ML19290A124

Forwards NRC Comments on Apr 1979 Draft Rept Environ Monitoring of Radioactivity

ML19290A124
Person / Time
Site:	Crane
Issue date:	09/13/1979
From:	Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT
To:	Alvarez R, Swick C ENVIRONMENTAL POLICY INSTITUTE
References
NUDOCS 7910170281
Download: ML19290A124 (21)

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.,' 3 "gg..- g > 5, m;:: 1. u fgy,mr i ;-? r;Thank..c..you for-providing.us wf th a copy of the draft repcrt,."Environa. ental..f _. ~ 'Y r W7 j-^ > Monitoring of Radioactivity", by Craig.Suick of the Environmental Policy ~

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Q' pig ';O Institute..,diately!following~ the Three. !iile Island accident, we pere;only%x

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v , B.W9 M 4 J the" report contains serious facti 41 errors and that it does not adequately' bi % - 'I reflect uither. the objectives or content of NFC environmental rddiation' i e monitoring requircaents. The attached staff' comments identify these areas., - ,. y' I b".. zIn general;.we have not cemented upon the statements which are cicarly that'- -personal opinions of Mr. SwickMO : ~4 ~'I.. h[b M .'MDYQ Y 3 $ f.1 " '.,' N D:T y. N : c u1 '* '~ 7 g,,ip,7 -the MRC:and' EPA techritcal '5t'affs "on June' 7,?1979 to -discuss.th'e report <>1 dby " ~. ;WV T Members;of h:y staff _ feel th'at the meeting was productive and will' help..te"- . Am. z u ~,v,?, ' ' W,c.V.. Qimprove future channels. f'conraunication. ' n. .,.. i. ~ o 4

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Thank 'ycu fer. pro fding us.with a ccpy.of the draft report,"Envirencental' c.,

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fd' reflect ~either the cbjectiks or content of ERC envirorcental radiation.

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monitoring requirer,ents. ~ Th ' attached staff ccmerits identify these areas.1

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.ation on the proposed EPI Ee 1:ould be~ 1nterested in. receiving. inf conference on' dose ecdeling that you men icned in your_ letter.

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1 NUCLEAR REGULATORY COMMISSION STAFF COMMENTS ON

" ENVIRONMENTAL MONITORING OF RADI0 ACTIVITY" BY CRAIG SWICK OF THE ENVIRONMENTAL POLICY INSTITUTE

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-l APRIL 1979

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l September 1979

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Nuclear Regulatory Commission Washington, D. C. 20555 i

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GENERAL COMMENT

S The principal point of the paper, " Environmental Monitoring of Radioactivity",

prepared by Craig Swick of the Environmental Policy Institute is that the Nuclear Regulatory Commission should establish standardized environmental moni-toring programs and specific requirements for procedures for the measurement of radioactive materials and that NRC should formally incorporate these requirements i

into its regulations in Title 10, Chapter I of the Code of Federal Regulations.

Response: The report does not adequately reflect the numerous Regulatory Guides and Technical Reports that NRC has issued which provide detailed guidance to license applicants and licensees on acceptable methods for conducting environ-mental radiation measurements. The report also fails to explore the actual con-ditions placed in NRC licenses which make the guidance in these Guides mandatory unless alternative methods are proposed and accepted by-the.NRC staff. Because of this lack of a thorough examination of existing NRC requirements, the report provides a misleading pictu e of the adequacy of NRC requirements.

With regard to the incorporation of standardized radioanalytical procedures into regulations, the NRC staff believes that such formalization would not only fail to have any beneficial result., but would actually be counterproductive.. Pre-sumably the use of standardized procedures is advocated as a means to obtain i

reliable results; i.e., results that are reasonably precise and accurate and that achieve the necessary lower limits of detection. The use of standardized

_j procedures alone would not achieve this end. Our view that the incorporation of standardized procedures into regulations would no' ce counterproductive is supported by Dr. John Harley, director of the Department of Energy's Environ-mental Measurements Laboratory (formerly the Health and Safety Laboratory or HASL) in the attached report by Dr. Harley.

