ML20004F555

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Recommends That ETS Include Requirements for Periodically Monitoring Groundwater for Radioactivity
ML20004F555
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 01/07/1981
From: Higginbotham L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20004F549 List:
References
FOIA-81-93 NUDOCS 8106190068
Download: ML20004F555 (19)


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?!El!0RANDUM FOR:

L. B. Higginbotham, Chief, Radiological Safety Branch, Division of Safeguards and Radiological Safety Inspection FROM:

A. B. Davis, Chief, Fuel Facility and ?bterials Safety Branch, Region III

SUBJECT:

ENVIROIO! ENTAL MONITORING OF GROUND WATER (AITS NO. F03000681 H08, REQUESTED COMPLETION DATE - 2/1/81)

Recently at the Dresden Nuclear Station Region III investigated an apparent loss of station water inventory (IE Report 50-10/80-15; 50-237/80-18; 50-247/80-22, attached).

One potential mode of water loss was identified to be leakage from inaccessible piping below the plant.

A further study of flow through these pipes failed to indicate leakage.

However to satisfy public outcry, the Region had to sacple and have analyses performed on well water in the area of the plant.

The licensee had no monitoring requirements for ground water or wells.

Subsequent to our sampling, the Region pursuaded the licensee to institute a temporary well monitoring progran.

A review of environmental technical specifications (attached) for this Region indicates that the three operating Cocmonucalth Edison plants (Dresden, Quad Cities and Zion) as well as Big Rock Point and LaCross Boiling Water Reactor (LACBUR) are the only plants that have no requirements to monitor ground water.

In this Region, wells are as important as private and public water supplies. Since leakage from pipes and tanks could cause contamination of the ground water we recommend that all environmen'al technical specifications include requirements to monitor ground water.

In particular, the laSalle Station, which is in the Near Term Operating License stage and in an area where all public and private water sources are ground water, should have a ground water monitoring requirement.

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' 7he Region recomraends that' this racnorandum be forwarded to hRR for action.

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The cognizant individual on this matter in the Region is C. J. Paperiello (FTS 8-384-2611).-

ch A. B. Davis, Chief Fuel Facility and Materials Safety Branch Attachments:

as stated D..(i t / O.L.y,

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e REGION III - GROUND WATER SAMPLING REQUIREMENTS

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Licensee Collection Frequency Number of Sacples Palisades Monthly 3

Dresden Big-Rock Point Davis-Besse Quarterly 3

-D. C. Cook Every 18 weeks 7

Duane Arnold Monthly 6

Kewaunee-Monthly 2

Quarterly 4

LACBWR Monticello' Quarterly 3 plus background Pt. Beach

. Quarterly 1

Prairie Island Quarterly 3 plus background Quad Cities I

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Revision 1 November 1979 1

Granch Technical Position

Background

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 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 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 'ddition, Appendix I to 10 CFR a

Part 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 the release of radioactive materials.

Surveillance should be established to identify changes in the use of unrestricted areas (e.g., for agricultrual purposes) to provide a basis for modifications in the monitoring programs for evaluating doses to individuals from principal pathways of exposure.

NRC Regulatory Guide A 1. Eev.1, " Programs for Monitoring Radioactivity in the

' Environs of Nuclear Power Plants," provides an acceptable basis for the cesign 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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i AN ACCEPTABLE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Procram Recuirements Environmental samples shall be collected and analyzed according to Table 1 at locations shown in Figure 1.1 Analytical techniques used shall be such that the detection capabilities in Table 2 are achieved.

The results of the radiological environmental monitoring are intended to supplement the results of the radiological effluent monitoring by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measure-ments and modeling of the environmental exposure pathways.

Thus, the specified environmental monitoring program provides measurements of radiation 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 operation (or other period corresponding to a maximum burnup in the initial core cycle).

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

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

Deviations are permitted from the required sampling schedule if specimens are enobtainable 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.

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

The results of analysis of these crosscheck samples shall be included in the annual report.

The participants in the EPA crossc'.eck program ciy provide their EPA program code so that the NRC can review the EPA's partic! pant data directly in lieu of submission in the annual report.

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

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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 of this investigation and corrective action shall be included in the annual report.

