ML24080A175
| ML24080A175 | |
| Person / Time | |
|---|---|
| Issue date: | 03/21/2024 |
| From: | David Garmon-Candelaria, Meena Khanna NRC/NRR/DRA, NRC/NRR/DRA/APLC |
| To: | |
| References | |
| Download: ML24080A175 (20) | |
Text
Recommendation to U.S. EPA Regarding the Renomination of Radionuclides as Chemicals of Mutual Concern under Annex 3 of the Great Lakes Water Quality Agreement Office of Nuclear Reactor Regulation Meena Khanna, Deputy Director, Division of Risk Assessment David Garmon, Health Physicist, Division of Risk Assessment March 21, 2024 ADAMS Accession No. ML24080A175*
- Find NRC public documents by using the following link, just replace the highlighted portion of the link with the appropriate ADAMS Accession Number (No.): https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML#########
About the NRC NRC Established by the Energy Reorganization Action of 1974 Several other key laws provide governing legislation Mission Statement: the NRC licenses and regulated the Nations civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety, to promote the common defense and security, and to protect the environment 2
ADAMS Accession No. ML24080A175 NRC regulations are contained in Title 10, Energy, of the Code of Federal Regulations, Chapter 1, Parts 1 to 199
NRC Regions 3
ADAMS Accession No. ML24080A175
Approach to Regulation 4
ADAMS Accession No. ML24080A175 Principles of Good Regulation NRC Inspectors at Vogtle Unit 4 in Georgia
Regulatory Framework for Release of Radioactive Material to the Environment Licensing and Oversight
- NRC licenses nuclear facilities to operate per our regulations
- NRC inspects nuclear facilities to ensure compliance with applicable requirements 5
ADAMS Accession No. ML24080A175 Key Aspects:
- General Design Criteria
- Technical Specifications
- Dose limits, design criteria and reference levels in oversight program
- Mandated Programs
Environmental Monitoring and Radiological Effluent Control Programs
- Radiological environmental monitoring program
- Establish baseline understanding of site location
- Surveys for life of facility
- Maintain understanding of population surrounding site
- Report results
- Radioactive effluent control programs
- Adequate instrumentation and processes to measure, evaluate and report results
- Ensure effluent discharges at ALARA levels
- Evaluate doses to members of the public 6
ADAMS Accession No. ML24080A175
Summary of 2017 NRC Response (ADAMS Accession No. ML16335A057)
- Described regulatory framework and opportunities for public participation
- Bases for NRC dose limits
- Regulations that apply to radioactive material discharges
- Oversight programs
- Minimizing risk of a release from a reactor accident
- Transportation regulations 7
ADAMS Accession No. ML24080A175 NRC staff recommended that radionuclides should not be designated as chemicals of mutual concern because the NRC already effectively regulates the use and transport of nuclear materials.
Overview of 2023 NRC Response (ADAMS Accession No. ML23261A383)
- Review of regulatory framework
- Review of risk associated with radiation exposures resulting from radioactive effluents
- Evaluation of renomination (2022) 8 ADAMS Accession No. ML24080A175 the NRC has established a robust regulatory framework that adequately protects public health, safety, and the environment. This framework is composed of regulations, licensing activities, guidance to licensees, oversight, enforcement, and emergency response. It also includes limits on radionuclide discharges and requires environmental monitoring to confirm that any discharges will remain both below regulatory limits and ALARA. The measured, low levels of radioactive materials in the environment related to U.S. nuclear power plants combined with the scientific consensus regarding the impacts of radioactive materials demonstrate that this regulatory framework is effective in protecting public health and safety and the environment.
Radiological Doses in Context 9
ADAMS Accession No. ML24080A175 Key limits and criteria (Annual)
NRC Public Dose Limit: 100 mrem (TEDE)
EPA Limits (Mandated by NRC Regulations)
- 25 mrem whole body
- 75 mrem thyroid
- 25 mrem other organ NRC Effluent ALARA Design Objectives
- Liquid
- 3 mrem whole body
- 10 mrem any organ
- Gaseous
- 10 mrad, gamma
- 20 mrad, beta
- Particulate
- 15 mrem any organ Reactor Performance Indicator and Required 30-day report to NRC
- 50% of NRC Effluent ALARA criteria/qtr Regulatory Guide 8.29 - Instructions Concerning Risks from Occupational Radiation Exposure Linear-No-Threshold Model
- 1. Toxic
- Criteria: Is the chemical substance toxic, persistent and/or bioaccumulative?
- Response:
- Radionuclides from source material, special nuclear material or byproduct material are excluded under U.S.
Toxic Substances Control legislation
- At doses resulting from radioactive effluents the risk of radiation-induced health effects are either nonexistent or too small to be observed (Health Physics Society, PS005-3) 10 ADAMS Accession No. ML24080A175
- 2. Release To what extent is the chemical substance released in the Great Lakes Basin?
