ML20151Q040

Forwards Draft Rept on Environ Monitoring of Low Level Radwaste Disposal Facilities & Presentation on Proposed Policy on Exemptions from Regulatory Control,Per Request

ML20151Q040
Person / Time
Issue date:	07/26/1988
From:	Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Pasternak A AFFILIATION NOT ASSIGNED
References
REF-WM-3 NUDOCS 8808100283
Download: ML20151Q040 (44)

Text

I LTR APASTERNAK JG JUL 2 61968 Alan Pasternak, Ph.D.

Technical Director 455 Capitol Mall Suite 380 Sacramento, CA 95814

Dear Dr. Pasternak:

Attached are copies of the documents (Draft Environmental Monitoring Technical Position and ANCW Presentation on Proposed Policy on Exemptions From Regulatory Control) you requested.

Both of these isrues are under staff review, and are subject to change.

If you have any further questions, please call me.

(StGNED) JOHNT.GREEVES John T. Greeves, Deputy Director Division of Low-Level Waste Management and Decommissioning, HMSS

Enclosures:

As stated DISTRIBUTION:

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. r' 'l 'M 7 $#D l l DRAFT FOR CCMMENT UNITED STATES NUCLEAR REGULATORY CCMMISSION DIVISION OF LCW LEVEL WASTE MANAGEMENT AND DECOMMISSIGNING TECHNICAL BRANCH TECHNICAL POSITION PAPER ENVIRONMENTAL MONITORING OF LOW-LEVEL RADI0 ACTIVE WASTE DISPOSAL FACILITIES l l l

i a f J 1 1 TABLE OF CONTENTS UH 1 INTR 00VCTICN................. I 1.1 Background................................ 1

1.2 Purpose and Scope

1 2 ENVIRONMENTAL MCNITORING PRCGRAM 0BJECTIVES................ 2 2.1 Primary Objective................................... 2 2.2 Supporting Tecnnica l Cbjective s....................... 3 3 ENVIRONMENTAL MONITORING PROGRAM PHASES................... 5 3.1 Preoperational Phase................................. 5 3.2 Operational Phase................................... 8 3.3 Postoperational Phase................................. 8 4 PATHWAY AND CONSTITUENT MONITORING......................... 9 4.1 Monitoring Specific Pathways.......................... 9 4.2 Monitoring Constituent Levels.......................... 19 5 OTHER PROG RAM COMPONEN TS................................... 22 5.1 Quality Control Program............................... 22 5.2 Maintenance and Decommissioning of Monitoring Equipment 23 6

SUMMARY

24 7 REFERENCES................................................ 25 t 1 l 1 LLW ENVRNMNT MNTR BTP/ SEPT 87 ~. -1

1 INTRODUCTION

1.1 Background

The Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974 give the U.S.~ Nuclear Regulatory Canission (NRC) the responsibility for licensing and regulating commercial nuclear facilities. The licensing requirements for near-surface disposal of low-level radioactive wastes are in Part 61 of Title 10 of the Code of Federal Regulations (10 CFR 61). The NRC is also responsible for ensuring compliance with the provisions of the National Environmental Policy Act (NEPA) of 1969. The licensing requirements related to environmental protection are in 10 CFR 51. With passage of the low-Level Radioactive Waste Policy Amendments Act of 1986, Congress improved procedures for the implementation of interstate compacts, subject to congressional approval, for the purpose of establishing and operating regional low-level radioactive waste sites. The NRC is aware that initial steps have been taken that will lead to the development of new sites' l for such disposal. To provide timely assistance in this process, the NRC is issuing this technical position paper on environmental monitoring programs for near surface low-level radioactive waste disposal facilities utilizing shallow land burial. 1.2 Purpose and Scoce 8 p gri 7 The purpose of this paper is to provide guidance, developed in accordance with 10 CFR 61, to appitcants, i f censees, and regulat 'ry authorities with respect to the monitoring of low-level waste disposal fact ities. This document presents the Division of Low-Level Waste Management and ecommissioning (LLWM) Technical Branch staf f's Qn technical requiremeht) for site environmental monitoring. It presents a rationale for the need and use of the types of monitoring suggested. This guidance will facilitate interaction with the NRC in the design, construction, operation, and closure of new and existing 1 LLW ENVRNMNT MNTR BTP/ SEPT 87

l I a f facilities. In addition, establishing guidance on environmental. monitoring fulfills some of NRC's statutory requirements under NEPA.On o@' The basic NRC requirement for near surface low-level radicactive dis:osal site monitoring is established in 10 CFR 61.53. The regulation calls for environmental monitoring during the preoperational, operational, and postoperational stages of the facility. The primary objective of envirorcental monitoring is to provide assurance that the performance objectives in 10 CFR 61.41 and 61.44 are met. The staff's interpretation of this basic cojective as well as related objectives is discussed in this paper. This paper is not intended to be a handbook on environmental monitoring.

Thus, the recommendations presented are not mandatory, and flexibility in applying this guidance is suggested on a site-by-site basis.

This paper does not present specific acceptable techniques for implementing the various components of a monitoring program. Rather, it presents philosophies and concepts that should be considered in the design and implementation of a comprehensive site monitoring program..This guidance in no way alters the regulations or their implementation as described in 10 CFR 61. For the purpose of this paper, environmental monitoring consists of the systematic collection, analysis, and interpretation of data related to the radiological, chemical, physical and other properties of specific media in the environs of a low-level radioactive waste disposal site during all phases of facility operation. External gamma radiation monitoring is included as environmental monitoring. Monitoring of worker exposure during site operations in accordance with 10 CFR 20 such as dosimetry for personnel and radiation surveys of containers, equipment, materials, and support facilities is not considered environmental monitoring as discussed in this report. 2 ENVIRONMENTAL MONITORING PROGRAM OBJECTIVES 2.1 Primary Objective 2 LLW ENVRNMNT MNTR BTP/ SEPT 87 I L__

I The primary regulatory objective of the environmental monitoring, program is to determine compliance with the performance objectives established in 10 CFR Part 61, Subpart C, specifically 10 CFR 61.41, "Protection of the General Population From Releases of Radioactivity," and 61.44, "Stability of the Disposal Site af ter Closure," which read: Concentrations of radioactive material which may ce released to the general environment in ground water, surface water, air, soil, plants, or animals must not result in an annual dose exceeding an equivalent of 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other organ of any member of the public. Reasonable effort should be made to maintain releases of radioactivity in effluents to the general environment as low as is reasonably achievable. (10 CFR 61.41) The disposal facility must be sited, designed, used, operated, and closed to achieve long-term stability of the disposal site and to eliminate to the extent practicable the need for ongoing active, maintenance of the ' disposal site following closure so that only surveillance, monitoring, or minor custodial care are required. (10 CFR 61.44) 2.2 Suoporting Technical Objectives The requirements pertaining to an environmental monitoring program are described in 10 CFR 61.53, "Environmental Monitoring": "(a) At the time a license application is submitted, the applicant shall have conducted a preocerational monitoring program to provide basic environmental data on the disposal site characteristics. The applicant shall obtain infornation about the ecology, meteorology, climate, hydrology, geology. ;eochemistry, and seismology of the disposal site. For those charactertitics that are subject to seasonal variation, data must cover at least a twelve month period. 3 LLW ENVRNMNT MNTR BTP/ SEPT 87

