ML20071D657

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Annual Radiological Environmental Operating Report
ML20071D657
Person / Time
Site: 07200011
Issue date: 02/20/2020
From: Gacke B
Sacramento Municipal Utility District (SMUD)
To: Scott(Ois) Morris
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
DPG 20-027
Download: ML20071D657 (28)
v • d • e


Text

Powering forward. Together.

DPG 20-027 February 20, 2020 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Docket No. 72-11 Rancho Seco Independent Spent Fuel Storage Installation License No. SNM-2510 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR 2019 Attention: Scott Morris In accordance with Rancho Seco Quality Manual, Appendix A, Section 1.5.2.2, SMUD is submitting the Rancho Seco 2019 Annual Radiological Environmental Operating Report for the period of January 1, 2019 through December 31, 2019.

If you or members of your ~~c:1ff tlc:1ye. questions requiring additional information or clarification, please contact me at (916) 732-4812 or by email at Brad.Gacke@smud.org.

Brad Gacke Manager, Rancho Seco Assets Enclosure (Rancho Seco Annual Radiological Environmental Operating Report for 2019)

Cc: NRC, Region IV w/ Enclosure William C. Allen, NRC w/ Enclosure RIC 1F.099 w/ Enclosure Rancho Seco Nuclear Generating Station / 14440 Twin Cities Road / Herald, CA 95638-9799 / 916.452.3211 / smud.org

ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT J* I, ,

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JANUARY - DECEMBER 2019 Rancho Seco Nuclear Station Herald, California 10 CFR Part 72 License Number SNM-2510

2019 ANNUAL RADIOLO*GICAL ENVIRONMENTAL OPERATING REPORT

. TABLE OF CONTENTS LIST OF FIGURES ........................................................................................................................................ 3 LIST OF TABLES ............. >.: ... :.: ....... :.. :..... :.:.:.:,..:...... :... :.1.-.. i;,:: .... ::::: ............................. .'.i.: ........... ,...... :.. ;... :4**.

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I. EXECUTIVE

SUMMARY

.................................................................................................................... 5 II. LAND USE CENSUS .......................................................................................................................... 5 Ill. RADIOLOGICAL IMPACT EVALUATION ........................................................................................... 5 IV. PROGRAM ANALYSIS RESULTS

SUMMARY

.................................................................................. 7 IV-A ATMOSPHERIC MONITORING ...............................................................................................7 IV-B. WATER MONITORING .............................................................................................................8 IV-C. DIRECT RADIATION MONITORING ....................................................................................... 8 V. REFERENCES ..................................................................................................................................... 10 VI. APPENDICES ..................................................................................................................................... 11 APPENDIX A: LAND USE CENSUS RESULTS ............................................................................... 12 APPENDIX B: SAMPLE SITE DESCRIPTIONS AND MAPS ........................................................... 13 APPENDIX C: QUALITY CONTROL SAMPLE ANALYSIS RES ULTS ............................................ 18 APPENDIX D: SAMPLE COLLECTION AND ANALYSIS METHODS ............................................. 20 APPENDIX E: ENVIRONMENTAL MONITORING PROGRAM DESIGN ........................................ 21 APPENDIX F: 2019 SAMPLE ANALYSIS RAW DATA TABLES ..................................................... 26 APPENDIX G: 2019 MISSED SAMPLE REPORT ...................-........................................................ 27 Rancho Secb Nuclear Station 2 2019 AREOR

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.* , OFFIGURES FIGURE TITLE PAGE I.

FIGURE B-1 RADIOLOGICAL ENVIRONMENTAL SAMPLING LOCATIONS ON AND NEAR THE SITE-------------------------------------------------------------- 15 FIGURE B-2. RADIOLOGICAL ENVIRONMENTAL CONTROL LOCATIONS .

. DI STANT FROM THE SITE~-~--------------------------~---~-------~~--~---------------

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Rancho Seco Nuclear Station 3 . 2019 AREOR *

. LIST OF TABLES TABLE TITLE PAGE 1 ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM ANNUAL

SUMMARY

9 B-1 RADIOLOGICAL ENVIRONMENTAL MONITORING SITES AND MAP LOCATIONS 17 1

F-1 2019 LUXEL BAQGE SUM MARY (DIRECT RADIATION)....

