ML19323G914
| ML19323G914 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 05/20/1980 |
| From: | Branagan E Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19323G915 | List: |
| References | |
| NUDOCS 8006090213 | |
| Download: ML19323G914 (31) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409
)
(FTOL Proceeding)
(La Crosse Boiling Water Reactor)
)
AFFIDAVIT OF EDWARD F. BRANAGAN, JR.
REGARDING INTERVENORS' CONTENTIONS 2A AND 8 My name is Edward F. Branagan, Jr.
I am employed by the Nuclear Regulatory Conmission in the Radiological Assessment Branch of the Division of Systems Integra tion.
I have been employed h this position since 1979. My professional qualifications are attached as Enclosure 1. to this affidavit. This affidavit was prepared by me.
The purpose of this affidavit is to present written testimony addressing Contentions 2A and 8 admitted for litigation in this proceeding.
Contention 2A reads as follows:
CREC contends that the excessive off-gas emissions from ? '1BWR are inimical to public health and ' safety, and fdl to comply with the restrictions set forth in 10 C.F.R. Part 50, Appendix I.
Response
The regulations in 10 C.F.R. 50 Appendix I set numerical design objectives for limiting the doses to offsite individuals to as low as reasonably achievable (ALARA) levels. There are three categories of radioactive effluents from light water reactors such as the La Crosse reactor:
(1) all liquid effluents; 8006090 2l3 Ce
. (2) noble gas effluents released to the atmosphere; and (3) radioiodines and particulates released to the atmosphere.
It is the NRC Staff's view that compl!3nce with these design objectives is sufficient to protect the public health and safety.
I will discuss, in turn, the estimated dose and the applicable design objective (s) for each category of radioactive effluent.
For liquid effluents, Appendix ! sets a design objective for annual doses of 3 millirem to the total body, and 10 millirem to any organ from all path-ways. Based on the liquid effluent source terms (i.e., TaL!a 3.6-2), and the dilution factors and transit times (i.e., lable 5.5-6) in the Final Environ-mental Statement (NUREG-0191), the calculated dose to the total body and the highest dose to any organ (i.e.,0.7 millirem, and 0.8 millirem, respectively) are estimated to be less than one-fourth of the design objective values (see Table 5.5-4).
Consequently, the quantity of liquid effluents that are estimated to be released in the future should result in doses within the design objectives of 10 C.F.R. 50 Appendix I for liquid effluents.
For noble gases, Appendix I sets four design objectives for annual doses:
(1) 10 millirad for the gamma ray air dose; (2) 20 millirad for the beta ray air dose; (3) 5 millirem to the total body of an individual and (4) 15 millirem to the skin of an individual. The estimated noble gas source term for future releases is contained in Tat, a 3.6-3 of the FES. Based on the noble gas source tem and the maximum atmospheric dispersion (X/Q) value (i.e., FES Table 5.5-2),
the estimated annual doses (5.6' mrad for the gamma air dose, 3.8 mrad for the beta air dose, 3.7 mrem to the total body of an individual, and 7.4 mrem to
. the skin of an individual are less than 75% of the design objectives. Con-sequently, the quantity of noble gases that are estimated to be released in the future. omply with the design objectives of 10 C.F.R. 50 Appendix I.
For radioiodines and particulates released to the atmosphere, Appendix I sets a design objective of 15 mrem to any organ from all pathways. The estimated radioiodine and particulate source term for future releases is contained in Table 3.6-3 of the FES. Based on the radiciodine and particulate source terms, and the relative deposition (D/Q) and the atmospheric dispersion (X/Q) values for nearby offsite locations, the highest dose to any organ (2.2 mrem to the thyroid) was estimated to be less than one-fifth of the design objective (see FES Table 5.5-4).
Consequently, the quantity of radiotodines and particulates that are estimated to be released in the future, comply with the design objectives of 10 C.F.R. 50 Appendix I.
Contention 8 reads as follows:
CREC contends that LACBWR's radiological environmental monitoring program is inadequate in terms of a) the methodology of the testing b) the size and distribution of the sample, and c) the frequency of the sampling, in light of the off-gas levels, the geography of the area to the east of the plant, and the fact that the area is primarily a dairy region.
l
Response
l The NRC requires two types of radiological monitoring at nuclear power reactors l
to ensure that radioactive effluents are within acceptable limits:
(1) radiological l
. effluent monitoring; and (2) radiological environmental monitoring. Radio-logical effluent monitors are required to monitor and control, as applicable, the releases of radioactive materials in liquid and gaseous effluents during actual or potential releases.
In addition, the NRC requires that the operator of a nuclear power reactor conduct radiological environmental monitoring to confinn that measured releases of radioactivity (i.e. radiological effluent monitoring) from the plant do not result in unanticipated build-ups in the environment. The requirements for an acceptable radiological monitoring program for nuclear power reactors are contained in the NRC's " Branch Technical Position" (Revision 1, Nov.1979, see Enclosure 2). Since Contention 8 alleges that the radiological environmental monitoring program is inadequate, the discussion that follows is limited to the radiological environmental monitoring program rather than radiological effluent monitoring.
