ML20151W519

Rev 1 to Reg Guide 4.16, Monitoring & Reporting in Releases of Radioactive Matls in Liquid & Gaseous Effluents from Nuclear Fuel Processing & Fabrication Plants & UF6 Production Plants

ML20151W519
Person / Time
Issue date:	12/31/1985
From:	NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
References
TASK-CE-401-4, TASK-RE REGGD-04.016, REGGD-4.016, NUDOCS 8808250011
Download: ML20151W519 (11)

Text

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.. .e Cb o Revision i' )

/pe% U.S. NUCLEAR REGULATORY COMMISSION Deczmber 1985 s/

@f!f REGULATORY GUIDE

,...,# OFFICE OF NUCLEAR REGULATORY RESEARCH ,

REGULATORY GUIDE 4.16 l (Task CE 4014)

MONITORING AND REPORTING RADIOACTIVITY IN RELEASES OF RADIOACTIVE MATERIALS IN LIQUID AND GASEOUS EFFLUENTS FROM NUCLEAR FUEL PROCESSING AND FABRICATION PLANTS AND URANIUM HEXAFLUORIDE PRODUCTION PLANTS A. INTRODUCTION by licensees to maintain radiation exposure and releases as far below the limits specified in 10 CFR Part 20 as Section 70.59,"Effluent Monitoring Reporting Require- is reasonably achievable. Sections 20.105, "Permissible ments " of 10 CFR Part 70, "Domestic Licensing Levels of Radiation in Unrestricted Areas," and 20.106, of Special Nuclest Material," requires licensees author- "Radioactivity in Effluents to Unrestricted Areas," of ized to possess and use special nuclear material for 10 CFR Part 20 require licensees engaged in uranium processing and fuel fabrication, scrap recovery, or fuel cycle operations subject to the provisions of 40 CFR conversion of uranium hexafluoride to submit semi- Part 190, "Environmental Radiation Protection Standards annual reports to the NRC specifying the quantity of for Nuclear Power Operations," to comply with 40 CFR each of the principal radionuclides released to unre- Part 190.

stricted areas and such other information as the NRC may require to estimate maximum potential annual This guide provides methods acceptable to the NRC radiation doses to the public resulting from effluent staff for developing effluent monitoring programs to be releases. Section 40.65, "Effluent Monitoring Reporting described in license applications and for monitoring and e

Requirements," of 10 CFR Part 40, "Domestic Licens- reporting effluent data by licensees. The guidance is ing of Source Material," requires each licensee authorized applicable to nuclear fuel processing and fabrication to possess and use source material in the production of plants and uranium hexafluoride production plant s.

uranium hexafluoride to submit semiannual reports similar to those required by 5 70.59. Information collection activities mentioned in t his regulatory guide are contained as sequirements in 10 CFR Section 20.106, "Radioactivity in Effluents to Unre- Parts 20, 40, or 70, which provide the regulatory basis stricted Areas," of 10 CFR Part 20, "Standards for for this guide. Tne infctmation colicction requirements Protection Against Radiation," prohibits a licensee from in 10 CFR Parts 20, 40, and 70 have been cleared releasing radioactive materials to an unrestricted area in under OMB Clearance Nos. 3150-00l4, 3150 0020, and c: concentrations that exceed the limits specified in 10 CFR 3150-0009, respectively.

@ - f Part 20 or that exceed the limits otherwise authorized N in a license issued by the Nuclear Regulatory Commission E (NRC). Section 20.201, "Surveys," of 10 CFR Part 20 B. DISCUS $10N CD requires that a licensee conduct surveys of concentrations 4 of radioactive materials as necessary to demonstrate Information on the identity, concentration, and g compliance with NRC regulations. Section 20.401, quantity of radionuclides in liquid and gaseous effluents o t.u "Records of Surveys, Radiation Monitoring, and Dis- from nuclear fuel processing and fabrication and oranium

{% posal," requires that records of surveys be maintained hexafluoride production pl.=nts 3 needed:

CD O for We period specified.

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CD a.o Paragraph (c) of 6 20.1, "Purpose," of 10 CFR Part 1. For rwa!ustion by the NRC staff of the environ-20 states that every reasonable effort should be made mental nyact of radioactive materials in effluent s,

'The substantial numbef of changes in this reskion has made it including estimates of the potential annual radiation impractical to indicate the changes with lines in the martrin. doses to t,hegh;c.

