ML20195G586
| ML20195G586 | |
| Person / Time | |
|---|---|
| Issue date: | 05/25/1988 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Nussbaumer D NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| REF-WM-3 NUDOCS 8806280060 | |
| Download: ML20195G586 (30) | |
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MAY 2 51987 MD/PA/88-079 MEMORANDUM FOR:
Donald A. Nussbaumer Assistant Director for State Agreements Program State, local and Indian Tribe Programs PROM:
Paul H. Lohaus, Branch Chief Operations Branch Division of Low-Level Waste Management and Dec.ommissioning
SUBJECT:
REVIEW 0F PENNSYLVANIA LLW LEGISLATION AND REGULATIONS As requested, we have reviewed Pennsylvania's legislation entitled, "Low-level i
Radioactive Waste Disposal Act" (signed by the Governor on February 9) and the draf t Pennsylvania regulation entitled, "Licensing Requirements for Low-Level-Radioactive Waste Management and Disposal" (working draft, dated February 25, i
1988). We focused cn the three areas Cardelia Maupin identified in her April 28 memorandum to Maxine Dunkelman. The three areas are:
the definition of waste given in the legislation, site suitability criteria regulations, and the recoverability regulation. We also have some additional coments on the regulations.
We have only one coment on the legislation. With respect to your concern with the definition of waste on page 9, lines 8-22, we are unsure if Agreement States can elect to define NARM wastes as low-level wastes. Note that NARM wastes are not defined as low-level waste under LLRWPAA and are not under the preview of the NRC. We suggest that OGC review this definition.
We have several coments on the draf t regulation. We reviewed Pennsylvania's inclusion of recoverability and find no technical problem as the regulation j
states that functioning of the site is of more importance than recoverability.
1 We have two coments on the regulations on site suitability:
(1) The analyses of the performance of a potentially suitable site should include not only a demonstration that the site meets the site suitability requirements but the analyses should also identify and differentiate between the roles performed by the natural disposal site characteristics and design teatures in isolating and segregating the wastes. We recomend that wording such as used in 10 CFR 61.13 be included in Section 236.162(b).
(2) Section 236.169, Subsurface Geology and Hydrology, requires a hydrogeologic setting which is relatively homogeneous and isotropic.
The word "relatively" is ambiguous.
Clearer is the wording for the similar concept in 10 CFR 61.50(a)(2), "The disposal site shall be capable of being characterized, modeled, analyzed and monitored." We recommend that this wording be used.
In any case the term "isotropic" should be dropped so as not to reject modelable sites that are homogenous, but not isotropic.
Isotropic sites are probably extremely rare in Pennsylvania, however there are probably good anisotropic sites available.
I Additional coments on the draft regulations which we wish to be conveyed to Pennsylvania are:
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(1) The last paragraph of the concepts section limits the scope of environmental monitoring to an unacceptable degree. Our draft Technical Position on Environmental Monitoring describes the site specific nature of environmental monitoring programs. Please forward the enclosed draft Technical Position on Environmental Monitoring so that the state can incorporate a more general concept of environmental monitoring and expand the area of consideration to more than that between the disposal units and the site boundary.
(2) The definition for "intruder barrier" as given in Section 236.2 is significantly different from that used in 10 CFR Part 61.
To avoid confusion, Pennsylvania should either use the definition as used in 10 CFR Part 61 or a term other than "intruder barrier."
j (3) Section 236.300 requires that design and construction of a disposal facility to have zero release of radioactive material. A requirement of zero release seems to be unreasonable and not demonstrably attainable.
- Further, Section 236.313 requires that the engineered structure provide leak resistance for a minimum of 100 years following the Post Closure Observation and Maintenance Period. This implies that all leakage after 100 years would be collected and treated, thus not allowing for any end to active institution control period, i
If you have any questions on our coments, contact either Maxine Dunkelman or iry self.
Please incorporate our coments with the coments you are sending to Pennsylvania.
4 M
Paul H. Lohaus, Chief Operations Branch Division of Low-Level Waste Management and Decomissioning
Enclosure:
As stated Record note: RJSttrmer, MYoung, & JKane provided coments.