The Branch Technical Position requires that the licensee monitor the principal pathways of exposure to radioactivity. Table 1 contains a sumary of the exposure pathways, sample locations, frequency of sampling, and types of analysis in the La Crosse radiological environmental monitoring program. These pathways and types of analysis include monitoring of:
(1) radiciodines in air for I-131; (2) particulates in air for gross beta activity and gamma isotopic analysis; (3) direct radiation for gamma dose; (4) surface and ground water for tritium and gama isotopic analysis; (5) drinking water for gross beta, tritium and gamma isotopic analysis; (6) shoreline sediment for gamma isotopic analysis; (7) milk for I-131 and gamma isotopic analysis, (8) fish and invertebrates for gamma isotopic analysis,and (9) food for gamma isotopic analysis. Consequently,
. the methodology of the radiological environmental monitoring program at the La Crosse nuclear power plant is adequate to ensure that the principal pathways of exposure are monitored.
The size (number of sample locations) and distribution (sample locations) of samples collected and analyzed are given in Table 1.
Comoarison of the number and distribution of samples in Table 1 with the requirements of the " Branch Technical Position" (see Table 1 of Enclosure 2) indicates that the size and distribution of samples is adequate to monitor the principal pathways of exposure.O The lower limits of detection of radioactivity in various typas of samples are listed in Table 2.
These limits conform to the basic requirements of the " Branch Technical Position" (see Table 2 of Enclosure 2).
In addition, Dairyland Power l
Cooperative is required to participate in an Interlaboratory Comparison Program to ensure the precision and accuracy of the measurements of radioactive material in environmental samples. The lower limits of detection of radioactivity in the La Crosse program, in combination with the requirements for participation in an Inter-laboratory Comparison Program, ensure that the size (i.e., volume or weight) or samples is adequate to meet the basic requirements of the Branch Technical Position.
1 1/ After the licensee applied for conversion of Provisional Operating License No. 45 to a full-tem operating license, the Branch Technical Position was updated to increase the number of direct radiation monitors to 40. The licensee will be required to meet this new requirement and to update the technical specifications in the near future, l
l
-. ~..
The frequency of radiological environmental sampling of the La Crosse nuclear plant ranges from at least weekly to annual sampling, depending on the type of sample (see Table 1). Milk samples are collected biweekly during the grazing 1
season, and monthly at other times. Water samples are collected on either a monthly or a quarterly basis (depending on the type of sample), and dosimeters are collected on a quarterly basis. Sediment from the shoreline, and fish and invertebrate samples are collected at least semi-annually if not seasonally.
Vegetation samples are collected at the time of harvest. Comparison of the frequency of sampling at the La Crosse nuclear plant with the requirements of the " Branch Technical Position" (see Table 1 in Enclosure 2), indicates that the sampling frequency is adequate to monitor the principal pathways of exposure.
]
-*~T
/
TABLE 1 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway Sampling and Type of Frequency and/or Sample Sample Locations **
Collection Frequency of Analysis 1.
AIRBORNE a.
Radioiodine and Locations #4, #6, Continuous operation of Radioiodine canister.
Particulates
- 15, #16, #17, sampler with sample collec-Analyze at least once per
- 18, and #22 tion as required by dust 7 days for I-131.
loading but at least once per 7 days.
Particulate sampler.
Analyze for gross beta radioactivity > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following filter change.
Perform gamma isotopic
. analysis on each sample',
when gross beta activity y
is > 10 times the mean of control sample. Perform gamma isotopic analysis on composite (by location) sample at least once per 92 days.
2.
DIRECT RADIATION Locations #1-#21 At least once per 92 days.
Gamma dose. At least once
> 2 dosimeters at per 92 days.
,cach location.
- Sample locations are shown on Figure 1 in Enclosure 3.
/ This table was taken from Proposed Changes to Technical Specificat:ons in a letter fr0m Frank Linder, General Manager of Dairyland Power Cooperative, to Dennis L. Ziemann dated August 4,1979.
TABLE 1
- (Cont'd)
/
RADIOLOGICAL ENVIR0iiMENTAL MONITORING PROGRAM Exposure Pathway Sampling and Type [ndFrequency and/or Sample Sample Locations **
Collection Frequency, of Analysis 3.
WATERBORNE a.
Surface Locations #15, #27 Composite
- sample collected Gamma isotopic analysis of and #30 over a period of < 31 days, each composite sample.
Tritium analysis of compo-site senple at least once per 92 days.
b.
Ground Locations #6 and At least once per 92 days.
Gamma isotopic and tritium
- 29 analyses of each sample.
c.
