P.1 

PICK-UPDATE: 3/8/2007 

BOX 10 OF 10 

Step 2: FOR ASRC INTERNAL USE 

ONLY 

(PART A of B) 

EPA DOCKET ID: 102RQ-RN 

1) INDEX 

3) 102RQ-RN-1-2 

5) 102RQ-RN-1-4 

7) 102RQ-RN-1-6 

9) 102RQ-RN-3-1 

11) 102RQ-RN-3-3 

13) 102RQ-RN-2-1-2 

15) 102RQ-RN-2-1-4 

17) 102RQ-RN-2-2-1 

19) 102RQ-RN-2-3-1 

21) 102RQ-RN-2-4-2 

23) 102RQ-RN-2-4-4 

25) 102RQ-RN-2-4-6 

27) 102RQ-RN-2-4-8 

29) 102RQ-RN-2-4-10 

31) 102RQ-RN-4-2 

33) 102RQ-RN-4-4 

35-XJ02RQ-RN-4-6 ^> 

37) 102RQ-RN-4-8 

39) 102RQ-RN-5-1 

Step 3: FOR ASRC INTERNAL USE 

ONLY 

CD: 

OA: / 

2) 102RQ-RN-1-1 

4) 102RQ-RN-1-3 

6) 102RQ-RN-1-5 

8) 102RQ-RN-1-7 

10) 102RQ-RN-3-2 

12) 102RQ-RN-2-1-1 

14) 102RQ-RN-2-1-3 

16) 102RQ-RN-2-1-5 

18) 102RQ-RN-2-2-2 

20) 102RQ-RN-2-4-1 

22) 102RQ-RN-2-4-3 

24) 102RQ-RN-2-4-5 

26) 102RQ-RN-2-4-7 

28) 102RQ-RN-2-4-9 

30) 102RQ-RN-4-1 

32) 102RQ-RN-4-3 

34) 102RQ-RN-4-5 

36) 102RQ-RN-4-7 

38) 102RQ-RN-4-9 

40) 102RQ-RN-5-2 

Step 1: FOR ASRC INTERNAL USE ONLY 

Are there more documents for this Docket in another box? 

*Fill out Continuation Sheet and go to Step 2 

Internal SFUND Box Number 35 OF 283 

Initials/Date: LDS_/_3-8-2007 

YES / NO 
P.2 

/od-Zf-^'1'-** 

ECONOMIC IMPACT ANALYSIS FOR THE PROPOSED 

REPORTABLE QUANTITY ADJUSTMENTS FOR RADIONUCLIDES UNDER 

SECTION 102 OF THE COMPREHENSIVE ENVIRONMENTAL 

RESPONSE, COMPENSATION, AND LIABILITY ACT 

A Report to the 

EMERGENCY RESPONSE DIVISION 

Office of Emergency and Remedial Response 

U.S. Environmental Protection Agency 

Prepared by 

ICF INCORPORATED 

under subcontract to 

Combustion Engineering, Inc. 

EPA Contract 68-03-3182 

December 1986 

ICF INCORPORATED International Square 

1850 K Street, Northwest, Washington, D. C. 20006 
P.3 

I 

I 

I 

I 

1 

I 

I 

I 

I 

I 

1 

I 

1 

f 

1 

t 

I 

I 

t 

ECONOMIC IMPACT ANALYSIS FOR THE PROPOSED 

REPORTABLE QUANTITY ADJUSTMENTS FOR RADIONUCLIDES UNDER 

SECTION 102 OF THE COMPREHENSIVE ENVIRONMENTAL 

RESPONSE, COMPENSATION, AND LIABILITY ACT 

A Report to the 

EMERGENCY RESPONSE DIVISION 

Office of Emergency and Remedial Response 

U.S. Environmental Protection Agency 

Prepared by 

ICF INCORPORATED 

under subcontract to 

Combustion Engineering, Inc. 

EPA Contract 68-03-3182 

December 1986 
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 Organization of This Report 1-4 

CHAPTER 2: ALTERNATIVE APPROACHES CONSIDERED FOR ADJUSTING 

RADIONUCLIDE REPORTABLE QUANTITIES 2-1 

2.1 Establishment of a Dose-Equivalent Level as the 

Radionuclide RQ 2-2 

2.2 The Selected Approach -- Setting RQs in Terms of Activity 

Levels 2-3 

CHAPTER 3: BASELINE REPORTABLE RELEASES 3-1 

3.1 Baseline Definition 3-1 

3.2 Availability Data Sets for Estimating Radionuclide Releases... 3-3 

3.3 Estimation of Historical Radionuclide Releases 3-5 

3.3.1 Total Number of Annual Releases of Radionuclides 3-7 

3.3.2 Frequency of Release for a Particular Radionuclide .... 3-14 

3.3.3 Size Distribution of Releases 3-14 

3.4 Baseline Reportable Release Estimation 3-17 

CHAPTER 4: VALUATION OF THE EFFECTS OF THE PROPOSED RQ ADJUSTMENTS ... 4-1 

4.1 Actions Taken With a Reportable Release 4-1 

4.1.1 Actions Undertaken By the Regulated Community 4-1 

4.1.2. Actions Undertaken by the Government 4-2 

4.1.3 Incremental Actions Attributable to the Radionuclide 

RQ Adjustments 4-3 

4.2 Valuation of Costs 4-4 

4.2.1 Value of Actions Performed by Regulated Parties 4-4 

4.2.2 Value of Actions Performed by the Government 4-7 

4.3 Valuation of Benefits 4-10 

CHAPTER 5: ESTIMATED ANNUAL COSTS OF THE PROPOSED RQ ADJUSTMENTS 5-1 

5.1 Estimated Change in the Number of Reportable Releases 5-1 

5.2 Estimated Costs of the Proposed RQ Adjustments 5-2 

5.3 Firm-Level Economic Effects 5-5 
P.5 

TABLE OF CONTENTS (continued) 

Page 

CHAPTER 6: ESTIMATED BENEFITS OF THE PROPOSED RQ ADJUSTMENTS 6-1 

CHAPTER 7: SENSITIVITY ANALYSIS 7-1 

7.1 Concepts and Key Variables 7-1 

7.2 Results of the Sensitivity Analysis 7-3 

7.3 Statistical Analysis of Radionuclide Data Base 7-5 

7 .4 Summary 7-6 

APPENDIX A: PROFILES OF FACILITIES THAT RELEASE RADIONUCLIDES A-l 
P.6 

LIST OF EXHIBITS 

Page 

3-1 Radionuclide Data Base Characteristics 3-6 

3-2 Profile of Releases in Nuclear Regulatory Commission AEOD 

Data Set 3-9 

3-3 Frequency of Release for Radionuclides in Data Base 3-15 

3-4 Size Distribution of Radionuclide Releases in Data Base 3-18 

4-1 Release Scenarios 4-8 

5-1 Calculations of Annual Costs of RQ Adjustments Under the 

Proposed Regulation 5-3 

6-1 Radionuclides With Proposed RQ Greater Than One Pound 6-2 

7-1 Sensitivity Analysis Results 7-4 

A-l Facilities using or Producing Radionuclides A-ll 
P.7 

CHAPTER 1 

BACKGROUN D AN D INTRODUCTION 

The purpose of an Economic Impact Analysis (EIA) is to estimate the 

incremental costs and benefits resulting from a regulatory action. Any 

regulation requiring behavior changes will usually result in some elements of 

society which will benefit from the regulation and some elements of society 

which will incur costs. An EIA analyzes those benefits and costs and 

estimates the net gain or net loss under the proposed regulation. 

This chapter describes the general reporting requirements under Sections 

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

Liability Act (CERCLA) and describes the reporting requirements for 

radionuclides in particular. It explains the purpose of the proposed 

regulation and introduces this report to the reader. Section 1.1 describes 

CERCLA reporting requirements and the ranges 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; and 

Section 1.3 describes the remaining chapters of this report. 

1.1 BACKGROUN D ON CERCLA AN D 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 reportable quantity (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, the Environmental Protection Agency (EPA) has the authority under 

Section 102 of CERCLA to designate additional hazardous substances. 

Currently, there are 717 CERCLA hazardous substances. Section 102(b) of the 

statute establishes a one-pound RQ for each of these substances, except those 

for which an RQ was established pursuant to Section 311 of the Clean Water 
P.8 

f 

1-2 

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 equal to or exceeding 

the reportable quantity (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 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 incident 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 radionuclides. A radionuclide is an element 

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

Instability is the net effect of 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. Each radionuclide decays at a different rate and, as a result, 

a pound of two different radionuclides could represent significantly different 

levels of radioactivity. 

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

1985 (50 FR 13456). RQ adjustments for an additional 102 substances were 

established in a final rule published September 29, 1986 (51 FR 34534). 

2 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.9 

1-3 

Radionuclides are designated as hazardous air pollutants under Section 112 

of the Clean Air Act and, as such, are designated CERCLA hazardous substances. 

Section 102 of CERCLA establishes a one-pound RQ for radionuclides, as a 

generic class of substances, but authorizes EPA to adjust the RQ by regulation 

if appropriate. EPA recognizes that an RQ of one pound for radionuclides is 

not appropriate in most cases because releases of less than one pound may 

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

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

commonly used for the purpose of radiation protection. 

All other CERCLA hazardous substances have RQs in units of pounds, ranging 

from one pound to 5000 pounds. For these substances, the principal health 

concerns are chemical toxicity, ignitability, reactivity, or potential 

carcinogenicity, which may be related to some number of pounds released of the 

hazardous substance. Radionuclides are different in this respect from other 

CERCLA hazardous substances. The principal health hazard associated with 

exposure to radionuclides is carcinogenicity, but the hazard is related more 

closely to the radioactivity emitted rather than the mass of the substance. 

Although the level of radioactivity is directly proportional to the mass 

(i.e., the number of pounds) of the radionuclide released, activity levels are 

generally used as indicators of radiation hazard. The quantity of 

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

radionuclide, 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. 

Besides curies, another widely used radiation measurement is the Roentgen 

Equivalent Man (rem).* The rem is a unit measure of radiation dose and is 

often expressed as some number of rem to a specific organ such as the lungs, 

thyroid, or whole body. The difference between curies and rem is that the 

latter considers the routes of exposure and biological effects and, therefore, 

directly reflects the levels of tissue damage. Curies can be converted into 

rem by identifying the radionuclide, mode and duration of exposure, quantity 

of intake, tissues most acutely affected, and other factors. 

The nuclear industry generally works with units of curies and rem and, in 

fact, most existing reporting triggers for radionuclide releases are expressed 

in terms of one 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 in units of curies or rem. Therefore, in order for the RQ under 

CERCLA to be consistent and meaningful, and to ensure that the radionuclide RQ 

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

curie equal to 3.7 x 1010 disintegrations per second. 

^Radiation measurements can also be expressed in international metric 

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

United States. 
P.10 

1-4 

allows for timely reporting and timely field response, if necessary, the 

statutory one-pound RQ is being adjusted in a proposed regulation. 

The proposed RQs are in units of curies and are not uniform across all 

radionuclides. The Agency is proposing to divide radionuclides into seven RQ 

groups: 0.001 curie, 0.01 curie, 0.1 curie, 1 curie, 10 curies, 100 curies, 

and 1000 curies. The Agency is proposing RQs for 757 individual radionuclides 

for which there are metabolic data presented in the International Commission 

on Radiation Protection (ICRP) Report Number 30. The Agency is also proposing 

an RQ for all radionuclides not listed by the ICRP. These other radionuclides 

have a proposed RQ of 1 curie for the entire class. 

For most radionuclides, the proposed RQ adjustments would require 

reporting releases that are considerably smaller than one pound. The proposed 

regulation, therefore, will impose additional reporting and report processing 

costs on the regulated community and the government respectively. This 

analysis discusses and quantifies, to the extent possible, the costs and 

benefits that will result from the proposed RQ adjustments. 

1.3 ORGANIZATION OF THIS REPORT 

This report analyzes the economic effects of the proposed RQ adjustments 

for radionuclides. It analyzes the costs and benefits and estimates the net 

gain or net loss under the proposed regulation. The remainder of this report 

is organized as follows: 

Chapter 2 -- Alternative Approaches Considered for 

Adjusting Radionuclide RQs -- a discussion of the 

regulatory options considered during the proposed rulemaking 

development process; 

Chapter 3 -- Baseline Reportable Releases -- an analysis 

of baseline (pre-regulatory) reportable releases, including 

a discussion of available release data, size distribution of 

releases, and the estimated number of baseline reportable 

releases; 

Chapter 4 -- Valuation of the Effects of the Proposed RQ 

Adjustments -- an explanation of the unit values used in 

estimating the incremental costs and benefits of the 

proposed regulation; 

Chapter 5 -- Estimated Annual Costs of the Proposed RQ 

Adjustments -- an analysis of the additional costs that 

would be incurred by both the regulated community and 

government as a result of the proposed regulation; 
P.11 

1-5 

Chapter 6 -- Estimated Benefits of the Proposed RQ 

Adjustments -- a qualitative assessment of the additional 

benefits under the proposed regulation; 

Chapter 7 -- Sensitivity Analysis -- a test of the 

assumptions used throughout this report to determine 

sensitivity of the results to various assumptions; and 

Appendix A -- Profiles of Facilities that Release 

Radionuclides -- a general discussion of the types and 

number of facilities that potentially release radionuclides. 
P.12 

i 

CHAPTER 2 

ALTERNATIVE APPROACHES CONSIDERED FOR ADJUSTING 

RADIONUCLIDE REPORTABLE QUANTITIES 

Radionuclide production and use in the United States is presently 

regulated and controlled by the Nuclear Regulatory Commission and the 

Departments of Energy and Transportation. These agencies were asked by EPA to 

participate actively in an interagency work group1 whose purpose was to 

explore the relative advantages and disadvantages of alternative approaches 

for adjusting the radionuclide RQ. The work group carefully considered 

numerous RQ adjustment options including: 

• Option 1: Allowing the radionuclide RQ to remain at 

one pound; 

• Option 2: Assigning no RQ to radionuclides; 

• Option 3: Establishing a dose-equivalent level (i.e., 

units of .rem) as the radionuclide RQ; 

• Option 4: Establishing a single level of activity as 

an RQ for all radionuclides; . 

• Option 5: Grouping radionuclides into categories and 

assigning an RQ in terms of activity to each category; 

and 

• Option 6: Establishing an RQ for individual 

radionuclides based on activity levels (i.e., units of 

curies). 

The option of leaving the RQ at one pound was rejected because pound units 

are not meaningful for radiation protection and a quantity of one pound often 

represents potentially high levels of radiation contamination. The second 

option, establishing no RQ for radionuclides, was rejected because it would 

have to be supported by a finding that existing reporting requirements 

adequately cover releases of all radionuclides, and, at present, EPA could not 

make such a finding. In particular, many releases of naturally occurring and 

accelerator produced radionuclides (NARM) are not required to be reported 

under existing federal regulations, and many existing reporting requirements 

do not require immediate telephone notification. 

Option 3 was seriously considered as it is presently the basis of existing 

reporting requirements by the Department of Energy and the Nuclear Regulatory 

*Work group membership also included representatives from the U.S. Coast 

Guard and several offices within EPA. 
P.13 

2-2 

Commission. It was determined, however, that this reporting option required 

too much judgment on the part of the person in charge of the facility or 

vessel and, for purposes of CERCLA reporting, may not produce timely reports. 

Option 4, establishing a single level of activity for all radionuclides, and 

Option 5, grouping radionuclides using specific criteria and assigning 

activity-level RQs to each group, were determined to be inappropriate because 

neither option accounted for the varying degrees of hazard posed by the same 

activity level of different radionuclides. These options would not have 

required radionuclide by radionuclide evaluation to develop an RQ, but rather 

would have required analysis of large groups of radionuclides based on a 

single characteristic. Because of the lack of homogeneity among 

radionuclides, grouping the radionuclides into meaningful categories for 

purposes of RQ development became difficult. 

EPA ultimately selected in the proposed regulation the last option, 

establishing a proposed RQ based on activity levels for selected 

radionuclides. This final option involved an analysis of individual 

radionuclides, evaluating their individual characteristics to determine 

appropriate proposed RQs. Ultimately, all radionuclides were grouped into one 

of seven RQ categories, but only after completion of the individual 

radionuclide evaluations. 

