ML20245H504
| ML20245H504 | |
| Person / Time | |
|---|---|
| Issue date: | 04/27/1989 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20245H485 | List: |
| References | |
| REF-WM-3 NUDOCS 8905030418 | |
| Download: ML20245H504 (37) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION DIVISION OF LOW LEVEL WASTE MANAGEMENT AND DECOMMISSIONING TECHNICAL BRANCH TECHNICAL POSITION PAPER ENVIRONMENTAL MONITORING OF LOW-LEVEL RADI0 ACTIVE WASTE DISPOSAL FACILITIES
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l 4 TABl.E OF CONTENTS Page 1 INTRODUCTION.................... 4
............................... 1 1.1 Background.................................................. 1 1.2 Purpose and Scope........................................... 2 2
ENVIRONMENTAL MONITORING PROGRAM OBJECTIVES...................... 4 2.1 Regul ato ry Requi rements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
- 2. 2 Environmental Monitoring Program Phases..................... 5 2.3 0bjectives of Environmental Monitoring Program.............. 5 3
GENERAL GUIDANCE ON PREOPERATIONAL ENVIRONMENTAL MONITORING...... 7 3.1 Program 0bjectives.......................................... 7 3.2 Environmental Factors and Parameters........................ 8 4 GENERAL GUIDANCE ON OPERATIONAL ENVIRONMENTAL MONITORING......... 15 4.1 ProgramObjectives.......................................... 15 4.2 Considerations in the Design of an Operational Environmental Monitoring Program.......................... 15 4.3 Measurements of Parameters in the Environment............... 18 5 GENERAL GUIDANCE ON POSTOPERATIONAL ENVIRONMENTAL MONITORING..... 22 5.1 Program Objectives............................................. 22 5.2 Physical Survei11ance....................................... 22 5.3 Environmental Sampling Media................................ 22 6 REFERENCES....................................................... 24 APPENDIX A - Suggested Preoperational Environmental Sampling Program Covering an Arid and a Humid Site........... A-1 APPENDIX B - Suggested Operational Environmental Sampling Program Covering an Arid and a Humid Site........... B-1 i
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- 1. INTRODUCTION
1.1 Background
The Atomic' Energy Act of 1954 and the Energy Reorganization Act of 1974 give the U.S. Nuclear Regulatory Commission (NRC) the responsibility for licensing and regulating commercial nuclear facilities. The licensing requirements for near-surface disposal of low-level radioactive wastes (LLW) are in Part 61 of Title 10 of the. Code of Federal Regulations (10 CFR 61). NRC is also respon-sible 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 Part 51.
With passage of the Low-Level Radioactive Waste Policy Amendments Act of 1985, Congress improved procedures for the implementation of interstate Compacts, sub-ject to Congressional approval, for the purpose of establishing and operating Regional low-level radioactive waste sites. Initial steps have been taken by States that will lead to the development of new sites for LLW disposal. To pro-vide timely assistance in this process, NRC is issuing this Technical Position on environmental monitoring programs for near-surface LLW disposal facilities.
The environmental monitoring program required in 10 CFR Section 61.53 has to be submitted as ; art of a license application, along with the Environmental Report (ER),.raquired in 10 CFR Part 51.
On November 5, 1987, NRC announced in the Federal Register (52 FR 42486) the ,
availability of a draft Branch Technical Position (BTP) on " Environmental Moni-toring of Low-Level Radioactive Waste Disposal Facilities" and requested public comments. Thirteen organizations / agencies and several individuals commented on the draft BTP. Subsequently, NRC's Advisory Committee on Nucler Waste (ACNW) also commented on the draft BTP. This final BTP has been revised, taking into consideration the comments.
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- 1. 2 Purpose and Scope The basic NRC requirement for near surface LLW disposal site monitoring is in 10 CFR Section 61.53. The regulation calls for environmental monitoring during the preoperational, operational, and postoperational stages of the facility. The primary objective of environmental monitoring is to provide assurance that the performance objectives in 10 CFR Part 61 are met. The staff's interpretation of this basic objective, as well as of related objectives, i is discussed in this paper.
The purpose of this paper is to provide general guidance, developed in accord-ance with 10 CFR Part 61, to applicants, their consultants and regulatory authorities (NRC. Agreement States) on monitoring low-level waste disposal facilities. This paper is not intended to be a handbook of detailed or manda-tory procedures. It must be stressed that an environmental monitoring program for a low-level waste disposal facility must be tailored to the detailed moni-toring needs dictated by the site-specific operating and environmental con-ditions. Because each site is unique as regards topography, meteorology, demography, geohydrology, etc., only general guidance can be given. In the design of an environmental monitoring program, there is no substitute for good professional judgement combined with a thorough knowledge of the local environ-ment (ICRP 43, 1984). Thus the guidance presented herein is not mandatory, and flexibility in applying this guidance is suggested, on a site-by-site basis.
Although only general guidance can be given in this paper, it provides insight into the opinions and expectations of NRC staff for the acceptance review of the applicant's environmental monitoring program.
