ML20002C231

Responds to 801126 Memo Re Lack of Groundwater Monitoring Program at Facility.Map of Station & Elevations Above Sea Level Encl.Monitoring Not Required Unless Hydraulic Gradient or Recharge Properties Are Suitable for Contamination

ML20002C231
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/23/1980
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FOIA-81-93 NUDOCS 8101090715
Download: ML20002C231 (23)

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2 Docket No. 50-295 and 50-304 MEMORANDU*i FOR: Samuel J. Chilk, Secretary FROM:

Willian J. Dircks Executive Director for Operations

SUBJECT:

GROUNDWATER MONITORING AT ZION STATION FACILITY On November 26,1980 (Reference SRM801126), you requested a response to Commissioner Bradford's request as to "why there is no groundwater moni-toring program at Zion".

The Zion Station sits on the shoreline of Lake Michigan about one mile from the western edge of the City of Zion, Illinois (see Enclosure 1).

The plant is on a sand dune knoll with a marsh between the plant and the population of Zion. Enclosure 2 gives a tabular accounting of the ele-vations above mean sea level for the plant, lake and the City of Zion.

From the table, it is seen that the land in this area slopes downward toward the east and the lake, with the western edge of Zicn about 120 feet above the level of the lake.

From the foundation borings taken during construction, the underlying fomations also slope eastward toward the lake as did the water table. The staff position (Branch Technical Position, Revision 1, dated November 1979, Enclosure 3) on groundwater monitoring does not require monitoring unless the hydraulic gradient or recharge properties are suitable for contamination. We do not believe that this is the case at the Zion site, and therefore, have not required groundwater monitoring.

MRCiaallDirclq William J. Dircks Executive Director for Operations

Enclosures:

1.

Zion EIS, Page 11-2 2.

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Branch Technical Position L

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ATTACHMENT 2 ELEVATIONS SHOWING GRADIENT TOWARD LAKE j

Elevation in Feet Eastern Edge of City of Zion (2-1/2 miles from plant) 700 Western Edge of City of Zion (1 mile from plant) 600 Marsh Betwden Plant and City of Zion 586 - 588 Grade at Plant 591 Average Lake Elevation

• 578 Static Low Water Level of Lake 577 Lake Bottom level at 1.2 Miles Offshore 550 (30 foot depth) f J

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• Recorded Maximum 584'; Minimum 577' SOURCE: Zion Station Final Safety Analysis Report

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ATTACHMENT 3 o

Revision 1 November 1979 Branch Technical Position Backtround 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 Raciological Assessment Branch 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 receivec after the issuance of the Regulatory Guide 4.8.

This is Revision 1 cf 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

? art 50 requires that the relationship between quantities of radioactive 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 tne release of radioactive materials.

Surveillance should be established to icentify changes in the use of unrestricted areas (e.g., for agricultrual purposes) to pr' ovide 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.

ihis 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.

1 I

l 2

1 AN ACCEPTABLE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Precram Recuirements Environmental samples shall be collected and analyzed according to Table 1 at locations shown in Figure 1.1 Analytical technicues used shall be sucn that the cetection capabilities in Table 2 are achievec.

The results of the radiological environmental monitoring are-intended to supplement the results of the radiological effluent monitoring by verifying tnat 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 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 should be conducted for the first three years of commercial oper: tion (or other period corresponding to a maximum burnup in the initial core cyc'e).

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

The sr detection capabilities are state-of-the-art for routine environ-mental

,asurements in industrial laboratories.

Deviations ara permitted from the required 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 sampling 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.

Tne laboratories of the licensee 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 i

determinations (sample medium-radionuclide combination) that are offered by E?A and that also are included in the monitoring program.

The results of l

analysis of these crosscheck samples shall be incluced in the annual report.

The participants in the EPA crosscheck program may provide their EPA program coce so that the NRC can review the EPA's participant data directly in lieu of suomission in the annual report.