Drinking Locations-#24 and Sample collected at least Gross beta and gama iso *
- 31 every 31 days.
topic analysis of each a
sample. Tritium analysis, m
of composite sample at least once per 92 days.
d.
Sediment from Locations #22, #27, At least twice per year.
Gamma isotopic analysis of Shoreline and #30 each sample.
- Composite samples shall be collected by collecting an aliquot during at least three batch effluent discharges.
- Sample locations are shown on Figure 1 of Enclosure 3.
e
TABLE 1
- (Cont'd)
RADIOLOGICAL ENVIRONMENTAL MONIT.0 RING PROGRAM Exposure Pathway Sampling and Type.and Frequency and/or Sample Sample Locations **
Collection Frequency 6f Analysis 4.
INGESTION
~
a.
Milk Locations #17, #18, At least once per 15 days Gamma isotopic and I,131 and #23 when animals are on pasture; analysis of each sample.
at least once per 31 days at other times.
b.
Fish and Locations #15 or One sample in season, or at Gamma isotopic analysis on Invertebrates
- 26 and #30 or #27 least once per 184 days if edible portions, or #28
not seasonal. One sample of each of the following species at two locations:
1.
Carp 2.
Catfish u) i c.
Food Products Locations #17, #16 At time of harvest.
One Ganna isotopic analysis on or #23, and #18 sample of each of the fol-edible portion.
lowing classes of food products:
1.
Legumes 2.
Feed Grains 3.
Garden Vegetables Location #17 At time of harvest.
One Gamma isotopic analysis, sample of broad leaf vegetation.
+
- Sample locations' are shown on Figure 1 of Enclosure 3.
TABLE _2_
MAX 1 HUM VALUES FOR THE LOWER LIMITS OF DETECT 10ti (LLD)"
Airborne Particulate Water Fish Milk Food Products SediiEent (pC1/l)
(Ci))
(pCi/kg, wet)
(pCi/1)
(pCi/kg, wet)
(pCi/ kg. dry)
Analysis b
gross beta 4
1 x 10" D
3 2000(1000 )
g 54 15.
130 gn 59,
3G 260 7
5 58,60 E
130 Co 65 30 260 Zn 95Zr-Nb 15 131; I
7 x 10-2 1
60c b
134,137 15(10 ) 18 1 x 10-2 130 15 80 150 Cs 140,,g, 15 15 g
i
- This table was taken from Proposed Changes to Technical Specifications in a letter from Frank Linder, General Manager of Dairyland Power Cooperative, to Dennis L. Ziemann (NRC/NRR) dated August 14, 1979.
o TABLE 2
'(Cont'd)
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TABLE f10TATION The LLD is the smallest concentration of radioactive material in a a
sample that will be detected with 95% probability with,:5% probability of falsely concluding that a blank observation represents a "real" signal.
For a particular measurement system (which may include radio-chemical separation):
4.66 sb LLD' =
?
E x V x 2.22 x Y x exp(-Aat)
WHERE:
LLD is the lower limit of detection as defined above -(as pCi per unit mass or volume) sb is the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute)
E is the counti,ng efficiency (as counts per transformation)
V is the sample size (in units of mass or volume) 2.22 is the number of transformation per min"te per picocurie Y is the fractional radiochemical yield (when applicable)
A is the radioactive decay constant for the particular radio-nuclide at is the elapsed time between sample collection (or end of the sample collection period) and time of counting The value of sb used in the calculation of the LLD for a detection system shall be based on the actual observed variance of the back-ground counting rate or of the counting rate of the blank samples (as appropriate) rather than on an unverified theoretically predicted variance. 'In calculating the LLD for a radionuclide detemined by gamma-ray spectrometry, the background shall include the typical contributions of other radionuclides normally present in the samples (e.g., potassium-40 in milk samples.
TABLE 2 (Cont'd)'
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~.
TABLE NOTATION Analyses shall be performed in such'a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of e
interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.
In such cases, the contributing factors will be identified and described in the Annual Radiological Environmental Operating Report.
b - LLD for drinking water.
c
,LLD for leafy vegetables.
D G
9 6
m l
l e
. In sumary, the methodology of testing; size, distribution and frequency of sampling in the La Crosse radiological environmental monitoring program meets the basic requirements of the NRC " Branch Technical Position," and are adequate to confirm that measured releases of radioactivity do not result in unacceptable doses to the public.
I have read the foregoing affidavit and swear that it is true and correct to 1
the best of my knowledge and belief.
/
V &/9 #? zw+ (
ns Edward F. Branagan, Jr.
/
Subscribed and sworn to before me day of 77,h,w 4
this 74
, 1980 Wiki 04-l.lz, j
Notary PubFic /
My Commission Expires
%d. /. Y.N
//
J'
Professional Qualifications My name is Edward F. Branagan, Jr.
I am an Environmental Scientist with the Radiological Assessment Branch in the Office of Nuclear Reactor Regulation.
Presently, I am responsible for evaluating the environmental radiological impacts from nuclear power reactors.