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Rancho Seco Nuclear Station 4 2019AREOR

2019 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT

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I. EXECUTIVE

SUMMARY

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This report contains results from the Radiological Environmental Monitoring Program (REMP) for the Rancho Seco Nuclear Station (RSNS) compiled for the period January 1, 2019 through December 31, 2019. This program is conducted py Sacramento Mupicipal Utility District (SMUD)

-staff-in accordance with the REMP Manual. .This report is* compiled arid submitted in accordance with the Rancho Seco Quality Manual, Appendix A, Section 1.5.2.2 [RS01].

The results of the 2019 Radiological Environmental Monitoring Program showed that operations at the Rancho Seco Nuclear Station had no significant radiological impact on the environment.

Phase I radiological dismantlement of the nuclear facility was completed in December 2008 and the release of the Rancho Seco property, except for the area associated with the Interim Onsite Storage Building (IOSB}, from NRC license DPR-54 was approved on September 25, 2009.

Phase II decommissioning activities, including the performance of Final Site Status Surveys, were performed in 2016 and early 2017. The NRC terminated the Part 50 license on August 31, 2018.

The remaining licensed area at the site consists of the approximately 14-acre Independent Spent Fuel Storage Installation (ISFSI) licensed under 10 CFR Part 72 for the storage of used nuclear fuel.

In accordance with the current site status, the REMP Manual reflects that the only normal remaining pathway to impact a member of the public at the Rancho Seco Nuclear Station is the direct radiation pathway from the ISFSI.

During the reporting period, the environs adjacent to RSNS were monitored using Luxel monitoring badges. Doses resulting from ambient exposure to terrestrial and atmospheric direct radiation sources were measured through the placement and retrieval of Luxel monitoring badges. Direct radiation measurements attributable to Station operations, based on control and indicator locations and review of historical data, ranged from indistinguishable above background levels to slightly elevated levels (approximately 1-2x BKGD).

II. LAND USE CENSUS With the completion of Phase I of Radiological Decommissioning in 2008, the requirement to perform a Land Use Census was removed as a required program from the Rancho Seco Quality Manual (RSQM).

Ill. RADIOLOGICAL IMPACT EVALUATION PREDICTED POTENTIAL RADIOLOGICAL IMPACT Rancho Seco Nuclear Station 5 2019AREOR *.

Gaseous Effluent Exposure Pathways No gaseous effluent releases were conducted in 2019; thereforet,n_o_'dos~: calculations .were*

performed.

i' Liquid Effluent Exposure Pathways The onsite liquid effluent pathway and any potential source of liquid effluents were re.moved duri_ng the decommissioning process; therefore, there were no liquid effluent releases conducted nor dose calcula.tions performed for 201 ~-

FUEL CYCLE DOSE EVALUATION REMP Manual section 8.1.4 requires each Annual Radiological E.nvironmental Operating :Report (AREOR) to include information related to REMP Manual section 5~0; Fuei Cycle Dose. The Fuel .

Cycle Dose Specification limits the annual dose or dose commitment to any real member of the public to 25*mrem to the total body or any prgan, except the-thyroid whi.ch is limited to:75:mrem.

  • This specification implements,requirements promulgated by the United1States Environmental ;
  • Protection Agency [CFRa]. *
  • Consistent with REMP* Manual. section 5.0,* AO fuel 'Cycle dos.e evaluation was required to be performed during 2019 since no REMP measurement exceeded the established reporting levels... ,

Additionally, with no liquid or gaseous effluent releases, effluent dose predictions did not exceed twice the dose guidelines of *10 CFRPart .50, Appendix I [CF Rb}.** Therefore, Appendix I guidelines.

  • for radioactive effluents were not exceeded and determination of an actual dose commitment
  • delivered to a real member of the public was not required.

Analysis of the Luxel measurements taken at the perimeter of the facility (fence boundaries beyond which public access is not normally controlled) indicate that in no case could a real member of the public have received more than 25 mrem during 2019, indicating compliance with 10'CFR 72.104.

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. j 1 Rancho Seco Nuclear Station 6 2019AREOR

OBSERVED POTENTIAL RADIOLOGICAL IMPACT Gaseous Effluent Exposure* Pathways No routine gaseous effluent pathways remain in the current site configuration. No gaseous effluents were released in 2019; therefore, no dose calculations were performed.