This chapter discusses briefly options 3 and 6, the two adjustment options 

considered most seriously for determining radionuclide RQs. The chapter 

begins with a discussion of the relative advantages and disadvantages of 

establishing dose-equivalent levels as the radionuclide RQ. The chapter then 

discusses the selected option, assigning proposed RQs based on the activity 

levels of individual radionuclides.2 

2.1 Establishment of a Dose-Equivalent Level as the Radionuclide RQ 

EPA explored the option of establishing a radionuclide proposed RQ based 

on a single dose-equivalent level or a set of dose-equivalent levels assigned 

to all radionuclides. A dose equivalent is a direct measure of the amount of 

biological damage resulting from exposure to ionizing radiation. Dose 

equivalent is measured generally in terms of rem or sieverts. A 

dose-equivalent level is not a measure of emitted radiation, but is a method 

of normalizing the effect of an absorbed dose of radiation in tissue, 

regardless of the type of radiation. It is therefore useful from a health and 

environmental protection perspective because the number of rem can be related 

directly to the amount of damage likely to be incurred. The Agency seriously 

considered establishing a proposed RQ for radionuclides in terms of rem 

because most reporting requirements of the Nuclear Regulatory Commission and 

the Department of Energy are in terms of rem. 

2The other adjustment alternatives not specifically presented in this 

chapter are discussed in depth in: ICF, Incorporated and Environmental 

Monitoring & Services, Inc., Technical Background Document to Support 

Rulemaking Pursuant to CERCLA Section 102: Radionuclides, Report to the 

Environmental Protection Agency, Office of Solid Waste and Emergency Response, 

October 1986. 
P.14 

2-3 

To assign proposed RQs in terms of dose equivalent or rem, the Agency 

first had to determine which dose-equivalent level is most appropriate for a 

radionuclide RQ. Several agencies of the U.S. Government and other national 

and international organizations have developed different estimates of the 

appropriate dose-equivalent level. Many of these dose-equivalent levels vary 

substantially. For example, the Federal Radiation Protection Guidance 

recommends a limiting exposure of 500 millirem per year for the general public 

and the ICRP recommends a limit of 5 rem per year for employees of nuclear 

facilities. EPA established an annual dose-equivalent level of 4 millirem per 

year in 40 CFR Part 141 (promulgated under the Safe Drinking Water Act). 

Therefore, there did not appear to be a universally accepted dose-equivalent 

reporting trigger for use under CERCLA. 

A second major issue faced by the Agency when considering this alternative 

involved the development of a standardized methodology for estimating 

dose-equivalent levels. A standardized methodology was considered desirable 

because a dose equivalent is not measurable directly. For a given release, 

different judgments regarding exposure pathways, intake quantity, and other 

factors could lead to different dose-equivalent estimates and, thus, different 

determinations of whether the release is reportable to the National Response 

Center under CERCLA. 

The advantages of establishing radionuclide RQs based on dose-equivalent 

levels are twofold. First, a dose-equivalent value can be related directly to 

potential health effects without having to make further assumptions or 

performing additional calculations. Second, a dose-equivalent level RQ could 

be established for all radionuclides, including mixtures, because one RQ level 

would suffice for all radionuclide releases. 

The disadvantages of the option, however, were perceived to be 

substantial. Among the primary disadvantages was that estimating a 

dose-equivalent level can be quite complicated and its magnitude may vary 

substantially for different circumstances involving the release of the same 

amount of the same radionuclide. For example, different exposure pathways, 

periods of exposure, and bodily organs exposed may yield order-of-magnitude 

differences in dose-equivalent estimates for the same release quantity. 

Moreover, dose-equivalent levels would be more difficult than an activity 

level to estimate quickly during an actual release event. 

For these reasons, the Agency decided to remove the dose-equivalent 

alternative from further consideration, favoring instead the determination of 

proposed RQs for individual radionuclides based on activity levels. 

2.2 The Selected Approach -- Setting RQs in Terms of Activity Levels 

The Agency ultimately decided to propose radionuclide RQ adjustments based 

on levels of activity. 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. 

There are several advantages to basing radionuclide RQs on activity 

levels. For example, a level of radioactivity is much easier to measure than 
P.15 

2-4 

a dose equivalent. A common survey instrument such as a Geiger counter can be 

used to measure directly the ionizing radiation. The Agency believes 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 (e.g., nuclide forms and the potential to migrate 

through the environment). An RQ in terms of dose equivalent (rem) would also 

(by definition) have considered nuclide form and migration 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 

minimizes 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 nuclide-specific RQ approach also has disadvantages however. 

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 health and welfare 

and environmental hazards associated with a radionuclide release, and to 

determine if a federal response is required. 

The general methodology used by the Agency to develop proposed RQs began 

with the ALIs listed in ICRP's Publication 30. These values are annual intake 

limits, in units of curies, that would result in radiation exposure of 5 rem. 

The ALIs were adjusted by EPA to reflect (1) the difference between intake 

levels and release levels and (2) a lower dose equivalent of 500 millirem (0.5 

rem), a more protective release level. Using conservative assumptions 

regarding different releases to air and water, and analyzing exposure through 

inhalation, ingestion, and direct exposure, EPA estimated the smallest number 

of curies for each radionuclide which, if released to the environment, could 

result in a person being exposed to a dose equivalent of 500 millirem. 

The inhalation equation derives a Release Value by dividing the ALI for 

inhalation developed by the ICRP by the product of the following factors: 

• The release fraction that describes the portion of 

radioactive materials that could become airborne in a 

release; 

• The Atmospheric Relative Concentration Value 

corresponding to a ground-level relative concentration 

at 30 meters from a ground-level release under stable 

meteorological conditions; 

• The breathing rate of "Reference Man"; and 
P.16 

2-5 

• Several numerical factors to account for a 500 

millirem dose limit for members of the general public 

and the conversion from microcuries to curies. 

The ingestion equation is based on a ground-water release scenario using 

an advection-dispersion model combined with conservative estimates for such 

parameters as ground-water flow velocities, retardation factors, and 

transverse and longitudinal dispersion. The resulting equation, like the one 

for inhalation, derives a Release Value by dividing the ALI for ingestion by 

the product of an assumed dilution factor, contact time, and water 

consumption, as well as the same numerical factors as the inhalation equation. 

A set of equations were also developed to calculate Release Values for a 

third route of exposure, direct exposure to a release of a radionuclide. One 

direct exposure equation derives the quantity of material intercepted by 

"Reference Man" at a distance 30 meters from a point source release, assuming 

an exposure of 500 millirem. Release Values are derived by dividing the 

product of the squared distance and the absorbed dose by the duration of 

exposure and the product of photon energy emitted and the fraction of the 

encountered radiation absorbed. 

A second direct exposure equation was derived for releases of noble gases 

which result in exposure by submersion in a cloud of radioactive material. 

This second equation uses air concentration values rather than ALIs and, 

therefore, also incorporates the Atmospheric Relative Concentration Value 

mentioned above. 

For each radionuclide, three Release Values were derived: inhalation, 

ingestion, and direct exposure.3 To simplify the administration and 

implementation of RQ reporting, the radionuclides were then assigned to seven 

groups based on the lowest Release Values: 

• 6 radionuclides (0.8%) have a proposed RQ of 0.001 

curie; 

• 25 radionuclides (3.3%) have a proposed RQ of 0.01 

curie; 

• 24 radionuclides (3.2%) have a proposed RQ of 0.1 

curie; 

• 35 radionuclides (4.6%) have a proposed RQ of 1 curie; 

3For further detail on the methodology used in developing the 

radionuclide proposed RQs, see ICF Incorporated and Environmental Monitoring 

and Services, Inc., Technical Background Document to Support Rulemaking 

Pursuant to CERCLA Section 102: Radionuclides, Report to the Environmental 

Protection Agency, Office of Solid Waste and Emergency Response. 
P.17 

2-6 

• 342 radionuclides (45.2%) have a proposed RQ of 10 

curies; 

• 242 radionuclides (31.2%) have a proposed RQ of 100 

curies; and 

• 89 radionuclides (11.8%) have a proposed RQ of 1000 

curies. 

In addition, radionuclides not listed by the ICRP have a proposed RQ of 1 

curie. For all but 30 of the radionuclides with a specific proposed RQ 

adjustment, the proposed RQ is smaller than one pound. It is expected that 

the number of reportable releases for these radionuclides will increase, 

resulting in notification, recordkeeping, and response costs for the affected 

community and notification processing and other response costs for the 

government. Increased benefits of more efficient and timely responses are 

also to be expected. 

For the 30 radionuclides whose proposed RQ is greater than one pound, the 

number of reportable releases are expected to decrease. This should result in 

lower costs to both the affected community and the government, and incremental 

threats to public health and welfare and the environment. Chapter 3 begins by 

discussing the baseline (pre-regulatory) reporting requirements and lays the 

foundation for'estimating the incremental costs and benefits resulting from 

changes in the number of reportable releases under the proposed regulation. 
P.18 

CHAPTER 3 

BASELINE REPORTABLE RELEASES 

A regulatory baseline is the starting point for any economic analysis. 

The baseline provides a measurement of the estimated costs and benefits that 

the affected community would incur if the proposed regulation were not to take 

effect. Once the baseline has been estimated, we can then model the effects 

of the proposed regulation and estimate the post-regulatory costs and benefits 

incurred by society. The difference between the post-regulation costs and 

benefits and the baseline represents the incremental costs and benefits of the 

proposed regulation. 

Baseline costs and benefits are related directly to the number of 

reportable radionuclide releases with a radionuclide reportable quantity (RQ) 

of one pound. The baseline costs are the values placed on actions resulting 

from a reportable release and the benefits are the values placed on cleanup of 

reportable releases. This chapter describes the methodology used to estimate 

baseline reportable releases and presents the baseline release estimates. 

Section 3.1 defines the regulatory baseline for the proposed regulation; 

Section 3.2 describes the data sets available for estimating baseline releases 

of radionuclides; Section 3.3 estimates the number of historical radionuclide 

releases; and Section 3.4 estimates the baseline number of reportable releases 

of radionuclides. 

3.1 BASELINE DEFINITION 

The baseline is an estimate of the costs and benefits the affected 

community would incur if the proposed regulation were not to take effect. It 

is related directly to the number of reportable releases under current 

reporting requirements. 

Many facilities that produce and use radionuclides are regulated already 

by a number of different federal agencies. The Nuclear Regulatory Commission, 

the Department of Energy, the Department of Transportation, and the 

Environmental Protection Agency all impose reporting requirements and/or 

release limitations on facilities under their auspices. In addition, local 

and state license and registration programs also control the regulated 

community. Each agency's reporting requirements are different, frequently 

involving different time frames for reporting. 

An important consideration in analyzing baseline reporting is that Section 

103(a) of CERCLA requires immediate notification to the National Response 

Center by the person in charge of a facility or vessel if a release equals or 

exceeds an RQ. Therefore, reports to other agencies are not a substitute for 

directly telephoning the National Response Center. 

For purposes of this analysis, therefore, the regulatory baseline is 

defined as the costs and benefits associated with reporting releases of 

radionuclides to the National Response Center prior to the proposed 
P.19 

3-2 

regulation. Releases of radionuclides need to be reported immediately to the 

National Response Center under (1) Department of Transportation regulations 

(49 CFR Parts 171-177), and (2) Sections 103(a) and (b) of CERCLA. 

The Department of Transportation (DOT) requires that all transportation 

incidents "involving the shipment of radioactive material in which fire, 

breakage, spillage, or suspected radioactive contamination occurs" shall be 

reported by telephone to the National Response Center "at the earliest 

practicable moment." (49 CFR Section 171.51(a)) 

Sections 103(a) and (b) of CERCLA require immediate notification to the 

National Response Center of all releases of radionuclides (and other CERCLA 

hazardous substances) in an amount that equals or exceeds the applicable RQ.. 

The present statutory RQ for radionuclides is one pound. Section 102(a) 

authorizes EPA to adjust the statutory RQs for all CERCLA hazardous 

substances, including radionuclides. 

There are two important exclusions to CERCLA notification requirements 

that pertain to radionuclides: 

(1) Section 101(22)(C) of CERCLA excludes from the 

definition of release, any release 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) Section 101(10)(K) of CERCLA defines a federally 

permitted release (such releases need not be reported 

to the National Response Center) to include "any 

release of source, special nuclear, or byproduct 

material, as those terms are defined in the Atomic 

Energy Act of 1954, in compliance with a legally 

enforceable license, permit, regulation, or order 

issued pursuant to the Atomic Energy Act of 1954." 

The first exclusion refers primarily to reactor incidents. The second 

exclusion has been interpreted by the Agency to mean any release that is in 

compliance with a regulation, license, or order from EPA, the Nuclear 

Regulatory Commission, an agreement state, or the Department of Energy. 

EPA has issued a proposed regulation defining the scope of the federally 

permitted release reporting exemption (48 FR 23552, May 25, 1983). This 

regulation is scheduled to be reproposed in the near future. The draft 

reproposal states that any release of a CERCLA hazardous substance must be 

reported immediately to the National Response Center if the release exceeds 

federally permitted levels by an RQ or more. If the release is less than an 

RQ above permitted levels, the release is not considered federally permitted 

but nonetheless need not be reported to the National Response Center under 
P.20 

3-3 

Sections 103(a) and (b) of CERCLA. Releases in compliance with EPA 

regulations, Nuclear Regulatory Commission licenses, agreement state licenses, 

and Department of Energy Orders are considered federally permitted under 

Section 101(10)(K) of CERCLA, and therefore do not need to be reported to the 

National Response Center. 

Given these baseline reporting requirements, the following radionuclide 

releases would be, strictly speaking, baseline reportable releases: 

• All reportable transportation incidents; 

• All federally permitted releases that equal or exceed 

permitted levels by the statutory one-pound RQ; and 

• All non-federally permitted releases that equal or 

exceed the statutory one-pound RQ. 

However, we focus the analysis on non-transportation releases because all 

transportation incidents are already required to be reported to the National 

Response Center and, thus, the proposed regulation should not generate any 

increased reporting of transportation incidents. Adjustment of the 

radionuclide RQ, however, could affect the number of reports from facilities 

with and without federal permits because the reporting trigger is being 

adjusted in the proposed regulation. 

3.2 AVAILABLE DATA SETS FOR ESTIMATING RADIONUCLIDE RELEASES 

A radionuclide release data base was created for this analysis. The data 

base contains information describing radionuclide releases in the United 

States. Included in the information assembled in the data base are the date 

of each release and, when available, the radionuclide and quantity (in curies) 

released. These data were used to develop size and frequency distributions 

for radionuclide releases. We estimated the expected number and size of 

future radionuclide releases using data on the number and size of past 

radionuclide releases. 

In developing the radionuclide release data base, release reports were 

incorporated from six sources: 

• 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, 1971 through 1985; 

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

Environment and Health, Emergency Operations Center 

(EOC), March 1983 through April 1986; 
P.21 

3-4 

• Reports to the National Response Center, 1982 through 

1985; 

• Reports to the Environmental Protection Agency'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. 

Of these six sources, the Nuclear Regulatory Commission's Office of 

Analysis and Evaluation of Operational Data (AEOD) incident reports were the 

most complete for our purposes, both in terms of release descriptions and the 

population of release events included in the data. These reports usually 

contained details on the quantity and identity of the radionuclide released. 

The AEOD reporting population includes all Nuclear Regulatory Commission 

licensees and some reports from agreement state licensees. 

The release data obtained from the Transportation Technology Center (TTC) 

and DOE's Emergency Operations Center (EOC) are equally complete in terms of 

information provided. These sources, however, provide information on a much 

smaller subset of release events than does AEOD. The TTC data are limited to 

transportation accidents/incidents involving radioactive material; the EOC 

data are limited to the past three years (1983-1986) and include only 

reportable events under DOE Order 5484.1. Other events are not included in 

the EOC data set. 

The release data from the National Response Center did not contain 

detailed quantity information and were, for the most part, not included in our 

data base. Reports examined from the Nuclear Regulatory Commission's 

Operation Center included only "release events" as defined by the Nuclear 

Regulatory Commission. The Commission's definition is narrower than CERCLA's 

definition of release. 

Incident report duplication between the six sources appears to be 

relatively limited. In developing the radionuclide release data base, we 

tried to avoid double counting of releases by cross-checking the details about 

particular release events. Incompleteness of the reports in some of the sets 

and inconsistencies in dates of the events, however, complicated this effort. 

Duplicates, therefore, have probably not been totally eliminated. 

The radionuclide release data base developed for this analysis includes 

1,139 events. These events range in size over many orders of magnitude, from 

-9 

5.0 x 10 curies to 56,892 curies. Of the 1,139 events in the data base, 

there are 455 events with no quantity information or for which units of curies 

could not be determined from available information. These 455 release events 

were used only in the estimation procedure to determine the frequency of 

release for particular radionuclides but could not be used to estimate the 

size distribution of radionuclide releases. There are also 23 events included 

in the data base that do not identify the radionuclide released but do have 
P.22 

3-5 

information on the quantities released. These events were used in the 

estimation procedure to determine the size distribution of radionuclide 

releases but could not be used to estimate the frequency of release for 

particular radionuclides. In cases where neither the radionuclide nor the 

quantity information was available in a data set, the event was not included 

in the data base of 1,139 events. Exhibit 3-1 summarizes the characteristics 

of the data base. 