DIST TION: 4 "'d
- ralFilewlod HMSS r/f LLOB r/f vlanc/
MMDunkelnaa, LLOB SBahadur, LLOB PLohaus, LLOB JSurmeier, LLTB MBell, LLRB JGreeves, LLWM MKnapp, LLWM RBangart, LLWM STreby, 0GC MTokar, LLTB JKane, LLTB AHuffert, LLOB CMaupin, SLITP RJStarmer, LLTB MYoung, LLTB JMcGrath, RI n,. A 6
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NAME:MDunkelman/dtw:SBahadur:PLohaus:JSrmeier DATE: 7//7/88
- 5 //b/88 :S/6/88:)/d/88 0FFICIAL RECORD COPY
b ORAFT FOR COMMENT UNITED STATES NUCLEAR REGULATORY COMMISSION OIVISION OF LOW LEVEL WASTE MANAGEMENT AND DECOMMISSIONING TECHNICAL BRANCH TECHNICAL POSITION PAPER ENVIRONMENTAL MONITORING OF LOW-LEVEL RADI0 ACTIVE WASTE DISPOSAL FACILITIES l
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TABLE OF CONTENTS
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INTRODUCTION...........................................
1 1.1 Background....................
1.2 Purpose and Scope
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2 ENVIRONMENTAL MONITORING PROGR/M OBJECTIVES.......2 2.1 Primary Objective....................................
2.2 2
Supporting Technical Objectives.......................
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ENVIRONMENTAL MONITORING PROGRAM PHASES............
5 3.1 Preoperational Phase........
3.2 Operational Phase....................................
5 3.3 Postoperational Phase................................
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4 PATHWAY AND CONSTITUENT MONITORING.........................
9 4.1 Monitoring Speci fic Pathways...........
4.2 Monitoring Constituent Leve1s...........
9 19 5
OTHER PROGRAM COMPONENTS...................................
22 5.1 Quality Control Program..............................
5.2 Maintenance and Decommissioning of Monitoring Equipment 22 23 6
SUMMARY
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REFERENCES.................................................
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LLW ENVRNMNT MNTR STP/ SEPT 87
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1 INTRODUCTION 1.1 Backgrourd The Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974 give the U.S. Nuclear Regulatory Commission (NRC) tne ec.ponsibility 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 Fsceral Regulations (10 CFR 61).
The NRC is also respansib'e for ensuring compliance with the provisions of the National Environmental Policy Act (NEPA) of 1969.
The licensing requirements related to envircraental protection are in 10 CFR 51.
With passage of the low-Level Radiocctive Waste Policy Amendments Act of 1 Congress improved procedures for the inplementation or interstate compacts, subject to congressional aoproval, for the purpose of establishing and i
operating regional low-level radioactivi waste sites.
The NRC is aware that initial steps have been taken that will lead to the development of new sites' 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 factitties utilizing shallow iand burial.
1.2 purpose and Scope The purpose of this paper is to provide guidance, developed in accordance with 10 CFR 61, to 4pplicants, licensees, and regulatory authorities with respect to the monitaring of low-level waste disposal factitties.
This document presents the Division of low-Level waste Management and Decommissioning (LLWM) Tech Branch staff's opinion on technical requirements for site environmental t
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
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6 facilities.
In addition, establishing guidance on environmental. monitoring fulfills some of NRC's statutory requirements under NEPA.
The basic NRC-rrquirement for near surface low-level radioactive discosal site monitoring is established in 10 CFR 61.53.
The regulation calls for onvironmental monitoring during the preoperatienal, operational, and r
postcperational stages of the facility.
The primary objective of envire, ental l
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 objective as well as related objectives is discussed in this paper.
This paper is not intended to be a handbook on environment;.1 monitoring.Thus, the rewommendations presented are not mandatory, and flexibility in applying this guidance is suggested on a site-by-site basis.
This paper does not present specific accep*.able 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 meritoring prcgram.. This guidance in no way alters the regulations or their implementation as descrfbed in IC 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 caeration.
External gamma radiation monitoring is included as environmentsi monitoring. Monitoring of worker exposure during site operat:ons in accordance with 10 CFR 20 such as dosimetry for personnel and radiation surveys of containers, equipment, materials, and support facilities is not considered envir1nmental monitoring as discussed in this report.
