ML19345F457

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Branch Technical Position on Reg Guide 4.8 Re ETS for Nuclear Facilities
ML19345F457
Person / Time
Issue date: 11/30/1979
From:
Office of Nuclear Reactor Regulation
To:
References
RTR-REGGD-04.008, RTR-REGGD-4.008 NUDOCS 8102170514
Download: ML19345F457 (18)


Text

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y.a Revision 1 November 1979 Branch Technical Position Backoround Regulatory Guide 4.8, Environmental Technical Specifications for Nuclear Power Plants, issued for comment in December 1975, is being revised based on comments received.

The Radiological Assessment B. ranch issued a Branch Position on the radiological portion of the environmental monitoring program in March, 1978.

The position was formulated by an NRC working group which considered comments received after the issuance of the Regulatory Guide 4.8.

This is Revision 1 of that Branch Position paper.

The changes are marked by a vertical line in the right margin.

The most significant change is the increase in direct radiation measurement stations.

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 radioactive

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material released in effluents during normal operation, including anticipated operational occurrences, and resultant radiation doses to individuals from principals pathways of exposure be evaluated.

These programs should be con-ducted to verify the effectiveness of in plant 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 ourposes) to provide a basis for modifications in 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 radiation and radioactivity in the station environs.

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.

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2 AN ACCEPTABLE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Program Recuirements Environmental samples shall be collected and analyzed according to Table 1 at locations shcwn in Figure 1.1 Analytical techniques used shall be such that the detection caoabilities 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 orogram provides measurements of radiation and of radio-active materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from the station operation.

The initial radiological environmental monitoring program I

should be conducted for the first three years of commercial operation (or other period corresponding to a maximum burnup in the initial core cycle).

Following this period, program changes may be proposed based on operational experience.

The specified detection capabilities are state-of-the-art for routine environ-mental measurements in industrial laboratories.

Oeviations are permitted from the required sampling schedule if specimens are unoctainable due to hazardous conditions, seasonal unavailaoility, malfunction of automatic sampling equipment and other legitimate reasons.

If specimens are unobtainable due to sampling equipment malfunction, every effort shall be mace 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.

The laboratories of the licensea and licensee's contractors which perform analyses shall participate in the Environmental Protection Agency's (EPA's)

Environmental Radioactivity Laboratory Intercomparisons Studies (Crosscheck)

Program or equivalent program.

This participation shall include all of the determinations (sample medium-radionuclide combination) that are offered by EPA and that also are included in tne monitoring program, The results of analysis of these crosscheck sacoles shall be included in the annual report.

The participants in the EPA crosscheck program may provide their EPA program code so that the NRC can review the EPA's participant data directly in l'eu of sucmission in the annual report.

k It may to necessary to require special studies on a case-by-case and site specific basis to establish the relationship between quantities of

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radioactive material released in effluents, the Concentrations in environmental media, and the resultant doses for important pathways.

3 If the results of a determination in the EPA crosscheck program (or equivalent program) are outside the specified control limits, the lacoratory shall invas-tigate 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 report.

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 of radioactive material in environmental sample matrices as part of the quality assurance program for environmental monitoring in order to comonstrate that the results are reasonably valid.

A census shall be conducted annually during the growing season to determine the location of the nearest milk animal and nearest garden greater than 50 square meters (500 sq. ft.) producing broad leaf vegetation in each of the 16 meteorological sectors within a distance of 8 km (5 miles).2 For elevated releases as defined in Regulatory Guide 1.111, Rev.

1., the census shall also identify the locations of all milm animals, and gardens greater than 50 square meters producing broad leaf vegetation out to a distance of 5 km. (3 miles) for each radial sector.

If it is learned from this census that the milk animals or gardens are present at a location which yields a calculated thyroid dose greater than those previously sampled, or if the census results in changes in the location used in the radiowtive effluent technical specifications for dose calculations, a written report shall be submitted to the Director of Operating Reactors, NRR (with a cooy to the Director of the NRC Regional Office) within 30 days idehtifying 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 (excluding the control sample location) having the lowest calculated dose may then be dropped from the surveillance program at the end of the grazing or growing season during which the census was con-i ducted. Any location from which milk can no longer be obtained may be dropped from the surveillance program after notifying the NRC in writing that they are no longer obtainable at that location.

