P.1 

loznQ-KiM~q~- c 

ECONOMIC IMPACT ANALYSIS FOR THE FINAL 

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 

February 15, 1989 

Prepared by: 

ICF Incorporated 

Contract No.: 68-03-3452 

9300 Lee Highway 

Fairfax, Virginia 

22031-1207 

ICF INCORPORATED 
P.2 

1 

ECONOMIC IMPACT ANALYSIS FOR THE FINAL 

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 

February 15, 1989 

Prepared by: 

ICF Incorporated 

Contract No.: 68-03-3452 
P.3 

TABLE OF CONTENTS 

Page 

EXECUTIVE SUMMARY ES-1 

CHAPTER I: BACKGROUND AND INTRODUCTION 1-1 

1.1 Purpose of the Analysis 1-1 

1.2 The Notification Process 1-2 

1.3 RQ Adjustments for Radionuclides 1-3 

1.4 Releases Exempted from CERCLA Reporting Requirements ..... 1-5 

1.5 Facilities Affected by Final RQ Adjustments 1-7 

1.6 Organization of this Report 1-10 

CHAPTER II: BASELINE REPORTABLE EPISODIC RELEASES -. 2-1 

2.1 Methodology to Estimate the Number of Baseline 

Reportable Releases 2-1 

2.2 Derivation of Total Annual Number of Radionuclide 

Releases (Factor A) 2-5 

2.3 Derivation of Radionuclide Release Probability 2-12 

2.4 Size Distribution of Radionuclide Releases 2-15 

2.5- Baseline Reportable Episodic Releases 2-20 

CHAPTER III: UNIT COSTS ASSOCIATED WITH REPORTABLE 

EPISODIC RADIONUCLIDE RELEASES 3-1 

3.1 Actions Taken with a Reportable Radionuclide Episodic 

Release 3-2 

3.2 Valuation of Actions Taken by Episodic Releasers of 

Radionuclides 3-4 

3.3 Valuation of Government Actions 3-9 

CHAPTER IV: ESTIMATED ANNUAL COST OF RQ ADJUSTMENTS 4-1 

4.1 Estimated Number of Incremental Reportable Episodic 

Releases 4-1 

4.2 Estimated Cost of Final RQ Adjustment 4-2 

4.3 Estimate of Number of Other Incremental Reportable 

Releases 4-9 

4.4 Firm Level Economic Effects 4-17 

CHAPTER V: SENSITIVITY ANALYSIS 5-1 

5.1 Concepts and Key Variables 5-1 

5.2 Results of the Sensitivity Analysis 5-4 

5.3 Statistical Analysis of EIA Radionuclide Data Base 5-6 

5.4 Summary 5-6 

APPENDIX A: PROFILES OF FACILITIES THAT RELEASE RADIONUCLIDES A-l 

APPENDIX B: ESTIMATE OF THE NUMBER OF FACILITIES WITH COAL-FIRED 

BOILERS EXPECTED TO REPORT UNDER SECTION 103(f)(2) B-l 
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LIST OF EXHIBITS 

Exhibit Page 

ES-1 Incremental Costs of Reporting Episodic and 

Continuous Releases of Radionuclides ES-4 

2-1 Assumptions Used to Estimate Baseline Reportable 

Releases 2-2 

2-2 Profile of Episodic Releases in Nuclear Regulatory 

Commission AEOD Data Set 2-10 

2-3 Characteristics of the Unified Radionuclide 

Data Base 2-14 

2-4 Frequency of Episodic Releases for Each Radionuclide 

in the Unified EIA Data Base 2-16 

2-5 Size Distribution of Radionuclide Releases in the 

EIA Data Base 2-19 

2-6 Reportable Baseline Radionuclide Releases 

Estimated from the Unified EIA Data Base 2-23 

3-1 Unit Notification Costs to Facility Owners/Operators 

of a Reportable Episodic Release 3-7 

3-2 Radionuclide Response Cost Estimates 3-10 

3-3 Unit Costs to All Government Entities of a 

Reported Episodic Release 3-12 

4-1 Reportable Radionuclide Releases under Final 

Adjusted RQs Estimated from EIA Data Base 4-3 

4-2 Unit Notification Costs to Facility Owners/Operators 

of a Reportable Episodic Release 4-5 

4-3 Calculation of Total Annual Costs to Facility 

Owners/Operators 4-6 

4-4 Calculation of Total Annual Costs to 

Government 4-8 

4-5 Estimated Number of Reporting Facilities Under CERCLA 

Section 103(f)(2) , 4-12 

4-6 Total Costs of Reporting Under Section 103(f)(2) 

(excluding facilities with coal-fired boilers) 4-18 

4-7 Total Costs of Reporting Under Section 103(f)(2) .... 4-20 
P.5 

LIST OF EXHIBITS (continued) 

Exhibit Page 

5-1 Results of the Sensitivity Analysis 5-5 

B-l Distribution by Capacity of Coal-fired Power 

Plants B-7 

B-2 Distribution by Capacity and Type of Coal-fired 

Inustrial Boilers B-7 
P.6 

EXECUTIVE SUMMARY 

Section 103 of the Comprehensive Environmental Response, Compensation, 

and Liability Act of 1980 (CERCLA) requires notification of the National 

Response Center when releases of hazardous substances occur in amounts that 

equal or exceed an RQ. Section 304 of the Superfund Amendments and 

Reauthorization Act of 1986 (SARA) amends CERCLA to require that State 

Emergency Response Commissions (SERCs) and Local Emergency Planning Committees 

(LEPCs) also be notified when a release occurs of a reportable CERCLA 

hazardous substance. Radionuclides are CERCLA hazardous substances; section 

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

of substances. EPA recognizes that a one-pound RQ is not appropriate in most 

cases because radionuclide releases of less than one-pound may present a 

substantial hazard to public health and welfare and the environment. The 

purpose of this Economic Impact Analysis (EIA) is to estimate the incremental 

costs to facility owners and operators and to the government that may be 

attributed to the final regulation adjusting the reportable quantities (RQs) 

for approximately 1,500 radionuclides. 

METHODOLOGY 

There are approximately 950,000 facilities in the United States that use 

and, therefore, potentially could release radionuclides into the environment. 

There are no comprehensive data on the number of radionuclide releases that 

occur annually, or on the amount of those releases. To establish an EIA 

release data base, therefore, this analysis uses data that are available from 

six sources, including the Transportation Technology Center of Sandia National 

Laboratory, the Department of Energy, the National Response Center, EPA's 

Office of Radiation Programs, the Nuclear Regulatory Commission's Office for 

Analysis and Evaluation of Operational Data (AEOD), and the Commission's 

Operations Center. 

To estimate the potential change in the number of reportable episodic 

radionuclide releases, historical reports of episodic releases are used to 

predict the characteristics of future releases by assuming that future 

radionuclide releases will occur with the same frequency and be of the same 

size as historical radionuclide releases. An EIA data base is developed, 

consisting of 1,139 radionuclide release events. Sixty-three different 

radionuclides are identified in the EIA data base, and 1,113 events have 

quantity information related to the release event. The EIA data base is used 

to estimate the historical frequency of release of a particular radionuclide, 

and thereby to project the future likelihood of a release of a specific 

radionuclide. If a radionuclide is not identified in the EIA data base, the 

analysis assumes that the particular radionuclide was never released in the 

past and assigns zero to the probability that a release event in the future 

would involve that particular radionuclide. 

The EIA data base also is used to estimate a second parameter, the amount 

released during an event. Release of a radionuclide to the environment by 

itself does not mean that the release must be reported to the National 

Response Center. A release is reportable only if the amount released equals 

or exceeds an RQ. As each radionuclide has been assigned one of seven RQs, it 
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is important to determine the probability that the released quantity is 

sufficiently large to warrant a report to the National Response Center and 

other government bodies. 

The analysis assumes that there is no correlation between the identity of 

the radionuclide released and the quantity released during an event. 

Therefore, by multiplying the probability that a particular radionuclide will 

be released, by the probability that the release will equal or exceed its RQ, 

the analysis derives the number of reportable radionuclide releases. The 

methodology also considers the amount of the radionuclide release that is 

federally permitted, and, thus, excluded from the CERCLA and SARA reporting 

requirements. Releases that are not in compliance with federally permitted 

release levels only need to report to the National Response Center and to 

SERCs and LEPCs if the release equals or exceeds the federally permitted level 

by an RQ or more. 

In addition to episodic releases, some facilities that release 

radionuclides regularly as a result of normal operations may be affected by 

the final adjusted radionuclide RQs. These facilities typically move, 

process, or consume large quantities of low activity materials such as coal or 

ore. Because the data used to estimate the incremental number of reportable 

episodic releases are not appropriate to estimating releases from these 

facilities, a different methodology is used. Facilities potentially releasing 

radionuclides on a continuous basis are estimated by reviewing the data 

available on these releases on an industry by industry basis. 

ESTIMATED COSTS OF RADIONUCLIDE RQ ADJUSTMENTS 

After estimating the number of reportable releases, the analysis 

identifies the actions that facility owners and operators and the government 

would likely take when a reportable radionuclide release occurs. These 

actions include notification, recordkeeping, and response activities for 

facility owners and operators, and notification processing, off-scene and onscene monitoring, and direct removal for the government. The analysis then 

estimates the unit costs of each of these actions, and considers the 

likelihood that each of these actions would actually be taken. For example, 

simply because a facility owner or operator notifies the National Response 

Center that a radionuclide release has occurred does not mean that a response 

action will be taken by either the government or the facility operators. The 

analysis, therefore, must account for both the likelihood that an action will 

be taken and the nature (i.e., cost) of that action. Ultimately, the analysis 

must estimate how these actions (and costs) will be modified by the final RQ 

adjustments. 

EPA is adjusting the RQs downward (i.e., below one pound) for nearly all 

radionuclides, and, therefore, expects an increase in the number of reportable 

radionuclide releases. This analysis estimates that there are approximately 

19 episodic radionuclide releases that would.be reportable annually if the RQ 

were to remain one pound, and.estimates that there will be approximately 78 

reportable episodic releases annually when the RQ adjustments are final. 

Therefore, there are 59 incremental reportable episodic releases annually as a 

result of the final RQ adjustments. As a result, facility owners and 

ES-2 
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operators and the government will incur increased costs because both entities 

will likely increase the number of response and recordkeeping actions taken, 

reflecting the increase in the number of reportable releases. This analysis 

estimates that these additional costs will be approximately $256,405 annually. 

The analysis also estimates the number and'costs of radionuclide releases 

that equal or exceed the final RQs, but are expected to be reported under the 

provisions of CERCLA section 103(f)(2) because these releases are "continuous" 

and "stable in quantity and rate." Facilities that are eligible to report 

releases under section 103(f)(2) must report releases initially, annually, and 

whenever a statistically significant increase (SSI) occurs. The types of 

facilities most likely to have a continuous radionuclide release include coalfired utility and industrial boiler sites, certain mining and ore-processing 

operations, and energy extraction and processing facilities. 

It is estimated that approximately 2,710 facilities are likely to release 

an RQ or more of a radionuclide on a continuous basis. The majority of these 

facilities (1,724) are utility and industrial facilities with coal-fired 

boilers. Because of the availability of data regarding the characteristics of 

releases from these facilities, U.S. Environmental Protection Agency (EPA) has 

examined these facilities in greater detail than other facilities with 

continuous releases. 

Because continuous releases are different in nature than episodic 

releases, the actions undertaken by industry and government following a 

continuous release of a radionuclide are also different. Specifically, the 

reporting requirements under section 103(f)(2) require initial and annual 

notification and the immediate reporting of a statistically significant 

increase in the release. Because these releases are assumed to be incidental 

to normal operating procedures and to have been reviewed by the appropriate 

government bodies through the initial and annual notification reports, it is 

assumed that no incremental response actions will be undertaken (or costs 

incurred) by either industry or government as a result of these releases. The 

annualized costs of reporting under section 103(f)(2) are estimated as 

$3,160,000 for industry and $660,000 for government. The total annualized 

costs to all parties is estimated to be $3,820,000. 

Excluding facilities with coal-fired boilers, the number of facilities 

that have continuous releases and are expected to report under section 

103(f)(2) is estimated at approximately 1,000. The annualized costs to these 

facilities of reporting releases is estimated as $1,150,000. The annualized 

costs to government of processing these release reports is estimated to be 

$240,000, resulting in total costs to all parties of $1,390,000. The 

estimated costs for reporting episodic and continuous releases under the final 

adjusted radionuclide RQs are presented in Exhibit ES-1. 

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EXHIBIT ES-1 

INCREMENTAL COSTS OF REPORTING EPISODIC AND 

CONTINUOUS RELEASES OF RADIONUCLIDES 

EPISODIC RELEASES 

Party 

Industry (59 episodic releases) 

Government 

TOTAL: 

Annual Costs 

$39,700 

S216.700 

$256,400 

CONTINUOUS RELEASES (All facilities) 

• Party 

Industry (2,710 facilities) 

Government 

TOTAL: 

Annualized Costs * 

$3,160,000 

$660.000 

$3,820,000 

CONTINUOUS RELEASES (Excluding facilities with coal-fired boilers) 

Party Annualized Costs * 

Industry (986 facilities) $1,150,000 

Government $240.000 

TOTAL: $1,390,000 

* Costs are annualized over a ten year period at a four 

percent discount rate. All costs are in 1987 dollars. 

ES-4 
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CHAPTER 1 

BACKGROUND AND INTRODUCTION 

The Comprehensive Environmental Response, Compensation, and Liability Act 

of 1980 (CERCLA) establishes broad federal authority to undertake removal and 

remedial actions in response to releases or threats of releases of hazardous 

substances and certain pollutants or contaminants into the environment. 

Section 103 of CERCLA requires notification of the National Response Center 

when releases of hazardous substances occur in amounts that equal or exceed a 

reportable quantity (RQ). Notification of the National Response Center serves 

to alert the federal government to releases of hazardous substances that may 

require response to protect public health and welfare and the environment. 

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 the 

Administrator of the U.S. Environmental Protection Agency (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 

the environment. EPA, therefore, is issuing a final regulation to adjust the 

RQs for approximately 1500 radionuclides. 

1.1 PURPOSE OF THE ANALYSIS 

There are several purposes for conducting an Economic Impact Analysis 

(EIA). One objective of an EIA is to estimate the incremental costs and cost 

savings resulting from a regulatory action. A second objective of an EIA is 

to determine whether or not the regulation constitutes a major rule. 

Executive Order (E.O.) 12291 requires regulatory agencies to prepare analyses 

of the economic impacts of a regulation. A Regulatory Impact Analysis is 

required for all major rules. According to E.O. 12291, major rules are 

regulations likely to result in: 

(1) An annual effect on the economy of $100 million or 

more; or 

(2) A major increase in costs or prices for 

consumers, individual industries, federal, 

state, or local government agencies, or 

geographic regions; or 

(3) Significant adverse effects on competition, 

employment, investment, productivity, 

innovation, or on the ability of United Statesbased enterprises to compete with foreign-based 

enterprises in domestic or export markets. 

Finally, an EIA is conducted to determine whether a regulation would have a 

significant impact on small businesses. 
P.11 

For most radionuclides, the final regulation adjusting RQs will require 

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

regulation, therefore, is expected to impose additional reporting and report 

processing costs both on the regulated community and on the government because 

a larger number of releases will be reportable. This analysis discusses and 

quantifies, to the extent possible, the costs that will be incurred by 

facility owners and operators and the government as a result of the final RQ 

adjustments. 

This chapter of the EIA describes the reporting requirements for releases 

of radionuclides under sections 103(a) and (b) of CERCLA, and also the 

additional reporting requirements that the Superfund Amendments and 

Reauthorization Act of 1986 (SARA) added to the requirements of CERCLA. 

Section 1.2 describes the notification process, the CERCLA and SARA reporting 

requirements, and the range of potential response activities triggered by a 

reportable release; Section 1.3 describes the purpose of the RQ adjustments 

for radionuclides; Section 1.4 describes the releases of hazardous substances 

that are exempt from the notification requirements; Section 1.5 describes 

those facilities that potentially are affected by the RQ adjustments; and 

Section 1.6 outlines the remaining chapters of this report. 

1.2 THE NOTIFICATION PROCESS 

Regulations implementing the general reporting requirements of sections 

103(a) and (b) of CERCLA require a person in charge of a vessel or facility to 

notify the National Response Center as soon as he has knowledge that there has 

been a release of a hazardous substance during a 24-hour period in an amount 

equal to or exceeding the RQ for that substance (40 CFR 302.6(a)). CERCLA 

section 103(b) makes those persons who are required to notify the National 

Response Center, but fail to do so immediately, subject to criminal penalties. 

CERCLA section 101 also provides exclusions to the reporting requirements for 

certain types of releases or certain types of substances.1 

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 necessary. Notification does not necessarily mean that a field 

reponse will occur, nor does it eliminate liability or responsibility for 

response costs or natural resource damages associated with the release. 

CERCLA section 101 defines the term "release" to include within its scope 

virtually all ways that substances may enter the environment: 

"release" means any spilling, leaking, pumping, pouring, 

emitting, emptying, discharging, injecting, escaping, 

leaching, dumping, or disposing into the environment 

(including the abandonment or discarding of barrels, 

containers, and other closed receptacles containing any 

1 For example, CERCLA section 101(10) exempts federally permitted 

releases from the CERCLA notification and liability provisions.1 

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hazardous substance or pollutant or contaminant) [section 

101(22) as amended by section 101(c) of SARA] 

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

substance designated under: 

• Section 307 and 311 of the Clean Water Act; 

Section 3001 of the Resource Conservation and 

Recovery Act (RCRA); 

Section 102 of CERCLA; 

Section 112 of the Clean Air Act; and 

Section 7 of the Toxic Substances Control Act (TSCA) 

Section 102(b) of CERCLA establishes a one-pound RQ for each hazardous 

substance, except those for which an RQ was established pursuant to section 

311 of the Clean Water Act. Section 102(a) of CERCLA authorizes EPA to adjust 

statutory RQs by regulation.2 

In addition to the reporting requirements established by CERCLA, SARA 

section 304 requires state and local reporting for releases of CERCLA 

hazardous substances. The SARA section 304 notification is to be given by the 

owner or operator of a facility immediately after the release of an RQ or more 

(one pound or more if a reporting trigger is not established by regulation). 

The notification is to be given to the community emergency coordinator for 

each Local Emergency Planning Committee (LEPC) for any area likely to be 

affected by the release, and to the State Emergency Response Commission (SERC) 

of any state likely to be affected by the release. 

1.3 RQ ADJUSTMENTS FOR RADIONUCLIDES 

There are approximately 1500 known radionuclides. A radionuclide is an 

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

The instability of such elements is the net effect of forces between these two 

types of nuclear particles. In order to achieve a more stable configuration, 

the nucleus releases energy in the form of particles or rays by a process of 

decay called radioactivity. Radionuclides decay at different rates; as a 

result, a pound of two different radionuclides could represent significantly 

different levels of radioactivity, and thus pose different threats to public 

health and welfare and the environment. 

2 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 on September 29, 1986 (51 FR 34534). 

EPA published a Notice of Proposed Rulemaking adjusting the RQs for 273 

chronic toxicants and potential carcinogens (52 FR 8140). There are currently 

719 CERCLA hazardous substances. 

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

ranging from 1 pound to 5000 pounds. For these substances, the principal 

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

carcinogenicity. These health concerns may be related to the number of pounds 

of a substance released. The principal health hazard associated with exposure 

to radionuclides is carcinogenicity, however,.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 

generally are 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. 

Another widely used radiation measurement is the Roentgen Equivalent Man 

(rem).* The rem is a unit measure of radiation dose and often is 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 former considers the 

amount of radioactive material; 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 

most existing reporting triggers for radionuclide releases are expressed in 

terms of one of these two units. Nearly 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. 

The final regulation being analyzed in this EIA is adjusting the RQ for 

radionuclides to make CERCLA regulations consistent with other industry 

measures and to ensure timely reporting and timely field responses to 

releases. The final RQs are in units of curies and are not uniform across all 

radionuclides. The Agency is dividing 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 establishing 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 also is establishing 

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

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

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 also can be expressed in international metric 

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

United States. This analysis will use curies and rem to measure amounts of 

radionuclides. 

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1.4 RELEASES EXEMPTED FROM CERCLA REPORTING REQUIREMENTS 

It is important to define clearly the types of releases and facilities 

that are subject to CERCLA notification requirements because only those 

facilities will be affected by the radionuclide RQ adjustments. Not all 

radionuclide releases that equal or exceed an RQ are reportable immediately to 

the National Response Center. CERCLA section 101(22) defines "release" and, 

in so doing, eliminates certain radionuclide emissions from the definition of 

release. CERCLA section 101(10) defines "federally permitted releases"; under 

section 103, such releases are exempt from CERCLA notification provisions. 

CERCLA section 103(f)(2) provides for reduced reporting for releases that are 

"continuous" and "stable in quantity and rate." Each of these provisions are 

discussed briefly below, with an explanation of how they may pertain to 

releases of radionuclides. 

The exclusion under section 101(22) of CERCLA most likely to be of 

greatest importance for radionuclides is for releases of source, byproduct, or 

special nuclear material5 from a nuclear incident subject to requirements of 

the Nuclear Regulatory Commission for financial protection under section 170 

of the Atomic Energy Act (AEA).6 Nuclear reactors are the primary type of 

facility subject to AEA section 170. EPA does not have the legal authority to 

require reports of nuclear incidents; such releases do not need to be reported 

to the National Response Center, regardless of the quantity released. It is 

necessary, however, for releases from nuclear power plants not constituting 

nuclear incidents, but at least an RQ above permitted levels, to be reported 

immediately to the National Response Center. 

Section 103 of CERCLA excludes releases that are federally permitted from 

its notification requirements; federally permitted releases are defined in 

section 101(10). 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 

5 Source material is defined as (1) natural uranium, thorium, or any 

combination thereof or (2) ores which contain 0.05 percent (by weight) of 

uranium or thorium (section ll(z) of the Atomic Energy Act (AEA), and Nuclear 

Regulatory Commission regulations in 10 CFR Part 40). Byproduct material is 

(1) any material made radioactive by exposure to radiation in the process of 

producing or using special nuclear material or (2) the wastes produced by the 

extraction or concentration of uranium or thorium from ore (section 11(e) of 

the AEA). Special nuclear material is defined as plutonium, or uranium 

enriched in the U-235 or U-233 isotope (AEA section ll(aa)). All of these 

materials are licensed by the Nuclear Regulatory Commission and its Agreement 

States. 

6 A release of source, byproduct, or special nuclear material from a 

processing site designated under sections 102(a)(1) or 302(a) of the Uranium 

Mill Tailings Radiation Control Act of 1978 is not a "release" for purposes of 

response actions under CERCLA, but is subject to the notification requirements 

of sections 103(a) and (b) (see section 101(22)) and liability under section 

107. 

1-5 
P.15 

the permitted level, the release is not federally permitted, but nonetheless 

does not need to be reported to the National Response Center. Any federally 

permitted release is exempt from CERCLA notification and liability provisions. 

Section 101(10)(K) of CERCLA exempts from reporting "any release of 

source, special nuclear, or byproduct material ... in compliance with a 

legally enforceable license, permit, regulation, or order issued pursuant to 

the ... [AEA]." The Nuclear Regulatory Commission is responsible for many 

activities under the AEA. Licenses and permits may be issued by the Nuclear 

Regulatory Commission or by states to whom the authority to regulate 

radiation-related activities has been relinquished under an agreement with the 

Nuclear Regulatory Commission (i.e., Agreement States). Releases in 

compliance with licenses and permits issued by the Nuclear Regulatory 

Commission or by Agreement States under such agreements are federally 

permitted releases. 

Administration of the AEA does not reside solely with the Nuclear 

Regulatory Commission, and, therefore, releases from facilities other than 

those regulated by the Commission or Agreement States may be federally 

permitted if they are authorized under the AEA. To the extent releases are in 

accordance with licenses, permits, orders, or regulations issued under the AEA 

through provisions not administered by the Commission, they also would be 

federally permitted releases. For example, the Department of Energy (DOE) 

governs its radiation protection activities under the AEA by a series of 

internal orders. When such orders are issued under DOE's AEA authority and 

releases are in compliance with the applicable order(s), these releases also 

are federally permitted. The Department of Defense issues regulations 

governing weapons and reactors within their jurisdiction; releases in 

compliance with these regulations are federally permitted. 

Regulations issued by the Nuclear Regulatory Commission specifically 

exempt certain facilities from the Commission's licensing, permitting, and 

regulatory requirements. Because of this specific exemption, the Agency does 

not consider releases of radionuclides from these facilities to be "federally 

permitted." Such releases, therefore, would not fall under the reporting 

exemption defined in section 101(10)(K) of CERCLA. 

Other aspects of the federally permitted release exemption also could 

apply in the case of radionuclides. The exemption generally covers discharges 

and emissions in compliance with permits and control regulations under 

specific environmental statutes listed in section 101(10) of CERCLA. 

Emissions covered under this exemption include those regulated by sections 111 

and 112 of the Clean Air Act (CAA) and State Implementation Plans (SIPs). 

Radionuclides, for example, are regulated by EPA as a hazardous air pollutant 

under section 112 of the CAA. Any radionuclide release subject to and in 

compliance with a permit or control regulation established under that section 

would be exempt as federally permitted, if the permit or control regulation is 

specifically designed to limit or eliminate such a release. If the release, 

however, exceeded the permitted level by an RQ or more, the release would be 

subject to the CERCLA notification requirements. 

1-6 
P.16 

In addition to the statutory exemptions from the RQ notification 

requirements for releases of hazardous substances, section 103(f)(2) of the 

Act provides a reduced reporting requirement for releases that are 

"continuous" and "stable in quantity and rate." Such releases only need to be 

reported annually and when there is a statistically significant increase in 

the quantity of the hazardous substance released. 

1.5 FACILITIES AFFECTED BY FINAL RQ ADJUSTMENTS 

Some facilities that use or produce large amounts of radionuclides are 

regulated by a federal agency (e.g., Department of Energy or Nuclear 

Regulatory Commission) or by Agreement States. Other facilities, particularly 

those that use small quantities of radionuclides or that use naturally 

occurring or accelerator-produced radioactive material (NARM), are not 

federally regulated. All of these facilities must comply with CERCLA 

notification requirements and thus the final RQ adjustments may affect all of 

these facilities either by increasing or decreasing the number of reportable 

releases. SARA's Title III provisions require that the appropriate State 

Emergency Response Commission (SERC) and Local Emergency Planning Committee 

(LEPC) also receive reports of releases of hazardous substances that equal or 

exceed the RQs established under CERCLA, and the final regulation, therefore, 

will affect the number of these reports that will be submitted. 

Appendix A of this report provides detail on the approximately 956,100 

facilities that potentially could release radionuclides. These facilities 

include the following: 

Nuclear Regulatory Commission licensees - 8,900; 

Agreement State licensees - 13,000; 

Department of Energy facility complexes - 78; 

Coal mines - 4,100; 

Coal-fired utility boilers - 514; 

Coal-fired industrial boilers - 51,187; 

Unlicensed laboratories - 700; 

Low-energy accelerators - 1,500; 

Uranium mines - 181; 

Aluminum smelters and bauxite mines - 44; 

Copper mines and smelters - 76; 

Zinc mines and smelters - 41; 

Lead smelters/refineries - 5; 

Elemental phosphorus plants - 6; 

Phosphate rock plants - 35; 

Wet process fertilizer plants - 35; 

Iron mines/smelters - 68+; 

Fluorospar mines - 15; 

Clay extraction facilities - 1,317; 

Limestone extraction facilities - 2,900; 

Geothermal energy plants - 20; 

Oil & Gas Production Facilities - 869,406; and 

Natural Gas-fired Boilers - 2,005 

1-7 
P.17 

This list of facilities may not cover completely all types of activities 

that release or could cause the release of radionuclides. Other types of 

activities also may result in the release of radionuclides to the environment, 

but most likely of a magnitude not relevant to the final RQ adjustments. 

The Atomic Energy Act of 1954 (AEA) gives the Nuclear Regulatory 

Commission the authority to regulate source, byproduct, and special nuclear 

materials. The Nuclear Regulatory Commission has delegated the,authority to 

regulate these same materials to states that enter into an agreement with the 

Commission. The regulations in these so-called Agreement States must be at 

least as stringent as those of the Nuclear Regulatory Commission. There are 

five primary types of facilities regulated by the Commission and Agreement 

States: (1) power reactors; (2) research and test reactors; (3) radiopharmaceutical suppliers; (4) radiation source manufacturers; and (5) other 

facilities including laboratories, waste disposal sites, mineral and metal 

processing facilities, fuel cycle facilities, and uranium milling. 

The Nuclear Regulatory Commission also licenses some Department of 

Defense facilities, specifically research facilities and naval shipyards that 

service nuclear-powered ships. The armed forces operate several research 

reactors and a linear accelerator, mainly to research the effects of nuclear 

radiation on human health and on electronics. In addition, nine naval 

shipyards involved in the construction, testing, refueling, and maintaining of 

nuclear-powered ships are licensed. 

