NUREG-0543

Methods for Demonstrating

LWR Compliance With the

EPA Uranium Fuel Cycle Standard

(40"CFR Part 190)

. J. Congel

:)ffice of

Muclear Reactor Regulation

S. Nuclear Regulatory

ommission
Available from

GPO Sales Program

Division of Technical Information and Document Control

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

and

National Technical

Springfield,

Information Service

Virginia 22161
NUREG-0543

Methods for Demonstrating

LWR Compliance With the

EPA Uranium Fuel Cycle Standard

(40 CFR Part 190)

Manuscript Completed: January 1980

Date Published: February 1980

F. J. Congel

Division of Site Safety and Environmental Analysis

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

CONTENT

Page

INTRODUCTION ........................................... 1

I. Technical Specification Implementation of

40 CFR Part 190 .................................. 2

II. Technical Specification Implementation of

10 CFR Part 50, Appendix I ...................... 2-

III. Relationship of Appendix I, 10 CFR Part 50 to

40 CFR Part 190 ................................. 5

IV. Demonstrating Compliance with 40 CFR 190 ......... 8

V. Conclusion ...................................... 11

REFERENCES ............................................ 12

NUREG-0543

Methods for Demonstrating LWR Compliance

with the EPA Uranium Fuel Cycle Standard

(40 CFR Part 190)

Introduction

The U.S. Nuclear Regulatory.Commission, on May 5, 1975, issued Appendix I,

Numerical Guides for Design Objectives and Limiting Conditions for Operation

to Meet the Criterion "As Low As Is Reasonably Achievable" for Radioactive

Material in Light-Water-Cooled Nuclear Power Reactor Effluents, to 10 CFR

Part 50. The rule was the result of a detailed review by the Commission of

the record of the public rulemaking proceeding which began in January, 1972.

The U.S. Environmental Protection Agency, on January 13, 1977, issued 40 CFR

Part 190, Environmental Radiation Protection Standards for Nuclear Power

Operations, pursuant to the Atomic Energy Act, as amended, and Reorganization Plan No. 3 of 1970, which gave the EPA the authority to set radiation standards.

The part of these standards affecting nuclear power facilities went into

effect December 1, 1979.

The NRC has been issuing radioactive effluent and environmental monitoring

Technical Specifications in accordance with the original proposed Appendix I

guidance of 1971 and the Appendix I as issued May 5, 1975, for nuclear

facilities as they were licensed or as their Technical Specifications

were amended. The NRC has also been. in the process of developing a standardized

radiological effluent and environmental i echnical specification to implement

Appendix I to 10 CFR Part 50 (NUREG-0472' and 04734). These standardized

specifications must now assure that 40 CFR Part 190 is implemented.

The purpose of this document is to: 1) present the specifications that

implement 40 CFR Part 190 and Appendix I to 10 CFR Part 50, 2) explain

the rationale for using Appendix I to demonstrate compliance with 40 CFR

Part 190 for sites with four or less nuclear power reactors, and 3) describe

acceptable methods for demonstrating compliance with 40 CFR Part 190 for

sites whose radioactive effluents exceed the Appendix I portion of the

specifications.
I. Technical Specification Implementation of 40 CFR Part 190

NUREG-0472 1 and 04732 contain the following Technical Specification to

implement 40 CFR Part 190:

3.11.4 The dose or dose commitment to a member of the public, due to

releases of radioactivity and radiation, from uranium fuel cycle sources

shall be limited to 25 mrem, or less, to the total body and/or any organ

(except the thyroid, which shall be limited to 75 mrem, or less), over

any 12 consecutive months.

APPLICABILITY: At all times

ACTION:

A. Whenever the calculated radiation doses from the release of radioactive

materials in liquid or gaseous effluents exceed twice the limits of Specification 3.11.1.2.a, 3.1l.l.2.b, 3.11.2.2.a, 3.11.2.2.b, 3.11.2.3.a, or

3.11.2.3.b, in lieu of any other report required by Specification 6.9.1,

prepare and submit a Special Report to the Director, Nuclear Reactor

Regulation, within 30 days, which defines the corrective action to be

taken to reduce subsequent releases to prevent exceeding or the recurrence of exceeding the limits of Specification 3.11.4 (i.e., 40CFRI90.10).