In this paper, the staff will define the objectives in the three phases of an r environmental monitoring program. These objectives constitute an acceptable basis for use in establishing an environmental monitoring program. General guidance is then provided for the applicant in the design of the monitoring program to meet these objectives. The staff also provides literature references for more details on the planning, design and implementation of an environmental monitoring program relevant to the operation of an LLW disposal facility.
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Early in the development of an LLW disposal facility, the applicant is encouraged to meet with NRC staff and discuss in specific detail the design of an appropriate environmental monitoring program suitable for a particular site. This is especially important during the preoperational phase, which covers a rather broad J'
scope of monitoring requirements, as defined in 10 CFR Subsection 61.53(a). This may help in avoiding any major deficiencies, during its review, and that licensing I action would not be delayed.
1 For the purpose of this paper, an environmental monitoring program consists of the collection of samples, and the measurement of radioactive concentrations or direct radiation, chemical concentrations, and other physical properties of specific media in the environs of a low-level radioactive waste disposal site, during all phases of facility operation. The scope of the monitoring program here is broader than those for other existing nuclear facilities that essen-tially consider only the measurement of radiological components in the environ-ment. The regulations in 10 CFR Section 61.53 require a broad range or moni-toring, covering the three phases of operation for a new low-level radioactive waste disposal site. Nonradiological and physical parameters are included in the monitoring, because they serve as indicators for waste migration and site characterization; however, their compliance with environmental standards are subject to the regulations of the State or the U.S. Environmental Protection Agency (EPA). i Monitoring of worker exposure during site operations, in accordance with 10 CFR Part 20- such as dosimetry for personnel and radiation surveys of containers, equipment, materials, and support facilities--is not included as environmental monitoring in this paper. Effluent monitoring of plant operations (e.g.,
releases from stacks through waste-handling or incineration, liquid effluent point of discharge from treatment of leachate) is not covered in this paper, either. Generally, worker exposure and effluent monitoring will be required in the applicant's safety analysis report (SAR), to demonstrate compliance with l the requirements of 10 CFR Subsection 61.12(k). Also, the monitoring of acci- I dental releases is not included here, since, in emergency situations involving !
sudden major radioactive releases, as a result of such events as criticality '
and fire, a special surveillance effort beyond the routine monitoring program !
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- 2. ENVIRONMENTAL MONITORING PROGRAM OBJECTIVES 2.1 Regulatory Requirements The requirements pertaining to an environmental monitoring program are described in 10 CFR Section 61.53, " Environmental Monitoring":
"(a) At the time a license application is submitted, the applicant shall have conducted a preoperational monitoring program to provide basic envi-ronmental data on the disposal site characteristics. The applicant shall obtain information about the ecology, meteorology, climate, hydrology, geo-logy, geochemistry, and seismology of the disposal site. For those charac-teristics that cre subject to seasonal variation, data must cover at least a twelve month period.
(b) The licensee must have plans for taking corrective measures :'
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, l the licensee shall maintain a monitoring program. Measurements and observations must 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 monitoring system must be capable of providing early warning of releases of radionuclides
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from the disposal site, before hey leave the site boundary. l 1
(d) After the disposal site is closed, the licensee responsible for postoperational surveillance of the disposal site shall maintain a moni- J t
toring system based on the operating history and the closure and stabili- l zation of the disposal site. The monitoring system must be capable of I providing early warning of releases of radionuclides from the disposal site before they leave the site boundary." )
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- 2. 2 Environmental Monitoring Program Phases Environmental monitoring consists of three major phases: preoperational, operational and postoperational. Preoperational monitoring occurs during the period before license application and could continue during the license reviewing period. Operational monitoring occurs from the beginning of facility construction through the period when waste is no longer accepted and the facility is closed. Postoperational monitoring occurs from this point through the long-term care period. Althaugh monitoring during each phase is related to the performance objectives in ;.0 CFR Part 61, the emphasis, scope and intensity of monitoring will vary from pnase 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 previous and subsequent phases.
2.3 Objectives of Environmental Monitoring Program The principal objectives of the three phases of an environmental monitoring program for a low-level radioactive waste disposal facility are as follows:
Objectives for Preoperational Monitoring
- 1. Provide site characterization information.
- 2. Demonstrate site suitability and acceptability.
- 3. Obtain background or baseline data. !
Objectives for Operational Monitoring
- 1. Demonstrate compliance with applicable environmental radiation standards.
- 2. Obtain data on critical pathway parameters to allow more accurate evaluation of radiation dose to the general public.
- 3. Provide records for public information.
Objectives for Postoperational Monitoring
- 1. Demonstrate compliance with site-closure requirements.
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- 2. Provide data to support long-term impact evaluation, such as long-term impact on groundwater.
- 3. Provide records for site closure and for public information.
The following chapters provide general guidance on establishing and implementing an environmental monitoring program and meeting the objectives of the three phases of monitoring, as just described. The guidance is intended for use by applicant managers or their consultants in developing environmental monitoring program. Before the development of the environmental monitoring program, the applicant is encouraged to meet and discuss with the NRC staff for further details.