3.3 ESTIMATION OF HISTORICAL RADIONUCLIDE RELEASES 

Baseline reportable releases are the number of releases that would need to 

be reported to the National Response Center if the proposed radionuclide RQ 

adjustments were not to take effect and the radionuclide RQ remained at one 

pound. Because it is not possible to predict the future with certainty, we 

rely on historical release events to characterize the likelihood of future 

releases of radionuclides. The number of historical radionuclide releases 

(both reportable and non-reportable) is the starting point in the estimation 

process for determining baseline annual reportable releases. We estimate 

baseline annual reportable releases to be a function of three factors: 

(A) total nunrber of annual releases of radionuclides; 

(B) frequency of release for a particular radionuclide; and 

(C) probability that a release equals or exceeds the 

reportable quantity of a particular radionuclide (i.e., 

the equivalent, in curies, of one pound or one pound 

above permitted or licensed levels). 

In particular, the total number of baseline reportable releases can be 

represented as follows: 

Total Baseline Releases = (A)*£[(B.)*(C.)] 

The product of B. and C. represents the product of B., the probability 

of a release of a particular radionuclide, and C , the probability that any 

radionuclide will be equal to or above reportable levels, as that is defined 

for each radionuclide. 

Therefore, the product [B.*C] represents the probability that a 

release of a particular radionuclide will be equal to or above reportable 

levels. The summation of this product represents the probability that any 

release will be equal to or above reportable levels. When we multiply this 

latter probability by (A), the total number of annual radionuclide releases at 

any level, we are able to derive the total number of annual radionuclide 

releases equal to or greater than the baseline RQ. Each of these factors is 

discussed in more detail below. 
P.23 

3-6 

EXHIBIT 3-1 

RADIONUCLIDE DATA BASE CHARACTERISTICS 

Total number of release events in data base 1,139 

Number of release events without quantity 

information 455 1 

Number of release events with quantity |--1,139 

information (used to estimate size distri- | 

bution of radionuclide releases) 684 ' 

Number of release events with radionuclide 

unidentified 23 1 

I 

Number of release events with radionuclide |--1,139 

identified (used to estimate the probability | 

of release for a particular radionuclide) 1,116 ' 

Number of radionuclides identified in data 

base 63 

Source: ICF analysis. 
3-7 

3.3.1 Total Number of Annual Releases of Radionuclides 

The available data sets discussed in Section 3.2 above do not cover 

releases from all facilities that handle and are therefore likely to release 

radionuclides.1 The data base established for this analysis is used 

primarily to develop the estimated frequency of release for particular 

radionuclides (factor B above) and the estimated size distribution of releases 

(factor C above). It is not used to estimate the total number of releases 

(reportable and non-reportable) of radionuclides by the affected community 

because a large portion of the releases by the affected community is not 

included in the data base (e.g., releases from facilities in agreement states 

are not included generally in the data base). 

To estimate the total number of annual radionuclide releases, we focus the 

analysis on non-transportation releases because all transportation incidents 

are already required to be reported to the National Response Center. Thus, 

the proposed regulation should not generate any increased reporting of 

transportation incidents; the incremental increase in reportable radionuclide 

releases consist only of non-transportation releases. 

We assume that the number of non-transportation releases is pr&portional 

to the number of facilities producing and using radionuclides in any 

appreciable quantity. We realize this assumption is an over-simplification 

and, thus, is not entirely accurate. The probability of a release event 

occurring at a facility is probably correlated with use levels and types and 

forms of radionuclides used at a facility. If a facility uses a small 

quantity of radionuclides in a sealed form, the likelihood of a release from 

that facility would be less than at a facility that uses a large quantity of 

radionuclides in an unsealed form. Unfortunately, facility-specific data on 

radionuclide production and use levels are unavailable. 

To derive the number of annual non-transportation radionuclide releases, 

therefore, we rely on the Nuclear Regulatory Commission AEOD data. We use 

these data because the number of facilities required to report releases to the 

Nuclear Regulatory Commission is well defined and we can thus establish the 

relationship between the number of releases and the number of facilities 

required to report. The AEOD data set includes most release events from 

Nuclear Regulatory Commission licensees and some small fraction of the release 

events from agreement state licensees. Only Commission licensees are required 

to notify the Nuclear Regulatory Commission when there is a radionuclide 

release. However, some states and some facilities licensed by agreement 

xAppendix A of this report describes the major types of facilities that 

produce and use radionuclides. Releases from facilities in agreement states 

would not be expected to be represented in the Nuclear Regulatory Commission 

data sets, the Sandia National Laboratory's data set, the Department of Energy 

data set, or the EPA's Office of Radiation Programs data set. It is possible 

that releases from these facilities could be represented in the data set from 

the National Response Center, but the data from this source are mostly 

qualitative and were, for the most part, not included in our data base. 
P.25 

3-8 

states notify the Commission of a release even though they are not strictly 

obligated to do so. 

It would not be appropriate simply to use the average number of events 

reported annually in the AEOD data set to represent average annual reportable 

releases in the baseline from Commission licensees. Because reporting an 

incident is relatively simple and because the nuclear industry is closely 

monitored and highly sensitive to public concerns, there is a tendency for the 

regulated community to report any incident, regardless of the quantity 

involved and regardless of whether the event actually results in a release to 

the environment. On the other hand, it is likely that some facilities may not 

be reporting all reportable release events. In addition, the AEOD data set 

does include some transportation incidents that must be elminated before we 

can use the data in our analysis. 

A release is defined as an event where radionuclides are released into the 

environment. Strict determinations of releases in the AEOD data are difficult 

to make because the reports generally lack detail. It is difficult to 

determine, for example, whether a radionuclide release was contained by a 

structure or whether the radionuclides escaped to the environment. To promote 

consistency, we established criteria for categorizing the various events. 

These criteria are conservative to develop an upperbound estimate of the 

number of release events per year. These release events are not necessarily 

large nor do they pose a danger to public health or welfare or the 

environment; they are simply release events reported to the Nuclear Regulatory 

Commission over the last five years. 

For the years 1981 through 1985, the release profile for the AEOD data set 

is shown in Exhibit 3-2. About 25 percent of all reports classified in this 

analysis as release events are clearly events involving releases to the 

environment. The remaining events were classified as releases to the 

environment in the following manner: 

• Reports of loss, theft, or burial of radioactive 

equipment or sources (approximately 40 percent of the 

reports) -- Reports of lost radioactive seeds, stolen 

machinery, and burials of radioactive machinery or waste 

in landfills were classified as releases to the 

environment. The most commonly reported event 

throughout the AEOD data is the abandonment of sources 

in drilling holes. Because the sources are not 

recoverable, the Agency considers all such events to be 

releases to the environment, even if the sources are 

encapsulated with cement or slurry. 

• Reports of contamination of shipped products or 

equipment (approximately 15 percent of all releases) --

Reports of contaminated or leaking equipment involved in 

shipping are considered events involving releases to the 

environment. They are, however, classified only as 

transportation releases when escape or leakage of 
P.26 

3-9 

EXHIBIT 3-2 

PROFILE OF RELEASES IN NUCLEAR REGULATORY COMMISSION 

AEOD DATA SET 

Year 

1981 

1982 

1983 

1984 

1985 

Annual 

Average 

Total 

Number of 

Release Events* 

103 

82 

103 

92 

83 

s: 93 

Total Number of 

Transportation 

Releases 

7 

5 

8 

3 

9 

6 

Total Nun 

Non-Transportat 

fron 

Agreement 

States 

2 

1 

8 

3 

15 

iber 

ion 

i : 

of 

Releases 

Commission 

Licensees 

94 

76 

87 

86 

59 

80 

*A release event is defined as an event where radionuclides are released 

into the environment. It was often difficult to determine from the 

information in the reports whether a release to the environment actually 

occurred. When in doubt, for purposes of this analysis, we assumed the event 

did result in a release to the environment. In addition, many of the releases 

were exceedingly small, posing no danger to public health or welfare or the 

environment. The number of releases represented in this table are not 

necessarily reportable under either the one-pound RQ or the proposed RQs. The 

table simply presents the maximum number of events in the AEOD data that could 

be considered releases to the environment. The AEOD data sets also include 

additional events that were not considered to be releases. These events 

include, for example, reports of failure to submit monitoring data and 

incorrect labels on containers. 

Source: ICF estimates. 
P.27 

3-10 

radioactive materials is evident to shipping personnel 

and reported by them. A spill of material on a highway, 

for example, is considered a reportable transportation 

release. Damage, loss, or contamination of a package 

during shipping that was not clearly evident to shipping 

personnel, however, is assumed to be a non-transportation 

release. For example, if a package was received 

damaged, and the report does not clarify that the 

shipping agent was aware of the damage and had actually 

reported the incident, for purposes of this analysis, 

the report is considered a non-transportation release. 

• Reports of high stack concentrations and radiation in 

unrestricted areas (approximately 15 percent of all 

reports) -- Citations of high concentrations of 

radioactive material in exhaust stacks and airborne 

radiation in unrestricted areas are both classified as 

releases to the environment. That is, if reports do not 

specify the location of airborne radioactive materials, 

we assume the event involved a release to the 

environment. 

• Reports of allegations of releases (about 2 percent 

of all reports) -- Although not officially confirmed, 

allegations by personnel of release events (e.g., the 

burial of radioactive waste in a landfill) are 

considered releases to the environment. 

• Report of fire (about 2 percent of all reports) --

Citation of a fire is considered evidence of a release 

except where a report indicates specifically no 

contamination. 

The following events were not classified as releases to the environment: 

• Reports of a leaking source -- Although it was not 

always possible to determine whether the leak occurred 

in a secure enclosure, we did not classify these events 

as releases to the environment. 

• Reports of positive radioactivity test results --

Reports citing test results that found "removable" 

radiation on lab and industrial equipment were not 

classified as releases to the environment. 

• Reports of exposure of badges or personnel -- Where 

badges worn by personnel reflect exposure to 

radioactivity, this analysis assumes exposure occurred 

in a contained structure. Badge exposure therefore was 

not classified as a release to the environment. 
3-11 

• Report of loose packaging -- Reports of loose or 

improper packaging used for purposes of transport were 

not considered evidence of a release. However, the 

observed escape of liquid or solid material from 

packaging was considered evidence of a release. 

As shown in Exhibit 3-2, there are an estimated 80 annual non-transportation release events reported by Commission licensees in the AEOD data set. If 

we assume that 80 percent of all releases are actually reported to the Nuclear 

Regulatory Commission,2 then the number of non-transportation radionuclide 

releases by Commission licensees is estimated to be 100 releases annually. 

As discussed in Appendix A of this report, there are approximately 75,000 

facilities that could potentially release radionuclides, including facilities 

in the following categories: 

• Nuclear Regulatory Commission licensees (8,900); 

• Agreement state licensees (13,000); 

• DOE facilities (78); and 

• Unlicensed facilities (53,475): 

Laboratories (700) 

Coal-fired utility and industrial boilers (52,500), 

Uranium mines (181 -- 21 active), 

Aluminum smelters (32), 

Copper smelters (15), 

Zinc smelters (5), 

Lead smelters (5), 

Phosphate rock plants (31), and 

Elemental phosphorous plants (6). 

These industries are heterogeneous and, therefore, have very different 

probabilities of releasing radionuclides at levels that equal or exceed an 

RQ. Several of these industries are unlikely to be affected by the proposed 

RQ adjustments because they release radionuclides in very small quantities and 

only as part of their normal operations. Examples of these industries 

include: coal-fired boilers, aluminum, copper, zinc, and lead smelters, and 

phosphate rock plants. Radionuclide release cannot occur due to a spill at 

these facilities, but only due to the burning of the coal or ores during the 

production processes. The radionuclide releases may occur into water, into 

2We have no data on the amount of under-reporting that occurs, but 

because Commission licensees are highly regulated and very sensitive to public 

concerns regarding radiation, we believe the assumption that 80 percent of 

releases are reported is reasonable. This figure is not assumed to be higher 

because there will always be some releases that the releaser will not report. 

Thus, under-reporting is taken into account here. We test the effect of this 

assumption in Chapter 7 of this report. 
P.29 

3-12 

air, or through disposal of the sludge. Air releases from the facilities were 

examined closely by the Agency because radionuclides are a hazardous air 

pollutant under Section 112 of the Clean Air Act. The following discussion 

presents the general results of the Agency's analysis of the air releases from 

each of the different facilities. 

Coal-fired boilers release radionuclides to the air only when they burn 

coal. The radionuclide quantities released during the coal-burning process 

are smaller than the proposed RQ levels. Radionuclides released from a large 

utility boiler, for example, are in the uranium and thorium series and are 

released at levels generally close to 0.0001 curies per day, except for 

radon-220 which is released at levels of close to 0.001 curie per day. These 

levels are below the proposed RQs for the affected radionuclides, and well 

below the proposed RQ of 100 curies for radon-220. For industrial boilers, 

which have relatively smaller thermal capacity and coal consumption, emission 

-5 levels are closer to 10 curie per day,3 well below the proposed RQs. 

Similarly, aluminum, copper, zinc, and lead smelters release radionuclides 

to the air only when they process their respective ores. The radionuclide 

quantities released to air from a typical smelter vary by the type of ore 

-7 -4 

processed, but range generally from close to 10 curie to 10 curie per 

day, well below the lowest proposed RQ of 0.001 curie per day.* Therefore, 

air releases from these industries will not be affected by the proposed RQ 

adjustments. 

Phosphate rock plants are also not expected to be affected by the proposed 

RQ adjustments due to releases to air. Phosphate rock plants release 

radionuclides to the air during grinding and drying processes at levels no 

higher than 10 curie per day.5 This is well below the lowest proposed 

-3 

RQ of 10 curie. 

The coal-fired boilers, smelters, and phosphate rock plant air emissions 

have been analyzed thoroughly by EPA when the Agency was considering 

regulating radionuclide emissions under Section 112 of the Clean Air Act. The 

Agency concluded that "good reasons exist to propose not to regulate the 

following categories of facilities: (1) coal-fired boilers, (2) the phosphate 

industry, (3) other extraction industries..." (48 FR 15076, April 6, 1983). 

Radionuclide air emissions from these facilities do not present a potential 

threat to public health or welfare or the environment and will not be affected 

by this proposed regulation because air releases from these facilities are 

expected to be the result of plant operations only and to be well below the 

3ICF analysis based on emissions data in U.S. Environmental Protection 

Agency, Radionuclides Background Information Document for Final Rule, Volume 

2, EPA 520/1-84-022-2, Office of Radiation Programs, October 1984, p. 4.2-7. 

"Ibid., pp. 7.1-8, 7.2-6, 7.3-4. 

5Ibid., p. 6.1-11. 
P.30 

3-13 

proposed RQs. Radionuclide releases due to contamination of sludge may be 

reportable under CERCLA, however, if the release is equal to or above an RQ. 

Regarding releases to water, the Supreme Court rules in Train vs. Colorado 

Public Interest Research Group, 426 U.S. 1 (1976) that "source," "special, 

nuclear," and "byproduct" materials are not pollutants within the meaning of 

the Clean Water Act. As such, specific releases of radionuclides were not 

considered in developing effluent limitations under the Act. However, NARM 

(naturally occurring and accelerator produced radioactive materials) can be 

limited specifically in water discharge permits, and regulation of certain key 

indicator pollutants can result in the control of other pollutants, including 

radionuclides. Therefore, water releases of radionuclides may or may not be 

considered federally permitted under Section 101(10) of CERCLA. 

In a similar manner, unlicensed laboratories are not licensed by the 

Nuclear Regulatory Commission because they do not handle radionuclides in 

sufficient quantities to warrant concern. In particular, unlicensed 

laboratories do not handle radionuclides in quantities close to the proposed 

RQs. It would be virtually impossible, therefore, for these facilities to 

release radionuclides at reportable levels. Therefore, for purposes of this 

analysis, we assume the universe of affected facilities does not include 

coal-fired boilers, aluminum, copper, zinc, and lead smelters, phosphate rock 

plants, or small, unlicensed laboratories. 

The remaining unlicensed facilities, uranium mines and elemental 

phosphorous plants, could be affected by the proposed regulation. These two 

industries were analyzed by EPA to determine the levels of radionuclide air 

emissions from these facilities. Unlike the boilers and smelters discussed 

above, uranium mines and elemental phosphorous plants were found to emit 

radionuclides at controllable levels. These emissions were controlled, 

therefore, under Section 112 of the Clean Air Act and these facilities could 

be releasing radionuclides in quantities greater than or equal to an RQ. 