Liquid Effluent Exposure Pa~hways ' , *

  • All liquid effluent pathways have been decommissioned at Rancho Seco.
  • The REMPManual was revised to' delete all liquid exposure pathway*sample locations in-reflection of current site -

conditions, therefore, no dose calculations were completed for 2019. ** * * * *. * * -1 :**:

Direct Radiation Exposure Pathway . * . *

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Based bri. Luxe I: control and indicator locations; and a review of historical :data; theHSNGS did not* *.

contribute*a significant component to the recorded direct gamma radiation field. The current year's :

data shows that there is little measurable.direct radiation effect on the,environment. Since, RS.NS, is in a static materials storage condition and there are minimal direct radiation measurements.ofthe surrounding environment, the conclusion remains that the Station has no significant direct radiation effect on the environment. This-is the same conclusion that has been made since the.fuehwas

  • placed into the ISFSI in 2002.: . * . L ..., , *. ,

Luxel :badge locations around the ,1sFSI security fence indicated higher readings,* attributed to the*

fuel stored in the ISFSI, and are Within design calculations. This monitoring is outsitle of the REMP and therefore the results of this monitoring are not.included in this report IV. PROGRAM ANALYSIS RESULTS .

SUMMARY

This section compiles Program data with corresponding evaluations. Each of the following subsections presents information about each of the principal environmental exposure pathways monitored by the Program:

~ Direct Radiation (Section IV-C)

Table 1 is a comprehensive data summary presented in a format considered acceptable by the US Nuclear Regulatory Commission. Information contained in Table 1 was derived from data presented in Appendix F.

IV-A. ATMOSPHERIC MONITORING DATA EVALUATION The REMP Manual was revised in January 201 O to delete all sample locations except for the Luxel direct radiation monitoring badges. No atmospheric monitoring data was collected.

Rancho Seco Nuclear Station 7 2019AREOR

IV-8. WATER MONITORING DATA EVALUATION The REMP Manual was revised in January 201 O to delete all sample,llocations except for the Luxel direct radiation monitoring badges. No water monitoring data:was col/ec~ed, IV-C. DIRECT RADIATION MONITORING DATA EVALUATION i-The revision to the REMP Manual conducteid in 201 O.eliminated some locatiqns where dose , *:*

monitoring was performed to reflect the current statu.s of the licensed facility as di&cussed; .*

above. During 2010, and again in 2011, the locations eliminated from the REMP' eontinued to.

be monitored. Beginning in 2012, only the locations requiring .monitoring by the Hl=MP are*

being monitored. Comparisons of historical *data on a ye~r:-to-year basis have be~n provided in previous reports. Because the environment~! impact is so low, such ,comparisons will no longer be reported.  :, * * * *.

In addition to the Control Locations utilized for comparison purposes,*Quality Coii,t'rol Luxels are included throughout the process to accountfor variables. like dose received during: shipment. ;

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2 Luxel data for indicator and control location.s during *20;19 r~nged:frorr,i to 13 mrem per qu.arter; with an average of 8.4 mrem. This confirms that there. continues fo b~f no _significant observable direct radiation component due to Station operations (i'.e., ~torag~ pr Utilizafiori* of licensed .,

radioactive material within the restricted area).

  • The summary data for 2019 direct radiation* monitoring is presented in Table 1. Comprehe11sive data tables are given in Appendix F, Table F-1. *
  • Rancho Seco Nuclear Station 8 2019AREOR

TABLE 1 ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM ANNUAL

SUMMARY

Name of Facility Rancho Seco Nuclear Station **. Docket No. SNM-2510 Location of Facility Sacramento, California . Reporting Period January :-*December 2019 (County, State)

Medium or Type and Lower All Indicator . Location with Highest Ptnnual Control locations Number of Mean *

  • Pathway Sampled Total Number of Limit of Detection Locations 8
  • Mean (f) 8 Non:..routine Reported Mean (f) Range (Unit of Analysis (LLD) Measurements Range Measurement) Performed Direct Radiation Luxe! 8.9 (48/48) RTL0.5 NP 10.8 (8/8) . ~5.3 (8/8) o* <

(mrem/qtr.) 56 1 mrem/qtr (6-13) o:5 miles 281° (9-13) (~-7)

RTLOA:PP a Mean and Range based upon detectable measurements only., Fraction of detectable rri*easurements at specified locations is indicated in parentheses. (f) * * ** * * **

  • Rancho Seco Nuclear Station 9 2019AREOR

V. REFERENCES CFRa Code of Federal Regulations, "Environmental Radiation Protection Standards for Nuclear Power Operations," Title 40, Part 190.

