sent the best available information in the world today regarding the hazards of radiation exposure and the degree of protection that must be provided. Nevertheless, the permit contains limits for many different radionuclides which are much lower than those recommended in the general radioactivity standards contained in the consultant's report and by the ICRP. In some cases the limits in the permit for radionuclides in liquid effluent are as low as one billionth of the ICRP values. Although the effluent monitoring requirements in the permit are not clear, it appears that the concentration of each of these radionuclides is required to be monitored to demonstrate compliance with the specified limits. Such monitoring requirements would be unnecessarily burdensome because many of the radionuclides are known from experience to occur in relatively unimportant concentrations. For example, the permit specifies limits for 14 different radionuclides of noble gases expected to be released to the atmosphere. The same degree of radiation protection could be achieved by specifying a single limit for the total radioactivity in the form of noble gases, and the ease of making the measurement would be much greater because of the difficulty of measuring the concentrations of individual nuclides in the presence of so many others.

In view of the low effluent release limits we do not believe that an environmental monitoring program as comprehensive as that required in the permit is warranted. In the presentation of the draft permit to the MPCA it was stated that the required monitoring program will be ". . . considerably more comprehensive and thorough than environmental programs required in the vicinity of other commercial power plants." At the same time, doubt was cast on the value of such an elaborate and costly monitoring program with the statement, "Quite frankly, if the permit is adopted as recommended, I expect the environmental monitoring program to demonstrate clearly that the radioactive waste releases from Monticello are so low as to be extremely difficult, if not impossible, to detect in the nearby environment." On the basis of existing information, including special studies in the environs of the nuclear power plants at Dresden and Indian Point by the U.S. Public Health Service and New York State Department of Health, respectively, we agree with this evaluation.

FUEL ELEMENT INSPECTION AND LEAK DETECTION REQUIREMENT

Section 2(e) of the permit provides, in part, for ". . . initial thorough inspection of fuel rods to identify those that might develop fission product leaks, and rejection of such rods for use in the reactor . . ." It is not clear whether this requirement is intended to impose inspection procedures over and above the extensive fuel element inspection procedures required to be carried out under the AEC licensing program.

Under 10 CFR Part 50 of the Commission's regulations, reactor fuel elements are required to be designed to function throughout their lifetime without exceeding acceptable fuel damage limits which have been specified and justified in the reactor license application. The AEC also requires quality assurance programs, test procedures and inspection criteria to be used in the fabrication of fuel elements.

With regard to reactor fuel, a typical AEC license application describes rigid quality controls that are applied at every stage of fuel manufacturing to ensure that the design specifications are met. Written manufacturing procedures and quality control plans define the steps in the manufacturing process. Fuel cladding is subjected to 100 percent dimensional inspection and ultrasonic inspection to reveal defects in the cladding wall. Destructive tests are performed on representative samples from each lot of tubing, including chemical analysis, tensile, bend, and burst tests. All tubes are subjected to a corrosion resistance test (autoclave). Integrity of end plug welds is assured by standardization of weld processes based on radiographic and metallographic inspection of welds. Completed fuel rods are helium leak tested to detect the escape of helium through the tubes and end plugs or welded regions. UO2 powder characteristics and pellet densities, composition, and surface finish are controlled by regular sampling inspection. UO2 weights at every stage in manufacturing are recorded. Dimensional measurements and visual inspections of critical areas such as fuel rod-to-rod clearances are performed after assembly and after arrival at the reactor site.