However, releases in compliance with Section 112 limitations are considered 

federally permitted under CERCLA Section 101(10)(H) and would need to be 

reported to the National Response Center only if the quantities released 

exceed federally permitted levels by an RQ or more.6 

Therefore, the facilities that could be affected by the proposed 

regulation because they could release radionuclides at levels equalling or 

exceeding an RQ make up a universe of approximately 22,000 facilities, 

consisting of 8,900 Commission licensees, 13,000 agreement state licensees, 78 

DOE facilities, and approximately 25 active uranium mines and elemental 

phosphorous plants. Releases from these facilities could be considered 

6The federally permitted release reporting regulation is scheduled to be 

reproposed in the near future. This proposed rule requires any federally 

permitted release, as defined in Section 101(10) of CERCLA to be reported to 

the National Response Center if it equals or exceeds licensed or permitted 

levels by an RQ or more. 
P.31 

•14 

federally permitted either under Section 101(10)(K) for releases from 

Commission licensees, agreement state licensees, and DOE facilities, or under 

Section 101(10)(H) for releases from uranium mines and elemental phorphorous 

plants. 

Because there are 8,900 Commission licensees that are responsible for an 

estimated 100 radionuclide non-transportation releases annually, the total 

number of annual non-transportation releases of radionuclides from all 22,000 

regulated facilities is approximately 250 release events per year (assuming 

proportionality between the number of releases and the number of regulated 

facilities). 

It must be emphasized that this is just a gross estimate. Because these 

22,000 regulated facilities are not homogeneous, they cannot be expected to 

have uniform release patterns. They release different radionuclides, at 

different propensities, and at different levels. We believe this estimate is 

an upperbound estimate, although not all facilities that could potentially 

release radionuclides have been included in this estimation procedure. In 

particular, facilities that use naturally occurring and accelerator produced 

radioactive material (NARM) are not included in this analysis. We have no 

data on these facilities. Nevertheless, we believe the estimate of 

approximately 250 release events per year is reasonable. It is based on 

several key assumptions: 

• total releases from regulated facilities are 

proportional to the number of regulated facilities using 

and producing radionuclides; 

• total number of releases per Commission licensee as 

reported in the AEOD data represents the average number 

of releases per facility for all types of regulated 

facilities; and 

• amount of under-reporting for Commission licensees is 

20 percent. 

We do rely heavily on these assumptions to estimate the number of 

non-transportation radionuclide releases from facilities using or producing 

radionuclides in any sizable quantity. We believe, however, that the 

assumptions used are reasonable for purposes of this analysis. The estimates 

include both reportable and non-reportable releases. The large majority of 

these releases are expected to be exceedingly small, well below the proposed 

RQs, and would not be expected to pose a danger to public health or welfare or 

the environment. We test the effect of these assumptions in Chapter 7 of this 

report. 

3.3.2 Frequency of Release for a Particular Radionuclide 

The data base assembled for this analysis identifies 63 radionuclides in 

1,139 release events. We assume that if a release of a particular 

radionuclide occurred in the past, it serves as an indication of the 
P.32 

3-15 

likelihood that the radionuclide will be released in the future. For each of 

the 63 radionuclides identified in our data base, we assume the probability of 

a future release can be derived from the frequency of past reported releases 

for that particular radionuclide. For example, uranium-238 (U-238) is 

involved in 129 of the 1,116 events with identified radionuclides in our data 

base. We assume, therefore, that the probability a radionuclide release is 

specifically a release of uranium-238 is 129/1,116 or .116. Iodine-125 

(1-125) is involved in 64 events. We assume the probability that a 

radionuclide release is specifically a release of iodine-125 is .057 

(64/1,116). This calculation is performed for each of the 63 radionuclides 

and is shown in Exhibit 3-3. All other radionuclides have been assigned a 

zero probability of release because we have no data on past releases for these 

radionuclides. 

3.3.3 Size Distribution of Releases 

The 684 release events in our data base that have quantity information are 

used to develop a size distribution of releases for radionuclides. By taking 

the logarithms of the release events in the data base, a log normal 

distribution develops, with a mean of 0.15 curies and standard deviation of 

2.7 curies. The data are skewed, reflecting a much higher probability of a 

small release and a small probability of a large release. Exhibit 3-4 

displays the size distribution of the releases in the data base. The 

frequency distribution shows, for example, that there are 152 release events 

in our data base where the quantity released is greater thaji 1 curie and less 

than or equal to 10 curies. There are 110 release events in our data base 

where the quantity released is greater than 10 curies and less than or equal 

to 100 curies. There are only 7 release events in our data base where the 

quantity released is greater than 1000 curies. 

3.4 BASELINE REPORTABLE RELEASE ESTIMATION 

Baseline non-transportation radionuclide releases include all radionuclide 

releases that exceed permitted levels by one pound or more at licensed or 

regulated facilities. We have already estimated annual non-transportation 

radionuclide releases to be approximately 250 releases per year. We now 

determine the fraction of these releases that are required to be reported in 

the baseline to the National Response Center. 

We estimate in Appendix A that there are about 21,900 Commission and 

agreement state licensees, 78 DOE facilities, and approximately 25 active 

uranium mines and elemental phosphorous plants. In addition, there are 

approximately 53,000 facilities without federal permits that could release 

radionuclides but only at extremely low levels. Although we estimate that 

there are about 250 annual releases of radionuclides, not all of these 

releases are reportable presently under CERCLA; only releases that equal or 

exceed one pound for releases that are not federally permitted, and releases 

that exceed permit or license levels by one pound or more need be reported to 

the National Response Center. 
CO 

co co 

H __ 

X 

X UJ 

co UJ _ J 

O _. 

z 

o 

Q 

< c_ C_ UJ O 00 

i_. < 

_ _* 

"**• I-

- • ^ UJ mmm 

----

>-

o 

z LU 

a UJ c_ 

LL. 

0) cn cd a) 

r-l a) Pi 

m 

o 

>-. 

-p •H 

i-H 

•i-t X I cd XI 

o 

I-I 

CL, MH 

o 

I-I a> X i 

H 

3 

Z 

0) 

-rt 

•r-l 

r-l 

O 

3 

G 

o 

•H T l cd 

K 

u a> 

P-, 

a> X) •H 

i—i 

o 

rc o 

•H TJ cd 

« 

r-l cu CL, cn -P 

C a) 

> 

w a) xi •H rH 

o ci 

o •H TJ cd 

cvicom^orNweoco-^flOwi^oxONvocomoi^oocnwrNMcococ^rvffiiowaiN^inaiv o 

oov4DO*o(TiCNiOiHrHio>HOcvioo<-iiHooi-0'-i

,

*oo\o<-ir-ir^ooooi--ioo*j-<o--*ocy » 

mvOOOOOOOOOOvOOOOOOOOOOOOCOOOiOOCMOOOOOCNiHOOC M 

OOOOOOOOOOOOOOOCMOOOOOOOOOOOOOOOOOOOOO O 

ooooooooooooooooooooooooooooooooooooo o 

-o*t H . o n 

VO r-* rH 

CM N -D N (O Cl 

VO 

lO CM <N <N 

i—i •—i vo CM r- i—i 

H CM N -* 

-4- vO 

CM CO 

OV 

MO 1(1 H (O 

CM T-I CO 

•-H co cjv.-1.4- rH .4 r^ CM -H; 

•* w H n Loo*t*tNcooriton(oio m NP?-tH4^HrlNIOUV_10HHHH H I — I I I-I I I I I I I I I I I I I I 2 a ps <c 1 <Qwsooot_;OTwcoD O 

^•^<imuoouuouuououw w 

r-» •-< C M 

10 ov r- r- av co -O ov >-H IH ov 

CO 10 i-O vO r-. H CM N N (O rt H 

r-HI I I I CO I rH rH rH i-H I I 

1 H H < (_| • O • • • *Z « 

hhhOUKWHHHHH H 

rH IO OV -4 OV CO 

CM 00 00 OV CM IO vo 

-4- I I I I 1 I I f_] OS O < ! H r-H w E 5 s z z z 
P.34 

3-17 

EXHIBIT 3-3 

FREQUENCY OF RELEASE FOR RADIONUCLIDES 

IN DATA BASE 

(Continued) 

Radionuclide 

OS-185 

OS-191 

P-32 

PB-210 

PB-212 

PM-147 

PO-210 

PU-238 

PU-239 

RA-226 

RB-88 

RU-106 

S-35 

SB-125 

SR-90 

TA-182 

TC-99 

TH-232 

TH-234 

TL-201 

TL-204 

U-235 

U-238 

XE-133 

ZN-65 

Subtotal 

Unknown i 

TOTAL 

Events 

sotopes 

Number of 

Pei 

1, 

1, 

• Radionuclide 

2 

1 

9 

1 

1 

14 

17 

3 

9 

4 

1 

2 

4 

1 

17 

2 

37 

12 

1 

2 

4 

18 

129 

15 

3 

116 

23 

139 

Probability of Release 

Per Radionuclide 

0.0018 

0.0009 

0.0081 

0.0009 

0.0009 

0.0125 

0.0152 

0.0027 

0.0081 

0.0036 

0.0009 

0.0018 

0.0036 

0.0009 

0.0152 

0.0018 

0.0332 

0.0108 

0.0009 

0.0018 

0.0036 

0.0161 

0.1156 

0.0134 

0.0027 

1 

Source: ICF estimates. 
P.35 

3-18 

EXHIBIT 3-4 

SIZE DISTRIBUTION OF RADIONUCLIDE RELEASES 

IN DATA BASE 

Number of Releases 

Quantity in Data Base that 

(Curies) Equals or Exceeds Quantity 

Probability that Release 

Will Equal or Exceed 

Quantity

 1 

0.001 

0.01 

0.1 

1 

10 

100 

1000 

521 

437 

337 

280 

128 

18 

7 

0.762 

0.639 

0.493 

0.409 

0.187 

0.026 

0.010 

1 Derived by dividing 684 into the number of releases in the data base 

that equals or exceeds that quantity. There is a total of 684 releases 

with quantity information in the data base. 

Source: ICF analysis. 

FREQUENCY DISTRIBUTION 

**7 

_ 

15 

RAW OATA 

17 

^?-—7 -

s 

SO 40 SO CO 

QUANTITY (CQ 

70 100 >100 
P.36 

3-19 

Federally permitted releases are assumed to be all releases from 

Commission licensees, agreement state licensees, and DOE facilities that are 

in compliance with 10 CFR Part 20 limitations and other license or contract 

requirements, and releases from uranium mines and elemental phosphorous plants 

that are specified in and in compliance with regulations under Section 112 of 

the Clean Air Act. As discussed in Chapter 2 of this report, the proposed RQs 

were derived from the Annual Limits of Intake (ALI) developed by the ICRP. 

These have been adopted by the Nuclear Regulatory Commission in its proposed 

revision to 10 CFR Part 20. For purposes of this analysis, therefore, we 

assume that the 10 CFR Part 20 limitations are equivalent to the proposed 

RQs. Because of the conservative assumptions used in the development of the 

proposed RQs, and because the ALIs are based on a dose equivalent of 5 rem, 

not 500 millirem, it is expected that, under most circumstances, facilities 

can release more than the proposed RQ without exceeding the 500 millirem per 

year limit for exposure to the general public (i.e., without exceeding 

federally permitted levels for licensees). The assumption that the proposed 

RQs equal the federally permitted release levels would, therefore, 

over-estimate the number of reportable releases at facilities with federal 

licenses in both the baseline and post-regulation situations. The incremental 

number of reportable releases should, however, remain unchanged. The 

sensitivity of our results to the number of reportable releases is addresssed 

in Chapter 7 of this report. 

The federally permitted release levels for uranium mines and elemental 

phosphorous plants have been established.by EPA under Section 112 of the Clean 

Air Act. These levels are independent of the ALIs. However, for purposes of 

this analysis, we treat all facilities that have federally permitted releases 

in the same manner; we assume the propensity to release radionuclides is 

uniform and that federally permitted release levels can be represented 

reasonably as being equivalent to the proposed RQs. Therefore, because 

baseline reportable releases from facilities with federal permits are all 

releases from these facilities that equal or exceed permitted or licensed 

levels by one pound, and because for any particular radionuclide, the 

federally permitted release level is assumed to equal the proposed RQ, a 

release of a radionuclide would need to be reported to the National Response 

Center if it equals or exeeds the proposed RQ plus one pound. 

For each radionuclide in our data base, the frequency of release shown in 

Exhibit 3-2 was multiplied by the probability that a release will equal or 

exceed the proposed RQ plus one pound for that radionuclide (all expressed in 

curies). This probability is derived from the size distribution of releases 

shown in Exhibit 3-4. By multiplying the frequency of release for a particular 

radionuclide by the probability that any radionuclide release will equal or 

exceed the equivalent, in curies, of the proposed RQ plus one pound, we derive 

the probability that a release of a particular radionuclide will be reportable. 

For example, radium-226 has an estimated frequency of release of 0.0036 

because it was reported released in our data base 4 times. Radium-226 has a 

proposed RQ of 1 curie and one pound of radium-226 is equivalent to 449 

curies. By examining all 684 releases with quantity information in our data 

base, we determine that there are 10 radionuclide releases in the data base 

that equal or exceed 450 curies, the proposed RQ plus one pound for 

radium-226. We estimate, therefore, that there is a 0.0146 (10/684) 
P.37 

3-20 

probability that a release of 450 curies or greater will occur. The estimated 

probability that radium-226 will be released at levels that equal or exceed 

the proposed RQ plus one pound, therefore, is equal to 0.00005 (0.0036 x 

0.0146). 

By performing this calculation for each radionuclide and summing, we 

derive the probability that a radionuclide will be released at levels 

exceeding its federally permitted level by one pound or more. Multiplying 

this sum by the number of annual radionuclide releases (250) from facilities 

that have federal permits, we estimate the baseline number of reportable 

releases to be 19 releases annually. 

Once again, we must emphasize that this figure is an estimate. It is 

based on a number of key assumptions that are, to some extent, 

over-simplifications, and should not be expected to be correct in every 

aspect. Chapter 7 of this report demonstrates the sensitivity of our results 

to this estimate of reportable radionuclide releases. 

Baseline costs and benefits are the estimated value of actions taken by 

both the regulated community and the government when baseline reportable 

releases occur. The value of these actions are discussed in Chapter 4 of this 

report. 
CHAPTER 4 

VALUATION OF THE EFFECTS OF THE 

PROPOSED RQ ADJUSTMENTS 

The purpose of an Economic Impact Analysis is to estimate the incremental 

costs and benefits resulting from a regulatory action. Any regulation 

requiring behavioral changes will usually lead to some elements of society 

benefiting from the regulation and some elements of society incurring costs. 

This report analyzes those benefits and costs and estimates the net gain or 

net loss resulting from the proposed regulation. Section 4.1 describes 

actions that could be taken by both the regulated community and government as 

a result of a reportable release and describes the actions that are 

attributable to the proposed RQ adjustments for radionuclides; Section 4.2 

discusses the valuation of the costs; and Section 4.3 discusses the valuation 

of the benefits. 

4.1 ACTIONS TAKEN WITH A REPORTABLE RELEASE 

For all radionuclides whose RQ adjustment is downward, the proposed 

regulation is expected to result in an increased number of releases reported 

to the National Response Center. This increased reporting requirement will 

impose costs on the regulated community and on the government. It could also 

result in benefits for society if reporting radionuclide releases result in 

faster and more efficient cleanups of the releases. 

For the 30 radionuclides whose RQ adjustment is upward, the proposed 

regulation is expected to result in cost savings (benefits) for both the 

regulated community and the government, as fewer releases will be reportable 

to the National Response Center. It could, however, result in fewer cleanups 

which may impose a cost on society due to a lower level of protection of 

public health and the environment. These costs and benefits are the result of 

actions taken by the regulated community and the government when a release 

occurs and is.reported by a facility to the National Response Center. The 

remainder of this section describes the likely actions by both the regulated 

community and the government as a result of a reportable release and describes 

the actions that are attributable to the proposed RQ adjustments. 

4.1.1 Actions Undertaken By the Regulated Community 

When a radionuclide release occurs, three categories of actions are 

undertaken by regulated parties. These actions can be classified as 

notification, recordkeeping, and response. The notification action is 

required by CERCLA in response to a reportable release. Recordkeeping and 

response actions, however, occur indirectly and are not required by the 

statute. 