This Special Report shall include an analysis which estimates the radiation dose to a member of the public from uranium fuel cycle sources

(including all effluent pathways and direct radiation) for a 12 consecutive month period that includes the release(s) covered by this report.

If the estimated radiation dose exceeds the limits of Specification 3.11.4,

and if the release condition which led to violation has not already been

corrected, the Special Report shall include a request for a variance in

accordance with the provisions of 40 CFR 190 and shall include the information specified in §190.11(b). Submittal of the report is considered a

timely request, and a variance is granted until staff action on the request

is complete. The variance only relates to the limits of 40 CFR 190, and

does not apply in any way to the requirements for dose limitation of 10 CFR

Part 20, as addressed in other sections of this technical specification.

II. Technical Specification Implementation of 10 CFR Part 50, Appendix I

NUREG-0472 1 and 04732 contain the following technical specification to

implement 10 CFR Part 50, Appendix I:

LIMITING CONDITION 'FOR OPERATION - Liquid Effluents

3.11.1.2 The dose or dose commitment to an individual from radioactive

materials in liquid effluents released from the site (see Figure 5.1-4)

shall be limited:

a. During any calendar quarter: < 1.5 mrem to the total body and

< 5 mrem to any organ, and

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-3-

b. During any calendar year: < 3 mrem to the total body and < 10 mrem

to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioactive

materials in liquid effluents exceeding any of the above

limits, in lieu of any other report required by Specification

6.9.1, prepare and submit to the Commission within 30 days,

pursuant to Specification 6.9.2, a Special Report which

identifies the cause(s) for exceeding the limit(s) and

defines the corrective actions to be taken to reduce the

releases of radioactive materials in liquid effluents

during the remainder of the current calendar quarter and

during the subsequent three calendar quarters so that the

cumulative dose or dose commitment to an individual from

such releases during these four calendar quarters is

within 3 mrem to the total body and 10 mrem to any organ.

(This Special Report shall also include (1) the results

of the radiological analysis of the drinking water source,

and (2) the radiological impact on finished drinking water

supplies with regard to the requirements of 40 CFR 141,

Safe Drinking Water Act.*)

LIMITING CONDITION FOR OPERATION- Noble Gases in Gaseous Effluents

3.11.2.2 The air dose due to noble gases released in gaseous effluents

from the site (see Figure 5.1-3) shall be limited to the following:

a. During any calendar quarter: < 5 mrad for gamma radiation and

< 10 mrad for beta radiation and,

b. During any calendar year: < 10 mrad for gamma radiation and

< 20 mrad for beta radiation.

(The dose design objectives shall be reduced based on predicted

noble gas releases from the turbine building if effluent sampling

is not provided. The dose design objectives shall also be

reduced based on expected public occupancy of areas, e.g.,

beaches and visitor centers within the site boundary.)

APPLICABILITY: At all times.
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ACTION:

a. With the calculated air dose from radioactive noble gases

in gaseous effluents exceeding any of the above limits,

in lieu of any other report required by Specification 6.9.1,

prepare and submit to the Commission within 30 days,

pursuant to Specification 6.9.2, a Special Report which

identifies the cause(s) for exceeding the limit(s) and

define the corrective actions to be taken to reduce

the releases of radioactive noble gases in gaseous

effluents during the remainder of the current calendar

quarter and during the subsequent three calendar quarters

so that the cumulative dose during these four calendar

quarters is within 10 mrad for gamma radiation and

20 mrad for beta radiation.

LIMITING CONDITION FOR OPERATION - Radiodines and Particulates

in Gaseous Effluents

3.11.2.3 The dose to an individual from radioiodines and radioactive materials in particulate form, and radionuclides (other

than noble gases) with half-lives greater than 8 days in gaseous

effluents released from the site (see Figure 5.1-3) shall be

limited to the following:

a. During any calendar quarter: < 7.5 mrem to any organ and,

b. During any calendar year: < 15 mrem to any organ.

APPLICABILITY: At all times.

