ML20045E774
| ML20045E774 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| HPPOS-321, NUDOCS 9307060029 | |
| Download: ML20045E774 (1) | |
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, 321 RECOPD #321 TITLE:
ENVIRONMENTAL MONITORING OF LOW-LEVEL RADIDACTIVE WASTE DISPOSAL FACILITY i
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s' NUREG-1388 Environmental Monitoring of Low-Level F adioactive Waste Disposa Facility Manuscript Completed: November 1989 Date Published: Decem,er 1989 E. Y. Shum, R. J. Starmer M. H. Young Division ofIm-Level Waste Mr,.nagement and Decommissioning Office of Nuclear Material Safety and Safeguards U.S. Nuclear Rgulatory Commission Washington, DC 20555 5%:
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ABSTRACT His branch technical position (BTP) paper on the envi-to document corn %mnce with regulations, the dose limits ronmental monitormg program for a low-level radioactive of 10 CFR Part 61, or applicable standards of the U.S. En-waste disposal facility provides general guidance on what vironmental Protection Agency. Data are aho used to up-is required by Section 61.53 of Title 10 of the Code offed-date important pathway parameters to impave predic-eral Regulations (10 CFR) of applicants submittmg a li-tions of site performance and to provide a record of cense application for such a facdity. In general, the envi-performance for public information. De postope-stional ronmental monitoring program consists of three phases:
environmental monitoring prograrn emphasizes meas-preoperational, operational, and postoperational. Each urements to demonstrate compliance with the site-phase of the monttonng program should be designed to closure requirements and continued compliance with the fulfill the specific objecuves defined in the BTP paper.
performance ' objective in regani to the release of During the preoperational phase, the objectives of the radionuclides to the environment. The data are used to program are to provide site characterization information, support evaluation of long-term effects on the general to demonstrate site suitability and acceptability, to obtain public and for public information. Guidance is also pro-background or baseline information, and to provide a re-vided in the BTP paper on the choice of which constitu-cord for public information. During the operational ents to measure, setting action levels, relating measure-phase, the emphasis on measurement shifts. Monitoring ments to appropriate actions in a corrective action plan, data are obtained to provide early warning of releases and and quality assurance.
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CONTENTS Page ABSTRACT...........................................................................
iii ACKNOWLED G MENI3....................................................................
vii 1 INTR O D U C'Il O N.....................................................................
1 1.1 B ackground........................................................................
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1.2 Purpose and Scope
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2 ENVIRONMENTAL MONTIDRING PROGRAM OBJECTIVES.............................
2 2.1 Regulatory Requirements............................................................
2 2.2 Environroental Monitoring Program Phases.............................................
2 2.3 Objectives of the Envi:enmental Monitoring Program....................................
2 3 GENERAL GUIDANCE ON PREOPERATIONAL ENVIRONMENTAL MONITORING........
3 3.1 Environmental Factors and Parameters.................................................
3 4 GENERAL GUIDANCE ON OPERATIONAL ENVIRONMENTAL MONITORING.............
6 4.1 Considerations in the Design of an Operational Enytronmental Monitoring Program..........
6 4.2 Measurement of Parameters in the Environment........................................
6 5 GENERAL GUIDANCE ON POTIOPERATIONAL ENVIRONMENTAL MONTIORING.......
8 5.1 Physgal Surveilla nce................................................................
8 5.2 Environmental Sampling Media.......................................................
8 6 OUALT1Y ASSURANCE /QUAIITY CONTROL............................................
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ACKNOWLEDGMENTS i
The authors wish to thank the Chairman, the staff, and Waste, U.S. Nuclear Regulatory Comnusson, for their.
the consultants of the Advisory Committee on Nuclear
. constructive suggestions in the completion of this paper.
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1 INTRODUCTION geohydrology, only general guidance can be given. In the design of an environmental monitoring program, there is no substitute for good professional judgment, combined
1.1 Background
with a thorough knowledge of the local environment.*
%c Atomic Energy Act of 19$4 and the Energy Reor-Although only general guidance can be given, this paper Provides insight into the opinions and expectations of the Eam2ation Act of 1974 assi n to the U.S. Nuclear Regula-8 NRC staff for the acceptance review of the applicant s en-tory Commission (NRC) the responsibility for licensing vironmental monitoring program. However, the guidance and regulatmg commercial nuclear facilities. He licens-ing requirements for near-surface disposal of low. level presented herein is not mandatory, and flenbihty in ap-radioactive waste (LLW) are specified in Part 61 of Title plying this guidance on a case-by-case basis is suggested.
10 of the Code of FederalRegulations (10 CFR Part 61).
In this paper, the staff defines the objectives of the three phases of an environmental monitoring program; these With passage of the 1.ow-Level Radioactive Waste Policy objectives constitute an acceptable basts for such a pro-Amendments Act of 1985, Congress improved proce-gram. The staff also provides general guidance to the ap-dures for the implementation of interstate compacts, sub-plicant for the design of the monitonng pregram as well as ject to Congressional approval. for the purpose of estab-references that provide greater detail on the planning, hshing and operating regional LLW sites. Initial steps design, and implementation of an environmental moni-have been taken by States and members of interstate tonng program relevemt to the operation of an LLW dis-compacts that will lead to the development of new sites posal facility.
for LLW disposal. To provide timely assistance in this process, the NRC is issutng this branch technical position Early in the development of an LLW disposal facility, the (BTP) paper on environmental monitoring programs for apphcant is encouraged to meet with NRC staff members near. surface LLW disposal facilities. As part of a license to discuss in specific detail the design of an appropriate application, a description of the environmental momtor-environmental monitoring program suitable for a particu-ing program required in 10 CFR 61.53 must be submitted.
lar site.His interaction is especially important during the preoperational phase, which covers a rather broad scope On November 5,1987, the NRC announced in the Federal of monitoring requirements, as defined in 10 CFR Register ($2 FR 42486) the availability of a draft BTP pa-61.53(a). This interaction may also help to reduce the per entitled " Environmental Monitoring of low-Level number of major deficiencies identified during the subso Radioactive Waste Disposal Facilities'* and requested quent NRC or State review that delay the licensing action.
public comments. Thirteen private orgamzations and Government agencies, as well as several individuals, com-For the purpose of this paper, an environmental monitor-mented on the draft BTP paper. Subsequently, NRC's ing program consists of the collection of samples and the Advisory Committee on Nuclear Waste also provided measurement of concentrations of radioactivity, comments. His final B'I? paper has been revised with radionuclides, direct radiation, chemnis, and other 3
the comments of these groups taken into consideration.
physical properties of specife media in the environs of an LLW disposal site during all phases of facility operation.