Notification includes the notification of the National Response Center by 

the responsible party if a reportable release occurs, as is required by 

Section 103(a) of CERCLA. This action includes activities beyond the time 
P.39 

4-2 

spent by facility managers in a telephone conversation with the National 

Response Center. There is often subsequent interaction with the government by 

various levels of firm personnel as the government evaluates and determines 

the appropriateness of a response action. 

Recordkeeping is often associated with notification. Although CERCLA 

does not require that records of releases be kept, regulated parties often 

maintain logs of calls to the National Response Center. These logs might 

include a description of the incident, its cause, a brief account of 

conversations with government officials, and a description of the outcome of 

the incident, as well as cleanup actions taken. 

Response includes actions taken by the responsible party to mitigate the 

effects of the release. Typical response actions might include sampling the 

air, water, or soil; evaluating the necessity for evacuation and relocation; 

directly containing the release; and removing and/or neutralizing the release. 

4.1.2 Actions Undertaken by the Government 

Actions undertaken by the government in response to a release can be 

divided into four categories. They include notification processing, off-scene 

monitoring, on-scene monitoring, and direct removal. Each category is 

directly caused by the notification of a release. 

Notification processing includes the initial communicat.ion with the 

person who calls in the report to the National Response Center. It also 

includes evaluation of the information, determination of an appropriate 

government response, and subsequent recordkeeping. 

Off-scene monitoring includes supervision and monitoring of the 

responsible party's actions through telephone and data monitoring. 

On-scene monitoring includes a government official providing advice and 

assistance in person to the cleanup team, coordinating communications among 

agencies, providing information to the public, and ensuring that the Agency's 

concerns are represented in determining the appropriate response. 

Direct removal is necessary when the responsible party cannot or will not 

adequately clean up the radionuclide release and the release represents a 

hazard to public health or welfare or to the environment. Although the 

government response agency will normally use a private contractor to clean up 

the release, government response teams nevertheless have sampling, monitoring, 

containment, and safety equipment to deal with the initial emergency and to 

assist the contractors in the cleanup. Direct removals also could require 

more than one government agency.

x 

*For example, EPA, the Coast Guard, the Nuclear Regulatory Commission, 

the Department of Energy, the Federal Emergency Management Agency, state 

response agencies, state and local police and highway resources, or local fire 

departments could become involved in a release event. 
P.40 

4-3 

4.1.3 Incremental Actions Attributable to the Radionuclide 

RQ Adjustments 

Section 103(a) of CERCLA requires any release of an RQ or more of a 

hazardous substance to be reported immediately to the National Response 

Center. The proposed regulation is adjusting the RQ for radionuclides, 

resulting in a change in the number of reportable releases. For those 

radionuclides whose RQ decreases, the proposed regulation will result in an 

increase in the number of reportable releases to the National Response 

Center. For those radionuclides whose RQ increases, the proposed regulation 

will result in a decrease in the number of reportable releases to the National 

Response Center. This will affect notification costs, recordkeeping, and 

response costs incurred by the affected facilities and it will affect 

notification processing costs, off-scene and on-scene monitoring costs, .and 

removal costs incurred by the government. 

The production, use, and transportation of radionuclides are already 

regulated and controlled. For the most part, facilities already face some 

reporting requirements for releases of radionuclides. All transportation 

releases, regardless of quantity, must already be reported to the National 

Response Center (49 CFR Parts 171-177). Therefore, the proposed regulation 

adjusting the radionuclide RQ from one pound to some new level will have no 

effect on transporters of radionuclides. 

The proposed regulation could increase notification, recordkeeping, and 

response activities for facilities handling and releasing radionuclides with a 

proposed RQ less than one pound. Similarly, it could decrease notification, 

recordkeeping, and response activities for facilities handling and releasing 

radionuclides with a proposed RQ exceeding one pound. The additional cost (or 

cost savings) any facility will incur is related to the number of reportable 

releases from that facility, which is a function of the handling practices at 

the facility, the quantity and type of radionuclides handled at the facility, 

and the forms of the radionuclides (e.g., sealed sources, solids, liquids, or 

gases). It is difficult to predict which facilities will be most affected by 

the proposed RQ adjustments, but it is reasonable to expect a change in the 

number of releases of radionuclides reported to the National Response Center 

as a result of the proposed regulation. The change in the number of 

reportable releases will directly affect the costs and benefits that accrue to 

both the regulated community and government. 

In addition to the direct economic costs and cost savings resulting from 

the change in the number of releases reported to the National Response Center, 

the proposed RQ adjustments can affect public health and welfare and 

environmental quality. If the likelihood of a cleanup response is greater 

when notification to the National Response Center is required, then RQ 

adjustments could have the following effects: 

• Raising RQs for particular radionuclides will 

decrease the number of reportable releases. Assuming 

that some releasers are less likely to clean up releases 

of radionuclides below the RQ, more public health and 
P.41 

4-4 

welfare and environmental damages could occur with 

higher RQs. These incremental damages are costs of 

raising the RQs for some radionuclides. 

• Lowering RQs for a particular radionuclide will 

increase the number of reportable releases for that 

substance. If these lower RQs lead to increased and 

earlier notifications of releases and to appropriate and 

timely response actions that would not otherwise have 

occurred, public health and welfare and environmental 

damages could be mitigated. These decreased or avoided 

damages can be considered to be a benefit of lowering 

the RQs for some radionuclides. 

Identifying, predicting, and measuring the public health and welfare and 

environmental effects of raising or lowering RQs is inherently difficult. An 

analysis of these effects is not included in this report because of serious 

information constraints. Although this report estimates the change in the 

number of reportable releases under the proposed regulation, reliable 

information is unavailable on the damages that have been associated with past 

radionuclide releases. There is no information regarding the role (if any) 

that RQ levels or reporting requirements played in contributing to these 

effects. Therefore, little information exists upon which to base a 

quantitative analysis of public health and welfare and environmental effects, 

and we discuss these changes in qualitative terms only. 

4.2 VALUATION OF COSTS 

This section describes the method of attaching values to the actions 

caused by changes in the RQs. The values associated with one reportable 

release are the resources that are consumed during the notification, 

recordkeeping, and response activities by both the regulated community and the 

government and also include the changes in public health and welfare and 

environmental quality that may be produced by a response. In general, 

estimates throughout this study of the resources consumed as a result of 

performing each action are quantitative, and the estimates of changes in 

public health and welfare and environmental quality are qualitative. The 

remainder of this section provides estimates of the value of the actions 

performed by regulated parties and the government. These estimates are 

examined more closely in Chapter 7 of this report, where we test the 

sensitivity of our results to each of the frequency estimates discussed below. 

4.2.1 Values of Actions Performed by Regulated Parties 

We base most of our cost estimates for each action on the estimates 

derived in the Regulatory Impact Analysis (RIA) supporting the RQ adjustment 

for 340 CERCLA hazardous substances.2 

2ICF Incorporated, Regulatory Impact Analysis of Reportable Quantity 

Adjustments Under Sections 102 and 103 of the Comprehensive Environmental 

Response, Compensation, and Liability Act, Volume I, March 1985. 
4-5 

Notification. Section 103(a) of CERCLA places the responsibility for 

notification of the National Response Center on the person in charge of the 

vessel or facility from which a hazardous substance is released. It is 

reasonable to assume, therefore, that a plant manager or representative will 

become involved in the notification process soon after a release is reported. 

In addition to the plant manager, the time expended and the type of other 

people who become involved in notification activities depend on the following 

four factors: the amount, identity, and form (solid, liquid, or gas) of 

radionuclide released; the location where it is released; the responses of 

government officials and the releaser of the radionuclide; and the size and 

organizational structure of the responsible party. 

The RIA in support of the RQ adjustment for 340 CERCLA hazardous 

substances assumed notification costs for releases of less than 55 gallons are 

$121, and notification costs for releases over 55 gallons are $323.3 It 

would not be appropriate to differentiate notification costs for radionuclide 

releases on the basis of whether the releases are above or below 55 gallons. 

As discussed earlier, a radionuclide release well below one pound could 

generate a great deal of concern and public interest, resulting in relatively 

high notification costs. Radionuclide releases in general engender public 

concern and scrutiny because of the lack of understanding and general fear 

felt by the public at large regarding radiation and radioactive contamination. 

The responsible party may have to respond to more calls from state and local 

government officials and from the press, for example, than would be the case 

for a chemical release. It seems more appropriate, therefore, to assume 

notification costs to industry for a radionuclide release are closer to $323, 

which includes three hours of managerial time and two hours of technical time, 

than it is to $121 which includes one hour of managerial time and one hour of 

technical time. We will assume, therefore, that each release notification 

costs the regulated community $323 (1983 dollars). 

Recordkeeping. The resources required to perform internal recordkeeping 

responsibilities were estimated in the RIA supporting the RQ adjustment for 

340 CERCLA hazardous substances to be 1 clerical hour per release, and assumes 

a ratio of 1 supervisory hour to each 10 hours of clerical time.* This 

estimate implies a cost of $28.10 per release, assuming $20 per hour for 

clerical time and $81 per hour for managerial time. Recordkeeping associated 

with a chemical release notification and recordkeeping associated with a 

radionuclide release notification should not differ substantially. We adopt 

this same unit cost estimate in this analysis of the proposed RQ adjustments 

for radionuclides. 

3Ibid, p. 3-11. The larger releases are assumed to take 3 hours of 

managerial time at $81 an hour and 2 hours of technical time at $40 an hour. 

The smaller releases, which are usually less serious, are assumed to take 1 

hour of managerial time and 1 hour of technical time. All estimates are 

expressed in 1983 dollars. 

"Ibid, p. 3-11. 
4-6 

Response. No public health and welfare or environmental costs or 

benefits are associated with notification and recordkeeping, per se. The 

public health and welfare and environmental effects of the proposed regulation 

are caused solely by the cleanup of releases that would not otherwise have 

been cleaned up, or which would have been cleaned up improperly, without the 

advice given to the releaser by the government because of the notification. 

Although accurate data are generally unavailable, Nuclear Regulatory Commission, Department of Energy, and Environmental Protection Agency sources 

agree generally that responsible parties currently respond adequately to a 

very large percentage of releases. Responsible parties are liable for 

response costs and natural resource damages for all releases of radionuclides, 

whether these releases are above or below the RQs. It is logical to assume, 

however, that a responsible party is more likely to respond to a release that 

is above the RQ than it is to a release that is below the RQ simply because 

the release is larger and the National Response Center must be notified of the 

release. For purposes of this analysis, therefore, we assume that responsible 

parties adequately respond to 90 percent of radionuclide releases below the RQ 

and adequately respond to 95 percent of radionuclide releases above the RQ. 

Hence, if the RQ is lowered, we might expect a 5 percent increase in response 

activities for those releases that are now reportable. For those 

radionuclides whose proposed RQ is greater than one pound, we would expect a 5 

percent decrease in response activities for releases that are greater than one 

pound but are no longer reportable under the proposed regulation. 

The Regulatory Impact Analysis (RIA) for RQ adjustments of 340 CERCLA 

hazardous substances estimated the range of response costs incurred by 

regulated parties to be between $185 and $2,093 per release (1983 

dollars).5 The costs are a function of the size of the release. 

Radionuclide releases are, in general, much smaller than the chemical releases 

considered in the RIA, which range from one pound to 5000 pounds. 

Radionuclide release responses, however, often require special equipment and 

protective clothing, resulting in higher response costs. To estimate 

radionuclide response costs, therefore, we did not rely on the RIA estimates. 

Instead, we'developed three model release scenarios. We based our model 

scenarios on release reports in the data sets and tried to select scenarios 

which reasonably represented a fair number of the events in the radionuclide 

data base. The three scenarios represent a range of response actions and 

response costs. 

Scenario 1 represents a small radionuclide release resulting from a faulty 

valve, for example, at a conversion facility or laboratory. The radionuclide 

released could conceivably be uranium-238, tritium, or krypton-85. The 

appropriate response for scenario 1 would probably be no more than monitoring 

for an 8-hour period. Costs for scenario 1 are used for all releases whose 

response costs would be expected to be minimal. 

'Ibid, p. 3-13. 
P.44 

4-7 

Scenario 2 represents a laboratory or hospital situation where a 

radionuclide is accidently disposed of with the regular garbage. The 

radioactive material is then shredded and put in a dumpster. Radionuclide 

releases likely to be represented by this model include cobalt-60, iodine-125, 

iodine-131, and iridium-192. Scenario 2 costs include monitoring and 

decontamination. 

Scenario 3 involves a hypothetical release of uranium-238 to surface 

water. The release may have resulted from a pipe failure or lagoon overflow 

and involves major response actions including monitoring and dredging of 

contaminated sediment. 

For each scenario, we have estimated the costs of hypothetical responses, 

shown in Exhibit 4-1. All costs are in 1986 dollars. Based on the frequency 

of occurrence of different types of releases in our data base, we assume 

scenario 1 costs are representative costs for 66 percent of response actions; 

scenario 2 costs are representative costs for 27 percent of response actions; 

and scenario 3 costs are representative costs for 7 percent of response 

actions. Using these percents as weights for each of the cost estimates, we 

derive an average weighted response cost for radionuclide releases of about 

$5,400 per response ((.66 x $160) + (.27 x $5,720) + (.07 x $53,600)). These 

estimates were deliberately based on small release scenarios, because large 

decontamination actions would occur regardless of the RQs involved and are 

therefore expected to be unaffected by the proposed RQ adjustments. We 

realize that this estimation process is very imprecise, however, and in 

Chapter 7 of this report, we test the sensitivity of our results to the 

response cost estimates. 

4.2.2 Value of Actions Performed by the Government 

Most of the.actions performed by the government involve costs which do not 

vary with the type of CERCLA hazardous substance released. Notification 

processing, off-scene monitoring, and on-scene monitoring costs for 

radionuclide releases are assumed to be similar to costs incurred for other 

CERCLA hazardous substance releases. The RIA in support of the RQ adjustment 

for 340 CERCLA hazardous substances assumed the government actions were valued 

at $70 for process notifications, $235 for off-scene monitoring, and $2,761 

for on-scene monitoring.6 We adopt these estimates in this analysis of the 

effects of the proposed RQ adjustments for radionuclides. 

The RIA also assumes that the likelihood of off-scene monitoring and 

on-scene monitoring by the government varies with the size of the reported 

release. For off-scene monitoring, the RIA assumes government response is 

likely between forty percent and seventy percent of the time. For on-scene 

monitoring, the RIA assumes government response is likely between five and 

twenty percent of the time. Because we believe a government response action 

is probably more likely for a radionuclide release than for the average 

chemical release simply because of public awareness and concern over radiation 

'Ibid, p. 3-17, 
P.45 

4-8 

EXHIBIT 4-1 

RELEASE SCENARIO 1 

CIRCUMSTANCE: A small radionuclide release from a failed valve at a 

conversion facility or laboratory 

-2 

TYPICAL RADIONUCLIDES: 10 curies of Uranium-238, Tritium, or Krypton-85 

RESPONSE ACTIVITIES AND COST ESTIMATES: 

A response may not be necessary nor appropriate for air releases of this 

size. However, we assume the response requires 8 hours of monitoring. 

Total estimated cost = $160 

RELEASE SCENARIO 2 

CIRCUMSTANCE: Radionuclide source accidently disposed of as standard solid 

waste, shredded, and put in dumpster. 

TYPICAL RADIONUCLIDES: 10~2 curies of Cobalt-60, Iodine-125, Iodine-131, 

or Iridium-192 

RESPONSE ACTIVITIES AND COST ESTIMATES: 

Monitoring and decontamination of bench, trash can, and janitor cart -- $320 

Monitoring and decontamination of shredder and dumpster -- $5,400 

Total estimated cost = $5,720 
P.46 

4-9 

EXHIBIT 4-1 (continued) 

RELEASE SCENARIO 3 

CIRCUMSTANCE: Radionuclide release from process discharge pipe to stream 

which feeds into a river. 

TYPICAL RADIONUCLIDES: 20 curies of Uranium-238 

RESPONSE ACTIVITIES AND COST ESTIMATES: 

Monitoring (1 wk.) at outfall, ditch, stream, and river -- $1,600 

Ground water monitoring well (drilling and sampling) -- $1,000 

Treatment of 5,000 gallons of contaminated water ($0.20/gal, including 

mobilization for ion-exchange resin) -- $1,000 

Dredging and disposal of contaminated sediments (1000 cu ft) -- $50,000 

Total estimated cost = $53,600 

Source: ICF analysis based on the following sources: U.S. Environmental 

Protection Agency, Remedial Response at Hazardous Waste Sites (EPA 

540/2-84-002), March 1984; Tawil, J.J. et al., Off-Site Consequences 

of Radiological Accidents: Methods, Costs, and Schedules for 

Decontamination, Battelle Northwest Laboratories, Prepared for U.S. 