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- 3. GENERAL GUIDANCE ON PREOPERATIONAL ENVIRONMENTAL MONITORING The preoperational environmental monitoring program, including site characterize-tion of a LLW disposal facility, covers a broad scope of observations and measurements. The program is comprehensive and site-specific, because each site will vary, depending on the physical characteristics of the site, proposed facility design, and the site environs. The following sections provide general I guidance on !.he design of a preoperational environmental monitoring program.
The guidance provides the specific areas that need to be covered but is non-prescriptive. Details on methods and frequency of sampling and location of sampling will vary among specific sites, because of the variation of environ-mental factors such as geology, hydrology, climate (arid and humid sites), land use, water use, and local population. The applicant should refer to the follow-ing documents for discussions of more detailed design and implementation of a preoperational program: I A. NUREG-090~2 - Branch Technical Position, LLW Licensing Branch - Site Suitability Selection and Characterization (NRC-1982).
B. Site Characterization Handbook (00E, 1988).
C. Low-Level Radioactive Waste Management Handbook Series, " Environmental Monitoring for Low-Level Waste-Disposal Sites" (D0E,1989).
D. " Recommendations to the NRC for Review Criteria for Alternative Methods of Low-Level Radioactive Waste Disposal Environmental Monitoring and Surveillance Programs" (NRC, 1988).
E. " Technology, Safety and Costs of Decommissioning a Refrence Low-Level Waste Burial Ground-Environmental Surveillance Program" (NRC, 1981).
3.1 Program Objectives I
The primary purpose of the preoperational program is to characterize the I environment before any waste-handling operations are begun. This program consists principally of collecting monitoring data to evaluate the geological, hydrogeological, climatological, ecological, radiological, and 7
nonradioactive pollutant environments of the site and the surrounding area. The site characterization is to demonstrate its acceptability and suitability as an LLW disposal site, compared with other alternative sites in the applicant's site-selection process. In the preoperational phase, environmental media are sampled and analyzed to provide background or baseline data to characterize the site environment. Some of the environmental sampling media can be used as indicators for long-term impact assessment. The choice of types of media and level of sampling depend on the critical pathways, which are generally site specific.
For those characteristics for which continuous measurements are required (e.g.,
windspeed, wind directinn, and atmospheric stability; subsurface water levels and contaminants; and radionuclides concentrations in air that may be subject to seasona changes), the program should be conducted for a minimum of one year (i.e., 12 consecutive months) and preferably should continue during NRC's license reviewing period (approximately 12 to 15 months). During the initial review of the license application, the NRC staff will work closely with the applicant to identify any additional preoper8tional monitoring needed, so that the applicant can still take action during the review process. However, as discussed above, the applicant is encouraged to discuss the preoperational program with the NRC staff before the initiation of the program, in order to avoid major deficiencies which otherwise might be identified later. The following section describes the environmental factors or parameters that need to be covered in a preoperational monitoring program, 3.2 Environmental Factors and Parameters 3.2.1 Meteorology and Climate Meteorological data are needed, during the preoperational u age: to provide baseline information on meteorologic conditions; to determine the site's water budget: to evaluate the impact from airborne release; to obtain information on the frequency probability of severe meteorological events; and to provide base-line air quality. The significant parameters specific to meteorology are:
onsite windspeed, wind direction and atmospheric stability joint frequencies; atmospheric pressure; precipitation; temperature; evaporation; solar radiation; severe weather; and concentration of contaminants in air.
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Most of the aforementioned data and other meterological.information, such as humidity, snow depth, and inversion height can be obtained from the nearby weather station, which has similar climatological patterns for the site. If there is no nearby weather station, the key parameters measured onsite are the joint windspeed, wind direction and atmospheric stability data and precipita-tion-~and evaporation-rate data. Initial onsite measurements of these parameters, for a period of at'least 12 consecutive months, or preferably, 24 consecutive months, are necessary. The program should be continued during the operational phase.
The background radiologic and nonradiologic air quality data should be measured for a period of at least 12 consecutive months, or, preferably, 24 consecutive inths, to account for seasonal variation. The locations of air sampling sta-tions, depending on the availability of power supply, should be at some of the strategic areas, such as upwind, downwind, area of maximum impact, nearest resi-dential area, and fenceline. These stations can also be used during the opera-tional phase. For more detailed planning, (for background air quality measure-ment), on sampling frequency, sample size, nonradiological and radiological para-I meters, and sample number in areas covering arid and humid sites, the licensee '
should review references in Section 3 to aid in developing an appropriate pro-gram tailored to the needs of site specific operating activities and environ-mental' conditions. An example of a suggested preoperational enviro'nmental sampling program on background radiological measurements covering an arid and a humid site is shown in Appendix A (DOE 1989 ).
3.2.2 Hydrology
< l 3.2.2.1 Ground Water Hydrology Groundwater data are needed to provide evidence for site suitability evaluation and to demonstrate that the site is hydrologically simple, that the site can provide sufficient depth to the water table so that ground-water intrusion into the waste is unlikely or, if disposal is below the water table is proposed, molecular diffusion must be the predominant means of radionuclides movement and the ground water pathway impact can be modeled and will meet performance objectives (NRC 1982).