In particular, I am responsible for evaluating radioecological models and health effect models for use in reactor licensing.
I have been with the Radiological Assessment Branch for about 1 year.
I' received a B.A. in Physics from Catholic University in 1969, an M.A. in.
Science Teaching from Catholic University in 1970, and a Ph.D. in Radiation Biophysics from Kansas University in 1976.
While completing my course work for my Ph.D, I was an instructor of Radiation Technology at Haskell Junior College.
My research work was in the area of DNA base damage, and was sup-ported by a U.S. Public Health Service tranineeship.
My dissertation was entitled " Nuclear Magnetic Resonance Spectroscopy of Gamma-Irradiated DNA Bases."
Since joining the NRC in 1976, I have been with both the Office of Nuclear Material Safety and Safeguards (NMSS), and with the Office of Nuclear Reactor Regulation (NRR).
In NMSS I was involved in project management and technical work.
I was the project manager for two contracts that the NRC had with Oak Ridge National Laboratory.
These contracts were concerned with estimating radiation doses from radon-222 and radium-226 releases from uranium mills.
As part of my work on NRC's Draft Generic Environmental Impact Statement on Uranium Milling (DGEIS), I calculated health effects from uranium m P!
tailings.
Upon publication of the DGEIS, I presented a paper entitled " Health Effects (# Uranium Mining and Milling for Commercial Nuclear Power" at a Conference on Health Implications of New Energy Technologies.
Since joining NRR, I have worked on several pro (1) analyzed the radioecologica1 _.
models in the "Heidelberg Report,jects:and (2) served as a technical contact on an NRC contract with Argonne National Laboratory involving development of a computer program to calculate health effects from radiation.
Presently, I am a member of the Health Physics Society and the American Association for the Advancement of Science.
Revision 1 November 1979 Branch Technical Position
===.
Background===
Regulatory Guide 4.8, Environmental Technical Specifications for Nuclear Power Plants, issued for comment in December 1975, is being revised based on comments received. The Radiological Assessment Branch issued a Branch Position on the radiological portion of the environmental monitoring program in March,1978.
The position was formulated by an NRC working group which considered comments -
received after the issuance of the Regulatory Guide 4.8.
This is Revision 1 of that Branch Position paper. The changes are marked by a vertical li'ne in the right margin. The most significant change is the increase in direct radiation measurement stations.
1 10 CFR Parts 20 and 50 require that radiological environmental monitoring i
programs be established to provide data on measurable levels of radiation and radioactive materials in the site environs.
In addition, Appendix I to 10 CFR Part 50 requires that the relationship between quantities of radioactive material released in effluents during normal operation, including anticipated operational occurrences, and resultant radiation doses to individuals from principals pathways of exposure be evaluated.
These programs should be con-ducted to verify the effectiveness of in plant measures used for controlling the release of radioactive materials.
Surveillance should be established to identify changes in the use of unrestricted areas (e.g., for agricultrual purposes) to provide a basis for modifications in the monitoring programs for evaluating doses to individuals from principal pathways of exposure.
NRC Regulatory Guide 4.1, Rev.1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants," provides an acceptable basis for the design of prog-ams to monitor levels of radiation and radioactivity in the station environs.
This position sets forth an example of an acceptable minimum radiological monitoring program.
Local site characteristics must be examined to determine if pathways not covered by this guide may significantly contribute to an individual's dose and should be included in the sampling program.
9
2 AN ACCEPTABLE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Program Requirements Environmental samples shall be collected and analyzed according to Table.1 at locations shown in Figure 1.1 Analytical techniques used shall be such that the. detection capabilities in Table 2 are achieved.
The results of the radiological environmental monitoring are intended to supplemect the results of the radiological effluent monitoring by verifying that the measurable concentrations of radicactive materials and levels of radiation are'not higher than expected on the basis of the effluent measure-ments and modeling of the environmental exposure pathways. Thus, the specified environmental monitoring program provides measurements of radiation and of radio-active materials in those exposure pathways and for those radionuclides which lead to the highest potential radiation exposures of individuals resulting from the station operation. The initial radiological environmental monitoring program should be conducted for the first three years of commercial operation (or other period corresponding to a maximum burnup in the initial core cycle).
Following this period, program changes may be proposed btsed on operational experience.
The specified detection capabilities are state-of-the-art for routine environ-mental measurements in industrial i t oratories.
Deviations are permitted from.. iequired sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal u. availability, malfunction of automatic sampling equipment and other legitimate reasons.
If specimens are unobtainable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the annual report.
The laboratories of the licensee and licensee's contractors which perform analyses shall participate in the Environmental Protection Agency's (EPA's)
Environmental Radioactivity Laboratory Intercomparisons Studies (Crosscheck)
Program or equivalent program.
This participation shall include all of the determinations (sample medium-radionuclide ccmbination) that are offered by EPA and that also are included in the monitoring program. The results of analysis of these crosscheck samples shall be included in the annual report.