The results of the land-use census shall be reported 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 l

on contaminated pasture and of leafy vegetation contaminated by airborne Broad leaf vegetation sampling may be performed at the site boundary in a ij' sector with the highest 0/Q in lieu of the garden census, l

4 radioicdine 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 square meter garden, considering 20% used for growing broad leaf vegetation (i.e., similar to lettuce and cabbage), and a vegetation yield of 2 kg/m,

2 will produce the 26 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 sector with the highest D/Q should De 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.

The increase in the number of direct radiation stations is to better characteri:e the individual exposure (arem) anc population exposure (man-rem) in accordance with Criterion 64 - Monitoring radioactivity releases, of 10 CFR Part 50, Appendix A.

The NRC will place a similar amount of stations in the area between the two rings designated in Table 1.

Recorting Recuirement A.

Annual Environmental 'Jperating Report, Part B, Radiological.

A report on the radiological environmental surveillance program for the previous calendar year shall be submitted to the Director of the NRC Regional Office (with a copy to the Director, Office of Nuclear Reactor Regulation) as a separate document by May 1 of each year. The period of the first report shall begin with the date of initial criticality.

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reports shall include a summary (format of Table 3), interpretations, and

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an analysis of trends for the results of the radiological environmental surveillance activities for the report period, including a comparison with operational controls, preoperational studies (as appropriate), and I

previous environmental surveillance reports and an assessment of the l

coserved impacts of the station operation on the environment.

1 In the event that some results are not available the report shall be submittec noting and explaining the reasons for the missing results.

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missing data shall be submitted as soon as possible in a supplementary l

report.

The reports shall also include the following:

a summary description of the radiological environmental monitoring program; a map of all sampling l

locations keyed to a table giving distances and directions from one l

reactor; the results of land use censuses; and the results of licensee l

carticipation in a laboratory crosscheck program if not participating l

in the EPA crosscheck program.

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5 8.

Nonroutine Radiological Environmental Operating Reports "If a confirmed 3 measured radionuclide concentration in an environmental 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 preopera-tional data) a report need not be submitted, but an explanation shall be given in the annual report.

When more than one of the radionuclides in Table 4 are detected in the medium, the reporting level shall have been exceeded if:

concentration (1) concentration (2) repotting level (1) reporting leve) (2) 11 If radionuclides other than those in Table 4 are detected and are due from plant effluents, a r porting level is exceeded if the potential e

annual dose to an inditifdual is equal to or greater than the design objective doses of 10 CFR Part 50, Appendix I.

This report shall include an evaluation of any release conditions, environmental factors, or other aspects necessary to explain the anomalous result.

a A 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 in any case within 30 days.

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I Alil E I OPERATIONAL HAD10 LOGICAL ENVIRONMENIAL HONITORING PROGRAM Enposure Pathway Number of Samples" Sampling and Type and frequency and/or Sample and Locations Collection Frequency

  • and Analysis hiltl10RNE Radiolodine and Samples from 5 locations:

Continuous sampler Radiolodine Cannister:

Particulates operation with sample analyze weekly for 3 samples from of(site locations collection weekly or I-131 (in different sectors) of the as required by dust inichest calculated annual average loading,whicgeveris groundlevel D/Q.

more frequent I sample from the vicinity of a Particulate Sampler:

community having the highest Gross beta radio-calculated annual average Ground-activity folloging level D/Q.

filter change, composite (bylocagion)forgamma isotopic quarterly m

I sample from a control location 15-30 km (10-20 miles) distant and d

in the least prevalent wind direction DIRECT RADIAll0N 40 stations with two or more dosi-Monthly or quarterly Gasuna dose monthly or meters or one instrument for measuring

. quarterly and recording dose rate continuously to be placed as follows:

1) an inner ring of stations in the general area of the site boundary and an outer ring in the 4 to 5 mile range from the site with a station in each sector of each ring

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(16 sectors x 2 rings = 32 stations).

