ML19220D062
| ML19220D062 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/05/1978 |
| From: | Regan W Office of Nuclear Reactor Regulation |
| To: | Herbein J METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19220D063 | List: |
| References | |
| NUDOCS 7905160462 | |
| Download: ML19220D062 (18) | |
Text
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6 2-January 5,1973 DISTRIBUTIO)
Occket No. 50-320 Dockets (ENffEON)
WKreger NRC PDR DVassalic Lccal PDR J0slocnd NRR Reading RBallard Metrepolitan Edison Crpany DSE Reading ATTN: Mr. J. G. !!erbein EP-2 Reading Vice President WRegan JNorr.is P.O. M 92 Reading. Pennsylvania 19603 re Region I JMcGurren Gentlemn:
RVollmer By letter of Deceder 14. 1977 you transuitted to us a revised ETS Section 3.2. Radiological Environmental Honitoring Prograa. Upon reviewing it we found that there are still several minor corrections which need to be made and that the whole portion on reporting require-mats was omitted.
Enclosed is a esarted-up copy of Section 3.2 (Enclosure 1) and a copy of Branch Technical Position (Enclosure 2) to be used as a guide for the c:sitted portion. We are also enclosing a copy of tha final version of the wradiological envirorcental technical specificaticas (Enclosure 3).
By letter of December 19. 1977, we sent you the final version of the effluent radiological Technical Specifications. The enclosure to this letter and the enclosuit ta our Deceder 19, 1977 letter conctituta F
(subject to final typing) the ec.frety of the Enviren= ental Tec.Mical Spacificaticcs.
Sincerely,....
aw.
- O ikt. H. Regan, Jr., Clif ef Envirccmental Projects Branch 2 Division of Site Sa'aty and Envirecciental Analysis j
Enclosures:
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,jg 513M Metropolitan Edison Cocipany cc: GPU Service Corporation ATTN: Mr. T. Gary Broughton Safety and, Licensing Manager 260 Cherry Hill Road Parsippany, New Jersey 07054 G. F. Truwbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.
Washington D. C.
20036 Dr. Chauncey R. Kapford Box 1093 Jackson, i&aciing 83001 The Honorable Karin W. Cartar
[.
o Assistant Attorney General Office of Enforcoment Dept. of Environrental Pascurces 709 Health and Walfare Building
. Harrisburg, Pennsylvania 17120 Lawrenca Sager, Esquire 3ager and Sager Associates 45 High Street s
Pottst::wn, Pennsylvania 19464 Dr. Chauncey Kepford Citizens for a Safe Envirorcent
& York Casmittee for a Safe Envinn:: ant 2S86 Broad Street York, Peresylvanit. 17404
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Branch Technical Positien Backcround Regulatory Guide 4.8, Environmental Tecnnical Specificatiens for Nuclear Power Plants, issued for comment in December 1975, is being revised based on comments received.
The Radiological Assessment Brench has developed the following Branch Position on the radiological portion of the environ-mental monitoring program.
The position was formulated by an NRC working group which considered comments recafved after the issuance of the Regulatory Guida 4.8.
10 CFR Parts 20 and 50 require that radiological environmental monitoring programs be established to provide data on measurable. levels of radiation and radioactive materials in the site environs.
In addition, Appendix I to 10 CFR Part 50 requires that the relationship between quantities of radio-active caterial released in effluents during normal operation, including anticipated cperational occurrences, and resultant radiation doses to in-dividuals from principals pathways of exposure be evaluated. These pro-grams should be conducted to verify the effectiveness of in clant measures used for controlling the release of radioactive materials.
Surveillance should be established to identify changes in the use of unrestricted areas (e.g., for agricultrual purposes) to provide a basis for modifications in i
the monitoring programs for evaluating doses to individuals from principal pathways of exposure. NRC Regulatory Guide 4.1, Rev.1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants," provides an acceptable basis for the design of programs to monitor levels of radia-tion and radioactivity in the station en/ irons.
This position sets forth an example of an acceptable minimum radiological monitoring program.
Local site characteristics must be examined to determine if pathways not covered by this guide may significantly contribute to an individual's dose and should be included in the sampling program.