ACTION:

a. With the calculated dose from the release of radioiodines,

radioactive materials in particulate form, or radionuclides (other than noble gases) with half lives greater

than 8 days, in gaseous effluents exceeding any of the

above limits, in lieu of any other report required by

Specification 6.9.1, prepare and submit to the Commission

within 30 days, pursuant to Specification 6.9.2, a Special

Report which identifies the cause(s) for exceeding the

limit and defines the corrective actions to be taken to

reduce the releases of radioiodines and radioactive

materials in particulate form, and radionuclides (other

than noble gases) with half-lives greater than 8 days in

gaseous effluents during the remainder of the current
-5-

calendar quarter and during the subsequent three calendar

quarters so that the cumulative dose or dose commitment

to an individual from such releases during these four

calendar quarters is within 15 mrem to any organ.

III. Relationship of Appendix I, 10 CFR Part 50 to 40 CFR Part 190

A. Potential radiation doses to individuals beyond the site

boundary in the vicinity of nuclear power reactors are

evaluated by the NRC staff and the applicant during the construction permit (CP) and operating license (OL) stages of

the licensing process. Based on an engineering evaluation

of the facility's radioactive waste treatment system and the

resultant estimated release of radioactive effluents, the

hydrologic and atmospheric dispersion characteristics, and the

-land use in the immediate site vicinity, potential doses to real

individuals at specific locations are calculated. These potential

doses must fall within the numerical design objective doses

stated in Appendix I to 10 CFR Part 50 before the final waste

treatment and effluent control system designs are approved.

Guidance for performing these analysgs is contaiyed in Regulatory

Guides 1.1093, l.llO, l.lll , 1.12 , and 1.113'.

Immediately prior to facility operation, radiological effluent

Technical Specifications are prepared by the licensee for review

by the staff which implement the individual dose design objectives

of Appendix I to 10 CFR Part 50 (see preceding section). The

design objectives are defined for the following three effluent

categories: 1) releases directly to the hydrosphere; 2) noble

gas releases to the atmosphere; and 3) radioiodine and particulate

releases to the atmosphere. For each effluent release category,

it is assumed in the calculations that an individual with the

highest dose potential is the receptor. Because of different

metabolic factors, internal organ sizes, consumption rates, and

diets, the critical individual may be either an infant, a child,

a teenager, or an adult. For example, an infant would potentially

receive the highest dose via the-cow-milk pathway due to his/her

relatively high consumption rate (300 litres/year) and small
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thyroid mass. However, the infant would receive no dose via the

leafy vegetable or fish pathway since no consumption of these foods

is considered to be involved. Similarly, children have the potential

for receiving the highest dose from consumption of leafy vegetables

due to their high consumption rates and relatively small thyroid

mass. Adults who consume fish harvested from the receiving waters

would potentially receive the highest dose from radionuclides

released to the hydrosphere. All individuals exposed externally to

noble gases receive the same numerical total body dose. Thus, it is

highly unlikely or impossible for the same individual to simultaneously receive the highest dose via all three effluent categories. For most reactor sites, it is also unlikely that all

different potential dose pathways would contribute to the dose to

a single real individual--for example, the cow-milk and vegetable

consumption pathway may not both simultaneously exist for the

same real individual.

Since it is difficult or impossible to continually determine

actual food use patterns and critical age groups, for calculational purposes, assumptions are made which tend to maximize

doses. For example, it is generally assumed that an infant

obtains his milk supply exclusively from cows grazing at a

location near the facility. In reality, the milk consumer may

be in an age group other than an infant, may be obtaining milk

from other sources, or may not be consuming at the assumed rate.

Any of these changes in the assumptions would reduce the estimated

dose. Similar maximizing assumptions are made for other pathways.

For radionuclides released to the hydrosphere, the degree of overestimation in most situations is such that no individual will

receive a significant dose (i.e., > 1 mrem/yr to the total body

or any organ).