The Department of Energy (DOE) also regulates facilities that use 

radionuclides. There are 78 DOE complexes; approximately 47 of these 

complexes actively use radionuclides. These complexes range in size from 

single structures to sites that include several hundred individual facilities, 

such as Hanford, Washington. 

Although uranium mines and elemental phosphorus plants are not licensed 

by the Nuclear Regulatory Commission, Agreement States, or DOE, EPA analyzed 

radionuclide air emissions from these industries and found uranium mines and 

elemental phosphorus plants to emit some radionuclides at controllable levels. 

These air emissions from uranium mines and elemental phosphorus plants, 

therefore, are controlled under section 112 of the Clean Air Act. Releases in 

compliance with section 112 limitations are 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. Releases of these radionuclides to other media and releases of 

other radionuclides to all media are not federally permitted and must be 

reported if they meet or exceed the relevant RQs. 

Other types of radionuclide releases also may be affected by the final RQ 

adjustments. Radionuclide releases due to contamination of sludge may be 

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

Supreme Court ruled in Train vs. Colorado Public Interest Research Group, 426 

U.S. 1 (1976) that, in the context of releases to water, "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 

1-8 
P.18 

(naturally occurring and accelerator produced 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. Water releases of radionuclides, therefore, may or may not be 

federally permitted under section 101(10) of CERCLA. 

The Nuclear Regulatory Commission does not have authority to regulate 

certain types of radionuclides, including naturally occurring and accelerator 

produced radioactive materials (NARM). The AEA also provides the Commission 

the authority to exclude from regulation facilities that the Commission 

determines do not warrant regulation. The Commission and Agreement States do 

not license facilities, for example, when they handle radionuclides in 

sufficiently small quantities. There are approximately 700 unlicensed 

laboratories and 1,500 low-energy accelerators that use radionuclides. 

Because the quantity levels that trigger licensing generally are below the 

final RQ levels, it is unlikely that these facilities would ever release 

radionuclides at levels that equal of exceed an RQ (except perhaps for NARM). 

The remaining facilities that potentially could release radionuclides 

include coal-fired utility and industrial boilers, unlicensed laboratories, 

low-energy accelerators, and mineral, energy, and metal extraction facilities. 

There are three main sources of radionuclide releases at these facilities: 

(1) the dumping of large volumes of low activity material outside a building; 

(2) emissions from stockpiles or from work-in-process materials; and (3) 

smokestack emissions. Because these releases result from large quantities of 

low activity material, they are unlikely to be episodic in nature. Rather, 

these releases are expected to be continuous and stable in quantity and rate. 

These releases may be reported, therefore, under the continuous release 

reporting requirements under CERCLA section 103(f)(2). 

With the exception of coal-fired boilers, EPA has limited information 

available to determine the number of these facilities likely to be releasing 

an RQ or more on a continuous basis and to assess the risks posed by releases 

to the environment from large area or volume sources. The information that is 

available suggests that some releases from these sources may exceed an RQ on a 

daily basis, and thus, these releases would have to be reported under CERCLA. 

Of the facilities without federal permits that are potentially releasing 

radionuclides, 2,710 are estimated to meet or exceed an RQ on a regular (i.e., 

daily) basis. (Appendix A provides a detailed description and estimate of the 

number of facilities likely to meet or exceed an RQ.) Excluding facilities 

with coal-fired boilers, approximately 1,000 facilities are likely to 

continuously release radionuclides above the RQ. 

EPA has examined in detail releases from coal-fired utility and 

industrial boilers, which comprise the overwhelming majority of facilities 

likely to meet or exceed a radionuclide RQ on a regular basis and, thus, to 

report under the continuous release reporting provisions of section 103(f)(2). 

(Appendix B provides a detailed estimation of the number of facilities with 

coal-fired boilers likely to be affected by the regulation.) 

1-9 
P.19 

1.6 ORGANIZATION OF THIS REPORT 

This report analyzes the economic impacts of the final RQ adjustments for 

radionuclides. The remainder of this report is organized as follows: 

Chapter 2: Baseline Reportable Episodic Releases --an analysis of 

baseline (pre-regulatory) episodic reportable releases, 

including a discussion of available release data, size and 

frequency distribution of releases, and the estimated 

number of baseline reportable releases; 

Chapter 3: Unit Costs Associated with Reportable Episodic 

Radionuclide Releases --an explanation of the unit values 

used to estimate the incremental costs of the final 

regulation; 

Chapter 4: Estimated Annual Costs of the Final RQ Adjustments --an 

analysis of the additional costs that the regulated 

community and the government will incur as a result of the 

final regulation; 

Chapter 5: Sensitivity Analysis -- a test of the assumptions used 

throughout this report to determine the sensitivity of the 

results to various assumptions; 

Appendix A: Profiles of Facilities that Release Radionuclides --a 

discussion of the types and number of facilities that 

potentially release radionuclides and an estimate of the 

number of facilities likely to be required to report 

continuous releases under section 103(f)(2); and 

Appendix B: Estimate of the Number of Facilities with Coal-fired 

Boilers Expected to Report Releases Under Section 

103(f)(2). 

1-10 
CHAPTER 2 

BASELINE REPORTABLE EPISODIC RELEASES 

A regulatory baseline is the starting point for any Economic Impact 

Analysis (EIA). The baseline provides a measure of the estimated costs that 

the affected community and government would incur if a regulation were not to 

take effect. Estimates of post-regulatory costs that society incurs can be 

measured once the baseline is estimated, and the difference between the postregulation costs and the baseline costs is the incremental cost of the final 

regulation. 

The baseline costs in this EIA are a function of the number of reportable 

radionuclide releases that equal or exceed CERCLA's statutory RQ of one pound. 

The baseline costs represent the value placed on the actions of a responsible 

party and the federal government as a result of a radionuclide release that 

equals or exceeds the RQ (i.e., one pound), and the value placed on actions of 

State Emergency Response Commissions (SERCs) and Local Emergency Planning 

Committees (LEPCs) because such radionuclide releases are also reportable to 

SERCs and LEPCs under section 304 of Title III of the Superfund Amendments and 

Reauthorization Act of 1986 (SARA). This chapter estimates the number of 

radionuclide releases that are reportable in the baseline. 

The baseline estimates presented in this chapter represent estimates of 

radionuclide release events, or episodic releases, as opposed to "continuous" 

releases from radioactive material such as stockpiles of coal or ore 

materials. This is an important distinction because although radionuclide 

releases that occur in a manner that is "continuous" and "stable in quantity 

and rate" are also subject to CERCLA notification and liability provisions, 

section 103(f)(2) of CERCLA provides for reporting relief for facilities with 

"continuous" and "stable" releases. The required reporting regime may be 

quite different for facilities with "continuous" releases of radionuclides 

that equal or exceed the RQ, as opposed to the reporting regime required for 

facilities that experience episodic radionuclide releases. The potential 

burden on facilities with "continuous" radionuclide releases is described more 

fully in Chapter 4 of the EIA. 

Section 2.1 of this chapter describes the methodology used to derive the 

number of baseline reportable episodic releases. Sections 2.2, 2.3, and 2.4 

describe the parameters of the methodology that are required to estimate the 

number of baseline reportable releases; and Section 2.5 presents the results 

of the analysis, an estimate of the number of baseline reportable releases. 

2.1 METHODOLOGY TO ESTIMATE THE NUMBER OF BASELINE REPORTABLE RELEASES 

Baseline reportable episodic releases are the number of episodic releases 

(e.g., spills or events) that would need to be reported to the National 

Response Center and to SERCs and LEPCs if the final radionuclide RQ 

adjustments were not to take effect and the RQ remained at 1 pound for all 

radionuclides. The methodology that is used in this analysis to estimate the 

number of baseline reportable releases is based on several important 

assumptions. These assumptions, shown in Exhibit 2-1 and discussed more fully 
P.21 

EXHIBIT 2-1 

ASSUMPTIONS USED TO ESTIMATE BASELINE 

REPORTABLE RELEASES 

The number of baseline reportable releases can be estimated from the 

following equation: 

BASELINE REPORTABLE RELEASES = A * S [Bi * CJ 

where A is the total number of radionuclide releases that occur 

irrespective of the size of the release; Bi is the probability that 

a release will be a particular radionuclide i; and CL is the 

probability that any radionuclide is released in a quantity that 

equals or exceeds the RQ for radionuclide i. 

There is no significant relationship between the identity of a 

radionuclide released and the mean size of a radionuclide release. 

Historical release reports from the Nuclear Regulatory Commission's 

Office of Analysis and Evaluation of Operational Data (AEOD) are 

relatively complete for use in deriving the annual number of 

releases per facility from Commission and Agreement State licensees 

and DOE facilities; under-reporting in the AEOD is no more than 

twenty percent. 

There are approximately 47 active DOE complexes that use and could 

release radionuclides. At each of these complexes, there are 

approximately 10 facilities that release radionuclides in a manner 

similar to those facilities that reported releases to the AEOD. 

Facilities subject to radionuclide release limitations established 

pursuant to the Clean Air Act are in compliance with those 

limitations. 

The historical frequency of reported radionuclide releases 

represents accurately the likelihood of future releases of that 

radionuclide. 

The historical size distribution of reported radionuclide releases 

represents accurately the future size distribution of radionuclide 

releases. 

Federally permitted releases are equivalent to releases that equal 

the RQ levels established by the final regulation. 

2-2 
throughout this chapter, are necessary because no data are available that 

permits the direct calculation of the number of radionuclide releases that 

equal or exceed the baseline RQ. 

The methodology used to estimate the number of reportable radionuclide 

releases in the baseline is based on the use of historical radionuclide 

release data and the assumption that radionuclides reported released in the 

past fairly represent future release events. This approach is subject to 

criticism in that the RQ adjustment rulemaking is lowering the reporting 

triggers for the vast majority of radionuclides and if this analysis attempted 

to project future release events based solely on historical releases reported 

to the National Response Center it would surely underestimate the number of 

releases reportable at the lower RQs. Because radionuclides were not required 

to be reported to the National Response Center if the release did not exceed 

one pound (the statutory RQ), few smaller releases would have been reported 

historically to the National Response Center.1 

Facilities that produce or use radionuclides in any significant quantity 

are highly regulated, however, by the Nuclear Regulatory Commission, the 

Department of Energy (DOE), and EPA. As such, radionuclide release data are 

collected routinely from many facilities, and facilities are encouraged to 

report radionuclide releases regardless of the release quantity. It is 

believed, therefore, that a data base can be developed that fairly represents 

the vast majority of radionuclide release events, and that this data base can 

be used to estimate reportable radionuclide releases under the baseline (one 

pound) RQ and under the lower adjusted RQs in EPA's final rule. 

The methodology used to estimate the reporting burden as a result of the 

radionuclide RQ adjustments relies on a unified data base of radionuclide 

release information derived from four different sources, including the Nuclear 

Regulatory Commission, DOE, the Department of Transportation (DOT), and EPA. 

The frequency with which each radionuclide is reported in the unified data 

base is assumed in this analysis to be a fair representation of the likelihood 

that the particular radionuclide will be released in the future. It is also 

used to derive an independent estimate of the probability that the release 

event will be reportable either in the baseline or after the radionuclide RQs 

are adjusted. Hence, the unified data base is used to derive the probability 

that a particular radionuclide will be involved in a reportable release event 

in the future. 

The methodology used in this analysis estimates three separate 

parameters, and then combines the parameters to estimate the number of 

baseline reportable episodic releases. Specifically, the number of baseline 

reportable releases can be calculated from the following equation: 

1 A notable exception is for releases of radionuclides that occur during 

a transportation incident; there is no minimum reportable quantity for such 

releases. 

2-3 
P.23 

BASELINE REPORTABLE RELEASES - (A) * 2 [Bi * Ci] where 

A is the Total annual number of episodic radionuclide releases, 

irrespective of the size of the release; 

Bi* is the Probability that the release is of a particular 

radionuclide i, given that a radionuclide 

release occurs; and 

C± is the Probability that a particular radionuclide 

release equals or exceeds the RQ for 

radionuclide i. 

This equation results in the following relationship for any radionuclide 

(i). Assuming that a radionuclide release occurs, the product of B± * CL is 

the probability that a particular radionuclide was released and that the 

release equals or exceeds one pound2 (i.e., was reportable in the baseline). 

The sum of the products is the aggregate sum of the probabilities, and is the 

probability that, given that a radionuclide release has occurred, the release 

was reportable. Multiplying this aggregate probability by (A), the average 

annual number of radionuclide releases that occur, produces the number of 

annual radionuclide releases equal to or greater than the baseline RQ (i.e., 

one pound). 

An implicit assumption in using this methodology is that there is no 

significant relationship between Factor B, the probability that a radionuclide 

will be released, and Factor C, the probability that a release is a certain 

size. The assumed independence of these probabilities enables a meaningful 

product, that is, Bi * Ci. This product can be interpreted to be the 

probability that a particular radionuclide will be released in quantities that 

equal or exceed its RQ. When the sum of these probabilities is multiplied by 

Factor A, the total annual number of radionuclide releases, the final answer 

represents the number of radionuclides that will be released annually that 

equal or exceed their RQ. 

The three factors in this equation are derived from one of two sources of 

information. Factor A, the total annual number of radionuclide releases, is 

derived from release reports to the Nuclear Regulatory Commission's Office for 

Analysis and Evaluation of Operational Data. This derivation, and the 

assumptions on which it is based, are explained in section 2.2. The remaining 

two factors, Factor B (the probability that a particular radionuclide is 

released) and Factor C (the probability that a release equals or exceeds a 

specific quantity) are derived from a unified data base of historical release 

2 For any given radionuclide, a pound translates into a different number 

of curies. Because radionuclide release data generally are in units of 

curies, quantity released during each release event must be translated into 

pounds to determine if the one pound RQ was exceeded. Alternatively, the one 

pound RQ for radionuclides must be translated into a different number of 

curies for each radionuclide to compare the released quantity with the curieequivalent of one pound. 

2-4 
P.24 

reports. The sources and characteristics of this unified data base, and the 

assumptions on which the derivation of these factors is based, are described 

in sections 2.3 and 2.4 of this chapter. 

2.2 DERIVATION OF TOTAL ANNUAL NUMBER OF RADIONUCLIDE RELEASES (FACTOR A) 

The total annual number of episodic radionuclide releases that occur is 

related to the number of facilities that use radionuclides, the amount of 

radionuclides handled at these facilities, and the manner in which 

radionuclides are handled at these facilities. There are several types of 

facilities that could release radionuclides. These facilities vary 

considerably in the type and quantity of radionuclides that could be released, 

and the frequency with which releases could occur. As described in Chapter 1 

of this report, most facilities that use or produce radionuclides in any 

significant quantity are licensed by the Nuclear Regulatory Commission or by 

an Agreement State. Facilities controlled by DOE also could potentially 

release a significant amount of radionuclides. Other types of facilities, 

such as mines and facilities that process minerals and metals, also could 

release radionuclides even though they are not licensed by the Commission or 

by an Agreement State. 

Six sources of radionuclide release data were identified during this 

analysis. These data sources are described in the next section of this 

chapter. • No one data source, however, provides a complete record of all 

radionuclide releases that have occurred, nor does the combination of thesesix sources provide a complete record. In addition, some of the data sources 

include reports from many different types of facilities; they generally do not 

present a complete picture of the number of releases that occur from any 

particular type of facility. One data set, however, does provide a relatively 

complete record of most of the releases that occur from the 8,900 facilities 

licensed by the Nuclear Regulatory Commission. The Commission's reporting 

requirements are stringent and require licensees to report immediately to its 

Office for Analysis and Evaluation of Operational Data (AEOD) losses, thefts, 

and releases that may have caused or threaten to cause certain dose levels to 

individuals. AEOD maintains complete records of the releases that are 

reported. The AEOD data, therefore, are used to estimate the average number 

of releases per Commission licensee. 

For purposes of this analysis, the estimated number of releases per 

Commission licensee is assumed to be identical to the number of potential 

releases per Agreement State licensee and the number of releases per DOE 

facility. It is further assumed that Commission licensees, Agreement State 

licensees, and DOE facilities comprise the entire universe of facilities 

likely to release reportable quantities of radionuclides during an episodic 

event.3 

3 An episodic event is used here in contrast to those radionuclide 

releases that occur in a manner that is "continuous" and "stable in quality 

and rate", and therefore could be reported under CERCLA section 103(f)(2). 

2-5 
P.25 

Agreement State licensees are expected to be no different from Commission 

licensees. They must, at a minimum, meet the release limitations established 

in 10 CFR Part 20, and they represent similar types of facilities (i.e., 

reactors, larger laboratories, etc.). Although DOE facilities are, generally, 

very different from Commission licensees in that they produce and use 

different radionuclides, perform different activities, and use different 

handling procedures, little data exist to develop an accurate characterization 

of radionuclide releases from DOE facilities. It is assumed, therefore, for 

purposes of this analysis, that radionuclide releases from DOE facilities 

follow a similar pattern to releases from Commission licensees. 

There are 78 complexes managed by DOE, 47 of which actively use 

radionuclides.4 DOE complexes, such as the one at Hanford, Washington, are 

comprised of many facilities (i.e., laboratories, reactors, etc.) that use 

radionuclides. For purposes of this analysis, an assumption is made that an 

average of 10 facilities within an active DOE complex use radionuclides and 

could release them in a pattern similar to releases from Commission licensees. 

This analysis assumes, therefore, that there are 470 DOE facilities (47 

complexes x 10 facilities per complex) similar to Commission licensees. The 

AEOD data, therefore, are assumed to be representative of releases from 

approximately 22,400 facilities (8,900 facilities licensed by the Nuclear 

Regulatory Commission; 13,000 facilities licensed by Agreement States; and 470 

facilities controlled by DOE), and that these 22,400 facilities comprise the 

universe of facilities that potentially could release radionuclides during an 

episodic event at levels that exceed the RQ. 

Estimated Number of Annual Radionuclide Episodic Releases in AEOD Data 

An estimate of the average number of episodic releases of radionuclides 

that occur annually from Commission licensees and, by analogy, from Agreement 

State licensees and DOE facilities, can be determined by analyzing the AEOD 

records. This analysis examined radionuclide release reports made to the AEOD 

from 1981 to 1985. These release events are not necessarily large, nor do 

they necessarily pose a danger to public health or welfare or the environment. 

They include all releases reported to the Nuclear Regulatory Commission over 

the last five years. 

The AEOD data are assumed to represent most episodic releases that occur 

from Commission licensees because reporting of an incident is relatively 

simple and because the nuclear industry is monitored closely and is highly 

sensitive, to public concerns. The data, however, requires some modification 

before it can be used to estimate the total number of radionuclide releases 

subject to CERCLA reporting requirements that occur from Commission licensees. 

For example, the AEOD data include transportation incidents. The Department 

of Transportation (DOT) requires that all releases of radionuclides that occur 

during transportation, regardless of the amount released, must be reported to 

the National Response Center (49 CFR 171.51(a)). Because of this DOT 

A The source of this information is an ICF estimate based on an 

examination of data in U.S. Environmental Protection Agency, Radionuclides 

Background Information for Final Rules. Volume II, October 1984. 

2-6 
P.26 

regulation, the number of reportable releases during transportation incidents 

will not be affected by the RQ adjustments; all radionuclide releases must be 

reported regardless of the quantity released. Transportation incidents, 

therefore, can be excluded from the data set. 

Another reason why it is not appropriate simply to use the average number 

of releases reported annually in the AEOD data set is that all of the releases 

reported to the AEOD may not be releases into the environment; only releases 

into the environment are reportable under CERCLA. Strict determinations of 

the number of "releases" in the AEOD data are difficult to make, however, 

because the reports generally lack detail. For example, it is sometimes 

difficult to determine from the information reported whether a radionuclide 

release was contained by a structure or whether the radionuclides escaped into 

the environment. Nonetheless, it is clear that some adjustment must be made 

to the AEOD data to eliminate reports of mislabeling and other "non-release" 

events. 

The final reason for screening the release events in the AEOD data is 

that it is likely that some facilities may not be reporting all release events 

to the AEOD, and the data most likely should be adjusted for potential underreporting. 

Two steps, therefore, are taken to estimate the number of releases likely 

to occur from Nuclear Regulatory Commission licensees. These steps are: 

(1) To define what is meant by a release event, adjust 

the data base accordingly, and determine an average 

annual number of historical release events for the 

8,900 Nuclear Regulatory Commission facilities; and 

(2) To estimate the potential number of future releases 

by adjusting the historical number for underreporting. 

To define a release event under CERCLA and to eliminate all non-release 

events from the AEOD data set, criteria were developed to categorize the 

releases in the AEOD data. These criteria are conservative in order to 

develop an upperbound estimate of the number of episodic release events likely 

to occur annually from these facilities. Approximately 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 if they exhibited the following 

characteristics: 

• 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 was the abandonment of 

sources in drilling holes. Because the sources are 

2-7 
P.27 

not recoverable, EPA considers all such events to be 

a release 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 were considered events involving 

releases to the environment. They were classifed as 

transportation releases, however, only when escape or 

leakage of radioactive materials was evident to 

shipping personnel and reported by them. A spill of 

material on a highway, for example, was considered a 

transportation release. Damage, loss, or 

contamination of a package during shipping that was 

not clearly evident to shipping personnel, however, 

was assumed to be a nontransportation release. For 

example, if a package was received damaged, and the 

report does not state that the shipping agent was 

aware of the damage and actually had reported the 

incident, the report was considered a 

nontransportation release. 

• • Reports of high stack concentrations and radiation in 

unrestricted areas (approximately 15 percent of all 

reports) -- Citations of high concentration, of 

radioactive material in exhaust stacks and airborne 

radiation in unrestricted areas were classified as 

releases to the environment. That is, if reports did 

not specify the location of airborne radioactive 

materials, it was assumed 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) were 

treated as if they were confirmed releases to the 

environment. 

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

Citation of a fire was considered evidence of a 

release except where a report indicated specifically 

that no contamination occurred. 

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

• Reports of leaking sources -- Although it was not 

always possible to determine whether the reported 

leak occurred in a secure enclosure, events such as 

these were not classified as releases to the 

environment. 

2-8 
P.28 

• Reports of positive radioactive 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 reflected exposure to 

radioactivity, this analysis assumed exposure 

occurred in a contained structure. Badge exposure 

therefore was not classified as a release to the 

environment. 

• Report of loose packaging -- Reports of loose or 

improper packaging used for purposes of transport 

were not considered evidence of a release. The 

observed escape of liquid or solid material from 

packaging, however, was assumed to be a release to 

the environment. 

Based on these criteria, the examination of releases in the AEOD data 

produced a count of the number of "release events" that occurred during each 

of the last five years. A "release event" was defined to be a release to the 

environment. The number of these release events reported to AEOD is shown in 

Exhibit 2-2. Subtracted from the number of release events that occurred each 

year is the number of transportation releases that were included in the AEOD 

data. This is done because the number of reportable transportation releases 

will not be affected by the RQ adjustments and, therefore, were excluded from 

this analysis. These adjustments, also shown in Exhibit 2-2, produce an 

estimate of the average number of release events in each of the last five 

years that are consistent with the purposes of this analysis. 

Adjustment of the AEOD data produces an estimate that an average of 

approximately 80 episodic release events have occurred annually and have been 

reported during each of the last five years by the 8,900 Nuclear Regulatory 

Commission licensees. This number of release events, however, still must be 

adjusted for any under-reporting of releases that may have occurred. 

There are no data on the amount of under-reporting that occurs annually. 

Because Commission licensees are highly regulated and very sensitive to public 

concerns regarding radiation, however, the assumption was made that 80 percent 

of all releases, irrespective of size, were reported. The estimate of the 

degree of "under-reporting" is not assumed to be lower because there will 

always be some releases that are not reported; this analysis was trying to be 

reasonably conservative in its estimation procedures. 

It is important to note that although the term "under-reporting" is used, 

it is not meant to imply that the unreported releases represent any level of 

noncompliance with existing reporting requirements. This analysis is 

attempting to estimate the number of radionuclide releases that occur 

annually, regardless of the quantity released; it is very likely that small 

releases well within the license limitations are not reported. The 20 percent 

2-9 
P.29 

EXHIBIT 2-2 

PROFILE OF EPISODIC RELEASES IN 

NUCLEAR REGULATORY COMMISSION AEOD DATA SET 

Year 

1981 

1982 

1983 

1984 

1985 

Annual Averageb 

Total Number 

Ep 

of 

Lsodic Release 

Events3 

103 

82 

103 

92 

83 

93 

Total Number of 

Transportation 

Releases 

7 

5 

8 

3 

9 

6 

Total Number 

of Nontransportation 

Episodic Releases from 

Agreement 

States 

2 I-I 8 

3 

15 

6 

Commission 

States 

94 

76 

87 

86 

59 

80 

a An episodic "release event" is defined as an event where radionuclides are 

released into the environment. It often is difficult to determine from the 

information in the reports whether a release to the environment actually 

occurred. When in doubt, the event was assumed to result in a release to the 

environment. The releases represented in this exhibit are not necessarily 

reportable under either the one-pound RQ or the final adjusted RQs. In 

addition, not all events reported in the AEOD data are represented in this 

exhibit; events that were not considered to be releases have been excluded 

from the exhibit. These excluded events include, for example, reports of 

failure to submit monitoring data and incorrect labels on containers. 

b Numbers may not add due to rounding. 

2-10 
P.30 

"under-reporting" adjustment includes these small, licensed releases, as well 

as any other releases that were not reported in the past. The effect on the 

results of the under-reporting assumption is tested in Chapter 5. 

Based on the assumption of 80 percent reporting, and given the estimate 

that an average of 80 annual release events have been reported to the AEOD 

during each of the last five years, this analysis assumes that there have been 

approximately 100 release events that occur from the 8,900 Nuclear Regulatory 

Commission licensees during each of the last five years. If 100 releases 

could occur from 8,900 facilities, it is assumed that approximately 250 

releases could occur from 22,400 facilities (i.e., Commission licensees, 

Agreement State licensees, and DOE facilities). 

To summarize: 

• The AEOD data, after adjustment of reported events to 

eliminate transportation incidents and all events 

that did not reflect "releases to the environment," 

show about 80 releases to the environment annually 

(see Exhibit 2-2). 

• There is probably some under-reporting that occurs 

because the purposes of this estimation process is to 

estimate the total number of releases that occur 

annually, irrespective of the amount released; annual 

release events were adjusted upward to 100 releases, 

reflecting an assumed 20 percent under-reporting. 

• Only 8,900 facilities are required to submit reports 

to AEOD; approximately 22,400 facilities are assumed 

to release radionuclides in a pattern similar to 

Commission licensees. 

• If 100 releases could occur from a universe of 8,900 

facilities, 250 releases could occur annually from 

22,400 facilities. 

This is a gross estimate of the number of episodic releases that can 

occur annually. Because the 22,400 facilities that are assumed to release 

radionuclides are not homogeneous, they cannot be expected to have uniform 

release patterns. Instead, they are likely to release different radionuclides 

with different propensities. This estimate is believed to be an upperbound 

estimate of the number of episodic radionuclide releases that could occur 

annually, although not all facilities that potentially could release 

radionuclides have been included in this estimation procedure. In particular, 

facilities that use naturally occurring and accelerator produced radioactive 

material (NARM) have not been included in this estimate because there is 

limited information about their radionuclide releases. These facilities are 

discussed more fully in Chapter 4 of this report. 

2-11 
P.31 

2.3 DERIVATION OF RADIONUCLIDE RELEASE PROBABILITY 

The estimated 250 annual episodic radionuclide releases from facilities 

include some releases that potentially equal or exceed the statutory one-pound 

RQ, and thus some that are baseline reportable releases. The 250 releases 

also include some releases that are smaller than 1 pound, and thus that are 

not reportable under the baseline. To estimate the number of the annual 

releases that equal or exceed 1 pound, estimates of the probability that a 

particular radionuclide will be released (Factor Bi) , and the probability that 

the release equals or exceeds 1 pound (Factor Ci) must be developed. 

As was the case with the derivation of Factor A, there is no single data 

source that allows the direct calculation of these probabilities. Several 

data sources can be combined, however, to provide some indication of the 

radionuclides that have been released in the past and the size of those 

releases. Of course, historical evidence is not necessarily indicative of the 

identity and size of future releases; technological innovations occur and 

processes change that can alter the pattern of radionuclide releases. For 

purposes of this analysis, however, the assumption is made that the 

probability that a particular radionuclide will be released in the future, and 

the probability that the release will equal or exceed an RQ, can be estimated 

based on the characteristics of historical radionuclide releases. 

Available Data Sources on Historical Radionuclide Releases 

A unified data base was assembled for this analysis that incorporates 

release reports 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 

Alburquerque, New Mexico, 1971 through 1985; 

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

Environment and Health, Emergency Operations Center 

(EOC), March, 1983 through April, 1986; 

• Reports to the National Response Center, 1982 through 

1985; 

• Reports to EPA's Office of Radiation Programs (ORP), 

October, 1981 through September, 1983; and 

• Reports to the Nuclear Regulatory Commission's 

Operations Center, January, 1983 through January, 

1986. 