The participants in the EPA crosscheck program may provide their EPA program code so that the NRC can review the EPA's participant data directly in lieu of submission in the annual report.
t It may be necessary to require special studies on a case-by-case and site soecific basis to establish the relationship between quantities of radioactive material released in effluents, the concentrations in environmental media, and the resultant doses for important pathways.
l 3-If the results of a determination in the EPA crosscheck program (or equivalent program) are outside the specified control limits, the laboratory shall inves-tigate the cause of the problem and take steps to correct it.
The results cf this investigation and corrective action shall be included in the annual report.
The requirement for the participation in the EPA crosscheck program, or.similar program, is based on the need for independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are reasonably valid.
A census shal] be conducted annually during the growing ser
- to determine the location of the nearest milk animal and nearest garden, eater than 50 square meters (500 sq. ft.) producing broad leaf vegetation in each of the 16 meteorological sectors within a distance of 8 km (5 miles).2 For elevated releases as defined in Regulatory Guide 1.111, Rev.
1., the census shall also identify the locations of all milk animals, and gardens greater than 50 square meters producing broad leaf vegetation out to a distance of 5 km. (3 miles) for each radial sector.
If it is learned from this census that the milk animals or gardens are present at a location which yields a calculated thyroid dose greater than thc:e previously sampled, or if the census results in changes in the location used in the radioactive effluent technical speci fications for dose calculations, a written report shall be submitted to the Director of Operating Reactors, NRR (with a copy to the Director of the NRC Regional Office) within 30 days identifying the new location (distance and direction). Milk animal or garden locations resulting in higher calculated doses shall be added to the surveillance program as soon as practicable.
The sampling location (excluding the control sample location) having the 1cwest calculated dose may then be dropped from the surveillance program at the end of the grazing or growing season during which the census was con-ducted. Any location from which milk can no longer be obtained may be dropped from the surveillance proqram after notifying the NRC in writing that they are no longer obtainable at that location.
The results of the land use census shall be reported in the annual report.
The census of milk animals and gardens producing broad leaf vegetation is based on the requirement in Appendix I of 10 CFR Part 50 to " Identify changes in the use of unrestricted areas (e.g., for agricultural purposes) tu permit modifications in monitoring' programs for evaluating doses to individu9s from principal pathways of exposure." The consumption of milk from animais grazing on contaminated pasture a7d of leafy vegetation contaminated by airborne
'Broaa leaf vegetation sampling may be performed at the site boundary in a l
sector with the highest 0/Q in lieu of the garden census.
l
4-radiciodine is a major potential source of exposure.
Samples from milk animals are considered a better indicator of radioiodine in the environment than vegetation.
If the census reveals milk animals are not present or are unavailable for sampling, then vegetation must be sampled.
The 50 square meter garden, considering 20% used for growing broad leaf vegetation 2
(i.e., similar to lettuce and cabbage), and a vegetation yield of 2 kg/m,
will produce the 26 kg/yr assumed in Regulatory Guide 1.109, Rev 1., for child consumption of leafy vegetation.
The option to consider the garden to be broad leaf vegetation at the site boundary in a sector with the highest D/Q should be conservative and that location may be used to calculate doses due to radioactive effluent releases in place of the actual locations which would be determined by. the census.
This option doe.t not apply to plants with elevated releases as defined in Regulatory Guide 1.111, Rev. 1.
The increase in the number of direct radiation stations is to better characterize the individual exposure (mrem) and population exposure (man rem) in accordance with Criterion 64 - Monitoring radioactivity releases, of 10 CFR Part 50, Appendix A.
The HRC will place a similar amount of stations in the area between the two rings designated in Table 1.
Reporting Recuirement A.
Annual Environmental Operating Report, Ps-t B, Radiological.
~
A report on the radiological environmental surveillance program for the previous calendar year shall be submitted to the Director of the NRC Regional Office (with a copy to the Director, Office of Nuclear Reactor Regulation) as a separate document by May 1 of each year.
The period of the first report shall begin with the date of initial criticality.
The reports shall include a summary (format of Table 3), interpretations, and an analysis of trends for the results of the radiological environmental tarveillance' activities for the report period, including a comparison with operational controls, preoperational studies (as appropriate), and previous environmental surveillance reports and an assessment of the observed impacts of the station operation on the environment.
In the event that some results are not available the report shall be submitted noting and explaining the reasons for the missing results.
The missing data shall be submitted as soon as possible in a supplementary report.
The reports shall also include the following:
a summary description of the radiological environmental monitoring program; a map of all sampling locations keyed to a table giving distances and directions from one reactor; the results of land use censuses; and the results of licensee participation in a laboratory crosscheck program if not participating
'n t's Ein crosscheck program.
v-
S.
B.