(b) The licensee must have plans for taking corrective measures if migration of radionuclides would indicate that the performance objectives of Subpart C may not be met. (c) During the land disposal facility site construction and operation, the licensee shall maintain a monitoring program. Measurements and observations gust be made and recorded to provide data to evaluate the potential health and environmental impacts during both the construction and the operation of the facility and to enable the evaluation of long-term effects and the need for mitigative measures. The moni tc.-i.,g system must be capable of providing early warning of releases of radionuclides from the disposal site before they leave the site boundary. (d) After the disposal site is closed, the licensee responsible for postoperational surveillance of the disposal site shall maintain a monitoring system based on the operating history and the closure and stabilization of the disposal site. The monitoring system must be capable of providing early warning of releases of radionuclides from the disposal site before they leave the site boundary. In summary, supporting technical objectives encompassed in the above regulations are to: (1) Characterize the site and processes affecting releases. (2) Establish a statistical data base for environmental parameters. (3) Assess environmental impacts. (4) Develop plans for taking corrective actions if the performance objectives in 10 CFR 61, Subpart C are not me't. (5) Detect radiological and nonradiological nonhazardous releases from waste disposal areas before they reach the site boundaries. 4 LLW ENVRNMNT MNTR BTP/ SEPT 87 ~

i 3 ENVIRONMENTAL MONITORING PRCGRAM PHASES Environmental monitoring consists of three major phases: precoerational, operational and postoperational. Preoperational monitoring occurs during the period prior to license submittal for a mir.imum of one year. Operational monitoring occurs frcm the beginning of facility construction through the period when waste.fs no longer accepted. Postoperational monitoring occurs from this point through the long-term care period. While monitoring during each phase is related to the performance objectives in 10 CFR 61, the e?phasis, scope, and intensity of monitoring will vary from phase to phase. The monitoring program should be planned so that the data collected during each phase will be compatible with and supplemental to data collected during the subsequent phases. 3.1 Preoperational Phase Background Determination 10 CFR 61 states the need to establish monitoring programs to obtain baseline information on o ecology o meteorology o climate o hydrology o geology o geochemistry o seismology To establish an adequate data base for pre-existing background concentrations of radioactive and chemical constituents and other time variant data, a preoperational monitoring program should begin early in the site characterization process. The program sheuld be conducted for at least 1 year to account for seasonal variations, though the staff anticipates that additional monitoring will occur during the license review to further define 5 LLW ENVRNMNT MNTR BTP/ SEPT 87

the physical system and to add to the existing data base from which action levels are established. The preoperational monitoring program should be developed so that all media sampling devices are operating concurrently during the minimum one year period, regardless of whether certain devices were operating for site characterization purposes to support site selection. To the extent practicable, preoperational monitoring stations should be located so that (1) they will, not have to be decommissioned during site operations, (2) they will continue to provide useful data during the operational and postoperational phases of site life, and (3) preoperational and postoperational levels can be compared. Furthermore, the monitoring stations should not be located in disturbed areas that will affect the monitoring results. Continuous media sampling for characterizing background levels of airborne constituents or direct gamma radiation is not necessary when the nature of potential releases from low-level radioactive waste disposal facilities is being considered. Discrete sampling is preferred for media that may be affected by random climatological events (e.g., surface-water quantity and quality). The minimal scope of analysis should include major radiological and nonradiological indicators, but may be more elaborate depending on site-specific conditions. Existing data that are considered reliable can also be used to establish baseline conditions, Action Levels i An action level is defined as the concentration of a specific radionuclide or chemical indicator above which additional monitoring or some mitigative action is required. Action levels should be related to background concentrations or regulctory limits for the particular media. The applicant should, when possible, test for parametric statistical characteristics so that proposed, statistically-based action levels are meaningful. For instance, for constituents possessing parametric statistical characteristics, an action level might be set at two stancard deviations above the background mean. Nonparametric statistical analysis could also be employed to evaluate seasonality and/or natural trends of concentrations, both of which are important when setting action levels. Another means of setting action levels 6 LLW ENVRNMNT MNTR BTP/ SEPT 87

could be the use of a fraction of the concentration limit in Table II of Appendix 8 to 10 CFR 20 as an action level based on the most restrictive radionuclide constituent. For example, the concentration limit for radium-226 could be used to set an action level for gross alpha measurements in grourd Also, the EPA maximum contaminant levels (40 CFR 141) for drinking water. water supplies could be used for nonradiological constituents. The staf f is currently evaluati.ng methods to statistically analyze background data for the purpose of setting action levels. Action levels that dictate remedial action may be much higher than those that mandate increased monitoring. Furthermore, if contaminants migrate toward the accessible environment, action levels might be lowered (i.e., become more stringent). Corrective Action plans At the time of license application, the applicar.t must present conceptual plans i for corrective measures in the event that radiological releases jeopardize facility compliance with performance objectives in Subpart C of 10 CFR 61. The corrective action plan should describe proposed actions to identify potential hazards associated with contaminant releases. The staff anticipates staged corrective actions that utilize increased monitoring to support or refute earlier laboratory results and the use of more detailed analytical procedures, i.e., gamma-scans, to more closely identify the species present in excessive levels. The increased monitoring actions should be designed to identify the approximate source and release rate of the contaminant to the environment. These data are necessary to choose the appropriate mitigative actions. The licensee should provide potentially applicable remediation measures to mitigate environmental impacts for a representative suite of failure scenarios. Example remedial measures could include the use of a grout curtain to slow the migration of contaminants in ground water during restoration, or the excavation and disposal of soil contaminated by surface releases. The submittal of a thorough corrective action plan indicates that the licensee is considering possible unanticipated events and their impacts on compliance wfth the performance objectives in Subpart C of 10 CFR 61. 7 LLW ENVRNMNT MNTR BTP/ SEPT 87