The most complete of these six sources, both in terms of release 

descriptions and the population of release events included in the data, is the 

2-12 
P.32 

Nuclear Regulatory Commission's Office of Analysis and Evaluation of 

Operational Data (AEOD) incident reports. These reports usually contain 

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

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 the AEOD set. The TTC data are limited 

to transportation accidents or 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. 

The release data from the National Response Center do not contain 

detailed quantity information. Reports examined from the Nuclear Regulatory 

Commission's Operations Center include only events that the Nuclear Regulatory 

Commission defines as releases. The Commission's definition is narrower than 

CERCLA's definition of release. Releases from facilities in Agreement States 

are not represented in the Nuclear Regulatory Commission's data set, the 

Sandia National Laboratory data set, the DOE data set, or the EPA Office of 

Radiation Programs data set. It is possible that releases from Agreement 

States are represented in the data set from the National Response Center, but 

the data from this source are mostly qualitative and, for the most part, were 

not included in the unified EIA data base. 

Incident report duplication between the six sources appears to be 

relatively limited. Double counting of releases in the development of the 

unified EIA data base was avoided by cross-checking the details about 

particular release events. The incompleteness of the reports in some sets and 

the inconsis-tencies in the dates of the events, however, made this a 

complicated effort. It is likely that some duplicate counting exists despite 

efforts to prevent it. 

The unified EIA data base developed for this analysis includes 1,139 

release events. These releases range in size from 5.0 x IO"9 curie to 56,892 

curies. There are 455 events in the unified EIA data base with no quantity 

information or for which the units of curies could not be determined from 

available information. These 455 events are used only to estimate the 

frequency of release for particular radionuclides. There also are 23 events 

in the EIA data base that are not identified by radionuclide but do have 

information on the quantity released. These events were included in 

determining the size distribution but not in calculating the frequency of a 

radionuclide release. Exhibit 2-3 summarizes the characteristics of the 

unified EIA data base. 

Frequency Distribution of Releases of Radionuclides 

The unified EIA data base assembled for this analysis includes 

information on 63 unique radionuclides that were released during 1,139 release 

events. Because this analysis assumes that the probability of a future 

release of a radionuclide is no different from the frequency with which a 

particular radionuclide was released in the past, the probability of a future 

2-13 
P.33 

EXHIBIT 2-3 

CHARACTERISTICS OF THE UNIFIED RADIONUCLIDE DATA BASE 

Total Number of Release Events - 1,139 

Number of release events without 

quantity information - 455 

Number of release events with ' 1,139 

quantity information (used to | 

estimate size distribution) - 684 

Number of release events with 

radionuclide unidentified - 23 

Number of release events with i 1,139 

radionuclide identified (used 

to estimate release frequency) - 1,116 

Source: ICF Analysis. 

2-14 
P.34 

release of each radionuclide included in the unified data base is derived from 

the frequency of past reported releases for that particular radionuclide. 

Exhibit 2-4 displays the frequency distributions for each radionuclide in 

the unified EIA data base, (i.e., for each radionuclide that has been released 

at least once during the five years represented in the EIA data base). For 

example, Uranium-238 (U-238) was involved in 129 of the 1,116 events with 

identified radionuclides in the unified data base.5 Therefore, based on the 

assumption that the frequency of past releases of a radionuclide is indicative 

of the probability of its future release, this analysis estimated that, given 

that a radionuclide release occurs, the probability is 0.115 (129/1,116) that 

the radionuclide will be Uranium-238. 

The release frequencies shown in Exhibit 2-4 were used to estimate the 

probability that a particular radionuclide will be released in the future. 

Another example is Iodine-129, reported in the unified data base to be 

released only once in the 1,116 release events that identify the radionuclide 

released. This analysis assumes that the probability of a release of Iodine129 in the future is 0.0009 (1/1116). 

For purposes of this analysis, radionuclides that are not represented in 

the unified data base (i.e., those that have not been reported released in the 

five year period represented by the data base) are assumed to have a zero 

probability of being released in the future. This is, of course, a 

simplifying assumption because no data base of historical releases can 

perfectly reflect future releases. The unified data base, however, is 

believed to be a reasonable representation of the types and quantities of 

radionuclides that will be released in the future. Some isotopes are more 

common and used more often by facilities than others and, therefore, are more 

likely to be released than radionuclides that are used less frequently. Many 

radionuclides are created in laboratories and may exist for only a few 

seconds; others have an extremely short half-life and may decay within 24 

hours. Therefore, although only 63 unique radionuclides are identified in the 

unified data base, it is believed that the historical release frequencies 

shown in Exhibit 2-4 are a reasonable approximation for the probability of a 

release in the future of a particular radionuclide. 

2.4 SIZE DISTRIBUTION OF RADIONUCLIDE RELEASES 

Factor B, derived in the last section of this analysis, is the 

probability that a particular radionuclide will be released. To determine 

whether a radionuclide release is reportable under the baseline, however, 

quantities released must be examined. 

The baseline RQ for radionuclides (i.e., 1 pound) is in mass units, 

although radionuclide releases generally are reported in activity levels 

(i.e., curies). In fact, curies are a much more common and appropriate unit 

5 Although there are a total of 1,139 release events in the data, only 

1,116 events included information sufficient to identify the radionuclide 

released. 

2-15 
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EXHIBIT 2-4 

FREQUENCY OF EPISODIC RELEASES FOR EACH RADIONUCLIDE 

IN THE UNIFIED EIA DATA BASE 

(Continued) 

Radionuclide 

Identity 

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 isotopes 

TOTAL 

Number of 1 

in Data Base 

1 

1 

2 r-i 9 

1 

1 

14 

17 

3 

9 

4 r-i 2 

4 r-i 

17 

2 

37 

12 

1 

2 

4 

18 

129 

15 

3 

116 

23 

139 

Frequency of Release 

(Factor B) 

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 

Source: ICF estimates. 

2-17 
P.37 

of measurement for radioactivity, and one pound of each radionuclide 

translates into a wide range of curie-equivalents. To determine if a release 

in the data base exceeds 1 pound, therefore, the curie-equivalent of 1 pound 

was derived for each radionuclide. The curie-eqivalent of 1 pound for each 

radionuclide is a function of a radionuclide's half-life and atomic mass. For 

example, 1 pound of Radium-226 is equal to 449. curies; 1 pound of Uranium-238 

is equal to 0.0002 curie. As a result of the different ranslations from one 

pound to units of curies, the probability that a particular radionuclide 

release will equal or exceed the 1 pound RQ was estimated individually for 

each radionuclide. 

Only 684 events in the data base have information about the quantity 

released. A summary of the size distribution of these 684 events is shown in 

Exhibit 2-5. An analysis of the data shows that they are skewed, reflecting a 

much higher probability of a small release and a small probability of a large 

release. A logarithmic analysis of 684 release events produces a log normal 

distribution, with a mean of 0.15 curie and a standard deviation of 2.7 

curies. The log normal distribution of the data illustrates that most of the 

releases are small. Exhibit 2-5 shows that 280 of 684 release events, or 

approximately 41 percent, were at least 1 curie in size. The exhibit also 

shows that only 7 of the 684 release events in the five-year period equalled 

or exceeded 1000 curies. 

This analysis assumed that the historical frequency with which a 

radionuclide release occurred at a given quantity is a good approximation of 

the probability that a future radionuclide release also will occur at that 

quantity. For example, 280 of the 684 releases in the data base were at least 

1 curie; this analysis assumed that the probability that a future radionuclide 

release will be at least 1 curie is 0.409 (280/684). Similarly, because only 

7 of the 684 release events in the data base were 1,000 curies or greater, 

this analysis assumed that the probability that a future radionuclide release 

will be 1,000 curies or more is 0.010 (7/684). 

Thus far, it has been assumed that Factor B and Factor C are independent 

and that the probability that a reportable radionuclide release occurs can be 

determined by the product of Factor B and Factor C. An analysis of the 

correlation between Factor B and Factor C in the unified data base was 

conducted to test the validity of this assumption. Although the results of 

the statistical test were not conclusive (see Chapter 5 for details), there 

was sufficient support for the assumption that Factor B and Factor C are not 

2-18 
P.38 

EXHIBIT 2-5 

SIZE DISTRIBUTION OF RADIONUCLIDE RELEASES 

IN THE EIA DATA BASE 

Quantity 

(Curies) 

Number of Releases 

in Data Base that 

Equals or Exceeds Quantity 

Probability that any Release 

Will Equal or Exceed 

Quantity3 

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 

a Derived by dividing 684 into the number of releases in the unified data 

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

releases with quantity information in the unified data base. 

Source: ICF analysis. 

DATA BASE RELEASE QUANTITY DISTRIBUTION 

400 

u 

z 

Id 

e 

5 

u 

8 

u. 

O 

c 

-I i 

_ 

350 -

300 -

250 -

200 -

150 -

100 -

50 -

i.-a 30 40 50 ao 

ROEASC QUANTITY (Cl) 

70 90 100 >100 

2-19 
correlated and thus are independent, and that the number of reportable 

radionuclide releases can be estimated by multiplying the two factors.6 

2.5 BASELINE REPORTABLE EPISODIC RELEASES 

Section 2.1 of this report presented the methodology for deriving the 

three factors necessary to calculate the number of baseline reportable 

episodic releases. Section 2.2 estimated Factor A (i.e., 250 radionuclide 

releases, occur annually); Section 2.3 derived estimates for Factor B (i.e., 

the probability that a particular radionuclide will be released); and Section 

2.4 derived estimates for Factor C (i.e., the probability that the release 

will equal or exceed a given quantity). This section combines these three 

factors and estimates the number of baseline reportable episodic releases. 

There is one additional factor, however, that must be considered before 

estimating the number of baseline reportable release's. Because some 

facilities are licensed and are allowed in their license to release certain 

quantities of radionuclides (i.e., federally permitted releases), this 

analysis must account for the amount of a release that is federally permitted, 

before calculating the number of baseline reportable releases. 

Section 101(10) of CERCLA defines federally permitted releases. Releases 

that are not in compliance with federally permitted release levels only need 

to be reported to the National Response Center and to state and local 

emergency response commissions if the release equals or exceeds the federally 

permitted level by an RQ or more. Therefore, in the baseline, reportable 

releases are those that are at least 1 pound above federally permitted levels. 

The federally permitted release level at any facility depends upon the 

specific release being controlled, and upon the relevant regulations (e.g., 10 

CFR Part 20 for the Nuclear Regulatory Commission licensees). Most federally 

permitted radionuclide releases are controlled through Nuclear Regulatory 

Commission or Agreement State licenses; the federally permitted release level 

for many facilities, therefore, is a 500 millirem whole body dose-equivalent 

for a maximum exposure to the general public. 

6The use of one size distribution is not the ideal methodology. To be 

sure, the release behavior of all radionuclides is not identical. Ideally, a 

separate size distribution of releases for each radionuclide should be 

developed. Given the paucity of the data available on radionuclide release 

events, however, the creation of one size distribution is not unreasonable. 

To test the sensitivity of our results to this assumption, however, the ElA 

data base was divided into two groups. The first group consisted of three 

radionuclides (Cs-137, Am 241, and Co-60) that are used commonly in large 

quantities and account for over one-third of the total number of release 

events in the data set. The second group was comprised of the remaining 60 

radionuclides in the data set. A unique size distribution of releases was 

calculated for each gorup. The analysis showed that the number of incremental 

reportable releases increased by 15 percent, a relatively small increase. 

Therefore, although use of one size distribution is a simplification, the 

effects on the results of the economic analysis appear to be minimal. 

2-20 
P.40 

The RQs are derived using exposure scenarios based on the number of 

curies that, if released into the environment over a 24-hour period, could 

result in a 500 millirem whole body dose-equivalent to an individual standing 

30 meters from the release point. Because the RQs are the quantities of 

radionuclides released, in curies, that could result in a 500 millirem 

exposure, and because 500 millirem is the exposure limitation to the general 

public for the Nuclear Regulatory Commission and Agreement State licensees, 

this analysis assumes that federally permitted release amounts are equivalent 

to * the RQs. 

This assumed equivalency between RQs and the federally permitted release 

levels is a simplification. EPA used conservative assumptions in developing 

RQs, and generally facilities can release more than an RQ without exceeding 

the 500 millirem exposure level to the general public. For example, the 

Agency used exposure models that assume an individual is located 30 meters 

from a release point and will maintain that position for 24 hours. Many 

facilities that potentially could release radionuclides (e.g., power reactors) 

have restricted zones; the general public often could be located 150 meters 

away. Thus, if a release of an RQ occurred from such a facility, it is 

unlikely that the general public would receive a 500 millirem whole body doseequivalent because they would be much farther away from the release point than 

30 meters. Similarly, the occupational exposure limitation under 10 CFR Part 

20 is 5 rem (10 times 500 millirem). The RQs are derived based on an exposure 

limit an1order of magnitude lower than the occupational exposure limits in 

Commission licenses. For purposes of this analysis, however, the RQs are 

assumed to equal the federally permitted level. Although this assumption is 

far from precise, it is a reasonable approximation for purposes of this 

analysis. However, it will tend to overestimate the number of reportable 

releases and, therefore, the costs and impacts of the radionuclide RQ 

adjustments. 

Given this assumption, therefore, under the baseline, radionuclide 

releases that equal or exceed the sum of one pound plus the final adjusted RQ 

for that radionuclide are reportable releases from facilities that hold 

federal permits; that is, baseline reportable releases are those releases that 

are at least 1 pound above "federally permitted" levels. 

Based on the methodology described in Section 2.1, estimates of the 

number of baseline reportable episodic releases can be derived for facilities 

licensed by the Nuclear Regulatory Commission, Agreement States, or DOE (i.e., 

reportable releases that are at least one pound above the federally permitted 

levels at these facilities). 

BASELINE REPORTABLE EPISODIC RELEASES = A * 2 [Bi * Ci] 

A is the Estimated total number of annual 

episodic releases (250), derived by 

assuming that the AEOD data base is 

representative of releases from 

Nuclear Regulatory Commission, 

Agreement State, and DOE facilities; 

2-21 
P.41 

Bi is the Probability that radionuclide i will 

be released, derived by assuming 

historical reported releases are 

representative of the probability that 

a future release of any radionuclide 

(i) will occur; and 

CA is the Probability that a radionuclide 

release is reportable, derived by 

assuming historical releases are 

representative of the probability that 

a future release equals or exceeds a 

given quantity. This given quantity 

is the sum of the curie-equivalent of 

one pound of each radionuclide (the 

statutory RQ) plus the final adjusted 

RQ, a proxy for the federally 

permitted release level. 

Given this methodology and the estimates for each of the three factors 

derived in this chapter, the number of baseline reportable episodic releases 

can be calculated. First, for each radionuclide, Factor B is multiplied by 

Factor C. For example, Cesium-137 has an estimated frequency of release of 

0.2016 because there were 225 reports in the unified EIA data base in which 

Cesium-137 was identified as the radionuclide that was released (see Exhibit 

2-4). It is assumed, therefore, that there is a twenty percent probability 

that Cesium-137 will be released in the future (Factor Bi) . The final RQ for 

Cesium-137 is 1 curie; 1 pound of Cesium-137 is equal to 3,940 curies (see 

Exhibit 2-6). Because federally permitted release levels are assumed in this 

analysis to equal the final adjusted RQ, a release of 1 pound above federally 

permitted levels for Cesium-137 is a release of 3,941 curies (3,940 curies + 1 

curie). There are 2 historical radionuclide releases reported in the unified 

EIA data base that equal or exceed 3,941 curies. This analysis assumes, 

therefore, that there is a 0.0029 (2/684) probability that the release will be 

at least 3,941 curies (Factor C). Multiplying Factor B for Cesium-137 by 

Factor C for Cesium-137 produces the probability, therefore, that a reportable 

release of Cesium-137 occurs. The estimated probability that a Cesium-137 

release will occur at levels that equal or exceed the RQ plus one pound is 

equal to 0.00058 (0.2016 x 0.0029). 

The calculation of the number of baseline reportable releases is shown in 

Exhibit 2-6. This exhibit shows for each radionuclide in the unified EIA data 

base, the probability that the radionuclide will be released in the future 

(Factor Bi) and the probability that a release equals or exceeds the baseline 

RQ for that radionuclide (Factor Ci). This product is then multiplied by the 

total number of annual radionuclide episodic releases (250), and summed across 

all radionuclides in the EIA data base. The exhibit shows the estimated 

number of baseline reportable releases; that is, the sum of the number of 

estimated reportable episodic releases for each radionuclide represents the 

total number of baseline reportable episodic releases from federally permitted 

facilities (i.e., Commission and Agreement State licensees, and DOE 

facilities). As shown on the second page of the exhibit, there are 19 

2-22 
EXHIBIT 2-6 

REPORTABLE BASELINE RADIONUCLIDE RELEASES ESTIMATED FROM THE UNIFIED EIA DATA BASE 

RADIONUCLIDE 

AM-241 

AM/BE 

AR-41 

BA-133 

C-14 

CA-45 

CD-109 

CE-141 

CM-244 

CO-57 

CO-58 

CO-60 • 

CR-51 

CS-131 

CS-134 

CS-137 

EU-152 

EU-154 

F-18 

FE-55 

FE-59 

6A-67 

GE-77 

H-3 

HG-197 

1-123 

1-125 

1-129 

1-131 

IN-111 

IR-192 

K-42 

KR-81 

KR-85 

MO-99 

NA-24 

NI-59 

NI-63 

OS-185 

OS-191 

P-32 

PB-210 

PB-212 

RQ 

(CURIES) 

0.01 

0.01 

10 

10 

10 

10 

1 

10 

0.01 

100 

10 

io 

1000 

1000 

1 

1 

10 

10 

1000 

100 

10 

100 

10 

100 

1000 

10 

0.01 

0.001 

0.01 

100 

10 

100 

1000 

1000 

100 

10 

100 

100 

10 

100 

0.1 

0.01 

10 

NUMBER OF 

CURIES PER 

POUND OF 

RADIONUCLIDE 

1.47E+03 

1.47E+03 

1.90E+10 

1.70E+05 

2.02E+03 

7.99E+06 

1.06E+05 

1.29E+07 

3.58E+04 

3.84E+06 

1.43E+07 

5.13E+05 

4.18E+07 

2.19E+10 

5.90E+05 

3.94E+04 

8.42E+04 

1.35E+05 

4.32E+10 

1.14E+06 

2.23E+07 

2.28E+09 

1.63E+09 

4.38E+06 

1.11E+08 

8.70E+08 

7.95E+06 

2.00E-04 

5.63E+07 

1.90E+08 

4.16E+06 

2.73E+09 

9.60E+00 

1.78E+05 

2.15E+08 

3.95E+09 

3.44E+01 

2.80E+04 

3.42E+06 

2.07E+07 

1.29E+08 

3.79E+04 

6.31E+08 

BASELINE 

REPORTABLE 

LEVEL 

(RQ + 1 POUND) 

1.47E+03 

1.47E+03 

1.90E+10 

1.70E+05 

2.02E+03 

7.99E+06 

1.06E+05 

1.29E+07 

3.58E+04 

3.84E+06 

1.43E+07 

5.13E+05 

4.18E+07 

2.19E+10 

5.90E+05 

3.94E+04 

8.42E+04 

1.35E+05 

4.32E+10 

1.14E+06 

2.23E+07 

2.28E+09 

1.63E+09 

4.38E+06 

1.11E+08 

8.70E+08 

7.95E+06 

2.00E-04 , 

5.-63E+07 

1.90E+08 

4.16E+06 

2.73E+09 

9.60E+00 

1.78E+05 

2.15E+08 * 

3.95E+09 

3.44E+01 

2.80E+04 

3.42E+06 

2.07E+07 

1.29E+08 

3.79E+04 

6.31E+08 

FREQUENCY OF 

RADIONUCLIDE 

RELEASE 

(FACTOR B) 

0.0995 

0.0251 

0.0009 

0.0054 

0.0090 

0.0027 

0.0009 

0.0018 

0.0018 

0.0054 

0.0018 

0.0609' 

0.0027 

0.0009 

0.0009 

0.2016 

0.0018 

0.0009 

0.0009 

0.0054 

0.0018 

0.0063 

0.0009 

0.0367 

0.0018 

0.0018 

0.0573 

0.0009 

0.0287 

0.0009 

0.0815 

0.0009 

0.0009 

0.0242 

0.0134 

0.0045 

0.0009 

0.0296 

0.0018 

0.0009 

0.0081 

0.0009 

0.0009 

FREQ. OF RELEASE 

ABOVE BASELINE 

REPORTABLE LEVEL 

(FACTOR C) 

0.0102 

0.0102 

0.0000 

0.0000 

0.0102 

0.0000 

0.0000 

0.0000 

0.0029 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0029 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.8319 

0.0000 

0.0000 

0.0000 

0.0000 

0.1871 

0.0000 

0.0000 

0.0000 

0.0512 

0.0029 

0.0000 

0.0000 

0.0000 

0.0029 

0.0000 

TOTAL NUMBER 

OF RADIONUCLIDE 

RELEASES 

(FACTOR A) 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

NUMBER 

OF BASELINE 

REPORTABLE RELEASES 

(A*B*C) 

0.25 

0.06 

0.00 

0.00 

0.02 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.15 * 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

0.17 

0.00 

0.00 I 

0.00 

0.00 

0.00 

0.00 

o.oo | 

0.00 

0.00 

0.02 

o.oo ! 

0.00 

0.00 

0.00 

0.00 

2-23 
P.43 

EXHIBIT 2-6 (continued) 

REPORTABLE BASELINE RADIONUCLIDE RELEASES ESTIMATED FROM THE UNIFIED EIA DATA BASE 

RADIONUCLIDE 

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 

RQ 

(CURIES) 

10 

0.01 

0.01 

0.01 

0.1 

1000 

1 

1 

10 

0.1 

10 

10 

0.001 

100 

1000 

10 

0.1 

0.1 

100 

10 

NUMBER OF 

CURIES PER 

POUND OF 

RADIONUCLIDE 

4.20E+05 

2.04E+06 

7.90E+03 

2.79E+01 

4.49E+02 

5.45E+10 

1.52E+06 

1.92E+09 

4.72E+05 

6.40E+04 

2.83E+06 

7.75E+00 

5.00E-05 

1.05E+07 

9.56E+07 

2.09E+05 

1.00E-03 

2.00E-04 

8.46E+07 

3.73E+06 

BASELINE 

REPORTABLE 

LEVEL 

(RQ + 1 POUND) 

4.20E+05 

2.04E+06 

7.90E+03 

2.79E+01 

4.49E+02 

5.45E+10 

1.52E+06 

1.92E+09 

4.72E+05 

6.40E+04 

2.83E+06 

7.75E+O0 

5.00E-05 

1.05E+07 

9.56E+07 

2.09E+05 

1.O0E-O3 

2.00E-04 

8.46E+07 

3.73E+06 

FREQUENCY OF 

RADIONUCLIDE 

RELEASE 

(FACTOR B) 

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 

FREQ. OF RELEASE 

ABOVE BASELINE 

REPORTABLE LEVEL 

(FACTOR C) 

0.0000 

0.0000 

0.0044 

0.0585 

0.0146 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.0000 

0.1930 

0.8596 

0.0000 

0.0000 

0.0000 

0.7617 

0.8319 

0.0000 

0.0000 

TOTAL NUMBER 

OF RADIONUCLIDE 

RELEASES 

(FACTOR A) 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

NUMBER 

OF BASELINE 

REPORTABLE RELEASES 

(A*B*C) 

0.00 

0.00 

0.00 

0.12 

0.01 

0.00 

0.00 

0.00 

0.00 

0.00 

0.00 

1.01 

2.03 

0.00 

0.00 

0.00 

1.92 

13.77 

0.00 

0.00 

TOTAL BASELINE REPORTABLE RELEASES 19 

SOURCE: ICF ANALYSIS 

* Numbers may not add due to rounding. 

2-24 
baseline reportable releases. Chapter 5 tests the sensitivity of the 

assumptions that underlie the methodology used to estimate the number of 

reportable releases. 

This chapter has addressed only radionuclide releases from federally 

permitted facilities. There also can be reportable radionuclide releases from 

unlicensed facilities. These additional reportable releases are discussed in 

Chapter 4 later in this report. 

2-25 
P.45 

CHAPTER 3 

UNIT COSTS ASSOCIATED WITH 

REPORTABLE EPISODIC RADIONUCLIDE RELEASES 

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

incremental costs that result from a regulatory action. This section of the 

report identifies the unit costs associated with actions attributable to the 

final RQ adjustments. Section 3.1 describes actions that are expected as a 

result of reportable episodic releases of radionuclides; Section 3.2 estimates 

the value of the actions that facility owners/operators are expected to take 

when a reportable episodic release occurs; and Section 3.3 estimates the value 

of actions that government officials are expected to take. 

The statutory RQ for radionuclides is one pound. The final radionuclide 

RQ adjustments will lower the RQ below one pound for 730 radionuclides and 

will raise the RQ above one pound for 27 radionuclides.x Because the RQ 

adjustments are generally downward, the final regulation would be expected to 

result in an increase in the number of reportable episodic releases to the 

National Response Center and to state and local emergency response 

commissions. These additional reportable episodic releases impose costs on 

the facility owners or operators, who must immediately notify government 

entities, and then may follow-up the telephone calls with response actions and 

written reports. The increase in reportable episodic releases also imposes 

costs on government employees, who must process the reports and ensure that 

parties take proper actions in response to the releases. 

The increase in the number of episodic reportable releases that results 

from the RQ adjustments will generate benefits for society. Generally, there 

is a positive correlation between reporting episodic radionuclide releases and 

faster and more efficient cleanups of the releases, resulting in less harm to 

public health and welfare and the environment. 

For 27 radionuclides, the final RQ adjustments raise the RQ. As a 

result, costs savings (benefits) for both the regulated community and the 

government may accrue because fewer releases will need to be reported to the 

National Response Center and to state and local emergency response 

commissions. 

The remainder of this chapter describes the actions taken by all parties 

affected by the radionuclide RQ adjustments, the incremental actions that are 

attributable to the final RQ adjustments, and the value of the actions taken 

by all parties. 

1 This discussion refers only to the individually adjusted RQs; other 

radionuclides are assigned an RQ of 1 curie that may be above or below a 

pound. Although it will vary with each radionuclide, generally the final 1 

curie RQ will be lower than the statutory RQ of one pound for these other 

radionuclides as well. 
P.46 

3.1 ACTIONS TAKEN WITH A REPORTABLE RADIONUCLIDE EPISODIC RELEASE 

ACTIONS BY RELEASERS 

Facility owners/operators can be expected to take three types of actions 

when an episodic radionuclide release occurs: notification, recordkeeping, 

and response. The notification action is required by CERCLA and SARA in 

response to a reportable release. Recordkeeping and response actions, 

however, are not required by the statutes and only occur indirectly as a 

result of the regulation. It is the action of owners or operators notifying 

the government that triggers subsequent actions by all parties and that, in 

turn, results in any costs society incurs. 

Notification by a responsible party of a reportable episodic release 

includes reporting to the National Response Center as required under section 

103(a) of CERCLA, and to state and local emergency response commissions as 

required under SARA section 304. Notification involves more than the time 

spent by a plant manager in a telephone conversation with these agencies. It 

also includes the time spent by anyone at a facility who might become involved 

in communicating with the government at the time of the release or subsequent 

to it. Depending on the size of the facility responsible for the release, the 

size of the release, and the identity of the substance that comprises the 

release, the following people at a facility might spend time communicating 

with the National Response Center and other federal, state, and local 

government agencies: foreman, plant manager, plant environmental control 

specialist, plant safety specialist, and attorneys. 

Section 304 of SARA also requires that a facility owner or operator 

provide a written follow-up report after the initial telephone notification. 

This follow-up report must include (1) actions taken to respond to and contain 

the release; (2) any known or anticipated acute or chronic health risks 

associated with the release; and (3) where appropriate, advice regarding 

medical attention necessary for exposed individuals. 

Recordkeeping is often associated with notification. Although neither 

CERCLA nor SARA requires that records of releases be kept, facility 

owners/operators could be expected to maintain logs of calls to the National 

Response Center. Such a log may be useful for managers in establishing that 

the notification requirements of CERCLA section 103(a) have been met, and in 

preparing the follow-up written report to state and local emergency response 

commissions as required under SARA section 304. The log 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 and 

cleanup actions. 

Response includes actions taken by the responsible party to mitigate the 

effects of the episodic release. Typical response actions include sampling 

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

relocation; directly containing the release; removing or neutralizing the 

release through such techniques as pumping, activated carbon treatment, or 

aeration; decontaminating affected areas; and removing any contaminated soil 

or other materials. 

3-2 
P.47 

ACTIONS BY GOVERNMENT 

The government takes four types of actions in response to notification of 

an episodic reportable release: notification processing, off-scene 

monitoring, on-scene monitoring, and direct removal. Officials taking these 

responses include officials responding to calls from the National Response 

Center, and those officials responding to calls from the state and local 

emergency response commissions. 