The "EML Procedures Manual" i

l (HASL-300), which Dr. Harley edits, is cited in Mr. Swick's report as a source 2223 236 2

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of " good methods" and "well standardized and accepted procedures." The NRC staft concurs in this judgement of the high quality of the EML procedures.

tj However, as indicated in the attached paper by Dr. Harley, EML does not require a

its own contractors "o use EML " standard methods."

Dr. Harley states that "When the subject of quality control in an analytical program is raised, the frequent bureaucratic response is that standard methods of sampling and analysis are required and that use of these methods will solve the problem.

This is certainly not true, and in my opinion, standardization of methods is usually a backward step."

Rather than requiring standard methods, quality control is achieved, by EML, by setting standards of analytical performance and using quality control samples to measure performance.

The NRC staff agrees that the use of performance standards and performance testing is the best way to achieve and maintain the necessary quality of analytical results.

Requiring the use of standard methods is counterproductive because such a requirement would significantly inhibit and delay the development and application of improved procedures and preclude the necessary adaptation of procedures to special circumstances and local condi-tions thus tending to degrade, rather than improve, the quality of the results.

At the same time there would be substantially increased costs to the tax paying j

public for developing, inspecting, and enforcing regulations which would incor-porate standard procedures that would not achieve the desired results.

U Guidance on environmental monitoring (rather than mandatory use of particulac i

standard methods) is contained in the NRC Regulatory Guides.

These guides set forth guidance for licensees and license applicants on acceptable methods of complying with the regulations.

For example, Regulatory Guide 4.15 provides guidance on quality assurance on radiological effluent and environmental moni-l i

toring and this guide includes numerous references to compilations of " standard" I

methoP. of sampling and analysis.

Use of Regulatory Guides permits flexibility i

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in meeting regulatory requirements since the guides permit alternative methods I

-l of compliance providing that they are at least equivalent to the NRC guidelines.

l These Regulatory Guides are issued for public comment and a notice of issuance 4

is published in the Federal Register.

Specific minimum requirements for effluent I

l and environmental monitoring programs at a particular power reactor are contained I

in the license conditions (Technical Specifications) for each reactor.

Compli-ance with these technical specifications is required and is enforced by the Office of, Inspection and Enforcement.

NRC has several programs to ensure that the monitoring results reported by P

licensees are reliable.

One of the principal means to ensure reliable effluent and environmental measurements is a thorough quality assurance program.

In the past, many licensee or licensee-contractor laboratories have voluntarily participated in a Analytical Quality Assurance Program run by the Environmental Protection Agency (EPA) as a means of performance testing for measurements of radionuclides in environmental samples.

The environmental technical specifica-tions for all nuclear power reactors are currently being amended to require participation in this EPA " Cross-check" program as was noted in the Environ-mental Policy Institute report.

In addition, NRC inspectors examine the licensee's records and procedures during the course of routine inspections.

There is an expanding in plant measurements program which compares the licensee's analytical results on effluent measurements with results obtained by an NRC contractor laboratory.

Also, the NRC is expanding its capability to perform I

its own independent analysis of effluent and environmental radioactivity through a

the acquisition of mobile laboratories and personnel to operate these labora-i tories.

One such unit is operated by our regional office in King of Prussia, j

Pennsylvania, and was used at Three Mile Island.

Similar units are located in 2223 238 4

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several other NRC Regional Offices.

In addition to this in-hous y,

there are cooperative agreements with 16 states to conduct inderen e..c environ-i i

mental monitoring arou;.J nuclear power reactors.

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SPECIFIC COMMENTS A. STATEMENTS THAT ARE BASED UPON CORRECT INFORMATION Page 3 Second Paragraph:

Statement:

"[The EPA Cross-check program] is a very good program but it is not appropriate for the levels of radioactivity encountered in the vicinity of l

nuclear power plants.

The program was intended for monitoring fallout from atmospheric nuclear explosions and consequently has levels of radioactivity 10-100 times higher than those near power plants."

Response

This aspect has been recognized.