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At disposal sites in humid climates, the primary mechanism for radionuclides migration will most likely 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 likeli-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 j
at arid sites, because of the long travel time for contaminants to reach the I 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 zone should be emphasized. 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 LLW 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. The movement of infiltrate in the unsaturated zone, the potential for deep percolation, and interactions of the unsaturated zone with saturated strata should be evaluated and used in design of the monitoring network.
Water levels and capillary potentials for the saturated and unsaturated zone, respectively, should be determined often enough so that seasonal fluctuations are taken into consideration.
Water samples from the saturated and unsaturated zones should be collected, when possible, and analyzed for radiological, and selected nonradiological, consti- !
tuents, so that the water chemistry can be assessed. 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. The applicant should define vertical and horizontal gradients throughout the affected saturated and unsaturated zones and use the information to design ground-water monitoring sys-tem for the operational and post operational phases. Furthermore, these data will enhance the understanding of the hydrogeologic system at the site.
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4 The applicant should sample, when possible, nearby residential, municipal, and industrial wells. The duration of pr. operational sampling shall be at least for a period of 12 consecutive months, preferably extended to 24 consecutive months.
3.2.2.2 Surface Water Hydrology Surface water. data are needed during the preoperational phase to verify that:
the site will be generally well-drained and free of areas of flooding or fre-quent ponding; upstream drainage areas-will be minimized to decrease the amount of runoff that could erode or inundate the site; the surface water pathway analysis meets performance objectives; and baseline data on water quality are provided (NRC, 1982). This compilation will include data on water users, historic floods, and droughts, rainfall, and snowfall records.
Field measurements will include runoff, infiltration rates, erosion rates, surface-water flow rates, and water quality on radiological and nonradiological components. In addition, sediment samples from a representative cross section of nearby surface water courses should be taken and analyzed.
3.2.3 Geology and Seismology Information on geology is needed to characterize the site to demonstrate that the natural processes affecting the site occur at consistent and definable rates, and that the site will be geomorphically and tectonically stable for a period of 500 years (NRC, 1982). The information includes geomorphology,
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stratigraphy, lithology, tectonics, structure, seismology and geologic hazards. ;
I Most of this information can be obtained from organizations such as the U.S. ;
Geological Survey.
Preoperational measurements consist of surface and trench geologic mapping and sampling, borehole logging, and sampling and analysis.
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[ t 3.2.4 Geochemistry and Hydrochemistry Geochemistry and. hydrochemistry information are needed to provide background chemistry data, to permit monitoring of key indicators of water quality and leachate migration, and to identify parameters that may affect transport of the waste leachates to the environment. Preoperational monitoring includes measurements of water quality, ion-exchange capacity, organic content, Eh pH, distribution coefficient, isotope content, performance of laboratory simulations of field conditions, and field tracer tests, if necessary.
3.2.5 Ecology Information on ecology is needed to define the baseline terrestrial and aquatic characteristics of the site, to support environmental impact assessments and mitigation planning. Important concerns include abundance of characteristics of species, importance of the species, and seasonal and migration patterns.
Ecological information includes terrestrial fauna species, terrestrial flora species, aquatic species, livestock, food chain, migratory species, game animals, habitat, and threatened and endangered species. Most of this information can be obtained from organizations such as the U.S. Fish and Wildlife Service.
A preoperational program includes surveying the site vicinity for major vegetation types and commercially or recreationally important vertebrate species.
Sampling should be conducted for a minimum period of 12 consecutive months, to determine seasonal variation of species. Site reconnaissance surveys (including aerial photography) can be used to confirm information obtained from existing sources, to determine species and habitat conditions., and to select sites and techniques for more intensive investigation, as necessary.
3.2.6 Demography Demographic data on geographic distributions and sizes of both existing and projected human populations, with designated distances of up to a 50-mile radius of the site, are needed. This information will be used to analyze the potential health impact from facility operation. The information includes population 12
- < r centers, population density, local residence distribution, transient population, and projected population. Most of the information can be obtained from the U.S.
Bureau of Census or the State or local government records.
A preoperational survey includes measuring or estimating distances and directions, regarding local residents' distribution, around the site, to evaluate the area of maximum impact from facility operation. This should include nearby schools and hospitals.
3.2.7 Background Radiation Characteristics Background radiological data are needed to establish baseline data on radiological characterization of the site. These data will be used as indicators to evaluate facility operation impact, decommissioning, and site closure, and they may be used as references in setting action levels.
Preoperational monitoring includes measurements of direct gamma radiation, airborne radionuclides, soil, sediment, surface water, ground water, flora, fauna, and food. At least one year (12 consecutive mont.s) of preoperational data should be submitted in the applicant's license application. Most of these measurements may have to be continued during the operational phase.
(See suggested program in Appendix A.)
3.2.8 Land Use Land-use data in the vicinity of the site are needed to evaluate the impacts of the plant operation on existing and potential surrounding land uses. Informa-tion includes residential, industrial, agricultural, and recreational land use, special areas, zoning restrictions, local land-use plans, farm 1cnd-use classi-fication, and utility land uses. This information generally can be obtained from f.e State and local government and the U.S. Geological Survey. The land-use infor-mation should include location of cultural resources at the vicinity of the site.