9 9
79i 119 ami
a AN ACCEPTABLE RADIOLCGICAL ENVIRONMENTAL MCNITORING PRCGRAM Procram Recuirements Environmentalsamplesshallbego}1ectedandanalyzedaccordingtoTable1 at locations shown in Figure 1.
Analytical tecnniques used shall be such that the detection capabilities in Table 2 are achieved.
The results of the radiological environmental monitoring are intended to supplement the results of the radiological effluent monitoring by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measure-ments and modeling of the environmental exposure pathways.
Thus, the specified environmental monitoring program provides measurements of radiation i
j and of radioactive materials in those exposure pathways and for those radio-j nuclides wnich lead to the highest potential radiation exposures of indivi-J duals resulting from the station operation.
The initial radiological environ-mental monitoring. program should be conducted for the first three years of commercial operation (or other period corresposaing to a maximum burnup i
in the initial core cycle).
Following this period, program changes may be proposed based on operational experience.
I The specified detection capabilities are state-of-the-art for ro'Jtine
( -
environmental measurements in industrial laboratories. The LL0s for I-131 I
in water, milk and other food products correspond to one quarter of the Apcendix I (10 CFR Part 50) design objective dose equivalent of 15 mrem /yr for atmospheric releases and 10 mrem /yr for liquid releases to the most sensitive organ and age group. They are based on the assumptions given f
in Regulatory Guide 1.109, Rev 1.
Deviations are permitted from the recuired sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment and other legitimate reasons.
If specimens are unobtainable due to sampli1g equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule
~
shall be documented in the annual report.
I The laboratories of the licensee and licensee's contractors w,
, perform analyses shall participate in the Envir-nmental Protection Agency's (EPA's)
Environmental Radioactivity Laboratory Intercoecarisons Studies (Crosscheck)
Program or equivalent program. This pa. ticipation shall include all of the-
'It may be necessary to icauire special studies en a case-by-case and site specific basis to establish the relationship between quantities of radioactive material released in effluents, the concentrations in environmental media, and the resultant doses for important pathways.
o 10
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determinations (sample medium-radionuclide comoination) that are offeret ay EPA and that also are included in the monitoring program.
The results of analysis of these crosscheck samples shall be included in the annual repo. t.
~
If the results of a deter.nination in the EPA crosscheck program (or equivalent program) are outside the specified control limits, the laboratory shall investigate the cause of the problem and take steps to correct it.
The results of this investigation and corrective action shall be included in the annual repret.
The requirement for the participation in the EPA crosscheck program, or similar program, is based on the need for independent checks on the precision and accuracy of the measurements cf radioactive material in environmental sample matrices as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid.
A census shall. be conducten annually during the growing seasoc to determine the location of the nearest milk animal and nearest garden greater than
~"
50 sq. meters (500 sq. ft.) producing broad leaf vegetation in each of the 15 meteorological sectors within a distance of 8 km (5 miles).2 For elevated releases as defined in Regulatcry Guide 1.111, Rev.1., the census shall also identify the locations of all milk animals, and gardens greater than 50 sq. meters producing broad leaf vegetation out to a distance of 5 km. (3 miles) for each radial sector.
If it is learned frem this census that the milk animals or gardens are pre-sent at a lccation which yields a calculated thyroid dose greater than those previously sampled, or if the census results in changes in the location used in the radioactive effluent technical specifications for dose calculations, a written report shall be submitted to the Director of Operating Reactors, NRR (with a copy to the Director of the NRC Regional Office) within 30 days identifying the new location (distance and direction).
Milk animal or garden locations resulting in higher calculated doses shall be added to the surveillance program as soon as practicable.
The sampling location having the lowest calculated dose may then be drepped frem the surveillance program at the end of the grazing or grcwing season during which the census was conducted. Any location from which milk can no longer be cbtained may be dropped from the surveillance program after
~Srcad leaf vegetation sampling may be performed at the site bcundary in a sector with the highest 0/Q in lieu of the garden census.
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notifying the NRC in writing tnat they are no longer obtainable at that location.
The results of the land-use census shall be reporteu in the annual report.