3.2 Ooerational Phase Operational monitoring should emphast?.e the measurement of short-term, releases of radioactivity in quantities and concentrations that either present an immediate health and safety problem or create the likelihood of a future problem. The staff anticipates that early in the operational phase of the site, most of the monitoring will be related to direct releases of radicactivity from incoming vehicles, waste containers, and handling equiorent that may migrate off-site and impact the environment. The monitoring pregram also should emphasize short-term releases caused by failure of the contair. ment system. In addition, any environmental monitoring that may be necessary in responsa to accidental releases from spills, container ruptures, fires, or other unanticipated events should be incorporated into a contingency plan. Environmental monitoring that was initiated during the preoperational phase should be continued, on a periodic basis, to determine if background concentrations have been exceeded. 3.3 Postoperational phase The postoperational monitoring plan should be based on information obtained during previous phases and include an optimal configuration of data collection stations or techniques necessary to detect radiological and nonradiological hazardous releases. A contingency monitoring plan should also exist during the postoperational stages in case significant migration of contaminants occurs. Initially, postoperational conitoring should continue at locations and frequencies specified during the operational phase. If postoperational monitoring revaals that no significant releases are occurring, sampling frequencies and locations ::uld be reduced. During site closure and early in the post-closure period. 't will be necessary to monitor representative site media frequently to confirm or modify predictions about site performance made from the analysis of previous monitoring data. These include air samples and surface soil samples. Tne sampling frequencies may be reduced for other media if there is no indication of radionuclide releases. The staff considers it 8 LLW ENVRNMNT MNTR BTP/ SEPT 87

inappropriate to establish frequency requirements for long-term postoperational monitoring because of the differences in natural site conditions, disposal technology, and facility performance history. The applicant must cr.ccese a projected long-term monitoring program, that is adeouate for maintaining surveillance that ensures compliance with the performance objectives and tra includes a contingency plan to be implemented in the event of a release. However, the staff believes that periodic collection and analysis should continue for ground water and surface water, onsite native vegetation (particularly deep-rooted species), and native rodents (particularly burrowing i species). Corrective action plans should be implemented if and when the monitoring program shows noncompliance with the performance objectives or a release resulting in concentrations greater than established action levels. 4 PATHWAY AND CONSTITUENT MONITORING 4.1 Monitoring Specific Pathways Radiological and nonradiological constituents should be monitored in ground water, soil, surface water, sediments, air and flora and fauna during the three phases of facility operation. Direct radiation should also be considered in the environmental monitoring program. Most of the monitoring stations should be located in the buffer zone, as noted in 10 CFR 61.52(a)(8), so that releases can be assessed and mitigative action can be performed, if necessary, before migration off site. o Ground Water At disposal sites in humid climates, the primary mechanism for radionuclide migration most likely will be ground-water flow. Humid sites generally have more direct ground-water recharge than do arid sites, usually resulting in larger seasonal fluctuations of water level and water quality, with the likell-hood that flow rates will be higher and more transient. Arid sites may have very deep, relatively stagnant flow systems with little seasonal change in water level or quality. Ground water flow may not be the principal release pathway at arid sites because of the long travel time for contaminants to reach 9 LLW ENVRNMNT MNTR BTP/ SEPT 87

l the water table (or a confined aquifer) and for the contaminated. groundwater to reach the facility boundary. Although both the saturated and unsaturated zones are important in both cases, the monitoring emphasis will depend largely on the behavior of the flow system. For example, at arid sites the unsaturated :ene should be emphasized; whereas at humid sites both the saturated and unsaturated zones should be considered. ) Preoperational ground-water monitoring involves the characterization of the recharge and discharge zones, and the determination of the rate and direction of ground-water movement, and the potentiometric and water table elevations for all potentially affected aquifer systems in the vicinity of the low-level radioactive waste disposal facility. The applicant should install an adequate number of monitoring wells, so that variability of flow rate and direction, during any given time period, can be assessed. Furthermore, tensfometers and/or suction lysimeters should be used so that movement of infiltrate in the unsaturated zone, the potential for deep percolation, and interactions of the unsaturated zone with saturated strata can be evaluated. Water levels and capillary potentials for the saturated and unsaturated zone, respectively, should be determined often enough 50 that seasona) fluctuations are taken into consideration. When conditions change rapidly, more frequent measurements will be needed. Conversely, sicwly changing systems probably will not require high-frequency sampling to characterize the system adequately. Water samples from the saturated and unsaturated zones should be collected, when possible, and analyzed for radiological, nonradiological, and organic con-stituents so that the water chemistry can be assessed. Understanding the aqueous chemistry during the preoperational phase, will enable the determination of indicators (i.e., total dissolved solids, pH) during the later phases of facility operation. Sampling frequency must be established on a site-by-site basis, taking into account expected changes in water quality and/or hydrologic conoitions during the year. Unless the applicant demonstrates that historical fluctuations were characterized adequately, NRC staff anticipates that a preoperational time period will be longer than the minimum specified in 10 CFR 61. 10 LLW ENVRNMNT MNTR BTP/ SEPT 87

l The applicant should be capable of defining vertical and horizon,tal gradf ents throughout the affected saturated and unsaturated :enes. These results will be necessary to design an efficient ground water monitoring system for.the o; era-tional and postoperational phases. Furthermore, these data will erhance tne understanding of the hydrogeologic system at the site. The applicant should sample, nhen possible, nearby residential, municipal, and industrial walls. The NRC staf f notes that adequate well completion data for these wells are important to ensure kncwledge of the monitored strata. These wells should also be included in the ground water monitoring plan and sampled. Ground water monitoring facilities developed curing the preoperational phase should be located so that they will continue to provide usable data during the subsequent phases of facility operation. In addition to wells downgradient of the site, upgradient wells should be maintained to detect changes in background levels during the later phases of operation. As noted in 10 CFR 61, wells should be located so that early warning of releases of radionuclides from the disposal site is ensured before they leave the site boundary. Thus, important release pathways should be monitored in the buffer zone. Ground-water monitoring facilities should be designed so tnat information gathered during the operational phase builds upon the information gathered during the preoperational phase. Emphasis should be placed on short-term releases caused by spills and other unanticipated eve.1ts. However, as disposal units become full and are closed, the NRC staff expects the emphasis to shif t from short-term releases to longe:r-term releases caused by gradual failure of the disposal units. Thus, monitoring frequencies may be reduced in specific areas of the facility as long as compliance with the performance objectives can be demonstrated, and contaminant releases can be detected before they migrate of f site (10 CFR 61.53(c)). Detection of a release should result in more thorough monitoring to assess envircnmental significance according to a corrective action plan outlined in the license applicaticn. Monitoring-locations should be maintained to the extent practicable so that data collection is as compatible with that collected during the preoperattonal phase as possible. 1 11 LLW ENVRNMNT MNTR BTP/ SEPT 87