Notification Processing includes the initial communication with the 

person who calls the National Response Center to report an episodic 

radionuclide release. It also includes evaluation of the reported 

information, determining the need for a field response, if any, and subsequent 

recordkeeping. Notification processing by state and local officials includes 

actions similar to those of federal officials. State and local emergency 

response commissions receive calls from facilities that release radionuclides, 

and these local officials must notify the appropriate personnel who can 

evaluate the information and determine the need for a field response. State 

and local officials also must process the releaser's follow-up written report 

when it is submitted. 

Off-scene monitoring includes supervision and monitoring of the 

responsible party's actions through telephone and data monitoring. These 

actions could include inquiries about the need for further data collection, 

determination of the extent of the release, or reports on the selection and 

progress of cleanup actions. 

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. The 

initiation of on-scene monitoring may be related to the danger or threatened 

danger that a release poses to public health or welfare or the environment, or 

may occur if a facility needs or requests a particular type of assistance. 

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 the environment. Although the 

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

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

containment, and safety equipment to assist in handling the initial emergency 

and to assist the contractors in the cleanup. Direct removals also could 

require or utilize more than one government agency.2 

2 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. 

3-3 
P.48 

ACTIONS ATTRIBUTED TO RADIONUCLIDE RO ADJUSTMENTS 

Facility owners or operators and the government perform some number of 

actions when a reportable episodic release of a radionuclide under the 

baseline scenario occurs (i.e., when a release exceeds one pound). Because 

the final regulation adjusts the RQs downward for 730 of 757 radionuclides, 

there is expected to be an increased number of reportable episodic releases 

and a corresponding increase in the number of times each action is performed. 

These additional actions are the incremental actions attributed to the final 

regulation.. 

The final regulation could increase notification, recordkeeping, and 

response activities for facilities handling and releasing radionuclides that 

have a final RQ of less than one pound. Similarly, it could decrease 

notification, recordkeeping, and response activities for facilities handling 

and releasing radionuclides with a final 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, the quantity and type of 

radionuclides handled at the facility, and the forms of radionuclides (i.e., 

sealed sources, solid, liquids, or gases) used at a facility. 

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

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

to state and local emergency response commissions, the final RQ adjustments 

affect public health and welfare and environmental quality. The final RQ 

adjustments could have the following effects: 

Raising ROs for particular radionuclides may 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 welfare and environmental damages could occur with higher 

RQs. These incremental damages are costs of raising the RQs for 

some radionuclides. 

Decreasing ROs 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. 

3.2 VALUATION OF ACTIONS TAKEN BY EPISODIC RELEASERS OF RADIONUCLIDES 

Economic costs include the value of resources that must be used as a 

result of a reportable episodic release. The majority of the time estimates 

3-4 
P.49 

used in this analysis are taken directly from the Regulatory Impact Analysis 

(RIA) that supported the RQ adjustment for 340 CERCLA hazardous substances.3 

Notification. Because the CERCLA and SARA notification requirements 

require a person in charge of a facility to notify the National Response 

Center and state and local emergency response .commissions, it is reasonable to 

assume that a plant manager or representative will become involved in the 

notification process soon after a release is discovered. In addition to the 

plant manager, the time expended and the type of other people who become 

involved in notification activities likely will depend on the following four 

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

radionuclide released; the location of the release; the responses of 

government officials; and the size and organizational structure of the 

responsible party's business. 

Based on time estimates in the RIA in support of the RQ adjustments for 

340 CERCLA hazardous substance, it is assumed that the cost of notifying the 

National Response Center of releases of less than 55 gallons of a hazardous 

substance is $76 per report, and notification cost for releases over 55 

gallons is $197 per report.4 It would not be appropriate, for two reasons, to 

differentiate notification costs for radionuclide releases on the basis of 

whether the release is above or below 55 gallons. First, gallons is not an 

appropriate measure for amounts of radionuclides; second, a radionuclide 

release well below one pound could be extremely dangerous and could generate a 

great deal of concern and public interest, resulting in relatively high 

notification costs. Radionuclide releases engender public concern and 

scrutiny because of the lack of understanding and general fear felt by the 

public 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 after a release of a radionuclide than if another 

type of hazardous substance was released. 

For these reasons, it seems appropriate to be conservative and to assume 

that the costs for facility owners or operators to notify the National 

Response Center of an episodic radionuclide release are closer to $197 (which 

includes three hours of managerial time and two hours of technical time) than 

to $76 (which includes one hour of managerial time and one hour of technical 

3 ICF Incorporated, Regulatory Impact Analysis of Reportable Quantity 

Adjustments Under Section 102 and 103 of the Comprehensive Environmental 

Response. Compensation, and Liability Act. Volume I, March, 1985. 

A Ibid.. p. 3-9. The compensation rates for industry are taken from U.S. 

Environmental Protection Agency, Estimated Costs of the Final Comprehensive 

Assessment Information Rule. Final Report. March 31, 1988, pp. 44-46. These 

assumed industry wage rates consist of direct salary and personal fringe 

benefits but do not include the allocation of other overhead costs. The 

hourly wage rates, updated to Third Quarter 1987 dollars and rounded to the 

nearest whole dollar, are: Management, $45; Technical, $31; and Clerical $14 

(Memorandum to Brian Muehling and Kate Devine, Regulatory Impacts Branch, EPA, 

from Jeff Karnes, Kearney/Centaur, April 5, 1988). 

3-5 
P.50 

time). The analysis assumes, therefore, that each episodic release 

notification costs the regulated community $197 to notify the National 

Response Center. 

The costs involved in reporting an episodic release under SARA section 

304 are the costs of managerial and technical personnel placing telephone 

calls to state and local emergency response commissions. This effort is 

estimated to require 0.08 hours of managerial time and 0.08 hours of technical 

time for preparation of necessary information, resulting in a total cost of 

$6.10.5 The telephone call to the local emergency planning committee is 

expected to take 30-minutes, with an associated labor cost of $22.50 (30-

minutes of managerial time). Another phone call to the state commission is 

required and also is likely to be a 30-minute toll call. A 30-minute call, at 

average business rates, costs approximately $8.87. Therefore, the estimated 

total cost of notifying the state commission is $31.37 ($22.50 plus $8.87), 

and the estimated cost of notifying both state and local authorities is 

estimated to be $59.97 ($6.10 + $22.50 + $31.37). Facility owners and 

operators also must follow-up their calls to the state and local emergency 

response commissions with a written report. The cost of producing this report 

will vary with the size and severity of the release. The RIA in support of 

rulemaking under sections 302, 303, and 304 of the Superfund Amendments and 

Reauthorization Act of 1986 estimated the average cost6 of producing a followup report to be $117.30. Exhibit 3-1 provides a summary of the notification 

costs described here. 

Recordkeeping. The RIA supporting the RQ adjustment for 340 CERCLA 

hazardous substances estimated the resources required to perform internal 

recordkeeping to be 1 clerical hour per release, and assumes a ratio of 1 

supervisory hour to each 10 hours of clerical time.7 This estimate implies a 

cost of $18.50 per release, assuming $14 per hour for clerical time and $45 

per hour for managerial time. Recordkeeping costs associated with a chemical 

release and recordkeeping costs associated with a radionuclide release should 

not differ substantially. This same unit cost, therefore, is used in this 

analysis for radionuclides. It also is assumed that the costs to facilities 

for recordkeeping associated with the notification of state and local 

emergency response personnel is included in the estimates for complying with 

CERCLA, and no additional time is required. 

5 These time estimates were developed in: U.S. Environmental Protection 

Agency, Regulatory Impact Analysis in Support of Rulemaking Under Sections 

302. 303. and 304 of Title III of the Superfund Amendments and Reauthorization 

Act of 1986. Economics and Technology Division, Office of Toxic Substances, 

EPA, April 10, 1987. p. A-9. 

6 Ibid. 

7 ICF 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, p.3-11. 

3-6 
EXHIBIT 3-1 

UNIT NOTIFICATION COSTS TO FACILITY OWNERS/OPERATORS 

OF A REPORTABLE EPISODIC RELEASE 

P.51 

Action 

Labor 

Category Hours 

Hourly 

Wage Cost 

Telephone National 

Response Center 

Manager 

Technical 

3 

2 

$45.00 

$31.00 

$197 

Preparation to Telephone 

State and Local Emergency 

Response Commissions 

Telephone Local Emergency 

Response Commission 

Telephone State Emergency 

Response Commission 

Manager 

Technical 

Manager 

Manager 

.08 

.08 

0.5 

0.5 

$45.00 

$31.00 

$45.00 

$45.00 

$ 6.10 

$ 22.50 

$ 31.37 

Cost of half-hour toll call $8.87 

Total cost of notifying state and local 

emergency response commissions 

$ 59.97 

Prepare Written Follow-up Report 

for state and local emergency response 

commissions 

$117.30 

Source: ICF analysis. 

3-7 
Response. To estimate response costs, two considerations must be 

factored into the analysis. The first factor is the probability that a 

facility will respond to an episodic release; the second factor is the cost 

that is associated with a response. Both factors likely are correlated with 

the size of a release and the damage that it has caused or threatens to cause. 

Although accurate data are generally unavailable, Nuclear Regulatory 

Commission, Department of Energy, and EPA sources agree generally that 

responsible parties currently respond adequately to a very large percentage of 

episodic releases. Responsible parties are liable for response costs and 

natural resource damages for all releases, whether these releases are above or 

below the RQs, episodic or continuous. 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 responsible party must notify the National Response Center and 

state and local emergency response commissions. For the purposes of this 

analysis, therefore, it is assumed that responsible parties adequately respond 

to 90 percent of episodic radionuclide releases below the RQ and 95 percent of 

episodic radionuclide releases above the RQ. Hence, if the RQ is lowered, a 5 

percent increase in response activities is expected for those episodic 

releases that are now reportable. 

The RIA for RQ adjustments for 340 CERCLA hazardous substances estimated 

that facilities incurred a range of response costs of between $202 and $2,296 

per release;8 this range was a function of the size of the release. 

Radionuclide releases are, in general, much smaller than the one pound to 5000 

pound chemical releases considered in the RIA. Radionuclide release 

responses, however, often require special equipment and protective clothing, 

resulting in response costs that may be higher than the response costs 

associated with other chemical releases. For these reasons, the RIA estimates 

were not used in this analysis to estimate radionuclide response costs. 

Instead, three model release scenarios were developed for this analysis based 

on representative episodic release reports in the EIA data base. The three 

scenarios represent a range of response actions and response costs. Based on 

the three response scenarios, cost estimates were derived to determine a 

weighted average response cost for an episodic radionuclide release. 

Scenario 1 represents a small radionuclide release resulting from a 

faulty valve at a conversion facility or laboratory. The radionuclide 

released could be Uranium-238, Tritium, or Krypton-85. The appropriate 

response for scenario 1 would likely be monitoring for an 8-hour period. 

Costs for scenario 1 are used for all releases whose response costs would be 

expected to be minimal. 

Scenario 2 represents a laboratory or hospital situation where a 

radionuclide accidently is disposed with the regular garbage. The radioactive 

material is then shredded and put in a dumpster. Radionuclide releases likely 

to be represented in this model include Cobalt-60, Iodine-125, Iodine-131, and 

Iridium-192. Scenario 2 costs include monitoring and decontamination. 

8 Ibid.. p. 3-11. 

3-8 
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. 

Exhibit 3-2 shows, for each scenario, the estimated costs of hypothetical 

responses. All costs are in 1987 dollars. Based on the frequency of 

occurrence of different types of releases in the EIA data base, it is assumed 

that 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. Therefore, these response scenarios yield the following 

average weighted response cost for radionuclide releases: 

$5,608 per response - [(0.66) x ($166)] + [(0.27) x ($5,937)] 

+ [(0.07) x ($55,637)] 

This analysis also assumes that government officials would agree on what 

response a facility should take to clean up an episodic release of 

radionuclides and that any response costs associated with reporting to state 

or local emergency response commissions are captured already in the above 

estimates. 

3.3 VALUATION OF GOVERNMENT ACTIONS 

Most actions performed by the government involve costs that do not vary 

with the type of CERCLA hazardous substance released. Notification 

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

releases are similar to costs incurred for other CERCLA hazardous substances. 

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

provides unit time estimates of government actions and are used in this 

analysis. The following estimates of costs are summarized in Exhibit 3-3. 

Notification Processing bv Government Officials. The RIA in support of 

the RQ adjustments for 340 CERCLA hazardous substances estimated that 

processing a call to the National Response Center takes approximately 30 

percent of a government workday.9 For purposes of this analysis, it is 

assumed that a government workday is valued at $184.10 This produces an 

9 The two and a half hours of government time for notification processing 

includes time for several government officials to confer about the release 

situation. Depending upon the nature and size of the release and the facility 

responsible for the release, it is likely that representatives from EPA, DOE, 

or the Nuclear Regulatory Agency could be called to assess the situation. 

10 The assumed compensation rate for government employees is based on the 

GS-11 step 1 pay level and is adjusted to include the cost of personal fringe 

benefits, assumed to be 40 percent of direct wages. The annual compensation 

for 220 workdays is $40,393, translating into a daily wage rate of $184. 

3-9 
EXHIBIT 3-2 

RADIONUCLIDE RESPONSE COST ESTIMATES 

RELEASE SCENARIO #1 

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

conversion facility or laboratory 

TYPICAL RADIONUCLIDES: IO"2 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, this analysis assumes response requires 8 hours 

of monitoring. 

Total Estimated Cost: $166 

RELEASE SCENARIO #2 

CIRCUMSTANCE: Radionuclide source accidently disposed of as standard 

solid waste, shredded, and put in dumpster 

TYPICAL RADIONUCLIDES: IO"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 cart - $332 

Monitoring and decontamination of shredder and dumpster - $5605 

Total Estimated Cost - $5937 

3-10 
P.55 

EXHIBIT 3-2 (continued) 

RADIONUCLIDE RESPONSE COST ESTIMATES 

RELEASE SCENARIO #3 

CIRCUMSTANCE: Radionuclide release from process discharge pipe to stream 

that 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 - $1661 

Ground water monitoring well (drilling and sampling) - $1038 

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

mobilization for ion-exchange resin) - $1038 

Dredging and disposal of contaminated sediments (1000 cu ft) - $51,900 

Total Estimated Cost - $55,637 

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 

1987. 

3-11 
EXHIBIT 3-3 

UNIT COSTS TO ALL GOVERNMENT ENTITIES 

OF A REPORTED EPISODIC RELEASE 

Action Estimated Cost 

Process one call to the National Response Center 

Process one call to local emergency response commission 

Process one call to State emergency response commission 

Process written follow-up reports (state and local 

commissions) 

Off-scene monitoring activities 

On-scene monitoring activities 

Direct removal 

$ 

$ 

$ •CO- $ 

$ 2 

$55 

57 

57 

57 

11 

219 

710 

637 

50 

50 

50 

50 

00 

00 

00 

Source: ICF analysis. 

3-12 
P.57 

estimate for processing notifications to the National Response Center of 

$57.50. Notification processing by state and local officials involves actions 

similar to those performed by the federal government. State and local 

officials must process calls to the state and local emergency response 

commissions that are similar to those received by the National Response 

Center. This analysis assumes, therefore, that the costs incurred by state 

and local governments also are $57.50 for each report; and that two reports 

(one to each commission) are required, yielding a total costs of $115. State 

and local officials also must process written follow-up reports; this analysis 

assumes processing follow-up reports requires a half-hour of government time, 

for a total cost per report of $11.50. 

Off-scene Monitoring. The RIA in support of the RQ adjustment for 340 

CERCLA hazardous substances estimated11 that the activities of off-scene 

monitoring are expected to consume 60 percent of a government workday and 30 

percent of a contractor workday (valued at $358 per day). These assumptions 

produce an estimated cost for off-scene monitoring of $219. The RIA also 

assumes that the likelihood of off-scene monitoring by the government varies 

with the size of the reported release. The RIA assumes government off-scene 

monitoring is likely between 40 percent and 70 percent of the time. This 

analysis assumes that a government response action is more likely for a 

radionuclide release than for the average chemical release because of public 

awareness and concern over radiation contamination. Therefore, it is assumed 

that the likelihood of off-scene monitoring by the government is 70 percent. 

On-scene monitoring. The RIA for adjusting the RQs of 340 CERCLA 

hazardous substances estimated that on-scene monitoring would require five 

government workdays and five contractor workdays, resulting in an estimated 

cost of $2,710 for each occurrence of on-scene monitoring. The RIA also 

assumes that the likelihood of the government becoming involved in on-scene 

monitoring is in the range of 5 to 20 percent. Because a government response 

action may be more likely for a radionuclide release than for a chemical 

release, this analysis assumes the likelihood of on-scene monitoring is 20 

percent. The sensitivity of the results to this assumption is tested in 

Chapter 5. 

Direct Removal. The RIA for 340 CERCLA hazardous substances estimated 

direct removal costs12 to be $39,273. This cost estimate is modified in this 

analysis because direct response actions for radionuclide releases are 

different from direct response actions for other chemical releases. 

11 Ibid. The difference in daily cost between a contractor and an EPA 

worker reflects differences in tasks performed and the personnel needed to 

perform those tasks, as well as the inclusion of overhead expenses (such as 

equipment) in contractor costs that are not included in the estimate for a 

government worker. 

12 The RIA for the 340 CERCLA hazardous substances assumed the likelihood 

of a direct government response action was between one and five percent. The 

high end of this range, five percent, is assumed to be more appropriate for 

radionuclide releases, Ibid.. p. 3-17. 

3-13 
P.58 

Decontamination procedures, for example, often involve special equipment and 

protective clothing. The model cost scenarios discussed earlier in the 

chapter and described in Exhibit 3-2 are the basis for estimating the direct 

removal costs associated with a radionuclide release. It is assumed that the 

government would get involved only in the most costly of the three scenarios 

(#3) and the cost estimate for it ($55,637) is a plausible estimate of the 

direct removal costs that the government would incur. An assumption is made 

that the government would get involved in direct removal five percent of the 

time. The sensitivity of this assumption on the results is tested in Chapter 

6. 

This analysis assumes that any costs associated with off-scene 

monitoring, on-scene monitoring, and direct removal by state and local 

emergency response commissions are included in the estimates above and that 

actions by these officials do not increase the cost estimates. 

3-14 
P.59 

CHAPTER 4 

ESTIMATED ANNUAL COST OF RQ ADJUSTMENTS 

This chapter estimates the total costs of the final RQ adjustments, 

including the increased economic burden for facility owners/operators and the 

government that may result from lowering the RQs for 730 radionuclides, and 

the potential cost savings that may result from raising the RQs for 27 

radionuclides. The analysis in this chapter combines the information 

presented in Chapters 2 and 3 and computes the incremental annual cost 

attributable to the final regulation. 

The cost and cost savings associated with the RQ adjustments are a result 

of the change in the number of releases reportable to the National Response 

Center and to state and local emergency response commissions. Reporting a 

release causes the facility owners/operators to incur costs for notification, 

recordkeeping, and response activities, and causes the government to incur 

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

direct removals. Section 4.1 of this chapter estimates the number of 

incremental reportable episodic releases that occur due to the final 

regulation; Section 4.2 estimates the incremental costs of the regulation 

associated with these episodic releases; Section 4.3 describes the number of 

releases that could occur from other facilities and the estimated cost of 

reporting those releases; and Section 4.4 discusses potential firm-level 

economic effects of the incremental costs due to the final regulation. 

4.1 ESTIMATED NUMBER OF INCREMENTAL REPORTABLE EPISODIC RELEASES 

The estimated change in the number of reportable episodic releases is 

equal to the difference between the number of baseline reportable episodic 

releases and the number of episodic releases that are reportable under the 

final regulation. In the baseline, a radionuclide release is reportable to 

the National Response Center and to state and local emergency response 

commissions if it equals or exceeds the statutory RQ of 1 pound.1 Chapter 2 

of this report estimated that there are 19 baseline reportable radionuclide 

releases annually. 

As in the baseline, this analysis must account for the amount of a 

release that is federally permitted in calculating the number of episodic 

releases that are reportable after the RQ adjustments. Most federally 

permitted releases are controlled through the Nuclear Regulatory Commission or 

Agreement States; 10 CFR Part 20 establishes a whole body dose-equivalent 

exposure limit to the general public of 500 millirem, the same exposure level 

that EPA used to derive the RQs. For purposes of this analysis, therefore, 

federally permitted release levels are assumed to equal the RQs. Thus, a 

reportable radionuclide release under the final regulation from a facility 

1 Reportable radionuclide releases from facilities that are licensed by 

the Nuclear Regulatory Commission, an Agreement State, or DOE, or that are 

controlled by permits or limitations issued pursuant to the provisions listed 

in section 101(10) of CERCLA, are one pound or more above the federally 

permitted levels. 
P.60 

holding a federal permit or license is assumed in this analysis to be any 

release that equals or exceeds twice the final RQ. Because the final RQs are 

used as proxies for the federally permitted release levels, all releases from 

facilities that are federally permitted that equal or exceed twice the final 

RQ must be reported to the National Response Center and state and local 

emergency response commissions.2 

The methodology presented in Chapter 2 of this report is used to estimate 

the number of reportable episodic releases under the final regulation. In 

particular, the total number of episodic radionuclide releases that occur 

annually (250) is multiplied by the probability that a particular radionuclide 

will be released at levels that equal or exceed the RQ (or twice the RQ for 

facilities that generally are in compliance with federal permits). 

The EIA data base is used to estimate the frequency with which a 

particular radionuclide has been released in the past, and the size 

distribution of those releases. Exhibit 4-1 presents the details of this 

analysis, depicting the calculations performed for each radionuclide in the 

EIA data base. As shown in the exhibit, there are an estimated 78 

radionuclide releases that would be reportable to the National Response Center 

and to state and local emergency response commissions given the final RQ 

adjustments. Maintaining the estimate of 19 reportable releases in the 

baseline, and 78 reportable releases using the final adjusted RQs, yields an 

estimate of 59 additional reports of eposodic releases under the radionuclide 

RQ final regulation. 

4.2 ESTIMATED COST OF FINAL RQ ADJUSTMENTS 

The total cost to regulated parties is the sum of notification, 

recordkeeping, and response costs. The units costs for each of these actions 

are shown in Exhibit 3-1, and have been reprinted in Exhibit 4-2. The total 

cost calculations are presented in Exhibit 4-3. The costs of the final 

regulation are calculated in the following manner: 

A. Notification. There are 59 incremental reportable 

radionuclide releases. Reporting an episodic 

radionuclide release to the National Response Center 

is estimated to cost $197, yielding a total annual 

cost of approximately $11,623. The total cost of 

2 This assumption is a simplification because federally permitted release 

amounts may vary from facility to facility. The Nuclear Regulatory Commission 

bases its 10 CFR Part 20 intake limitations on a dose of 5 rem for nuclear 

facility workers and 500 millirem for the general public. EPA based its final 

RQs on a dose-equivalent of 500 millirem for an individual standing 30 meters 

from the release point for 24 hours. These conservative assumptions were then 

used to calculate the release levels for the final adjusted RQs. Chapter 5 

tests the sensitivity of the results to the number of reportable releases to 

account for this assumption. 

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EXHIBIT 4-1 (continued) 

REPORTABLE RADIONUCLIDE RELEASES UNDER FINAL ADJUSTED RQs ESTIMATED FROM EIA DATA BASE 

RADIONUCLIDE 

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 

RQ 

(CURIES) 

10 

0.01 

0.01 

0.01 

0.1 

1000 

1 

1 

10 

0.1 

10 

10 

, 0.001 

100 

1000 

10 

0.1 

0.1 

100 

10 

REPORTABLE RELEASES 

FROM FACILITIES 

WITH FEDERAL PERMITS 

(2*RQ) 

2.00E+01 

2.00E-02 

2.00E-02 

2.00E-02 

2.00E-01 

2.00E+03 

2.00E+00 

2.00E+00 

2.00E+01 

2.00E-01 

2.00E+01 

2.00E+01 

2.00E-03 

2.00E+02 

2.00E+03 

2.00E+01 

2.00E-01 

2.00E-01 

2.00E+02 

2.00E+01 

FREQUENCY OF 

RADIONUCLIDE 

RELEASE 

(FACTOR B) 

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 

FREQUENCY OF 

RELEASES ABOVE 

REPORTABLE LEVEL 

(FACTOR C) 

0.0936 

0.5789 

0.5789 

0.5789 

0.4591 

0.0102 

0.3304 

0.3304 

0.0936 

0.4591 

0.0936 

0.0936 

0.7354 

0.0190 

0.0102 

0.0936 

0.4591 

0.4591 

0.0190 

0.0936 

TOTAL NUMBER 

OF RADIONUCLIDE 

RELEASES 

(FACTOR A) 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

250 

NUMBER OF 

REPORTABLE 

RELEASES 

(A*B*C) 

0.29 

2.20 

0.39 

1.17 

0.41 

0.00 

0.15 

0.30 

0.02 

1.75 

0.04 

0.78 

1.98 

0.00 

0.00 

0.08 

1.85 

13.27 

0.06 

0.06 

TOTAL REPORTABLE RELEASES 78 

SOURCE: ICF ANALYSIS 

Numbers may not add due to rounding 

4-4 
P.63 

EXHIBIT 4-2 

UNIT NOTIFICATION COSTS TO FACILITY OWNERS/OPERATORS 

OF A REPORTABLE EPISODIC RELEASE 

Action 

Telephone 

Response 

National 

Center 

Preparation to ' 

State and 

Response 

Telephone 

Response 

Telephone 

Local 

relephone 

Emergency 

Commissions 

Local 

Commis 

State 

Emergency 

s ion 

Emergency 

Labor 

Category 

Manager 

Technical 

Manager 

Technical 

Manager 

Manager 

Hours 

3 

2 

0 

0 

08 

08 

5 

5 

Hourly 

Wage 

$45 

$31 

$45 

$31 

$45 

$45 

00 

00 

00 

00 

00 

00 

Cost 

$197 

$ 6 

$ 22 

$ 31 

10 

50 

37 

Response Commission 

- Cost of half-hour toll call $8.87 

Total cost of notifying State and Local 

Emergency Response Commissions 

$ 59.97 

Prepare Follow-up Report $117.30 

Source: ICF analysis. 

4-5 
P.64 

EXHIBIT 4-3 

CALCULATION OF TOTAL ANNUAL COSTS TO FACILITY OWNERS/OPERATORS 

A. Costs of Notification: $22.082 

1. National Response Center 

(59 incremental reports) * $197 $11,623 

2. State and Local Response Commissions 

a. Costs of Immediate Notifications 

(59 incremental reports) * $59.97 $ 3,538 

b. Costs of follow-up reporting 

(59 incremental reports) * $117.30 $ 6,921 

B. Cost of Recordkeeping $ 1,092 

(59 incremental reports) * $18.50 

C. Cost of Response $16,544 

(59 incremental reports) * .05 * $5,608 

TOTAL COST TO FACILITY OWNERS/OPERATORS $39,718 

Source: ICF analysis. 

4-6 
P.65 

reporting a release to state and local officials is 

estimated to be $177.27 ($59.97 for the initial calls 

and $117.30 for the follow-up report), yielding a 

total annual cost of reporting 59 additional episodic 

releases of $10,459. The total costs of notification 

are the sum of the costs to report to the National 

Response Center and to report to state and local 

officials, or approximately $22,100. 

B. Recordkeeping. Multiplying 59 incremental reportable 

releases by $18.50, the cost of recordkeeping per 

release, yields a total annual recordkeeping cost of 

$1,092. 

C. Response. This analysis3 assumes that the 

probability of a 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, five 

percent of the incremental reportable releases will 

experience response actions as a result of the lower 

RQs. Multiplying the number of incremental 

reportable release (59) by the incremental 

probability of response (0.05) and by the weighted 

average cost per response ($5,608) yields an 

estimated annual response cost of $16,544. 

The total cost of the final regulation to facility owners/operators 

responsible for reportable episodic releases of radionuclides is the sum of 

the costs in each of the three areas. This is estimated to be about $39,700. 

The total cost to the government of RQ adjustments is the sum of 

notification processing for federal officials, notification processing for 

state and local officials, off-scene monitoring, on-scene monitoring, and 

direct removal costs. These costs are shown in Exhibit 4-4 and the 

calculations are summarized below:* 

A. Notification Processing for Federal Officials. A 

total annual notification processing cost of $3,393 

is calculated by multiplying 59 incremental 

reportable releases by $57.50 (the estimated cost of 

processing one notification at the National Response 

Center). 

3 The sensitivity analysis in Chapter 5 tests the result of assuming 

different probabilities of response to releases above and below an RQ. 

Derivation of the average cost of response is shown in Exhibit 3-2. 