The census of milk animals and gardens producing broad leaf vegetation is based on the requirement in Appendix I of 10 CFR Part 50 to " Identify changes in the use of unrestricted areas (e.g., for agricultural purposes) to permit modifications in monitoring programs for evaluating doses to individuals from principal pathways of exposure." The consumption of milk from animals grazing on contaminated pasture and of leafy vegetation con-l taminated by airborne radiciodine is a major potential source of exposure.
Samples from milk animals are considered a better indicator of radiciodine in the environment than vegetation.
If the census reveals milk animals are not present or are unavailable for sampling, then vegetation must be sampled.
The 50 sq. meter garden, considering 20% used for growing broad leaf vege-tation (i.e., similar to lettuce and cabbage), and a vegetation yield of 2
2 kg/m, will produce the 25 kg/yr assumed in Regulatory Guide 1.109, Rev 1., for child consumption of leafy vegetation.
The option to consider the garden to be broad leaf vegetation at the site boundary in a ;ector 1
with the highest /Q should be conservative and that location may be used to calculate doses due to radioactive effluent releases in place of the actual locations which would be determined by the census.
This option does not apply to plants with elevated releases as defined in Regulatory Guide 1.111, Rev. 1.
i Recortino Recuirement A.
Annual Environmental Operating Report, Part B, Radiological.
A report on tne radiological environmental surveillance program for the previous calendar year shall be submitted to the Director of the NRC Regional Off,r.e (with a copy to the Director, Of fice of Nuclear Reactor Regulad;n; as a separate document by May 1 of each year.
The period of the first report shall begin with the date of initial criticality.
The reports shall include a summary (format of Table 3),
interpretations, and statistical evaluation of the results of the radiological environmental surveillance activities for the recort period, including a comparison sith operational controls, preoperational studies (as appropriate), and previous environmental surveillance reports and an assessment of tne observed impacts of the station operation on the environment.
In the event that some results are not available the report shall be submitted noting and explaining the reasons for the missing results.
The missing deta shall be submitted as soon as possible in a supple-mer'=.ry report.
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The reports shall also include the following:
a summary description of the radiological environmental monitoring program including sampling methods fo~ each sample type, si:e and pnysical cnaracteristics of each sample typc, sample preparation methods, analytical methccs, and measuring equic=ent used; a map of all samoling locations keyed to a table giving
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distances and directions from one reactcr; the results of land use censuses; and the results of licensee participation in the Environmental Protection Agency's Environmental Radioactivity Laboratory Intercom-parisons Studies (Crosscheck) Program.
B.
Nonroutine Radiological Environmental Operating Reports "If a confirmed 3 measured radionuclide concentration in an environ-mental sampling medium averaged over any quarter sampling period exceeds the reporting level given in Table 4, a written report shall be submitted to the Director of the NRC Regional Office (with a copy to the Director, Office of Nuclear Reactor Regulation) within 30 days from the end of the quarter.
If it can be demonstrated that the level is not a result of plant effluents (i.e., by comparison with control station or preoperational data) a report need not be submitted, but shall be discussed in the annual report. When more than one of the radionuc13 des in Table 4 are detected in the medium, the reporting level shall have been exceeded if:
concentration (1) concentration (2)
. ***> 1 reporting level (1) reporting level (2)
If radionuclides other than those in Table 4 are detected aid are due from plant effluents, a reporting level is exceeded if tbs potential annual dose to an individual is equal to or greate".
the design objective doses of 10 CFR Part 50, Appendix I.
This report shall include an evaluation of any release conditions, enc ironmentai factors, or other aspects necessary to explain the anomalous result.
aA confirmatory reanalysis of the original, a duplicate, or a new sample may be desirable, as appropriate.
