The Essence of REMP

1. The Essence of REMP Jim Key Key Solutions, Inc. 2002 RETS/REMP Workshop

2. Document Compliance with Regulations Verify Proper Functioning of Effluent Controls and Monitoring Identify Trends Related to Plant Releases Assess Impact of Releases on Environment and Public Allow Assessment of Impact of Accidental Releases Provide Information to Public Provide Documentation for Litigation Defense Reasons for Environmental Monitoring

3. The Radiological Environmental Monitoring Program is Required by 10 CFR 50, Appendix I, Section IV.B.2 and IV.B.3. Regulatory Requirementsfor the REMP

4. Pre-Operational Data (P.S. Where’s yours?) General Program Description Sample and Analysis Selection Criteria Land Use Census Personnel and Vendor Qualification Statistical Requirements Critical Components of the REMP

5. Sampling Media and Location Driven By: Likely Critical Exposure Pathways Critical Population Group Verified By Land Use Census Design Considerations

6. Driven By: Variation in Release Rate of Activity Radiological Half-life Dispersion and Deposition in Environment Sampling Frequency

7. Reg Guide 1.109 and NUREG 0133 Use Very Simple Dispersion and Deposition Models Source of Greatest Model Uncertainty Important To Monitor Environment To Insure Doses Are Not Substantially Underestimated Dispersion and Deposition in Environment

8. Transitory Exposure Pathways Integrating Exposure Pathways Cumulative-Integrating Exposure Pathways Types of Exposure Pathways

9. Radionuclide concentration in environmental media is directly proportional to the rate of release of activity into the environment. Environmental concentrations will exist only as long as activity is released. Transitory Exposure Pathway

10. Direct Radiation Noble Gas Immersion Inhalation Potable Water (Fast Flowing Stream or Large Water Body) Transitory Exposure PathwayExamples

11. Potential To Be Highly Variable With Time Requires Continuous or Integrating Monitoring TLD Continuous Air Sampling Transitory Exposure PathwayMonitoring Strategy

12. Radionuclide concentration in environmental media increases with continued release of activity into the environment. Environmental concentrations can continue to increase even after release to environment ceases. Integrating Exposure Pathway

13. Ground Plane Sediment and Soil (Including Shoreline) Potable Water (Slow Flowing Stream) Aquatic Food Ingestion Leafy Vegetation Ingestion Integrating Exposure PathwayExamples

14. Concentration Less Variable With Time Batch Sampling Frequency Driven Primarily by Half Life Integrating Exposure PathwayMonitoring Strategy

15. Radionuclide concentration in environmental media is described by two integrating processes. Environmental concentration in media is driven by a primary integration pathway. Potential to be particularly sensitive environmental indicators. Cumulative-Integrating Exposure Pathway

16. Aquatic Food Ingestion (Small Water Body) Shoreline Exposure (Small Water Body) Grass-Cow-Milk Ingestion Grass-Cow-Meat Ingestion Uptake From Soil by Crops Cumulative-Integrating Exposure Pathway - Examples

17. Concentration Varies Slowly With Time Sampling Time May Be: Determined by Growing Season Semi-annual or Annual Cumulative-Integrating Exposure Pathway – Monitoring Strategy

18. Ideal – Sample in Human Food Chain. May Not Always Be Practical of Possible No Local Agriculture Species Unavailable or Endangered Acceptable To Use Alternate Environmental Indicators. Sampling

19. Aquatic Plants Not Considered Part of Human Food Chain in U.S. Kelp Concentrates Iodine Algae/Plankton Concentrate Co-58, Co-60, Zn-65, Cs-137 Shellfish Filter Feeders Freshwater Bioaccumulation Higher Than Fish Useful Aquatic Indicators

20. Required to sample “broad leaf vegetation” NUREG 0472 – “similar to lettuce and cabbage” Also Turnips (leafy portion), Spinach, Celery What If Unavailable? Reg Guide 4.8 “Nonedible plants with similar characteristics may be substituted.” Leafy Vegetation

21. Broad Leaf Vegetation defined as: “A plant with leaf area typically greater than 1 square inch.” Based on above definition, the leafy portion of the following would also meet the criteria: Corn, Sugar Beet, Peas, Beans, Soybeans, Potato, Cucumber, Tomato, Zucchini, Polkweed, Tobacco. Fast Growing Broad Leaf Ornamentals Leafy Vegetation - Substitute