i The emphasis during postoperational ground-water monitoring (enc,ompassing closure, the period af ter closure, and long-term care) should be placed on the detection of long-term releases caused by the gradual failure of disposal units or other unanticipated events, such as damaging. weather conditions or j inadvertent intrusion. As in cperational monitoring, the applicant must increase the scope of the monitoring plan to assess the environ.~ ental impacts f of possible contaminant releases, and if necessary, perform mitigative actions. However, if postoperational monitoring indicates that isolation of the low-level radioactive waste has been adequately isolated, the sampling frequency may be reduced, provided compliance with the performance objectives can be demonstrated. The staff considers this to be an important aspect of the oostoperational phase because it provides for eventual decreased monitoring during the long-term care period. For example, if monthly ground-water sampling at a humid disposal site indicates that therc has been no significant change for several years following closure the licensee could justify quarterly or bi yearly ground-water sampling. A licensee performing quarterly sampling at an arid site that yields acceptable results could possibly justify yearly sampling. In both e/amples, the licensee should analyze the ground-water samples for radiological and nonradiological indicators such as tritium, gross alpha activity, gross beta activity, pH, and total dissolved solids, total organic carbon, or other indicators expected to be in the waste stream, o Soil Preoperational soil sampling will be performod during site characterization. Samples should be taken from surficial soils as well as at depths that reflect the site's stratigraphy. The staff recognizes that soil analysis costs can be prohibitive if the soil depth is very great. The applicant, therefore, should sample material that is reasonably expected to becomo a migration pathway. Naturally occurring radioactivity should be analyzed in addition to those chemical constituents that might affect site performance, for example, complexing agents present tr. the soil. During site operations, samples should be taken to detect surface contamination as a result of operations. Soil sampling and testing should be done 12 LLW ENVRNMNT MHTR BTP/SFPT B7

periodically at locations where contamination is likely and at locations near areas where waste has been buried. Accidents and nonroutine or positive release events may dictate more frequent sampling. This monitoring c ould continue through closure. During the postclosure period, soil sampling should include areas rear the disposal units or. cells -- f ar enough away, however, to ensure tnat the integrity of the disposal unit is not compromised -- as well as onsite areas remote from buried waste and in the buffer zone. The number of samples and frequency of sampling may be gradually decreased during the postclosure period if laboratory results indicate no significant releases have occurred. The staff anticipates that soil sampling will eventually be performed in response to an unanticipated eveqt where the cover has been breached, or simply at very low frequencies to assess cell performance. Soil sampling during the post-closure period should be performed so that disturbance to the site and vegetation is minimized to ensure that erosion does not become a problem. Surface Water and Sedi eny o Because of siting requirements in 10 CFR 61, perenni~al surface water is not anticipated within the boundaries of the low-level radioactive waste disposal facility. However, it is importa*t that nearby offsite surface water be monitored for :wo reasons: (1) the monitoring could indicate surf ue contamination that is being removed from the site by surface runoff and (2) perennial surface water downgradient of the site may be a manifestation of ground water that originates at or passes beneath the site. If significant intermittent surface-water flow occurs on site, it should be included in the monitoring program. During the preoperational : ase, surface water sampling locations should be selected upgradient of, aff acent to, and downgradient of the, site in all sub- ~ watersheds to which the site may contribute. Nearby impoundments and surface-water drinking sources should be included in the sampling program. Estabitshed sampling stations, constructed during the preoperational phase would ensure consistent sampling during subsequent monitoring phases. 13 LLW ENVRNMNT MNTR BTP/ SEPT 87

Sampling of perennial surface-water sources near the site should,be representa-tive of the flow regime. Therefore, flow measurement should oe part of :N i monitoring program. Efforts should be made to sample ephemeral water courses during runoff periods and to correlate the results with the results related :o ~ perennial water courses. Samples should be analyzed for the same ractological and nonradiological constituents as those that are included in ground water sample analyses. During the operational conitoring plan, samples should be taken folicwing extreme hydrologic events that result in large amounts of surface runoff fr m the site and following uncontrolled release -- spills, accidents, failures -- of radioactive or chemical materials. Sample analyses should be the same as the ground-water sample analyses during the operational phase. Onsite surface-water sampling stations should be located in areas of runoff from active operations. For example, off-site runoff from truck wash basins and temporary storage areas should be included in the monitoring program. Snowmelt and large precipitation events that cause abnor.nal surface flows, temporary ponding, spillovers and other such unanticipated events should prompt special or more frequent surface water sampling to determine if releases have occurred, Surface water should be sampled during the postoperational phase at the same frequency as that during the operational phase. Samples should be analyzed for the indicators determined during the previous aionitering phases. Following site stabilization, sampling frequency may be reduced if there are acceptable results. positive results, on the other hand, would necessitate more frequent and rigorous sampling and analysis or, in the extreme, mitigative actions. During all three phases, sedicent samples from representative cross-sections of nearby surface water courses should be taken and analyzed for the same radio-active and chemical constituents as those in soil samples. Sample locations should be approximately the same as those for surface-water sampling. Samples should be collected at various points and depths in the cross-section of the sediment profile. Samples from a discrete cross-section may be aggregated for radiological and chemical analysis. 14 LLW ENVRNMNT MNTR BTP/ SEPT 87

Meteorology and Air Caalfty o A meteorological monitoring program should be established as part of, the site i characterization process, and should co,tinue throughout the operational and postoperational stages. Site-specific sorological data should be collected for a m'nimum period of 1 year during the preoperational environmental monitoring period,. unless the applicant can demonstrate that date from other meteorological stations represent conditions on site. These data may include precipitation, temperature, wind speed and direction, etc. The applicant must demonstrate that the seasonal variations noted in the characterization period represent hittorical conditions. Thus, comparisons with east records should be made. In addition to site-specific measurements, regional long-term meteorological data should be obtained from offsite sources such as the nearest National Weather Service station. These additional data are necessary to supplement site-specific records and to determine the extent to which they are representative of the prevailing climatological conditions. Along with surface temperature records, measurements of additional *meteorolcgi-cal parameters are needed to determine une water budget for the waste disposal site, as well as ground water levels and stream discharge. Measurements of the amount, rate and type of precipitation are very important for estimating flow and potential contamination of surface and subsurface waters. Eyspotranspiration, which can account for the largest component of outflow of precipitation, should be estimated using soil moisture measurements, pan evaporation, and meteorological conditions. The fraction of precipitation in. the form of snow and rainfall should be measured. Evapotranspiration processes will typically move significant amounts of water from the near-surface environment into the atmosphere. Pan evaporation can be measured at the site to provide an upper bound an evaporation rates. Additional supporting data for quantifying evapora.tive processes may be derived from measurements of temperature within the soil, solar radiation (insolation), i soil moisture, matric potential, wind speed, and relative humidity or dew point. 15 LLW ENVRNMNT MNTR BTP/ SEPT 87