Provisions for the EPA to provide a certain number of quality control samples which have lower levels (somewhat above the concentrations given in Regulatory Guide 4.8, " Environmental Technical Specifications for Nuclear Power Plants") are contained in the Interagency Agreement between EPA and NRC cancerning these quality assuranc9 services.

All nuclear power plants will be r2 quired to participate in the EPA Cross-check prcgram or a similar program acceptable to the NRC as the multi year efhrt to revise technical specifications (license conditions) is completed.

In accordance with the interagency agreement, NRC has requested that the EPA include in its " cross-check" program samples that better meet NRC needs.

The samples requested include samples that have concentrations of radionuclides that are lower than those previously supplied in order to more closely approximate the concentrations found in the environment around nuclear power plants.

Because of the demand of higher priority tasks 'related to on-site evaluation of State analytical laboratories for compliance with the National Interim Primary Drink-ing Water Regulations, EPA has not yet responded to this request.

The NRC staff has contacted EPA staff requesting its support to initiate the requested actions to better meet NRC needs.

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i Environmental thermoluminescent dosimeter (TLD) measurements of radiation expo-l sure are an important part of the environmental monitoring programs for nuclear power plants.

Such measurements of environmental radiation exposure are not included in the EPA " cross-check" program which is not limited to radioactivity measurements.

However, both NRC and EPA are considering means for performance testing of environmental radiation measurements.

Some measure of the adequacy i

l of licensee environmental TLD measurements will be obtained by new NRC (Office of Inspection and Enforcement) environmental TLD measurements which will in part duplicate the licensee measurements.

Page 2, Last Paragraph

.i Comment:

"An indication of how closely NRC has looked into the monitoring methods of the utilities can be seen in its removal of the strontium-90 monitoring requirement, presumably because none of the laboratories were finding any.

Rather than cor.cluding that something might be wrong with the inboratory procedures or collection methods, NRC decided it was no longer no essary to perform the test, even though the Commission knew the plants wcce emitting Sr-90."

Response

Experience with many plants years of operating data showed that radio-strontium related to nuclear plants was being detected at insignificant levels or not at all.

At the same time strontium-90 from world-wide fallout was also being detected at very low concentrations.

However, these low concentrations of fall-out strontium-90 masked the presence of the even lower concentrations of any 1

1 plant-related strontium-90 in the environment. Thus, the cost of the environ-mental radiostrontium monitoring program was unproductive. Monitoring both l

strontium-89 and strontium-90 continues to be required for radioactive effluents from nuclear power plants where their changing levels and higher concentrations

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can more easily be detected.

Should unusual circumstances warrant environmental monitoring for radiostrontium, it will be required, on a case-by-case basis, by the NRC staff.

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B.

FACTUAL ERRORS REGARDING NRC REQUIREMENTS Page 1, Paragraph 1:

Statement:

"This deplorable condition is almost entirely due to the Nuclear Regulatory Commission's (NRC) failure to establish any required guidelines for environmental monitoring of radioactivity."

Response

The Nuclear Regulatory Commission has established a series of guide-lines for effluent and environmental monitoring.

Although these guidelines are not required in the sense of being incorporated in the NRC Regulations, they provide guidance on methods which are acceptable to the NRC staff for complying with the requirements for operating effluent and environmental monitoring i

programs which are contained in the regulations.

In lieu of acceptable alter-native methods for achieving the same objectives, licensee operations and license applications are evaluated against these guidelines.

A listing of the portions of the NRC regulations which apply to effluent and environmental moni-toring, titles of.related Regulatory Guides, and NRC technical documents are appended to these comments.

Page 1, Second Paragraph:

Statement:

"[The EPA Standards in 40 CFR 190]... represents the first time that an actual dose limit has been set for the public."

Response

Dose limits for individuals (in unrestricted areas) are in Section 20.105 of 10 CFR Part 20.

The NRC and its predecessor, the Atomic t

Energy Commission, have had limits on doses to members of the general popula-tion (dose limits applicable to unrestricted areas) since the earliest days of the civilian atomic energy program.