The identification of buildings, structures, or objects of historical, archeo-logical, architectural, scenic, cultural, or landmark significance in the vicinity l
of the site is required before disposal facility construction. l 13
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Preoperational monitoring may include field reconnaissance, and limited surface testing on archeological finds, if necessary. The applicant should consult the State Historic Preservation Officer in all data-collection activities, to ensure compliance with standards and procedures, i
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- 4. GE'4ERAL GUIDANCE ON OPERATIONAL ENVIRONMENTAL MONITORING
~ 4.1 Program Objectives The principal purposes of the operational environmental program are to monitor site performance and to demonstrate compliance with applicable standards.
During the construction phase of an LLW disposal facility, the environmental-monitoring measures non-radiological impacts of facility construction on the environment, because no radioactive materials are disposed of at the site yet.
Most'of the environmental concerns are from release of airborne dust as a result of earth work; enhanced soil; erosion caused by disturbance of the site and traffic; and noise impact. The monitoring of these effects is subject to the regulation and compliance requirements of the State or EPA. During routine operation, minute quantities of radioactivity and chemical effluent may be released from the site.
The radiological releases are subject to the regulathns and compliance requirements of NRC. Non-radiological' chemicals in air and ground water are rormally regulated by the State or EPA. Surface water discharges of chemicals-are regulated by the State or EPA. The following monitoring discussion will emphasize radiological aspects. Non-radiological constituents are discussed only to the extent that they affect transport of radionuclides and can be used as early warning indicators of waste migration, into ground-water.
It is expected that the site operational environmental-monitoring program will be conducted during the entire time that waste is being buried, estimated at about 30 years. Appropriate records and data must be submitted to NRC during periodic license-renewal action, and as public information, to demonstrate com- 1 pliance, for continued operation. The data and records will provide 1 1
1 information for the post-operational program. J 4.2 Considerations in the Design of an Operational Environmental-Monitoring Program
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4.2.1 Pathway Analysis The pathways for the migration of waste from the burial site to member of the )
public are important in the design of an operational environmental-monitoring 15 l
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program. The purpose of pathway analysis'is to predict the amount of waste that reaches persons under a measured or assumed set of conditions and to estimate the potential hazard to humans resulting from this exposure. By performing a radiological assessment, the critical pathways of radiation dose to humans can be identified. The objective of an operational program is to monitor critical pathways, by selecting appropriate environmental sampling media and sample locations, to ensure that human exposure can be measured or calculated as accu-rately as possible. The critical pathways where monitoring efforts should be concentrated are site-specific and will usually be known after the preoperational program and after the completion of the radiological assessment, which is required as part of the license submittal of an Environmental Report (ER), in support of the license application.
l 4.2.2 Critical Nuclides and Groups The " critical" nuclides and groups refer to the radionuclides and population groups that receive the greatest exposure in the radiological assessment. To identify critical radionuclides, the characteristics of the waste that is to be buried at the facility must be known. The following documents or references l
provide some guidance on the waste characterization of existing low-level waste-disposal facilities.
A. NRC, " Update of Part 61 Impact Analysis Methodology," NUREG/CR-4370, 1985.
B. NRC, Final Environmental Impact Statement on'10 CFR Part 61, " Licensing Requirements for Land Disposal of Radioactive Waste," NUREG-0945, 1982.
C. DOE /RW-006, Spent Fuel and Radioactive Waste Inventories, Projections, and Characteristics - Updated Annually,.
During the preoperational phase, demographic data should be obtained and incorporated into the pathway analysis, to identify any population group whose location (with respect to the site) and dietary, domestic, and occupational habits make it the critical group.
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4 4.2.3 Quality Assurance / Quality Control The applicant's environmental monitoring program should include a quality I assurance / quality control program. These proghams are needed for the following reasons: (1) to identify deficiencies in the samplincJ and measurement processes to those responsible for these operations so that cor-rection action can be taken, and (2) to obtain some measure of confidence in the results of the monitoring programs in order' to assure the regulatory agencies and the public that the results are valid.
In general the design of a quality acsurance program should take the following factors into account (ICRP, 1984):
(a) quality of equipment and instruments; (b) training and experience of personnel; (c) verification of procedures by the routine analysis of control samples and the use of standard methods for analysis; (d) frequency of calibration and maintenance of equipment and instruments.
Variability in the measuring system will be an important aspect of influencing this matter; (e) the need for traceability of.the results of monitoring programs.to a national standard; and (f) the degree of documentation needed to demonstrate that the requried quality has been achieved and is maintained.
Quality control applies to all steps of a measurement program which include sampling procedures, precautions to be taken in transport of samples, initial physical or chemical preparation, radiochemical separation, measurement of .
activity, data interpretation, reporting and record keeping (ICRP, 1984).
The applicant should refer to the following NRC documents for the design of a QA/QC program. The program should apply to all phases of the environmental monitoring program.
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NRC Regulatory Guide 4.15. - Quality Assurance for Radiological Monitoring Program (Normal Operations) - Effluent Stream and the Environment (NRC,
.1979).