USNRC REGULATORY GUIDES Written comments may be submitted to the Rules and Procedures Bra n c h, ORR AtiM, U.S. Nuclear Regulatory Commission, Regulatory Guides are issued to describe and make available to the Washiogton, DC 205 5 5.

pu blic rnet hods &CC ep ta ble to the NRC staff of im plem en t ing specific parts of the Commission's regulations, to delineate tech.

at aCcl ent or t IG u ance to DD Ce s. egu ato y h is n a uit d eth dsan of tl 3 di er ru o; t Rose rth a Test Reactors r o laticn out in the guldet vvill be acceptable if they provide a balls for the a. Fuels and Wterials Facil: ties 8. Occupational Health findings requisite to the issuance or cont 6 nuance of a permit or 4. EnWcomen+al and Siting 9. Antitrust and Finsncial Review 16 cense by the Commission. 5. Mateelais ano Ptant Protection 10. General

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2.To enable the NRC staff to ascertain whether quarter is equal to 10% or more of the appropriate regulatory requirements have been met and whether concentration listed in Table II of Appendix B to 10 CFR conemtrations of radioactive material in liquid and Part 20.

gaseous effluents have been kept as low as is reasonably achievable (ALARA). The sampling program should be sufficient to permit a determination of the quantities of radionuclides and

3. For evaluation by the licensee and the NRC staff the a verage concentration of radionuclides being dis-of the adequacy and performance of effluent controls. charged from the plant. The sampling rate at each release point should be such that a representative sample l It is essential to have a degree of uniformity in the of the effluent is collected. The volumes of gaseous l programs for monitoring and reporting data on radio- effluents should be reported so the NRC staff can active material in effluents. This guide provides a basis calculate the quantities of radionuclides discharged. <

for uniform reporting, for comparing data from different sources, and for permitting the preparation of consistent summaries for use by the NRC staff as bases for asses- 2.2 Liquid Effluents sing a licensee's effluent controls and the potential environmental impact of radioactive material in effluents. Representative samples should be collected at each liquid release point for the subsequent determination of the quantities and average concentrations of radionuclides C. REGULATORY POSITION discharged in any liquid effluents that could reach an unrestricted area, including discharges to a sanitary sewerage system. For continuous releases, representative I. METHODS OF SAMPLING AND ANALYSIS samples should be continually collected at each release point. For batch releases, a representative sample of The sa m pling and analysis methods used in the each batch should be collected.

effluent momtoring progra ms should be chosen to proyule information on the quantity and concentration For some liquid effluents, the licensee may establish, of radionuclides in gaseous and liquid effluents. The by periodic sampling or by other mean., that radioac-bibbography in this guide provides useful reference; on tivity in the effluent is insignificant. In such cases, the sa m pling, analysis, statistical analysis, and the prepara- effluents should be sampled at least quarterly. The tion and maintenance of effluent monitoring programs. licensee should show, as supplemental information, that these samples are representative of actual releases. For the purposes of this guide, a liquid effluent release is

2. SAMPLING PROGRAM significant if the concentration averaged over a calendar quarter is equal to 10% or more of the appropriate 2.1 Gaseous Effluents concentration listed in Table II of Appendix B to 10 CFR Part 20.

Gaseous effluents from all operations associated with the plant, including such nonprocessing areas as labora- The sampling program should be sufficient to permit tories, experimental areas, storage areas, and fuel element a determination of the quantities of radionuclides and assembly areas, should be sampled. the average concentration of rrdionuclides being dis-charged from the plant. The sampling rate at each For gaseous effluents from process confinement release point should be such that a representative sample systems and process areas where material is handled in of the effluent is collected. The volumes of liquid dispersible form, a representatise sample of the effluent effluents should be reported so the NRC staff can from each stack, vent, or other point of release should calculate the quantities of radionuclides discharged.