The monitoring program described herein is broader than
1.2 Purpose and Scope
that for other existing nuclear facilities where considera-ne purpose of this paper is to prtmde general guidance tion is dincted onh to de sneaswement of radoygical
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to applicants and regulatory authorities (NRC Agree-components m the environment. De regulations m 10 ment States) on the design of a monitoring program for CFR 61.53 require a broad range of monitoring, covering LLW disposal facilities. De basic NRC requirement for the three phases of operation for a new LLW disposal monitoring of near-surface LLW disposal sites is located site. Nonradiological and physical parameters are m.
in 10 CFR 61.53. De regulation calls for environmental cluded in the monitoring because they serve as tndicators monitoring during the preoperational, operational, and i r waste migration and for site characterization; how-postoperational stages of the facility.He primary objec-ever, &c applicant,s mmphance with environmental trve of environmental monitoring is to assist in ensuring standards is subject to the regulations of the State or the that the performance objectives in 10 CFR Part 61 are U.S. Environmental Protection Agency (EPA).
met. The staff's interpretation of this basic objective, as Monitoring of worker exposure during site operations in well as of other related objectives, is discussed herem.
accordance with 10 CFR Part 20, such as dosimetry for Ihis paper is not intended to be a handbook of detailed or personnel and radiation surveys of mntainers, equip-mandatory procedures, and it must be stressed that a de-ment, materials, and support facilities, does not come j
tailed environmental monitoring program for an l_LW disposal facility must be tailored to the site-specific opet-
- IntemationalC_= ---on RadsolopealProtecton 0CRPl*Pnnci-ating and environmental conditions. Because each site Q,QRad Q
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has unique topography, meteorology, demography, and nm Publication O. vol.15. No. t.1985.
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l under the scope of envtronmental monitoring as defined (d) After the disposal site is closed, the licen-m this paper. Effluent monitoring of associated facihty see responsible for post-operational surveil-operations or supplemental operations, such as effluent lance of the disposal site shall maintain a moni-releases from stacks resulting from waste hand!tng or in-tonng system based on the operating history cineration, and the discharge of liquid effluent from treat-and the closure and stabiltzation of the disposal ment of leachate, is also not covered in this paper. Gener-site. De monitoring system must be capable of ally, momtonng of worker exposure and effluents will be providing early warning of releases of radionu-required in the applicant's safety analysis report to dem-clides from the disposal site before they leave onstrate compliance with the requirements of 10 CFR the site boundary.
61.12(k). Also, the monitoring of accidental releases is not included herein because emergency sit uations mvolv-2.2 Environmental Monitoring ing sudden major radioactive releases as a result of such events as enticahty or a fire may require a special surveil-PrOgrama Phases lance effort beyond the routine monitoring program.
Environmental monitoring has three major phases: pre-operational? operational, and postoperational. Preoper-ational monitoring occurs during the penod before 1
2 ENVIRONMENTAL license application and could continue dunng the applica-MONITORING PROGRAM ti n review period. operational monitonng occurs from OBJECTIVES the begmnmg of facility construction through the period when waste is no longer accepted and the facility is closed.
Postoperational monitoring occurs from closure through 2.1 Regulatory Requirements the I ns. term care period. Although monitoring during each phase is related to the performance objectives in 10 The requirements pertammg to an environmental moni-CFR Part 61, the emphasis, scope, and intensity of moni-toring program are desenbed in 10 CFR 61.53, " Environ-tonng will vary from phase to phase. The monitoring pro-mental Monitoring":
gram should be planned so that the data collected dunng each phase will be compatible with and supplemental to (a) At the time a license application is sub-data collected dunng previous and subsequent phases.
mitted, the applicant shall have conducted a preoperational monitoring program to provide 2.3 Obj,ectives of the Environmental basic environmental data on the disposal site Monitoring Program characteristics. The applimnt shall obtain in-formation about the ecology, meteorology, cli-he principal objectives of the three phases of an envi-mate, hydrology, geology, geochemistry, and ronmental momtoring program for an 11W disposal fa-seismology of the disposal site. For those char, cility are as follows:
actenstics that are subject to seasonal van-(1) Preoperational Monitoring Objectives ation, data must cover at least a twelve month period.
(a) Provide site characterization information.
(b) ne licensee must have plans for taking (b) Demonstrate site suitability and acceptability.
corrective measures if migration of radionu-(c) Obtain background or baseline data.
clides would indicate that the performance ob-jectives of Subpart C may not be met-(d) Provide records for public information.
(c) During the land disposal facility site con-(2) Opundonal Monitag O$cdves struction and operation, the licensee shall (a) Demonstrate compliance with applicable envi-maintain a momtonng program. Measure-ronmental radiation standards.
ments and observations must be made and re-corded to provide data to evaluate the potential (b) Obtain data on critical pathway parameters to health and environmental impects during both allow more accurate evaluation of radiation the construction and the operation of the facil-doses to the general public, ity and to enable the evaluation of long-term effects and the need for mitigative measures.