For most cases, the overestimation is due to the following three

assumptions: 1) the effluents are either undiluted or only

slightly diluted by the receiving water, 2) the fish live in the

undiluted or slightly diluted water-long enough to reach equilibrium

concentrations with the surroundings, and 3) an adult obtains his

annual fish consumption from the undiluted or slightly diluted water

in the immediate surroundings of the nuclear facility. These assumptions generally result in an overestimation of dose by one or two

orders of magnitude. Since these assumptions are reflected in

the Technical Specifications limiting radionuclide releases to
-7-

design objective individual doses, no off-site individual is

likely to actually receive a significant dose (i.e.,

>1 mrem/year/reactor) via the liquid pathways. The

conservatism is considered justified since state of the art

liquid radioactive waste treatment is able to achieve these

small values of liquid releases.

The EPA uranium fuel cycle standard, 40 CFR Part 190, limits

the total dose to an individual from radiation and radioactivity associated with the nuclear fuel cycle to 25 mrem/yr

to the total body or any organ except thyroid and 75 mrem/yr

to the thyroid. The standard primarily differs from Appendix

I in that it does not address specific pathways but includes

contributions to a real individual from all uranium fuel cycle

facilities and all pathways. In comparing Appendix I to

40 CFR Part 190, the only potentially significant exposure

pathway for LWR's included in 40 CFR Part 190 but not addressed

by Appendix I is the direct radiation pathway (i.e., radiation from radionuclides in plant equipment and systems, or

stored on site). However, since both regulations address

individual doses, it is possible to state conditions under

which conformance with Appendix I provides reasonable

assurance of conformance with 40 CFR Part 190.

Since the doses via liquid releases are very conservatively

evaluated, there is reasonable assurance that no real individual will receive a significant dose from radioactive

liquid release pathways (<1 mrem/yr/reactor). Therefore,

only doses to individuals via airborne pathways and doses

resulting from direct radiation need to be considered in

determining potential compliance to 40 CFR Part 190.

Direct radiation is radiation due to contained radioactive

sources within the facility. Since all primary reactor components.

for PWR's are within heavily shielded areas of the facility, doses

due to contained radioactivity are very small at the site boundaries

(<I mrem/yr). BWR's designed within the past 10 years also have

all the primary reactor components shielded and therefore the

doses at the site boundaries are small'(<l mrem/yr). However,

about 8 to 10 BWR's of an earlier design may have substantial

direct radiation doses (>5 mrem/yr) that can occur at locations

where members of the public could be. Licensees will be required

to evaluate these doses and the staff will review these evaluations on a case-by-case basis.

Another possible source of direct radiation is an outside storage

tank. These tanks exist at both PWR's and BWR's. In cases

where such tanks are located in areas that can result in exposure

to members of the public, an assessment of the magnitude of

potential doses must be performed. The staff will review each

analysis on a case-by-case basis. Regardless of the source,
-8-

substantial direct radiation doses may result in reduced

individual dose design objectives to ensure that the EPA fuel

cycle standard is met.

Appendix I requires that the off-site location with real

pathways (e.g., grazing milk animals), real receptors, and

the highest dose potential based on a study of the dispersion

characteristics of the site environs, serve to establish

airborne radioiodine and particulate release rates. Calculations of maximum organ doses from both noble gases and

radioiodines and particulates at that limiting location will

provide data for determining compliance with 40 CFR Part 190.

For example, the Appendix I radioiodine and particulate

design objective is 15 mrem/yr to any organ and the noble

gas design objective is 5 mrem/yr to the total body (see Table I).

It is assumed that an external total body dose from noble gases

irradiates internal body organs at the same numerical rate.

For a four reactor unit site with all four units operating

the full year at the design objective values for both the

noble gas and the radioiodine and particulate releases (a

very unlikely situation), the thyroid organ dose could be

80 mrem/yr. Since the offsite location for food pathway doses is

seldomly the same location as the location where the noble

gas dose is a maximum, it appears reasonable that even a four

unit station could meet the 40 CFR Part 190 dose limit if

each unit remained within the Appendix I design objective

doses. For sites with less than four units and no significant

direct shine dose, conformance with Appendix I should establish

conformance with 40 CFR Part 190.

IV. Demonstrating Compliance with 40 CFR 190

The Appendix I Technical Specifications for single unit sites require a

report within 30 days if the effluent releases exceed one-half the

annual design objectives in a calendar quarter. For multi-unit sites,

the reporting requirement is reached at one-fourth the design objective

value in a calendar quarter. Absolute upper (shutdown) limits of radioactive releases are based on 10 CFR Part 20 doses and concentrations.