'It may be nece'ssary to require special studies on a case-by-case and site specific basis to establish the~relationsnip between quantities of racioactive material released in effluents, the concentrations in environmental media, and the resultant doses for important pathways.

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3 If the results of a determination in the EPA crosscheck program (or equivalent program) are outside the specified control limits, the laboratory shall inves-tigate the cause of.the problem and take steps to correct it.

The results cf tais investigation and ccrrective action shall be included in the annual report.

The recuirement for the participation in the EPA cresscheck program, or similar pregram, 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 demonstrate 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 garcen greater than 50 square 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 Regulatory Guide 1.111, Rev.1., the census shall also icentify the locations of all milk animals, and gardens greater than 50 square meters producing broad leaf vegetation out to a distance of 5 km. (3 miles) i 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 sammled, or if the census results in changes in the location used in the radioactive effluent technical specifications for dose calculations, a written recort shall be submitted to the Director of Operating Reactors, NRR (with a cocy to the Director of the NRC Regional Office) within 30 days identifying tne new location (distance and diraction).

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-ducted.

Any location from which milk can no longer be obtained may be dropped free 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 l

snall be reported in the annual report.

l 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 areat (e.g., for agricultural purposes) to permit mocifications in monitoring programs for evaluating doses to incividuals from crincipal pathways of exposure." The consumotion of milk from animals gra:ing en contaminated pasture and of leafy vegetation contaminated by airborne

^ 5ccac leaf vegetation sampling may be performed at the site boundary in a sector with the highest D/Q in lieu of the garden census.

4 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 samplir.g, then vegetation must be sampled.

The 50 scuare meter garden, considering 2C% used for growing broad leaf vegeta' tion 2

(i.e., similar to lettuce and cabbage), and a vegetation yield of 2 kg/m,

will produce the 26 kg/yr assumed in Regulatory Guide 1.109, Rev 1., for child consumption of leafy vegetation.

The cption to consider the garden to be breac leaf vegetation at the site boundary in a sector with the highest D/Q should be conservative and that location may be used to calculate doses due to radioactive effluent releases in place rf 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 indivicual exposure (mrem) and population exposure (man-rem) in accordance with Criterion 64 - Monitoring radioactivity releases, of 10 CFR Part 50, Aopendix A.

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

Recortine Recuirement A.

Annual Environmental Operating Report, Part B, Rad 1ological.

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. The reports shall include a summary (format of Table 3), interpretations, and 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 previous environmental surveillance reports and an assessment of the observed impacts of the station operation on the environment.

l 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 data shall be submitted as soon as possible in a supplementary report.

The reports shall also include the following:

a summary description of the radiological environmental monitoring program; a map of all sampling locations keyed to a table giving distances and directions from one reactor; the results of land use censuses; and the results of licensee

~

carticipation in a lacoratory crosscheck program if not participating l

in tne EPA crosscheck program.

5 B.

Nonroutine Radiological Environmental Operating Reports "If a confirmed 8 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 cuarter.

If it can be comonstrated that the level is not a result of

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lant effluents (i.e., by comparison with control station or preepera-tional cata) a report need not be suomitted, but an explanation shall be given in the annual report.

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

concentration (11 concentration (2)

• • • 3 3 reporting level (1) reporting level (2)

If radionuclides other than those in Table 4 are detected and are due from plant effluents, a reporting level is exceedec if the potential annual cose to an individual is equal to or greater than the design ocjective doses of 10 CFR Part 50, Appendix I.

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

A confirmatory reanalysis of the original, a duplicate, or a new sample may be cesirable, 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.

