ML060480033

Letter from James Kottan of NRC to Linda Downing, Transmitting Comments on Report

ML060480033
Person / Time
Site:	Nine Mile Point
Issue date:	06/05/1991
From:	Kottan J NRC Region 1
To:	Downing L State Univ of New York at Oswego
References
Download: ML060480033 (2)

Text

UNITED STATES is gNUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406 JUN 0 5 19gw State University of New York Research Center ATTN:

Linda Downing Research Assistant 319 Piez Hall Oswego, New York 13126

Dear Ms. Downing:

We are returning the draft copy of your paper with our comments.

If you have any questions regarding these comments, please feel free to contact me at (215) 337-5214.

Additionally, I would like to reiterate several general comments discussed during our telephone conversation on May 30, 1991.

1. The utility is responsible for radiological environmental monitoring around a particular site.

State programs serve only as verification or quality assurance programs of the utility's program. The State programs are not intended to be complete radiological environmental monitoring programs.

2.

The radiological environmental monitoring program is designed to monitor potential pathways for human radiation exposure. The program is not designed-to monitor all possible indicators of bioaccumulation in the environment.

3.

It may be difficult to use data to assess sampling and analytical protocols.

For example, sampling and analytical protocols determine the detection limit and, therefore, the "quality" of the data.

4. Although the paper is entitled, "Nine Mile Point Nuclear Surveillance Program - A Summary", the paper appears to focus on the New York State radiological environmental monitoring verification program extensively.

Perhaps the paper should be given a different title to more accurately reflect its focus. Additionally, the recommendations appear not to discuss sampling protocols, but rather sampling locations and frequency.

There is virtually no discussion of analytical protocols.

JUN 0 5 1991 State University of New York 2

5. The tables appear to be incomplete. More information is needed regarding the data presented in the tables.

Were "less than" values included?

What about results that Include "zero", i.e., 6 +/- 4, for example.

The standard deviation should be reported with the average.

The "total n" should be defined. The reporting of data without the associated uncertainty is the reporting of meaningless data.

Sincerely, James J.

Enclosure:

As Stated