Nuclear Regulatory Commission, August 1985; ICF 1986. 
P.47 

4-10 

contamination, we assume, for purposes of this analysis, that the likelihood 

of an off-scene monitoring response by the government is seventy percent and 

the likelihood of an on-scene monitoring response by the government is twenty 

percent, the high end of the assumed ranges for chemical releases. We test 

the sensitivity of our results to these assumptions in Chapter 7 of this 

report. 

Direct removal cost estimates in the RIA for 340 CERCLA hazardous 

substances were assumed to be $39,273.7 We modify this cost estimate in 

this analysis because direct response actions for radionuclide releases tend 

to be very different from direct response actions for other chemical releases; 

for example, decontamination procedures often involve special equipment and 

protective clothing. 

For purposes of this analysis, therefore, we rely on the model cost 

scenarios discussed earlier in the chapter and described in Exhibit 4-1. We 

assume the government would get involved in only the most costly scenario and 

so assume scenario 3 costs ($53,600) are appropriate for government removal 

actions. We further assume that five percent of all radionuclide releases 

will involve government response activities.8 

The unit cost estimates are not precise, relying on estimates that may not 

be totally applicable for radionuclide release actions. We have made very 

conservative assumptions regarding likelihood of a response action and have 

tried to cost each action conservatively so as to err on the side of higher 

cost estimates. We discuss, in Chapter 7 of this report, the sensitivity of 

our results to these assumptions. 

4.3 VALUATION OF BENEFITS 

The economic benefits of adjustments are the decreased industry and 

government costs that result from raising RQs for some radionuclides. 

Assuming that industry generally reports and responds to a release at or 

exceeding the RQ, raising the RQ should decrease industry's and government's 

notification, recordkeeping, processing, monitoring, and response costs. The 

unit cost savings are the same as the unit cost estimates discussed in Section 

4.2 above. 

The public health and welfare and environmental benefits of RQ adjustments 

are the avoided or decreased damage costs that result from lowering RQs for 

most radionuclides. Assuming that a releaser generally reports (or is more 

7Ibid, p. 3-17. 

8The RIA for the 340 CERCLA hazardous substances assumed the likelihood 

of a direct government response action was between one and five percent. We 

assume the high end of the range is more appropriate for radionuclide 

releases. We test this assumption in Chapter 7 of this report. 
P.48 

4-11 

likely to report) a release at or exceeding the RQ, lowering the RQ should 

both increase the number of notifications and provide incentives for earlier 

responses to releases. 

The public health and welfare and environmental effects of adjusting RQs 

for some substances are difficult to identify, predict, and measure for 

several reasons: 

• The only certain effect of lowering RQs is that it 

increases the number of reportable releases. The costs 

and benefits of RQ adjustments are several steps removed 

from changes in the number of reportable releases and 

depend upon uncertain regulated party and government 

behavior. 

• Even if it could be established that lowering RQs 

generally decreases public health and welfare and 

environmental damages, it is difficult to specify the 

nature, magnitude, and value of those changes. Almost 

no data exist on the damages associated with past 

releases of small quantities of radionuclides. There is 

even less information on the role (if any) that 

reporting levels or notifications play in augmenting 

these damages. Therefore, there is hardly any 

information upon which to base prediction of effects. 

If lowering RQs for most radionuclides leads to more or earlier 

notifications and more effective response actions, then the following benefits 

could occur: 

• Reductions in the threat of mortality and acute or 

chronic morbidity. These include reductions in human 

exposure (ingestion, inhalation, or physical contact) to 

radiation contamination. 

• Reductions in the threat of general environmental 

damages such as plant and animal damages. These 

include reductions in the adverse impact of released 

radionuclides on crop yields, non-crop vegetation, fish, 

wildlife, and farm and commercial animal production. 

• Reductions in the threat of public damages. These 

include mitigation of property damages, recreational 

damages, and lost productivity. 

Without data on release damages and the possible relationship of 

notification to damages, it is not possible to quantify the public health and 

welfare and environmental costs and benefits under the proposed regulation. 

However, if greater non-economic benefits result from more reporting, then the 

public health and welfare and the environmental benefits provided by the 

proposed regulation will probably be positive because 96 percent of all 
P.49 

4-12 

specific radionuclide RQ adjustments are downward, resulting in a net increase 

in expected reports to the National Response Center. 

The unit costs and cost savings estimates can now be combined with the 

estimated number of baseline reportable releases to determining the baseline 

and incremental costs and benefits attributable to the proposed regulation. 

Chapter 5 presents the cost estimates and Chapter 6 presents the benefits 

estimates. 
P.50 

CHAPTER 5 

ESTIMATED ANNUAL COSTS OF THE PROPOSED 

RQ ADJUSTMENTS 

This chapter discusses the costs of reportable quantity (RQ) adjustments, 

including the potential increased economic burden on society that may be 

caused by lowering most of the radionuclide RQs, and the potential reduction 

in public health and welfare and the environmental quality that may be caused 

by raising some radionuclide RQs. The analysis in this chapter combines the 

information presented in Chapters 3 and 4 to compute the annual cost of RQ 

adjustments. 

The costs of RQ adjustments are a result of the change in the number of 

releases reportable to the National Response Center. Reporting a release 

causes both the regulated community and the government to incur costs for 

notification, recordkeeping, and possible response activities; not reporting a 

release could affect human health and welfare and environmental quality. 

Section 5.1 presents the estimates of the change in reportable releases under 

the proposed regulation; Section 5.2 presents the estimate of the incremental 

costs of the proposed RQ adjustments; and Section 5.3 presents firm-level 

economic effects of the proposed regulation. 

5.1 THE ESTIMATED CHANGE IN THE NUMBER OF REPORTABLE RELEASES 

The estimated change in the number of reportable releases is equal to the 

difference between baseline reportable releases (19) (derived in Chapter 3) 

and reportable releases under the proposed regulation. In the baseline, a 

radionuclide release at a licensed or regulated facility is reportable to the 

National Response Center if it equals or exceeds permitted levels by one 

pound. Under the proposed regulation, a radionuclide release is reportable to 

the National Response Center if it equals or exceeds permitted levels by the 

proposed RQ. 

Most licensed or regulated facilities must comply with the Nuclear 

Regultory Commission 10 CFR Part 20 release limitations. Because the ALIs in 

10 CFR Part 20 are the basis for the derivation of the proposed RQ 

adjustments, for purposes of this analysis, federally permitted levels are 

assumed to equal the proposed RQs.1 Thus, a reportable radionuclide release 

under the proposed regulation from a facility holding a federal permit is 

assumed, for purposes of this analysis, to be all radionuclide releases that 

1This is a simplification because the 10 CFR Part 20 intake limitations 

are based on a dose of 5 rem for nuclear facility workers. EPA based its 

proposed RQs on a dose-equivalent of 500 millirem and then made several 

conservative assumptions to calculate the release levels for the proposed 

RQs. We examine in Chapter 7 of this report the sensitivity of our results to 

the number of reportable releases. 
P.51 

5-2 

equal or exceed twice the proposed RQ. Because the proposed RQs are being 

used as a proxy for the federally permitted release levels and releases 

exceeding these levels by an RQ or more must be reported to the National 

Response Center, all releases from facilities holding federal permits that 

equal or exceed twice the proposed RQ must be reported to the National 

Response Center. 

To estimate the expected number of releases above two times the proposed 

RQ, we rely on the size distribution of releases in our data base and each 

radionuclide's frequency of release shown in Exhibit 3-2 of this report. The 

probability that a particular radionuclide release will equal or exceed two 

times the proposed RQ is estimated to be the frequency of release of that 

radionuclide in our data base, multiplied by the fraction of releases in our 

data base that equal or exceed two times the proposed RQ. This calculation is 

performed for each of the radionuclides identified in our data base. We then 

sum across the radionuclides. Hence, reportable radionuclide releases under 

the proposed regulation is estimated to be the number of annual releases 

(250), multiplied by the probability that a radionuclide will be released in 

quantities equal to or exceeding two times the proposed RQ. Reportable 

releases are estimated to be approximately 62 releases annually. Thus, the RQ 

adjustments result in 43 (62-19) incremental reportable releases. 

Although 30 radionuclides have upward adjustments of their RQs, there is 

no change in the number of reportable releases for these radionuclides in our 

data base. In both the baseline and with the proposed RQs, we estimate there 

will be approximately 18 reportable releases annually of these radionuclides. 

We estimate there will be no change in the number of releases that must be 

reported to the National Response Center. That is, based on the release 

information in our data base, 18 releases would be required to be reported in 

the baseline and 18 releases will be required to be reported under the 

proposed regulation. Therefore, there is no expected increase in the threat 

to public health or welfare or the environment. The remainder of this chapter 

will estimate the incremental costs associated with the downward adjustment of 

727 radionuclide RQs. 

5.2 ESTIMATED COSTS OF THE PROPOSED RQ ADJUSTMENTS 

Because we estimate that the 30 radionuclides whose proposed RQ exceeds 

one pound have no expected change in the number of reportable releases, all of 

the costs under the proposed regulation are due to the reduction in the 

proposed radionuclide RQs and economic costs associated with increases in 

reportable releases to the National Response Center. The cost calculation is 

shown in Exhibit 5-1. Many of the unit costs described in Chapter 3 were 

derived from estimates in the RIA supporting the RQ adjustments for 340 CERCLA 

hazardous substances. Those cost estimates were in 1983 dollars. For 

purposes of this analysis, we have converted all cost estimates to 1986 

dollars. 
5-3 

EXHIBIT 5-1 

CALCULATIONS OF ANNUAL COSTS OF RQ ADJUSTMENTS 

UNDER THE PROPOSED REGULATION 

COSTS TO BE REGULATED PARTIES 

A. Cost of Notification 

(43 incremental reports) x $336 = $ 14,448 

B. Cost of Recordkeeping 

(43 incremental records) x $29.24 = $ 1,257 

C. Cost of Response 

(43 incremental releases) x (.05) x ($5,400) = $ 11,610 

TOTAL COST TO REGULATED PARTIES $ 27,315 

COSTS TO GOVERNMENT 

D. Cost of Notification Processing 

(43 incremental reports) x $73 = $ 3,139 

E. Cost of Off-Scene Monitoring 

(43 incremental releases) x (.70) x ($245) = $ 7,375 

F. Cost of On-Scene Monitoring 

(43 incremental releases) x (.20) x (2,873) = $ 24,708 

G. Cost of Direct Removal 

(43 incremental releases) x (.05) x ($53,600) = $ 115,240 

TOTAL COST TO GOVERNMENT $ 150,462 

TOTAL COST OF PROPOSED REGULATION (1986 dollars)* $ 177,777 

*The RIA cost estimates supporting the RQ adjustment for 340 CERCLA 

hazardous substances are in 1983 dollars. The 1983 dollars were converted to 

1986 dollars using the Construction Cost Index. March 1986 dollars equal 4219 

and 1983 dollars equal 4055; Engineering News Record, March 1986, p. 107. 

Source: ICF estimates. 
P.53 

5-4 

The total cost to regulated parties is the sum of notification, 

recordkeeping, and response costs. The costs of the proposed 

regulation are calculated in the following manner: 

A. Notification. There are 43 incremental reportable 

radionuclide releases and each report costs an estimated 

$336, yielding a total annual cost of about $14,500. 

B. Recordkeeping. Multiplying 43 incremental reportable 

releases by $29.24, the cost of recordkeeping per 

reportable release, yields total annual recordkeeping 

costs of about $1,260. 

C. Response. It is assumed in this analysis that the 

probability of response to a given release is 90 percent 

if the release is below the RQ and 95 percent if the 

release is above the RQ. Therefore, an extra 5 percent 

of incremental reportable releases will be responded to 

as a result of lowering RQs. Multiplying the number of 

incremental reportable releases (43) by the incremental 

probability of response (0.05) and by the weighted 

average cost per response ($5,400), equals total annual 

response costs of about $11,600.2 

The total cost to regulated parties, which is the sum of notification costs, 

recordkeeping costs, and response costs, is about $27,300. 

The total cost to the government of RQ adjustments is the sum of 

notification processing, off-scene monitoring, on-scene monitoring, and direct 

removal costs. These costs are calculated in the following manner: 

• Notification Processing. A total annual notification 

processing cost of approximately $3,140 is calculated by 

multiplying 43 incremental reportable releases by $73 

(the estimated cost of processing one notification). 

• Off-Scene Monitoring. Multiplying 43 incremental 

reportable releases by the probability that off-scene 

monitoring is required3 (.70), by the cost of 

off-scene monitoring per release ($245), yields a total 

annual off-scene monitoring cost of about $7,400. 

2The sensitivity analysis in Chapter 7 tests the results of assuming 

different probabilities of response to releases below and above the RQ. 

3The sensitivity analysis in Chapter 7 tests the results of assuming 

different probabilities of off-scene monitoring. 
P.54 

5-5 

• On-Scene Monitoring. Multiplying 43 incremental 

reportable releases by the probability that on-scene 

monitoring is required* (.20), by the cost of on-scene 

monitoring per release ($2,873) yields a total annual 

on-scene monitoring cost of about $24,700. 

• Direct Removal. Multiplying 43 incremental 

reportable releases by the probability of direct 

response by the government (.05) and the estimated cost 

of direct removal ($53,600) yields a total annual cost 

for direct responses of about $115,000.s 

The total cost to the government, which is the sum of notification processing 

costs, off-scene monitoring costs, on-scene monitoring costs, and direct 

response costs is approximately $150,500. 

The sum of the total costs to the government and to regulated parties 

equals the total costs of all effects, which is approximately $178,000. 

5.3 FIRM-LEVEL ECONOMIC EFFECTS 

The estimated costs of the proposed regulation are small relative to the 

sales and revenues generated by the industries most likely to be affected by 

the proposed regulation. The average facility handling radionuclides is not 

expected to experience a radionuclide release above the proposed RQ. We 

estimate that there will be about 43 incremental reportable releases annually, 

and there are as many as 22,000 facilities potentially affected by the 

proposed regulation. The probability that any particular facility will 

experience a reportable release is a function of the types, quantities, and 

forms of radionuclides used and produced at the facility, and the facility's 

handling procedures. 

The types of facilities affected by the proposed regulation vary widely, 

from laboratories to large uranium mining operations. It is not possible to 

predict with any degree of accuracy the facilities most likely to experience 

reportable radionuclide releases and, therefore, it is not possible to develop 

a financial model of a typical releaser. We can discuss in general terms, 

however, the magnitude of costs for a facility experiencing a reportable 

release under the proposed regulation. These cost estimates are as follows: 

• Notification costs $336 

• Recordkeeping costs $30 

• Cleanup costs $5,400 

*The sensitivity analysis in Chapter 7 tests the results of assuming 

different probabilities of on-scene monitoring. 

5The sensitivity analysis in Chapter 7 tests the results of assuming 

different probabilities of direct response. 
P.55 

5-6 

The total cost to a facility or vessel experiencing a reportable 

radionuclide release is, therefore, estimated to be about $5,800. The cost to 

the facility will depend directly upon the cleanup costs, estimated to range 

between zero and $54,000, with a weighted average cleanup cost of about $5,400. 

The total annual burden under the proposed RQ adjustments experienced by 

all affected entities depends on the size and number of reportable releases. 

The burden imposed by the CERCLA notification requirements on an individual 

business depends directly on the number of reportable releases that occur at 

that facility. Most of the facilities potentially affected would, in fact, 

experience no costs from the notification requirements because they would have 

no reportable releases. Even assuming a reportable release occurs at a 

facility, the likely costs incurred are so small that we must conclude that 

the proposed regulation will not adversely affect any facility, large or small. 

The largest costs under the 

Most releases are cleaned up re 

below the RQ. Cleanup of large 

proposed RQ adjustments because 

proposed regulation and cleanup 

put the magnitude of the costs 

prospective, it is important to 

adjustments as well. These are 

proposed regulation is due to cleanup costs. 

gardless of whether the release is above or 

releases will probably not be affected by the 

they would be reportable even without the 

would probably occur regardless of the RQ. To 

attributable to the proposed regulation into 

consider the benefits of the proposed RQ 

discussed in Chapter 6 of this report.. 
P.56 

I 

I 

I 

I 

I 

I 

I 

1 

I 

t 

I 

I 

I 

I 

1 

I 

I 

I 

I 

CHAPTER 6 

ESTIMATED BENEFITS OF THE PROPOSED RQ ADJUSTMENTS 

This chapter analyzes the benefits of adjusting the reportable quantities 

(RQs) for radionuclides. The benefits fall into two categories: 

(1) Cost savings to affected parties. Raising RQs for some 

radionuclides could decrease the number of reportable 

releases. This decrease in turn reduces the costs to 

regulated parties and government for notification, 

recordkeeping, response, and monitoring. 