Statement:

"The current NRC guidelines merely require that the design model for the plant not result in a dose of more than 500 mrem to a ' typical' individual.

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A Response: The design objectives for nuclear power reactors tro not 500 milli-rem per year and are not in 10 CFR Part 20 (reference 4 in the paper).

The 500 millirem annual dose in 10 CFR Part 20, Section 20.105(a) is a limit, not a design objective. The design objectives are found in Appendix I to 10 CFR Part 50 (Section II).

These design objectives are:

Organ Liquid Effluents Airborne Effluents

-Whole Body Dose 3 mi11irem/ reactor year 5 millirem / reactor-year (from noble gases) i

-Dose to Other 10 millirem / reactor year 15 millirem / reactor-i Organs year (from radioactive l

particulates, carbon-14 and tritium)

In addition,Section IV of Appendix I to 10 CFR Part 50, specifies that, if the quantity of radioactive materials released from nuclear power reactors would give calculated doses in excess of one half of the design objective in any calendar quarter, the licensee shall:

1.

Make an investigation to identify the cause for such release rates; t

2.

Define and initiate a program of corrective action; and

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Report these actions to the appropriate NRC Regional Office within l

j 30 days after the end of the calendar quarter.

Page 2, Second Paragraph:

I Statement:

"There are no [NRC] requirements that the laboratories be certified or even be able to obtain accurate results."

And Page 3, Second Paragraph Statement:

"However, the laboratories are not required to do well in the

[ EPA Cross-check] program; and the utilities are still free to use their results, even if they are shown to be totally inconsistent."

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Response

Section 6.3.2 of Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" (December,1977) states that:

"If the mean result of a cross-check analysis exceeds the control limit as defined by EPA (Ref. 28), an investigation should be made to deter-mine the reason for this deviation and corrective action should be taken.

Similarily, an investigation and any necessary corrective action should take place if the ' normalized range', as calculated by EPA exceeds the control limit, as defined by EPA."

I l

The material in this Regulatory Guide is part of the basis for the NRC staff determination for acceptable environmental and effluent monitoring programs.

1 For example, the proposed Environmental Technical Specifications (license I

conditions) for the Three Mile Island Nuclear Station Unit No. 2 (Section 3.2 t

of Appendix Appendix B dated February 8, 1978, NRC Report NUREG-0432) state:

"If the results of a determination in the EPA cross-check program (or equivalent program) are outside the specified control limits, the laboratory shall investigate the cause of the deviation and take steps to correct it.

The results of this investigation and corrective action shall be included in the annual report." [ emphasis added].

C.

OTHER FACTUAL ERRORS Page 1, Second Paragraph l

Statement:

"New guidelines [40 CFR 190] by the Environmental Protection t

Agency (EPA) make a reliable monitoring program necessary."

I Response: The EPA position on the implementation of 40 CFR 190, as stated in the Statement of Consideration accompanying the final regelations (42 FR 2858-9 January 13,1977) is contrary to this statement:

"Some commenters expressed the view that it was not feasible to monitor cor.formance with these standards through the use of environmental mea-suraments.

The Agency agrees that routine monitoring based exclusively upon environmental measurements would not be a reasonable means for assuring conformance and the regulations do not contain such a require-ment.

Environmental objectives are best achieved through controls exercised at the source.

For this reason, effluent monitoring is generally perferable and such measurements, when combined with regula-R n'odels for environmental transport, would provide quite adequate den.onstration Jf Conformance with the standards, based upon existing 7223 744 10 1

Response

Section 6.3.2 of Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" (December,1977) states that:

"If the mean result of a cross-check analysis exceeds the control limit as cefined by EPA (Ref. 28), an investigation should be made to deter-mine the reason for this deviation and corrective action should be taken.

Similarily, an investigation and any necessary corrective action should take place if the ' normalized range', as calculated by EPA exceeds the control limit, as defined by EPA."

The material in this Regulatory Guide is part of the basis for the NRC staff I

determination for acceptable environmental and effluent monis ring programs.