The balance of the stations, 8, should be place in special interest areas such l

as population centers, nearby residences, schools, and in 2 or 3 areas to serve as control stations.

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TABLE 1 (Continued) a Exposure Patliway Ntaber of Samples

$ nipling and Type and frequency and/or Sample and locations Collection Frequency" of Analysis WAILim0ltNE Surfaced I sample upstream Composite sample Gamena is topic analysis I sample downstream one month period *yer h

monthly.

Composite for tritium analyses quarterly Ground Samplesfrom1or2sourgesonly Quarterly Gasmia isotopic and if likely to be affected tritium analysis quarterly Drinking I sample of each of 1 to 3 of Composite sample I-131 analysis on each g

the nearest water supplies over two-week period composite when the dose could be affected by its if I-131 anlysis is calculated for the con-discharge performed, monthly sumption of the water composite otherwise is greate{ than 1 mrem I sample from a control location per year.

Composite for Gross p and gamma isotopic y

analyses monthly.

Compo-site for tritium analysis quarterly Sediment from I sample from downstream area Semiannually Ganna isotopic analyses Shoreline with existing or potential semiannually recreational value INGESfl0N Hilk Samples from milking animals Semimonthly when ani-Gamma isotopic and I-131 in 3 locations within 5 km mais are on pasture, analysis semimonthly when distant having the highest dose monthly at other times animals are on pasture potential.

If there are pone, monthly at other times.;

then, 1 sample froin milking animals in each of 3 areas between 5 to 8 km distant where doses are calculated to be k

greater than 1 mrem per year

TABLE 1 (Continued)

Exposure Pathway Huaiber of Samples

  • Sampling and Type and frequency a

and/or Sample and Locations Collection Frequency of Analysis Milk (cont'd)

I sample from milking animals at d control location (15-30 km distant and in the least prevalent wind direction)

Fish and I sample of each commercially and Sample in season, or Gasna isotopic Invertebrates recreationally important species semianually if they are analysis on edible in vicinity of discharge point not seasonal portions I sample of same species in areas not influenced by plant discharge Food Products 1 sample of each principal class At time of harvest Gamma isotopic of food products from any area analysis on edible which is irrigated by water in portion.

which liquid plant wastes have been discharged oo 3 samples of broad leaf vegetation Monthly when available grown nearest offsite locations of highest calculated annual average ground-level D/Q if milk sampling is not performed 4

I sample of each of the similar Monthly when available vegetation grown 15-30 km distant in the least prevalent wind direction if milk sampilng is not performed 9

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d Ihe number, media, frequericy and location of sampling may vary from site to site.

It is recognized that, at tinies, it may not he possible or practical to obtaisi samples of the media of choice at the most desired location or time.

In these instances suitable alternative media and locat. ions may be chosen for the particular pathway in question and submitted f or acceptance.

Actual locations (distance and direction) from the site shall be provided.

Refer to Regulatory Guide 4.1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants."

bParticulate saniple 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 after samipling to allow for radon and thoron daughter decay.

If gross beta activity in air or water is greater than ten times the yearly mean of control samples for any medium, ganana isotopic analysis should be performed on the individual samples.

'Gauinia isotopic asialysis means the identification and quantification of gasmia emitting radionuclides that may be i

attributable to the effluents from the facility.

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ihe purpose of this sample is to obtain background information.

If it is not practical to establish control loca-Lions in accordance with the distance and wind direction criteria, other sites which provide valid background data 1

cay be substituted.

" Canisters for the collection of radiciodine in air are subject to channeling.

These devices should be carefully checked before operation in the field or several should be mounted in series to prevent loss of iodine.

f Regulatory Guide 4.13 provides minimum acceptable performance criteria for thermoluminescence dosimotry (lLD) systems used for environmental monitoring. One or niore instruments, such as a pressurized ion chamber, for measur-i.