(c) Pmvide records for public information.
The monitonng system must be capable of pro-(3) Postoperational Moniforing Objectives viding early warning of releases of radionu-clides from the disposal site before they leave (a) Demonstrate compliance with site closure the site boundary.
requirements.
NUREG-13SS 2
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(b) Provide data to support long-term impact In the preoperational phase, environmental media are evaluation, such as long-term impacts on sampled and analyzed to provide background or baseline ground water.
data to characterize the site environment.Some of the en-vironmental sampling data can be used as indicators for (c) Provide records for site closure and for public long-term impact assessment. For some characteristics mformation.
that may be subject to seasonal changes, the program must be continued for at least 1 year and should be ex-tended through NRC's license review period of 12 to 15 months. Characteristics such as wind speed, wind direc.
3 GENERAL GUIDANCE ON tion, and atmospheric stability; subsurface and surface PREOPERATIONAL water levels; and radionuclide and nonradiological con-ENVIRONMENTAL taminant concentranons in air and water may buuWect MONITORING to seasonal changes. As previously noted, the applicant ts encouraged to discuss the preoperational program with the NRC staff before initiation of the program in ortler to This section provides general guidance on the design of a reduce the number of major deficiencies. During the in-preoperational environmental monitormg program, m-itial review of the license application, the NRC staff will ciudmg definition of the specific areas that should be cov-continue to work closely with the applicant to identify any cred. Details on methods and frequency of samp!mg and additional preoperational monitoring needed so that the location of sampling will vary among specific sites because applicant can still take action during the review process-of the variation of environmental factors such as geology, The following section desenbes the environmental fac-hydrology, clin' ate, land use, water use, and local popula*
tors or parameters that should be covered in a preopera-tion.ne following documents discuss the design and tm-tional monitoring program, plementation of a preoperational program in greater detail:
3.1 Environmental Factors and (1) U.S. Nuclear Regulatory Commission, NUREG-Parameters 0902, " Site Suitability, Selection and Characteriza-tion," B ranch Technical Position, Iow. Level Waste 3.L1 Meteorology and Climate Licensing Branch, April 1982 Metectalogical data are collected during the preoper-(2) U.S. Department of Energy, DOE /LLW-67T, " Site ational sage m pmvide baseline inforrnation on Characterization Handbook-National Iow-level meteorologic conditions, to determme the site's water Waste Management Program," March 1988 budget, to evaluate the impac; from airborne releases of effluents, to obtain information on the frequency prob-(3)
U.S. Department of Energy, DOE /LLW-13Tg aWity of severe meteorologimi events, and to pmvide (draft), " Environmental Monitoring for Iow-Level baschne data on air quahty.ne significant, specine mem-omlog' Cal Parameters are onsim wind speed, wind direc-Waste-Disposal Sites," Low-level Pdeve Waste Management Handbook Series, March 1989 tion, and atmospheric stability frequencies; atmospheric pressure; precapttation; temperature; evaporation; solar radiation; severe weather; and the concentration of con-(4)
U.S. Nuclear Regulatory Commn.=% NUREG/
tammants in the air, CR-5054, " Recommendations to the NRC for Re-view Criteria for Alternative Methods of Iow-Level Radioactive Waste Disposah Environmental Mcni-Most of these data and other meteorological information toring and Survedlance Programs," Battelle Pacific such as humidity, snow depth, and inversion height can be obtained from a nearby weather station that has Northwest Laboratory, July 1988 climatological patterns similar to those of the site. If there is no weather station nearby, the key parameters meas-De primary purpose of the preoperational program is to ured on site are wind speed, wind direction, and atmos-characterize the site environment. Part of the averall pro-pheric stability, as well as the precipitation rate and i
gram consists principally of collecting new or existing evaporation rate. Initial onsite measurements of these monitoring data to evaluate the geological, hydrogeologi-parameters for a period of at least 12 consecutive months, cal, climatological, ecological, radiologim1, and non-or preferably 24 consecutive months, are necemry. This radioactive pollutant environments of the site and the program should be continued during the operational surrounding area.These data are needed to assist in dem-phase.
onstrating the site's acceptability and suitability for LLW disposal compared with other altemative sites in the ap-Background radiologic and nonradiologic air quality data plicant's site-selection process.
Should be measured for a period of at least 12 consecutive 3
months. preferably for 24 consecutive months, to account Water samples from the saturated zone, and from the un-for seasonal vanation. Depending on the availability of saturated zone when possible, should be collected and power, air sampling stations should be located at some analyzed for radiological and selected nonradiological strategic points, such as upwind and downwmd of the fa-constituents so that the water chemistry can be assessed.
cility, the area of maximum impact, the nearest residen-Sampling frequency must be established on a site-by-site tial area, and the fenceline. Dese stations can also be basis, taking into account expected changes in water qual.
used during the operational phase.
ity and hydrologic conditions during the year. De appli-cant should define vertical and horizontal hydraulic gradi-ents and use the information to design a ground water 3.1.2 Hydrology monitoring system for the operational and postop-erational phases. Furthermore, hydraulic gradient data will provide an understanding of the hydrogeologic sys-3.1.2.1 Ground Water Hydrology tem at the site necessary for hydrologic modeling and for use in pathway analysis and performance assessment.Re Ground water data are needed to provide information on applicant should sample, when possible, nearby residen-site suitability. The information is used to demonstrate tial, municipal, agricultural, and industrial wells.ne pre-that the site is relatively simple hydrologically, that the operational sampling should be continued for 12 consecu.
site can provide a water table of sufficient depth so that tive months and should be carried on throughout the ground water intrusion into the waste is unlikely, or if dis-license review. He preoperational program should be posal below the water table is proposed, that molecular designed so that it can be integrated into the programs for diffusion will be the predominant means of radionuclide the operational and postoperational periods.
movement and the ground water pathway impact can be modeled to meet performance objectives.