B. NRC NUREG-1293 - Quality Assurance Guidance for Low-Level Radioactive Waste Disposal Facility (NRC 1989).
4.3 Measurement of Parameters in the Environment 4.3.1 Physical Parameters In the operational phase, most physical parameters to be measured during the preoperational stage are not measured, since the site Aas been characterized and found to be acceptable by the NRC or the State (Agreement States).
The physical parameters, such as data on the onsite windspeed, wind direction and atmospheric stability joint frequencies should be measured throughout the operational phase to determine movement of air releases from routine or accident J.
situations. Precipitation, temperature and evaporation data should be measured onsite to determine water budget. Ground-water direction and velocity should be' reevaluated during periodic license-renewal action usually every five years, since changes may occur as a result of variation in precipitation rates, water use, pumping and other factors. These changes may indirectly affect the ground-water monitoring program.
4.3.2 Radiological Contaminants The sampling and measuring of radiological contamirkants in the environment constitute the major components of an operational environmental-monitoring pro-gram. The sample locations, frequency, and radionuclides measurement are site-specific and are determined on a case-by-case basis. In general, samples should be collected to represent background levels, points of maximum impact, where people can be exposed, and where measurements can be useful in interpreting the results of the overall monitoring program. The frequency of sampling depends on the critical pathway determination and the compliance requirements, which are site-specific. Radionuclides to be measured in the sampling media depend on 18
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l-the waste characterization'and pathway consideration. An example of a suggested operational monitoring program on radiological measurements covering both an i
arid and a humid site is shown in Appendix B (DOE 1989). The applicant should refer to the numerous literature references on the methodology of samp'ing and analysis of various environmental media in this document (DOE 1989).
4.3.2.1 Environmental Sampling Media 1
1 4.3.2.1.1 Air l Air monitoring is one of the major components in an operational monitoring program. Waste can become airborne from spills, waste-handling and by incinera-l tor operation. Gases containing tritium (H-3), carbon-14 (C-14), and radon-222 (Rn-222), for example, can be generated by chemical or biological activity reac-tions in the waste, and by evaporation of volatile compounds. Evaporation may l- be the critical pathway in an arid site, because there is less vegetative ground
! cover and lower soil-moisture in an arid site than at a humid site, thus enhancing airborne and evaporation processes. Air monitoring should include fenceline and offsite sampling. The locations of the sampling stations should be based on meteorological data (wind directions) and critical group locations.
Radionuclides to be measured include gross alpha, beta and gamma, in particu-l lates which essentially serve as a screening measurement and some of the aforementioned isotopes (H-3, C-14, Rn-222), as appropriate.
3 Based on operating experience (00E, 1989), the probability of an I airborne (releasefromalow-levelwastesiteissmall,andthelevelofmonitor-ing should be tailored to its need. For example, if the radiological assessment from routine operation demonstrates that the offsite dose resulting from airborne releases is well below the applicable standards, such as the existing NRC stan-dards (10 CFR Section 61.41) or the currently promulgating EPA Clean Air Act standards (54 FR 9612), then the level of air monitoring, particularly the offsite monitoring can be reduced to a minimum, such as periodic sampling at prevailing down-wind locations simply to provide a periodic record for public information. In addition the level of monitoring should be adjusted by com-paring the data to a preset action level, as discussed below, i
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4.3.2.1.2 Direct Radiation Direct gamma radiation should be measured onsite and offsite. Thermoluminescence detectors (TLD), which are easily installed at a fixed location are commonly used.
The onsite TLDs provide information on direct gamma radiation for workers or transient workers, such as truck drivers inside the facility. Offsite TLDs should reflect background variation since it is not expected that direct gamma radiation l from a LLWDF would change off-site background radiation significantly. The slight change of direct gamma radiation offsite from background can only be estimated by pathway modeling. The TLDs me; ement off-site will serve as a record that the change is insignificant.
4.3.2.1.3 Ground Water Because early warning can provide an opportunity for timely mitigating action during operational phase, ground water sampling stations should be located up gradient and down gradient of operating trenches or sumps at disposal units to detect potential leachate from the trenches. Non radiological parameters, such as pH, specific conductance, nitrate or fluoride can be used as indicators in ground water to provide an early warning for potential problems. Gross alphas, betas and gamma should be analyzed in ground water and serve as screening levels.
Analysis of key radionuclides based on trench waste inventory may be needed if action levels are exceeded. The applicant should establish action levels for the key sampling parameters and reporting requirements (see following discussion).
4.3.2.1.4 Surface Water During the operational phase, surface water sampling should be conducted in areas of runoff from active operation. If there is a direct discharge into the surface stream, the outfall and the water course, upstream and downstream, should be l monitored Sample analyses should be the same as the ground water sample analyses during the operational phase.
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l l 4.3.2.1.5 Soil and Sediment Soil and sediment samples should be taken at strategic locations such as:
upwind, prevailing wind direction, and area of maximum impact; area of potential contamination from waste handling, runoff, and outfalls. Analyses should include gross alpha, beta and gamma measurement and isotopic analysis if action levels are exceeded. Only periodic sampling is needed since they serve as indicators for long-term impact from operation.