2 ENVIRONMENTAL MONITCRING PROGRAM OBJECTIVES 2.1 Primary Objective 2
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i The prirary 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:
Concentratior!s of radioactive material which may be released to the general environment in ground water, surfa.a 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 tne 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 affluents 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 follow!ng closure so that only surveillance, monitoring, or minor custodial care are required. (10 CFR 61.44) 2.2 Supporting Technical Objectives The requirements pertaining to an environmental monitoring program are described in 10 CFR 61.53, "Environmental Monitoring":
"(a) At the time a Itcense application is submitted, the applicant shall have conducted a preoperational monitoring program to provide basic environmental data on the disposal site characteristics.
The applicant shall obtain information about the ecology, meteorology, climate, hydrology, geology. ;eochemistry, and seismology of the disposal site.
For those character:stics that are subject to seasonal variation, data must cover at least a twelve month period.
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t (b) The licensee must have plans for taking corrective measures if migration of radionuclides would indicate that the perfarmance cbjectives 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.must be made and recorded te provide data to evaluate the potential health and environmental impacts during both the construction and the operation of the facility and to enable the evaluasion of long-term effects and the need for mitigative measures, The monitoring 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 stabilizatien 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 met.
(5)
Detect radiological and nonradiological nonhazar.us releases from waste disposal areas before they reach the site boundaries.
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3 ENVIRONMENTAL MONITORING PRCGRAM PHASES Environmental monitoring consists of three major phases:
precoerational, operational and'postoperational.
Preoperational monitoring occurs during the period prior to li:ense submittal for a minimum of one year. Operational monitoring occurs from the beginning of facility construction through the period when waste,is no longer accepted.
Postoperational monitoring occurs from this point through the long-term care period. While monitorino during each phase is related to the performance objectives in 10 CFR 61, the e?phasis, scope, and intensity of monitoring will yary 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
meteorolegy o
climate o
hydrology o
geology o
geochemistry o
seismology l
To establish an adequate cata 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 should 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
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the ohysical system and to add to the existing data base from which action levels are established. The preoperational monitoring crogram should be developed so that all media sampling devices are operating concurrently during the minimum one5 year period, regardless of whether certa,in devices were operating for site characterization purposes to support site selection.
To tne 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 compered. Furthermore, the monitoring stations should not be I
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 ts being considered.
Discrete sampling is preferred for media that may be af fected by random clin:atological 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 ecnsidered reliable can also be used to establish baseline conditions.
l Action levels 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 regulatory limits for the particular media.
The applicant should, when possible, test for parametric statistical charteteristics so that proposed, statistically-based action levels are meaningful.
For instance, for constituents possessing parametric statistical characteristics, an action level I
might be set at two standard deviations above the ba:kground 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
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i could be the use of a fraction of the concentration Ifmit in Table II of i
Appendix B 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-tu set an action level for gross alpha measurements in grourd Also, the epa maximum c:ntaminant levels (40 CFR 141) for drinking water.
water supplies could be used for nonradiological constituents.
The staff is currently evaluati.ng methods to statistically analyze background data for the j
purpose of setting action levels. Action levels that dictate re. medial 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).
Correc+'ve Action plans At the time of license appitcation, the applicant must present conceptual plans 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
. d 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 with the performancs objectives in Subpart C of 10 CFR 61.
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i 3.2 Operational Phase t
u Operational monitoring should emphasize the measurement of short-term releases of radioactivity in quantities and concentrations that c,ither present an immediate health and safety problem or create the likelihood of a future i
problem.
The staf f anticipates that early in the operational phase of tre i
site, most of the monitoring will be related to direct releases of radioactivity from incoming venicles, waste containers, and handling equip ent that may migrate off-site and impact the environment.
The monitoring program also should emphasize short-term releases caused by failure of the contain ent In addition, any environmental monitoring that may be necessary in system.
t response to accidental releases'from spills, container ruptures, fires, or other unanticipated events should be incorporated into a contingency plan.
i Environmental monitoring that was initiated during the preoperational phase should be continued, on a periodic basis, to determine if background j
j concentrations have been exceeded, i
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 j
hazardous releases.
i A contingency monitoring plan should also exist during the
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postoperational stages in case significant migration or contaminants occurs.