The requirement for the participatica 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 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 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 milk animals, and gardens greater than 50 square nieters 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 calcula.ted thyroid dose greater than those previously sampled, or if the ceasus results in changes in the location used in the radioactive effluent technical specifications for dose calculations, a written report shall be submitted to the Director of Operating Reactors, NRR (with a copy to the Director of the NRC Regional Office) within 30 days identifying the new location (distance and direction).

Milk animal or garden locations resulting in higher calculated doses shall be added to the surveillance program as soon as practicable.

The sampling location (excluding the contro? sample location) having the icwest 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 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 on contaminated pasture and of leafy vegetation contaminated by airborne ABroad leaf vegetation sampling may be performed at the site boundary in a sector with the highest D/Q in lieu of the garden census.

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4 radiofodine 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/m0, 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 0/Q should be conservative and that location may be used to calculate doses due to radioactive effluent releases in place of the actual locations which would be determined by the census.

This option does not apply to plants with elevated releases as defined in Regulatory Guide 1.111, Rev. 1.

The increase in the number of direct radiation stations is to better characterize the individual exposure (mrem) and 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.

Reoorting Requirement A.

Annual Environmental Operating 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. 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.

In the event that some results are not available the report shall be submitted noting end 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:

? summary description of the radiological environmental monitoring procraci a map of all sampling locations keyed to a table giving distances aes d'.rections from one reactor; the results of land use censuses; and the results of licensee participation in a laboratory crosscheck program if not participating in the EPA crosscheck orogram.

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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 Of rectcr 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)

,y reporting level (1) reporting level (2)

If radionuclides other than those in Table 4 are detected and are due from plant effluents, a reporting icvel is exceeded if the potential annual dose to an individual is equal to or greater than the design obje'ti>e doses of 10 CFR Part 50, Appendix I.

This report shall include an es oation 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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TABLE 1 OPERATIONAL RADIOLOGICAL ENVIR0tMENTAL MONITORING PROGRAM Exposure Pathway Number of Sampits" Sampling and Type and Frequency and/or Sample and Locations Collection Frequency" and Analysis AIRDORl4E Radiciodine and Samples from 5 locations:

Continuous sampler Radioiodine Cannister:

Particulates operation with sample analyze weekly for 3 samples from offsite locations collection weekly or I-131 (in different sect 6rs) of the as required by dust highest calculated annual average loading,whicgeveris groundlevel D/Q.

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

community 'taving the highest Gross beta radin-calculatu annual average ground-activity folloging level D/Q.

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

in the least prevalent wind dire;. tion I

DIRECT RA01AT10N 40 stations with two or more dost-Monthly or quarterly Ganuaa 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 be 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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TABLE 1 (Contimed)

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0 Exposure P.sthway Nie.ber of Samples Collection frequency" of Analyfls Sampling and Type and frequency and/or Sample and Locations

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4 WATERBORNE Surface 9 1 sample upstream Crzpositesampleyyer G ama isotopic analysis e

h 1 sample downstream one month period monthly.

Composite for tritium analyses quarterly Ground Samplesfrom1or2sourjesonly Quarterly Ganca isotopic and if likely to be affected tritium analysis quarterly

'!;i Drinking 1 sample of each of 1 to 3 of Composite sample I-131 analysis on each g

l 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-I discharge performed, monthly sumption of the water composite otherwise is greate per year.g than 1 area i sample from a control location

- Composite for Gross p and gamma isotopic y

analyses monthly.

Compo-site for tritium analysis quarterly Sediment from I sample from downstream area Semiannually Gamma isotopic analyses Shoreline with existing or potential semiannually recreational value INGESTION

.I Milk Samples from milking animals Semimonthly when ani-Gacma isotopic and I-131 in 3 locations within 5 km mais are on pasture, analysis semimonthly when distant having the hi0 hest dose monthly at other times animals are on pasture potential.

If there are none, monthly at other times,;

then, 1 sample from 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 e

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Exposure Pathway Number of Samples

  • Sampling and Type and Frequency and/or Sample

.and tocations Collection Frequency

  • of Analysis Hilk (cont'd)

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1 sample from milking animals at a control location (15-30 km distant and in the least prevaler.-t wind direction)

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

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 on 3 samples of broad leaf vegetation Monthly when available grown nearest offsite locations.

of highest calculated annual average ground-level D/Q if allk sampling is not performed i

l sample of each of the similar Honthly when available vegetation grown 15-30 km distant in the least prevalent wind direction if milk sampling is not performed r

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.3 TABLE'1 (Continued)

O the number, media, frequency and location of sampling may vary frna 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 time.

in these instances suitable alternative media and locations may be chosen for t.he particular pathway in question and submitted for acceptance. Actual locations (distance and direction) from the site shall be provided.