4.3.2.1.6 Vegetation and Farm Crops and Others Vegetation and farm crops representing dominant species of the area should be sampled periodically at locations representing background, off-site impacted areas. Analyses are the same as for soil and sediment. They serve as indicators for the ingestion pathway impact analysis. Other indicators, such as small mammals, game birds, fish, and milk (if obtainable) should be sampled and anal-yzed periodically. Grab samples are acceptable since the data provide a record to demonstrate that the off-site impact from pathway analysis is insignificant.
4.3.3 Action Level An action level is defined as the concentration of radionuclides or chemical indicator above which an investigation is required. The investigation includes checking on laboratory procedures for analysis, contamination, resampling, iso-topic analysis, increased frequency and expansion of monitoring. The findings could lead to mitigative action. The applicant should set the action level on j the key enviror. mental media to ensure that mitigating measures are taken in a )
timely manner and in compliance with 10 CFR Subsection 61.53(b). Action levels should be related to background concentration or percentage of the applicable dose limits that are intended as triggering levels for initial investigation..
The applicant should also set concentration levels on key environmental media 1 1
I fi.e., air and water), such as levels that exceed the applicable dose limit for the reporting requirement to NRC.
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- 5. GENERAL GUIDANCE ON POSTOPERATIONAL ENVIRONMENTAL MONITORING l
l 5.1 Program Objectives After closure of a LLW disposal site, it is expected that the facility has been proper 1" decommissioned and that residual contamination at the site has been decontaminated to acceptable levels. Disposal units are capped to protect intruders and to provide biobarrier intrusion. The site is placed under institutional control. The postoperational monitoring is to ensure that the site continues to meet closuce requirements. At this time, most of the environmental sampling can be terminated except for ground water monitoring, which will need to be carried on to provide data to support long-term impact evaluation of ground water.
5.2 Physical Surveillance A physical surveillance program should be conducted periodically after site closure. The surveillance program should provide for physical inspection of the site and the performance of any required repairs to maintain the site integrity. This includes the repair, and maintenance of the perimeter fence, backfill of any area due to subsidence of the trenches, and repair of damage caused by erosion.
5.3 Environmental Sampling Media 5.3.1 Ground Water After site closure, the primary path for radionuclides release to the environment is through the ground water pathway. The ground water monitoring program for the operational phase should be continued during the initial period after site closuro, and can be gradually reduced, at proper timing if no problem exists. I The analysis of chemical indicatcrs should be continued and for radionuclides, errpnasis st.ovld De placed on long-lived isotcpes, such &s tritum, Sr-90, Tc-99, I-129, C-14, uranium and thorium isotopes and Ra-226 or Ra-228.
If subsurface water could to reach ground surface and eventually enter any streams, rivers, or leker, these water bedits shocid to monitored.
22
5.3.2 Other Sampling Media l
1 Vegetation (particularly deep-root plants) grown on the surface of the site to control soil erosion should be sampled periodically (i.e. annually) to determine any uptake of radionuclides. Burrowing animals that may inhabit the site should also be sampled and analyzed. This serves as an indicator to demonstrate the effectiveness of the biobarrier design.
I
'6 REFERENCES
- 1. , Department of Energy - (updated annually) - Spent Fuel and Radioactive Waste Inventories, Projections, and Characteristics.
- 2. Department of Energy (19881 - Site Characterization Handbook - National Low-Level Waste Management Program. 00E/LLW-67T.
- 3. Department of Energy (1989) - Low-Level Radioactive Waste Management Handbook Series - Environmental Monitoring for Lo,-Level Waste-Disposal Site, 00E/LLW-13Tg (Draft).
- 4. Federal Register - Availability and Request for Public Comment on a Branch Technical Position Paper Concerning Environmental Monitoring, Vol. 52,
- p. 42486, November 5, 1987.
- 5. Federal Register - National Emission Standards for Hazardous Air Pollutions; Regulation of Radionuclides; Proposed Rule and Notice of Public Hearing, Vol. 54, p 9612, March 7, 1989.
- 6. ICRP-43 (1984) - Principles of Monitoring for the Radiation Protection of the Population.
- 7. NUREG-1293 (1989) - Quality Assurance Guidance for Low-Level Radioactive Waste Disposal Facility.
- 8. NUREG-0902 (1982), Branch Technical Position--Low-Level Waste Licensing Branch - Site Suitability, Selection and Characterization.
- 9. U.S. Nuclear Regulatory Commission (1979) - Reg., Guide 4.15 - Ouality Assurarce for Radiological Monitoring Programs (Normal Operations) -
L Effluent Streams and the Environtrent. !
- 10. U.S. Nuclear Eagulatory Commission (1981) - Technology, Safety and Costs of Decunaissioning a Reference Low-Level Waste Burial Ground - Environmental Surveilia cen Program, NUREC/CR-0570 Addendem.
24
- 11. U.S. Nuclear Regulatory Commission (1982) - Final Environmental Impact Statement on 10 CFR Part 61 " Licensing Requirements for Land Disposal of Radioactive Waste." NUREG-0945.