(2) Public health and welfare and environmental benefits. 

Lowering RQs for some radionuclides increases the number 

of reportable releases. This increase in turn decreases 

the probability of public health or welfare or 

environmental damage if earlier or more notifications of 

releases*are followed by prompt, appropriate response 

actions by the responsible party (or in some cases, by 

the various local, state, or federal agencies involved). 

Benefits of the proposed regulation flow from government and regulated party 

responses to changes in the number of reportable releases. If we assume that 

industry normally reports and responds to a radionuclide release equal to or 

exceeding its RQ, then raising the RQ level should decrease the notification, 

recordkeeping, processing, monitoring, and response costs of the regulated 

community and government. 

Of the 757 radionuclides whose RQs are individually adjusted in the 

proposed regulation, only 30 radionuclides have a proposed RQ greater than one 

pound. Exhibit 6-1 displays these 30 radionuclides and their proposed RQs. 

Six of these 30 radionuclides are represented in our data base. These six 

radionuclides with proposed RQs that are greater than the curie equivalent of 

one pound were reported released 198 times in the recent past in the data sets 

we examined. However, because we estimate there will be no change in the 

number of reportable releases of these 30 radionuclides as a result of the 

proposed RQ adjustments, there are no cost savings attributable to the 

proposed regulation. 

The public health and welfare and environmental benefits of RQ adjustments 

are, therefore, the avoided or decreased damage costs that result from the 

lower RQs for 727 radionuclides. Assuming that a responsible party is more 

likely to respond to a release at or exceeding the RQ, lowering reporting 

levels for a substance should increase the number of notifications and provide 

incentives for earlier responses to releases. These notifications may lead to 

more prompt, effective cleanup or containment of releases, thus avoiding or 

mitigating damages that would otherwise occur. 
P.57 

I 

I 

I 

I 

6-2 

EXHIBIT 6-1 

RADIONUCLIDES WITH PROPOSED RQs 

GREATER THAN ONE POUND 

Radionuclide 

Aluminum-26 

Cadmium-113 

Calcium-41 

Cesium-135 

Chlorine-36 

Gadolinium-152 

Hafnium-182 

Indium-115 

*Krypton-81 

Lanthanum-138 

Lead-205 

Lutetium-176 

Manganese-53 

*Nickel-59 

Palladium-107 

Plutonium-244 

Potassium-40 

Rhenium-187 

Rubidium-87 

Samarium-147 

Selenium-79 

Tantalum-180 

Technet ium9 7 

Technetium-98 

*Technetium-99 

Tellurium-123 

*Thorium-232 

*Uranium-235 

Uranium-236 

*Uranium-238 

Propos 

Curies 10 

1 

1000 

100 

100 

0.001 

0.1 

0.1 

1000 -• 

1 

100 

1 

1000 

1000 

100 

0.01 

100 

1000 

1000 

0.01 

100 10 

1000 10 

100 

100 

0.001 

0.1 

0.1 

0.1 

ed RQ 

905, 31 51 26 

111 

985 

Pounds 

1.2 

000,000 

25.3 

250 

6.7 

103,000 

1 

200,000 

104 

90,100 

1,910 

39,000 

1,200 

32.7 

428 

1..2 

30,800 

900,000 

200,000 

978 

2.9 

000,000 

1,550 

25.3 13 

000,000 20 

103 

3.4 

654 

^Radionuclides represented in our data base . 

Source: Memorandum from Alan Messing, Environ-

mental Monitoring and Services, Inc. t o 

Ellen Warhit, ICF, "Radionuclides with 

Proposed RQs in Greater Than or Equal t o 

one pound," October 1986. 
P.58 

6-3 

If lowering RQs for certain radionuclides leads to more or earlier 

notifications and more effective response actions, then the following benefits 

may occur: 

• Reductions in the threat of mortality and acute 

chronic morbidity; 

• Reductions in the threat of general environmental 

damages such as plant and animal damages; and 

• Reductions in the threat to public welfare damages 

(including property damage, recreational damage, and 

lost productivity). 

Unfortunately, we have no data on release damages nor on the possible 

relationship of the timing of notifications to the extent of damages. It is 

not possible, therefore, to quantify the benefits of the proposed regulation. 

The direction of all but 30 of the 757 individual proposed RQ adjustments is 

downward, however, resulting in an expected increase in the future number of 

radionuclide releases reported to the National Response Center. We anticipate 

that the earlier notification will result in faster and more appropriate 

response actions, yielding benefits to both the regulated community (in terms 

of lower response costs) and to society in general (in terms of reduced theats 

to human health and welfare and the environment). 

Our analysis of both costs and benefits under the proposed regulation is 

based on several key assumptions which, if inaccurate, could cause the 

estimates to misrepresent the effects of the proposed regulation. We, 

therefore, test the major assumptions to determine the sensitivity of our 

results to each assumption. The results of this analysis are presented in 

Chapter 7 of this report. 
P.59 

CHAPTER 7 

SENSITIVITY ANALYSIS 

Several times in this analysis, data have been used whose margin of error 

could have been improved through further research. Similarly, in several 

instances, key study assumptions were made which used the best available 

information from a very limited data base. Under these circumstances, 

therefore, it is important to conduct a sensitivity analysis to test the 

impact that changing key study assumptions would have upon the results of the 

analysis. The first two sections of this chapter present a sensitivity 

analysis on the results of this analysis. The first section discusses the 

importance of a sensitivity analysis and establishes the ranges for the key 

variables and assumptions that will be tested. The second section presents 

the results of the sensitivity analysis using these ranges. The third 

section, Section 7.3, describes our statistical analysis of our radionuclide 

release data base; and Section 7.4 summarizes our results. 

7.1 CONCEPTS AND KEY VARIABLES 

In general, a sensitivity analysis indicates how the results of an 

analysis might vary if some of the basic building blocks of the study had been 

different. If, for example, the analyst is reasonably certain that one of two 

particular values for a key variable is correct but does not know which one, 

or that two values will bracket the true value, each may be used in the 

sensitivity analysis. The result is then presented twice -- once for each 

value of the key variable. 

In other situations, there may be very little guidance on a particular key 

variable. A reasonable guess can be made about the likely value for the 

variable; other values may be selected to determine the sensitivity of the 

results to this choice. This technique has the virtue of indicating the range 

of possible results, although it does not indicate whether the "true" results 

are included. 

A sensitivity analysis is sometimes thought to add information, and it 

does in the sense of bracketing a range. Nonetheless, the range may be too 

small or too large, depending on the quality of the values used in the 

sensitivity analysis. Thus, the value of the analysis still depends on the 

quality of the input data. 

This sensitivity analysis tests the impact of changing six basic 

assumptions that have been used during this analysis. These assumptions 

include: (1) the number of incremental reportable releases; (2) the hours 

required and, therefore, the unit cost per release notification; (3) the 

frequency of on-scene monitoring; (4) the frequency of direct removal; (5) the 

frequency of off-scene monitoring; and (6) the frequency of cleanups by 

responsible parties. We test the frequency of actions rather than the unit 
P.60 

7-2 

costs of performing such actions because the cost estimates are considered 

reasonable and adjustments in the cost estimates are overwhelmed by the 

frequency estimates. 

Assumptions regarding each of these key variables are varied in the 

following manner in the sensitivity analysis: 

1. Number of incremental reportable releases. The number of incremental 

reportable releases is perhaps the most important single variable on which 

costs are estimated. The analysis in Chapter 5 assumes there will be 43 

annual incremental reportable releases of radionuclides. This estimate may 

vary because the estimates of under-reporting could be inaccurate, the AEOD 

data set may not contain representative facilities, or the number of releases 

may not be proportional to the number of facilities. To reflect the 

order-of-magnitude changes in costs that would result from large differences 

in the numbers of incremental reportable releases, the sensitivity analysis 

will estimate the results of halving and doubling this figure. Thus, the 

following assumption is tested: 

Number of Incremental Releases 

Low Estimate Base Case High Estimate 

20 43 100 

2. Notification hours. The costs associated with notification represent 

over 50 percent of total costs to regulated parties. The base case analysis 

in Chapter 5 assumes that 3 hours of managerial time and 2 hours of technical 

time would be required for each release. To estimate a range of notification 

costs that might be experienced by industry and individual firms, the estimate 

of hours are halved and doubled for the senstivity analysis, resulting in the 

following unit cost estimates: 

Managerial and Technical Hours Required for Reporting 

Low Estimate Base Case High Estimate 

$168 $336 $672 

No variation of the hourly cost of managerial and technical time is 

available. The average hourly rates used in the base case analysis are 

considered to be reasonably accurate. Moreover, potential variations in the 

magnitude of these rates is overwhelmed by the potential variation in hours 

required for reporting. 

3. Frequency of cleanups. The base case analysis assumes that there is 

a measurable difference in responses to releases that are above or below the 

RQ. If this assumption is inaccurate (i.e., if responsible parties would not 

respond differently to releases above or below the RQ), then no costs or 

benefits of cleanup can be attributed to regulations that adjust RQs. In the 

sensitivity analysis, various assumptions are used relating to this difference 

in percentage of releases cleaned up above and below RQs to estimate response 

costs. 
P.61 

7-3 

Frequency of Cleanups 

Low Estimate Base Case High Estimate 

.00 .05 .20 

4. Frequency of off-scene monitoring. In Chapter 5, it is assumed that 

all releases require notification processing but that some of these releases 

require no further action. The three sets of estimates for frequency of 

off-scene monitoring that will be used in the sensitivity analysis are as 

follows: 

Frequency of Off-Scene Monitoring 

Low Estimate Base Case High Estimate 

.35 .70 .90 

5. Frequency of on-scene monitoring. It is also important to examine 

the sensitivity of estimates of the frequency with which on-scene monitoring 

efforts will be needed (i.e., the percent of incidents that results in federal 

government on-scene monitoring) both because the government share of costs is 

about 85 percent of total effects, and because on-scene monitoring activities 

account for about 16 percent of government effects. 

Based on judgments of the likelihood of need for on-scene monitoring and 

the availability of resources, the following "low" and "high" estimates have 

been formulated: 

Frequency of On-Scene Monitoring 

Low Estimate Base Case High Estimate 

.10 .20 .40 

6. Frequency of direct removal. The following estimates of frequency of 

direct removal are constructed and used in the sensitivity analysis. Direct 

removal costs represent about 77 percent of government costs. 

Frequency of Direct Removal 

Low Estimate Base Case High Estimate 

.025 .05 .20 

7.2 RESULTS OF THE SENSITIVITY ANALYSIS 

This section presents the results of the sensitivity analysis. The 

section includes a description of changes in estimated costs to the government 

and regulated parties that occur from reporting and cleanup activities using 

the assumptions which were described in Section 7.1. The results of this 

analysis are organized in the same manner as the previous section and 

presented in Exhibit 7-1. 
7-4 

P.62 

EXHIBIT 7-1 

SENSITIVITY ANALYSIS RESULTS 

Low Estimat e Base Case 

1. Number of incremental 

Reportabl e release s 

Assumption : 

Cost of proposed regulation : 

2. Notification hours 

Assumption 

Notification Costs 

Cost of proposed regulation 

3. Incremental frequency of 

cleanups by responsible 

parties 

20 

$ 82,700 

168 

$ 7,200 

$170,700 

4. Frequency of off-scene 

monitoring 

Assumption 

Off-scene monitoring costs 

Cost of proposed regulation 

5. Frequency of on-scene 

monitoring 

Assumption 

On-scene monitoring costs 

Cost of proposed regulation 

6. Frequency of direct government removal 

.35 

$ 3,700 

$174,300 

.10 

$ 12,350 

$165,400 

43 

$178,000 

336 

$ 14,500 

$178,000 

.20 

$ 24,700 

$178,000 

High Estimate 

100 

$ 413,400 

672 

$ 28,900 

$ 192,400 

Assumptions : 

Cost of Cleanups : 

Cost of proposed regulation: 

.00 

$ 0 

$166,200 

.05 

$ 11,600 

$178,000 

$ 

$ 

.20 

46,400 

212,800 

.70 

$ 7,400 

$178,000 

$ 

$ 

.90 

9,500 

180,000 

.40 

$ 49,400 

$ 202,500 

Assumption : 

Direct removal costs : 

Cost of proposed regulation: 

7. Cost of Proposed Regulation 

with All assumptions 

varied : 

.025 

$ 57,600 

$120,200 

$ 40,000 

.05 

$115,240 

$178,000 

$178,000 

.20 

$ 461,000 

$ 523,500 

$1,400,000 

Source: ICF estimates. 
7-5 

1. Number of incremental reportable releases. Estimates of the number 

of reportable releases affect all of the estimates of costs that result from 

increased notification, recordkeeping, and response activities on the part of 

government and regulated parties. Exhibit 7-1 presents the results of 

changing the estimated number of incremental reportable releases and compares 

the cost of the proposed regulation to the base case estimate of 43 

incremental reportable releases. 

2. Notification hours. Varying the estimated number of hours required 

to report releases will affect the cost estimates associated with notification 

activities. Exhibit 7-1 presents the results of the sensitivity analysis, in 

which the base case hours estimates are halved and doubled. Note that this 

sensitivity analysis pertains only to effects on regulated parties; the costs 

to government do not change with variations in industry hours. 

3. Frequency of responsible party cleanups. Varying the assumption 

concerning the difference in responsible parties' cleanup efforts for reported 

versus unreported releases leads to different response costs for regulated 

parties. The difference in industry response to reported releases versus 

unreported releases is shown in Exhibit 7-1. 

4. Frequency of off-scene monitoring. Variations in the assumed 

frequency of off-scene monitoring affect the costs associated with government 

off-scene monitoring activities. Exhibit 7-1 shows the effect on government 

costs. 

5. Frequency of on-scene monitoring. Variations in the assumed 

frequency of on-scene monitoring for radionuclide releases affect the costs 

associated with government on-scene monitoring activities for each 

alternative. Exhibit 7-1 shows the effect on on-scene monitoring costs of the 

base case frequencies and of lower and higher frequency estimates. 

6. Frequency of government direct response. Variations in the assumed 

•frequency of direct response affect the costs of the proposed regulation. 

Exhibit 7-1 shows the effect on direct response costs of the base case 

frequencies and of changing the frequency estimates. 

By varying all assumptions simultaneously, we estimate that the proposed 

regulation will cost between $40,000 and $1,400,000 annually, with a most 

likely annual cost of about $178,000. 

7.3 STATISTICAL ANALYSIS OF RADIONUCLIDE DATA BASE 

The analysis for estimating the number of reportable releases in both the 

baseline situation and under the proposed regulation implicitly assumes that 

there is no correlation between the size of a release and the identity of the 

radionuclide released. We have tested this hypothesis. 

An analysis of variance model (ANOVA) was used to test this hypothesis on 

a formal basis. The release observations were grouped by isotope and the 
P.64 

7-6 

General Linear Model (GLM) procedure of the Statistical Analysis System (SAS) 

was used for the test. The results indicated1 that we could not reject the 

hypothesis of no association between isotope and mean release amount. 

Therefore, we have assumed that there is no such association. 

7.4 SUMMARY 

A sensitivity analysis is as enlightening as the data that cause the 

estimates to change. The results in this chapter suggest that halving and 

doubling many of the effects and altering other key assumptions would not 

change the overall conclusions of the analysis that the estimated cost of the 

regulation is small. Because data on the health and welfare and environmental 

effects of altering RQs are not available, this sensitivity analysis does not 

vary these effects. 

1The F-statistic was 1.05 (d.f. of 52;632) which was a p-value of 0.39. 
APPENDIX A 

PROFILES OF FACILITIES THAT RELEASE RADIONUCLIDES 

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 delegated authority by the 

Commission, and the Department of Energy (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 also potentially release radionuclides 

at levels equalling or exceeding an RQ. Coal-fired utilities and industrial 

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

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

radionuclides during their operations. 

The following sections briefly discuss each of the release categories 

cited above, describing the source of radionuclide emissions, the number of 

facilities within each category, and, where available, general trends in the 

industries. Discussion in A.l encompasses most of the Nuclear Regulatory 

Commission and agreement state licensees; Section A.2 discusses Department of 

Defense facilities; Section A.3 discusses Department of Energy facilities; and 

Sections A.4 and A.5 discuss coal-fired utility and industrial boilers, and 

the primary mineral extraction industries, respectively. 