22. Slow Growing Plants Will Integrate Activity Over Long Period of Time Moss & Lichens Spanish Moss – Good Integrating Filter for Airborne Particulate. Not a part of human food chain, but potentially sensitive indicators. Other Vegetation

23. Species Considered Important If: Commercially or Recreationally Valuable, or Affects The Well Being of Some Important Species, or Biological Indicator of Health of Ecosystem Other Indicators

24. Examine Lean Muscle (Consumable Portion) Thyroid (Iodine) Bone (Strontium) Liver (Cobalt, Manganese) Sources Game Animals Road Kill Large Animals

25. Small Game Animals Limited Use – Not Significant Part of Food Chain Rabbits and Field Mice could be considered potential indicator species. Small Animals

26. “Radioactive Kelp Washes Up On Beach” San Onofre Radioiodines of plant origin? Koeburg Newspapers claimed from plant. Later proved to be of medical origin. Why Sample “Other” Indicators?

27. Effluent Dose Limits of 10 CFR 50, Appendix I are so low as to be immeasurable in the environment. The Offsite Dose Calculation Manual contains the methodology and parameters used in the calculation of offsite doses due to radioactive liquid and gaseous effluents. Relationship of the REMP to the ODCM - I

28. Appendix I allows accounting for real phenomenon or factors actually affecting the estimate of radiation exposure including physical processes tending to attenuate the quantity of radioactive material to which an individual would be exposed. Relationship of the REMP to the ODCM - II

29. The Dose Models of Reg Guide 1.109 and NUREG 0133 Consider: Site-Specific Exposure Pathways Site-Specific Parameters Relationship of the REMP to the ODCM - III

30. The Land Use Census data should indicate the presence or absence or pathways and provide information on site specific dose model parameters. Calculation of non-existing pathways results in significant over estimation of dose to a member of the public and is discouraged. Relationship of the REMP to the ODCM - IV

31. ODCM methodology contains numerous parameters which should be site specific. Use of Reg. Guide default values results in overestimation of dose to member of the public. NRC and ANI strongly encourage use of site specific parameters. Relationship of the REMP to the ODCM - V

32. Age of Receptor Four age groups are considered: Infant: 0 to 1 year old Child: 1 to 11 years old Teen: 11 to 17 years old Adult: 17 years and older Site Specific ODCM Parameters Which Have Greatest Effect On Dose - I

33. Agricultural Productivity - kg/m2 Vegetation Pathway Fresh Leafy Vegetables Stored Vegetable Cow/Goat Milk and Cow Meat Pasture Grass Stored Feed Site Specific ODCM Parameters Which Have Greatest Effect On Dose - II

34. Usage Fractions Vegetation Pathway Annual intake of leafy vegetation grown locally Annual intake of stored vegetation grown locally Cow/Goat Milk and Cow Meat Fraction of year cow is on pasture Fraction of cow feed that is pasture grass when cow is on pasture Site Specific ODCM Parameters Which Have Greatest Effect On Dose - III

35. Environmental concentrations are typically below detection limits. ODCM models can be used to predict concentration in various environmental media. ODCM models tend to overestimate environmental concentration. Correlation of Effluent Concentrations with Concentrations in the Environment

36. ODCM models can estimate an upper bound on environmental concentrations when REMP results are below detection limits. ODCM predicted concentrations well above detection limits with REMP being below detection limits may indicate: Excessively conservative ODCM methodology OR An ineffective REMP program Correlation of Effluent Concentrations with Concentrations in the Environment

37. Predicted Ground Plane Concentrations Where: Conc = Predicted Concentration in mCi/m2 D/Q = Atmospheric Deposition in 1/m2 Qi = Activity Released in mCi

38. Where: QF = Cow Feed Consumption (kg/da) Fm = Feed to Milk Transfer Term (mCi/l per mCi/da) r = Fraction of activity retained on feed fs fp = Grazing Fractions Yp Ys = Agricultural Productivity th tf = Pathway Transport Times Predicted Cow Milk Concentrations