As long as a nuclear plant site operates at a level below the Appendix I

reporting requirements, no extra analysis is required to demonstrate

compliance with 40 CFR Part 190. If a site's Appendix I reporting

requirement dose level is reached or exceeded, the Technical

Specifications require an analysis to be performed to determine if

any additional limitations will be necessary to ensure continued

compliance with 40 CFR Part 190.
-9-

Based on experience, most Technical Specification reporting levels

are not exceeded by substantial amounts. Thus, in most situations,

it should be possible to demonstrate continued compliance with

40 CFR Part 190 by reevaluating the exceeded Appendix I design

objective dose using more realistic assumptions. This approach is

not only permitted but encouraged since 40 CFR Part 190 applies to

real individuals. Appendix I to 10 CFR 50 lists design objectives

doses which may or may not apply to real people. For example,

referring to Table I, assume that the radioiodine and particulate

pathway for a single site is calculated to result in 25 mrem to an

infant's thyroid, for one year of operation.

Simple inspection of the potential total dose would immediately

show that the 40 CFR 190 limit of 75 mrem/yr to the thyroid

could not be reached. If the example dose of 25 mrem/yr applied

to an organ other than the thyroid, additional analysis would

be necessary. If the calculated dose was the result of consumption of vegetation, then an investigation of the reality of the

pathway would be necessary. Does a garden actually exist at the

assumed location? Does the garden produce a sufficient amount

of vegetables to support an individual at the assumed consumption

rate? Does the assumed age of the consumer correspond to the

actual consumer? Do the results of the radiological environmental

surveillance substantiate the predicted concentrations? The

answer to any one of these questions could establish that the real

ýindividual dose is clearly within the 40 CFR 190 requirement. The

level of effort required will depend upon the dose pathway and

magnitude.

For most facilities with significant off-site direct radiation doses

(> 5 mrem/yr), it will be necessary to determine the magnitude and

distribution of these doses. Most assessments have already been

performed. After the dose fields are characterized, the dose due

to direct radiation must be added to doses due to effluents at the

critical locations. At the present time, since only older BWR's

have significant direct radiation doses, there are not many sites

where the highest off-site food pathway location could also be in

a region where the direct radiation dose is significant. Generally,

the food pathway locations are more than 1200 meters from the

reactor and thus not in a high direct radiation dose region.
Table I

INDIVIDUAL DOSES AT LIMITING OFF-SITE LOCATION

PATHWAY

NOBLE GAS

(SUBMERSION)

RADIOIODINES &

PARTICULATES

(MILK & LEAFY

VEG. CONS. +

GROUND PLANE +

INHALATION)

LIQUID

(FISH CONS.)

APPENDIX I DOSE

DESIGN OBJECTIVE

5 MREM/YR - T.B.

15 MREM/YR SKIN

(SITE BOUNDARY)

15 MREM/YR - ORGAN

(NEAREST ACTUAL

RECEPTOR)

THYROID DOSE AT OFF-SITE LOCATION

WITH LIMITING PATHWAY(S)* (MREM/YR)

INFANT CHILD TEEN ADULT

<5.

15+

<5 <5 <5

8 2 2

3 MREM/YR - T.B.

10 MREM/YR - ORGAN

(DISCHARGE CANAL)

NOT ADDRESSED BY

APPENDIX I

<1 <1 <1

DIRECT RADIATION

(TURBINE SHINE)

<1 <1 <1 <1

MAXIMUM POTENTIAL SUM IS 21 MREM/YR/REACTOR

PROBABLY REAL SUM IS 20 MREM/YR/REACTOR OR LESS

* E.G. MILK, MEAT, OR VEGETABLE CONSUMPTION

+ IF NO INFANT IS PRESENT, THEN NEXT AGE GROUP PRESENT BECOMES LIMITING,

I.E., CHILD.