3.1.2.2 Surface Water Hydrology Surface water data are needed during the preoperational At disposal sites in humid climates, the primary mecha-P ase to verify that the site will be generally well dramed h
nism for radionuclide migration will most likely be ground and free of areas of flooding or frequent ponding, to de-water flow. Humid sites generally have more direct termine the amount of nmoff that muld erode or tnun-ground water recharge than do arid sites, usually resulting date the site, to demonstrate that the surface water path-in larger seasonal fluctuations of water level and water way analysis meets performance objectives, and to quality, with the likelihood that flow rates will be higher Provide baseline data on water quality (NUREG-0902).
and more transient. Arid sites may have very deep, rela.
Das mmpilation will include data on water users and his-tively stagnant flow systems with little seasonal change in toric floods, as well as data on droughts, rainfall, and I
water level or quality. Ground water flow may not be the snowfan.
principal release pathway at arid sites because of thelong travel time necessary for contaminants to reach the water Field measurements will include runoff, infiltration rates, i
table (or a confined aquifer) and for the contammated nadeeMgaWe ground water to reach the facility boundary. Although quality in regard to radiological and nonradiological com-both the saturated and unsaturated zones are important ponents. In addition, sediment samples from nearby sur-m both cases, the monitoring emphasts will depend face water courses should be taken and analyzed for both largely on the behavior of the flow system. For example, radiological and nonradiological components.
at arid sites the unsaturated zone should be emphamM At humid sites, both the saturated and unsaturated zones 3.1.3 Geology and Seismology s.hould be considered.
Information on geology is needed to demonstrate that the Preoperational ground water monitoring includes study-natural processes affecting the site occur at consistent irig the recharge and discharge zones, determmmg the and definable rates and that the site will be geomorphi-rate and direction of ground water movement, and deter-cally and tectonically stable for a period of 500 years mining the potentiometric and water table elevations for (NUREG-0902). The information includes geomorphol-all potentially affected aquifer systems in the vicinity of ogy, stratigraphy, lithology, tectonics, structure, seismol-1 the LLW disposal facility. De applicant should install oEy, and geologic hazards. Regional information can be monitoring wells so that variability of flow rate and direc-obtained from organizations such as the U.S. Geological tion can be assessed. De movement of infiltrate in the Survey. Site-specific information is likely to require first-unsaturated zone and the potential for deep percolation hand field investigation by the applicant.
should be evaluated and used in the design of the moni-toring network. Water levels and capillary potentials Preoperational measurements such as surface and trench should be determined often enough 50 that seasonalfluc-geologic mapping and sampling, borchole logging, and tuations can be taken into consideration.
analysis may be necessary. Accumulated scismic data NUREG-1388 4
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l must be assembled and evaluated m areas of potential ac-designated distances of up to a 50. mile radius of the site, tive faultmg or other earthquake danger. Short-term are needed. His information will be used to analyze the I
monitonng may be useful in confirming local confor-potentialimpact on health from operation of the facility.
mance to regional seismic characteristics.
De information includes population centers, population density, distribution of local residents, transient popula-i tion, and projected population. Most of the information 3.1,4 Geochemistry and Hydrochemistry can be obtained from the U.S. Bureau of Census or State or local government records.
Geochemistry and hydrochemistry information is needed to provide background chemistry data, to permit monitor-Preoperational data collection near the site includes ing of key indicators of water quahty and leachate migra-measuring or estimating the distribution oflocal residents tion, and to identify parameters that may affect transport around the site to evaluate the area of manmum impact of the waste leachate to the environment. Preoperational from facility operation. Rese data should include infor-geochemical monitonng may include measurement of mation on nearby schools and hospitals.
ground water composition and Eh-pH, radionuclides in both water and soil, soil ion exchange capacity, and distri-bution coefficients of selected radionuclides between soil 3.1.7 Background Radiation Characteristics and water. Additional tests could include field and labora-tory measurements of leachate migration rates. Sampling Background radiological data are needed to establish frequency and duration for time-variant parameters and g
gg factors are sunilar to those for hydrologic measurernents.
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ate the impact of operation of the facility, decomnussion-3.1.5 Ecology ing, and site closure, and may be used as references to set action levels.
Information on ecology is needed to define the baseline terrestrial and aquatic characteristics of the site in order Preoperational monitoring includes measurements of di-to support environmentalimpact assessments and mitiga.
rect gamma radiation and of the concentrations of radio-tion phnning. Important concerns include abundance of active material in the air, soil, sediment, surface water, species, their characteristics, importance of the species, ground water, and biota. At least 1 ycar of preoperational and seasonal and migratory patterns. Ecx>logx:al informa-data should be submitted in the applicant's license appli-tion includes terrestrial fauna species, terrestnal flora cation. Most of these measurements may have to be con-species, aquatic species, livestock, food cham, migratory tinued during the operational phase.
species, game animals, habitat, and threatened and en-dangered species. He presence of burrowmg rodents and deep-rooted vegetation at the site should also be deter-3.1.8 Land Use mined because rodents and vegetation are potential vec-tors. Most of this information can be obtained from or-IJtnd use ~ data in the vicinity of the site are needed to ganizations such as the U.S. Fish and Wildlife Service and evaluate the potentialimpacts of facility operation. Infor-the State's Fish and Game Service-mation includes residential, industnal, agricultural, and recreational land use; special areas; zoning restnctions; A preoperational program includes surveying the site vi.
local land use plans; farmland use timenfkatinn; and util-cinity for major vegetation types and commercially or ity land uses. His information generally can be obtained recreationally important vertebrate and invertebrate spe.
from State and local government agencies, the U.S. De-cies. Sampling should be conducted for a muumum of 12 Partment of Interior, and the U.S. Department of Agri-consecutive months to determme the seasonal variation culture.De land use information should include location of species. Site reconnaissance surveys (including aerial of cultural resources in the vicinity of the site. Buildings, photography) can be used to confirm information ob.
structures, or objects of historical, archeological, archi-tained from existing sources, to determme species and tectural, scenic, cultural, or landmark sagruficance in the habitat conditions, and to select sites and techniques for vicinity of the site,should be identified before construc-more intensive investigation, as necessary tion of a disposai usy.