4 Exhibit 3-3 presented the unit costs for government actions. 

4-7 
P.66 

EXHIBIT 4-4 

CALCULATION OF TOTAL ANNUAL COSTS TO GOVERNMENT 

A. Cost of Notification Processing to Federal Officials $ 3.393 

1. Reports to National Response Center 

(59 incremental reports) * $57.50 

B. Cost of Notification Processing to State and 

Local Officials S 8.142 

1. Reports to State and Local Commissions 

(59 incremental reports) * $115.00 $6,785 

2. Follow-up Reports 

• (59 incremental reports) * $23.00 $1,357 

C. Cost of Off-Scene Monitoring $ 9.045 

(59 incremental reports) * .70 * $219 

D. Cost of On-Scene Monitoring $ 31.978 

(59 incremental reports) * .20 * $2,710 

E. Cost of Direct Removal $164.129 

(59 incremental reports) * .05 * $55,637 

TOTAL COST TO GOVERNMENT $216,687 

Source: ICF analysis. 

4-8 
P.67 

B. Notification Processing for State and Local 

Officials. A total annual notification processing 

cost of $8,142 is calculated by multiplying the 

number of incremental releases (59) by the unit costs 

of processing calls ($115), and the same number of 

incremental reports by the cost to process two 

follow-up reports (one to the state and one to the 

local committee) at $11.50 per report, and adding the 

two results together. 

C. Off-scene monitoring. Multiplying 59 incremental 

reportable releases by the probability that off-scene 

monitoring is required5 (.70), and by the cost of 

off-scene monitoring per release ($219), yields a 

total annual off-scene monitoring cost of $9,045. 

D. On-scene monitoring. Multiplying 59 incremental 

reportable releases by the probability that on-scene 

monitoring is required6 (.20), and this product by 

the cost of on-scene monitoring per release ($2,710) 

yields a total annual on-scene monitoring cost of 

$31,978. 

• E. • Direct Removal. Multiplying 59 incremental 

reportable releases by the probability of a direct 

removal by the government (.05) and by the estimated 

cost of a direct removal ($55,637) yields a total 

annual cost for direct removal of $164,129. 

The total cost to the government is the sum of notification processing 

costs, off-scene monitoring costs, on-scene monitoring costs, and direct 

removal costs. This sum is approximately $216,687. 

The sum of the total costs to facility owners/operators and to the 

government for reporting and responding to reports of 59 additional reportable 

episodic radionuclide releases, therefore, is estimated to be approximately 

$256,400. 

4.3 ESTIMATE OF NUMBER OF OTHER INCREMENTAL REPORTABLE RELEASES 

Until this point in the analysis, only the number of incremental releases 

from certain types of facilities have been estimated. These facilities are 

generally those that are licensed by the Nuclear Regulatory Commission and 

Agreement States, and those controlled by DOE. The analysis has estimated 

that there will be 59 incremental reportable episodic releases annually as a 

5 The sensitivity analysis in Chapter 5 tests the results of assuming 

different probabilities for off-scene monitoring. 

6 The sensitivity of this assumption is tested in Chapter 5. 

4-9 
P.68 

result of the final radionuclide RQ adjustments, and that the resulting cost 

due to the actions taken to notify the National Response Center and to notify 

SERCs and LEPCs is approximately $256,400. 

There are a certain number of radionuclide releases that occur from other 

types of facilities that also could be affected by the final RQ adjustments. 

These other releases are not federally-permitted and include releases from 

coal-fired utility and industrial boiler sites, unlicensed laboratories, lowenergy linear accelerators, energy extraction and processing facilities, and 

certain mining and ore-processing operations. Some of these facilities may 

release radionuclides at or above an RQ and, therefore, have to report under 

CERCLA section 103. 

Releases of radionuclides from high-energy accelerators are regulated by 

DOE through NESHAP. Radionuclide releases from low-energy accelerators are 

not regulated through NESHAP, but are permitted by states. Because these" 

releases are not federally permitted and are not releases of source, special 

nuclear, or by-product materials, they are not covered by CERCLA sections 

101(10)(H) or (K), and, therefore, are subject to the reporting requirements 

under CERCIA section 103. Licensed laboratories are permitted by Agreement 

States; unlicensed laboratories are not because they store and use 

radionuclides in quantities and concentrations below the licensing thresholds. 

Unlicensed laboratories tend to be specialized, small facilities using a 

limited number of radionuclides in small quantities. Because unlicensed 

laboratories and linear accelerators maintain such small inventories of 

radionuclides, they are unlikely to release an RQ or more of radionuclides 

under less than exceptional circumstances. 

The other facilities that could have radionuclide releases that are not 

federally permitted move, process, or consume large quantities of low activity 

materials during normal operating processes. The process of radioactive decay 

that governs these releases is predictable, continuous, and very stable in 

quantity and rate; as such, these releases are generally expected to be 

continuous and stable in quantity and rate as defined under the regulations 

implementing CERCLA section 103(f)(2). Under the reduced reporting 

requirements of section 103(f)(2), such releases must be reported initially, 

annually, and whenever a statistically significant increase (SSI) occurs. In 

addition, under section 304 of the SARA (Title III), these releases must be 

reported to the appropriate SERC and LEPC. 

Radionuclides may be released from these facilities by a number of 

release pathways but three pathways predominate: (1) the dumping of an 

intermediate product or waste outside a facility (such as the stockpiling of 

coal, coal ash, or ore tailings); (2) emissions of radon and other 

radionuclides from stockpiles or work-in-process inventories (e.g., natural 

gas at a processing plant); and (3) smokestack emissions. 

With the exception of releases from coal-fired boilers, EPA does not have 

much information about the quantity of radionuclides released from these 

facilities. In particular, information about release pathways other than 

smokestack emissions, especially with respect to the frequency and amount of 

stockpiling that occurs at facilities, is sparse and incomplete. In addition, 

4-10 
P.6JL 

EPA lacks detailed information about the characteristics of facilities within 

these industries, many of which show considerable diversity in size and 

operation. It is difficult, therefore, to estimate with precision the number 

of facilities likely to release an RQ or more of any radionuclide on a regular 

basis. Based on the information available, EPA has estimated that 2,710 

facilities could be releasing radionuclides in a continuous manner above the 

RQ. The 2,710 facilities are listed by industry category in Exhibit 4-5. 

Facilities with coal-fired boilers comprise nearly two-thirds of these 

facilities. The basis of this estimate is provided in detail in Appendix A. 

Actions and Value of Actions Taken bv Industry for Reporting under CERCLA 

Section 103(f)(2) 

If the owner or operator reports continuous releases under the authority 

of CERCLA section 103(f)(2), the owner must meet the following reporting 

requirements: 

Initial Notification: Facilities must notify the National Response 

Center (NRC), SERC, and LEPC by telephone that releases from that facility are 

continuous and will be reported under section 103(f)(2). The information 

required in the initial telephone call is: 

(1) the name and location of the facility or vessel; 

(2) the name and identity of the hazardous substance, the Chemical 

Abstracts Service Registry Number (CASRN) for the substance, and the 

media affected; 

(3) identification of the release as continuous; and 

(4) the upper bound of the normal range of the release under normal 

operating conditions. 

It is estimated that initial notification to the NRC requires one hour of 

managerial time and one hour of technical time7 at a hourly wage rate of 

$45.00 and $31.00 respectively. In addition, each telephone call to the SERC 

and LEPC is expected to require 0.25 hours of managerial time. The cost of an 

intrastate toll call to the SERC is estimated at $8.87. Consequently, the 

total cost of providing initial notification to all government bodies is 

estimated as $107.40 ($45 + $31 + (2)(0.25 x $45) + $8.87). 

Initial Written Report: Facilities also must submit a follow-up written 

initial report to the On-Scene Coordinator (OSC), SERCs, and LEPCs within 30 

days of the initial telephone call. In the follow-up report, facilities must 

project estimates of the total annual amount released and the upper bound of 

7ICF 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, p.3-11. 

Based on estimated notification costs for releases of less than 55 gallons. 

4-11 
P.70 

EXHIBIT 4-5 

ESTIMATED NUMBER OF REPORTING FACILITIES 

UNDER CERCLA SECTION 103(f)(2) 

Facility Type Number 

Coal Mines 363 

Uranium mines 181 

Bauxite mines & aluminum smelters 44 

Copper mines & smelters 76 

Zinc mines & smelters 41 

Lead smelters/refineries 5 

Elemental phosphorus plants 6 

Phosphate rock plants 35 

Wet process fertilizer plants 35 

Iron mines & smelters 68 

Geothermal energy plants 20 

Gas-fired boilers 112 

SUBTOTAL: 986 

Coal-fired industrial boilers 1,210 

Coal-fired utility boilers 514 

TOTAL: 2,710 

Source: Appendix A and B 

4-12 
P.71 

the normal range that describes the pattern of releases from the facility. 

These estimates should be based on the operating history of the plant and 

professional judgment. The information required in the initial written report 

includes: 

(1) name and location of the facility or vessel, and name and 

telephone number of the person in charge; 

(2) name/identity of the hazardous substance, Chemical Abstracts Service 

Registry Number (CASRN) number for the substance, and media 

affected; 

(3) a brief description of the pattern or profile of the release 

during any 24-hour period under normal operating conditions, 

including a description of the source(s) of the release and the 

basis for asserting continuity and stability in quantity and rate, 

and a description of the nature of the predictability of the release 

cycle; 

(4) the frequency of the release (i.e., the number of times the 

release is expected to occur during the year); 

(5) ' the upper bound of the normal range of the release during any 24-

hour period under normal operating conditions (in pounds or 

kilograms); 

(6) an estimate of the total annual amount that is expected to be 

released (in pounds or kilograms); 

(7) the method that will be used to identify SSIs, (including the 

sensitivity of the statistical test, if used); 

(8) the population density within a one mile radius of the facility 

described in terms of the following ranges: 0-10 persons, 11-50 

persons, 51-100 persons, or 100 persons or more; 

(9) the identity of any sensitive populations or ecosystems within 

a one mile radius of the facility (e.g., elementary schools, 

hospitals, retirement communities, or aquifers); and 

(10) the date elected for submittal of subsequent annual reports. 

All of the required information is assumed to be readily available to the 

facility. Costs will be incurred for the compilation and formatting of the 

information into a report suitable for submission to the government. The 

amount of time required to prepare an initial report is estimated to be 3 

hours of managerial time, 1 hour of technical time, and 1 hour of clerical 

4-13 
P.72 

time.8 The hourly cost estimates are $45 for managerial time, $31 for 

technical time, and $14 for clerical time, resulting in a final annual report 

cost of $180.00. The costs of photocopying and mailing the report to 

additional government bodies is assumed to be negligible. 

Annual Report: An annual written report must be submitted to the EPA 

designated OSC and must include certain specified summary information about 

the substances released during the preceding year. This report is 

retrospective and must contain actual release information for the preceding 

year. Facilities do not need to provide annual reports to SERCs and LEPCs. 

The information required in this report includes: 

(1) name and location of the facility or vessel, and name and 

telephone number of the person in charge; 

(2) name/identity of the hazardous substance, CASRN number for the 

substance, and media affected; 

(3) a brief description of the pattern or profile of the release 

during any 24-hour period under normal operating conditions, 

including a description of the source(s) of the release and the 

basis for asserting continuity and stability in quantity and rate, 

and a description of the nature of the predictability of the release 

• cycle; 

(4) the frequency of the release (i.e., the number of times the 

release occurred during the year); 

(5) the upper bound of the normal range of the release during any 24-

hour period under normal operating conditions (in pounds or 

kilograms); 

(6) an estimate of the total annual amount released (in pounds or 

kilograms); 

(7) the number of times during the preceding year that SSIs occurred and 

were reported to the NRC; 

(8) the method used to identify SSIs, (if a statistical test is used, 

the sensitivity of that test must be included); 

(9) the population density within a one mile radius of the facility 

described in terms of the following ranges: 0-10 persons, 11-50 

persons, 51-100 persons, or 100 persons or more; and 

8 U.S. Environmental Protection Agency, Background Document in Support of 

the Proposed Continuous Release Reporting Regulation under Section 103(f)(2) 

of the Comprehensive Environmental Response. Compensation, and Liability Act. 

Emergency Response Division, EPA, September 1987. p.5-4. 

4-14 
P.73 

1 

I 

I 

I 

I 

I 

I 

I 

I 

I 

I 

(10) the identity of any sensitive populations or ecosystems within 

a one mile radius of the facility (e.g., elementary schools, 

hospitals, retirement communities, or aquifers). 

Because the information required in the annual report is similar to that 

required in the written initial notification, it is assumed that annual 

reports require the same amount and level of effort as the initial report, 

resulting in a per report cost of $180.00. This analysis assumes that annual 

reports will be submitted one year after the initial notification is provided, 

such that the costs of initial notification are incurred in year one and the 

costs of the annual report are incurred in year two and in subsequent years. 

Revisiting Initial and Annual Reports: For some percentage of facilities 

reporting under section 103(f)(2), the information provided in the initial 

and/or annual reports will prompt requests for additional information and 

communication about the nature and extent of the release. For instance, an 

OSC may seek clarification or verification of information concerning release 

activity in order to assess the degree of threat the release poses to human 

health, welfare, and the environment. It is estimated that approximately 5 

percent of the initial and annual reports will be revisited each year and that 

this process will require two hours of management time per report. The 

resulting unit cost is $90 (2.0 x $45). 

Statistically Significant Increases: Section 103(f)(2) also requires 

that "statistically significant increases". (SSIs) in the continuous releases 

be reported to the National Response Center.9 Because continuous radionuclide 

releases are assumed to be the result of radioactive decay that occurs at a 

predetermined and fixed rate, it is unlikely that there will be any 

statistically significant increases in the release. Nevertheless, this 

analysis conservatively assumes that statistically significant increases in 

these releases will occur and will be reported to the National Response 

Center, SERC, and LEPC. 

It is assumed that reporting of an SSI will involve less time than for an 

episodic release because information about the release is already known and 

available from previous initial and annual reports. Consequently, only one 

hour of managerial time and one hour of technical time are estimated to be 

required to report the release to the National Response Center. The technical 

time consists of determining if the release is reportable, briefing management 

of the situation, and collecting the information required by the National 

Response Center. The managerial time includes being informed of the 

situation, alerting the appropriate personnel, and making one notification 

telephone call. Reporting of SSIs to other appropriate government bodies is 

estimated to require 0.5 hours of management time per phone call, resulting in 

a total costs of reporting of $129.90 ($45 + $31 + (2)(0.5 x $45) + $8.87). 

9 EPA currently is evaluating five percent and one percent as the 

appropriate level of significance. This analysis only presents costs for the 

one percent definition. 

4-15 
B 

0 

1 

1 

I 

1 

I 

Follow-up Written Report of a Release: Following a release requiring 

notification under section 304, the facility owner/operator is required to 

provide a follow-up written report to the appropriate SERC and LEPC updating 

the information given in the phone call and providing additional information. 

The estimated cost of this activity increases with the size of the release. 

Based on estimates derived for reporting episodic releases, this activity is 

assumed to cost $117.30.10 

Recordkeeping: Although neither CERCLA nor SARA requires that records of 

releases be kept, it is likely that a facility will maintain a log or some 

other record of reported releases. Such a log would be useful for managers in 

establishing that the facility is in compliance with the provisions of section 

103(f)(2), and would serve as a depository for information relevant to 

preparing a follow-up written report or annual report. For example, 

information recorded in the log may be used to demonstrate the continuity and 

stability of the release. Recordkeeping is estimated to require one hour of 

clerical time per reported release and one-tenth of an hour of managerial 

supervision per reported release for a cost of $18.50 ($14 + 0.10 x $45). 

Although the notification requirements of CERCLA section 103 do not 

require response action, it was argued earlier that cleanup response is more 

likely to occur when notification is required. Because continuous releases 

represent regular occurrences from large quantities of materials incidental to 

normal operations, they are unlikely to provoke or require an immediate 

response action. More likely, the reporting requirements of section 103(f)(2) 

may lead to action over the long term to mitigate or reduce these releases 

through new operating procedures, better containment systems, or smaller 

piles. This analysis assumes, therefore, that facilities that release 

radionuclides continuously will not respond to or cleanup these releases. 

Actions and Value of Actions Taken bv Government tinder CERCLA Section 

103(f)(2) 

Initial Notification: The cost of processing an initial notification for 

government officials is assumed to require 0.25 hours for collecting and 

processing the information received during the telephone call. Assuming a 

cost estimate of $184 per government workday, processing an initial 

notification costs $5.75 (0.25 x $184/8). 

Written Initial Notification and Annual Report: Processing a written 

initial report or an annual report by federal officials is assumed to require 

one hour of government time. At a wage rate of $184 per government workday, 

this cost is $23.00 ($184/8). 

10 U.S. Environmental Protection Agency, Regulatory Impact Analysis in 

Support of Rulemaking Under Sections 302. 303. and 304 of Title III of the 

Superfund Amendments and Reauthorization Act of 1986. Economics and Technology 

Division, Office of Toxic Substances, EPA, April 10, 1987. p. A-9. 

4-16 
P.75 

Revisiting Initial and/or Annual Reports: For some percentage of 

facilities reporting under section 103(f)(2), the information provided in the 

initial and/or annual reports will prompt requests for additional information 

and communication about the nature and extent of the release. For example, 

facilities located near sensitive populations and ecosystems may be asked to 

provide additional information in order to assess the risks associated with 

the release. It is estimated that approximately 5 percent of the initial and 

annual reports will be revisited each year and that this process will require 

two hours of government time per report for a cost of $46.00 (2.0 x $184/8). 

Statistically Significant Increases (SSIs): The cost of processing an 

SSI includes both an immediate evaluation to determine whether a response 

action is necessary and the collection and storage of the transmitted 

information. It was estimated that 0.3 government workdays are necessary to 

process an episodic release notification. The time required to evaluate an 

SSI is expected to be considerably less for two reasons: (1) information 

pertaining to the facility, the nature of the release, and the population and 

environment at risk will already be available from filed initial and/or annual 

reports, and (2) the SSI report represents a release under normal operating 

conditions and, therefore, is unlikely to require a response. Because the 

information previously submitted by the facility is assumed to be readily 

available through the Emergency Response Notification System (ERNS), 

evaluation of the release is expected to occur simultaneously with the 

telephone report from the facility. Consequently, processing a notification 

of an SSI is estimated to require 0.5 hours of government time, for a cost of 

$11.50 (0.5 x $184/8). It is assumed that all government bodies require the 

same amount of time to process and evaluate an SSI. 

Follow-up Written Report of a Release: SERCs and LEPCs will also receive 

follow-up written reports of SSI releases. Because these releases are 

unlikely to generate a response action and will have been evaluated already 

during the telephone notification, little time is expected to be required to 

process these reports beyond filing and recordkeeping activities. It is 

estimated to require 0.5 hours of government time for this activity, at a cost 

of $11.50. 

The total estimated annual costs to both industry and government are 

summarized in Exhibit 4-6 for facilities other than those with coal-fired 

boilers. Estimated annual costs for all facilities are presented in Exhibit 

4-7. 

4.4 FIRM LEVEL ECONOMIC EFFECTS 

The estimated costs of the final regulation are small relative to the 

sales and revenues generated by the industries most likely to be affected by 

the final regulation. The average facility handling radionuclides is not 

expected to experience a radionuclide release above the final RQ. The 

analysis estimates that there will be approximately 59 incremental reportable 

releases annually from Nuclear Regulatory Commission, Agreement State, and DOE 

facilities, and about 1,000 facilities reporting releases of radionuclides 

that occur in a continuous manner. There are approximately 950,000 facilities 

potentially affected by the final regulation. The probability that any 

4-17 
EXHIBIT 4-6 

TOTAL COSTS OF REPORTING UNDER SECTION 103(f)(2) 

(EXCLUDING FACILITIES WITH COAL-FIRED BOILERS) 

P.76 

ACTION UNIT COST NUMBER OF REPORTS 

OR NOTIFICATIONS 

FIRST YEAR 

COSTS 

SUBSEQUENT 

YEAR COSTS 

INDUSTRY 

Provide Initial 

Notification to 

NRC, SERC, LEPC 

Submit Written 

Notification to 

OSC, SERC, LEPC 

Submit Annual 

$107.40 

$180.00 

TOTAL COSTS: 

ANNUALIZED COSTS: 

986 

986 

Report to OSC 

Revisit Initial/ 

Annual Report 

Report an SSI to 

NRC, SERC, LEPC 

Follow-up Report 

of an SSI to 

SERC, LEPC 

Recordkeeping 

$180 

$ 90 

$129 

$117 

$18 

00 

00 

90 

30 

50 

3 

3 

3 

986 

49 

599 

599 

,599 

$105,896 

$177,480 

$4,410 

$467,510 

$422,163 

S 66.582 

$177,480 

$4,410 

$467,510 

$422,163 

S 66.582 

$1,244,041 $1,138,144 

$1,150,000 

Costs are annualized over a ten year period at a discount 

rate of 4 percent. All costs are in 1987 dollars. 

4-18 
EXHIBIT 4-6 (continued) 

TOTAL COSTS OF REPORTING UNDER SECTION 103(f)(2) 

(EXCLUDING FACILITIES WITH COAL-FIRED BOILERS) 

P.77 

ACTION UNIT COST NUMBER OF REPORTS 

OR NOTIFICATIONS 

FIRST YEAR 

COSTS 

SUBSEQUENT 

YEAR COSTS 

Process Initial 

Notification 

Process Written 

Initial Reports 

Process Annual 

Reports 

Revisiting Initial/ 

Annual Reports 

Process SSIs 

Process Follow-up 

Report of an SSI 

$17 

$69 

$23 

$46 

$34 

$23 

25 

00 

00 

00 

50 

00 

986 

986 

986 

49 

3,599 

3,599 

TOTAL COSTS: 

ANNUALIZED COSTS: 

TOTAL ANNUALIZED COSTS TO 

INDUSTRY AND GOVERNMENT: 

$17,009 

$68,034 

$2,254 

$124,166 

$22,678 

$2,254 

$124,166 

$ 82.777 $ 82.777 

$294,239 $231,875 

$240,000 

$1,390,000 

Costs are annualized over a ten year period at a discount 

rate of 4 percent. All costs are in 1987 dollars. 

4-19 
EXHIBIT 4-7 

TOTAL COSTS OF REPORTING UNDER SECTION 103(f)(2) 

FOR ALL FACILITIES 

ACTION UNIT COST NUMBER OF REPORTS 

OR NOTIFICATIONS 

FIRST YEAR 

COSTS 

SUBSEQUENT 

YEAR COSTS 

INDUSTRY 

Provide Initial 

Notification to $107.40 

NRC, SERC, LEPC 

Submit Written 

Notification to $180.00 

OSC, SERC, LEPC 

Submit Annual 

2,710 

2,710 

Report to OSC 

Revisit Initial/ 

Annual Report 

Report an SSI to 

NRC, SERC, LEPC 

Follow-up Report 

of an SSI to 

SERC, LEPC 

Recordkeeping 

TOTAL COSTS: 

ANNUALIZED COSTS: 

$180 

$ 90 

$129 

$117 

$18 

00 

00 

90 

30 

50 

2 

9 

9 

9 

710 

136 

892 

892 

892 

$291,054 

$487,800 

$12,240 

$183.002 

$487,800 

$12,240 

$1,284,971 $1,284,971 

$1,160,332 $1,160,332 

$183.002 

$3,419,398 $3,128,344 

$3,160,000 

Costs are annualized over a ten year period at a discount 

rate of 4 percent. All costs are in 1987 dollars. 

4-20 
EXHIBIT 4-7 (continued) 

TOTAL COSTS OF REPORTING UNDER SECTION 103(f)(2) 

FOR ALL FACILITIES 

ACTION UNIT COST NUMBER OF REPORTS 

OR NOTIFICATIONS 

FIRST YEAR 

COSTS 

SUBSEQUENT 

YEAR COSTS 

GOVERNMENT 

Process Initial 

Notification 

Process Written 

Initial Reports 

Process Annual 

Reports 

Revisiting Initial/ 

Annual Reports 

Process SSIs 

Process Follow-up 

Report of an SSI 

$17 

$69 

$23 

$46 

$34 

$23 

25 

00 

00 

00 

50 

00 

2 

2 

2 

OV 9 

710 

710 

710 

136 

892 

892 

TOTAL COSTS: 

ANNUALIZED COSTS: 

TOTAL ANNUALIZED COSTS TO 

INDUSTRY AND GOVERNMENT: 

$46,748 

$186,990 

$6,256 

$341,274 

$227.516 

$ 808,784 

$660,000 

$3,820,000 

$62,330 

$6,256 

$341,274 

$227.516 

$637,376 

Costs are annualized over a ten year period at a discount 

rate of 4 percent. All costs are in 1987 dollars. 

4-21 
P.80 

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 or production processes. 

The types of facilities that may be affected by the final regulation 

vary widely from small laboratories to large uranium mining operations. It is 

not possible to identify the facilities that are 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 the costs for a facility experiencing a reportable 

release under the final regulation. These costs are as follows: 

Notification Costs -- $ 197 to the National Response Center 

$ 177 to State and Local officials 

Recordkeeping Costs -- $ 18.50 

Response Costs -- $5,608 

The total cost to a facility or vessel experiencing a reportable radionuclide 

release, therefore, is estimated to be approximately $6,000. The actual costs 

that a facility will incur will depend largely on cleanup costs, estimated to 

range from $0 to $55,637, with a weighted average cleanup cost of $5,608. 

The total annual burden under the final RQ adjustments experienced by 

all affected parties depends on the size and number of reportable releases. 

The burden imposed by the CERCLA and SARA 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, in fact, 

would experience no costs from the notification requirements because they have 

no reportable releases. Even assuming a reportable release occurs at a 

facility, the likely costs incurred are small compared with the overall 

economic situation at that facility. Cleanup and other response actions are 

not required by this regulation; facilities are liable under CERCLA for any 

response costs or natural resource damages regardless of whether the release 

is reportable. A conclusion can thus be made that the regulation will not 

have a significant impact on any firm, large or small, that potentially incurs 

a radionuclide release. 

4-22 
P.81 

CHAPTER 5 

SENSITIVITY ANALYSIS 

Several times in this analysis, data were used whose margin of error 

could have been improved through further research. Similarly, in several 

instances, key assumptions in the study were made that used the best available 

information from a limited data base of historical radionuclide releases. 

Under these circumstances, it is important to conduct a sensitivity analysis 

to test the impact that changing key assumptions would have upon the results 

of the analysis. The first two sections of this chapter conduct a sensitivity 

analysis on the results of this economic impact study. Section 5.1 discusses 

the importance of a sensitivity analysis and establishes the ranges for the 

key variables and assumptions that will be tested; Section 5.2 presents the 

results of the sensitivity analysis using these ranges; Section 5.3 describes 

the results of a statistical analysis of the radionuclide data base; and 

Section 5.4 summarizes the results of the sensitivity analysis. 

5.1 CONCEPTS AND KEY VARIABLES 

A sensitivity analysis indicates how the results of an analysis might 

vary if some of the basic components or assumptions of the study were 

different. If, for example, an 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 bracket the true value, the analyst may use each of the 

values in the sensitivity analysis to see how the results might differ. 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. An analyst can make a reasonable guess about the likely value 

for the variable; the analyst may select other values to determine the 

sensitivity of the results to that choice. This technique has the advantage 

of indicating the range of possible results, although it does not indicate 

whether the "true" result is included. 

A sensitivity analysis often adds information because it provides upperand lower-bound estimates of the results. Nonetheless, the range of results 

may be too small or too large, depending on the quality of the values used in 

the sensitivity analysis. The values obtained both in the initial analysis 

and the sensitivity analysis ultimately rely on the quality of the input data. 

