for Normal Operations - Subpart BRelease Limit190.10(b): “...total quantity of radioactive materials entering generaenvironment...

p gg er 

gigawatt

-y gy ear of electrical energy...contains less 

50,000 Ci Kr-85, 5mCi I-129, and 0.5 mCi Pu-239...”EPA concerned about build-up of persistent isotopes (I-129, Kr-85, especially in light of growth projections for nuclear powe

r

I-129 produced – 1000mCi/GWe-yrKr-85 produced – 300,000Ci/GWe-yrRelease limits for I-129 & Kr-85 could be difficult to meet in 

effective manner

July 2010 
Global Build-up of Kr-8

EPA AsGWe in 

“Actual” environmental burden uses historic global growth, no 

“ C

controls

“A

CT

ENVBUR

July 2010 

Actual global capacity growth From www.eia.doe.gov, Table 27 
Envisioned Benefit of “New” S

July 2010 
EPA Methodology

 Final Environmental Statement and supp g ortin

g tec

documents provide basis for rule (1976)

 EPA developed model for estimating health effect

– 1500 MT/yr reprocessing plant used as basic unit– Developed release, transport, and health effects model f

interest

• Parametrically varied decontamination factors Parametrically varied decontamination factors

 Determined cost of decontamination systems

– Wide range of technologies assessed Wide range of technologies assessed

 Evaluated cost versus effectiveness (as measured 

effects avoided

)

July 2010 
Overview of EPA Method

Isotopic Source

(Ci / MT / yr)

DF 

(Decontamination

Factor)

Environmental 

Transport

Cost Analysis Health Effects

DF vs. $ Avoided vs. Cost Release 

Limit Set to

B

ala

nce DF 

Growth in 

Nuclear Power

a a ce

Cost with Ben

July 2010 
General Form of Dose 

and Risk Calculations and Risk Calculations

D ~ Q • 1/DF • TF • DCF • P 

HE = RF • D

Symbol Description Units

D Dose rem or person-rem

Q Isotopic Source (Material at Risk) Ci

DF Decontamination Factor dimensionless

TF Environmental Transport Factor dimensionless

DCF Dose Conversion Factor Rem/Ci

P Population Persons

HE Health Effects Cancers, fatalities, etc

RF Risk Factors Health Effects/rem

July 2010 
Radionuclide Pathway

(Kr-8

(Pu)

(I-129)

(C-14)

(H-3)

July 2010 
Fission Product Transport in 

Re

g g ion Surroundin

g Plant 

 Annual-average dilution factors 

used to determine

(

Χ/Q)

used to determine

– Dose at 3 km (2 mi) from plant 

(nearest population)

– Average dose within 80 km (50 Average dose within 80 km (50

mi) from plant

 Assumptions

– Continuous release from 1500

3 Km

Continuous release from 1500

tonne/yr plant

– Population doubles over plant 

lifetime of 40 

years

– Lifetime doses are constructed 

by integrating over 40 years

– Health effects are proportional 

Initially (1980) 1.5 mipeo

ple in surroundin

July 2010 

to dose (HE = RF • D)

pp 
Health Effects for U.S. Population fro

Assumes Kr Assumes Kr

“cloud

”

makes one pass over Eastern U.S. • Effects are uniform Continuous

Release • Exposure pathway is 

immersion

Accounts for Accounts for

population growth in U.S. 

July 2010 
Health Effects for World from K

Kr uniformKr uniformin entire aWorld popexposed bIncludes gworld popworld popKr decay.

July 2010 
Calculated Health Effects for 1500 MT

E ti t d H lth Eff t B d LNT f Estimate

d

Health Effects 

Base

d on LNT

fr

40 Years of Operation of 1500 Tonne/Yr Pl

Radionuclide Organ 3 km Regional US W

Kr-85 Effective 6.0 E-6 0.38 6.4 1

H-3 Effective 5.2 E-5 3.2 62 2

I-129

Thyroid 

Adult 7.4 E-5 0.02 0.12

(DF=1000 for I-129)

July 2010 

(DF=1000 for I-129)
Individual and Collective Dos

Individual and Collective Annual Doses from 1500-ton

3 km Regional Regional US US 

Radionuclide Organ mrem/yr

Personrem/yr μrem/yr Person- rem/yr μrem/yr P

r

Kr-85 Effective 0.37 24 10 560 2 H-3 Effective Effective 3.2 200 89 3900 16 I-129 Thyroid 

Infant

1.4 28 12

ThyroidAdult

0.4 12 5

July 2010 

(DF=1000 for I-129)
Cost Effectiveness of 

Decontamination Technolo

Iodine Scrubber Repro

Krypton Removal Repro

Zeolite (Repro)

July 2010 
DFs Implied by EPA Stand

 Based on this analysis EPA concluded that the follo

be appropriate

– DF=1000 for Iodine – DF=10 for Kr– DF=1 for T and C-14 because of insufficient control measu

time

 It th t t l li it dd d i It appears th

a

t ac

tual li

mits add

e

d margin

– Required DF for I ~200– Required DF for Kr ~5

July 2010 
What’s Changed Since 197

 Dose Conversion Factors Health Effects Modeling Health Effects Modeling Coolin

g p Time Assum

ptions

 Decontamination System Costs

July 2010 
Evolution of Dose Conver

Factors

Dose Conversion Factors

(rem•cm

3/yr/

μCi

)