NRC has no aJthority to enforce against noncompliance with air e? mission standards. However, the license will most itxely contain provisions whereby the applicant is required to comply with applicable state and/or federal standards under the Clean Air Act. Therefore, it is incumbent upon the applicant to establish ambient air quality levels early during the period of site characterization, Air quality parameters can include carbon monoxide, oxides of nitrogeq, sulfur dioxide, hydrocarbons, photochemical oxidants, and suspended particulates. Amoient levels constitute part of the data base for the disposal site. Potential sources of nonradiological pollutants that might affect air quality during disposal facility operations typically would be combustion emissions from transportation vehicles or power equipment operations, dust from trench excavations or backfill operatior.s, ar., gaseous emanations from the decomposition of organic waste products. During the preoperational phase, at least one continuous air sampler should be located downwind of the site in the most prevalent wind direction (as deter-mined during site characterization) so that baseline air quality conditions can ba established. At least one background continuous air sampler should be located a suitable distance upgradient of the most prevalent wind direction in an area that will remain undisturbed by site operations and that is not affected by other sources. Air filters should be collected and analyzed for gross alpha and gross beta activities, and other indicators at a frequency adequate to evaluate air quality changes. A composite gamma scan snould be performed at least quarterly. l Air samplers should continue to be used during the sfte operational phase, although they may be repositioned depending on the analysis of climatological data. During normal operations, air sampling should be performed regularly. Non*outine occurrences such as onsite accidents or extreme climatological events may mandate more rigorous sampling and analyses. During closure activities, air sampling should e.antinue as during site opera-tions. Once the site surface has been stabilized after closure, routine air sampling may be reduced in frequency and number of sampling points. For several years during the postclosure observation period, at least one 16 LLW ENVRNMNT MNTR BTP/ SEPT 87

continuous air sampler shoulo be maintained near the site boundary doe wind of n the most prevalent wind direction. Filters should be monitored for gross aloha and beta activity. If the activity is high, the filters should be collected more frequently, and a comoosite gamma scan should be performed. Annual isoton analysis of composite samples also should be performed. If appropriate, air sampling may be reduced during the institutional control

period, o

Flora and Fauna Flora and fauna may be potential pathways for human exposure. Also, the presence of certain species at or near a waste site may affect the ability of th9 site to contain the waste. Therefore, because knowledge of preoperational ecological conditions are necessary to evaluate putential impacts caused by releases, monitoring of flera and fauna at or near the site should be a component of the monitoring program. The purpose of en ecological monitoring program is to verify that, in the case of non-compliance with release criteria, the populations in the floral and faunal communities that have been identif id as pathways to man have not beeri affected in such a way that public health and safety are threatened. The creoperational monitoring program should identify those aspects of the ecolcgical community that are "impcrtant" from the health and safety standpoint. Thus, for the purposes of thia document, a species is important if: (1) The species has been identified as a potential pathway to man. (2) The species is a biological indicator of radiological and nonradiological constituents in the environment. During the preoperational phase, vegetation should be collected in the vicinity of soil sampling locations and from areas that may later be centaminated by migrating waste. Sampling sbculd include all major species of vegetation 17 LLW ENVRNMNT MNTR BTP/ SEPT 87

characteristic of the site that could become involved in the foqd chain and impact humans, or lead to other parts of the food chain. The samples should be analyzed routinely for gae.ma activity and tritium. An adequate number of samples should be collected and analy:ed so that baseline conditions are established. However, to cistinguish between surface contamination and plant uptake, the sample should be washed before it is analyzed for plant uptake. During the operational phase, sampling frequency may be reduced for shallow-rooted vegetation. The species of vegetation collected and the types of constituents analyzed in the sample should remain constant from year to year. The operational $sa conitoring program should be expanded later to include deep-rooted veget ion. Leaves from representative deep-rooted species should be sampled annuais, beginning 5 years after operations begin. They should be analyzed for at least gross alpha and gross beta activity and tritium. All vegetation samples that exceed action level cancentrations established during the preoperational phase should undergo a complete isotopic analysis. During the postoperational phase, sampling and analysis of vegetation should continue as during the operational phase, though the sampling frequency will likely be lowered following acceptable analytical results. A faunal inventory should establish the identity of the major terrestrial and aquatic organisms on or near the site that are determined to be pathways of radiological transport. From this list, the important species should be identified and their quantitative abundances ascertained. This inventory should be used to identify potential vectors and indicator species that are present, particularly in the case of an accidental release. Representative samples of local livestock, dairy products, and game species i should be taken and ana'j:ed quarterly during the preoperational survey. i Analyses should include ;ama scans of sample portions known to accumulate contaminants. These samples can provide the bests for determination of environmental impacts and information on base level in potentia. vectors to man in the case of accidental release. 18 LLW ENVRNMNT MNTR BTP/ SEPT 37

Care should be taken tu properly account for seasonal or other dif ferences in the abundance of such species. The inventcry should include species that migrate through the area. In addition to wild species, the survey should consider the locations and numbers of domesticated animals, especially dairy cows and goats. The monitoring program for fauna should never involve the harvesting of rare, endangered or locally important species. Game animals should be sampled primarily during the hunting season for each species. If these samples indicate the need for out-of-season sampling, approval should be obtained from the appropriate agency. If an accident occurs, the applicant should sample the established vector species and determine whether they have been impacted by the contaminant release. 4.2 Monitoring Constituent Levels The site environmental monitoring program involves the analysis of two major ccnstituent types: (1) Detection of direct gamma radiation. (2) Detection of radiological and nonradiological nonhazardous constituents released to the environment from the facility or elsewhere. Direct Gamma Radiation During the preoperational phase, continuous measurements of direct gamm radiation should be made at locations selected for air sampling and at various other locations on the site and in the site environs. Devices should ideally be located 1 m above the ground and at least 10 m from ex sting buildings. During the operational phase, monitoring of direct gamma radiation should continue. Measurement of direct gamma radiation during the institutional care period will be left to the discretion of the custodial agency. 19 LLW ENVRNMNT MNTR BTD/ SEPT 87