For example, the proposed Environmental Technical Specifications (license j

conditions) for the Three Mile Island Nuclear Station Unit No. 2 (Section 3.2 of Appendix Appendix B dated February 8, 1978, NRC Report NUREG-0432) state:

"If the results of a determination in the EPA cross-check program or equivalent program) are outside the specified control limitr. the j

laboratory shall investigate the cause of the deviation and uke steps j

to correct it.

The results of this investigation and corrective action i

shall be included in the annual report." [ emphasis added].

C.

OTHER FACTUAL ERRORS Page 1, Second Paragraph Statement:

"New guidelines [40 CFR 190] by the Environmental Protection l

Agency (EPA) make a reliable monitoring program necessary."

Response

The EPA position on the implementation of 40 CFR 190, as stated in the Statement of Consideration accompanying the final regulations (42 FR 2858-9 January 13, 1977) is contrary to this statement:

"Some commenters expressed the view that it was not feasible to monitor conformance with these standards through the use of environmental mea-surements.

The Agency agrees that routine monitoring based exclusively upon environmental measurements would not be a reasonable means for assuring conformance and the regulations do not contain such a require-ment.

Environmental objectives are best achieved through controls

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exercised at the source.

For this reason, effluen; monitoring is generally perferable and such mea:urements, when combined with regula-tory models for environmental transport, would pr> vide quite adequate demonstration of conformance with the standards, tased upon existing 2223 245 I

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experience.

However, since varying degrees of conservatism and uncer-tainty exist in all environmental models, the Agency believes it will often be appropriate to supplement effluent monitoring with confirming environmental measurements, as is now the regulatory practice.

In the case of light water reactors, models and monitoring requirements for demonstrating conformance with Appendix I of 10 CFR Part 50 are generally adequate for demonstrating conformance with these standards.

Similiar models and measurements would, in general be appropriate for most other types of facilities."

Page 6, Paragraph 2 Statements: "The NRC has failed to specify which methods should be used in conducting environmental monitoring.

They have, however, specified very demanding quality controls for medical personnel before they are allowed to use radioisotopes at levels far below what is routinely encountered in [the]

vicinity of nuclear facilities..... Laboratories doing the environmental measurements should be required to follow procedures at least as strict because they are measuring much higher levels of radioactivity and radiation that affects a much larger population."

Response: The NRC does specify the conduct of environmental monitoring programs. The Radiological Assessment Branch's Branch Technical Position, "An Acceptable Radiological Environmental Monitoring Program," March, 1978, which i

updates the radiological portion of Regulatory Guide 4.8, is used as the basis i

to specify the plant's environmental monitoring program required by the technical specification of the utility's license. The levels of radioactive materials in environmental samples collected in the vicinity of nuclear reactors t

are generally far below the amounts of similar radioisotopes used in nuclear medicine for diagnostic and theraputic procedures. Although annual effluents i

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may approach or exceed the levels routinely used in nuclear medicine, the i

activity in periodic routine effluent samples are also generally below those used in nuclear medicine.

In addition, radioactive materials used in nuclear medicine are administered directly to individuals and are in concentrated form, J

unlike reactor effluents which must be low concentrations to meet the concentra-tion limits in 10 CFR 20, Appendix B, Table II.

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Page 8, First Paragraph Statement:

"It should also be noted that it is possible to obtain the same type of spectrographic information in the field through the use of hand held scintillation counters and portable semiconductors."

Response

Portable spectrometry equipment can be useful for evaluating the composition of deposited radionuclides on the ground or grass and for qualita-tively screening milk and other food products for high levels of radioactivity.

.iowever, portable equipment generally does not have the sensitivity or ability to make prolonged counts to reach the low limits of detection required for the analysis of environmental.adiation levels from routine reactor operation.

Page 8, Third Paragraph Statement:

"Also, the milk samples are diluted with all the other milk from that milkshed before being counted.

This may be appropriate for stating how much radiation is received by an individual buying milk at a supermarket, but it says nothing about the dose received by farm residents who drink milk from their own cows."

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Response: Gamma-ray spectrometry and radiochemical analyses for radiciodine are generally performe'd on samples from each individual dairy farm.