1 Alll E 1 Ol'LHAT10HAl. HA010 LOGICAL I NVillotitl[NIAL H0HII0ltING PROGilAH Lxposure Pa w.iy Number of Samples" Sampling and Type and frequency and/or Sample and Locations Collection Frequency

• and Analysis hlRBORNE i

R:dioiodine and Samples from 5 locations:

Continuous sampler Radiolodine Cannister:

Particulates operation with sample analyze weekly for 3 samples from offsite locations collection weekly or 1-131 (in different sectors) of the as required by dust highest calculated annual average loading.whicp,everis groundlevel D/Q.

more frequent t

I sample from the vicinity of a Particulate Sampler:

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

filter change, composit.e (bylocagion)forgamma isotopic quarterly as I sample from a control location 15-30 km (10-20 miles) distant and d

in the least prevalent wind direction DlHECf RAlllAll0N 40 stations with two or more dost-Honthly or quarterly Gamma 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 (16 sectors x 2 rings = 32 stations).

The balance of the stations, 8. should he place in special interest areas such as population centers, nearby residences.

schools, and in 2 or 3 areas to serve as control stations.

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I TABLE I (Cent.inued)

Exposure Pithway Nimber of Samples" Sampling and lype and Frequency l

and/or Sample and Locations Collection f requency" of Analysis WAllitil0ltNE Surface 1 sample upstream Composite sample "Yer Gamma isot plc analysis 9

h g

j i sample downstream one month period monthly.

Composite for j

tritita analyses quarterly Ground Samplesfrom1or2sourgesonly Quarterly Gamma isotopic and if Ilkely to be affected trittim analysis quarterly Drinking I sample of each of 1 to 3 of Composite sample I-131 analysis on each j

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 greatep than 1 mrem I sample from a control location per year.

Composite for l

Gross p and gamma isotopic y

analyses monthly.

Compo-l site for tritium analysis quarterly l

Ssdiment from I sample from downstream area Semiannually Gamma isotopic analyses 3

Shoreline with existing or potential semiannually i

recreational value INGEST 10N Hilk Samples from allkin0 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 monthly at other times,;

potential.

If there are pone.

then, I sample from milking animals in each of 3 areas between 5 to 8 km distant where tinses are calculated to be k

greater than 1 mrem per year 1

4

TABLE I (Centinued)

E posure Pathway Number of Samples" Sampling and Type and frequency and/or Sample and Locations Cn11cction frequency" of Analysis Milk (cont'd)

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

Fish and 1 sample of each commercially and Sample in season, or Gamma isotopic Invertebrates recreationally important species semianually if they aro analysis on edible in vicinity of discharge point not seasonal portions I sample of same species in areas not influenced by plant discharge l

Fcod Products I 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 heen dischar0ed a

3 samples of broad leaf vegetation Monthly when available grown nearest offsite locations of highest calculated annual average ground-level D/Q if milk sampilng is not performed I sample of each of the similar Monthly whbn available vegetation grown 15-30 km distant in the least prevalent wind direction if milk sampilng is not per, formed 1

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TADLE I (Continued) f "the number. media, frequency and location of sampling snay vary from site to site.

It is recognized that, at times.

it may not he possible or practical to obtain samples of the media of choice at the most. desired location or t.ime.

in these in.tances suitable alternativo media and locations may he chosen for the particular pathway in question-and submitted for 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 Nucicar Power plants."

bparticulate sample 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 sampilng 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 Joy medium, ganea isotopic analysis should be performed on the individual samples.

{

Gamma isotopic analysis means the identification and quantification of ganna-emitting radionuclides that may be C

attributable to the effluents from the facility.

d ihe purpose of this sample is to obtain background information.

If it is not practical to establish control loca-Lions in accordarice with the distance and wind direct.lon criteria, other sites which provide valid background data cay be substituted.

' Canisters for the collect.lon of radiofodine in air are subject. to channeling.

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

fRe0ulatory Guide 4.13 provides minimum acceptable performance criteria for thermoluminescence dosimetry (TLD) systems used for environmental monitorinD. 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

'a the purposes of. this table, a thermoluminescent dos! meter may be considered to be one phosphor and two or more phosphors in a packet may be considered as two or more dosimeters.

Flim badges should not be used for measuring direct. radiat. inn.

The 40 stations is not. an absolute number. This number may be reduced according to geographical limitations, c.0.. at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly.

UIhe "upstrearn sample" should be taken at a distance heyond significant influence of the discharge.