The sensitivity analysis in this study tests the impact of changing six 

basic assumptions that have been used during the analysis. These assumptions 

are: (1) the number of incremental reportable episodic releases; (2) the 

hours required, and therefore, the unit cost of notification; (3) the 

frequency of off-scene monitoring; (4) the frequency of on-scene monitoring; 

(5) the frequency of cleanups by responsible parties; and (6) the frequency of 

direct removal by the government. The last four assumptions subject the 

frequency of actions to the sensitivity test rather than the unit costs of 

performing such actions because the cost estimates are considered reasonable, 

and adjustments in the cost estimates are overwhelmed by the frequency 

estimates. 
P.82 

The values used in the base case for each of these six key assumptions 

are varied in the following manner in the sensitivity analysis: 

1. Number of incremental reportable episodic releases. The number of 

incremental reportable releases is perhaps the most important variable on 

which costs are estimated. The analysis in Chapter 4 estimates that there 

will be 59 annual incremental reportable releases. This estimate may vary 

because the estimates of under-reporting could be inaccurate; the AEOD data 

set may not contain representative facilities; the number of releases may not 

be proportional to the number of facilities; or the assumption that 13,000 

Agreement State and 470 DOE facilities release radionuclides in a pattern 

similar to Nuclear Regulatory Commission facilities may be inaccurate. In 

order to reflect the order of magnitude changes in costs that would result 

from large differences in the number of incremental reportable releases, the 

sensitivity analysis will estimate the costs of halving and doubling the base 

case estimate of 59. Thus, the following assumptions are tested: 

Number of Incremental Releases 

Low Estimate Base Case High Estimate 

30 59 120 

2. Notification hours. The costs associated with notification of the 

National Response Center and state and local emergency response commissions 

represent approximately 60 percent of total costs to regulated parties. The 

base case analysis in Chapter 4 assumes that 3 hours of managerial time and 2 

hours of technical time would be required for each episodic release to notify 

the National Response Center. Notification may take more or less time 

depending on factors such as the size of the release and the type of 

radionuclide released. To estimate the range of notification costs that 

regulated parties might experience, the estimate of hours are halved and 

doubled for the sensitivity analysis, resulting in the following unit cost 

estimates: 

Managerial and Technical Hours Required for Notification 

Low Estimate Base Case High Estimate 

$99 $197 $394 

3. Frequency of off-scene monitoring. In Chapter 4, it is assumed that 

all releases require the government to incur costs for notification 

processing, but that some of these releases (30 percent) require no further 

government action, and that the remainder (70 percent) do require the 

government to perform off-scene monitoring. The sensitivity analysis tests 

scenarios in which lower and higher percentages of episodic releases reported 

to the National Response Center require off-scene monitoring. The three sets 

of estimates for frequency of off-scene monitoring used in the sensitivity 

analysis are: 

Frequency of Off-Scene Monitoring 

Low Estimate Base Case High Estimate 

.35 .70 .90 

5-2 
P.83 

4. Frequency of on-scene monitoring. It also is important to' examine 

the sensitivity of estimates for the frequency of on-scene monitoring efforts 

that will be needed (i.e., the percent of reportable releases that result in 

federal, state, or local officials providing monitoring at the scene of the 

release). On-scene monitoring accounts for approximately 13 percent of the 

total cost of the final regulation and for 16 percent of the government's 

share of the total costs. 

Frequency of On-Scene Monitoring 

Low Estimate Base Case High Estimate 

.10 .20 .40 

5. Frequency of cleanups by regulated parties. The base case assumes 

that there is a measurable difference in the percent of episodic releases to 

which regulated parties respond, depending on whether the release is 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 that result from response activities can be attributed to the final 

regulation that adjusts the RQs. The sensitivity analysis tests how the 

results are changed if the incremental change in cleanup activities by 

regulated parties is 0, and if the incremental percentage is higher than the 

base case scenario of 5 percent. 

Incremental Frequency of Cleanups by Regulated Parties 

Low Estimate Base Case High Estimate 

.00 .05 .20 

6. Frequency of direct removal by government. The base case assumes 

that a direct removal is necessary by the government in 5 percent of all 

episodic releases. The sensitivity analysis tests the effect on the results 

if government removal were necessary in a lower percentage of reportable 

radionuclide releases, and if the government would be required to become 

involved in a direct removal action in a greater percentage of radionuclide 

releases. 

Frequency of Government Direct Removal 

Low Estimate Base Case High Estimate 

.025 .05 .20 

After the sensitivity analysis is conducted for each of these six sets 

of assumptions, a seventh sensitivity test is conducted by combining all of 

the low and all of the high estimates together. For example, in order to see 

the impact of all of the low estimates, the analysis assumes that there are 30 

incremental reportable releases, the notification cost is $99, there is a 35 

percent chance of the government conducting off-scene monitoring, a 10 percent 

chance of the government conducting on-scene monitoring, no change in the 

percentage of releases to which regulated parties respond, and a 2.5 percent 

chance that the government will conduct a direct removal. The combination 

5-3 
of these six assumptions produces a lower-bound estimate for the sensitivity 

analysis. The same is done for the high estimates to produce an upper-bound 

estimate. 

5.2 RESULTS OF THE SENSITIVITY ANALYSIS 

This section presents the results of the sensitivity analysis, and 

includes a description of changes in the estimated costs to the government and 

to regulated parties that occur from reporting and cleanup activities 

described in the last section. The results of the sensitivity analysis are 

summarized in Exhibit 5-1. 

1. Number of incremental reportable releases. Estimates of the number 

of incremental reportable releases affect all of the estimates of costs 

that result from increased notification, recordkeeping, and response 

activities by regulated parties and government officials. Exhibit 5-1 

presents the results of changing the estimated number of incremental 

reportable releases and compares the cost of the final regulation to the base 

case of 59 releases. 

2. Notification hours. Varying the estimated number of hours required 

to report releases will affect the cost estimates associated with notification 

acitivities for regulated parties. Exhibit 5-1 presents the results of the 

sensitivity analysis, in which the base case hour estimates are halved and 

doubled. These cost variations only affect regulated parties and would not 

change the costs to government officials of processing the notifications. 

3. Frequency of Government Off-Scene Monitoring. The results of 

variations in the percent of releases that the analysis assumes are necessary 

for the government to become involved are presented in Exhibit 5-1. These are 

costs to the government officials responsible for the off-scene monitoring. 

4. Frequency of Government On-Scene Monitoring. Variations in the 

assumed frequency of on-scene monitoring for radionuclide releases affect the 

costs that the government incurs. Exhibit 5-1 shows the effect on on-scene 

monitoring by assuming that the percent of releases during which the 

government must conduct on-scene monitoring are higher and lower. 

5. Frequency of incremental responses bv regulated parties. Varying the 

assumption concerning the difference in responsible parties' cleanup efforts 

for reportable and unreportable releases leads to different response costs for 

regulated parties. The difference in industry response to reportable releases 

as opposed to unreportable releases is shown in Exhibit 5-1. 

6. Frequency of direct removal bv government. Variations in the assumed 

frequency of direct response and removal by the government affect the costs of 

the final regulation. Exhibit 5-1 shows the effect on the government's costs 

if the government responds 2.5 percent and 20 percent of the time to releases, 

instead of the base case estimate of 5 percent. 

5-4 
EXHIBIT 5-1 

RESULTS OF THE SENSITIVITY ANALYSIS 

Low Estimate. Base Case High Estimate 

Number of incremental 

reportable releases 

Assumption : 

Cost of proposed regulation: 

Notification costs to 

National Response Center 

30 

$130,375 

59 

$256,405 

Incremental frequency of 

cleanups by responsible 

parties 

Frequency of off-scene 

monitoring 

Assumption 

Off-scene monitoring costs 

Cost of proposed regulation 

Frequency of on-scene 

monitoring 

Assumption 

On-scene monitoring costs 

Cost of proposed regulation 

Frequency of direct government removal 

120 

$521,498 

Assumption : 

Notification Costs : 

Cost of proposed regulation: 

$99 

$5,841 

$250,623 

$197 

$11,623 

$256,405 

$394 

$23,246 

$268,028 

Assumption : 

Cost of Cleanups : 

Cost of proposed regulation: 

.00 

0 

$239,861 

.05 

$16,543 

$256,405 

.20 

$66,174 

$306,035 

.35 

$4,522 

$251,882 

.70 

$ 9,045 

$256,405 

.90 

$11,629 

$258,989 

.10 

$15,989 

$240,416 

.20 

$31,978 

$256,405 

.40 

$63,956 

$288,383 

Assumption 

Direct removal costs 

Cost of proposed regulation 

Cost of Proposed Regulation 

with ALL assumptions varied 

.025 

$82,065 

$174,341 

$66,866 

5-5 

.05 

$164,129 

$256,405 

$256,405 

.20 

$656,517 

$748,793 

$1,717,844 
P.86 

Varying all of the low estimate assumptions at one time produces a 

lower-bound estimate of the cost of the final regulation. This estimate is 

approximately $66,900. Conducting the same test for all of the high estimates 

produces an upper-bound cost of the final regulation of approximately $1.72 

million. In addition to these lower and upper-bound estimates, an additional 

$1.39 million must be added for the costs of the annual reports for facilities 

that release radionuclides and report under section 103(f)(2) of CERCLA. 

Therefore, the lower and upper-bound estimates of the cost of the final 

regulation, given the quality of the input data that is available, are 

approximately $1.46 million and $3.11 million, respectively. 

5.3 STATISTICAL ANALYSIS OF EIA RADIONUCLIDE DATA BASE 

The analysis for estimating the number of reportable releases in both 

the baseline situation and under the final regulation implicitly assumes that 

there is no correlation between the size of a release and the identity of the 

radionuclide released. This hypothesis was tested. 

An analysis of variance model (ANOVA) was used to test the hypothesis 

that there is no relationship between the size of a release and the identity 

of the radionuclide. The release observations were grouped by isotope and the 

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 the isotope and mean release amount. 

Therefore, we have assumed that there is no association. 

5.4 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, both for regulated parties and for the government. 

Because data on the health and welfare and environmental effects of altering 

the RQs are not available, this sensitivity analysis is not able to vary these 

effects. 

1 The F-statistic was 1.05 (d.f. of 52; 632) which was a p-value of 0.39. 

5-6 
P.87 

APPENDIX A 

PROFILES OF FACILITIES THAT RELEASE RADIONUCLIDES 

Radionuclide emissions are identified most closely with the nuclear 

power industry, but commonly occur during other activities as well. The 

Nuclear Regulatory Commission, Agreement States delegated authority by the 

Commission, the Department of Defense (DOD), and the Department of Energy 

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

nonindustrial operations that emit radionuclides. In addition, several 

industrial categories not licensed by the Commission or an Agreement State 

also release radionuclides, and may do so at levels that equal or exceed an 

RQ. For example, coal-fired utility and industrial boilers and facilities of 

many mineral extraction industries, such as uranium, aluminum, zinc, copper, 

lead, and phosphorus mining, all release quantities 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. In addition, for facilities whose releases are not federally 

permitted, a further estimate is made of the number of facilities that are 

likely to be releasing daily an RQ on a continuous basis and thus, eligible 

for reporting under section 103(f)(2). Section A.l describes facilities that 

are licensed by the Nuclear Regulatory Commission and Agreement States; 

Section A.2 discusses Department of Defense facilities, most of which the 

Nuclear Regulatory Commission licenses; Section A.3 describes Department of 

Energy facilities; and Section A.4 discusses other facilities potentially 

affected by adjustment of the radionuclide RQs. Coal-fired utility and 

industrial boilers are discussed in greater detail in Appendix B. 

A.l NUCLEAR REGULATORY COMMISSION AND AGREEMENT STATE LICENSEES 

The Nuclear Regulatory Commission has the authority under the Atomic 

Energy Act to license source, byproduct, and special nuclear materials. The 

Commission has delegated to Agreement States licensing authority to regulate 

source, byproduct, and special nuclear materials for facilities within their 

boundaries. As of 1984, the Commission licensed approximately 8,900 

facilities and Agreement States licensed approximately 13,000 facilities.1 

Releases at facilities licensed by the Nuclear Regulatory Commission and 

Agreement States 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 are divided into five 

categories: power reactors, research and test reactors, radiopharmaceutical 

manufacturers, radiation source manufacturers, and other licensees. The 

Commission also licenses most of the Department of Defense facilities, but 

these facilities are discussed separately in Section A.2 of this report. 

U.S. Nuclear Regulatory Commission, 1984 Annual Report, p. 73 
P.88 

Power Reactors 

Power reactors utilize a controlled fission reaction of uranium fuel to 

produce heat. The heat converts water to steam, which 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 in "nuclear incidents" (section ll(q) of the Atomic 

Energy Act) at facilities covered by the Price-Anderson Act are exempt from 

CERCLA reporting requirements (section 101(22)). Releases at Nuclear 

Regulatory Commission and Agreement State facilities that are an RQ or more 

above federally permitted release levels, but do not constitute a nuclear 

incident, must be reported under CERCLA to the National Response Center and 

under SARA to State Emergency Response Commissions (SERCs) and Local Emergency 

Planning Committees (LEPCs). 

Research and Test Reactors 

As of 1983, there were 70 reactors in operation in the United States 

used in basic and applied research, and teaching. The research conducted 

includes testing of reactor designs, components, and safety features, as well 

as work in the fields of physics, biology, and chemistry. 

Radiopharmaceutical Manufacturers 

Radiopharmaceuticals are radioactive chemicals used for medical 

applications and research. In 1979, there were 26 industrial suppliers of 

radiopharmaceuticals producing 65 generally used radionuclides. These 26 

firms exclude firms that purchase radiopharmaceutical products in bulk and 

repackage them in smaller containers (repackagers). 

In 1984, the Commission licensed more than 2,800 medical facilities for 

use of radiopharmaceuticals, and Agreement States licensed approximately 7,000 

facilities.2 Medical facilities use radionuclides in all forms including 

solids, liquids, and gases; uses include diagnostic and therapeutic 

procedures. 

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 licensed by Agreement States. EPA estimates that 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 2,800 

Commission licensees from the total estimate of 10,000, yields roughly the 

7,000 Agreement State licensees. 

A-2 
P.89 

Radiation Source Manufacturing 

"Radiation sources" refer to radioactive materials enclosed in sealed 

containers. They are found in a number of industrial and consumer products 

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 10 curies to 100,000 

curies. 

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. 

Laboratories 

Approximately 700 laboratories are licensed to handle radioisotopes in 

unsealed form.3 These laboratories are located in industry, government 

agencies, and academic and research institutions. They are used to perform 

testing and research and development, and they vary a great deal in size. 

Although some institutions have only one small, multi-purpose laboratory, 

other institutions have up to 300 individual laboratories in several 

buildings. 

Small laboratories tend to specialize in a limited number 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 food and drug testing or water and air quality monitoring. 

The most commonly used radionuclides in laboratory work are tritium, carbon14, 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. 

3 Corbit CD., Herrington W.N., Higby D.P., Stout L.A., and Corley J.P., 

Background Information on Sources of Low-Level Radionuclide Emissions to Air. 

PNL-4670, Prepared for EPA under U.S. DOE Contract by Battelle Memorial 

Institute, September 1983. It is assumed that an equal number of smaller, 

unlicensed laboratories handle unsealed radioisotopes, resulting in a 

estimated total of 1,400 laboratories that are potential sources of low-level 

radioactive emissions. These unlicensed labs are discussed in Section A.4. 

A-3 
P.90 

Waste Disposal Sites 

Although there are six low-level radioactive waste disposal sites 

licensed in the United States, only three are operational. These sites accept 

low-level radioactive wastes in a stabilized form from three major sources: 

power-reactor and fuel cycle 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 that 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, dypsrosium, and 

ytterbium). Thorium also is 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 field fabrication done in the United States. 

Uranium Milling 

Uranium ore is delivered to mills where it is crushed and ground, and 

uranium oxide is extracted chemically. The mill product, also called uranium 

concentrate or yellow cake, then is 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 United States (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 21,800 tons in 

1980.* 

4 U.S. Environmental Protection Agency, Proposed Standard for Radon-222 

Emissions from Licensed Uranium Mill Tailings: Draft Economic Analysis (EPA 

520/1-86-002), Office of Radiation Programs, January 1986. 

A-4 
P.91 

A.2 DEPARTMENT OF DEFENSE FACILITIES 

The Nuclear Regulatory Commission also licenses some Department of 

Defense (DoD) facilities. These facilities, therefore, must comply with 

limits for airborne and liquid discharges to unrestricted areas under 10 CFR 

Part 20 that govern federally permitted releases for all other Nuclear 

Regulatory Commission facilities. 

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 that are similar in design and 

are used to support studies on the effects of nuclear radiation. Both are 

fueled with enriched uranium. 

Nine naval shipyards account for almost all of 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) has authority under 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 that 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 also is 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. An estimated 47 of 

these complexes contain facilities that actively use radionuclides. These 

complexes include laboratories operating diversified programs, and facilities 

conducting weapons production and testing, nuclear materials production, and 

physical research. 

5 Rogers and Associates Engineering Corp., Radioactive Contamination at 

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

A-5 
P.92 

A.4 OTHER FACILITIES 

In addition to the Nuclear Regulatory Commission or Agreement State 

licensees, and facilities controlled by DOE, other facilities may potentially 

release radionuclides at levels that equal or exceed the final adjusted 

radionuclide RQs. These facilities, however,do not have federally permitted 

releases, and thus, have to report releases of an RQ or more under section 103 

of CERCLA. In addition to possible episodic releases, many of these 

facilities release low-level amounts of radionuclides in a manner that is 

"continuous" and "stable in quantity and rate," and therefore, may be subject 

to the continuous release reporting requirements under section 103(f)(2). 

These facilities, principally coal-fired boilers, mineral and energy 

extraction and processing facilities, and natural gas furnaces are considered 

in further detail below. 

Coal Mines 

As of 1987, there were approximately 1,980 underground and 2,120 surface 

mines in operation in the United States, producing approximately 919 million 

short tons of coal. Coal production has increased approximately 3 percent 

annually over the last several years, despite a reduction in the number of 

active mines and in total employment in the industry. Increases in production 

have largely resulted from the continued growth of efficient mining on a large 

scale. Mining in the states of Kentucky, West Virginia, and Wyoming account 

for nearly 50 percent of the annual production. 

Coal contains mineral matter including trace quantities of 

radionuclides, sulfides, chlorides, hydrates, and oxides. The Atomic Energy 

Act does not give the Nuclear Regulatory Commission (or Agreement States) the 

authority to license releases of these radionuclides, which are principally in 

the uranium and thorium series. As coal is burned, the minerals in the coal 

melt and then condense into a glass-like ash. The mineral content of the coal 

will determine the concentration of the contaminants in the ash. To remove 

some of this mineral content and achieve other desired qualities, coal is 

frequently cleaned in a three-step process: size reduction and screening, 

separation of impurities, and dewatering and drying. Coal is reduced in size 

through a crushing process that liberates some impurities and also makes the 

coal easier to burn in some types of boilers. Impurities can be further 

removed from coal by additional cleaning. Finally, the coal is dewatered to 

reduce its moisture content to acceptable levels. 

Coal cleaning plants are often located close to or on the site of the 

mine and may stockpile quantities of uncleaned or cleaned coal at the facility 

in unenclosed areas. Based on average concentrations of radionuclides in 

coal, approximately 2,360 tons of coal contain an RQ of a mixture of naturally 

occurring uranium series and thorium series radionuclides in secular 

equilibrium.6 Any mine producing this quantity of coal on a daily basis may 

dump this amount outside on a daily basis and thus, be required to report 

6 See Appendix B for a detailed derivation of this figure and the 

assumptions underlying it. 

A-6 
P.93 

releases of radionuclides under CERCLA. Based on the average number of 

working days at coal mines throughout the United States, this daily production 

quantity can be converted to an annual figure:7 

224 days/year * 2,360 tons/day = 528,600 tons/year 

There are 363 mines in the United States with an annual production in 

excess of 500,000 tons.8 Although the operations of these facilities have not 

been characterized in great detail, it is reasonable to assume that these 

facilities potentially may release an RQ of radionuclides by the dumping or 

moving of coal on a regular basis. 

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. More than 

600 million tons of coal are burned each year in utility and industrial 

boilers. 

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.9 In early 1987, there were approximately 1,400 

coal-fired units on-line with a total generating capacity of 300 gigawatts.10 

Coal-fired industrial boilers mainly produce process steam and hot water 

to generate electricity (for the producer's own use), and to 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.11 

Not all of these 52,600 facilities, however, release an RQ of 

radionuclides on a continuous basis. Appendix B provides a detailed 

7 Energy Information Administration, Coal Production 1987. EIA, 

Department of Energy, 1988, p.70.. 

8 Ibid.. p.28. 

9 U.S. Department of Commerce, Statistical Abstract of the U.S.. (1985), 

105th Edition. Government Printing Office, Washington, D.C, p. 564. 

10 U.S. Environmental Protection Agency, Report to Congress: Wastes from 

the Combustion of Coal by Electric Utility Power Plants (EPA 530-SW-88-002), 

Office of Solid Waste and Emergency Response, EPA, February 1988. p.2-22. 

11 U.S. Environmental Protection Agency, The Radiological Impact of CoalFired Industrial Boilers (Draft). Office of Radiation Programs, October 1981. 

A-7 
P.94 

examination of the potential release pathways of radionuclides from these 

facilities and an estimate of the number of facilities likely to meet or 

exceed an RQ on a daily basis. 

Unlicensed Laboratories 

Approximately 700 unlicensed laboratories use small quantities of 

radionuclides in highly controlled environments. These facilities do not need 

licenses because they use radionuclides in quantities and concentrations below 

the licensing thresholds. Because of the low quantities and concentrations of 

radionuclides used at these laboratories, it is unlikely that a facility uses 

or stores sufficient quantities of any radionuclide to release at or above the 

RQ on a continuous basis. Episodic radionuclide releases at or above an RQ 

are more probable and would have to be reported under CERCLA. 

Low-energy Accelerators 

There are approximately 1,500 low-energy accelerators in the United 

States. Based on estimates of annual emissions from typical particle 

accelerators, radionuclide emissions from these facilities do not exceed RQs 

(EPA'84 p.3.2-4). As these facilities do not stock large quantities of 

materials, it is also unlikely that other release paths are significant. 

Uranium Mining 

There are several different types of uranium mines and extraction 

processes, including 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.12 

Domestic uranium is mined almost exclusively 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.13 

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

GJO-100(83), Grand Junction, Colorado, January 1983, p. 9. 

13 Ibid, p. 9. 

A-8 
P.95 

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, consequently, the industry currently is faced with 

excess capacity and supply, and the potential for increased competition from 

imports. 

Releases of radon from underground uranium mines are federally permitted 

under section 112 of the Clean Air Act. Releases of other radionuclides are 

not necessarily permitted and could regularly exceed RQs.1A It is reasonable 

to assume, therefore, that approximately 180 uranium mines could be affected 

by the CERCLA notification requirements, but are likely to report continuous 

releases under the provisions of section 103(f)(2). 

Aluminum Industry 

Several materials are used in the production of aluminum. Bauxite, the 

principal aluminum ore found in nature, 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. EPA reports that 

atmospheric emissions of radon from bauxite mines could exceed the RQ on a 

continuous basis (EPA'80 p.4.5-9). 

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 alumina 

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. 

These smelters release radionuclides to the air from the uranium and 

thorium series at extremely low levels, typically in a range from about IO"6 

curie per day to nearly IO"7 curie per day, which is well below the lowest 

adjusted RQ value (EPA'84, p.7.1-8). The data on emissions from smelters, 

however are limited to smokestack emissions and do not provide an adequate 

basis for judging emissions from other sources (e.g., piles, lagoons). 

Maintaining a conservative bias therefore, this analysis assumes that aluminum 

smelters could release an RQ of radon on a daily basis and would be affected 

by the radionuclide RQ adjustment rulemaking. 

1A U.S. Environmental Protection Agency, NESHAP: Radionuclides: 

Background Information Final Rule. Volume II (EPA 520/1-84-022-2), Office of 

Radiation Programs, U.S. EPA, October 1984, Chapter 5. 

A-9 
P.96 

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. Of the fifteen operating primary smelters in the United States, all 

are located in rural areas with low population densities. Ninety percent of 

the 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.15 

Modeling of these facilities indicate that atmospheric emissions of 

radon from copper mines, on average, could exceed an RQ on a daily basis 

(EPA'80 p.4.5-9). The data on radionuclide releases from smelters are limited 

to smokestack emissions and do not provide an adequate basis for judging 

releases from all sources (smokestacks, piles, lagoons). Given that many of 

these facilities are co-located, this analysis assumes that copper smelters 

also exceed the RQ for radon and must report under section 103. 

Zinc Industry 

Zinc usually is found in nature as a sulfide ore called sphalterite. 

The ores are processed at the mine to form concentrates typically containing 

62 percent zinc and 32 percent sulfur. Based on a model facility, studies 

indicate that atmospheric emissions of radon from zinc mines, on average, 

could exceed the RQ on a continuous basis (EPA'80 p.4.5-9 and EPA'84 p.7.3-3). 

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. Emissions 

from smelters are in levels ranging from 1.1x10"* curie to 1.5xl0"6 curie per 

day, all well below the final RQ values. Radon-222 is released at an expected 

level of 0.001 curie per day (EPA'84, p.7.3-4). Because information on 

releases via other pathways is not available, this analysis assumes that these 

facilities meet or exceed the RQ for at least radon. 

Lead Industry 

Galena is the principle lead-bearing ore found in nature. It contains 

small amounts of copper, iron, zinc, and other trace elements (including 

radionuclides). Lead smelting involves three processes: sintering, 

furnacing, and drossing. Sintering converts the ore from a sulfide to an 

15 Schroeder, H.J., Mineral Commodity Profiles -- Copper. U.S. Department 

of the Interior, Bureau of Mines, Washington, D.C, 1979. 

A-10 
P.97 

oxide or sulfate form and prepares the feed materials for furnacing. 

Furnacing reduces the oxide feed to lead metal. Drossing reduces the copper 

content of the lead bullion from the furnace. After drossing, additional 

refining steps, which are dictated by the specific impurities present and the 

intended end-use of the product, are performed to produce the purified lead 

metal. 

There are five primary lead smelters in the United States. Three 

facilities have integrated smelter/refining complexes; two facilities ship 

their drossed lead bullion away for final processing. Three of the smelters 

are located in Missouri and process only ores from the Missouri lead belt. 

The remaining smelters are located in Texas and Montana. The two western 

smelters are custom smelters that are designed to handle larger variations in 

ore composition than the Missouri smelters. Both domestic and foreign ores 

are smelted at the western plants. In 1979, total production from primary 

lead smelters was 594,000 tons.16 

Available information is inadequate to determine total releases from 

these facilities, so this analysis assumes that releases of radionuclides from 

these facilities could meet or exceed an RQ on a daily basis. 

Phosphate Rock Processing Plants 

Mining of phosphate rock is the fifth largest mining industry in the 

United States in terms of quantity of material mined. Total 1978 production 

was approximately 57.9 million metric tons. Prior to 1983, twenty firms were 

operational, with plants in 31 locations. The ten largest producers 

controlled about 84 percent of the capacity, with the two largest firms 

controlling over 34 percent 17 

Phosphate rock plants (generally mine and beneficiation facilities) most 

likely regularly exceed the RQ for radon. Phosphate ore drying and grinding 

plants modeled by EPA appear to release below the RQ for most radionuclides 

but could release an RQ of radon (EPA'80, p.4.3-11 - 4.3-15). Given that many 

of these facilities are co-located with phosphate rock plants, a conservative 

assumption is to assume that releases from these grinding and drying plants, 

either independently or in conjunction with mine and beneficiation operations, 

also exceed the RQ for radon. 

16 U.S. Department of Commerce, U.S. Industrial Outlook for 200 

Industries with Projections for 1984. Washington, D.C, 1980. 

17 U.S. Environmental Protection Agency, Phosphate Rock Plants. 

Background Information for Proposed Standards (EPA 450/3-79-017), Office of 

Air Quality Planning and Standards, 1979, p. 7-5. 

A-ll 
P.98 

Elemental Phosphorus Plants 

Another type of phosphorus plants produces elemental phosphorus, which 

is used primarily in the production of high grade phosphoric acid, phosphatebased detergents, and organic chemicals. Almost half of the elemental 

phosphorus produced domestically is used in the production of detergents. 

Metal treatment, foods and beverages, and chemicals are the other major end 

uses for elemental phosphorus. Approximately 10 percent of the total U.S. 

marketable phosphate rock mined is used for elemental phosphorus production. 

Four major corporations operate six plants in the U.S. The total amount of 

elemental phosphorus produced in 1983 was approximately 366,000 tons (EPA'84, 

p.6.3-1). 

These plants exceed the RQs for several radionuclides on a continuous 

basis, although some of the releases, such as of Polonium-210, are federally 

permitted (EPA'80, p.4.3-1 - 4.3-10). 

Wet Process Fertilizer Plants 

Most phosphate rock produced in the United States is used for the 

production of high-analysis agricultural fertilizers. In 1976, 50 million 

metric tons of phosphate rock were used to produce 9 millon metric tons of 

phosphoric acid, the starting material for ammonium phosphate and triple 

superphosphate fertilizers. 

Phosphate rock is not a pure compound, but a fluoroappitite material 

containing minor quantities of fluorine, iron, aluminum, silica, and uranium. 

Wet process phosphoric acid is produced by mixing ground phosphate rock with 

93 percent sulfuric acid and water in a digester. In the process, gypsum 

(calcium sulfate) is produced as a byproduct. Following the reaction in a 

digester, the mixture of phosphoric acid and gypsum is pumped to a filter 

which mechanically separates the particulate gypsum from the phosphoric 

acid.18 In 1981, Florida and North Carolina supplied 86 percent of the 

domestic and 33 percent of the world's phosphate requirements.19 

Concentrations of natural uranium and its decay products (including 

radium, the immediate parent of radon) in phosphate deposits range from ten to 

one hundred times the concentration of uranium in other natural rocks and 

soils (49 FR 43914, October 31, 1984). Most of radium-226 contained in the 

phosphate rock is transferred to the gypsum byproduct. Consequently, plant 

operation emissions and releases from waste gypsum piles generally exceed the 

RQ for radon as modeled by EPA (EPA'80 p.4.3-22) and, therefore, would be 

18 U.S. Environmental Protection Agency, Radiological Impact Caused by 

Emissions of Radionuclides into Air in the United States. Preliminary Report, 

EPA 520/7-79-006, p. 6.2-1. 