The AEC believes that reactor fuel elements which are manufactured and inspected in accordance with such quality assurance procedures will perform safely and satisfactorily without the need for any additional inspection require

ments such as may be imposed under the MPCA permit. Further, the Commission's requirements, which experience has shown to be technically and economically feasible; have been demonstrated in practice to result in the limiting of radioactive releases to the environment to levels well below acceptable standards. Section 2(e) of the MPCA permit further provides for "development and application of methods and techniques for locating and identifying leaking fuel rods after operation of the reactor begins. . . The operator shall report in detail to the Agency the actual measures taken in both of these regards before startup of the reactor. If necessary, he shall initiate research and development activities designed to develop the needed procedures." In the presentation of the draft permit to the MPCA, it was stated: "This is another measure that has not been required before at commercial nuclear power plants. It may not prove an easy burden to assume, but the permit requires the company to demonstrate that it is making every effort to do so. It is emphasized that the successful development and conduct of an effective program for finding and selectively removing leaky fuel elements or fuel assemblies would introduce a new and higher level of control over radioactive wastes from reactors. It would constitute a substantial practical step forward in terms of really minimizing radioactive pollution of the environment."

The practicality of the above requirement depends on how it would be interpreted and administered. Under a strict interpretation it cannot be met with presently designed reactors. Redesign could be costly. It is more practical to fix limits on radioactivity in the primary coolant and monitor it. Operating experience with these reactors indicates that radioactivity levels in plant effluents has not resulted in any safety problem even though operation has been continued with small leaks in the fuel. This experience has not demonstrated the need for such changes in present reactor designs or in existing regulation requirements. Further, the incentive for keeping radioactivity levels low in the primary system to minimize difficulties during refueling and maintenance operations has led to development and current use of fuel claddings with very high integrity. These efforts have resulted in actual radioactivity levels well within the Commission's regulatory requirements.

DESIRABILITY OF ADOPTION OF RECOMMENDATIONS CONTAINED IN MPCA REPORT AND PERMIT

In view of the foregoing, we believe that many of the recommendations in the report cannot be justified and, apart from the legal impediment to the issuance of the permit, that the inclusion of the radiological conditions in the permit is not desirable. As discussed above, some of the recommendations of the report and restrictions in the permit, depending on how they are interpreted and administered, could be unduly burdensome without making a meaningful contribution to the public health and safety. Beyond this, the report and the permit reflect an "ad hoc" approach to the regulation of nuclear power plants which, in our view, cannot and should not be made the basis for a fair and effective regulatory program.

1967 OPERATING EXPERIENCE IN RELEASES OF RADIOACTIVITY IN LIQUID AND GASEOUS EFFLUENTS FROM NUCLEAR POWER REACTORS

The release of radioactive materials in liquid and gaseous effluents from nuclear power reactors and other AEC licensed nuclear facilities is governed by the Atomic Energy Commission's regulation, 10 CFR Part 20, "Standards for Protection Against Radiation." The following Tables I and II provide information on actual releases of radioactivity in liquid and gaseous effluents from 14 licensed nuclear power reactors in 1967.

RADIOACTIVE RELEASES IN LIQUID EFFLUENTS, 1967-TABLE I

Licenses authorizing the operation of nuclear power reactors limit concentrations in liquid effluents to concentrations given in Appendix B, Part 20. Note 1 of Appendix B requires that the concentration permitted for any one radioisotope take into account other radioisotopes that may be present. Under this requirement an individual member of the general public could use continuously the water released by a nuclear power reactor without exceeding radiation protection

Reactor

TABLE 1.-RELEASES OF RADIOACTIVITY FROM POWER REACTORS IN LIQUID EFFLUENTS, 1967

1 Facility 'icenses require that the release of radioactive liquids in plant effluents be in accordance with 10 CFR part 20, "Standards for Protection Against Radiation." Where there is a mixture of more than 1 radionuclide in the effluent, the permissible concentration is dependent upon the extent to which the licensee determines the isotopic composition of the mixture. In recognition of the time and effort required to provide complete information on the mixture, note 3 of appendix B to part 20 provides a table for determining the limiting permissible concentration if it can be demonstrated that certain isotopes are not present. The values selected by licensees from that table are shown in this column.

2 In view of the considerations expressed in note 1 above, the values given in this column represent upper bounds to the percentage of a limit that would be applicable on the basis of a complete analysis of the composition. Limits based on complete analysis, if performed, would be expected to be substantially higher than those used and the percentages in this column would be substantially less.