The results of the confirmatory analysis shall be completed at the earliest time consistent with the analysis, but 'n any case within 30 days.
k)9 J'd
.j TABLE 1 OPERATI0flAL RADIOLOGIG.L ENVI90flMEllTAL H0 tilt 0 RING PROGRAli i
l Exposure Pathway llumber of Saniples" Sampling and Type and frequency and/or Sample and Locations Collection Frequency ^
and Analysis AIRBORilE Radioindine aiul Saniples frorn 3 of fsite locations (in Radiolodine Cannister:
l i
Particulates different sectors) of the hi0 est analyze 5,eekly for l
h l
calculated annual average ground-1-131
>i level D/Q.
l 1 sample from the vicinity of a Continuous sampler Particulate Sampler:
conununity having the highest operation with sample Gross beta radio-calculated annual average ground-collection weekly or activity folloging i
level D/Q.
as required by dust filter change, composit.
loading,whicheveris (by locapion) for gan.ma '
more frequent i sc $.opic quarterly I sample from a control location 15-30 km (10-20 miles) distant and d
in the least prevalent wind direction I
2 or niore do;i eters or one in-Monthly or quarterly Gamma dose monthly or DIRECT RADIAIIO!!
m strument for measuring and record-quarterly ira dose rate continuously to be placed at each of the same loca-tions as for air particulates, and at each of three additional offsite l
locations (different sectors) or highest calculated annual avera0e ground-level X/Q.
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g TABLE 1 (Continued)
Exposure Pathway flumber of Samples' Sampling and Type and Frequency and/or Sample and locations Collection Frequency of Analysis Hilk (cont'd)
I sample fran milking animals at i
a control location (15-30 km distant and in the least prevalent I
wind direction) e Fish and I sample of each connerciclly and Semiannually or in Ganna isotopic Invertebrates recreationally important species season analysis on edible in vicinity of discharge point portions 1 sample of same species in areas not influenced by plant discharge I
food Products 1 sample of each princir,al class At time of harvest Gamma isotopic of food products from aay area analysis on edible which is irrigated by water in portion.
1-131 which Ilquid plant wastes have analysis or broad been discharged lea f vegetation 3 samples of broad leaf vegetation Mcnthly when available gre.;n nearest of fsite locations of highest calculated annual average ground-level D/Q if milk sampling is not perfonned 1 sample of each of the similar llonthly when available vegetation grown 15-30 kn distant in the least prevalent wind direction I
if milk sampling is not perfonned A
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TABLE I (Continued) ihe number, media, f:cquency and location of sampling may vary from site to site It is recognized that, at times, d
it may not be possible or practical to obtain samples of the media of choice at th most desired location or t.ime.
In these instances suitable alternative media and locations may be chosen for the particular pathway in question and sutsnitted f or acceptance.
Actual locations (distance and direction) from the site shall be provided.
Refer
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to R"dulatory Guide 4.1, "Prograriis for Monitorin0 Radioactivity in the Environs of Nuclear Power Plants."
Particulate saruple filters should be analyzed for gross beta 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more af ter san.pling to allow for radon and b
thoron daughter decay.
If gross beta. activity in air or water is greater than ten times the mean of control samples for any medium, gamma isotcpic analysis should be performed on the individual samples.
j isotopic analysis means the identificaticn and quantification of gamma-emitting radionuclides that may be i
CGamma attributable to the effluents from the facility.
I Ihe purpose of this sample is to obtain background information.
If it is rot practical to establish control loca-tioas in accordance with the distance and wind direction criteria, other sites which p'covide valid background data may be substituted.
" Canisters for the collection of radiolodine in air are subject to channeling.
These devices should be carefully checked hetore operation in the ficid or several should be mounted in series to prevent loss of iodine.
(Regulutory Guide 4.13 provides minimum acceptable performance criteria for thermoluminescence dosimetry (TLD) systeno used for environmental monitoring. One or more instruments, such as a pressurized ion chamber, for measur-ing and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters.
For the purposes of this table, a thern.aluminescent do i.:aeter may be considered to be one chip, and two or more chips in a packet may be considered as two or more dosiraeters.
Ulhe " upstream sample" should be taken at a distance beyond significant influence of the discharge.
The "down-streaai" sample should be taken in an area beyond but near the mixing zone.
" Upstream" samples in an estuary must be taken far enough upstream to beyond the plant influence.
hGenerally, salt water is not sampled except when the receiving water is utilized for recreational activities.