-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 thermoluminescent dosimeter may be considered to be one phosphor and two or more l

phosphors in a packet may be considered as two or more dosimeters.

Film badges should not be used for measuring i

direct radiation.

Ihe 40 stations is not an absolute nuaiber.

This nismber may be reduced according to geographical

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limitations, e.g., at an ocean site, some sectors will be over water so that the n unber of dosimeters may be reduced accordingly.

I UIhe " upstream sample" should be taken at a distance beyond significant influence of the discharge.

The "down-

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stream" sample should be taken in an area beyond but near the mixing zone.

" Upstream" samples in an estuary must 4

be taken tar enough upstrease to beyond the plant influence.

hGenerally, salt water is not sampled except when the receiving water is utilized for recreational activities.

IComposite 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 compositing period (e.g., monthly).

l dGroundwater samples should be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

k The dose shall be calculated for the maxistan organ and age group, using the methodoloc/ contained in Regulatory 2

Guide 1.109, Rev. 1., asid the actual parameters particular to the site.

1 If harvest occurs more than once a year, sampling should be performed during each discrete harvest.

If harvest occurs continuously, sampling should be monthly.

Attention should be paid to including samples of tuborous and root food products.

TAlllE I (Continued)

Note:

In addition to the above guidance for operational moniitorisig, the following material is supplied for guidance on preoperational programs.

Preoperational Environmental Surveillance Program A Preoperational Environmesital Surveillance Prograan should be instituted two years prior to the institution of station plant operation.

Ih1: purposes of this program are:

1.

To measure background levels and their variations along the anticipated critical pathways in the area surrounding the station.

2.

To train personnel 3.

To evaluate procedures, equipment and techniques Tha elements (sampling media and type of analysis) of both preoperational and operational programs should be essen-tia11y the same.

The duration of the preoperational program, for specific media, presented in the following table should be followed:

Durotion of Preoperational Saapling Program for Specific Media g

6 aonths 1 year 2 years

. airborne iodine

. airborne particulates direct radiation iodine in milk (while

. allk (remaining analyses) fish and invertebrates animals are in pasture)

. surface water food proclucts

. groundwater sediment (c9m shoreline

. drinking water b

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IABLE 2 a

Detection Capabilities for Environmental Sample Analysis lower Limit of Detection (LLD)b Airborne Particulate Water or Gas Fish Hilk Food Products Sediment Anaysis (pCi/1)

(pCi/m3)

(pCi/kg, wet)

(pCi/1)

(pCi/kg, wet)

(pCl/kg, dry) gross beta 4

1 x 10 11 2000 54Hn 15 130 59Fo 30 260 58,6000 15 130 652n 30 260 SZr 30 0 Nb 15 l3I c

-2 I

I 7 x 10 1

60 134

-2 Cs 15 5 x 10 130 15 60 15t:

137

-2 Cs 18 6 x 10 150 18 80 180 1408a 60 60 140,

jg jg g

Note:

This list does not mean that only these nuclides are to be detected and reported. Other peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported.

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TABLE 2 NOTES aAcceptable detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13.

DTable 2 indicates acceptable detection capabilities for radioactive materials in environmental samples.

These detection capabilities are tabulated in terms of the lower limits of detection (LLDs).

The LLD is defined, for purposes of this guide, as the smallest concentration of radioactive material in a sample that will yield a net count (above system background) that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.

For a particular measurement system (which may include radiochemical separation):

4.66 s b LLD =

E V 2.22 exp(-Aat)

Y where LLD is the "a priori" lower limit of detection as defined above (as pCi per unit mass or volume).

(Current literature defines the LLD as the detection capability for the instrumentation only, and the MD'C, minimum detectable concentration, as the detection capability for a given instrument, procedure, and type of sample.)

b is the standard deviation of the background counting rate or of s

the counting rate of a blank sample as appropriate (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 disintegrations pe.r minute per picocurie Y is the fractional radiochemical yield (when applicable) l A is the radioactive decay constant for the particular radionuclide at is the elasped time between sample collection (or end of the sample collection period) and time of counting The value of S used in the calculation of the LLD for a particular measure; g

ment system sh5uld be tased on the actual observed variance of the back-ground counting rate or of the counting rate of the blank samoles (as acpropriate) rather than on an unverified theoretically predicated variance.