be collected continually for subsequent determinatiou of quantities and average concentrations of radionuclides released. This sampling should be conducted regardless 2.3 Quality of Samples of the concent rations of radioactis e material in the ef fluent. Provisions should be made to ensure that representa-tive sa mples are obtained by the usc of appropriate Other geeous ef fluent s shauld also be continually sampling equipment, proper locations of sampling points, sampled unleu the bcensee has estabbshed, by periodie and proper procedures for collection and storage of stack samphng or by other means, that radioactivity in sa m ples.

the effluent is insigmficant. In such cases, the effluents should be umpled at least quarterly. If periodie um- Gaseous samples collected at the ume location may phng is used in heu of continual sampling, the licensee be combined for analysis if they represent a sampling should show, as supplemental inform ation, that the period of one week or less. Liquid samples collected at '

sa m ples are representatis e of actual releases. For the the same location may be combined if they represent pur po ses of t his guid e, a gaseous effluent relea se is a sampling period of one month or less. Samples should significant if the concentration averaged over a calendar not be combined if they are from different locations.

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3. ANALYSIS OF SAMPLES 3.2 Lower Limit of Detection '

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3.1 Gaseous and Liquid Samples The lower limit of detection for any analysis should l be not more than 5% of the concentration limits listed l For nuclear fuel processing and fabrication opera- in Table 11 of Appendix B to 10 CFR Part 20. For l mj tions,10 CFR Part 70 requires that gaseous samples be example, the lower limit s of detection for soluble  !

analyzed at least weekly and liq uid samples at least uranium-238 should be not more than 1.5 x 10 d3 i monthly for gross alpha and beta activity. For uranium microcurie per milliliter for air and 2 x 10 4microcurie hexafluoride production (licensed under 10 CFR per milhliter for liquid. '

Part 40), gaseous samples should be analyzed at least weekly and liquid samples at least monthly for gross if the actual concentrations of radionuclides being alpha activity. Liquid samples of effluents from uranium sampled are known to be higher than the lower limits hexafluoride production plant s should be analyzed of detection indicated above, the sampling and analysis periodically for thorium by gross beta activity or some procedures need only he adequate to measure the other method to ensure com pliance w it h 10 CFR actual concentrations. Ilowever, in such cases, the lower Part 20. limit of detection should be low enough to accom-modate fluctuations in the concentrations of the effluent f Radionuclide analyses should be performed on selected samples unless (1) the gross alpha and gross beta activi- An acceptable method for calculating lower limits of ties are so low that individual radionuclides could not detection is described in Appendix A to this guide.

be present in concentrations greater than 107o of the quantities specified in Table II of Appendix B to 10 CFR 4. PRECISION AND ACCURACY OF RESULTS j Part 20 or (2) the radionuclide composition of the sample is known through such operational data as the 4.1 Random Error composition of the feed material.

For each reportcd value, the standard deviation should '

Examples of cases in which operational data may not be calculated for the random error associated with the ,

be adequate for the determination of radionuclide analysis. The calculations should take into account all I composition are (1) plants processing uranium in which significant random uncertainties. The appropriate calcula, I extraction, ammonium diuranate precipitation, ion ex- tions will depend on whether the reported value is change, or other separation processes could result in based on (1) a single count, (2) an average of counts 4 concentration of thorium isotopes (principally thorium-234), (2) plants in which uranium of varying enrichments is processed during the period of consideratior., (3) from several samples, some of which may be below the lower limit of detection, or (3) indirect methods such as calculations based on gross alpha counts.

plants processing plutonium in which significant varia-tion in the plutonium 238/ plutonium-239 ratio among 4.2 Calibration batches of plutonium and the continuous ingrowth of americium 241 would preclude the use of feed material Individual written procedures should be prepared and data in determining the radionuclide composition of used for calibrating all sampling and measuring equip-effluents, and (4) uran um hexafluoride production ment, including ancillary equipment such as air flow plant s in which evaluations based on feed materials measurement instruments. The procedures should ensure show significant changes in the radionuclide ratio (e.g., that the equipment will operate with adequate accuracy uranium, radium, thorium). and stability over the range of its intended use. Calibra-tion procedures may be compilations of published Radionuclide analyses should be made more eften (1) standard practices, manufacturers' insti uctions that at the beginning of the monitoring program until a secompany purchased equipment, or procedures written predictable radionuclide com position of effluents is by the licensee. Calibration procedures should identify established, (2) w henever there is a significant unex- the specific equipment or group of instruments to which plained increase in gross radioactivity, or (3) w henever a the procedures apply. To the extent possible, calibrations process change or other circu m stance might cause a of measuring equipment should be performed by using significant variation in the radionuclide composition. radionuclide sources that have been calibrated by a Reports in which estimates of quantities of individual measurement system traceable to the National Bureau of radionuclider are based on methods other than direct Standards radiation measurements system.