I Composite samples should be collected with equipment (or equivalent) which is capable of collecting an aliquot at time intervals Which are Very short (e.g., hourly) relative to the Cc.TQositing period (e.g., monthly),
broundw';rsamplesshouldbetakenwhenthissourceistappedfordrinkingorirrigationpurposesinareaswhere
' Jhe hydraulic gradient or recharge properties are suitable for contamination.
he dose shall be calculated for the maximum organ and age group, using the melhor' ology contained in Regulatory uide 1.109, Rev.
I., and the actual parameters particular to the site.
f harvest occurs more th once a year, sampling should be performed durin0 each discrete harvest.
If harvest x
occurs continuously, sampling should be monthly.
Attention should be paid to including samples of tuhorous and root rood products.
i TABLE 1 (Conttaued) tiote:
In addition to the above guidance for operational monitor!ag, the following material is suppiled for guid-ance on preoperational programs.
Preoperationai Environmental Surveillance Program A Preoperatloaal Environmental Surveillance Program should be instituted two years prior to the institution of stattoi plant operation.
l 1
The purposes of this program are:
l.
To measure background levels and their variations aloag the anticipated critical pathways in the area surrounding the station.
I 2.
To train personnel i
i 3.
To evaluate procedures, equipment and techniques The elements (sampling media and type of analysis) of both preoperational and operational programs should be essen-
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tially the same. The duration of the preoperational program, for specific media, presented '- the following table j
should be followed-I i
Duration of Preoperational Sampling Program for Specific fledia 6 months l_ year
?_ years
. airborne iodine
. airborne particulates
. direct radiation iodine in milk (while
. milk ' remaining analyses)
. fish and invertebrates I
animals are in pasture)
. surface water
. food products
. groundwater
. sediment from shoreline
. drinking water 0
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l
TABLE 2 Detection Capabilities for Environmental Sample Analysis
- Lower Lirait of Detection (LLD)b Airborne Particulate l
Water or Gas Fish Hilk food Products Sediment Analysis (pci/l)
(pCl/m )
(pCl/kg, wet)
(pci/l)
(pci/kg, wet)
(pci/kg, dry) f 3
c
-2 i
gross beta 2
I x 10 3
11 330 51 130 1-1n 15
'"9fe 30 260
'a n,60Co 15 130 g
6Sin 30 260 9' I r-fah 10
-2 d
d 131 d
7 x 10 O.8 25 '"
g o,s
-2 I['I3#Cs 15 1 x 10 130 15 80 150 Ibla-l a 15 15 i
uw Li
t i
TABLE 2 90TES
- cceptable detection capabilities for thermoluminescant dosimeters used for A
environmen*.al measurenents are given in Regulatory Guide 4.13.
Table 2 indicates acceptable a tection capabilities for radioactive materials in environmental samples.
ihese detection capabilities are tabulated in terms of the lower limit! of detection (LLDs).
The LLD is, defined, for purposes of this guide, as the smallest concentration af radioactive material in a sample that will yi.ild a net count (above system background) that will be detected with 95% prot ability with only 5% probability of fcisely con-cluding that a blank obsorvation represents a "real" signal.
For a particular measurvment system (which may include radiocnemical separation):
4.6f s b et.(- M LLD =
E V
- 2. <.4 Y
where i
4 LLD is the lower limit of detection as defined above (as pCi per unit mass or volume) s a the standard deviation of the background counting rate or cf bthe counting rate of a blank sample as appropriat (as counts per minute)
E is the counting efficiency (as counts per disintegration)
V is the sample size (in units of mass or volume) 2.22 is the number of disir.tegrations per minute per picocurie Y is the fractional radiochemical yield (when applicable)
A is the radioactive decay constant for the particular radionuclide at is the elasped time between sample collection and counting The value of S usad in the calculation of the LLD for a particular measure-q ment system sh5uld be based on the actual observed variance of the back-ground counting rate or of the counting rate of the blank samoles (as appropriate).rather than on an unverified theoreti; ally predicated varicrce.
In calculating the LLD for a radionuclice cetermined by ;2mma-ray spectrometry, the background should include the typical cor.tributions of other radionuclices normally present in the samoles (e.g., potassium-a0 in milk samoies).