13 In calculating the LLO for a radionucl:de determined by gamma-ray spectrometry, the background should include the typical contributions of other radionuclides normally present in the samples (e.g., potassium-40 in milk samples).

Typical values of E, V, Y and at should be used in the calculation.

It should be recognized that the LLD is defined as an a orfori (before the fact) limit representing the capability of a measurement system and not as a costeriori (after the fact) limit for a particular measurement.*

cLLD for drinking water samples.

  • For a more complete discussion of the LLD, and other detection limits, see the following:

(1) HASL Procedures Manual, HASL-300 (revised annually).

(2) Currie, L. A., " Limits for Qualitative Detection and Quantitative Determination - Application to Radiochemistry" Anal. Chem. 40, 586-93 (1968).

(3) Hartwell, J. X., " Detection Limits for Radioisotopic Counting Techniques," Atlantic Richfield Hanford Company Report ARH-2537 (June 22, 1972).

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TABLE 3 LNVIRONHLNTAL RADIOLOGICAL MONIIORING PROGRAM ANNUAL

SUMMARY

Hame of Facility Docket No.

Locationi of facility Reporting Period (County, State)

Medium or Type and Lower Limit All Indicator Location with lii0 hest Controllocatfons Number of Pathway Sampled lotal Number of Location Annual Mean Hean (f)

Nonroutine Mean (f)g Name Mean (f)b Range Reported 3

(Unit of of Analyses Detection Measurement)

Performed (LLD)

Rasige Distance &

Range Measurements Direction Air Particu 3) lates (pCl/m Gross p 416 0.01 0.08(200/312) Hiddletown 0.10 (S/52) 0.08 (8/104) 1 (0.05-2.0) 5 miles 340 (0.08-2.0)

(0.05-1.40)

~ y-Spec. 32 137 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 0.12 (2/24)

Podunk 0.20 (2/4) 0.02 (2/4) 1 5

3 (0.09-0.18) 4.0 miles 270* (0.10-0.31)

Fish pCi/kg (wet wei0ht) y-Spec. 8 137 130

<LLD

<LLD 90 (1/4) 0 Cs 134 130

<LLO

<tLD

<LLD 0

Cs 60 130 180 (3/4)

River Mile 35 See~ Column 4

<LLD 0

Co (150-225)

"Sto Table 2, note b.

bHean and range based upon detectable measurements only.

Fraction of detectable measurements at specified locations is indicated in parentheses.

(f)

Note:

1he example data are provided for illustrative purposes only.

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1ABLE 4 REPORl LNG LEVELS FOR NONROUllNE OPERATING REPORTS Reporting Level (RL)

Broad Leaf Water Airborne Particulate Fish Hilk Vegetation Analysis (pCi/l) or Gases (pCi/m )

(pCi/Kg, wet)

(pCi/1)

(pCi/Kg, wet) 3 4Id) 11-3 2 x 10 3

4 Mn-54 1 x 10 3 x 10 2

4 fe-59 4 x 10 1

10 3

4 Co-58 1 x 10 3 x 10 2

4 Co-60 3 x 10 1 x 10 2

4 2n-65 3 x 10 2 x 10 2

Z r-Nb-95 4 x 10 g7, 2

1-131 2

0.9 3

1 x 10 3

3 Cs-134 30 10 1 x 10 60 1 x 10 3

3 Cs-137 50 20 2 x 10 70 2 x 10 2

2 Bs-La-140 2 x 10 3 x 10 i

for driHkIng Waler samples.

This is 40 CfR Part 141 value.

  • 16 Figure 1 (This figure shall be of a suitable scale to show the distance and direction of each monitoring station.

A key shall be provided to indicate what is sampled at each location.)

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