CFRb Code of Federal Regulations, "Domestic Licensing of Production and Utilization Facilities," Title 10, Part 50.

NRC79a United States Nuclea_r gegulatory Commission, 1979, "An Acceptable Radiological Environmen.tal Monitoring Program," Branch Technical Position, Revision 1.

NRC79b United States Nuclear Regulatory Commission, 1979, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment," Regulatory Guide 4.15, Revision 2.

NUREG79 United States Nuclear Regulatory Commission, 1979, "Radiological Effluent Technical Specifications for PWRs," NUREG-0472, Revision 2.

NUREG80a United States Nuclear Regulatory Commission, 1980, "Methods for Demonstrating LWR Compliance with the EPA Uranium Fuel Cycle Standard (40 CFR Part 190)," NUREG-0543.

RS01 RSLBD-010, Rancho Seco Quality Control Manual, Appendix A Rancho Seco Nuclear Station 10 * . 2019 AREOR

VL' *:APPENDICES*,

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Rancho Seco Nuclear Station 11 2019AREOR

  • . *APPENDIX A: LAND U:SE CENSUS,RESULTS,:,

With the revision of the REMP Manual in January 2010, the requirementto complete a Lanc;I Use Census has been deleted.  :, , -, : : , " .. ; *..

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  • Rancho Seco Nuclear Station 12 2019AREOR

APPENDIX B: SAMPLE SITE DESCRIPTIONS AND MAPS This appendix provides descriptive. information about the sampling locations and maps of all the locations for the Radiological Environmental Monitoring Program sites.

Table B-1 provides information on sample type, identification codes, and map location references.

The sample identification code is an alphanumeric string beginning with the prefix "R" (for Rancho Seco Nuclear Station) followed by two letters to identify the sample media:

TL Direct Gamma Radiation (Luxel)

The numeric designations, which follow the letter designations, indicate the straight-line distance (in miles) from the center of the Reactor Building to the monitoring site.

The next letter designates the sector in which the monitoring location is located. The letters A through R are used for sector designators. The letters I and O are not used to prevent confusion with the numbers one and zero in the ID codes.

Sector Letter Degrees Azimuth Compass Point A 348.75 to 11 .25 N B 11 .25 to 33.75 NNE C 33.75 to 56.25 NE D 56.25 to 78.75 ENE E 78.75 to 101.25 E F 101 .25 to 123.75 ESE G 123.75 to 146.25 SE H 146.25 to 168.75 SSE J 168.75 to 191 .25 s K 191 .25 to 213.75 SSW L 213.75 to 236.25 SW M 236.25 to 258.75 WSW N 258.75 to 281 .25 w p 281 .25 to 303.75 WNW Q 303.75 to 326.25 NW R 326.25 to 348.75 NNW The final letter designation indicates if the location is part of the operational REMP program ("O")

or post-operational REMP program ("P").

Rancho Seco Nuclear Station 13 2019 AREOR

Table 8-1 Lists each location referencing the sample type and the location ID code to the map site number on one of the four Radiological Environmental Monitoring Site Maps included in this Appendix.

Figure 8-1 Site Location Map: Shows the locations of the sample locations near the Site.

Figure 8-2 Distant Locations Map: c 'onltol 1ocations away from the site are shown on this map. '!*

Map Key 0 0 Location that reqt;Jires monito~ing per R~MR -~

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Rancho Seco Nuclear Station 14 2019AREOR

Figure B-1 Radiological Environmental Sampling Locations on and near the Site Rancho Seco Nuclear Station 15 2019 AREOR

Figure 8-2 Radiological Environmental Control Locations Rancho Seco Nuclear Station 16 2019AREOR

. Table 8-1 Radibiogicai Emdro.nmental Monitoring Sites and Map Loc*ations Sample Type *__ ,** ID Cod~ Sector LUXEL RTL1.7FO G LUXEL F LUXEL p LUXEL N LUXEL N LUXEL p LUXEL Q LUXEL p LUXEL p LUXEL p LUXEL p

";!,.,' .,i*: ' . . . ,. -~ . *'

RTL0.2N°P' * .* IND. . 98 .. ,..