Refer j

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

bPerticulate 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 arter sampling 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, gamma isotopic analysis should be performed on the individual samples.

  1. Gamma < isotopic analysis means the identification and quantification of gaa.ma-emitting radionuclides that may be attributable tu the effluents from the facility.

dfhe purpose of this sample is to obtain background information.

If it is not practical to establish control loca-tions in accordance with the distance and wind direction criteria, other sites which provide valid background data may be substituted.

OCenisters 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.

  1. R39ulatory Guide 4.13 provides minimum acceptable performance criteria for thermoluminescence dosimetry (TLD) systems used for environmental monitoring. One or more instruments, such as a pressurized ion chamber, for measur-ing and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters.

For the purposes of this table, a thermoluminescent dosimeter may be considered to be one phosphor and two or more is phosphors in a packet may be considered as two or more dosimeters.

Film badges.should not be used for measuring direct radiation.

The 40 stations is not an absolute numb c.

This number may be reduced according to geographical limitations, e.g., at an ocean sice, some sectors will be over water so that the number of dosimeters may be r2duced accordingly.

UThe " upstream sample" should be taken at a distance beyond significant influence of the discharge. The "down-stream" sample should be taken in an area beyond but near the mixing zone.

" Upstream" samples in an estuary must bn taken far enough upstream to beyond the plant influence.

h :nerally, salt water is not saapled except when the receiving water is utilized for recreational activities.

G 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., houriy) relative to the compositing period (e.g., montisly).

IGroundwater 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.

a The dose shall be calculated for the maximum organ and age group, using the methodology contained in Regulatory Guide 1.109, Rev.

1., and the actual parameters particular to the site.

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

If harvest 4

cccurs continuously, sampling should be monthly. Attention should be paid to including samples of tuborous and root food products.

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for guidance supplied TABLE 1 (Continued)ing, the following mate rial is erational monitor of station above guidance for op to the institution cddition to the grams.

ted two years prior on prcoperational promental Surveillanc Program should be institu e Program In area

,percti nal Environ tal Survefilance l pathways in the ecoperctional Environmen anticipated critica int ep;rction.

are:

along the variations of this program and their 2 purpts:s levels essen-should be mensure backgroundstation.

d operational programsthe following tab To the surr undin0 h preoperational anmedia, presented in iques g;

To train personnel quipment and '.echnof analysis) of botl program, for specific evaluate procedures, e 2.

and typeof the preoperationa 2 years To dia 3.

alcments (samplin0 meThe duration cific Media

. direct radiat rtebrates ion tially theshould be followed:

Sampling Program for Spe Tha same.

1 year

. fish and inve iculates

. food products shoreline of Preoperational

. airborne partining analyses)

. sediment from Durction

. milk (remawater 6 months

. surface

. groundwater ie

. airborne iod n milk (while

, drinking water

. iodine inare in pasture) animals

TABLE 2 I)etection Capabilities for Envirormental Sample Analysis' i'

Lower Limit of Detection (LLD)b Airborne Particulate Water or Gas Fish Milk Food Products Sediment Anaysis (pCl/1)

(pCi/m3)

(pCl/kg, wet)

(pCi/1)

(pCi/kg, wet)

(pCl/kg, dry)

-2 grcss Leta 4

1 x 10 11 2000 54 Ha 15 130 59Fe 30 260 50,60Co 15 130 m

652n 30 260 95fr 30 95Nb 15 I3I c

-2 I

I 7 x 10 1

60 134

-2 15 60 150 Cs 15 5 x 10 130 I37

-2 Cs 18 6 x 10 150 18 80 180 140 i

Ba 60 60 140La 15 15 N2te:

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

  • Acceptable detection capabilities for thermoluminescent dodmeters used for environmental measurements are given in Regulatory Guide 4.13.