As part of the postoperational phase, a direct gamma radiation survey of the site surface will be conducted according to the acceptable frequency as described in the license application or for special cases. Ofrect ga-a radiation surveys should be conducted before the license is terminated or transferred and after major site disturbances such as t erch sobsidence or disruptive climatological events. Radiological and Nonradiological Constituents The primary technical objective of a monitoring program at a low-level radio-active waste disposal facility is to monitor radiological and nonradiological nonhazardous species that may be released in order to: (1) Determine the extent and direction of migration. (2) Estimate whether (and when) such movement will reach offsite areas. (3) Estimate potential radiation doses from ground and surface water contamination. (4) Identify, monitor and estimate potential radiation doses associated with other pathways. (5) Identify whether contaminant release occurred as a result of gradual failure of the disposal unit or normal onsite operations. A program for determining background concentrations of radioactive constituents should be initiated during the preoperational phase. Pertinent literature and knowledge of the site area should be helpful in selecting specific constituents for which background levels will be determined. Seasonal and climatological variations must be considered. During the operational phase, important radio-logical constituents in the waste form should be identified, and their signift-cance with respect to hazard, volume, potential mobility, and half-life should be determined. This identification will enable the determination of background concentrations and the monitoring for radionuclide migration after waste 20 LLW ENVRNMNT MNTR BTP/ SEPT 87

emplacement. During the operational and postoperational phases, radiological constituents identified as important should be monitored in all potential pathways (particularly soil and water). At a minimum, media should be analy:ed for gross alpha activity, gross beta activity and tritium in water and vegetation. Gamma-ray spectrometry should be performed to characteri:e the principal gamma emitting radionuclides present. Non adiological nonhazardous constituents in ground water should be monitored at 4 low-level radioactive waste disposal facility for three reasons.

First, cert. o inorganic and organic species occurring naturally or introduced by waste 'mplacement, such as decontaminating agents, can form chemical complexes with radionuclidec., potentially increasing radionuclide mobility.

Studies have shown that some organo-radionuclide complexes may persist and increase radionuclide mobility over significant distances. It is necessary to understand whar radionuclide complexes are being formed under the disposal site's geochemical conditions so that their migration behavior may be monitored. Second, the nonradiological constituents may themselus cause anvironmental impacts and therefore pose a public health problem.

Third, changes in concentrations of nonradiological constituents could signify radionuclide release and migration and can provide indications of off-normal performance.

It is appropri&te to note that 10 CFR 61.56(a)(8) requires treatment to the extent possible of nonradiological haiardous constit'uents to limit potential health effects. However, the staff considers it prudent to monitor for indicators of nonradiological hazardous relaases for the above reasons. During the preoperational phase, the soil and water at the site should be evaluated for the presence of chelating agents and known deleterious chemicals and background concentrations should be determined. It is recognized, however, that monitoring every chemical parameter in every media that could potentia!!y mobilize radioactive material or acet radionuclide migration is impracticable. Therefore, a program for screening representative indicators of chemical constituents in the waste form should be developed that is based on the abfifty of the constituents to form chemical complexes. Those constituents identified 21 LLW ENVRNMNT MNTR BTP/ SEPT 87 .-.I

as significant in the preoperational and operational phases and in the waste form, respectively, should be monitored, i 5 OTHER PROGRAM COMPONENTS 5.1 Quality Control Program The applicant must provide a written Quality Control Program in the license application adequate to meet the requirements of 10 CFR 61.12. It is stated in 10 CFR 61.12(j) that every application for a license to design, construct, and operate a low-level waste disposal facility is required to include a de-scription of the Quality Control Program to be applied to the determination of natural disposal site characteristics, and for quality control during design, construction, operation, and closure of the land disposal facility and the receipt, handling, and emplacement of waste. The quality control requirements 61.12(j) are the bases for the development of such a program, and the QC plan for EM is considered to be an integral part of the overall program. NRC staff expect the QC Program to be implemented fully at the beginning of the preopera-tional monitoring phase so that action levels are defined accurately. Although not explicitly stated in 10 CFR 61, it is incumbent upon the applicant to ensure that an adequate Quality Assurance Program is implemented, including management organization, such that the QC Program is maintained. This will provide assurance, to the licensing authority and intervenors, that the data collected on environmental conditions are defensible. The description of the QC Program with respect to EM should contain criteria which include, but are not limited to: performance specifications for all sampling equipment; sampling instructions and procedures; control of measuring and test equipment; sample handling, preservation, storage and shipping; chain-of-custody procedures; performance specifications for all sampling equipment; calibration pre:edures; field checks; and the use of spiked, split, and blank samples. A procedures audit plan should also be included with the QC Program in the license application. 22 LLW ENVRNMNT MNTR BTP/ SEPT 87 )

5.2 Maintenance and Decommissioning of Monitorino Equioment Monitoring equipment should be maintained in operating order during its useful life. Manufacturers' recommendations for cleaning, refu'rbishing, and calibrating equipment should be followed. Monitoring facilities and equi; ment should be protected frcm damage from other site operatiens. Areas around monitoring equipment should be maintained so that natural or human factors (e.g., vegetative growth in the vicinity of a wind vane) do not bias sampling results. Whenever practicable, monitoring facilities should be developed to be opera-tional during all phases of site life. However, it is likely that some monitoring facilities and equipment will have to be replaced during their life-time. If decommissioning of monitoring facilitie's becomes necessary for any reason, it should be performed in a manner that is least disruptive to site performance or the local environment. This concept is especially important with regard to decommissioning of ground water monitoring facilities. Wells and other facilities that cenetrate the site surface should be completely re-moved, if possible, and sealed with grout cement to restrict contaminant migration. If it is not possible to remove a particular facility, it should be plugged throughout its full extent and either capped in a manner that prevents infiltration along its external interface with surrounding soil, or preferably cut off below the site surface, capped, and backfilled to natural grade. Plans for doing this, along with a technical basis, should be developed at the time the system is designed. Sealing activities should be compatible with applicable State requirements. Complete decommissioning of monitoring facilities should be considered only when the facility is proc.cing false or misleading data or no data at all. Replaced factitties that are capable of yielding usable data should be retair.ed as backup facilities. in case of f ailure of the new facilities. When possible. a new facility replacirg an old facility should be operational before the old facility is dismantled. Inis will help ensure continuous data collection. 23 LLW ENVRNMNT MNTR BTP/ SEPT 87

6

SUMMARY

V Components of an environmental monitoring program are described in 10 CFR 61.53. The purpose of this document is to provide guidance to applicants, licensees, and government entities for the development and implementation of such programs. The primary objective of the environmental monitoring program is to determine compliance with the performance objectives in 10 CFR 61.41 and 61.44 Supporting technical objectives of the program are to characterize the site and processes affecting releases, assess environmental impacts, establish a statistical data base for environmental performance parameters, detect radiological and nonradiological nonhazardous releases from waste disposal areas before they leave the facility boundary, and develop remedial action plans when the performance objectives in 10 CFR 61, Subpart C are not met. Environmental monitoring consists of three major phases: preoperational, operational, and postoperational. During the preoperational pase, a back-ground data base is compiled for radioactive and nonradiological constituents, appropriate action levels are determined, and remedial action plans are formu-lated. Site monitoring for potential radiological and nonradiological releases is performed during the operational and postoperational phases, and if releases result in exceedance of action levels, remedial action plans are implemented. The site environmental monitoring program consists of two major components: detection of direct gamma radiation and detection of radiological and non-radiological constituents. Direct gamma radiation surveys should be conducted regularly during all three phases of the programs; or in special cases, such as before the license is terminated or transferred and af ter major site disturbances. Radiological and nonradiological constituents should be sampled and analyzed periodically, and when migration is suspected, at a greater frequency and more comprehensively. Specific pathways to be monitored during the three phases of facility operation are ground water, soil, surface water (including site runoff), sediments, air, and flora and fauna. Important radiological and chemical indicators include tritium, gross alpha activity, gross beta activity, pH, total dissolved solids, total organic carbon, or other indicators expected to be fn the waste stream. In addition, supplemental data 24 LLW ENVRNMNT MNTR BTP/ SEPT 87