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Initially, postoperational monitoring should continue at locations and frequencies specified during the operational,nhase.
If postoperational monitoring reveals that no significant releases are occurring, sampling 7
frequencies and locations ::vid be reduced. During site closure and early in the post-closure period, 4 will be necessary to monitor representative site media frequently to confirm or modify predictions about site performance made from the ar.alysis of previous monitoring data, These include air samples and surface soil samples.
The sampling frequencies may be reduced for other media if there is no indication of radionuclide releases.
The staf f cons'ders it j
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l inappropriate to estabitsh frequency requirements for long-term postoperational
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monitoring because of the differences in natural site conditions, dispc al technology, and facility performance history.
The applicant must propose a
'i projected long term monitoring program, that is adequate for maintaining surveillance that ensures compliance with the performarc'e objectives and that includes a contingency plan to be implemented in the event of a release.
However, the staff believes that periodic collection and analysin should continue for ground water and surface water, onsite native vegetation I
(particularly deep-rooted specios), and native rodents (particularly burrewing 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 A M CONSTITUENT MONITORING 4.1 gr '
_ Specific pathways Radiological and nonradiological constituents shou,d be monitored in ground 3
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i water, soil, surface water, sediments, air and flora and fauna during the three i
phases of facility operation.
Direct radiation should also be considered in 4
the environmental me.71toring program. Mast 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 migratfor aff site.
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Ground Water
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At disposal sites in humid climates, the primary mecnanism 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 likelf-hood tha. flow rates will be higher and more transient.
Arid sites may have I
very deep, relativaly stagnant flow systems with li ttle seasonal change in water level or quality. Ground water flow may not ce the principal release pathway at arid sites because of the long travsl time for contaminants to reach 9
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the water table (or a confined aquifer) and for the contaminated, groundwater to reach the facility boundary.
Although both the saturated and unsaturated :enes are important in both cases, the monitoring emphasis will depend largely on the O
behavior of the flow system.
For example, at arid sites,the unsaturated zone should be emphasized; whereas at humid sites both the saturated and unsatur zones shoulo be considered.
Precperational ground water monitoring involves the characterization of the rechargo and discharge zones, and the determination of the rate and direction of ground water movement, and the potentiometric and water table elevations ft" 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.
.c Furthermore, tensiometers and/or suction lysimeters should be used so that movement of infiltrate in the unsaturated zone, tne 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 determinea often enough so that seasonal fluctuations are taken into consideration.
When conditions change rapidly, more frequent measurements will be needed.
Conversely, slowly changing systems probably will not require high-frequency sampling to characterize the sys. tem adequately Water samples from the saturated ard unsaturated zones should be collected when possible, cnd 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 conditions during the year.
Unless the applicant demonstrates that historical fluctuations were charactertzed adequately
, NRC staff anticipatt.s that a preoperational time period will be longer than the minimum specified in 'O CFR 61.
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Tha applicant should be capable of definino ve, tical and horizontal gradients throughout the affected saturated and unsaturated zcnes.
These results will be necessary to design an efficient ground-water monitoring system for the c: era-i tional and postoperational phases.
Furthermore, these data will enhance the understanding of the hydrogeologic system at the site.
The applicant should samole, when possible, nearby residential, municipal, and industrial wells.
The NRC staff notes that adequate well completion data for these wells are important to ensure knowledge of the monitored strata.
These wells should also be included in the ground water monitoring plan and sampled Ground-water monitoring facilities developed during 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 that information gathered during the operational phase builds upon the information gathered l
during the preo;erational phase.
l Emphasis should be placed on short-ter releases caused by spills and other unanticipated events.
However, as disposal units become full and are closed, the NRC staff expects the emphasis to shift i
from short-term releases to longer-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 off site (10 CFR 61.53(c)). Detection of a release should result in more thorough monitoring to assess environmental significance according to a corrective action plan outlined in the license application.
Monitoring-locations should be maintained to the extent practicable so that data collection is as compatible with that collected during the preoperational phase as possible.
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The emphasis during postoperational ground water monitoring (enc,ompassing closure, the period after closure, and long-term care) should be placed on the detection of long-term releases caused by the gradual failure of d'spcsal units or other unanttcipated events, such as damaging weather condition. or inadvertent intrusion.