Nonroutine Radiological Environmental Operating Reports "If a confirmed 3 measured radionuclide concentration in an environmental sampling medium averaged over any quarter sampling period exceeds the reporting level given in Table 4, a written report shall be submitted to the Director of the NRC Regional Office (with a copy to the Director, Office of Nuclear Reactor Regulation) within 30 days from the end of the quarter.
If it can be demonstrated that the level is not a result of
. plant effluents (i.e., by comparison with control station or preopera-tional data) a report need not be submitted, but an explanation shall be.
given in the annual report. When more than one of the radionuclides in Table 4 are detected in the medium, the reporting level shall have been exceeded,if:
concentration (1) concentration (2)
. * * *,, ^
reperting level (1) reporting level (2)
If radionuclides other than those in Table 4 are detected and art due from plant effluents, a reporting level is exceeded if the potential annual dose to an individual is equal to or greater than the design objective doses af 10 CFR Part 50, Appendix I.
This report shall include an evaluation of any release conditions, environmental factors, or other aspects necessary to explain the anomalous result.
aA confirmatory reanalysis of the original, a duplicate, or a new sample may be desirable, as appropriate. The results of the confirmatory analysis shall be completed at the earliest time consistent with the analysis, but in any case within 30 days.
?
1
TABLE 1 OPERATIONAL RADIOLOGICAL ENVIRONMLNTAL MONITORING PROGRAM Exposure Pathway Number of Samples
- Sampling and Type and Frequency and/or Sample and Locations Collection. Frequency
- and Analysis AIRBORNE Radioiodine and Samples from 5 locations:
Continuous sampler Radiciodine Cannister:
Particulates operation with sample analyze weekly for 3 samples from offsite locations collection weekly or I-131 (in different sectors) of the as required by dust highest calculated annual average loading, whichever is groundlevel D/Q.
more frequent" 1 sample from the vicinity of a Particulate Sampler:
community having the highest Gross beta radio-calculated annual average ground-activity folloging,
level D/Q.
filter change, composite (bylocagion)forgamma isotopic quarterly as 1 sample from a control location 15-30 km (10-20 miles) distant and d
in the least prevalent wind direction DIRECT RADIATION 40 stations with two or more dosi-Monthly or quarterly Gamma dose monthly or meters or one instrument for measuring quarterly and recording dose rate continuously to be placed as follows:
- 1) an inner ring of stations in the general area of the site boundary and an outer ring in the 4 to 5 mile range from the site with a station in each sector of each ring (16 sectors x 2 rings = 32 stations).
The balance of the stations, 8, should be place in special interest areas such as population centers, nearby residences, schools, and in 2 or 3 areas to serve as control stations.
O
TABLE 1 (Continued) a Exposure Pathway Number of Samples Sampling and Type and frequency and/or. Sample and Locations Collection Frequency" of Analysis WATERBORNE Surface 9 1 sample upstream Compositesamplefoyer Gamma isotopic analysis 1 sample downstream one-month period '
monthly. Composite for tritium analyses quarterly Samplesfrom1or2sourjesonly Quarterly Gamma isotopic and Ground if likely to be affected tritium analysis quarterly Drinking 1 sample of each of 1 to 3 of Composite sample I-131 analysis on each the r.earest water supplies over two-week period' composite when the dose could be affected by its if I-131 anlysis is calculated for the con-discharge performed, monthly sumption of the water composite otherwise is grea,tep th3n 1 mrem 1 sample from a control location per year.
Composite for Gross p and gamma isotopic analyses monthly. Compo-site for tritium analysis quarterly Sediment from 1 sample from downstream area Semiannually Gamma isotopic analyses Shoreline with existing or potential semiannually recreational value INGESTION Milk Samples from milking animals Semimonthly when ani-Gamma isotopic and I-131 in 3 locations within 5 km mais are on pasture, analysis semimonthly when distant having the highest dose monthly at other times animals are.on pasture; potential.
If there are none, monthly at other times.
- then, I sample from milking animals in each of 3 areas i
between 5 to 8 km distant where l
doses are calculated to be k
greater than 1 mrem per year
TABLE 1 (Continurd)
Exposure Pathway Number of Samples
- Sampling and Type and Frequency and/or Sample and Locations Collection Frequency" of Analysis Milk (cont'd) 1 sample from milking animals at a control location (15-30 km distant and in the least prevalent wind direction)
Fish and 1 sample of each commercially and Sample in season, or Gamma isotopic Invertebrates recreationally important species semianually if they are analysis on edible in vicinity of discharga point not seasonal portions 1 sample of same species in areas not influenced by plant discharge I sample of each principal chass l
At time of harvest Gamma isotopic Food Products of food products from any area analysis on edible which is irrigated by water in
- portion, which liquid plant wastes have been discharged 03 i
3 samples of broad leaf vegetation Monthly when available grown nearest offsite locations of highest calculated annual average ground-level D/Q if milk sampling is not performed 1 sample of each of the similar Monthly when available vegetstion grown 15-30 km distant in the least prevalent wind direction
+
if milk sampling is not performed l
TABLE 1 (Continued) aIhe number, media. frequency and location of sampling may vary from site to site.