LUXEL N

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LUXEL * .. -J~TL0.3NP

<; IND. . 99\ :;,.,

  • N LUXEL tRtL0,31\lP N Note: Prior to ~he g-~-~o L 0

F{epbr{ th~.:'~?P q9atl~,~-~-p:": 1J;~~~~~r~-W~{diff~f~nt,:th'~~':,!P~:{i;~K~~Jl Nu~~-~_r,' _i-:id:;~":fable F-1. To prevent confus1on,tbe'same numbenng-sys,tem_is.now usedthr9ughoutthe:rep,oq. : '\.~ .~:, 'J;--, , '* *.: . _.;_(;**

t;.r,.,. . __., _, . :" '.;: ;, : : : *, ;-(" -.* : . . ** . ** .:C, :; .::./:\:::,: *J;;t . \_\ . ; -~: ~;*,*r;-:-,J -: ,:

  • The monitoring b~Qge at,Map'Locatioth~o: ~l w~~ moved approxir:nateJy"~3Q.feefsQ.~th\l\l~st,prtN6vembe{'20,;2Q1,8 to support removal of unnecessary fen6ing. >n,e 'badge wgs rtteved fron(tt,e *t~Jicefto;,.Q1ilitfp'b'~{O.P034403,:c:.,:t:.; .. ***;0,*
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Rancho Seco Nuclear Station 17 2019AREOR

APPENDIX C: QUALITY CONTROL SAMPLE ANAL YSJS RESULTS*

QUALITY ASSURANCE AND CONTROL* . ,<: 'I i lmplementation'of the Radiological Environmental Monitoring Program (REMP) consists .of a number of discrete steps including: . , *., *

=> Sample collection,

=> Packaging,

=> Shipment and receipt,

=> Measurements of radioactivity,

=> Data evaluation, and

=> Reporting.

These program elements are performed according to approved, written procedures to assure the validity of REMP results.

Because REMP measurement validity is important for evaluating protection of the health and safety of the public, RSNS has established an Environmental Quality Assurance Program (EQAP) for radiological environmental measurements. The Environmental QA Program implements the guidance provided in Regulatory Guide 4.15, [NRC79b].

INTERLABORATORY COMPARISON PROGRAM With the revision of the REMP Manual to delete all sample locations except for Direct Radiation monitoring locations, no discussion of lnterlaboratory Comparison or analysis of laboratory Quality Assurance program is necessary.

RANCHO SECO AUDIT AND SURVEILLANCE RES ULTS The Rancho Seco Quality Program requires periodic audits of REMP activities. Contract laboratory performance is evaluated by an independent Quality Assurance audit company and an "Approved Vendor List" is created from these audits. Audits are either conducted by independent Quality Assurance audit company or by reviewing audits conducted by other facilities (NUPIC audit review). Landauer is currently on the approved supplier list.

Rancho Seco Nuclear Station ta 2019AREOR

DIRECT RADIATION (Luxel) COMPARISON PROGRAM Landauer maintains NVLAP certification with NIST. A review of Landauer's NVLAP certification results indicates that Landauer has satisfactorily completed all the required tests for the types of environmental radiation monitored at RSNS and is certified through December 31, 2020. NVLAP certification *is c0nsideredto satisfy the interlaboratory.comparison req!Jirements for the direct radiation measurement devices.

This comparison program satisfies the requirement of the REMP Manual section.6,0.

Rancho Seco Nuclear Station 19 ' 2019'AREOR

APPENDIX D: *SAMPLE COLLEC'J'"ION AND: ANA_LYS.l~JVIETHODS

  • For each of the sample media collected, the method of collection is documentectin Ranchp Seco Nuclear Station procedures. A brief description of these collection and analysis.methods is * **

included in this Appendix.. ...~ i,,..

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Sample Media .

  • Collection/Analysis Method DIRECT a

. Monitoring badges, (luxels)i are. located within two (2) mile radius of RADIATION the.site . Th~ bac,iges within a ,qne (1) mile radius are consid~red .. *

... indicator badg'es. Two* (2) badges are pfaced at each monitoring .

location to assure adequate data recovery and to improve

.~easurement stati~tics ... The b_a,dge fielq exposur~ cycle i~ . .. . . .. .. ..

. approximately ninety (90) days. At.the ehd. ofthe field exppsl:lre ¢y~I~ *.*

~he badgis.are ex~hanged aod returned to the contract 'laboratory for *.

_proqessing. ** * * * ** ' * * * *. , ' ** * ***. * . *

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Rancho Seco Nuclear Station 20 2019AREOR

APPENDD(E::ENVIRONMENTAL MONITORINGPROGRAM DESIGN PROGRAM'BASis**: ,,:,,, '-' °);:: *

  • The Sacramento Municipal Utility District conducts a continuous Radiological Environmental **

Monitoring Program (REMP) at the Rancho Seco Nuclear Station to asses~ the impact of Station .

operation on the surrounding environment. The current Post-Operatforial REMP has=been revised.

to reflect the requirements of the ISFSI Technical Specifications for direct radiation monitoring.