The "down-stream" sample should he taken in an area beyond but near the mixing zone.

" Upstream" samples in an estuary must.

he 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.

IComposite samples should be collected with equipment (or equivalent) which is capable of collecting an aliquot at. Lime intervals which are very short. (e.g., hourly) relat.ive'to the compositing period (e.g., monthly).

i 3 Groundwater samples should he taken when this source is tapped for drinkin0 or irrigat.lon purposes in areas where tha hydraulic gradient or recharge properties are suitable for contamination.

i "Tha dose shall be calculated for the maximum organ and age Group, using the methodology contained in Regulatory Guide 1.109, Rev.

I., and 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 cont.inuously, sampling should be monthly.

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

i TAlli.E 1 (Continued) l Note:

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

Preopsrational Environmental Surveillance Program A Prcoperational Environmental Surve111ance Program should be instituted two years prior to the institution of station plcnt operation.

Th2 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 The elements (sampling media and type of analysis) of both preoperational and operational programs should be essen-ticily the same.

The duration of the preoperational program, for specific media, presented in the following. table l

should be (n110wed:

Duration of Preoperational Samplin] Program for Specific Media g

6 months 1 year 2 years

. airborne lodine

. airborne particulates

. direct radiation iodine in slik (while

. milk (remaining analyses)

. fish and invertebrates animals are in pasture)

. surface water food products

. groundwater

. sediment from shoreline

, drinking water 9

TAntE 2 Detection Capabilities for Environmental Sample Analysis" Lower Limit of fletection (ILD)b Airborne Particulate Water or Gas Fish

.Hilk Food Products Sediment Anaysis (pCi/l)

(pCi/m3)

(pCi/kg,we't)

(pCl/1)

(pCl/kg, wet)

(pCi/kg, dry)

-2 gross beta 4

1 x 10 3ll 2000 b Hn 15 130 59Fe 30 260 58,60C0 15 130 65 2n 30 260 952r 30 95Hb 15 I3I C

-2 l

I 7 x 10 1

60 134

-2 Cs 15 5 x 10 130 15 60 150 137

-2 0s 18 6 x 10 150 18 80 180 140

-60 Ba 60 140 15 ta 15 Note:

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

12 TABLE 2 NOTES aAcce: table detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13.

Ta:1e 2 indica'tes 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 exp(-Aat)

V

2. 22 LLD =

E Y

where LL.') is th9 "a priori" lower limit of detection as defined above (as pCi per unit mass or volume).

(Current literature defines the LLO as the cetection 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.)

s is the standard deviation of the background counting rate or of bthe 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 per minute per picoeurie 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 (or end of the sample collection period) and time of counting The value of S used in the calculation of the LLO for a particular measure-s nent system sh5uld be caseo en the actual observed variance ~ of the back-grounc counting rate or of the counting rate of the blank samoles (as accrocriate) rather than on an unverified theoretically predicated variance.

o 2

13 In calculating the LLD for a radionuclide determined by gamma-ray spectrometry, the background should include the typical contributions of other radionuclides j

nor= ally 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 recognited that the LLD is defined as an a erfori (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.

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l

" 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 Com:any Report ARH-2537 (June 22, 1972).

l l

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TABLE 3 ENVIRONMENTAL RADIOLOGICAL H0HITORING PROGRAM ANNUAL SUliHARY N.me of Facility Docket No.

location of facility Reporting Period (County, State)

Medium or Type and Lower Limit All Indicator Location with H10 est Controllocatfons Number of h

location Annual Mean Hein (f)

Nonroutine Pathway Sampled Total Htmiber of (Unit of of Analyses Nicction, Hean(f)g Name Mean (f)b Range Reported He:surement)

Performed (LLD)

Range Distance &

Range Measurements Direction Air Particu-lates (pCi/m )

Gross ji 416 0.01 0.08(200/312) Middletown 0.10 (5/52) 0.08 (8/104) 1 (0.05-2.0) 5 miles 340" (0.08-2.0)

(0.05-1.40)

'y-Spec. 32 1

C5 b 3-0 3) 5 11 160* b03 131 0.07 0.12 (2/24)

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

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

l Fish pCi/kg (wet weight) y-Spec. il 137 130

<LLD

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

<LLD

<LLO

<tLD 0

Cs 60,

130 180 (3/4)

River Mile 35 See Column 4

<LLD 0

i g

(150-225) aSso Table 2, note h.