- 12. U.S. Nuclear Regulatory Commission (1985) - Update of Part 61 - Impact Analysis Methodology. NUREG/CR-4370.
- 13. U.S. Nuclear Regulatory Commission (1988) - Recommendations to the NRC for Review Criteria for Alternative Methods of Low-Level Radioactive Waste Disposal Environmental Monitoring and Surveillance Program.
NUREG/CR-5054, PNL-6553.
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APPENDIX A i
SUGGESTED PRE 0PERATIONAL ENVIRONMENT AT SAMPLING PROGRAM COVERING AN ARID AND HUMID SITE -- TABLE TAKEN FROM REFERENCE 3 0F THIS PAPER (D0E 1989)
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i Suggested preoperational environmental sampling program Sample Arid a Humid a j Sample type Sampling frequency size sampling number sample.n' umber I
-Air- particulate . Continuous, with weekly --
2 perimeter 2 perimeter filter changes Air--tritiated water vapor Continuous, changed --
2 perimeter- 2 perimeter weekly Air- gases and radiciodine Continuous, changed --
2 perimeter 2 perimeter weekly Precipitation Monthly --
1 perimeter 1 perimeter location location Direct radiation-TLD Bimonthly --
6 perimeter 6 perimete r Wa'ter--surface Semiannually 4L Lakes, streams, ponds, rivers etc., within 10 km Water--offsite--subsurface Semiannually 4L Wells, municipal and private within 10 km Water--onsite--subsurface Quarterly 4L 8 perimeter monitoring wells in the saturated zone and any wells into aquifers Soil--subsurface -- --
Collect soil at time boreholes are dug Surface soil--onsite Annually 4-5 kg Divide site in grid system of 100 x 100-meter squares and take one soil sample from each grid Surface soil--offsite Semiannually 4-5 kg Collect multiple samples using the sampling distribution outlined in Ref. 3 (DOE 1989)
Vegetation- grass Ar,r.ually with soil 1m2 -
Collect grass samples at 30% of the soil sampiing locations A-1
3 .- 4
, Suggested preoperational environmental sampling program (Continued)
Sample Arid a Humid a
. Sample. type Sampling frequency. size sampling number sample number.
Vegetation--other-onsite Once 1 kg Representative samples of the common vegetation of the area Bottom sediment Annually Up to Nearby rivers Nearby rivers several that drain area that' drain kg if within 10 km the site (upstream and downstream)
Small mammals Once Total Representative samples of the I of 1 kg common species of the area Game birds Once Total In-season species at conveni-of 1 kg ent locations within 10 km of the site Fish Once Total Nearest river Upstream frosi of 1 kg that drains site and dowi area stream where i seepage or runoff from the site may occur Farm crops Once 1 kg Representative samples of i per the major constituents species within 10 km of site Milk Semiannually when cows 4L If available Upwind of the are in pasture, and from site and a local dairy downwind of the site
- a. Sites where the unsaturated zone extends for greater than atout 50 ft below tne trench bottom are defined as arld; those sites where the unsaturated zone is less than about 50 ft are classified as humid. It should be noted, however, that arid and humid are extremes of a continuum of conditions.
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l Suggested preoperational analysis schedule Sample type Analysis Conditions Air- particulate Total alpha and Composite weekly Total beta samples by location Gamma ray spec each month Air--tritiated water vapor Hydrogen-3. All samples Air--other vapors, gases Carbon-14, Iodine-129, Krypton-85 Radon-222 50%
Precipitation Gamma-ray spec Analysis on evaporated residue Direct radiation i
Water- surface Gamma-ray spec 50%
Hydrogen-3 All samples Strontium-90 25%
Uranium, Carbon-14 Technetium-99 10%
Radium-226 Water--of f site--subsurface Gamma-ray spec 50%
Hydrogen-3 All samples Strontium-90 25%
Uranium, Carbon-14 Technetium-99 10%
3 Radium-226 !
Water--onsite--subsurface Gamma ray spec 50% 4 Hydrogen-3 All samples Strontium-90 25% '
Uranium, Carbon-14 Technetium-99 10%-
Rsdium-226 Soil--onsite Gamma-ray spec Total of 30 Hydrogen-3 (soil moisture)
Strontium-90 Uranium Soil--offsite Same All Soil--subsurface Same 10% of total collected A-3 J
l Suggested preoperational analysis schedule (Continued)
Sample type Analysis Conditions Vegetation- grass Gamma-ray spec Analyze 30% of those Hydrogen-3 ollected Vegetation--other Gamma ray spec Each species Hydrogen-3 Bottom sediment Gamma-ray spec All Small mammals Game birds Gamma-ray spec Each species Fish Farm crops Gamma-ray spec Each variety Milk Gamma ray spec All Hydrogen-3, Iodine-129, Strontium-90 I
A-4
. _ L, g.
.i..,
APPENDIX B SUGGESTED OPERATIONAL ENVIRONMENTAL SAMPLING PROGRAM COVERING AN ARID AND HUMID SITE-- TABLE TAKEN FROM REFERENCE 3 0F THIS PAPER (DOE 1989)
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