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  • During 2019,' the program was directed and executed by the Manage,:.; Rancho Seco As.sets; whb has primary accountabi_lity. * ' * * * *
  • The Programjs designE;}d _consister:itwith TitieJOi~ode'of Federal Regulations, Part 50, Appendix I - Section* iv, S.2, 'R3 and C, and Appendix A,' "General Design' Criteria for Nuclear Power Plants, Criterioh 64.
  • The program alsb 'complies* with Title* 10, Code* of Federal Regulations, Part 20, "Standards for Protection Against Radiation," Section 1302. These'federal requirements are cited in the Rancho Seco Quality Manual, Appendix A, and the REMP Manual. REMP requirements are implemented through the review, approval and routine use of several documents, namely the REMP Manual, , Surveillance Procedures and Health Physics Implementing Procedures.

The programmatic elements of the REMP are based on regulatory requirements and associated guidelines. The objectives of the Program are to:

1. Provide the technological basis and the instruction for monitoring the environs for radioactivity sources. The radioactive sources, which contribute to detectable radioactivity in the local environs, are comprised of:

~ Naturally occurring background,

~ Direct radiation from materials storage,

~ World-wide weapons testing, and

~ Major global nuclear accidents

2. Provide quantitative measurements in the direct radiation exposure pathway.
3. Provide indications of the largest potential radiation exposure for individuals because of radionuclides in the principal exposure pathways.

The Program is developed and conducted using recognized standards and practices NRC79a, NRC79b, NUREG79, and NUREG80a.

Rancho Seco Nuclear Station 2019AREOR

REMP CHANGES '* **:h...f .

The REMP Manual and sa.mpling program was revised during 20fo t~ d~iete all s~mple.. lo~a~lons* .

except for the direct radiat.ion pathway. The requirement fo~ a Lar:,.tj,~lse Census and, , .. ,

conducting an ICP for the radioactivity analysis laboratory was also deleted.

No revisions to the REMP Manual have occurred since that revision.

EXPOSURE PATHWAYS

  • .: \ *i .

The fundamental parameter~, which have. been defined prior to monitoring the envirqn~ 1 are: ..

1. Identification of the effluent release pathways
2. Identification of the human exposure pathways Each of these paramet~rs is discussed-below,..

Effluent Releas~ Pathways 1*l', ,.

The principal pathways which may result in human exposure to radiation and radioactive material originating from Station operation are direct radiation'from*onsite sources. Gaseous.and liqllid

  • effluents are not currently being discharged or: monitored.:: * -: . .
  • Direct Radiation In the direct radiation pathway, potential radiation exposure may occur from radioactive material storage areas, which are contained within the facility. perimeter.

MONITORING LOCATION SELECTION The required monitoring sites are listed in the. REMP Manual; Table 3 .. This program is ..

supplemented with additional samples to compensate for changes in the radiological environment surrounding Rancho Seco." Indicator sites are;placed in.areas.which would be most sensitiveJo*

  • the effects of Station operations. If radioactive material is detected above background at any,of . ..

these indicator sites, observed potential exposure and dose to humans can be estimated to verify the effectiveness of the REMP in monitoring potential exposures or doses ...

Control locations provide data that should not be influenced by the operations of Rancho Seco.

These locations are selected based upon distance from the Station. Samples obtained from control locations should, upon analysis, reveal information about the presence and distribution of naturally occurring and man-made radioactive materials. Data from these locations are used to aid in the discrimination between the effects of Rancho Seco direct radiation sources and other natural phenomena or accidental releases, which may result in human exposure.

The direct radiation pathway is monitored through a network of monitoring badges at sites distributed in sectors centered on the Station. The badges are located primarily at the site around the ISFSI. This design provides the capability to easily detect Station-induced direct radiation contributions to the observed terrestrial and cosmic direct radiation background.

Rancho Seco Nuclear Station 2019AREOR

Some badges have been sited in locations to record direct radiation to provide 10:CFR Part 72 .

  • license required data for the Independent Spent Fuel Storage Installation (ISFSI) .