As in operational monitoring, the applicant must increase the scope of the monitoring plan to assess the environ.? ental impacts of possible contarpinant releases, and if necessary, perform mitigative actions.
However, if pcstoperational 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 ;mportant aspect of the
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postoperational phase because it provides for eventual decreased monitorinn during the long-term care period.
For example, if monthly ground-water sampling at a humid disposal site indicates that there 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 epamples, 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 performed 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 unalysis costs can be prahibitive if the soil depth is very great. The applicant, therefore, should sample material that is reasonably expected to become a migration pathway.
Naturally occurring radioactivity should be analyzad in addition to those chemical constituents that might affect site performance, for example, complexing agents present in 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 LW ENVRNMNT MNTR BTP/ SEPT 87
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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 should continue through closure.
Ouring the postclosure period, soil sampling should include areas near the disposal units or. cells -- far enough away, however, to ensure that the integrity of the disposal unit is not compecnised - as well as onsite 2 eas remote from buried waste and in the buf fer zone.
The number of samples and frequency of sampling may ve gradually decreased during the postclosure period if laboratory results indicate no significant releases have occurred.
The staf f anticipates that soil sampling will eventually be performed in response to an unanticipated event 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 aad Sediments o
Because of siting requirements in 10 CFR 61, perennial surface water is not anticipated within the boundaries of the low-level radioactive waste disposal facility.
However, it is important that nearby offsite surface water be monitored fer two reasons:
(1) the monitoring could indicate surface 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 incluced in the monitoring program.
During the preoperational omase, surface-rater sampling locations should be selected upgradient of, adjacent 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 caring subsequent monitoring phases.
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i Sampling of,,erennial surface water sources near the site sheuld,be representc-tive of the flow reg.ne. Therefore, flow measurement should ce part of the monitorir. program.
Efforts should be made to sample ephemeral water courses during runoff periods and to correlate the results with,the results relatea to perennial water courses.
Samples should be analyzed for the same radiological and nonradio ogical constituents as those that are included in ground water sample analyset.
During the operational monitoring plan, sampi a should be taken following extreme hydrologic events that result in,large amounts of surface runoff frcm 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 tamporary storage areas should be included in the monitoring program Snowmelt and large precipitation events that cause abnormal surface flows, temporary ponding, spillovers and other such unanticipated events should prompt special q
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 monitoring 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, sediment 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.
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d Meteorology and Air Quality o
A meteorological monitoring program should be established as part of the itte characterization process, and should continue throughout, the operational and postoperational stages. Site-specific meteorological data should be collected for a minimum period of 1 year during the preoperational environmental monitoring period, unless the applicant can demonstrate that data from other meteorological stations represent conditions on site.
- :ese data may include precipitation, temperature, wind speed and direction, etc.
The applicant must demonstrate that the seasonal variations noted in the characterization period represent historical conditions.
Thus, comparisons with past records should be made.
Ir 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 cond' as.
Along with surface temperature records, measurements of additional meteo cal parameters are needed to determine the water budget for the waste disposa 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.
Evapotranspiration, which can account for the largest component of outflow of precipitation, should be estimated using soil moisture measurements, pan evaporation, and meteorologicsl conditions.
The fraction of precipitatior in the farm of snow and rainfall should be me,atured.
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 on evaporation rates.
Additional supporting data for quantifying evaporative processes may be. derived from measurements of temperature within the soil, solar radiation (insolatio soil moisture, matric potential, wind speed, and relative humidity or dew point.
15 LLW ENVRNMNT MNTR BTP/ SEPT 87
4 NRC has no authority to enforce against noncompliance with air emmission standards.
However, the license will most likely 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 nitroger), sulfur dioxide, hydrocarbons, photochemical oxidants, and suspended particulates.
Ambient levels constitute part of the data base for the disposal site.
Potential sources of nonradiological pol!utants 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 operations, and gaseous emar.ations from the decomposition of organic waste products.
During the preoperational phase, et 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 be 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 cnanges. A composite gamea scan should be performed at least quarterly, Air samplers should continue to be used during the site operational phase, although they may be repositioned depending on the analysis of climatologica data.
During normal operations, air sampling should be performed regularly, i
Nonroutine occurrences such as onsite accidents or extreme climatological events may mandate more rigorous sampling and analyses.