It is recognized that, at times, it may not he possible or practical to obtain samples of the media of choice at the most desired location or time.
In these instances suitable alternative media and lucations may be chosen for the particular pathway in question and submitted for acceptance. Actual locations (distance and direction) from the site shall be provided.
Refer to Regulatory Guide 4.1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants."
bParticulate sample filters should be analyzed for gross beta 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more after sampling to allow for radon and thoron daughter decay.
If gross beta activity in air or water is greater than ten times the yearly mean of control samples for any medium, gamma isotopic analysis should be performed on the individual samples.
C Ganuna isotopic analysis means the identification and quantification of ganuna-emitting radionuclides that may be attributable to the effluents from the facility.
The purpose of this sample is to obtain background information.
If it is not practical to establish control loca-tions in accordance with the distance and wind direction criteria, other sites which provide valid background data may be substituted.
" Canisters for the collection of radioiodine in air are subject to channeling. These devices should be carefully checked before operation in the field or several should be mounted in series to prevent loss of iodine.
fRegulatory Guide 4.13 provides minimum acceptable performance criteria for thermoluminescence dosimetry (TLD) systems used for environmental monitoring.
One or more instruments, such as a pressurized ion chamber, for measur-ing and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters.
For the purposes of this table, a thermoluminescent dosimeter may be considered to be one phosphor and two or more phosphors in a packet may be considered as two or more dosimeters.
Film badges should not be used for measuring direct radiation. The.40 stations is not an absolute number. This number may be reduced according to geographical limitations, e.g., at an ocean site, some sectors will be over water so that the number of dosimeters may be reduced accordingly.
O fhe " upstream sample" should be taken at a distance beyond significant influence of the discharge.
The "down-stream" sample should be taken in an area beyond but near the mixing zone.
" Upstream" samples in an estuary must be taken far enough upstream to beyond the plant influence.
hGenerally, salt water is not sampled except when the receiving water is utilized for recreational activities.
IComposite samples should be collected with equipment (or equivalent) which is capable of collecting an aliquot at time intervals which are very short (e.g., hourly) relative to the compositing period (e.g., monthly).
iGroundwate" samples should be taken when this source is tapped for drinking or irrigation purposes in, areas where the hydraulic gradient or recharge properties are suitable for contamination.
The dose shall be calculated for the maximum organ and age group, using the methodology contained in Regulatory Guide 1.109, Rev. 1., and the actual parameters particular to the site.
l If harvest occurs more than once a year, sampling should be performed during each discrbte harvest.
If harvest occurs continuously, sampling should be monthly.
Attention should be paid to including samples of tuborous and root food products.
TABLE 1 (Continued)
Note:
In addition to the above guidance for operational monitoring, the following material is supplied for guidance on preoperational programs.
~
Preoperational Environmental Surveillance Program A Preoperational Environmental Surveillance Program should be instituted two years prior to the institution of station plant operation.
The purposes of this program are:
l.
To measure background levels and their variations along the anticipated critical pathways in the area surrounding the station.
2.
To train personnel 3.
To evaluate procedures, equipment and techniques The elements (sampling media and type of analysis) of both preoperational and operational programs should be essen-tially the same.
The duration of the preoperational program, for specific media, presented in the following table, should be followed:
Duration of Preoperational Sampling Program for Specific Media g
6 months 1 year 2 years
. airborne iodine
. airborne particulates direct radiation iodine in milk (while
. milk (remaining analyses) fish and invertebrates animals are in pasture)
. surface water food products
. groundwater sediment from shoreline
. drinking water d
e e
9 O
TABLE 2 Detection Capabilities for Environmental Sample Analysis' Lower Limit of Detection (LLD)b Airborne Particulate Water or Gas Fish Milk Food Pr'oducts Sediment Anaysis (pCi/1)
(pCi/m3)
(pCi/kg, wet)
(pCi/1)
(pCi/kg, wet)
(pCi/kg, dry)
-2 gross beta 4
1 x 10 3
11
-2000 54tin 15 130 59Fe 30 260 58,60Co 15 130 m
C52n 30 260 95Zr 30 95Nb 15 I3I c
-2 1
60 I
i 7 x 10
-2 134 Cs 15 5 x 10 130 15 60 150
-2 137Cs 18 6 x 10 150 18 80 180 140 60 Ba 60 i
140 15 La 15 flote: This list does not mean that only these nuclides are to be detected and reported. Othe'r peaks which are measurable and identifiable, together with the above nuclides, shall also be identified and reported.
I
la TABLE 2 NOTES aAcceptable detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13.
Table 2 indicates acceptable detection capabilities for radioactive materials in environmental samples.
These detection capabilities are tabulated in terms of the lower limits of detection (LLDs).