19 Ibid. 

A-12 
P.99 

subject to the reporting requirements under section 103(f)(2). At least 

commenter agreed with this assessment.20 

one 

Iron Mines and Smelters 

Crude iron ore production in the United States amounted to 215 million 

tons in 1975, with open pit mines accounting for 96 percent of the ore 

produced. Twenty states have significant iron ore deposits but Michigan, 

Minnesota, and Wisconsin produced 85 percent of the ore mined in 1975. 

Based on analysis of a representative model facility, studies suggest 

that atmospheric emissions of radon from iron mines, on average, exceed the RQ 

on a continuous basis (EPA'80 p.4.5-9). No data on emissions from smelters 

are available. Maintaining a conservative bias, we will assume that iron 

smelters also exceed the RQ for radon and must report under section 103. 

Fluorospar Mines 

Fluorospar mines are located in Illinois, Kentucky, Montana, Nevada, New 

Mexico, Texas, and Utah, but Hardin County, Illinois accounts for 

approximately 75 percent of production. The average production per mine was 

15,000 short tons in 1975 and total production amounted to approximately 

375,000 tons. 

Emissions from mining and milling operations at these facilities 

including those from tailing piles do not exceed the RQs for relevant 

radionuclides (EPA'80 p.4.5-9). 

Clay Extraction Facilities 

Clay is produced throughout the united States, with Georgia, Texas, and 

Ohio being the leading producers. In 1975, 1,317 mines produced approximately 

49.4 million tons, mostly from surface mines. 

Emissions of radon from clay extraction facilities, as modeled by EPA, 

fall just below the daily RQ (EPA'80 p.4.5-9). Information on releases of 

other radionuclides and other release pathways are inadequate or unavailable. 

Because the annual production amount per mine is small relative to other 

mineral extraction industries and because there is little or no waste 

associated with this mining, it appears unlikely that releases of 

radionuclides via other pathways could meet or exceed an RQ on a regular 

basis. 

20 Mobil Mining and Minerals Company commented: "Based on available 

data, calculations show that radon emissions from the three phosphogypsum 

storage areas in Pasadena and one storage area in DePue will all exceed the RQ 

for radon." (Commenter 5, p.11, Comment Response Document to Radionuclide 

Rule). 

A-13 
P.1 

Limestone Extraction Facilities 

In 1975, more than 2,900 quarries and underground mines produced 

approximately 67,000,000 tons of limestone. These quarries and mines are 

located throughout the United States, but the states of Illinois, Missouri, 

Pennsylvania, Ohio, and Texas account for nearly 40 percent of this annual 

production. Mined limestone is then crushed into more usable forms at 

processing plants. There is no waste associated with this processing. 

Emissions of radon from limestone extraction facilities, as modeled by 

EPA, are below the daily RQ (EPA'80 p.4.5-9). Information on releases of 

other radionuclides and other release pathways are inadequate or unavailable. 

Geothermal Energy Plants 

Dissolved radon gas in subterranean water can be liberated and vented to 

the atmosphere in geothermal energy plants. At the time of the EPA report, 

only one facility was operating in the U.S. and it exceeded the RQ for Radon 

(EPA'80 p.4-6A-l - 4.6A-7). It is likely that any additional plants that have 

come on-line since then do also. 

Natural Gas Extraction and Processing Facilities 

In 1987, over 20,000,000 million cubic feet (MMcf) of natural gas were 

withdrawn from the ground by nearly 250,000 natural gas wells and by some 

fraction of the 620,000 oil wells. Of the approximately 17,000,000 MMcf of 

marketed natural gas production, over a third was delivered to industrial 

facilities and about a quarter to residential consumers. Electric utility 

consumers, although few in number, consumed approximately 16 percent of the 

1987 volume. Natural gas is produced in 32 states but Texas and Louisiana 

account for nearly 60 percent of annual production, and together with Alaska 

and Oklahoma, represent over 77 percent of the gross production for 1987. 

Underground natural gas contains quantities of dissolved radon produced 

by the natural decay of elements in the surrounding rock. When natural gas is 

extracted from the ground, the radon gas may be released to the environment 

through venting, flaring, or spot releases. Spot releases that equal or 

exceed an RQ are typically associated with malfunctions and would have to be 

reported under CERCLA section 103(a); releases of an RQ or more of radon from 

venting and flaring may be reported under section 103(f)(2). 

Concentrations of radon in natural gas vary, but average values are on 

the order of 100 pCi/liter of natural gas.21 At this concentration, the 

quantity of natural gas containing an RQ of radon is calculated as follows: 

21 Letter from Chevron Corporation, dated May, 13, 1987, Public Comment 

to Notice of Proposed Rulemaking, (Commenter 102RQ-RN-6-7), p.6. 

A-14 
P.2 

Quantity of natural gas -= RO of radon 

containing an RQ of radon Concentration of radon 

in natural gas 

100.000.000.000 oCi 0.0353 liters 

100 pCi/1 x cu. ft. 

35,300,000 cu. ft. 

= 35.3 MMcf (million cubic feet) 

Natural gas wells typically vent or flare less than 1 percent of their 

production, suggesting that a well would have to extract 3,530 MMcf per day to 

release an RQ of radon to the air through routine venting and flaring.22 This 

amount of gas exceeds the daily production of existing wells; therefore, 

natural gas wells are assumed not to be affected by the radionuclide RQ 

adjustment regulation. 

The production of natural gas is also associated with oil production. 

For some wells producing oil, it is uneconomical to recover the associated 

extraction of natural gas. Consequently, for these facilities, all of the 

natural gas removed from the ground is flared, usually under a state 

permitting process. The upper limit for such flaring under permit is 

typically about 40,000 cu. ft. per day, several orders of magnitude below what 

would need to be flared to release an RQ of radon.23 Therefore, oil wells 

also are assumed not to be affected by the radionuclide RQ adjustment 

regulation. 

Natural gas is often processed before distribution in large plants with 

considerable throughput quantities. Although gas processing plants generally 

control routine venting and flaring to a greater extent than wells, it is 

reasonable to assume that 1 percent of daily throughput for these facilities 

is lost to the environment. As calculated above, to release an RQ of radon 

would require a throughput of 3,530 MMcf per day; no plant in the United 

States has such a capacity.2* 

Gas-Fired Boilers 

Large natural gas boilers are used to produce heat and process steam in 

many large refining and petrochemical plants, in municipal facilities, and in 

utility power plants. The largest boilers are used to generate electricity 

22 Across the industry, venting and flaring accounts for approximately 

0.6 percent of annual production, although some facilities may have higher 

rates. Energy Inform 

23 Communication with Texas Railroad Commission, Oil and Gas Division, 

January 12, 1989. 

24 Energy Information Administration, Natural Gas Monthly. August 1988, 

EIA, Department of Energy, 1988, p.5. 

A-15 
P.3 

for public consumption. In 1987, electric utilities consumed approximately 

2.84 trillion cubic feet of natural gas, roughly 16 percent of total 

consumption for that year. The amount of natural gas consumed by electric 

utilities has declined over the last eight years, with annual consumption 

tending to move in the opposite direction of oil prices, reflecting the 

ability of many of these boilers to burn either product. 

When natural gas is burned in these boilers, the radon dissolved in the 

gas is liberated and released to the environment. The quantity released will 

depend on the volume of gas burned and the concentration of radon in the gas. 

As calculated above, at a radon concentration of 100 pCi/liter of natural gas, 

35.3 MMcf of natural gas contains an RQ of dissolved radon gas. If all the 

radon is released upon burning, then this quantity is also the amount of gas 

that needs to be burned to trigger a reportable release under section 103. To 

calculate the number of gas-fired boilers likely to burn this quantity of gas 

on a regular basis, this quantity of natural gas is converted to a measure of 

its energy potential. A cubic foot of natural gas contains approximately 

1,003 British thermal units (Btus) of energy, thus: 

35.3 MMcf = 35,300,000 cu. ft 

35,300,000 cu. ft./day 

x 1.003 Btus/ cu. ft. 

35,400,000,000 Btus/day 

Approximately 10,000 Btus are required to generate a kilowatt-hour (kwh) of 

electricity, so 

(35,400,000,000 Btus/day)/(10,000 Btus/kwh) = 3,540,000 kwh/day 

= 3,540 MWh/day 

Therefore, a gas-fired boiler capable of producing 3,540 MW-hour per day could 

potentially burn enough natural gas to release an RQ of radon to the 

environment on a daily basis. This generating capacity translates into a 

daily capacity of 147.5 MW (3,540 MW-hour/24 hours/day). According to the 

Utility Data Institute Power Statistics Data Base, there are approximately 225 

utility power plants with natural gas boilers of this generating capacity. 

This number overestimates the actual number of power plants burning enough 

natural gas to release an RQ of radon on a regular basis for two reasons. 

Because many of these boilers can burn either natural gas or oil with slight 

modifications, it is likely that some fraction of this number of power plants 

actually burn oil and not natural gas. In addition, because of the economics 

of electricity generation, these plants seldom operate at 100 percent 

capacity, as assumed in the calculation above. Under a more realistic 

assumption of approximately 50 percent utilization, only about 112 facilities 

are likely to release radon regularly in a continuous and stable manner. 

A-16 
P.4 

SUMMARY AND CONCLUSIONS 

In addition to the Nuclear Regulatory Commission or Agreement State 

licensees, and facilities controlled by the Department of Energy, other 

facilities may potentially release radionuclides at levels that equal or 

exceed the final adjusted radionuclide RQs. Releases from these facilities 

that do not have federal permits are expected to be continuous and stable in 

quantity and rate and, therefore, are expected to be reported under the 

continuous release reporting requirements of section 103(f)(2). Below is a 

tabulated summary of the estimated number and type of these facilities 

potentially affected by the radionuclide RQ final adjustments: 

Coal mines 

Unlicensed laboratories 

Low-energy accelerators 

Uranium mines 

Aluminum smelters/Bauxite mines 

Copper mines and smelters 

Zinc mines/smelters 

Lead smelters/refineries 

Elemental phosphorus plants 

Phosphate rock processing plants 

Wet process fertilizer plants 

Iron mines/smelters 

Fluorospar mines 

Clay extraction facilities 

Limestone extraction facilities 

Geothermal energy plant 

Oil/Gas Extraction Facilities 

Natural Gas-fired Boilers 

SUBTOTAL: 

Coal-fired utility boilers 

Coal-fired industrial boilers 

TOTAL: 

Total Number 

of Facilities 

Expected to Equal or Exceed 

an RQ on a Continuous Basis 

and Number 

4,100 

700 

1,500 

181 

44 

76 

41 

5 

6 

35 

35 

68+ 

15 

1,317 

2,900 

20 

869,406 

2.005 

882,454 

514 

51.187 

SOME 

NO 

NO 

YES 

YES. 

YES 

YES 

YES 

YES 

YES 

YES 

YES 

NO 

NO 

NO 

YES 

NO 

SOME 

YES 

SOME 

363 

181 

44 

76 

41 

5 

6 

35 

35 

68 

20 

112 

986 

514 

1.210 

956,133 2,710 

A-17 
P.5 

APPENDIX B 

ESTIMATE OF THE NUMBER OF FACILITIES WITH COAL-FIRED BOILERS 

EXPECTED TO REPORT UNDER SECTION 103(f)(2) 

Along with oil and gas extraction facilities and gas-fired boilers, 

coal-fired boilers comprise the overwhelming majority of the facilities that 

potentially release radionuclides. 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. 

At these facilities, coal is stored frequently in large, exposed piles. 

The size, configuration, and characteristics of these piles vary depending on 

the type of facility and the type of boiler. In addition, some 

characteristics of these piles of coal and waste ash change over time as 

material is added to or removed from the piles, or as inventory and waste 

management practices change. Consequently, in order to estimate the number of 

these facilities that could be affected by the radionuclide RQ adjustment 

rulemaking (i.e., the number of utility and industrial facilities that 

potentially could release an RQ or more of a radionuclide from a coal or ash 

pile), it is necessary to make certain assumptions and generalizations that, 

while characteristic of many of these facilities, may not be appropriate for 

the entire universe of facilities with coal-fired boilers. 

Coal is primarily stockpiled in two basic types of geometry: cones and 

rectangular shapes. Conical stockpiles are generally associated with smaller 

piles and smaller boilers, such as at industrial facilities, where ground 

space may be at a premium and the quantity of coal handled on a regular basis 

is not large. For facilities consuming larger amounts of coal and maintaining 

larger piles, coal is often stored in rectangular shapes, facilitating the use 

of machines to move and handle the coal. This analysis considers only 

rectangular piles because only larger facilities are expected to release an RQ 

or more of a radionuclide on a regular basis. 

Ash is generated when coal is burned. The amount of ash generated 

depends on the mineral content of the coal burned and the type of boiler used. 

Some of the ash generated is emitted with the boiler flue gases as fly ash, 

while heavier bottom ash remains at the base of the boiler. Because of 

government regulations on particulate emissions, significant percentages of 

fly ash are often recovered and disposed of with the bottom ash. Waste ash 

generally is landfllled or otherwise disposed of at the facility site in large 

piles or lagoons, although some is used in commercial applications (e.g., 

cement substitute). This analysis assumes that these waste ash piles are 

rectangularly shaped. 

Coal contains mineral matter including trace quantities of naturally 

occurring radionuclides that the Atomic Energy Act does not give the Nuclear 

Regulatory Commission (or Agreement States) the authority to regulate. 
P.6 

Uranium-238 and Thorium-232 and their decay products are the principal 

radionuclides found in significant quantities in coal.1 The radioactivity 

content of coal varies over two orders of magnitude, but most values fall in 

the range of 0.1 to 1.32 pCi/g for the Uranium-238 series and slightly less 

for the Thorium-232 series.2 Based on information used by EPA in the 

development of airborne emission standards, this analysis uses reported mean 

concentrations of 0.43 pCi/g for the Uranium-238 series and 0.35 pCi/g for the 

Thorium-232 series (EPA'84, p.4.0-2). In stable, undisturbed formations over 

long periods of time, members of a radioactive decay series achieve secular 

equilibrium with each other, meaning that the daughter radionuclides are found 

in the same concentration as the parent. Radionuclides in coal have been 

found to be in secular equilibrium; therefore, the above concentration figures 

for Uranium-238 and Thorium-232 are assumed to be valid for all members of the 

respective series. 

Radionuclide releases from these facilities may occur via numerous 

release pathways. There are more than 51,000 industrial boilers and 1,300 

utility boilers. Some facilities have multiple boilers; therefore, some 

smaller number of facilities could potentially be affected by the radionuclide 

RQ adjustment rule. In order to derive a reasonable estimate of the number of 

these facilities potentially affected by the final regulation, five pathways 

by which radionuclides may be released are evaluated: (1) smokestack 

emissions; (2) dumping of radionuclide-laden materials onto stockpiles or 

wastepiles; (3) releases of radon gas to air from coal stockpiles and waste 

ash piles at the facility; (4) releases of radionuclide particulates to air 

from coal and ash piles; and (5) releases of radionuclides from coal and ash 

piles to groundwater. Each of these release pathways is considered below to 

determine the likely number of facilities that could release an RQ or more of 

radionuclides. 

Smokestack Emissions 

EPA background documents supporting the development of airborne emission 

standards indicate that daily emissions from a smokestack at a "model" coalfired boiler are typically substantially below the final adjusted RQs (EPA'84, 

chapter 4). Smokestack emissions should not be sufficiently large to trigger 

the notification requirements under CERCLA. Smokestack emissions, however, 

are not federally permitted releases because in promulgating radionuclide 

emission standards under the National Emission Standards for Hazardous Air 

Pollutants (NESHAP), EPA did not establish standards for radionuclide 

emissions from coal-fired boilers (50 FR 5190: February 6, 1985). If a 

1 U.S. Environmental Protection Agency, Radionuclides Background 

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

(EPA'84). 

2 This range encompasses 90 percent of the coals in an EPA survey 

(EPA'84, p.4.0-2 - 4.0-3). Another evaluation of over 900 coal samples 

reported average values of Uranium-238 and Thorium-232 of 0.6 and 0.5 pCi/g of 

coal respectively. Beck, Harold L. and Kevin M. Miller, Some Radiological 

Aspects of Coal Combustion, letter transmittal of paper, January 1989. 

B-2 
P.7 

facility is substantially larger than the "model" facilities analyzed in the 

NESHAP document and, therefore, could potentially release more than an RQ of a 

radionuclide, those releases would be reportable under CERCLA. For purposes 

of this analysis, it is assumed that smokestack emissions from coal-fired 

boilers would be below the final adjusted radionuclide RQs. ' 

Dumping of Coal and Ash 

The dumping of coal or ash outside a facility in a non-enclosed site 

represents a radionuclide release to the environment. The size of the coal or 

ash load being dumped determines whether the release equals or exceeds the RQ. 

Presented below is an estimate of the number of facilities with coal-fired 

boilers that could be affected by the lower radionuclide RQs simply as a 

result of dumping coal or ash outside their facilities. 

To estimate the quantity of coal that contains an RQ or more of 

radionuclides, it is assumed that all radionuclides of a particular series 

(e.g., Uranium-238 and its daughters) are in secular equilibrium (i.e., are 

found in the same concentration) in the transported coal. Because all member 

radionuclides of a series are present in the coal, the relative contribution 

of each toward meeting or exceeding an RQ must be assessed using the mixture 

rule. Specifically, it is necessary to calculate, for each radionuclide 

released, the ratio of the quantity released in curies to the appropriate RQ. 

If the sum of the ratios for all radionuclides is less than one, the release 

need not be reported. If the sum equals or exceeds one, the release must be 

reported. Mathematically, the mixture rule can be expressed: 

(1) Percentage of an V^ Quantity released (pCi) 

RQ released /_

 RQ (Pci) 

where n is the number of radionuclides in the mixture 

The dumping of coal constitutes a release of members of the Uranium-238 series 

and the Thorium-232 series. To determine the amount of coal containing an RQ 

of radionuclides, the left-hand side of equation (1) is set equal to one, and 

the equation is solved for the "quantity released." The quantity of 

radionuclide released, in turn, depends on the concentration of the 

radionuclides in the coal and the quantity of coal dumped. Because it is 

assumed that radionuclides are in secular equilibrium in coal, the 

concentrations of the daughter radionuclides present in the coal are known to 

equal the concentration of the parent. In addition, the RQs for natural 

Uranium-238 and natural Thorium-232 in secular equilibrium with their 

daughters are 0.052 Ci and 0.011 Ci, respectively. Thus, the concentration 

values of the radionuclides and the unknown quantity of coal (Q) can be 

substituted for the "quantity released" in equation (1). The calculation 

reduces, therefore, to two terms: 

B-3 
P.8 

(2) 1 RQ - (0.43 pCi/g * 14 members) * 0 + (0.35 pCi/g * 11 members) * 0 

52,000,000,000 pCi 11,000,000,000 pCi 

Uranium-238 series Thorium-232 series 

where Q is the quantity of coal dumped in grams 

Simplifying terms and solving: 

1 RQ - (1.16 * 10"10 pCi/g + 3.50 * 10"10 pCi/g) * Q 

1 RQ = 4.66 x IO"10 pCi/g * Q 

Q = 2,150,000,000 g 

This quantity can be converted to a more familiar unit of measurement: 

Q - (2,150,000,000 g)/(908,000 g/ton) 

- 2,360 tons 

Large quantities of coal are often transported by train in 100-ton boxcars. 

The quantity calculated above represents approximately 24 boxcars, which is a 

plausible amount to be delivered in a 24-hour period. Such a delivery, if 

dumped on the ground, would constitute a release of an RQ of radionuclides 

under the final adjusted radionuclide RQs. Because the economics of coal 

transport are very facility specific, little generalization can be made about 

the frequency and size of coal shipments that is relevant to more than a small 

number of facilities. If weekly deliveries are assumed, however, then a 

facility receiving loads of 2,360 tons would consume 122,700 tons of coal 

annually (52 deliveries * 2,360 tons per delivery). 

As a rule of thumb, a 100 MW coal-fired utility boiler consumes 

approximately 275,000 tons of coal annually.3 This relationship between 

3 This rule of thumb is approximate and is based on the assumption that 

the boiler is used at 70 percent utilization; that 10,000 British thermal 

units (Btus) are necessary to generate a kilowatt-hour (Kwh) of electricity; 

and that a ton of coal contains 22,000,000 Btus of energy. To determine the 

amount of coal consumed annually, the amount of electricity produced is 

calculated first: 

Electricity produced - Boiler size * hours per year * capacity utilization 

= 100 MW * 1.000 Kw * 8.760 hr * .70 

MW year 

- 613,200,000 Kwh/year 

The amount of coal necessary to generate this quantity of electricity is now 

calculated: 

Amount of coal - Electricity produced * thermal energy needed to produce 

consumed a unit of electricity * thermal energy available in coal 

B-4 
P.9 

generating capacity and annual coal consumption holds over a reasonably broad 

range of boiler sizes, suggesting that each megawatt (MW) of capacity requires 

about 2,750 tons of coal for a boiler operating at average utilization. 

Applying this ratio to the amount of annual coal consumption calculated in 

equation (2) provides an estimate of the size of the boiler that a facility 

would have to have to be likely to equal or exceed an RQ of radionuclides on a 

regular basis. The boiler size implied by an annual coal consumption of 

122,700 tons is: 

(3) Boiler size Annual coal consumption 

2,750 tons/year per MW 

Boiler size 122.700 tons/year 

2,750 tons/year/MW 

45 MW 

Therefore, a facility with a coal-fired boiler larger than 45 MW that receives 

weekly deliveries of coal is expected to release an RQ or more of 

radionuclides during such deliveries. 

The ash produced when coal is burned is also disposed of on a regular 

basis, usually into an ash lagoon or onto an ash pile. Dumping of ash 

represents a release to the environment. Coal, on average, has about a 10-

percent ash content by weight, suggesting that the amount of ash generated is 

approximately one-tenth of the amount of coal burned.* To be conservative, it 

is assumed that all of the radionuclides in the coal remain in the ash (i.e., 

none are released to air or destroyed in the combustion process), so that the 

concentrations of radionuclides in the ash are ten times that of the raw coal. 

Thus, the concentrations for the Uranium-238 and Thorium-232 series in secular 

equilibrium are 4.3 pCi/g and 3.5 pCi/g respectively. In addition, it is 

assumed that all of the ash is recovered and dumped. 

- 613.200.000 Kwh * 10.000 Btus * 

year Kwh 

= 278,800 tons/year 

ton of coal 

22,000,000 Btus 

For this analysis, a rounded value of 275,000 tons per year is used. 

* EPA'88, Appendix B reports an average ash content of 10.5 percent for a 

variety of U.S. coals, with a range from 6.0 to 18.1 percent. This average 

figure has been rounded to 10 percent. For the sake of simplicity, all ash 

will be considered collectively; no attempt will be made to differentiate 

between quantities of bottom ash and fly ash. This assumption eliminates the 

need to account for the various distributions of ash depending on boiler type 

and is reasonable because most boilers employ particulate control systems that 

capture large percentages of the fly ash. Most of this fly ash is disposed of 

in a manner similar to bottom ash. 

B-5 
P.10 

Because the concentration of radionuclides in the ash is assumed to be 

ten times that of coal, the amount of ash containing an RQ of radionuclides is 

assumed to be one-tenth that of coal, or 236 tons of ash. Assuming that the 

boiler dumps its bottom ash on a daily basis, the size boiler suggested by 

such characteristics can be calculated again. Boilers do not necessarily 

operate continuously; based on a capacity utilization of 70 percent, this 

analysis assumes that the boiler operates 255 days per year.5 Two hundredthirty- six tons of ash dumped per day suggests an annual production of bottom 

ash of 60,200 tons (236 tons * 255 days/yr). If the ash content of the coal 

burned is 10 percent, this amount of ash corresponds to an annual coal 

consumption of 602,000 tons. Substituting these values into equation (3) to 

determine the size of the boiler: 

(3) Boiler size -- Annual coal consumption 

2,750 tons/year per MW 

Boiler size = 602.000 tons/year 

2,750 tons/year/MW 

220 MW 

Any facility whose boiler size exceeds 220 MW, therefore, is likely to meet or 

exceed the RQ for a mixture of natural Uranium-238 and Thorium-232 in secular 

equilibrium each time it dumps ash onto its wastepile or into an ash lagoon. 

These same facilities have a boiler capacity large enough (i.e., greater than 

45 MW) that they are expected to equal or exceed an RQ whenever they receive a 

coal delivery. Dumping of coal ash, therefore, is not the critical activity 

that would cause a coal-fired boiler facility to be affected by the 

radionuclide RQ adjustment rulemaking. 

As shown in Exhibit B-l, the majority of power plants with coal-fired 

boilers have generating capacities larger than 45 MW. Because the size 

distribution of plants smaller than 100 MW is not known, it is conservatively 

assumed that all of these facilities are larger than 45 MW and, therefore, are 

expected to meet or exceed an RQ during routine coal deliveries. In addition, 

there are 423 industrial boilers larger than 75 MW and some number of the 

1,181 boilers in the size range of 30-75 MW that meet the 45 MW criterion, as 

5 Utility plants operate at approximately 70 percent of capacity over the 

course of a year, although there is considerable variation depending on the 

type of plant (EPA'84, p.4.1-1). Plants providing baseload generation 

typically show utilization rates around 90 percent. Other plants providing 

electricity only during periods of peak demand have much lower utilization 

rates. The 70 percent figure used here is an average for all utility plants. 

Industrial boilers generally have lower utilization rates. To be 

conservative, it is assumed that whenever a plant runs, its runs at 100 

percent of capacity and, therefore, produces the most ash possible in a 24-

hour period. A utility boiler used at this rate would operate 255 days per 

year (365 * 0.7). 

B-6 
TYPE 

M WATER TUBE 

FIRE TUBE 

I CAST IRON 

• TOTAL 

EXHIBIT B-l 

DISTRIBUTION BY CAPACITY OF 

COAL-FIRED POWER PLANTS 

CAPACITY (MW) NUMBER 

<100 151 

101 - 500 159 

501 - 1,000 89 

1,001 - 2,000 92 

>2.001 23 

TOTAL: 514 

These plants represent 1378 generating units (i.e., boiler, 

turbine, and generator). 

Source: Utility Data Institute Power Statistics Data Base 

EXHIBIT B-2 

DISTRIBUTION BY CAPACITY AND TYPE 

OF COAL-FIRED INDUSTRIAL BOILERS 

CAPACITY 

0-3 MW 3-15 MW 15-30 MW 30-75 MW OVER 75 MW 

683 2,309 1,290 1,181 423 

8,112 1,224 

35,965 

44,760 3,533 1,290 1,181 423 

Source: EPA'84 

B-7 

TOTAL 

5,886 

9,336 

35,965 

51,187 

p.11 

! 

i 
shown in Exhibit B-2.6 Assuming a uniform distribution by size of boilers in 

the 30-75 MW range, an additional 787 boilers from this group also have a 

generating capacity of 45 MW or more (30/45 or 0.667 * 1,181). Therefore, if 

each industrial boiler larger than 45 MW represents a unique facility, the 

total number of utility and industrial boiler facilities likely 

to release an RQ or more of radionuclides during coal deliveries is 1,724 (514 

utility boiler facilities + 423 industrial boilers larger than 75 MW + 787 

industrial boilers between 45 MW and 75 MW). 

Radon Releases from Piles 

Releases of radon gas from coal and aish piles tend to occur at low rates 

over broad areas, as naturally occurring radium decays and the resulting radon 

gas escapes to air. Although the amount released per unit of area is 

typically quite low, aggregation of these releases over large areas may equal 

or exceed the RQ for radon. All other things being equal, the quantity of 

radionuclide released is essentially a function of the size and composition 

(i.e., coal type) of the piles of raw and waste materials kept at the 

facility. 

Because radon gas diffuses upward, it is assumed to be released to the 

atmosphere in only one direction and the amount released is essentially a 

function of the exposed surface area of the reserve coal pile and the waste 

ash pile, not the volume of the piles.7 Hence, the calculations below are 

based on surface area, and the results are later converted into volume 

measurements based on typical characteristics of coal and ash piles. The 

relationship between the amount of radon released and the size of the piles at 

a facility can be stated mathematically as follows:8 

6 This count does not include any industrial boilers that have come online since these data were gathered. 

7 This simplification holds for piles of the thickness considered here. 

For shallow piles, all of the radon gas may be assumed to migrate upward 

through the pile and escape to the atmosphere. For deeper piles, some 

fraction of the radon gas is unlikely to have migrated upward through the 

entire pile before decaying into its daughters (the half-life of Radon-222 is 

3.82 days). This analysis assumes that all of the radon gas created in a pile 

escapes. 