. .. t:1 :_ ~.: t. I:.. i : . , ;* *.*

Appendix B contains a detaife!d'Cles'cription and illustration of the HEMP sample' and monitoring locations. * *- ,* ** *** *  :

SAMPLE MEDIA Samples are collected from predetermined monitoring sites at a specified frequency. The sample media chosen is a:function of the type of monito-ring desired and coincides with tme of the following exposure pathways:

o Direct radiation Direct radiation monitoring is achieved by placing monitoring badges at aboveground sites.

The monitoring badges respond to, and record the amountof, gamma radiation exposure-. 1;The*' ..,.

source of this gamma radiation exposure is varied and includes potential Station effluents, naturally occurring terrestrial, and cosmogenic radionuclides. The monitoring badges are-also

  • influenced by seasonal and global (fallout) radiation sources.

There are 14 sites that requtre :monitoring per.the, REMP,: which' are* within a 2-mile* radius. of the ,

RSNS. The monitoring badges are placed at ther Station Industrial Area Boundary, atthe ISFSI and IOSB, and at control locations located beyond one mile of the Station.

SAMPLE ANALYSIS & DATA HANDLING Data comparisons are made between individual control and indicator sample sites to isolate potential Station influences on the measurement results. Quality Control dosimeters stored in a shielded storage location during the measurement period, but kept with the dosimeters during **

shipping and storage measure non-environmental doses and this amount is subtracted from the total measurements atJhe monitoring and* control locations.

The summarized:results of the 2019 Radiological Environmental Monitoring Program are presented in Table 1-:

  • Individual (raw data) results are presented in Appendix F, Table'F-1 .

..: *~,. ' ' '

Rancho Sec'o Nuclear Station 23 2019AREOR

REGULATORY REPOR.TING LE;YELS , : . ,

Sample analysis, da~a is reviewed ar:,d evaluated by the Sta,ff a~ th~. r~~ults. are receiv~d,,. All ,*.

sample analysis results are revieweg: for correct sensitivity a,nd arn;>m~lies. * .. .

The.activity,concenfration.values list~d ,in Jable E-1 .are the eqyironmerital F~ei *cycle.Dose . *:

quantities that, if.exceeded, require a ,Special Report to be subniit~e~ to the US.NR~ .. In,. : * , .

accordance with the REMP Manual (Section 5, Fuel Cycle Dose),: the ~pecial .Repqrt must iriclude an evaluation of any release conditions, environmental factors or other aspects, which causedthe reporting li,nits,to. be :e?(ceed~d. . ,. "

In addition to the Fuel Cycle Dose reporting .requirements, a Special Report is required to be ...

submitted to the USNRC when more than one ofthe radionuclides in Table E-1 are detected in.

the sampling m_edium :ar,id i'he summed* r~tiq of det~cted acti.vity concentration t9 th~:respecti~e Reporting !-e,vel ccmcentration* is great.er tt,an, or equal to, unity (1 ).

  • When radion4clides other .

than those listed in Table E-1 are detected which are a result. of Station effluents,.a.Special Report is required to be submitted if the potential annual dose commitment exceeds the* 16 CFR 50*.

  • Appendi~ I .guidelines ....

,( i  !. * , r; . :- . : . *.. , ,

No reports .of the types.:.c;lesc,ribe9 above, were ~equired t9 be submitted.during 201~.

SENSITIVITY OF THE. REMP .MEASUREMENTPRO~E;SS,

', ' ' ' ' 'i. ' ' ' '. ' '

All Program measurements must be performed at a sensitivity, which meets USNRC requirements. This sensitivity is determined "before the fact" (a prion) for each radionuclide of interest and sample analysis type. Typical controllable sensitivity parameters include:

~ Sample volume or mass

~ Sampling efficiency

~ Time from sample collection to measurement

~ Instrument detection efficiency for the nuclides (energies) of interest

~ Background radiation levels

~ Chemical recovery factors By adjusting and controlling each of these parameters to maximize measurement process efficiency, a maximum sensitivity level (activity concentration) can be specified for each nuclide of interest and analysis type while maintaining an economic measurement process. The maximum sensitivities in the REMP are specified by the USNRC in the REMP Manual approved for Rancho Seco. These sensitivities are referred to as "LLD's", an acronym for "Lower Limit of Detection".

LLD's are specified on an "a prior," basis and apply to routine measurement process capabilities when no other interfering radioactivity is present. The word "routine" is emphasized since occasional circumstances, such as limited sample mass, elevated levels of background radiation and interfering nuclides can contribute to sensitivity degradation.