m ea surem ent should include an explanation and justifi-cation of how the result was obtained. The results of Calibrations shoukt generally be performed at regular the analyses of the sa m ples for each release point intervals. The frequency of calibration should be based should be used to determine (1) the total gross alpha on the use and stability of the system. If appropriate, and gross beta activity (as applicable) discharged, (2) the equipment may be calibrated by counting standardized concentration of gross alpha and gross beta radionuclide sources during u se. Systems should be 4 average activity (as applicable) discharged , and (3) the total activity and average concentrations of each of the calibrated more frequently when counting at low radia-tion levels than when counting at levels that are statisti-radionuclides discharged. cally significant from background. Equipment should be 4.16-3

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recalibrated or replaced whenever it is suspected of 6. The percentage of the appropriate concentrations }

being out of adjustment, excessively worn, or otherwise listed in Table' 11 of Appendix H to 10 CFR Part 20.

damaged and not operating properly. Functional tests, i.e., routine checks performed to demonstrate that a The following summary should be included in each given instrument is in working condition, may be per- report:

form ed using sources that are not calibrated by a system traceable to the National Bureau of Standards. 1. For all gaseous releases, the total quantities of gross alpha activity, gross beta activity (if appropriate),

4.3 Quality of Results and each radionuclide, A program should be prepared and implemented for 2. For all liquid releases, the total quantitics of gross ensuring the quality of results and for keeping random alpha activity, gross beta activity (if appropriate), and and systematic uncertainties to a minimum. Regulatory each radionuclide, Guide 4.15, "Quality Assurance for Radiological Moni-toring Programs (Normal Operations)-Effluent Streams 3. For the gaseous sample observed to contain the and the E nvironme n t," provides useful guidance on highest concentration of radioactivity for the semiannual quality assurance. period, the concentrations of gross alpha activity, gross beta activity (if appropriate), and each radionuclide, along Procedures should be established to ensure that the with the percentages of the appropriate concentrations samples are not affected by improper handling or listed in Table 11 of Appendix B to 10 CFR Part 20, storage prior to analysis. For example, liquid samples may have to be chemically treated to prevent losses to 4. For the liquid sample observed to contain the the walls of storage containers, and samples containing highest average concentration of radioactivity for the solids either should be made homogeneous or the liquid semian nual period, trie concentrations of gross alpha and solid portions should be analyzed and reported activity, gross beta activity (if appropriate), and each separately.

radionuclide, along with the percentages of the appro-priate concentrations listed in Table il of Appendix B Tc st s should be applied to analytical processes, to 10 CFR Part 20.

includmg duplicate analyses of selected effluent samples and periodic cross-chcek analyses with independent If the highest concentrations in paragraphs 3 and 4 labora tories.

aie less than 107c of those listed, the summary should indicate that the result was below the stated appropriate Because much of the data to be reported may be value.

based on gross raNoactivity mea =urements, the program should include periodic tests to ensure that such meas-urements represent actual qua ntities of individual 5.2 Error Estimates rad,onuelides in sa m ples. Fcr examp!e, in plants han-dimg uranium, a chemical analysis for uranium should be Reported results should include error estimates. The performed at least quarterly on selected samples for standard deviation representing the random error of the comparison with the gross radioactivity analyses. analysis should be reported for each result. An estimate of the magnit ude of the systematic error should be reported separately. Results reported as below the lower

5. REPORTING RESULTS limit of detection need not include error estimates.

Ilowever, the value of the lower limit of detection 5.1 Sampling and Analysis Results should be included.