ICRP- 8

(1970)

ICRP-72

(1970) (2008) Ra

Kr 15,000 28,000 2H-3 (ingestion) 100 55 1

July 2010 
Evolution of Health Effects Mo

DOCUMENT DATE “NATURAL” U.S. BACKGROUND Kr-85 EXPOSURE 

ESTIMATES (MREM)

DOSE RESPONSE M

Second Life Style Second Life Style 1941 0 1 μg Ra body burden

Symposium

1941 0.1 μg Ra body burden

1E-11 Ci/liter in surround

Chalk River Meeting 1953 15 mrem/year uniformly 

the body

ICRP 8 1965 80 to 100 mrem/year

BEIR I 1972 180 mrem/year natural+medical 

+fallout+nuclear power

4E-4/person in 19704E-2/person in 2000

5.68E-4 LCFper rem-yeapopulation; 1.15E-4LCF 

Fuel Cycle EIS 1973 200 mrem/year natural+medical 

+fallout+nuclear power 

0.38 mrem/y whole body; 13 mrem/y skin; PROJECTED

1.5E-3/rem/year to U.S. 

UNSCEAR 1977 4.03-4/ rem/year: relativBEIR III 1980 210 mrem/year natural+medical 

+fallout+nuclear power

2.1E-2/person in 19701.7/person in 2000

1.69E-4/ rem/year: relat

BEIR V 1990 360 mrem/year natural+medical 

+fallout+nuclear power

5.6E-4/ rem/year relative

ISCORS Technical Report 1

2002 6E-4/ rem/year relative

July 2010 

BEIR VII 2006 365 mrem/year natural+medical 

+fallout+nuclear power

6.1E-4/ rem/year relativ
Effect of Fuel Cooling Tim

Lon

ger Coolin

g Time is Beneficial for Kr

Isotope Fuel 

Cooling 

Time (yrs)

mCi per GWY(e) in Fuel

40CFR190 Quantity Limit (mCi)

Req

t

St

g g

Time (yrs) Fuel Limit (mCi) St

Kr-85 4 2.21E+08 5.00E+07 Kr-85 10 1.50E+08 5.00E+07 Kr-85 27 5.00E+07 5.00E+07 I-129 27 9.32E+02 5.00E+00 

Table assumes 50 GWd fuel burn-up

July 2010 
Financial cost of complia

( ) 2008 dollars

)

I t Th l

Annual Operating Cost C it l C t C it 

EPA

1500 MTHM/yr

INRA800 M

Iso

tope

Tec

hnology Operating Cost

Estimate

Capit

al Cos

t

Estimate

Capit

a

Estim

I-129

Silver 

I 129 zeolite beds $ 1.8 M $ 16 M $ 300 

& voloxidation

$ 1.8

M

$ 16

M

$ 300

K 85

Cryogenic 

Kr-85 Distillation Distillation $61M . $ 120 M $ 120

M $10B .

Industry cost estimate is greater than 10 times tha

July 2010 

Industry cost estimate is greater than 10 times tha
Observations on EPA 

Methodology

 EPA dose and health effects model is conservative

significantly different from current methods

 Obviously the growth in nuclear power projected in 

not been met (10x less) not been met (10x less)

 There has been no major change in assessing biolo

of radiation

 Need realistic cooling time assumptions (Kr-85) C t b i f d t i ti t h l i 

Cos

t

basis 

for 

decon

tamination 

tec

hnologies seem

optimistic (10X)

 EPA results are dominated by collective dose mode

July 2010 

EPA results are dominated by collective dose mode
Collective Dose Model 

 Collective dose calculated with linear no-threshold do

response is frequently used in studies comparing tech

options (e.g., PEIS)

 However, its use in an absolute sense leads to unreali

high number of f

 cancers and has been a subject o

f deb

decades. 

 F d t d d it i f bl t M i E 

For 

dose s

tan

dar

ds, it is pre

ferable 

to use 

Maximum 

E

Individual as the metric

July 2010 
What would be acceptable effluen

management approaches?

 25 mrem/yr at site boundary would still seem to be relevant Some degree of sequestration of I-129, H-3, C-14 might be advisable

– Ocean disposal probably not an option– Public concern about H-3 releases might be raised– Capture store and geologically store majority and release some fraction migh

Capture, store, and geologically store majority and release some fraction migh

– Worker doses may become a problem without radiological controls

 Recycling of older fuel helps mitigate expected doses

– Kr-85 no longer is an issue (probably is not a real issue in any case)

– Tritium decay would also be significant– Unlikely that industry could build enough recycling plants to even deal with ba

 Issues with recycling older fuel

– Utilities might desire hotter fuel removed first– Fissile quality of recycle product degrades with build up of Am-241

July 2010 
Summary

 Collective dose method drives the regulation and 

– This is especially true for world-wide projections

– Need to develop an alternate approach Need to develop an alternate approach

 Cost estimates for decontamination systems shou

eval td ua e

 Realistic growth curves for nuclear power should 

incorporated into analysis

 Need to develop a holistic approach for effluent co

July 2010 

p pp