Preoperational monitoring may include field reconnais-3.1.6 Demography sance and limited surface testing of archeological finds, if necessary. De applicant should consult the State His-Demographic data on geographic distributions and sizes toric Preservation Officer in all data collection activities of both existing and projected human populations, within to ensure compliance with standards and procedures.
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and serve as tndicators for the ingestion pathway impact 5.1 Physical Suneillance analysis. Other indicators such as small mammals, game birds, burrowing rodents or their fecal pellets, fish, and Physical surveillance should be conducted periodically af-milk (if obtainable) should be sampled and analyzed.
ter site closure. The sun ci!!ance program should provide for physical inspection of the site and the performance of any required repairs to mamtam the site mtegnty. This m-4.2.3 Action Levels spection includes monitoring the penmeter fence, backfilling subsidence of the trenches, and repairing dam-age caused h emsion.
The appbcant :;hould set action levels on the key environ-mental media to provide early warning of problems, if any, and to ensure that mitigating measures are taken in a 5.2 Environmental Sampling Media timely manner and in compliance with 10 CFR 61.53(b).
In the design of operational and postoperational monitor-5.2.1 Ground Water ing programs, the following types of action levels should be considered:
After site closure, the pnmary path for radionuclide re-lease to the environment is through ground water. He ground water monitonng program for the operational (1) Tng;enng Lewl: This level is defined as the level of phase should be contmued dunng the mittal period after concentration of radionuclides, radioactivity, or site closure but can be gradually reduced if no potential chemical indicators above which an mvestigation ts probiern is identified. The analysts of chemical indicators required. The investigation includes checking of and radioactive matenals should be continued.
laboratory procedures, checking for contamination, resampling, radionuclide analysis, increased fre-If subsurface water is known to reach ground surface and quency of sampling, and erpansion of the monitor-eventually enter any streams, rivers, or lakes, these water ing pmgram. He triggering level should be related bodies should be monitored.
to multiples of background mncentrations or a frac-tion of applicable dose limits.
5.2.2 Other Sampling Media (2) Repomy Lews his level is defined as the level of Vegetation particularly deep-rooted plants, should be sampled penodically to determme any uptake of concentration of radionuclides, radioactivity, or radionuclides. Burrowing animals or their fecal pellets chemicals that exceeds or is about to exceed reguia-should also be sampled and analyzed. Such plants and ani-tory standards. lf regulatory standards are exceeded, mais serve to indicate whether the biological barrier con-the applicant must report to the NRC or State tinues to be effective.
authonties the monitoring results, its investigation and findings, and mitigating measures taken to cor-recube pmblem.
6 QUALITY ASSURANCE / QUALITY CONTROL Re applicant's environmental monitoring program 5
GENERAL GUIDANCE ON should include a quality assurance / quality control (QA/
POSTOPERATIONAL oc) pmgram.nese pmgrams are needed for the follow-ENVIRONhENTAL ins reasons- (1) to identify deficiencies in the sampling and measurement processes to those responsible for MONITORING these operations so that correctrve action can be taken and (2) to obtain some measure of con &d rce in the re-After closure of an LLW dtsposal site, it is crpected that sults of the monitoring programs in order to assure the the facility buildmgs and land will have been properly de-regulatory agencies and the public that the results are comrmssioned and that residual contammation will have valid.
been decontaminated to acceptable levels. Disposal units are capped to limit infiltration, to protect intruders, and In general, the design of a quality assurance program to prevent biointrusion. he site is then placed under in-should take the following factors into account."
stitutional control. The postoperational monitoring en-sures that the site continues to meet closure require.
(1) Quality of equipment and instruments.
ments. At this time, most of the environmental sampling can be terminated except for ground water monitoring,
- Intem tonM Camon on Radologal Pmtecton 0CRPh *Pnm-ples of Monitonn for the Radisten Protection of the Populaten."
which must be carn. d on to provide data to support long-gyn,f,,f 3, fcph lenanonal Commmma om RadelopcalIbec-e term impact evaluation.
non. Publeanon 4 3. Vol.15. No.1.1965.
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b t-(2) Training and experience of personnel, of activity, data interpretation, reporting, and record
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(3) Venfication of procedures by the routine analysis of control samples and the use of standard methods for The applicant should refer to the following NRC docu-analysis.
ments for the design of a QA/QC program. Quality assur-ance should apply to all phases of the environmental t
(4) Frequency of calibration and maintenance of equip-monitoring program, ment and instruments. Vanability in the measuring f
system will be an important aspect of this program.
(1) U.S. Nuclear Regulatory Commission, Regulatory Guide 4.15, " Quality Assurance for Radiological (5) The traceability of the results of the monitoring pro-Monitoring Programs (Normal Operations)-
l grams to a national standard.
Effluent Streams and the Environment" (6) The degree of documentation needed te demon-(2) U.S. Nuclear Regulatory Commission, NUREG-strate that the required quality was achieved and is 1293, " Quality Assurance Guadana for Low-level rnaintained.
Radioactive Waste Disposal Facility," January 1989 Quality control applies to all steps of a measurement pro-I gram. These steps include sampling procedures, precau.