Typical values of E, V, Y and at should be used in the calculation.
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1, It should be reccgnized that the LLD is cefined as an a oriori (before the fact) limit representing the capability of a measurement system and not as a Epsteriori (af ter the fac-) limit for a particular measurament.*
cLLD for drinking water.
1I LLDs for I in water, milk and other food products correspond to one-quartar of the Appendix I (10 CFR Part 50) design objective cose equivalent of 15 mrem / year for atmospheric releases and 10 arem/yr for liquid releases to the most sensitive organ and age group using the asssumption= given in Regulatory Guice 1.109, Rev. 1.
e LLD for leafy vegetables.
l a cor a more complete discussion of the LLD, and other cetection limits, see the following:
(1) HASL Procedures Manual, PASL-300 (revised annually).
(2) Curria, L. A., " Limits for Qualitative Detection and Quantitative Determination - Apolication to Radiochemistry" Anal. Chem. 40, 586-93 (1968).
(3) Hartwell, J. X., " Detection Limits for Radioisotocic Counting Technicues," Atlantic Richfield Hanford Company Report ARH-2537 (June 22, 1972).
<4 7'7 llm JJJ
'/
TABLE 3 ENVIRONMENTAL RADIOLOGICAL HONITORiflG PROGRAM ANNUAL StH4ARY Name of Facility Docket No.
j Location of facility Reporting Period (County, State)
Hedium or Type and Lower Limit All Indicator Location with liighest Contr5T locctfons llumber of Location Annual Mean H"8" (I)
N "I "lI"*
Pathway Sampled lotal N eiber of (Unit of of Analyses Deteciton,
,Hean(f)g Hean (f)b Range Reported Hame Heasurement)
Performed (LLD)
Range Distance 8.
Range Measurements I
Direction Air Particu 3) lates (pCi/o Gross p 416 0.01 0.08(200/312) Hiddletown 0.10 (S/52) 0/08 (8/104) 1 (0.05-2.0) a miles 34G*
(0.08-2.0)
(0.05-1.40) y-Spec. 32 117
- 0.01 0.05 (4/24)
Smithville 0.08 (2/4)
<LLD 4
(0.03-0.13) 2.5 miles 160 ( 0. 03-2.~ 0) 131 0.07 0.03 (2/24)
Podunk 0.05 (2/4) 0.02 (2/4) 1 l
g (0.01-0.08) 4.0 miles 270* (0.01-0.08)
)
t fish pCi/kg (wet weight) y-Spec. 8 MD 90 (1/4) 0 137 I6 0
Cs.
I 134 130 MD
<UO
<UD D
Cs 60 130 120 (3/4)
River Mile 35 See Column 4
<LLD 0
m (90-200)
- See lable 3, note b.
l L4 b
La Hean and range based upon detectable measurements only.
fraction of detectable measurements at specified locations j
4s is indicated in parentheaes.
(f) j Cilo t e:
lhe example data are provided for illustrative purposes only.
TAlllE 4 REPORTIf;G LEVEL G FOR 110flR0'JTIllE OPERATillG REPORIS ReportinD Level (RL)
Broad Leaf j
Water Airborne Particulate fish Hilk Vegetation i
Analysis (pCi/l) or Gases (pC1/m )
(pCi/Kg, wet)
(pCi/1)
(pCl/Kg, wet) l 3
I ll-3 3 x IC 3
4 Ha-54 1 x 10 3 x 10 2
4 Fe-S9 4 x 10 1 x 10 3
4 Co-Sil I x 10 3 x 10 2
4 00-60 3 x 10 1; 10 2
4 2n-65 3 x 10 2 x 10 2
/r-flb-95 4 x 10
(
2 l
l-131 2
0.9 3
1 x 10 I
3 3
Cs-134 30 10 1 x 10 60
) x 10 3
3 Cs-137 SO 20 2 x 10 70 2 x 10 2
2 l
Ha-to-140 2 x 10 3 x 10 e
t,-4 U4 C.M w
e
T-Igure 1 (This figure shall be of 3 suitable scale to show the distance and direction of each monitoring station.
A key shall be provided to indicata what is sampled at each location,)
I 4
-.I e