Samples from a given location may be composited quarterly for radiochemical analysis of cer-tain radionuclides (such as strontium-89, strontium-90, and tritium) but samples from different locations are not " diluted" with samples from other locations.

Thus the samples do provide estimates of the potential doses received by farmers i

f drinking milk from their own cows. We believe that the reactor monitoring pro-grams may have been confused with the EPA national radiation monitoring network which does utilize composite milkshed samples.

Page 9, Second Paragraph Statement:

"The only environmental monitoring equipment that had been installed [at Three Mile Island] were therm' luminescent dosimeters (TLD['s])

which are only capable of detecting gamma radiation. This means that the major source of radiation, the beta emissions from the noble gases were totally unmonitored until special equipment was brought in."

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Response

In addition to the TLDs (which were sensitive only to gamma radiation), the licensee also had continuous air radiciodine and continuous air particulate monitors at several locations as shown in Table A-1, p. 27 of the Three Mile Island 1978 Environmental Surveillance Report.

These samplers collect airborne radiciodines and particulates for subsequent laboratory analysis.

These samples are analyzed for beta activity as well as for specific gamma-emitting radionuclides.

The beta radiation from the noble gas emissions is not a major source of radiation (in the sense of contributing to potential health consequences) because of the following reasons:

i 1.

The range in air is small (approximately 30 inches for Xenon-133 beta particles) so that actual immersion in the cloud is required for exposure.

2.

External beta radiation is highly attenuated in passing through the outer

(" dead") layer of skin and any clothing.

3.

The internal inhalation dose from inhalation of noble gases is small compared to the total body gamma dose from external exposure.

l These points are discussed in detail on pages 66 to 73 of the report of the i

Ad Hoc Population Dose Assessment Group.

This report also contains estimates

'1 of the potential health significance from beta radiation which show that these i

d contributions are small compared with those from the external whole body gamma doses.

In view of these considerations, the information that would have been gained by having dosimeters that would detect beta radiation would not have materially improved the dose assessment for the accident.

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MISLEADING STATEMENTS Page 1, First Paragraph Statement:

"The frs gently quoted statement of the National Research Council "i

that 'the nation's information on environmental quality is dep orably and unnecessarilybad'isespeciallytrueofradiationmonitoring.]"

Response

The reference citation (superscript 1) is misplaced as it should follow the quote. That this situation is "especially true of radiation monitoring" could then be correctly identified as the author's personal opinion and not that of the National Research Council.

Page 3, Second Paragraph Statement:

"The [ EPA] Cross-check program sends out food samples with a known amount of various radionuclides added to them."

Response

The EPA Cross-check program distributes more than food samples.

The EPA program also has distributed samples of water, urine, and air filters to determine the precision of analyses of these media.

The results of the EPA Cross-check program for these media are found on pp. 86 - 91 of the Three Mile Island Nuclear Station Annual (1978) environmental radiation monitoring report.

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I REQUIREMENTS IN THE NRC REGULATIONS RELATED TO EFFLUENT AND ENVIRONMENTAL MONITORING The requirements for effluent and environmental monitoring programs are found in

g the following sections of Title 10, Chapter I of the Code of Federal Regulations

Part 20 Standards for Protection Against Radiation

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20.201 - Surveys l

20.401 - Records of surveys, radiation monitoring and disposal 20.405 - Reports of overexposures and excessive levels and concentrations Part 30 Byproduct fiaterial Licensing 30.51 - Records (paragraph [c])

i Part 40 Domestic Licensing of Source Material 40.61 - Records 40.65 - Effluent monitoring reporting requirements Part 50 Domestic Licensing of Production and Utilization Facilities 50.34 - Contents of applications; technical information - in particular 50.34(b)(2) and 50.34(b)(3).