The LLD is defined, for purposes of this guide, as the smallest concentration of radioactive material in a sample that will yi. eld a net count (above system background) that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal.
For a particular measurement system (which may include radiochemical separation):
4.66 s b LLD =
E exp(-Aat)
V 2.22 Y-where LLD is the "a priori" lower limit of detection as defined above (as pCi per unit mass or volume).
(Current literature defines the LLD as the detection capability for the instrumentation only, and the MOC, minimum detectable concentration, as the detection capability for a given instrument, procedure, and type of sample.)
s is the standard deviation of the background counting rate or of bthe counting rate of a blank sample as appropriate (as counts per minute)
E is the ceunting efficiency (as counts per disintegration)
V is the sample size (in units of mass or volume) 2.22 is the number of disintegrations per minute per picocurie Y is the fractional radiochemical yield (when applicable)
A is the radioactive decay constant for the particular radionuclide at is the elasped time between sample collection (or end of the sample collection period) and time of counting The value of S used in the calculation of the LLD for a particular measure-b ment system should-be based on the actual observed variance of the back-ground counting rate or of the counting rate of tr.2 blank samples (as appropriate) rather than on an unverified theoretically predicated variance.
13 In calculating the LLO for a radionuclide dc*. ermined by gamma-ray spectrometry, the background should include the typical contributions of other radionuclides normally present in the samples (e.g., potassium-40 in milk samples)..
Typical values of E, V, Y and at should be used in the calculation.
It should be recognized that the LLO is defined as an a priori (before the fact) limit representing the capability of a measurement system and, not as a posteriori (after the fact) limit for a particular measurement.*
cLLO for drinking water samples.
d
- For a more complete discussion of the LLO, and other detection limits, see the following:
(1) HASL Procedures Manual, HASL-300 (revised annually).
(2) Currie, L.
A., " Limits for Qualitative Detection and Quantitu'.'.ve Determination - Application to Radiochemistry" Anal. Chem. 40, 586-93 (1968).
(3) Hartwell, J. K., " Detection Limits for Radioisotopic Counting Techniques," Atlantic Richfield Hanford Company Report ARH-2537 (June 22, 1972).
4 e
TABLE 3 ENVIRONMENTAL RADIOLOGICAL MONITORING PROGRAM ANNUAL
SUMMARY
Hame of Facility Docket No.
Location of Facility Reporting Period (County, State)
Medium or Type and Lower Limit All Indicator Location with Highest, Controllocatjons Number of Location Annual Mean Mean (f)
Nonroutine Pathway Sampled Total Number of (Unit of of Analyses Detection, Mean (f)g Hame Mean (f)b Range Reported Measurement)
Performed (LLD)
Range Distance &
Range Measurements Direction Air Particu 3) lates (pCi/m Gross p 416 0.01 0.08(200/312) Middletown 0.10 (5/52) 0.08 (8/104) 1 (0.05-2.0) 5 miles 340*
(0.08-2.0)
(0.05-1.40) y-Spec. 32 i
137 0.01 0.05 (4/24)
Smithville 0.08 (2/4)
<LLD 4
Cs (0.03-0.13) 2.5 miles 160* (0.03-2.0) 131 0.07 0.12 (2/24)
Podunk 0.20 (2/4) 0.02 (2/4) 1 5
g (0.09-0.18) 4.0 miles 270 (0.10-0.31)
Fish pCi/kg (wet weight) y-Spec. 8 137 130
<LLD
<LLD 90 (1/.1) 0 Cs 134 10
<LLD
<LLD
<LLD 0
Cs 50 130 180 (3/4)
River Mile 35 See Column 4
<LLD 0
C (150-225) aSee Table 2, note b.
Mean and range based upon detectable measurements only.
Fraction of detectable measurements at specified locations is indicated in parentheses.
(f)
Note: The example data are provided for illustrative purposes only.
9
TABLE 4 1
REPORTING LEVELS FOR NONROUTINE OPERATING REPORTS Reporting Level (RL)
Broad Leaf Water Airborne Particulate Fish Milk Vegetation Analysis (pCi/1) or Gases (pCi/m )
(pCi/Kg, wet)
(pCi/1) 3 (pCi/Kg, wet) 4f^)
H-3 2 x 10 _
3 4
Mn-54 1 x 10 3 x 10 2
4 Fe-59 4 x 10 1 x 10 3
4 Co-58 1 x 10 3 4 10 2
4 Co-60 3 x 10 1 x 10 2
4 Zn-65 3 x 10 2 x 10 2
Z r-Nb-95 4 x 10 2
I-131 2
0.9 3
1 x 10 3
3 Cs-134 30 10 1 x 10 60 1 x 10 3
3 Cs-137 50 20 2 x 10 70 2 x 10 2
2 Ba-La-140 2 x 10 3 x 10
- or drinking water samples. This is 40 CFR Part 141 value.
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