- InwrnationaK-- ce 8 dM PmetmegCRP)." Pried-t D yd" %f
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tions in the transport of samples, initial physical or chemi-cal preparation, radiochemical separation, measurement man. Publication 43. Vol.15
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(2491 Supp., Rev.. and AJacaruhm Num-
""cIN' BIBLIOGRAPHIC DATA SHEET 32
<s in.iruction. m in.r
..i NUREG-1388
- 2. TITLE AND SUBTITLE
~ ' ' " '
RE T NM ENVIRONMEN'FAL MONTFORING OF LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITIES December 1989 l
BRANCH TECHNICAL POSITION
- 4. m oR oRauf etiunER I
s.
ur % s, s.rveE oFREpoRT Technical E. Y. Shum, R. J. Starmer, M. H. Young T. PER8oo COVEREo (retusiv. osteel N/A i
i
- e. etRroRuno oRcmzaTion nAue Are AooREss in mc. prw om.mn. on or R.g.an v.s. nue, R.ou.iwy comme..m. and mamna ocuress. tr contractor, provios name and mainne maareas.)
l Division of low-level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555
- e. sponsoRea oRomzAnon - nauE Aro AooREsa <w NRc. typ. sam. as neo : n earnr.etor. prw rec om.mn, oma. or R.gion.
U.S. Nuctaar Reguiatcry Commissaan, and maling acmroes,)
Same as above 10 SUPPLEMENTARY NOTES
- 11. ABSTRACT (200 woros or 6ees)
His branch technical position paper on the environmental monitoring program for a low level radioactive waste dis-posal facility provides general gnidaw on what is required by Sectaan 61.53 ofiltle 10 of the Code offederalRqpda-riori.r of applicants submitting a heense application for such a facihty. In general, the environmental monttonng pro.
gram contists of three phases: piwtional, operational, and postoperatinnal. Durmg the preoperational phase, the objectrves af the program are to pmvide site characterization information, to demonstrate site sunabdity and na:eptabil-ity, to obtaia background or baschne information, and to prtmde a record for pubbe information. During the opera-tional phase, the emphasis on measurement shifts. Monitoring data are obtained to provide early warnmg of releases and to document conspliance with regMatiam-the dose limits of 10 CFR Part 61, or applicable standards of the U.S.
Environmental Protection Agency. De postoperational environmental maaitaring program emphastses measurements to demonstrate comphance with the site. closure i%uavments and continued compliance with the performance objec-Live in regard to the release of radiawlidae to the environment. De data are used to support evaluation of long-term effects on the general public and for public information. G=4aw is also prtmded in the BTP paper on the choice of which constituents to measure, setting action levels, relating measurements to appropriate actions in a correctrve mason plan, and quality assurance.
- 12. KEY WoRoS/oEScRPToRS (Ust omros or pNrmese that will assist researchers et locat>g the report.)
- 13. AVAA>aUTY STATEIENT Un1imited
- 14. SECX.JRfrY CLASSFtCATioN m arec) low-Level Waste Disposal Unclassified Environmental Monitoring (m. a.p.ri)
Unclassified
- 15. NUMBEA oF PAGEs 1s. PRsCE NRC FORu 336 (2 eg;
UNITED STATES
(
NUCLEAR REGULATORY COMMISSION 7
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j WASHING TON. D. C. 20555 i
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SEP 2 41992 pl 0 (P.c/
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,: l MEMORANDUM FOR:
Ronald R. Bellamy, Chief Nuclear Materials Safety and Safeguards Branch, RI A.,
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P,/ [a q
i FROM:
John E. Glenn, Chief Medical, Academic, and Commercial Use Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS
SUBJECT:
TECHNICAL ASSISTANCE REQUEST DATED JUNE 10, 1992, RE:
AN AMENDMENT REQUEST FROM WALTER REED ARMY MEDICAL CENTER, WASHINGTON, DC, LICENSE NO. 08-01738-02 (CONTROL NO. 116472)
This memorandum responds to a technical assistance request (TAR) dated June 10, 1992 (enclosed), regarding an amendment request from the Walter Reed Army Medical Center, Washington, DC.
In a letter dated April 8, 1992, the licensee requested an exception to 10 CFR 35.315(a)(7) to allow dedication of a single patient room for radiopharmaceutical therapies without being required to decontaminate to the levels required for unrestricted occupancy and assignment to a non-therapy patient.
It is our understanding that the licensee does survey and decontaminate the patient room after release of each therapy patient, but restricts the room for use only by iodine therapy patients. The licensee therefore requests relief from the requirement of decontaminating the room to the level required to release it as an unrestricted area.
If granted this practice would require an exemption from the requirements of 10 CFR 35.315(a)(7) because the regulation does not anticipate subsequent use of the room by therapy patients, and the requirea decontamination level of 200 disintegrations per minute (dpm) per 100 centimeters squared (cm) is for release of the room as an unrestricted area.
In the letter dated April 8,1992, the licensee submitted procedures to ensure the safety of facility personnel who frequent the vicinity of a dedicated therapy patient room.
1.
The licensee states that the door to the contaminated therapy room will remain closed and locked when the room is unoccupied.
2.
The licensee states that access to the unoccupied and locked room will be under the control of the Health Physics Office (HPO) at all times and can only be opened by HP0 personnel.
3.
The licensee should be required to decontaminate the dedicated therapy room, prior to use by any other therapy patient, to the restricted area action level for removable surface contamination of 2,200 dpm/100 cm as described in Regulatory Guide 8.23, " Radiation Safety Surveys at Medical Institutions", or the licensee may be approved to decontaminate based g,, u u --
'1 }/3f/M '
l Mr. Ronald R. Bellamy )
upon action levels determined to meet the following criteria:
J
- a. No primary radiation protection standards will be exceeded (personal dose, men.ber of the public dose or environmental release limits.); and
- b. The action levels are determined to be ALARA based upon a.
consideration of worker, environmental,and public exposures.
The licensee must describe the procedures to be followed to determine these criteria are met.
In summary, the licensee's request for an exemption (to be provided by a license amendment) from the requirements in 10 CFR 35.315(a)(7) may be granted at such time as the licensee provides the additional commitments including the decontamination level described in item 3 above.