All data should be summarized on a semiannual basis. 5.3 Supplemental Information For each release point, the following should be reported, as appropriate (see Appendix B to this guide for illus- The following information should be included in the trative formats):

first effluent monitoring report (subsequent reports should include only changes in this information):

1. Type of sample (gaseous or liquid),

1. Description of sampling equipment,

2. Sampling location,

2. Description of sampling procedures, including sam-

3. Dates during which samples were collected, pling times, frequencies, rates, and volumes,

4. The quantities of gross alpha activity, gross beta 3. Description of analytical procedures, activity, and each radionuclide released,

4. Description of calculational methods, for example,

5. The average concentrations of gross alpha activity, calculation of radionuclide quantities using gross radio-gross beta a c tivit y , and each radionuclide relea sed , activity measurements, 4.16-4 l

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5. Discussion of random and systematic error esti- 5.5 Significant Figures mates, including methods of calculation and sources of systematic error, Results should not be reported with excessive signifi-cant figures so that they appear more precise than they

( 6. Description of the calculation of the lower limit of detection, actually are. The reported estimate of error may contain one significant figure. The reported result should contain the same number of decimal places as the report ed

7. Discussion of the program for ensuring the quality error, of results, 5.6 Format

8. Description of calibration procedures, A sample format is illustrated in Appendix B.

9. Discussion of any unusual releases, including the circumstances of the release and any data available on The term "not detected" or similar terms should not the quar;tities of radionuclides released, be used. Each reported result should be (1) a value and its associated standard deviation or (2) an indication

10. The basis for any determination that a stack or that the result was below the stated value of the lower liquid release point need not be continuously sampled. limit of detection.

D. IMPLEMENTATION 5.4 Units The purpose of this section is to provide information Radionuclide quantities should be reported in curies to applicants and licensees regarding the NRC staff's or multiples of curies as defined in s 20.5 of 10 CFR plans for using this regulatory guide.

Part 20. Radionuclide concentrations should be reported in microcuries per milliliter. Except in those cases in which an applicant or licensee proposes an acceptable alternative method for Standard deviations for random error should be monitoring or reporting radioactivity in effluents, the reported in the same units as the result. Estimates of methods presented in this guide will be used in the systematic error should be reported as a percentage of evaluation of applications and licensee reports after the result. December 1985.

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7 BIBLIOGR APH Y American National Standards institute, Inc., "Guide Cavallo, L. M., et al., "Needs for Radioactivity Stan-to Sam pling Airborne Radioactive Materials in dards and Measurements in Different Fields," Nuclear I Nuclear Facilities," ANSI N13.1-1982, New York, Instruments and Methods, Vol. I12, pp. 5-18,1973.

!982.

Currie, Lloyd A., "Limits for Qualitative Detection American National Standards Institute, Inc., "Speci- and Quantitative Determination," Analytical Chem-

,' fication and Performance of On-site Instrumentation istry, Vol. 40, No. 3, pp. 586-593, March 1968.

for Continuously Monitoring Radioactivity in Efflu-ents," ANSI N42.18-1980, New York,1980. Environmental Protection Agency, "Sampling and Data Reporting Considerations for Airborne Partic-ulate Radioactivity," ORP/LV 76-9,1976.

American Society for Testing and Materials, "Stan-dard Test Method for Particulates Independently or National Council on Radiation Protection and for Particulates and Collected Residue Simultaneously Measurements, "A flandbook of Radioactivity Meas-in Stack G a ses," ASTM D3685 78, Philadelphia, urements Procedures," NCRP Report No. 58, 1979. Washington, DC,1978.

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l APPENDIX A Lower Limit of Detection l

For the purposes of this guide, the lower limit of V is the sample volume (milliliters);

detection (LLD) is defined as the smallest concentration Y is the fractional radiochemical yield of radioactive material sampled that has a 95% probabil- (when applicable);

ity of being detected. (Radioactive material is "detected" A is the radioactive decay constant for if it yields an instrument response that leads the analyst the particular radionuclide; and to conclude that activity above the system background At is the elapsed time between the mid-is present.) point of sample collection and the time of counting.