Response
- Nuclear facility effluents are controlled by NRC regulations and inspected regularly for compliance with NRC limits and ALARA criteria
- Effluents from NRC licensees result in doses that are very small percentages of exposure from natural background radiation (NCRP-160)
- NRC licensees report, annually, the results of their environmental monitoring and effluent control programs:
https://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html 11 ADAMS Accession No. ML24080A175
5-Year Trend of Calculated Public Doses 12 ADAMS Accession No. ML24080A175
- Key Concept -
Maximally exposed member of the public Industry performance summarized in NUREG/CR-2907 https://www.nrc.gov/reading-rm/doc-collections/nuregs/contract/cr2907/index.html
- 3. Levels Are levels of the chemical substance harmful, or likely to become harmful, in the Great Lakes environment?
Response
- NRC mandated environmental monitoring programs ensure that NRC licensees provide data on measurable levels of radiation and radioactive materials in the environment to evaluate the relationship between quantities of radioactive material released in effluents and resultant radiation doses to individuals from principal pathways
- No NRC licensee has reported harmful levels of radioactive materials being released through effluents or as the result of environmental monitoring
- Environmental Operating Reports available at the NRC public web site: https://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html 13 ADAMS Accession No. ML24080A175
- 4. Route of Exposure 14 ADAMS Accession No. ML24080A175
- Are the Great Lakes a significant route of exposure to humans or wildlife for this chemical substance? Are the impacts, or likely impacts, cause by routes of exposure via water, sediments or food web?
- Response:
- Radionuclides are transported through the environment in pathways similar to equivalent non-radioactive chemical species
- The amount and type of material plays a significant role in the applicable pathways and resulting dose impacts
- NRC regulations and industry initiatives ensure that radioactive material that is released has negligible impact on the environment
Groundwater Protection Initiative Example of publics influence on NRC and U.S. industry decisionmaking In the early 2000s, concern over unplanned, unmonitored releases of radioactive liquids into the environment led to several NRC taskforces/studies Industry established a voluntary initiative (GPI)
- Develop site conceptual model
- Equipment leakage risk assessment
- Groundwater monitoring program (wells)
- Remediation process
- Record Keeping
- Communications (stakeholder briefings and reports)
NRC inspects performance
- Enduring Commission interest item
- Decommissioning records regulation 10 CFR 50.75(g)
- Minimization of contamination 10 CFR 20.1406 15 ADAMS Accession No. ML24080A175
- 5. Scale
- Does the geographic scale of the levels of the chemical substance in the Great Lakes have binational significance?
- Response:
- Public records of released radioactive material and the dose impacts do not indicate that radioactive material should have binational significance
- The NRC staff does not foresee future radioactive material releases that would have binational significance 16 ADAMS Accession No. ML24080A175
- 6. Management To what extent are the releases of the chemical substance controlled/managed?
Response
- NRC oversight and existing regulatory framework ensures that radionuclide release levels will remain at levels that are within regulatory limits and ALARA criteria, ensuring adequate protection of the public and the environment
- Licensees are required to maintain equipment and processes to ensure releases result in doses that are within limits and ALARA
- NRC oversight includes inspection by resident and regional-based subject matter expert inspectors 17 ADAMS Accession No. ML24080A175
Oversight: Inspection and Assessment 18 ADAMS Accession No. ML24080A175
Conclusions and Recommendations The NRC staff reviewed the information in the 2022 nomination and information submitted to support a similar nomination in 2016. The NRC staff concludes that radionuclides should not be designated as chemicals of mutual concern. The basis for this recommendation is provided in the enclosure to this letter. The enclosure shows that there is a sound technical basis to demonstrate that the NRCs regulatory program is adequate in ensuring that radionuclide releases from NRC-licensed facilities into the environment are monitored, controlled, and have a negligible impact on the water quality of the Great Lakes. Therefore, there is no practical benefit to designating radionuclides as chemicals of mutual concern.
NRC Recommendation to U.S. EPA, ADAMS Accession No. ML23261A383 19 ADAMS Accession No. ML24080A175
References 1.
Instruction Concerning Risks from Occupational Exposure, Regulatory Guide 8.29, February 1996, ADAMS Accession No. ML003739438.
2.
Ionizing Radiation Safety Standards for the General Public, Position Statement of the Health Physics Society, PS005-3, Reaffirmed February 2009, https://hps.org/documents/publicdose_ps005-3.pdf.
3.
Ionizing Radiation Exposure of the Population of the United States (Report No.
160). National Council on Radiation Protection and Measurements (NCRP). 2009.
4.
Industry Ground Water Protection Initiative - Final Guidance Document (NEI 07-07), Nuclear Energy Institute, August 2007.
20 ADAMS Accession No. ML24080A175