50.34a - Design objectives for equipment to control releases of radioactive j

materials in effluents - nuclear power reactors I

50.36 - Technical specifications I

50.36a - Technical specifications on effluents from nuclear power reactors i

Io 10 CFR Part 50 - Appendix A, General Design Criteria for Nuclear Power Plants Criterion 1 - Quality standards and records (General applicability)

Criterion 60 - Control of releases of radioactive materials to the environment Criterion 64 - Monitoring radioactivity releases 2223 250

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10 CFR Part 50 - Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing 91 ants (This requirement does not' apply specifically to monitoring as it applies generally to quality assurance criteria for design and construction as well as for plant operation. )

c 10 CFR Part 50 - Appendix E, Emergency Plans for Production and Utilization Facilities (Section IV C. in particular)

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10 CFR Part 50 - Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion.

"As Low As Is I

Reasonably Achievable" for Radioactive Material on Light-Water-Cooled Nuclear Power Reactor Effluents (Section IV B. contains explicit conditions on effluent and environmental radiation monitoring.)

10 CFR Part 51 - Licensing and Regulatory Policy and Procedures for Environmental Protection (General requirements for environmental reports.)

10 CFR Part 70 - Domestic Licensing of Special Nuclear Material 70.22 - Contents of applications (paragraph [a] [7] in particular) 70.59 - Effluent monitoring reporting requirements

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REGULATORY GUIDES CONTAINING GUIDANCE TO LICENSEES AND LICENSE APPLICANTS ON EFFLUENT CONTROL AND MONITORING, EN"IRONMENTAL RADIATION MONITORING AND DOSE ASSESSMENT

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Division 1 Nuclear Power Reactors Regulatory Guide 1.21, Rev. 1, " Measuring, Evaluating, and Reporting Radio-

'l activity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants"

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Regulatory Guide 1.23, "Onsite Meteorological Programs" Regulatory Guide 1.70 (Rev. 3), " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants" (in particular Chapter 11 - Radioactive Waste Management and Chapter 12 - Radiation Protection) i Regulatory Guide 1.109 (Rev. 1), " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I" Regulatory Guide 1.110, " Cost-Benefit Analysis for Radwaste Systems for Light-Water-Cooled Nuclear Power Reactors" Regulatory Guide 1.111 (Rev. 1), " Methods for Estimating Atmospheric Transport i

and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors" Regulatory Guide 1.112, " Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents from Light-Water-Cooled Power Reactors" Regulatory Guide 1.113 (Rev. 1), " Estimating Aquatic Dispersion of Effluents j

from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I" t

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Regulatory Guide 1.140, " Design, Testing, and Maintenance Criteria for Normal Ventilation Exhaust System Air Filtration and Absorption Units of Light-Water-l Cooled Nuclear Power Plants"

,l Division 3 Fuels and Materials Facilities Regulatory Guide 3.2, " Efficiency Testing of Air-Cleaning Systems Containing Devices for Removal of Particles" 2223 252 l

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. ~wmawm Regulatory Guide 3.5 (Rev. 1), " Standard Format and Content of License Applications for Uranium Mills" (in particular, Chapter 5 - Environmental Effects of Mill and Mine Operation, Chapter 6 - Effluent and Environmental Measurements and Monitoring Programs and Appendix A - Suggested Format for Reporting Radiological Parameters)

Regulatory Guide 3.12, " General Design Guide for Ventilation Systems of Plutonium Processing and Fuel Fabrication Plants" Regulatory Guide 3.20, " Process Offgas Systems for Fuel Reprocessing Plants" Regulatory Guide 3.25, " Standard Format, and Content of Safety Analysis Reports for Uranium Enrichment Facilities" (for commercial plants - in partir:ular, Chapter 8 - Radiation Protection)

Regulatory Guide 3.26, " Standard Format and Content of Safety Analysis f

Reports for Fuel Reprocessing Plants" (in particular Chapter 7 - Waste Confinement and Management and Chapter 8 - Radiation Protection)

Regulatory Guide 3.32, " General Design Guide for Ventilation Systems for Fuel Reprocessing Plants" Regulatory Guide 3.39 NUREG-0010), " Standard Format and Content of License Applications for Plutonium Processing and Fuel Fabrication Plants" (in particular Chapter 7 - Waste Confinement and Management and Chapter 8 -