Any questions regarding this information should be directed to Robert Ayres of this staff at (301) 504-3423.
John E. Glenn, Chief Medical, Academic, and Commercial Use Safety Branch i
Division of Industrial and Medical Nuclear Safety, NMSS
Enclosure:
TAR dtd 6/10/92 DISTRIBUTION:
IMAB922 NRC File Center TAR r/f JEGlenn RECunningham JGreeves IMNS Central File PCVacca RRBellamy, RI DCollins, RII JGrobe, RIII RJPate, RV MShanbacky, RI JKinneman, RI PSwetland, RI CHosey, RII GMMcCann, RIII BPrange, RV MLamastra RFonner, 0GC NMSS r/f JPelchat, RII LJCallan, RIV VLMiller, GPA/SP WFisher, RIV i
JRicci, AE0D/TTC CCain, RIV LWCamper, IMAB BJHolt, RII i
JPiccone, IMAB JJohansen, RI FCombs, IM0B 0FC :IMAB
- I AB
- 0
- IMAB
- IM0B
______4gA______
._I______________
NAME :RAyres per :ST by n :F
ht------
0FFICIAL RECORD COPY G:/IMAB922
REQUEST FOR TECHNICAL ASSISTANCE DATE:,
6/10/92 TO: Jonn E. Glenn
, Chief, Wedical, Academic, and Commercial lg Use Safety Brancn. NM55 M' N!, Chief, Nuclear Materials Safety ana rROM:
Ronald R. Bellamy Safeguaras Branch, Region I
08-01738-02 LICENSEE: Walter Reed Amy Medical Center LICENSE NO.
X Control No.
116472 (enclosed)
X Letter dated Acril 8, 1992 (enclosed)
Suggested change in licensing procedure (enclosed)
Other (see remarks)
Prob 1em/ Issue: Walter Reed Amy Medical Center GMC) is requesting an exemption frcxn 10 GR 35.315(a) (7) which requires that for each patient receiving radiopharaceutic.
i therapy and hospitalized, a (Continued on attached sheet)
Action Required:
Alternatives Considered:
Recommenced Alternative:
n - M +hnt + hic evomtien be cranted with the t
- c;_ricticr.
- ctatM M *ke4 " '**a" da*rd A vi l R. 1992. This letter should be a tie down condition in their license.
Remarks:
Regional Reviewer:
Pamla Henderson Reviewer Code:
K-7 I
Reviewer Phone No..
ETS 346-6952 REV. 8/90
i REQUEST FOR TECHNICAL ASSISTANCE -
Walter Reed Army Medical Center Problem / Issue continued:
l licensee shall survey the patient's room and private sanitary facility for removable contamination with a radiation detection survey instrument before assigning another patient to the room. The i
i room must not be reassigned until removable contamination is less than 200 disintegrations per minute per 100 square centimeters. WRAMC states that they average thiny iodine therapies per year and have a dedicated room which is assigned only to' iodine therapy-patients. Before reassigning the room to another iodine patient, their Health Physics Office personnel clean and disinfect it. The room remains locked until needed for an iodine therapy and may only be opened by health physics personnel.
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o30 o13/7 DEPARTMENT CF ~HE ARMY 7
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WASHINGTON, C C 20307 5001 i
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a Apr 92 HSHL-HP (385-11m)
MEMORANDUM THRU HQDA (SGPS-PSP-E), 5109 Leesburg Pike, Falls Church, VA 22041-3258 FOR US Nuclear Regulatory Commission, Region I, Nuclear Material Safety Section A, 475 Allendale Road, King of Prussia, PA 19406-1415 3
SUBJECT:
Application for Exemption to 10 CFR 35.315(a)7 P
1.
Request that Walter Reed Army Medical Center (WRAMC), NRC j
'.:ense No. 08-01738-02, be granted exemption frc= the provisions
_:f 10 CFR 35.315 (a) 7.
2.
WRAMC averages thirty iodine theraples per year and has a
- edicated room wnich is assigned only to :.coine therapy patients.
7-3etare reassigning the room to another iodine therapy - patient,
ll5b 2
Health Physics Office (HPO) personnel clean and disinfect it.
The room remains locked until' needed for an iodine therapy and may only be opened by HPO personnel.
Although ensuring a maximum removable room contamination level 3.
of 200 dpm/cm is appropriate for a room that may be utilized by 2
the general public, it does not seem necessary for a room that is solely used by patients that have just received 150 mci of radiciodine and well trained radiation workers.
Also, Condition No.5 of the WRAMC authorization procedures has 4.
been. codified to delete addresses for USAMRIID and Andrew Rader Army Clinic; to change the Health Physics Office mailing address to the recently assigned street address;.and to include the Nuclear Medicine Clinic as a
receipt point for radiopharmaceutical shipments. (Enclosure)
Y llbb, 5.
Nuclear Medicine has been approved by the WRAMC Radiation Centrol Committee to receive radiopharmaceuticals directly from l
local pharmacies for more ti=aly and cost effective handling of this material.
Nuclear Medicine will process all incoming shipments 'in accordance with Regulatory Guide 10.8 and. f orward inventory records to the Health Physics Office.
'i 1
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1 "SECTIOc. COPY" 116472
_grouun
MSHL-HP Application for Exemption to 10 CFR 35.315(a)7
SUBJECT:
FOR THE COMMANDER:
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ROYp'. QUICK,JR./
Enc 1 LTC, MS as
. Executive Officer Copy Furnished HSCL-P, Fort Sam Commander, US Army Health Services Command, ATTN:
Houston, TX 78234-6000 1
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HEALTH PHYSICS WALTER REED ARMY MEDICAL CENTER Washington, D.C. 20307-5001 CONDITION No. 5 FOR RADIOACTIVE MATERIAL AUTHORIZATIONS PROCEDURES FOR RECEIVING AND SA'ELY OPENING PACKAGES ORDERING.CONTAINING RADIOACTIVE MATRRIAL Radioactive material for Walter Reed Army Medical 1.