3 The maximum permissible concentration of tritium in water is 3X10-3uCi/ml.

4 These reactors use no lithium or boron in the primary coolant and their only significant source of tritium is fission. The fraction of fissions producing tritium is so small that none of these reactors can produce 100 curies per year, and most of the tritium produced is retained in the fuel elements until they are dissolved in a chemical reprocessing plant. 5 These data are for the 1st 8 months and the last 4 months of 1967, respectively. During the 1st 8 months the licensea used the concentration limit for a completely unidentified mixture of radioisotopes. When it became evident that the average concentration for the year would probably exceed that level, he made sufficient analyses to demonstrate that the MPC would not be less than 3X10-5 uCi/ml.

guides developed by the Federal Radiation Council, the National Council on Radiation Protection and Measurements, or the International Commission on Radiological Protection.

and

Actual use of Note 1, Appendix B, to compute the gross activity limit that must be met would require the licensee to determine the radioisotopic composition of the radioactivity in the effluent. The licensee may elect, under the provisions of Note 2, to forego some or all of such determinations if he uses more restrictive limits which assume that all of the unidentified radioisotopes in the mixture have the same concentration limit as does the most restrictive radioisotope which has not been determined to be absent from the unidentified portion of the mixture. Table I of this attachment lists for each of the operating licensed nuclear power reactors the curies of fission and corrosion products (second column), the curies of tritium (fifth column) released in effluent waters. Part 20 concentration limit for fission and corrosion products which the licensee elected to use, in accordance with the conditions of Appendix B, Part 20, and the percent of that limit actually utilized are shown in the third and fourth columns, respectively. The limit of 1×10 uc/ml selected by most of the licensees is sufficiently restrictive that it can be used for any mixture of fission and corrosion products without any identification of the specific radionuclides present in the mixture. The typical radionuclides present in water effluents from power reactors are such that, if the licensee wishes to identify them and measure their concentrations by radioisotopic analysis, limits which are less restrictive than 1×10-7 uc/ml by a factor of 100 or more could be selected. For five of the reactors shown in Table I the licensee elected to perform radioisotopic analysis and use a less restrictive limit.

RADIOACTIVE RELEASES IN GASEOUS EFFLUENTS, 1967-TABLE II

In practice, releases of radioactivity from nuclear power rectors to the atmosphere are controlled by release rate limits incorporated in the respective operating licenses. Each release rate limit is designed to make it unlikely that any

TABLE II.-RELEASES OF RADIOACTIVITY FROM POWER REACTORS IN GASEOUS EFFLUENTS, 1967

1 Where the technical specifications express a release limit in terms of a constant factor times the 10 CFR Part 20 concentration limits, the MPC used is 3X10-8 uCi/cc. This MPC is based on typical noble mixture release with less than 2 hours holdup. (For holdup longer than 2 hours the MPC is larger.)

2 Where the technical specifications do not state an annual limit for the iodines and particulates, an MPC value of 1X10-10 uCi/cc was used. This MPC is based on the most restrictive isotope normally found, 1-131. The annual limit was reduced by a factor of 700 to account for reconcentration.

3 Permissible release rate based on average wind directions from Bonus final hazards summary report PRWRA-GNEC. 4 Negligible.

individual in the vicinity of the reactor will be exposed to radiation in excess of FRC or ICRP radiation protection guides. To provide this assurance, there is computed for each reactor release rate limits in the atmosphere, taking into account local meteorology, geography, utilization of land and pathways of exposures of people. Simplicity of operation and a high degree of effectiveness are achieved by the development of limits for two basic groups of radioisotopesa) noble and activation gases, and b) halogens and particulates.

By assuming that each group consists entirely of the most hazardous isotope likely to occur, limits for the total activity of each group can be established which at the same time are conservative from the point of view of radiation protection and minimize the effort required by the licensee to meet the limit and demonstrate that he has done so.

Table II lists for each of the oeprating licensed nuclear power reactors the number of curies of radioactivity released, the limit in the license condition, and number of curies permitted to be released, and the precent of that limit actually utilized.