Radiation Protection)

Draft Regulatory Guide RH-802-4, " Calculational Models for Estimating Radiation Doses to Man from Airborne Radioactive Materials Resulting from Uranium Milling Operations" Division 4 Environment and Siting Regulatory Guide 4.1 (Rev.1), " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants" f

Regulatory Guide 4.2 (Rev. 2), " Preparation of Environmental Reports for Nuclear Power Stations" (in particular Section 3.5 - Radwaste Systems and Source Team, Section 5.2 - Radiological Impact from Routine Operation" and Environmental Measurements and Monitoring Programs)

Regulatory Guide 4.5, " Measurements of Radionuclides in the Environment -

j Sampling and Analysis of Plutonium in Soil' Regulatory Guide 4.6, " Measurements of Radionuclides in the Environment -

Strontium-89 and Strontium-90 Analyses" l

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Regulatory Guide 4.8, " Environmental Technical Specifications for Nuclear Power Plants" Radiological Assessment Branch Technical Position, "An Acceptable Radiological d

Environmental Monitoring Program," March, 1978.

(This updates the radiological portion of Regulatory Guide 4.8)

Regulatory Guide 4.9, " Preparation of Environmental Reports for Commercial Uranium Enrichment Facilities (Rev. 1)"

(in particular Chapter 6 - Effluent and Environmental Measurements and Monitoring Programs)

Regulatory Guide 4.13 (Rev. 1), " Performance, Testing, and Procedural Specifications for Thermoluminescent Dosimetry:

Environmental Applications" Regulatory Guide 4.14, " Measuring, Evaluating and Reporting Radioactivity in Releases of Radioactive Materials in Liquids and Airborne Effluents from Uranium Mills" Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment" i

Regulatory Guide 4.16, " Measuring, Evaluating, and Reporting Radioactivity in Releases of Radioactive Materials in Liquid and Airborne Effluents from Nuclear Fuel Processing and Fabrication Plants" i

Division 8 Occupational Health i

These guides relate to in plant operations and worker protection.

Division 10 General Regulatory Guide 10.2 (Rev. 1), " Guidance to Academic Institutions Applying l

for Specific Byproduct Material Licenses of Limited Scope" Regulatory Guide 10.3 (Rev. 1), " Guide for the Preparation of Applications for Special Nuclear Materials Licenses of Less Than Critical Mass Quantities" I

Regulatory Guide 10.4 (Rev.1), " Guide for the Preparation of Applications for Licenses to Possess Source Material" 1

Regulatory Guide 10.5 (Rev. 1), " Guide for the Preparation of Applications i

for Type A Licenses of Broad Scope for Byproduct Material" Regulatory Guide 10.7, " Guide for the Preparation of Applications for Licenses Nr Laboratory Use of Small Quantities of Byproduct Material" 2223 254 1

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l NRC TECHNICAL REPORTS PROVIDING ADDITIONAL GUIDANCE ON EFFLUENT CONTROL, ENVIRONMENTAL RADIATION MONITORING AND DOSE ASSESSMENT

" Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants", NRC Report NUREG-0133, October, 1978

" Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents from Pressurized Water Reactors (PWR-GALE Code)", NRC Report NUREG-0016 (Rev. 1)

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" Calculation of Releases of Radioactive Materials in Gaseous and Liquid j

Effluents from Boiling Water Reactors (BWR-GALE Code)", NRC Report NUREG-0017 I

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" Radiological Environmental Monitoring by NRC Licensees for Routine Operation of Nuclear Facilities", NRC Report NUREG-0475, October, 1978.

" Radiological Effluent Technical Specifications for PWR's," NRC Report NUREG-0472, Rev 3, March 1979.

" Radiological Effluent Technical Specifications for BWR's," NRC Report NUREG-0473, Rev 3, March 1979.

t Gail de Planque, " Evaluation of Methods for the Determination of X-and Gamma-Ray Exposure Attributable to a Nuclear Facility Using Environmental TLD Measurements." NRC Report NUREG/CR-0711 (June 1979).

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