For a particular measurement system (which may include radiochemical separation): The value of Sb used in the calculation of the LLD for a particular measurement system should be based on 2.71 + 4.66Sb the actual observed variance of the instrument back-LLD = ground counting rate rather than on an unverified 3.7 x 104 EVY exp( A At) theoretically predicted variance.

where Since the LLD is a function of sample, volume, counting efficiency, radiochemical yield, etc., it may vary LLD is the lower limit of detection (micro- for different sampling and analysis procedures. Whenever curies pe milliliter); there is a significant change in the parameters of the Sb is the standard deviation of the instru- measurement system, the LLD should be recalculated.*

mer.t background counting rate (counts per second); _ l 3.7 x 104 is the number of disintegrations per *For a rnore complete discussion of the LLD, see EAfL Proce. i dures Afarusal, H. L. Vokhok and G. dePlanque, editors, U.S. '

second per microcurie; Department of Energy (revised annually); and L. A. Currie,"Lirnits OE is the counting efficiency (counts per for Qualitative Detection and Quantitative Determination- Applica.

" Anatyrw I chemtstry, y L 40, pp. 586 disintegration); 'sN('TaNe'$,#Ns O

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APPENDIX B Example of Format For Reporting Effluent Data' I. CONTINUOUSLY SAMPLED STACKS Fct each release point, report the following information:

a. Reporting period

b. Stack iocation (process or area)

c. Stack flow rate (m3/sec) or total stack flow (m3) (if stack is not in continuous use)

Radioactivit y2 (Ci)

Gross alpha Gross beta Concentration I rror Estimate 3 LLD 4 Quantity Released R.edionuclide l (p Ci/ml) (t p Ci/ml) (p Ci/ml) (Ci)  % MPC U-234

• U-235

& U-238 do i

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I l for instance, sectsons 2.I and 2.2.)Thes table is for illustratkan only and is not a cornplete listing of data to be reported. Supplemental and espi.astory informa:km shoulJ alw be submitted. (See footno This the of radioactivity and radionuchdes is typk.nl for uranium fuel fabrication plants. It is not complete for all licensees, nor will all licensees need to report the radioactivity or radio-nuciales shown. (6 or example, some facensees may need to report natural uranium,inutopes or plutonium, etc., and some licensees may not need to report gross beta activity.)

Istamates of random errors shogdJ he calculated at the 95% confidence enterval. Lgnificant systematic error shou!J te reported,if appropriate,in supplemental informatima.

Cakulatkin of lower limits of detection (LLD) should be shown in supplemental information.

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2. OTIIER SAMPLED STACKS 5 For each release point, report the following information:

a. Date(s) sampled

b. Stack location

c. Stack total flow (m3)

Radioactivity2 4p;)

Gross alpha Gross beta Concentration Lrror Estimate 3 LLD 4 Quantity Released Rad onuclide 2 (p Ci/ml) (! p Ci/ml) (p Ci/ml) (Ci)  % MPC

3. LIQUID SAMPLES For each release point, report the following information:

[ a. Reporting period or date(s) sampled

? b. Location of sample collection

c. Total liquid fk)w

d. 15atch or continuous sample

c. Dilution flow (if not included in total flow) l Radioactivity 2 (Ci) l Gross alpha Gross beta Concentration Error Estimate 3 LLD 4 Quantity Released Radionuclide 2 (p Ci/ml) (t p Ci/ml) (p Ci/ml) (Ci)  % MPC U-234 (dissolved)

U-234 (suspended)

U-235 (dissolved)

U-235 (suspended) i l

U-238 (dissolved)

U-238 (suspended) 5This section is intended to cover stacks or vents not routinely sampled (see Section 2.1). (For example, some stacks of vents may neul to tse sampled periodically to verify that radioactive effluents are insignificant or that the systems are used only intermittently.)

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VALUE/ IMPACT STATEMENT A draft value/ impact was published with the proposed impact statement for the final guide has not been prepared.

Revision I to Regulatory Guide 4.16 (Task CE 401-4) when A copy of the draft value/ impact is available for inspection the draft guide was published for public comment in Sep- and copying for a fee at the Commission's Public Document tember 1984. No changes are necessary, so a separate value/ Room at 171711 Street NW., Washington, DC.

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UNITED STATES ,,ast etass una NUCLEAR REGULATORY COMMISSION '"^*""

WASHINGTON, D.C. 20555 wf.50"o'c psnuit n oo OFFICIAL BUSINES3 PENALTY FOR PRIVATE USE. 5300

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