GENERAL.
and tenant activities will be ordered, received Center (WRAMC) and secured in accordance with US Army Regulations, Title 10, Code of Federal Regulations, and the provisions of WRAMC's Nuclear Regulatory Commission License.
PRINCIPAL USER'S RESPONSIBILITIES.
2.
WRAMC Principal Users are responsible for ordering and a.
receiving radioactive material in accordance with the instructions outlined below, A Principal User may procure only those radioisotopes b.
currently authorized for their use by the WRAMC Radiation Control subject to the limitations of their authorization.
Ocamittee, Unless specified prior arrangements have been made with c.
the Health Physics Officer,the maximum quantity which may be ordered at any one time is limited by the maximum activity of radioisotope which the User is authorized to possess less that thd amount of activity the User will have on hand at the time the new order is received.
Specific prior approval of the Health Physics Office d.
shall be required before receiving and/or transferring gifts containing radioactive material.
This procedure applies to those All instances where normal supply channels are not utilized.
gifts will be delivered to the Health Physics Office unless alternate arrangements are specifically approved by the Health Physics Office.
3.
CRDERING PROCEDURES.
The Principal User shall submit a completed Purchase
- a. through normal supply channels for procurement of all Request radioactive materials.
REVISION 3, effective 6 April 1992
l CCNDITION NO. 5 FOR RADIOACTIVE MATERIAL AUTHORIZATION
/PPOCEDURES FOR ORDERING. RECEIVING AND SAFELY OPENING PACKAGES CONTAINING RADIOACTIVE MATERIAL) b.
In addition to the information required by WRANC Procurement Regulations, each purchase request shall contain the following:
(1)
Radionuclide, chemical form, and total activity (Activity is given as microcuries (Uci), millicuries (Mei), er curies (Ci); for natural radioactive materials microgram (ug),
ailligram (mg), gram (g), or kilogram (kg) may be used.
(2)
This notice will be typed after the item description:
RADIOACTIVE MATERIAL NOTIFY HEALTH PHYSICS OFFICE PRIOR TO PLACING ORDER (TELEPHONE NO. (301) 427-5104)
(3)
The WRAMC Radioactive Material Authorization Number will be indicated in the " Attention Line" of the " Ship To" address.
(4)
Date required or delivery date.
(5)
The proper shipping address for any radioactive material not specifically exempted by the Health Physics office (HPO) is:
Health Physics Office Bldg 188, 2681 Linden Lane Forest Glen Section Walter Reed Army Medical Center ATTN:
Authorization No.
Two specific approved exemptions are:
(a)
Army Medical Laboratory, Ft. Meade, MD:
Radiation Protection Officer Army Medical Laboratory Bldg 2490 Fort Meade, Maryland 20755 i
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CONDITION NO. 5 FOR RADIOACTIVE MATERIAL AUTHORIZATION (PROCEDURES FOR ORDERING, RECEIVING AND SAFELY OPENING PACKAGES CONTAINING RADIOACTIVE MATERIAL)
(b)
Radiopharmaceuticals for WRAMC Nuclear Medicine Clinic:
Walter Reed Army Medical Center Nuclear Pharmacy Bldg 2, Room 7A14 Washington, D.C.
20307-5001 4.
PECEIVING PROCEDURES.
All incoming shipments of radioactive material to the a.
Health Physics Office will be received by the Health Physics Office during duty hours, or by the Military Police, WRAMC Forest Glen Section during non-duty hours.
Shipments to Fort Meade, or the WRAMC Nuclear Medicine Clinic will be delivered to the address shown in paragraph 3.
The Health Physics Office must be notified immediately of any shipment delivered to an unapproved address.
b.
All incoming packages of radioactive material will be examined for damage immediately upon receipt.
Any packages that appear to be wet, punctured, crushed, or otherwise damaged will be considered to be contaminated, until it can be determined that they are not.
Incoming radioactive material shipments must be c.
continuously secured against unauthorized removal and the radiation levels adjacent to the secured storage area may not exceed 0.5 mR/hr.
5.
SHIPMENT MONITORING & DELIVERY M AUTHORIZED RECIPIENTS, All shipments of radicactive material must be inspected a.
to insure that the shipment does not exceed the possession limits of the Authorization under which it is ordered.
Unauthorized shipments will be returned to the vendor when possible, disposed of as radioactive waste, or held by the Health Physics Office until the Principal User obtains an amended Radioactive Material Authorization allowing recaipt of the material.
Unauthorized i
shipments will not be held by Health Physics for more than ninety I
(90) days.
b.
Shipments vill be Delivered to Principal Users by the H,ealth Physics Office after monitoring procedures have been accomplished.
3
T!DITICN NO. 5 FOR RADIOACTIVE MATERIAL AUTHORIZATION
'PROCEDUPES FOR ORDERING. RECEIVING AND SAFELY OPENING PACKAGES
~0NTAINING PADIOACTIVE MATERIAL) 5.
FINAL SOUFCE CONTAINER CHECK.
The Principal User is responsible for making a final check of the radioactive materials
- source container after it is delivered by the Health Physics Office.
This check will follow the steps outlined below:
a.
Put on gloves.
j b.
Open outer package (following manufacturer's directions, if supplied) and remove packing slip.
Open inner package and verify that the contents are as listed on the pack:.r?
slip.
Check integrity of source container, inspecting for c.
creakage of seals or vials, loss of liquid, discoloration of packaging material, etc.
d.
Before disposing of clean outer packaging ensure that 2ny " radioactive" labels or statements have been defaced or removed.
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116472
- SECTION COPY"
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