During closure activities, air sampling should continue as during site opera-I 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 peric,I, at least one 16 LLW ENVRNMNT MNTR BTP/ SEPT 87
s continuous air samp;er should se maintained near the site boundar,y downw ad of the most prevalent wind direction.
Filters should be monitored for gross alpha and beta activity.
If the activity is high, the filters should be collected more frequently, and a composite gamma scan should be performed.
Annual isotopic 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 mcy be potential pathways' for numan exposure.
Also, the presence of certain species at or near a waste site may affect the ability of the site to contain the waste.
Therefore, because knowledge of preoperational ecological conditions are necessary to evaluate potential impacts caused by releases, monitoring of flora and fauna at or near the site should be a component of the monitoring prcgram.
The purpose of an ecological monitoring program is to verify that,in the case of non-compliance with relecse criteria, the populations in the floral and faunal communities that nave been identified as pathways to man have not been affected in such a way that public health and safety are threatened. The preoperational monitoring program should identify those aspects of the ecological community that are "important" from the health and safety standpoint.
Thus, for the purposes of this 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 radio cgical 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 contaminated by migrating waste.
Sampling should include all major species of vegetation 17 LLW ENVRNMNT MNTR BTP/ SEPT 87
j 3
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 gamma activity and tritium.
An adequate number of samples should be collected and analyzed so that baseline conditions are established.
However, to distinguish 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 The operational phase monitoring program should be expanded later to year.
include deep-rooted vegetation.
Leaves from representative deep-rooted species should be sampled annually 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 concentrations established during the preoperational phase should undergo a complete isotopic analysis.
Ouring 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 re ults.
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
.adiological transport.
From this list, the important species should be ide.'tified and tnelr 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 Iccal livestock, dairy products, and game species should be taken and anal f:ed quarterly during the preoperational survey.
Analyses should include paa scans of sample portions known to accumulate contaminants.
These samples can provide the basis for determination of environmental impacts and information on base level in potential vectors to man in the case of accidental release.
18 LLW ENVRNMNT MNTR BTP/ SEPT 87
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/
Care should be taken to properly account for seasonal or other differences in the abundonce of such species.
The inventory 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 frcm the appropriate agency.
If an accident occurs, the appifcant 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 constituent types:
(1) Detection of direct gamma radiation.
(2)
Detection of rcdiological and nonradiological nonnatardous constituents released to the environment from the facility or elsewhere.
Direct Gamma Radiation 1
During the preoperational phase, continuous measurements of direct gamma 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 existing buildings.
During the operational phase, munitoring 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 BTP/ SEPT 87
A e
D 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.
Direct gamma radiation surveys should be conducted before the license, is terminated or transferred and af ter major site disturbances such as trench subsidence or disruptive climatological events.
Radiological and Nonradiological Constituent:
The primary technical objective of a monitoring program at a low-level radio-active waste disposal facility is to monitor radiological and norradiological 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.
(C)
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 constituen's for which background levels will be determined.
Seasonal and climatological variations must be considered.
During the operational phase, important rad;o-logical conscituents in the waste form should be identified, and their signif t-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 wasta 20 LLW ENVRNMNT MNTR BTP/ SEPT 87
M 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 analyzed for gross alpha activity, gross beta activity aid tritium in s.ater and vegetation.
Gamma ray spectrometry should be performed to characterize the principal gamma-emitting radionuclides present.
Nonradiological nonhazardous constituents in ground water should be monitored at a low-level radioactive waste disposal facility for three reasons.
- First, certain inorganic and organic species occurring naturally or introduced by waste emplacement, such as decontaminating agents, can form chemical complexes with radionuclides, potentially increasing radionuclide mobility.Studies have shown that some organo-radionuclide complexes may pe sist and increase radionuclide mobility over significant distances.
It is necessary to understand what radionuclide complexes are being formed under the disposal site's geochemical conditions so that their migration behavior may be monitored.
Second, the no.iraciological constituents may themselves cause environmental 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 appropriate to note that 10 CFR 61.56(a)(8) requires treatment to the extent possible of nonradiological hazardous constit'uents to limit potential health effects.