A . l NUCLEAR REGULATORY COMMISSION AND 

AGREEMENT STATE LICENSEES 

The Nuclear Regulatory Commission has authority under the Atomic Energy 

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

states have been delegated licensing authority by the Commission to license 

source, byproduct, and special nuclear materials for facilities within their 

boundaries. As of 1984, there were 8,900 Commission licensees and 13,000 

agreement state licensees.1 All licensees are subject to the radioactive 

material release limits specified in 10 CFR Part 20, as well as other controls 

specified by the license. For purposes of this discussion, licensees have 

been divided into five general categories: power reactors, research and test 

reactors, radiopharmaceuticals, radiation source manufacturing, and other 

licensees. Most Department of Defense facilities are also licensed by the 

Commission but are discussed separately in Section A.2 of this report. 

A. 1.1 Power Reactors 

Power reactors are units which utilize a controlled fission reaction of 

uranium fuel to produce heat. The heat converts water to steam, which 

U.S. Nuclear Regulatory Commission, 1984 Annual Report, p. 73. 
P.66 

A-2 

provides the force to spin a turbine-generator to produce electricity. "The 

nuclear fission chain reaction is controlled by the reactor's control rods. 

The movement of the control rods up or down within the fuel assemblies 

sustains the chain reaction at a desired power level. There are over 100 

nuclear plants in the United States in operation, generating approximately 13 

percent of electricity consumption. 

Releases resulting from "nuclear incidents" (see Section 11(q) of the 

Atomic Energy Act) at facilities covered by the Price-Anderson Act are exempt 

from CERCLA reporting requirements. Releases at these facilities that are an 

RQ or more, but do not constitute a nuclear incident, must be reported under 

CERCLA to the National Response Center. 

A. 1.2 Research and Test Reactors 

As of 1983, there were 70 reactors in operation in the United States for 

basic and applied research and for teaching purposes. The research conducted 

includes testing of reactor designs, components, and safety features, as well 

as work in the fields of physics, biology, and chemistry. 

A. 1.3 Radiopharmaceuticals 

Radiopharmaceuticals are radioactive chemicals used for medical 

applications and research. In 1979, there were twenty-six industrial 

suppliers of radiopharmaceuticals producing sixty-five generally used 

radionuclides. These twenty-six firms exclude firms that purchase 

radiopharmaceutical products in bulk and repackage them into smaller 

containers (repackagers). 

In 1984, there were over 2,800 medical facilities licensed by the 

Commission to use radiopharmaceuticals, and approximately another 7,000 

facilities licensed by agreement states.2 In 1946, almost 40 years earlier, 

only thirty-eight medical facilities were licensed. Medical facilities use 

radionuclides in all forms including solids, liquids, and gases; uses include 

diagnostic and therapeutic procedures. 

A. 1.4 Radiation Source Manufacturing 

"Radiation sources" refer to radioactive materials enclosed in sealed 

containers. They are found in a number of industrial and consumer products 

2 The number of medical facilities that are Commission licensees is 

reported on page 73 of the 1984 U.S. Nuclear Regulatory Commission Annual 

Report, but the publication does not report the number of medical facilities 

that are agreement state licensees. The U.S. EPA estimated the total number 

of radiopharmaceutical manufacturers and users to be over 10,000 in 1977 (U.S. 

Environmental Protection Agency, Radionuclides Background Information 

Document for Final Rules, Volume II, October 1984, p. 3.3-5.). Subtracting 

the 2800 Commission licensees from the total estimate of 10,000, yields rougly 

7,000 agreement state licensees. 
A-3 

such as radioisotope gauges used to measure thickness, static eliminators for 

industrial machinery, testing equipment, self-illuminating signs and watch 

dials, and smoke detectors. 

Manufacturers of radiation sources process bulk quantities of radioactive 

materials received from radionuclide production facilities such as accelerators 

or reactors. The radiation source manufacturers keep inventories of radioactive materials in quantities ranging from ten curies to 100,000 curies. 

A. 1.5 Other Commission or Agreement State Licensees 

Other Nuclear Regulatory Commission or agreement state licensees include 

laboratories, low-level waste disposal sites, mineral and metal processing 

facilities, fuel cycle facilities, and uranium mills. They are all subject to 

the emission requirements of 10 CFR Part 20, Appendix B, Table II. 

Laboratories 

Approximately 700 laboratories are licensed to handle radioisotopes in 

unsealed form, and it is assumed that an equal number of smaller laboratories 

that are unlicensed handle unsealed radioisotopes, resulting in an estimated 

total of 1400 laboratories that are potential sources of low-level radioactive 

emissions.3 These laboratories are established in industry, government 

agencies, and academic and research institutions. They perform testing and 

research and development, and vary a great deal in size. While some 

facilities have only one small, multi-purpose laboratory, others have up to 

300 individual laboratories in several buildings. 

Small laboratories tend to specialize in a limited use of radionuclides 

for a single specific testing purpose. Academic and industrial laboratories 

use byproduct materials in research and testing. Medical laboratories conduct 

basic chemical and applied radionuclide research related to disease and health 

problems. Government laboratory facilities may use radionuclides for purposes 

such as food and drug testing or water and air quality monitoring. The most 

commonly used radionuclides in laboratory work are tritium, carbon-14, 

xenon-133, iodine-125, and iodine-131. Testing and industrial laboratories 

tend to use larger quantities of radionuclides than academic or other research 

laboratories; conversely, academic and research laboratories tend to use a 

wider variety of radionuclides. 

Waste Disposal Sites 

Although there are six low-level radioactive waste disposal sites licensed, 

only three are operational. These sites accept low-level radioactive wastes 

in a stabilized form from three major sources: power-reactor and fuel cycle 

3 Corbit CD., Herrington W.N., Higby D.P., Stout L.A., and Corley J.P., 

Background Information on Sources of Low-Level Radionuclides Emissions to 

Air, PNL-4670, Prepared for EPA under U.S. DOE Contract by Battelle Memorial 

Institute, September 1983. 
A-4 

operations, laboratory research, and medical facilities. Wastes accepted by 

these facilities for disposal by shallow-land burial must meet specific site 

acceptance criteria. The disposal sites do not accept special nuclear 

materials, transuranics (elements having a higher atomic number than uranium), 

or spent reactor fuel. Wastes are buried at the disposal site in the 

transport containers in which they arrive. 

Mineral and Metal Processing Facilities 

Commission and agreement state licensees include facilities which extract 

metals from thorium- and uranium-bearing ores. Ten such facilities are 

licensed in the following nine states: Alabama, California, Colorado, 

Florida, Illinois, New Mexico, Oregon, Pennsylvania, and Tennessee. These 

facilities generally process ores for either refractory metals and their 

oxides (such as zirconium, columbium/niobium, tantalum, and hafnium), or for 

rare earths (such as cerium, praseodymium, neodymium, dysprosium, and 

ytterbium). Thorium is also used in some of these facilities to manufacture 

welding rods and to cast machine parts. 

Fuel Cycle Facilities 

The Commission and agreement states also license the use of source, 

byproduct, and special nuclear material at facilities engaged in the 

production of nuclear fuel. These facilities include operating uranium mills, 

uranium.hexafluoride. conversion plants, and uranium fuel fabrication plants. 

There is currently no plutonium fuel fabrication being done in the United 

States. 

Uranium Milling 

Uranium ore is delivered to mills where it is crushed and ground, and 

uranium oxide is chemically extracted. The mill product, also called uranium 

concentrate or yellow cake, is then sent to conversion facilities, where it is 

chemically converted to uranium hexafluoride. Uranium milling activity is a 

declining industry. As of November 1985, there were only three active 

uranium mills in the U.S. (one of which is expected to go on standby status). 

An additional 17 mills are already on standby status. Total uranium oxide 

production from mills was about 7,400 tons in 1984, down from a high of 21,800 

tons in 1980." 

A.2 DEPARTMENT OF DEFENSE (DOD) FACILITIES 

Department of Defense (DOD) facilities are also licensed by the Nuclear 

Regulatory Commission and must comply with limits for airborne and liquid 

discharges to unrestricted areas under 10 CFR Part 20, Appendix B, Table II. 

* U.S. Environmental Protection Agency, Proposed Standard for Radon-222 

Emissions from Licensed Uranium Mill Tailings; Draft Economic Analysis, 

Office of Radiation Programs, EPA 520/1-86-002, January 1986. 
P.69 

A-5 

The Armed Forces Radiobiology Research Institute (AFRRI), located at the 

National Naval Medical Center in Bethesda, Maryland, operates both a thermal 

research reactor and a linear accelerator (linac), mainly in support of 

research on the medical effects of nuclear radiation and the effects of 

transient radiation on electronics and other equipment. The U.S. Army Test 

and Evaluation Command operates two reactors which are similar in design and 

are used to support studies in the effects of nuclear radiation. Both are 

fueled with enriched uranium. 

Nine naval shipyards contribute almost all the radionuclide releases from 

U.S. Navy facilities. Pressurized water reactors power the nuclear fleet at 

the naval shipyards. Standard operations at the shipyards include 

construction, startup testing, refueling, and maintenance of the reactors. 

Radioactive wastes generated by these operations are processed and sealed, 

then shipped to commercial waste disposal sites. 

A.3 DEPARTMENT OF ENERGY (DOE) FACILITIES 

The U.S. Department of Energy (DOE) is given authority by the Atomic 

Energy Act of 1954 (Section 161 of Public Law 83-703) "to protect the public 

health and safety" with respect to the operation of so-called "G0C0" 

facilities -- facilities which are "government owned, contractor operated." 

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.5 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. 

As of 1980, 78 GOCO facilities in 24 states were subject to the health and 

safety requirements contained in DOE Order 5484.1. In 1982, there were thirty 

"active" DOE complexes, many of which have several operating facilities. 

("Active" is defined to mean facilities currently generating radioactive 

waste.) Fourteen of these complexes are laboratories operating diversified 

programs. The other complexes operate programs including primarily weapons 

production and testing, nuclear materials production, and physical research. 

A . 4 COAL-FIRED UTILITY AND INDUSTRIAL BOILERS 

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. Boilers used in the utility industry are designated as utility boilers, 

and those used to generate process steam, process hot water, space heat, or 

electricity for in-house use are designated as industrial boilers. 

5 Rogers and Associates Engineering Corp., Radioactive Contamination at 

Federally Owned Facilities, June 1982, pp. 3-2, 3-3. 
P.70 

A-6 

In 1983, coal-fired steam electric power units accounted for 63 percent of 

total capacity and 55 percent of total energy generation by U.S. electric 

utility generating units.6 In early 1985, there were 1,281 coal-fired units 

on-line with a total generating capacity of 281 gigawatts.7 

Coal-fired industrial boilers are used mainly to produce process steam and 

hot water, generate electricity (for the producer's own use), and provide 

space heat. Major users of industrial boilers include the steel, aluminum, 

chemical, and paper industries. There are approximately 51,200 coal-fired 

industrial boilers operating in the United States.8 

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.9 

The emission of radionuclides to the air from coal-fired utility and 

industrial boilers is small. In promulgating radionuclide emission standards 

under the National Emission Standards for Hazardous Air Pollutants (NESHAP), 

EPA did not regulate radionuclide emissions from these boilers (50 FR 5190). 

Coal-fired steam electric power generators and industrial boilers are not 

considered affected by the proposed RQ adjustments because radionuclide 

emissions to the air from these facilities are small. Quantities of all 

radionuclides expected to be released are well below the proposed RQ values. 

A.5 MINERAL EXTRACTION INDUSTRY 

Almost all mineral extraction industries that involve the removal and 

processing of ores to recover metal release some radionuclides. EPA has 

identified the following mineral extraction industries as having potential for 

releases 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 

quantity of ore mined domestically and because the mining processes used 

6 U.S. Department of Commerce, Statistical Abstract of the U.S. (1985), 

105th Edition. Government Printing Office, Washington, D.C, p. 564. 

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

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

8 U.S. Environmental Protection Agency, The Radiological Impact of 

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

Washington, D.C, October 1981. 

9 U.S. Environmental Protection Agency, Radionuclides Background 

Information Document for Final Rules, Volume II, October 1984, p. 4.0-1. 
P.71 

A-7 

create a likelihood for radionuclide emissions.10 Only underground uranium 

mining and elemental phosphorus plants were found to warrant radionuclide 

emission standards under the Clean Air Act (50 FR 5190). Each mineral 

extraction industry is discussed below. 

A.5.1 Uranium Mining 

There are several different types of uranium mines and extraction 

processes. These include: open pit, underground, and in-situ (solution) 

mining operations. In 1982, there were 24 open pit uranium mines, 139 

underground uranium mines, and 18 in-situ mines in operation, producing about 

86 percent of the total uranium oxide domestic production in that year. Total 

uranium oxide production was 13,400 tons.11 

Domestic uranium is almost exclusively mined in the western portion of the 

United States, mostly in New Mexico, Wyoming, and Texas. As of 1984, uranium 

production in these states collectively accounted for approximately 65 percent 

of the national total. Several other states (including Arizona, Colorado, 

Florida, South Dakota, Utah, and Washington) together accounted for the 

remaining 35 percent of the total.12 

The majority of the uranium industry is owned by large, publicly held 

corporations. During the early and mid-1970's, the industry experienced rapid 

growth, spurred by expectations of increasing demand. This demand, however, 

did not materialize and, as a result, the industry is presently faced with an 

excess of capacity and supply, and the potential for increased competition 

from imports. 

A.5.2 Aluminum Industry 

Several materials are used in the production of aluminum. Bauxite is the 

principal aluminum ore found in nature. Bauxite contains elevated levels of 

both uranium-238 and thorium-232. The ore is processed at the mine to produce 

alumina, the basic feed in the aluminum reduction process. Twelve domestic 

firms produce primary aluminum. Almost all of the bauxite ore used in 

aluminum production is imported. Only five of the twelve firms that own 

primary aluminum plants also own domestic plants that produce alumina. These 

five firms own 73 percent of the current U.S. primary aluminum capacity. 

Currently, there are 32 operating primary aluminum smelters in the United 

States. With one exception, all of the plants are located in rural areas. 

10 U.S. Environmental Protection Agency, Radionuclide Background 

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

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

GJO-100(83), Grand Junction, Colorado, January 1983, p. 9. 

12 Ibid. 
P.72 

A-8 

These smelters release radionuclides to the air from the uranium and 

thorium series at extremely low levels, however. A typical aluminum smelting 

operation releases radionuclides in a range from close to 10 curie per day 

to nearly 10 curie per day,13 which is well below the lowest proposed RQ 

value. Therefore, these facilities are not affected by the proposed RQ 

adjustments. 

A.5.3 Copper Industry 

Most firms in the copper industry perform all production processes from 

mining through refining. Copper mills and smelters are located near copper 

mines. There are fifteen operating primary smelters in the United States. 

All smelters are located in rural areas with low population densities. Ninety 

percent of U.S. copper smelter capacity is located in Arizona, Montana, 

Nevada, New Mexico, Texas, and Utah. The sites tend to be large and generally 

contain associated mining and milling operations. In 1978, 1.5 million metric 

tons of primary copper was produced.1* Copper smelters also release 

radionuclides to the air at very small levels. At a typical copper smelter, 

radionuclides are released principally from the uranium and thorium series at 

levels ranging from 1.4x10 to 5.4x10 curies per day.15 These levels 

are well below the lowest proposed RQ value of 0.001 curie per day, and 

therefore, these facilities are not affected by the proposed RQ adjustments. 

A.5.4 Zinc Industry 

Zinc is usually found in nature as a sulfide ore called sphalerite. The 

ores are processed at the mine to form concentrates typically containing 62 

percent zinc and 32 percent sulfur. In the past 10 years, U.S. demand for 

zinc metal has grown slowly, but U.S. smelting capacity has declined by more 

than 50 percent. Plants closed because they were obsolete, could not meet 

environmental standards, or could not obtain sufficient concentrate feed. 

Consequently, the metal has replaced concentrate as the major form of import. 

This situation is expected to continue. There are five operating primary zinc 

production facilities in the United States. Radionuclides in the uranium and 

thorium series are released from zinc smelters at extremely low levels, except 

for radon-222. Most radionuclides from zinc smelters to the air are released 

-4 -6 

in levels ranging from 1.1x10 curie to 1.5x10 curie per day, all well 

below the proposed RQ values. Radon-222 is released at an expected level of 

13U.S. Environmental Protection Agency, Radionuclide Background 

Information Document for Final Rules, Volume II, October 1984, p. 7.1-8. 

14 Schroeder H.J., Mineral Commodity Profiles -- Copper, U.S. 

Department of the Interior, Bureau of Mines, Washington, D.C, 1979. 

15U.S. Environmental Protection Agency, Radionuclide Background 

Information Document for Final Rules, Volume II, October 1984, p. 7.2-6.