- 10 ,
- 11 -

In several situations, the direct radiation dose may be high enough

such that recreational use of the immediate reactor environs could

result in doses in excess of the fuel cycle standards. For example,

annual doses at some locations have been measured as high as

1 rem/yr, before correction for occupancy time. Such cases must

be evaluated individually using site-specific data and land use

characteristics before a determination is made regarding the

acceptability for use by members of the general public.

V. Conclusion

There is reasonable assurance that sites with up to four operating

reactors that have releases within Appendix I design objective

values are also in conformace with the EPA Uranium Fuel Cycle

Standard, 40 CFR Part 190. The Technical Specifications require

that evaluations be performed to ensure this conformance.
REFERENCES

1. NUREG-0472, "Radiological Effluent Technical Specifications for PWR's",

Rev. 2, January, 1980.

2. NUREG-0473, "Radiological Effluent Technical Specifications

Rev. 2, January, 1980.

3. Regulatory Guide 1.109, "Calculation of Annual Doses to Man

Releases of Reactor Effluents for the Purpose of Evaluating

with 10 CFR Part 50, Appendix I", Rev. 1, October, 1977.

4. Regulatory Guide 1.110, "Cost Benefit Analysis for Radwaste

Light-Water-Cooled Nuclear Power Reactors", March, 1976.

for BWR's",

From Routine

Compliance

Systems for

5.K Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and

Dispersion for Gaseous Effluents in Routine Releases from Light-WaterCooled Reactors", Rev. 1, July, 1977.

6. Regulatory Guide 1.112, "Calculation of Releases of Radioactive Materials

in Gaseous and Liquid Effluents from Light-Water-Cooled Power Reactors",

March, 1976.

7. Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from

Accidental and Routine Reactor Releases for the Purpose of Implementing

Appendix I", Rev. 1, April, 1977.

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NRC FORM 335

(7-77)

1. REPORT NUMBER (Assigned by DDC) U.S. NUCLEAR REGULATORY COMMISSION

BIBLIOGRAPHIC DATA SHEET NUREG-0543

4. TITLE AND SUBTITLE (Add Volume No., if 4ppropriate) 2. (Leave blank)

Methods for Demonstrating LWR Compliance with the

EPA Uranium Fuel Cycle Standard (40 CFR Part 190) 3. RECIPIENT'SACCESSIONNO.

7. AUTHOR(S) 5. DATE REPORT COMPLETED

Frank J. Congel MONTH IYEAR

January 1980

9. PERFORMING ORGANIZATION NAME AND MAILING ADDRESS (include Zip Code) DATE REPORT ISSUED

Division of Site Safety & Environmental Analysis MONTH YEAR

Office of Nuclear Reactor Regulation January 1980

United States Nuclear Regulatory Commission 6. (Leave blank)

Washington, DC 20555 8. (Leave blank)

12. SPONSORING ORGANIZATION NAME AND MAILING ADDRESS (Include Zip Code) 10. PROJECT/TASK/WORK UNIT NO.

Division of Site Safety & Environmental Analysis Office of Nuclear Reactor Regulation 11. CONTRACT NO.

United States Nuclear Regulatory Commission

Washington, DC 20555

13. TYPE OF REPORT PERIOD COVERED (Inclusive dates)

Technical Report

15. SUPPLEMENTARY NOTES 14. (Leave blank)

16: ABSTRACT 1200 words or less)

The U. S. EPA Uranium Fuel Cycle Standard (40 CFR 190) went into effect for

nuclear power facilities on December 1, 1979. This document presents the

model technical specifications that implement 40 CFR Part 190 and Appendix I

to 10 CFR Part 50, explains the rationale for using Appendix I as a basis for

demonstrating compliance with 40 CFR Part.190 for sites with four or less

reactors, and describes methods for establishing compliance with 40 CFR

Part 190 for sites with radioactive effluents exceeding the Appendix I design objectives or sites with significant direct radiation dose rates (> 5 mrem/yr).

17. KEY WORDS AND DOCUMENT ANALYSIS 17a. DESCRIPTORS

17b. IDENTIFIERS/OPEN-ENDED TERMS

18. AVAILABILITY STATEMENT 19. S 9 ITY lCUC-AShis report) 21. NO. OF PAGES

Open 20. SECURITY CLASS (This page) 22. PRICE I $

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