UTable 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 falsaly 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)

LLD =

E V 2.22 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 LLO as the j

detection capability for the instrumentation only, and the MOC, minimum detectable concentration, as the detection capability for a given instrument, procedure, and type of sample.)

j s is the standard deviation of the background counting rate or of bthe counting rate of a blank sample as appropriate (as counts per l

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 picocurie Y is the fractional radiochemical yield (when applicable)

A is the radioactive decay constant for the particular radionuclide at is the elasped time between sample collection (or end of the sample collection period) and time of counting t

The value of S used in the calculation of the LLO for a particular measure b

ment system should be based on the actual observed variance of the back-ground counting rate or of the counting rate of the blank samples (as appropriate) rather than on an unverified theoretically predicated variance.

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In calculating the LLD for a radionuclide 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 priori (before the fact) limit representing the capability of a mcasurement system and not as a posteriori (after the fact) limit for a particular measurement.*

"LLD 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. K., " Detection Limits for Radioisotopic Counting Techniques," Atlantic Richfield Hanford Company Report ARH-2537 (June 22, 1972).

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SUMMARY

Name of Facility Docket No.

Location of Facility Reporting Period (County, State)

Medium or Type and Lower Limit All Indicator Location with liighest Controllocatgons

, Number of Location Annual Mean Mean (f)

Nonroutine Pathway Sampled Total Number of (Unit of of Analyses Detection, Mean(f)g Name Mean (f)b Range Reported Measurement)

Performed' (LLD)

Range Distance &

Range Measurements Direction Air Particu 3) l lates (pC1/m Gross p 416 0.01 0.08(200/312) Middletown 0.10 (5/52) 0.08 (8/104)

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(0.05-2.0) 5 miles 340*

(0.08-2.0)

(0.05-1.40)

  • y-Spec. 32

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~,37 0.01 0.05 (4/2*)

Smithville 0.08 (2/4)

<LLO 4

Cs (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 3

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

Fish pC1/kg (wat wei0ht) y-Spec. 8

<LLD 90 (1/4)

O 137 130

<LLD Cs a

134 130

<LLO

<LLD

<LLD 0

Cs 60

  • 130 180 (3/4)

River Mile 35 See Column 4

<tLD 0

C (150-225) i "Sco Table 2, note b.

b Mean and range based upon detectable measurements only.

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

(f)

Note:

The example data are provided for illustrative purposes only.

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TABLE 4 REPORilNG EVELS FOR HONROUTIt4E OPERATING REPORTS Reporting Level (RL) t Broad Leaf Water Airborne Particulate Fish Hilk Vegetation Analysis (pCi/1) or Gases (pCi/m )

(pCi/Xg, wet)

(pCi/1)

(pCi/Xg, wet) 3 4E*I 11-3 2 x 10 3

4 Hn-54 1 x 10 3 x 10 2

4 fc-59 4 x 10 1 x 10 3

4 Co-58 1 x 10 3 x 10 2

4 Cs-60 3 x 10 1 x 10 j

f 2

4 Zn-65 3 x 10 2 x 10 2

Z r-Nh-95 4 x 10 g

2 I-131 2

0.9 3

1 x 10 j

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 i

2 2

Ds-La-140 2 x 10 3 x 10 1

  1. er drinking water samples. This is 40 CFR Part 141 value.

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DEC 2 3 lo30 d'Alu i

Docket No. 50-295 and 50-304 MEMORANDUM 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 SRM80ll26), you requested a response to Commissioner Fradford'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 Zion about 120 feet above the level of the lake.

From the foundation borings taken during construction, the underlying fcrpations also slope eastward toward the lake as did the water table. The staff position (Branch Technical Position, Revision 1, dated November 1979 Enc'esure 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.

WDQ.ctfz r

William J. Dircks Executive Director for Operations Encl osures:

1.

Zion EIS, Page 11-2 nn plcWAl 2.

Elevations Showing Gradient UU U n l u B H n E-

.Toward Lake ee

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T 12/18/80 12/[$/80 12/p/80 4

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1 Zion EIS, Page II-2 P00R ORIGINAL 4

-9

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ATTACHMENT R.

ELEVATIONS SHOWING GRADIENT TOWARD LAKE 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 500 Marsh Betwe'en Plant and City ot tion 586

.588 Grade at Plant

,591 Average Lake Elevation

  • 578 Static Low Water Leve's of Lake 577 Lake Bottom. Level at 1.2 Miles Offshore 550 (30 foot depth) s
  • Recorded Maximum 584 '; Minimum 577' SOURCE:

Zion Station Final Safety Analysis Report 9

4

.