J on site-specific release mechanisms should be compiled which relate to ecology, meteorology, climate hydrology, geology, geochemistry, and seismology. A quality control program should be developed and implemented to ensure the accuracy of all monitorf ag techniques and analyses. Important components include maintenance and verification of monitoring equipment, documentation of field and laboratory procedures, checking and documentation of data files and computations, and conducting an independent audit program. Reporting requirements for the licensee include maintenance of permanent record files, preparation of periodic summary reports, and submission of all monitoring data and audit results to appropriate regulatory authorities (10 CFR 61.80). Monitoring equipment should be maintained and decommissioned when necessary to ensure accuracy in data collection end to allow facility performance without disruption. Equipment should be cleaned, refurbished, and calibrated according to the manufacturers' speqifications. Instruments should be protected from natural and human intrusion during the active life of the monitoring program. When components of the monitoring system reach the end of their useful operating life or are no longer needed, they should be replaced or decommissioned. 7 REFERENCES Code of Federal Regulations, Title 10, "Energy," and Title 40, "Protection of Environment," U.S. Government printing Office, Washington, OC, revised annually. U.S. Department of Energy, 00E/LLW-13 Tg-1983, "Environmental Monitoring for Low-level Waste Disposal Sites," National Low-Level Waste Management Program, Washington, DC, 1983. U.S. Geological Survey, "National Handbook of Recommended Methods for Water-Data Acquisition," U.S. Department of the Interior, Reston, Virginia,1977. l 25 LLW ENVRNMNT MNTR BTP/ SEPT 87 _~.

.U.S.' Nuclear Regulatory Commission, NUREG/CR-1759, "Data Base for Waste Management," Vol. 1, Washington, OC, November 1981. --, NUREG/CR-4352, "Suggested State Requirements and Criteria for a low-Lev Radioactive Waste Disposal Facility," Washington, CC, "August 1935. --, Regulatory Guide 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Ef fluent Streams and the Environment " Washington, DC. 1 26 LLW ENVRNMNT MNTR BTP/ SEPT 87 i s

NRC STAFF PRESENTATION TO THE ACNW

SUBJECT:

Preo Po srD Po Lic y o n! Ex'm i'i od' neorn ar&or a rox.y c o Mac t-. DATE: TVLf' l / < /988 PRESENTER: kJ /"'M E-44MS PRESENTER'S TITLE / BRANCH DIV.: cu/Er, etsva rio a oevez.o+ cur- \\ 8g4McN, DiV/Sior) of & queAroit.y nopuc A ric as, ess PRESENTER'S NRC TEL NO.: (del) b92' J77Y l SUBCOMMITTEE: Aow. cony commi rrer sa duncius ws.cn=- WC EMPt.QYEtt TO BE USED ALL PMSENTATIONS TO THE ACNW BY.

l I i l l ACNW BRIEFING JULY 21, 1988 I I PROPOSED POLICY ON EXEMPTIONS FROM l REGULATORY CONTROL FOR PRACTICES WHOSE PUBLIC HEALTH AND SAFETY SIGNIFICANCE IS BELOW REGULATORY CONCERN 1 I l I I i i 1

i CONTENTS OF COMMISSION PAPER o SRM OF MARCH 30, 1988 o PROPOSED POLICY STATEMENT o OPTIONS FOR NUMERICAL VALUES WITHIN THE PROPOSED EXEMPTION POLICY l o MAJOR POLICY CONSIDERATIONS l o RESPONSE TO COMMISSION QUESTIONS REGARDING BASIS FOR PRIOR BRC ACTIONS AND UNCERTANTIES IN DOSE - RESPONSE COEFFICIENTS 1 1 1 l

PURPOSE OF COMMISSION PAPER o RESPOND TO COMMISSION DIRECTION IN MARCH 30,1088 SRM l -SUBMIT POLI.CY, WITH OPTIONS, ESTABLISHING GENERIC NUMBER f l FOR EXPOSURES THAT ARE BELOW REGULATORY CONCERN -IMPLEMENT NUMBER FOR MULTIPLE SOURCES WHICH DOES NOT l REQUIRE JUSTIFICATION BY INDIVIDUAL LICENSEES -RESPOND TO OTHER QUESTIONS RAISED BY COMMISSION l o PROVIDE PROPOSED POLICY FOR DISCUSSION WITH INTERNATIONAL GROUPS O i 2 = - - - - - - - - = - - - - - - l

i. l { } l l ),^- i REGULATORY EXEMPTION POLICY i m i PERSPECTIVE ON ANNUAL INDIVIDUAL EXPOSURE LEVELS / , { I h-J l o BACKGROUND EXPOSURE EXCLUDING RADON 100 mrom l o PROPOSED 10 CFR PART 20 DOSE LIMIT l UNRESTRICTED AREA FROM LICENSEE PRACTICES 100 mrom o VARIATION IN COSMIC RADIATION l WASHINGTON, DC. VS DENVER, COLORADO 25 mrom o EPA GENERALLY APPLICABLE ENVIRONMENTAL 7; l STANDARD ( FUEL CYCLE ) 25 mrom /- l i o CLEAN AIR ACT ( under reconalderation) 25 mrom I o PROPOSED EPA ~ BRC LEVEL-WASTE DISPOSAL 4 mrem o COMMISSION POLICY STATEMENT (8/25/96) l MAX. DOSE CRITERIA-EXPEDITED HANDLING a few mrom l WASTE DISPOSAL PETITIONS o 10 CFR PART 50, APP. I-REACTOR EFFLUENTS 3 mrom -IIquid j 10 mrad air )