However, the staff considers it prudent to monitor for indicators of nonradiological hazardous releases for the above reasons Ouring 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 cuncentrations sr.ould be determined.
It is recognized, however, that monitoring every chemical parameter in every media that could potenti mobilize radioactive material or abet radionuclide migration is impracticable ally Therefore, a program for screoning representative indicators of chemical constituents in the waste form should be developad that is based on the ability of the constituentr. to form chemical complexes.
Those constituents identified 21 LLW ENVRNMNT MNTR BTP/ SEPT 87 l
as significant in the preoperational and operational phases and in the waste form, respectively, should be monitored.
5 OTHER PROGRAM COMPONENTS I
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 Centrol program to be applied to the determination of natural oisposal 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 measurin and test equipment; sample handling, preservation, storage and shipping; chain-of-custody procedures; performance specifications for all sampling equipment; calibration procedures; field checks; and the use of spiked, split, and blank samples.
A precedures aucit 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 Monitoring Equipment Monitoring equipment should be maintained in operating order during its useful life.
Manuf.act.urers' recommendations for cleaning, refurbishing, and calibrating equipment should be followed.
Monitoring facilities and equicment should be protected from damage from other site operations.
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 facilities 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 penetrate the site surface shguld 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 j
infiltration along its external interface with surrounding soil, or preferably cut off below the site surface, capped, and backf:lled to natural grade.
Plans for doing this, along with a technical basis, should be develaped at the time the system is designed.
Sealing activities shculd be compatible with applicable State requirements.
Complete decommissioning of monitoring facilities should be considered only when the facility is prcducing false or misleading data or no data at all.
Replaced facilities that are capable of yielding usable data should be retained as backup facilities in case of failure 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
=
9 6
SUMMARY
Components of an environmental monitoring program are described in 10 CFR 61.53.
The pur. pose of this docunent 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 compliarce with the performance objectives in 10 CFR 61.41 and 61.44 Supporting technical objectives of the program are to characteriza 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 monitorino consists of three major phases:
preoperational, operational, and postoperational. During the preoperational phase, a back-ground data base is compiled for radioactive and nonradiological constituents, appropriate action levelr. are determined, and remedial action olans 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
.i detection of direct gamma radiation and detection of radiological and non-i radiological constituents.
Direct gamma radiation surveys should be conducted regularly during 111 three phases of the programs; or in special cases, such as before the license is terminated or transferred and after major site disturbances, Radiological and nonradiological constituents should be sampled and analyzed periodically, and when migration is suspected, at a g* eater
{
frequency and more comprehensively.
Specific pathways to be monitored during the three phases of facility operation are ground water, soil, surface water 1
l (including site runoff), sediments, air, and flora and fauna.
Important radiological and chemical indicators include tritium, gross alpha activity, gross beta activiti, pH, total dissolved solids, total organic carbon, or other indicators expected to be in the v:aste stream.
In addition, supplemental data 24 LLW ENVRNMNT MNTR BTP/ SEPT 87
r e
on site-specific release mechanisms should be compiled which relate to ecology, meteorology, climate hydrology, geology, geochemistry, and seismology.
A quality coatrol program should be developed and implemented to ensure the accuracy of all monitoring techniques and analyses.
Important components include maintenance and verification of monitoring equipment, documentation or 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 t ensure accuracy in data collection and to allow facility performance without disruption.
Equipment should br cleaned, refurbished, and calibrated according to the manufacturers' specifications.
Instruments should be protected from natural and hu;.1an intrusion during the active life of the monitoring program.
When cenponents 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 cf Environment," U.S. Government printing Office, Washington, DC, revised annually.
U.S. DepartLent 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.
25 LLW ENVRNMNT MNTR BTP/ SEPT 87
o a
l U.S. Nuclear Regulatory Commission, NUREG/CR-1759, "Data Bas Waste Management,"
or Radioactive Vol.1, Washington, DC, Ncvember 1981.
--, NUREG/CR-4352, "Suggested State Requirements and Criteria Radioactive Waste-&f sposal Facility," Washington, CC ow-Level August 1985.
--, Regulatory Guide 4.15, "Quality Assurance for Radiological Mo it Programs (Normal Opera'tfons) - Effluent Streams and the Envi n oring Washington, DC.
ronment,"
i i
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