8 This analysis assumes that facilities maintain both a coal stockpile 

and an ash wastepile. This is only true for a minority of facilities. About 

40 percent of the facilities landfill the ash at the facility, or transport it 

off-site to landfills. These landfills are often covered by a depth of soil, 

effectively limiting radon releases, often to normal background levels. An 

additional 35 percent dispose of some or all waste ash by placing it in large 

containment lagoons that reduce radon emissions to air. U.S. Environmental 

Protection Agency, Report to Congress: Wastes from the Combustion of Coal by 

Electric Utility Power Plants (EPA 530-SW-88-002), Office of Solid Waste and 

Emergency Response, EPA, February 1988, p.4-22. (EPA'88). 

B-8 
P.13 

Amount of radon ([Area of coal stockpile] * [amount of radon 

(4) released per day -» released per day per unit area]) + 

([area of ash pile] * [amount of radon released 

per day per unit area]). 

This equation simply states that the amount of radon released per day by a 

facility is the sum of the amounts released by the individual piles at the 

facility, which, in turn, depends on the size of the piles and the amount of 

radon released per day per unit area. 

Facilities normally maintain regular reserve quantities of coal which is 

burned over time into waste ash. It is possible, therefore, to establish a 

relationship between the size of these two piles under consideration. Most 

utility boilers maintain approximately a 92-day reserve of coal at the 

facility, while industrial boilers average approximately a 37-day reserve.9 

Furthermore, as noted above, coal, on average, has about a 10 percent ash 

content by weight. For a typical utility boiler consuming a quantity (X) of 

coal per year, therefore, the size of its reserve coal pile (R) is: 

(5) R = X * (92/365) or R - X/4 

Because both quantities in equation (5) are coal, the relationship established 

is equally valid if the unit of measurement is weight or volume. The weight 

of coal ash generated each year is 10 percent that of the coal burned (i.e., 

coal has a 10 percent ash content): 

(6) V - (0.10 of Z) or W - X/10 

The volume size of the waste ash pile (W) generated each year is a 

function of the amount of coal burned and the ratio of the densities of coal 

to ash. A ton of loose bulk coal occupies approximately 42 cubic feet, equal 

to a bulk density of about 48 lbs/cu. ft.10 The bulk density of dry coal ash 

varies depending on the type of coal, type of boiler, and kind of ash (i.e., 

fly or bottom) but is approximately 70 to 90 lbs./cu. ft.11 For this 

analysis, a figure of 72 lbs/cu. ft. is used as an estimated density of coal 

ash. Using the ratio of the densities of coal and coal ash, the relationship 

between by the weight of the two piles can be translated into a relationship 

based on the volume of the two piles. 

9 U.S. Environmental Protection Agency, Source Assessment: Coal Storage 

Piles (EPA 600/2-78-004), EPA, May 1978, p.4. (EPA'78). 

10 U.S. Department of Energy, Coal Data: A Reference. Energy 

Information Administration, DOE, March 1987. 

11 EPA'88, p. 3-14 and American Coal Ash Association, personal 

communication, January 1989. Regardless of the figure selected from this 

range, ash is more dense than coal and, therefore, occupies less space. 

B-9 
P.14 

(7) Volume of ash produced - Weight of ash produced * ratio of the densities 

annually (expressed as annually (expressed as of coal and ash 

a function of the a function of the 

volume of coal) weight of coal) 

W (volume) - W (weight) * (48/72) 

W - (X/10) * (48/72) or W - X/15 

Combining equations (5) and (7): 

(8) W = 4 R/15 or W = 0.267 R 

For each year, therefore, the amount of waste ash generated per year is 

approximately equal to 27 percent of the amount of coal in the coal reserve 

pile. The size of the inventory of reserve coal (R) is assumed to remain 

relatively constant over time, however, the size of the wastepile of ash (A) 

grows over time as more ash is dumped. This analysis assumes that the waste 

ash pile represents 20 years of operation;12 thus, 

(9) A - 20 * 0.267 R or A - 5.3 R 

Repeating this calculation for industrial boilers, which maintain a 

smaller reserve pile of coal (37/365 or 0.10), produces the following 

relationship: 

(10) R = X * (37/365) or R = X/10 

(7) W - (X/10) * (48/72) or W - X/15 

Combining equations (7) and (10): 

(11) W = 10 R/15 or W - 0.667 R 

Consequently, for an industrial facility with 20 years of accumulated waste 

ash, the relationship between the reserve coal pile (R) and the cumulative ash 

pile (A) is: 

(12) A = 20 * 0.667 R or A - 13.3 R 

These equations relate the size (i.e., volume) of the piles of coal and 

ash for a representative facility. As noted above, the relevant dimension for 

considering the amount of radon released is the exposed surface area through 

which the radon gas may diffuse to the atmosphere. If it is assumed that the 

12 The average age of utility boilers in the United States is 

approximately 20 years. EPA'84, p.4.1-3. 

B-10 
P.15 

piles have the same geometry and height, then these same equations essentially 

describe the relationship between the surface area of the two piles.13 

The amount of radon released per unit area per day depends on two 

factors: (1) the amount of radium in the coal or ash1* and (2) the rate at 

which radon escapes from the pile, the so-called emanation rate. In addition, 

two conversion constants are needed to ensure that the units on both sides of 

the equation are consistent and yield a result expressed in acres. The term 

representing the amount of radon released per unit area per day, thus, appears 

as follows: 

(13) Quantity of radon = [(Emanation rate) * (number of seconds/day) * 

released (number of square meters/acre) * (radium 

concentration in coal or ash)] 

There are 86,400 seconds in a day (60 * 60 * 24) and 4,047 square meters in an 

acre. Substituting these values into equation (13): 

Quantity of radon -= [Emanation rate (pCi/sqm-sec per pCi of radium 

released in a gram of coal or ash) * 86,400 (sec/day) * 4047 

(sqm/acre) * radium concentration in coal or ash 

(pCi per gram)] 

Consolidating these terms produces a single term of the amount of radon 

released, expressed in pCi per acre per day: 

(14) Quantity of radon - [ Emanation rate * radium concentration * 

released 349,660,800 ] (pCi/day-acre) 

Radium is a decay daughter of Uranium-238 and is found in bulk coal in 

secular equilibrium with its parent. Consequently, the concentration value of 

Uranium-238 of 0.43 pCi/g of coal is assumed to be the concentration value for 

radium in coal. It is assumed also that all of the radium present in the coal 

is retained in the ash; therefore, the concentration in ash is ten times that 

of coal or 4.3 pCi/g of ash. 

13 This analysis assumes that the piles are roughly rectangular in shape 

and 20 feet deep (EPA178, p.2). Extension of the volume relationship to 

exposed surface area only holds true if the surface area along the sides of 

these piles is ignored and only the "top" portion of the piles is considered. 

This seems a reasonable assumption for two reasons: (1) many of these piles 

are placed intentionally in shallow pits or depressions to reduce particulate 

emissions to air caused by wind and, thus, do not have exposed sides, and (2) 

the shallow depth of these piles relative to their length and width suggests 

that relatively little radon escapes through diffusion sideways. Ignoring the 

possibility of radon escaping through exposed sides results in approximately 

an 11 percent distortion in the relationship of the surface areas of these 

piles over if the side surface areas were included. 

14 Radium-226 decays to Radon-222; thus, the amount of radon present in a 

pile varies with the amount of radium present. 

B-ll 
P.16 

The emanation rate of radon varies according to specific circumstances, 

such as atmospheric pressure and humidity; however, the emanation rate of 

radon from coal and ash is typically less than that from soil, which is 

commonly accepted to be 0.5 - 0.7 pCi/sqm-sec per pCi of Radium-226 in a gram 

of coal or ash.15 Lab tests of radon emissions from coal show considerable 

variation over two orders of magnitude, yielding emanation rates 'from 0.1 to 

6.0 pCi/sqm-sec per pCi/g.16 For purposes of this analysis, it is assumed 

that the emanation rate of radon from coal piles is the upper range 

measurement from soil (0.7 pCi/sqm-sec per pCi/g of radium). Coal ash 

typically demonstrates a much lower emanation rate because some of the ash is 

vitrified which impedes the escape of radon. This analysis assumes the 

emanation rate of ash to be 0.13 pCi/sqm-sec per pCi/g of radium.17 

These values for coal and ash can be substituted into equation (14): 

(14) Quantity of radon = [ Emanation rate * radium concentration * 

released 349,660,800 ] (pCi/day-acre) 

For coal: 

(15) Quantity of radon = [ 0.7 * 0.43 * 349,660,800 ] (pCi/day-acre) 

released 

For ash: 

(16) Quantity of radon - [ 0.13 * 4.3 * 349,660,800 ] (pCi/day-acre) 

released 

Referring back to equation (4): 

Amount of radon ([Area of coal stockpile] * [amount of radon 

(4) released per day = released per day per unit area]) + 

([area of ash pile] * [amount of radon released 

per day per unit area]). 

15 EPA'84, p.4.1-6; NCRP#78, p.13; and Edison Electric Institute, Review 

of the EPA Reportable Quantity Adjustments for Radionuclides. May 1987, p.14. 

(EEI'87), (Commenter 102RQ-RN-6-L1). The emanation rate is expressed in 

pCi/(sqm-sec) because radon gas must diffuse across an exposed surface to be 

released to the atmosphere. It is also possible that radon can enter other 

media such as groundwater through leaching. 

16 Energy Resources, The Toxicity and Radioactivity of Ashes of U.S. 

Coals: Final Report. March 1979. DOE Contract No. EJ-78-C-01-63945. 

17 U.S. Environmental Protection Agency, Technical Background Supplement 

in Support of Rulemaking Adjustment Activities for Reportable Quantities (RO) 

of Radionuclides: Second Draft, (prepared by Sanford Cohen & Associates), 

February 1989, p.16. (EPA'89). 

B-12 
Substituting equations (9), (15), and (16) into equation (4): 

Amount of radon R (acres) * [ 0.7 * 0.43 * 349,660,800 ] (pCi/day-

(4) released per day - acre) + 5.3 R (acres) * [ 0.13 * 4.3 * 349,660,800 ] 

(pCi/day-acre) 

By substituting in the RQ of radon (0.1 Ci) for the amount of radon released, 

an equation is generated that can be used to calculate the surface area of the 

coal and ash piles necessary to release an RQ of radon on a daily basis: 

0.1 * IO12 pCi = R (acres) * [ 0.7 * 0.43 * 349,660,800 ] (pCi/dayacre) + 5.3 R (acres) * [ 0.13 * 4.3 * 349,660,800 ] 

(pCi/day-acre) 

0.1 * IO12 pCi = 105,000,000 pCi/day-acr e * R + 1,036,000,000 pCi/dayacr e * R 

Solving for R: R = 88 acres and A = 466 acres 

Thus, this analysis suggests that a representative, twenty year-old utility 

boiler facility would need to maintain a reserve coal pile of 88 acres and a 

corresponding waste ash pile of 466 acres before these piles are estimated to 

release an RQ of radon on a daily basis, and, therefore, be subject to CERCLA 

notification requirements. 

To determine the number of utility facilities that could have coal and 

ash piles of these sizes, additional conversions are necessary. Assuming that 

the piles are 20 feet deep and knowing that an acre equals 43,560 sq. ft., 

these area measurements can be converted into volume measurements: 

(17) Volume of coal -» 20 ft. * 43,560 sq. ft./acre 

or ash in an acre - 871,200 cu. ft./acre 

Thus, for a pile of 88 acres: 

(18) Volume of coal pile - 88 acres * 871,200 cu. ft./acre 

R •= 76,700,000 cu. ft. 

And, for an ash pile of 466 acres: 

(19) Volume of ash pile = 466 acres * 871,200 cu. ft./acre 

A = 406,000,000 cu. ft. 

Using the bulk densities of the two materials, these volume measurements can 

be translated into masses. The bulk density of coal is 48 lbs/cu. ft. or 42 

cu. ft./ton. The bulk density of ash is 72 lbs/cu. ft. which can be expressed 

as 28 cu. ft./ton. These conversions are: 

(20) Mass of R - 76,700,000 cu. ft./ 42 cu. ft./ton 

1,826,000 tons 

(21) Mass of A - 406,000,000 cu. ft./ 28 cu. ft./ton 

14,500,000 tons 

B-13 
P.18 

I 

I Referring back to equation (5), a reserve coal pile of 1,826,000 tons suggests 

an annual consumption of approximately 7,300,000 tons (1,826,000 x 4). Using 

equation (3), this annual coal consumption can be translated into an estimate 

of the boiler size needed to consume such a quantity of coal. 

(3) Boiler size -» Annual coal consumption 

2,750 tons/year per MW 

(22) Boiler size •= 7.300.000 tons/year 

2,750 tons/year/MW 

2,660 MW 

There are 23 coal-fired power plants larger than 2,000 MW, as shown in 

Exhibit B-l; the number larger than 2,600 MW is likely to be a fraction of 

this figure. As this size of boiler generating capacity is larger than the 

necessary cut-off size calculated for coal deliveries, all facilities having 

to report because of radon emissions would have to report also for coal 

deliveries. 

This same calculation can be repeated for industrial boilers, for which 

it is assumed that the waste ash pile is 13.3 times the size of the coal 

stockpile, as calculated in equation (12). Again, using equation (4): 

Amount of radon ([Area of coal stockpile] * [amount of radon 

(4) released per day -= released per day per unit area]) + 

([area of ash pile] * [amount of radon released 

per day per unit area]). 

Substituting equations (12), (15), and (16) into equation (4): 

Amount of radon R (acres) * [ 0.7 * 0.43 * 349,660,800 ] (pCi/day-

(4) released per day - acre) + 13.3 R (acres) * [ 0.13 * 4.3 * 349,660,800 ] 

(pCi/day-acre) 

By substituting in the RQ of radon (0.1 Ci) for the amount of radon released, 

an equation is generated that can be used to calculate the surface area of the 

coal and ash piles necessary to release an RQ of radon on a daily basis: 

0 . 1 * 1012 pCi - R (acres) * [ 0.7 * 0.43 * 349,660,800 ] (pCi/dayacre) + 13.3 R (acres) * [ 0.13 * 4.3 * 349,660,800 ] 

(pCi/day-acre) 

0 . 1 * 1012 pCi -• 105,000,000 pCi/day-acr e * R + 2,600,000,000 

pCi/day-acre * R 

Solving for R: R - 37 acres and A - 492 acres 

Thus, an industrial facility with a coal stockpile of 37 acres and a 

corresponding ash pile of 492 acres is likely to release an RQ of radon to air 

on a daily basis. To convert these surface measurements into volume units 

using equation (17): 

B-14 
P.19 

(23) Volume of coal pile -= 37 acres * 871,200 cu. ft./acre 

R •= 32,200,000 cu. ft. 

(24) Volume of ash pile - 492 acres * 871,200 cu. ft./acre 

A - 429,000,000 cu. ft. 

The bulk density of coal is 42 cu. ft./ton and that of ash is 28 cu. ft./ton. 

Using these values, these volume measurements can be converted into masses: 

(25) Mass of R = 32,200,000 cu. ft./ 42 cu. ft./ton 

767,000 tons 

(26) Mass of A - 429,000,000 cu. ft./ 28 cu. ft./ton 

15,300,000 tons 

A reserve coal pile of 767,000 tons suggests an annual consumption of 

approximately 7,670,000 tons (767,000 x 10), because industrial boilers 

maintain only a 37-day reserve of coal. This quantity of annual coal 

consumption is slightly larger than that calculated for utility boilers in 

equation (22) which corresponds to an aggregate boiler capacity of over 2,600 

MW. Although there are utility power plants with an aggregate capacity of 

this size, it is highly unlikely that any industrial facility has such 

aggregate, generating capacity, as shown in Exhibit B-2. 

In summary, under representative conditions and operating procedures, 

fewer than 23 of the coal-fired utility power plants with a generating 

capacity over 2,000 MW are expected to meet or exceed the RQ for radon based 

on releases to air from coal and coal ash piles maintained at the facility. 

These facilities are expected to have to report releases of radionuclides 

already because of releases to land associated with the delivery of coal. 

Particulate Releases to Air 

The windborne release of radionuclide-laden particulates represents a 

release to air. As estimated in equation (2), the quantity of coal containing 

an RQ of radionuclides is 2,360 tons. Typical particulate releases to air 

from a "model" coal pile are reported as 610 kg annually for a 95,000 metric 

ton pile (EPA'78, p.2). This quantity equals an average daily loss of 1.67 kg 

or 0.000002 percent of the pile. Using this percentage daily loss and the 

quantity of coal known to represent an RQ of radionuclides, the size pile 

needed to make this release pathway relevant can be calculated as follows: 

(27) Size of coal pile -= Quantity containing an' RO 

Percentage lost daily 

2.360 tons 

0.000002 percent 

118,000,000,000 tons 

B-15 
P.20 

No facility maintains a reserve coal pile of this size. Consequently, no 

facility is likely to release an RQ of radionuclide via this release path. 

This release path is equally implausible for particulate releases of ash from 

waste piles. 

Releases to Groundwater and Leaching 

Piles of coal and ash may also release radionuclides to groundwater. 

Because radionuclides are primarily heavy metals and, therefore, not readily 

soluble in water, the most likely path of release is the transport of 

particulates by water percolating through the piles, such as during a rain 

shower or by leaching from ash lagoons. 

To estimate the quantity of water that could leach out an RQ or more of 

radionuclides, it is assumed that all radionuclides of a particular series 

(e.g., Uranium-238 and its daughters) are in secular equilibrium (i.e., are 

found in the same concentration) in the coal and ash pile. Because all member 

radionuclides of a series are assumed to be present in the coal and ash, the 

relative contribution of each toward meeting or exceeding an RQ must be 

assessed using the mixture rule. Specifically, it is necessary to calculate, 

for each radionuclide released, the ratio of the quantity released in curies 

to the appropriate RQ. If the sum of the ratios for all radionuclides is less 

than one,, the release need not be reported. If the sum equals or exceeds one, 

the release must be reported. Referring to equation (1), the mixture rule can 

be expressed: 

(1) Percentage of an 1 Quantity released (pCi) 

RQ released Lt [_ RQ (pCi) _ 

n 

where n is the number of radionuclides in the mixture 

- [ < 

The "quantity released" of an individual radionuclide depends on four 

factors: (1) the concentration of the radionuclide in the coal, (2) the 

concentration of the radionuclide in the ash, (3) the adsorption coefficient 

of the radionuclide, and (4) the volume of water passing through the pile. 

The adsorption coefficient (Kd) is a measure of the extent to which the 

radionuclide adheres to the soil and thus, is not free to migrate out of the 

pile via leaching. It is, therefore, a measure of the radionuclide's ability 

to be transported out of the pile by leaching. This analysis assumes that Kd 

values are the same for radionuclides in coal piles and in ash piles. The 

"quantity released" of an individual radionuclide can be expressed as the sum 

of the quantities released by the. coal and ash pile, divided by the adsorption 

coefficient, multiplied by the volume of leachate. Mathematically, this term 

is: 

Quantity Radionuclide Radionuclide 

(28) released - concentration in coal + concentration in ash (pCi/g) * Volume 

(pCi) Kd (ml/g) 

where Volume is the volume of leachate passing through the pile in ml 

B-16 
P.21 

The concentration of Uranium-238 and Thorium-232 series radionuclides in 

secular equilibrium in coal are 0.43 pCi/g and 0.35 pCi/g respectively. 

Assuming no radionuclides are lost or destroyed during combustion, the 

concentration of these radionuclides in ash are 4.3 pCi/g and 3.5 pCi/g 

respectively. This analysis assumes also that all of the precipitation seeps 

through the coal and ash piles and none is diverted as surface runoff or 

evaporates. 

Because of a combination of short half-life and high adsorption 

coefficient, some radionuclides in the Uranium-238 and Thorium-232 series 

contribute negligibly to meeting or exceeding an RQ of radionuclides via this 

release pathway. Consequently, these radionuclides are ignored in this 

analysis. Below is a table summarizing the radionuclides considered relevant 

to this release pathway and the values used in the analysis:18 

Radionuclide 

URANIUM SERIES 

Uranium-238 

Uranium-234 

Thorium-230 

Radium-226 

Lead-210 

Polonium-210 

Concentration in 

Coal (oCi/e) 

0.43 

0.43 

0.43 

0.43 

0.43 

0.43 

Concentration in 

Ash (nCi/e) 

4.3 

4.3 

4.3 

4.3 

4.3 

4.3 

Adsorption 

Coefficient (ml/g) 

50 

50 

3,000 

75 

100 

100 

THORIUM SERIES 

Thorium-232 

Radium-228 

Thorium-228 

0.35 

0.35 

0.35 

3.5 

3.5 

3.5 

3,000 

75 

3,000 

These values are substituted into equation (28) for each radionuclide 

and the resulting products are substituted into equation (1). To determine 

the volume of leachate containing an RQ of radionuclides, the left-hand side 

of equation (1) is set equal to one and the equation is solved for the unknown 

volume: 

(D 

(29) 

1 RQ (pCi) 

Volume 

1.41 * 10"11 (pCi/ml) * Volume 

70,900,000,000 ml19 

18 EPA'89, p.22-24. 

19 One commenter provided an estimate of one billion liters per day to 

exceed an RQ of Thorium-230. This estimate was based on a concentration of 

Thorium-230 of 10 pCi/liter and did not consider other radionuclides, 

p.14. 

EEI'87, 

B-17 
P.22 

70,900,000,000 ml * 1 cubic inch 

16.38 ml 

4,330,000,000 cubic inches (cu. in.) 

Therefore, it is estimated that 4.33 billion cubic inches of water would have 

to seep through the coal and ash piles maintained at a facility and escape to 

the environment to contain an RQ of radionuclides. Leaching of this magnitude 

from existing ash lagoons does not occur on a continuous basis. If the piles 

are large enough, however, this volume of water could pass through them on a 

regular basis during periods of precipitation. 

To convert this volume of precipitation into a measurement bf surface 

area, the depth of the volume (i.e., number of vertical inches of rain or snow 

that falls over 24 hours) must be known. Because even an average depth of 

rain per storm varies greatly across regions and within regions across 

seasons, this figure necessarily will be somewhat inappropriate for all 

facilities maintaining coal and ash piles. This analysis uses a reasonably 

conservative figure of six inches. Thus, the conversion to surface area is: 

(30) Surface area of leachate - Volume of leachate/depth of leachate 

4.330.000.000 cu. in. 

6 in. 

722,000,000 sq. in. 

722,000,000 sq. in. * 1 acre 

6,270,000 sq. in. 

-= 115 acres 

Therefore, the quantity of rain estimated to contain an RQ of radionuclides 

must cover an area of 115 acres to a depth of six inches. This area is the 

combined size of the coal pile and ash pile necessary to make this release 

pathway feasible. Equation (9) above represents the relationship between the 

surface areas of coal and ash piles at utility facilities: 

(9) A - 5.3 R 

where- A is the size of the ash pile and R is the size of the coal pile 

Therefore, the combined area of the two piles is 6.3 R (i.e., R + 5.3 R). 

Dividing this figure by the area calculated in equation (30): 

(31) 6.3 R - 115 acres 

R - 18.3 acres 

To determine the number of utility facilities that could have coal piles 

of these sizes, additional conversions are necessary. Assuming that the piles 

are 20 feet deep and knowing that an acre equals 43,560 sq. ft., these area 

measurements can be converted into volume measurements using equations (17): 

B-18 
P.23 

(17) Volume of coal - 20 ft. * 43,560 sq. ft./acre 

in an acre - 871,200 cu. ft./acre 

Thus, for a pile of 18.3 acres: 

(32) Volume of coal pile = 18.3 acres * 871,200 cu. ft./acre 

R = 15,900,000 cu. ft. 

Using the bulk density of coal, this volume measurement can be translated into 

a mass measurement. The bulk density of coal is 48 lbs/cu. ft. or 42 cu. 

ft./ton. The conversion is: 

(33) Mass of R - 15,900,000 cu. ft./ 42 cu. ft./ton 

379,000 tons 

Referring back to equation (5), a reserve coal pile of 379,000 tons suggests 

an annual consumption of approximately 1,520,000 tons (379,000 x 4). Using 

equation (3), this annual coal consumption can be translated into an estimate 

of the boiler size needed to consume such a quantity of coal: 

(3) Boiler size - Annual coal consumption 

2,750 tons/year per MW 

(34) Boiler size - 1.520.000 tons/year 

2,750 tons/year/MW 

550 MW 

There are 204 power plants with coal-fired boilers whose aggregate 

capacity is greater than 500 MW, as shown in Exhibit B-l. This analysis 

assumes that all of these facilities have generating capacities larger than 

550 MW. 

This same calculation can be repeated for industrial facilities, which 

maintain coal and ash piles in different proportions to those found at utility 

facilities. Referring to equation (12): 

(12) A = 13.3 R 

where A is the size of the ash pile and R is the size of the coal pile 

Therefore, the combined area of the two piles at industrial facilities is 14.3 

R (i.e., R + 13.3 R). Dividing this figure by the area calculated in equation 

(30): 

(35) 14.3 R - 115 acres 

R - 8.0 acres 

To determine the number of industrial facilities that could have coal 

piles of these sizes, additional conversions are necessary. Assuming that the 

B-19 
P.24 

piles are 20 feet deep and knowing that an acre equals 43,560 sq. ft., these 

area measurements can be converted into volume measurements using equations 

(17): 

(17) Volume of coal -= 20 ft. * 43,560 sq. ft./acre 

in an acre - 871,200 cu. ft./acre 

Thus, for a pile of 8.0 acres: 

(36) Volume of coal pile •= 8.0 acres * 871,200 cu. ft./acre 

R - 6,970,000 cu. ft. 

Using the bulk density of coal, this volume measurement can be translated into 

a mass measurement. The bulk density of coal is 48 lbs/cu. ft. or 42 cu. 

ft./ton. The conversion is: 

(37) Mass of R - 6,970,000 cu. ft./ 42 cu. ft./ton 

166,000 tons 

Referring back to equation (10), a reserve coal pile of 166,000 tons at an 

industrial facility suggests an annual consumption of approximately 1,660,000 

tons (166,000 x 10). Using equation (3), this annual coal consumption can be 

translated into an estimate of the boiler size needed to consume such a 

quantity of coal. 

(3) Boiler size = Annual coal consumption 

2,750 tons/year per MW 

(38) Boiler size •= 1.660.000 tons/year 

2,750 tons/year/MW 

600 MW 

As shown in Exhibit B-2, it is highly unlikely that there are industrial 

facilities with an aggregate generating capacity of 600 MW. 

Therefore, based on the assumption that a facility regularly receives 

six inches of precipitation over a 24-hour period which seeps through its coal 

and ash piles, a total of 204 facilities with coal-fired boilers (204 utility 

boilers and no industrial boilers) are likely to meet or exceed the RQ for 

radionuclides on a regular basis. 

This analysis does not consider the cumulative releases occurring from 

all separate release pathways simultaneously because such a calculation 

depends on too many variables and assumptions to yield an accurate and 

meaningful result. However, it is unlikely that the size cutoff for boiler 

facilities would change significantly from the result reported above. 

B-20 
Summary 

This analysis considered five release pathways by which an RQ or more of 

a radionuclide could be released on a regular basis by a facility with a coalfired boiler. The five release pathways are: (1) smokestack emissions; 

(2) dumping of radionuclide-laden materials onto stockpiles or wastepiles; 

(3) releases of radon gas to air from coal stockpiles and ash wastepiles; 

(4) releases of radionuclide particulates to air from coal and ash piles; and 

(5) releases of radionuclides from coal and ash piles to groundwater (i.e., 

leaching). 

The analysis presented above concludes: 

• no utility or industrial facility is likely to release an RQ or 

more on a regular basis through smokestack emissions or through 

particulate releases to air; 

• 23 utility power plants are estimated to release radon gas from 

coal and ash piles at or above the RQ on a continuous basis; 

• 204 utility power plants are estimated to release an RQ of 

radionuclides in a mixture through leaching from coal and ash 

piles; and 

• 514 utility power plants and 1,210 industrial facilities are 

likely to receive'shipments of coal larger than 2,360 tons over a 

24-hour period on a regular basis and, therefore, exceed the RQ 

for a mixture of natural Uranium-238 and natural Thorium-232 in 

secular equilibrium by the act of dumping coal in an exposed site. 

Facilities that receive delivery of more than 2,360 tons of coal at one 

time maintain much smaller volumes of coal and ash than are required to meet 

or exceed a radionuclide RQ by the two other relevant pathways (i.e., leaching 

and radon releases). Consequently, any facility meeting or exceeding an RQ 

because of these release pathways is expected to exceed an RQ because of 

releases associated with the delivery of coal. The final estimate, therefore, 

of facilities likely to release an RQ or more of a radionuclide on a regular 

basis is 1,724 (514 utility power plants and 1,210 industrial facilities). 

These facilities are expected to report these releases under the provisions of 

the reporting requirements of section 103(f)(2) of CERCLA. 

B-21 
P.26 

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) 102RQ-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 

3S)3U2Rq^N^9 ^ 

40) 102RQ^P5^2 

Step 1: FOR ASRC INTERNAL USE ONLY X* ^ 

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

*Fill out Continuation Sheet and go to Step 2 \^X 

Internal SFUND Box Number 35 OF 283 

Initials/Date: LDS /3-8-2007