Rancho Seco Nuclear Station 24 .2019AREOR

Such occurrences are normally noted and reported during the conduct of RE.MP *activities:

'a Meeting the LLD requireme~ts 'is q_uafity control function 'shared by both* REMP and the analytical laboratory personnel: ::once the laboratory establishes values for the controllable parameters for each analysis type, .sample chain of custody controls ensure that these parameters are upheld: lfall para'ri:ieters are\ uph~ld; then complia'nce with 'the'LLD requirements has been*

demonstrated. No specific ~LD v~ILies for Program fTl'easLiremenfs are included in this report as

  • no ~pplicabte' rhonitoring* Vlias p~rformed. * ** * , * : * * * . '*

Since most of the samples analyzed result in the detection decision ;'activity* not ideiltifiec:!" 1 a:' ,. *, *

  • Minimum Detectable Activity (MDA) concentration value is calculated and reported. This value can be thought'of as the LLD-at-the-time-of-counting since* it is calculated* using an equation which to is similar fhe one used to establish LLD parameters. The biggest differe-nc~ -fs'tthat *actual (not * *

"a priort) pf:irameter~ are used, including interference from natural radio'active *material irHhe sample_.' ltis im,port~rit to 1n6te, that MbA's are reported' ohly forthbse. meas*urenients where the "activity frat i9e~tified 11 decision has already been made .. * .* **, * * * * -* ** . - : . ** * .* i *.

  • MDA values are used primarily to identify changes in the measurement process 1 ~md to convey :

more information about .the measurement itself. Without the use of the MDA concept, most Program measurements would be' reported simply a*s 1'<LLD". With* MDA used/ Program: *, .. * **

measurements are reported as "< xxx " where "xxx" is the calculated MDA concentration.

With the revision of the REMP Manual't6'delete-ali'exposure *pathways excepffor direct radiation, -

these sensitivities are no longer applicable to the current monitoring program.

. .. . * ' ! *. ~ .* ' :

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,' I J, *

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Rancho Seco Nuclear Station 25 2019AREOR

APPENDIXiF::201~ SAIUIPLE:ANALYSIS RAWrDATJ,\TABLES

.*, TABLE F-1 . *:-,.;

2019 Luxel Badge Summary (Direct Radiation)

Quarterly (mrem) l~~~tio:~:lijf ,~.~~

Numbet ,, ,, , , ,

o,~~ilre~i§~* ~ypetyt~-,1t:. ~~g19~.~~lt}£1~f1. 9:~Jl~~R1*1t

  • "J!:',9,,,,::t,  :" .; j,,,. , ... ; ,4,;;;;<', .'.  :*, < ,,:* , ,1;;

19 RTL 1.8FO RS Lake Maintenance Building C 4 5 5 5 43 RTL 1.7FO RS Lake Well Enclosure C 6 5 7 7 68 RTL0.3PO Site fence west by ISOB 8 7 9 9 88 RTL0.3NP ISFSI south fence 9 7 10 10 89 RTL0.4NP ISFSI south fence 7 7 8 10 90 RTL0.5NP ISFSI west fence 10 10 12 12 91 RTL0.3QP Site fence NW corner 8 7 8 9 94 RTL0.4PP ISFSI fence north 11 9 11 11 95 RTL0.2PP IOSBWell 11 9 11 11 96 RTL0.2NP IOSB Electrical Transformer 9 9 10 10 97 RTL0.3NP IOSB Roof Access Ladder 9 9 9 10 98 RTL0.2NP Switchyard Fence 7 8 9 9 99 RTL0.3NP 100 Meter Fence 10 8 10 10 100 RTL0.3NP Access Road NW of IOSB 9 8 9 10 Minimal Reporting Dose is 1 mrem.

I = Indicator Location / C = Control Location M = Missing Data, see Appendix G Rancho Seco Nuclear Station 26, .. 2019 AREOR

APP'ENDIX G: 2019 MISSED;SAMPLE REPORT , . ;

In accordance with the requirements REMP Manual section 3.1, the following samples are being reported as not being collected for the reasons indicated. Corrective action as required by the REMP Manual is as indicated.

Direct Monitoring Pathway {Luxel Badge)

No Luxei badges w~re missing from* their locptions in 2019.

. . *

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.* ('

I ~ :' '.

i ':

Rancho Seco Nuclear Station 27 2019AREOR

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