Hein and range based upon detectable measurements only.

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

(f)

Note:

the example data are provided for ill"strative pisrposes orily.

TABl.E 4 HEPORTING LEVELS FOR HONRolliiNE OPERATING REPORTS Reporting level (RL)

Droad Leaf Water Ai:1)orne Particulate Fish Milk Ve0etation Analysis (pC4/l) or Gases (pCl/m )

(pCi/Kg, wet)

(pCl/1)

(pCl/Kg, wet) 8 4I")

11-3 2 x 10 4

Hn-54 1 x 10 3 x 10 2

4 Fo-59 4 x 10 1 x 10 3

4 Co-58 1 x 10 3 x 10 Cc-60 3 x 10 1 x 10 2

4 in-65 3 x 10 2 x 10 2

Ir-Hb-95 4 x 10 g

2 l-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

1. Fer drinking water samples.

This is 40 CFR Part 141 value.

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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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' * * * %"o' UNITED ST ATES NUCLEAR REGULATORY COMMISSION IN RESPONSE l

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~j 5 's N) E W ASHIN GTON. D.C. 2055s REFER TO SRM 801126

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s November 26, 1980

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• p OFFICE OF THE SECRETARY MEMORANDUM FOR:

Williar J.

Dircks, Executive Director for Operations

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FROM:

Samuel J. Chilk, Secreta

SUBJECT:

COMMONWEALTH EDISON COMPANY'S ZION STATION FACILITY

(

In connection with a recent commission action on an Appeal Board decision, Commissioner Bradford requested information from the staff as to "why there is no groundwater monitoring program at Zion."

It is requested that you provide a response to Commissioner Bradford's request through the Office of the Secretary by 1

c.o.b. December 26, 1980.

cc:

Chairman Ahearne Commissioner Gilinsky Commissioner Hendrie Commissioner Br'adford 1

General Counsel Director,' Policy Evaluation t

CONTACT:

E. W. McGregor (SECY) 41410 i

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..,4f UNITED STATES g

NUCLEAR REGULATORY COMMISSION )

g g(/ ' E WASHINGTON, D. C. 20555

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Docket No. 50-295 and 50-304 MEMORANDUM FOR: Samuel J. Chilk, Secretary FROM:

William J. Dircks Executive Director for Operations

SUBJECT:

GROUNDWATER MONITORING AT ZION STATION FACILITY On November 26, 1980 (Reference SRM801126), you requested a response to Commissioner Bradford's request as to "why there is no groundwater moni-toring program at Zion".

The Zion Station sits on the shoreline of Lal:e Michigan about one mile from the western edge of the City of Zion, Illinois (see Enclosure 1).

The plant is on a sand dune knoll with a marsh between the plant and the population of Zion. Enclosure 2 gives a tabular accounting of the ele-vations above mean sea level for the ' plant, lake and the City of Zion.

From the table, it is seen that the land in this area slopes downward toward the east and the lake, with the western edge of Zion about 120 feet above the level of the lake. From the foundation borings taken during construction, the underlying fomations also slope eastward toward the lake as did the water table. The staff position (Branch Technical Position, Revision 1, dated November 1979, Enclosure 3) on groundwater monitoring does not require monitoring unless the hydraulic gradient or recharge properties are suitable for contamination. We do not believe that this is the case at the Zion site, and therefore, have not required groundwater monitoring.

William J. Dircks Executive Director for Operations

Enclosures:

1.

Zion EIS, Page 11-2 2.

Elevations Showing Gradient Toward Lake 3.

Branch Technical Position l

_.