. i; ~/ e,. I ,I j l 1 l 1 REGULATORY EXEMPTION POLICY f PERSPECTIVE ON EXPECTED EXEMPTED PRACTICES l O PRACTICES INVOLVING WlDESPREAD DISTRIBUTION & USE I OF RADIOACTIVE MATERIAL BY THE PUBLIC 1 CONSUMER PRODUCTS RECYCLE OF SLIGHTLY CONTAMINATED EQUIPMENT & MATERIAL I f o PRACTICES ANTICIPATED TO RESULT IN ONLY LIMITED j INTERACTIONS WITH THE PUBLIC LAND DISPOSAL OF LOW LEVEL RADIOACTIVE WASTE j l RELEASE OF SLIGHTLY CONTAMINATED LANDS & STRUCTURES t i FOR UNRESTRICTED USE i RADIOACTIVE EFFLUENT RELEASES l i l j t 4 ^^ ~ ' ' ~ ~ ~ r T T r ~ L

I } l j CONDITIONS APPLICABLE TO EXEMPTION DECISIONS i l 1 i i l o THE APPLICATION OR CONTINUATION OF REGULATORY CONTROLS i DOES NOT RESULT IN ANY SIGNIFICANT REDUCTION IN THE INDIVIDUAL OR COLLECTIVE DOSE RECEIVED, OR i l o THE COSTS OF REGULATORY CONTROLS TO REDUCE DOSE f ARE NOT BALANCED BY THE BENEFITS OF DOSE REDUCTION i i \\. I { 1 l 5 I _.. _ _ _ _ __ _ _ _

l ~ i I j 8 i i

SUMMARY

OF PROPOSED POLICY f I 1 o PROVIDES FOR TWO GENERAL EXEMPTION CATEGORIES -BOTH BASED ON JUSTIFICATION OF PRACTICE & COST / BENEFIT ANALYSES (LENEAR DOSE-EFFECT MODEL) -BOTN ALLOW AN INDIVIDUAL DOSE CUTOFF IN COLLECTIVE DOSE ASSESSMENTS j o INCLUDES GUIDANCE ON FRIVOLOUS PRACTIOES l I { 's j e... / 'e 4 6 i 1

l I ) t 4 I i 1 i l THE UPPER CATEGORY IN THE EXEMPTION POLICY l o ALLOWS POSSIBLE EXEMPTIONS IF INDIVIDUAL DOSES KEPT BELOW 100 mram/ year - MOST EXEMPTIONS EXPECTED TO INVOLVE i DOSES BELOW 10-15 mrom/ year o REQUIRES EXEMPTION TO BE BASED ON SUPPORTING OUANTITATIVE COST-BENEFIT ANALYSES i e ALLOWS DEGREE OF RIGOR IN C/B ANALYSIS TO BE A FUNCTION 1 OF INDIVIDUAL & COLLECTIVE DOSE i l ,, i \\ i j l s \\ I 7 A- = -r - -:-

1 I t 1 THE LOWER CATEGORY IN THE EXEMPTION POLICY o PROVIDES BASIS FOR EXEMPTING PRACTICES j INVOLVING SMALL RADIOLOGICAL RISK i l - INDIVIDUAL DOSE TARGET OF f 1 mrem / year I - COLLECTIVE DOSE TARGET OF i l 1000 person-rem i i PROVIDES FOR SIMPLE ANALYSIS TO SUPPORT 3 o I l EXEMPTION JUSTIFICATION ,eS 'l ,,, ~ .l i# ,j u .c v ,,ri e g e j. i g i

4 NATIONAL AND INTERNATIONAL PICTURE 1 1 1 CANADIAN ATOMIC ENERGY CONTROL BOARD-PROPOSED o 5 mrem / year DOSE LIMIT FOR DISPOSAL OF WASTE U.K. NATIONAL RADIOLOGICAL PROTECTION BOARD-DE MINIMIS l o 5 mrem / year ALL SOURCES COMBINED O.5 mrem / year INDIVIDUAL SOURCES NATIONAL COUNCIL FOR RADIATION PROTECTION o l '/ 1 mrem / year NEGLIGIBLE INDIVIDUAL RISK LEVEL CUTOFF FOR COLLECTIVE DOSE </ ) %,) e - / /t 'TI% /d) INTERNATIONAL ATOMIC ENERGY AGENCY o I mrem / year DE MINIMIS -TO INDIVIDUAL O.1 m rem / year PER PRACTICE 100 PERSON-REM COLLECTIVE } \\

a.., )

v 'w g

d i i I l i 1 f MAJOR POLICY CONSIDERATIONS I i o JUSTIFICATION OF PRACTICE PRINCIPLE 1 o EXCLUSIONS FROM EXEMPTION POLICY l l o CALCULATION AND USE OF COLLECTIVE l DOSE ASSESSEENTS l l ~ \\ 10 1

t l ll JUSTIFICATION OF PRACTICE l ! l l ! A BASIC PRINCIPLE OF RADIATION PROTECTION l BOTH NATIONALLY AND INTERNATIONALLY RETAINED IN PROPOSED EXEMPTION POLICY l o AT LOWER RADIOLOGICAL RISKS JUSTIFICATION DETERMINATION l CAN BE MADE ON SIMPLE BASES l o PRECLUDES PLETHORA OF UNCONTROLLED PRACTICES CAUSING MULTSPLE SOURCE PROBLEM CLOSELY TIED TO OTHER poi. ICY DECISIONS INDIV! DUAL DOSE CUTOFF FOR COLLECTIVE DOSE ASSESSMENTS o o EXCLUSIONS FROM EXEMPTION POLICY 1 WITHOUT THRS PRINCIPLE, COMMISSION WOULD BE OPTING I FOR DEFINITION OF DE MINIMIS OR NEGLIGIBLE RISK POLICY 11

I J i l i i i I PRACTICES EXCLUDED FROM EXEMPTION POLICY i STAFF BELIEF THAT CERTAIN PRACTICES ARE o SOCIALLY UNACCEPTABLE REGARDLESS OF RISK l I (DOSE) INVOLVED v INCLUDED AS GUIDANCE (IF JUSTIFICATION OF o PRACTICE REMAINS INTEGRAL PART OF EXEMPTION POLICY) i ~ i i 12

t INDIVIDUAL DOSE CUTOFF IN COLLECTIVE DOSE CALCULATIONS o 0.1 mrom VALUE REPRESENTS 1 IN A MILLION LIFETIME RISK TO INDIVIDUAL - LEVEL AT WHICH ACTION NOT TYPICALLY TAKEN BY FEDERAL AND STATE AGENCIES IN CLEANUP OF CHEMICAL CARCINOGENS - IEVEL USED BY FDA IN RESIDUAL FOOD CONTAMINATION INITIALLY PROPOSED IN REVISION TO 10 CFR PART 20 o o COLLECTIVE 90SE REALISTICALLY LIMITED TO -VALUE FOR WHICH SOCIETAL HEALTH EFFECT UNLIKELY -VALUE COMPARABLE TO 1000 PERSON-REM TARGET d 13 l --}}