1. The Changing Faces in Effluent and Environmental Monitoring Douglas Wahl Exelon

2. REMP Sensitivity Seasonal Mixing of the Stratosphere and Troposphere Seasonal Mixing of the Stratosphere and Troposphere Documented the Environmental Impact Documented the Environmental Impact –Fallout from Nuclear Weapons Test –Three Mile Island Unit 2 Accident in 1979 –Destruction of Chernobyl Reactor No. 4 in 1986 Radioactivity Passing Radioactivity Passing –From the Atmosphere and Rainfall –To the Grass-Cow-Milk Pathway –Through the Water Pathway

3. Demographic Changes Change of Program Ownership Change of Program Ownership –Nuclear Generator –NRC Inspections Many of the New Owners Many of the New Owners –Never Experienced a Significant Event in the REMP –Activity is < MDC Most Programs 30+ Years in Existance Most Programs 30+ Years in Existance

4. Knowledge Base Being Lost by the Nuclear Generator Being Lost by the Nuclear Generator –Lack of Mentoring Program –Bases not well Documented –Major Reductions in Gaseous and Liquid Effluents. –Big Deal when »Plant Related Activity is Found in the Environment »Medical Isotopes are Found in REMP Samples

5. Knowledge Base Ignored by the Nuclear Regulator Ignored by the Nuclear Regulator –Wanting Documentation on the Bases for Establishing the REMP –Changing Interpretation of the Program Requirements Where is the NRC’s Knowledge Base? Where is the NRC’s Knowledge Base?

6. NRC Knowledge Base Branch Technical Position Paper Branch Technical Position Paper –Revision 1 Issued in 1979 –Incorporated into NUREG 1301/1302 BTP Developed in part from the following: BTP Developed in part from the following: –Reg. Guide 1.21, 4.1, 4.8, and 1.109 –NUREG 0472, 0473, and 0133

7. What was the World Like when the BTP was Drafted? The United States and Soviet Union had Eliminated above Ground Testing of Nuclear Weapons in 1963 The United States and Soviet Union had Eliminated above Ground Testing of Nuclear Weapons in 1963 The French and Chinese Continued until 1980 The French and Chinese Continued until 1980 The Result of all these Tests was an Atmosphere Polluted with Radioactive Fallout The Result of all these Tests was an Atmosphere Polluted with Radioactive Fallout

8. Summary of Above Ground Weapons Tests Nation No. of Detonations Years Total Yield Mt United States 2161945-1962153.8 Soviet Union 2141945-1962281.6 United Kingdom 211952-195810.8 France461960-197411.4 China231964-198021.5 South Africa 119790.003 compiled by Wm. Robert Johnston http://www.johnstonsarchive.net/nuclear/atest00.html

9. What Did the Data Tell the Authors of the BTP? Source EPA

10. What Did the Data Tell the Authors of the BTP?

11. Differences Between the 60’s/70’s and Today 2006 2006 –Sr-90 < 2 pCi/L LOD –Maximum Concentration of Gross Beta in Air < 0.07 pCi/ m 3 –Average Concentration of Gross Beta in Air < 0.04 pCi/m 3 60’s and 70’s 60’s and 70’s –Maximum Sr-90 concentration was 39 pCi/L –Maximum Monthly Average Gross Beta in Air was 0.92 pCi/m 3 –Average Monthly Gross Beta Concentration in Air was 0.14 pCi/m 3 Clearly the Drafters of the BTP Never Foresaw that the Atmosphere Would Clean Itself Up and Return to Low Activity State

12. Changing Interpretation of Program Requirements Dose Calculations from Contributions of Transuranics Dose Calculations from Contributions of Transuranics No Clear Understanding of Importance of Transuranics to Overall Dose No Clear Understanding of Importance of Transuranics to Overall Dose –Is it a Test of the Program Owner Knowledge Level? –Is it a “Failure to Perform an Adequate Survey”? –Transuranic Dose Factors not Available in Reg. Guide 1.109 Transuranics Contribute an Insignificant Amount to the Overall Dose from Effluents Transuranics Contribute an Insignificant Amount to the Overall Dose from Effluents

13. Impact of Transuranics on Dose Contribution RelativeRankRadionuclideAGi (Relative Activity to Groundwater) Solubility,SiTransport,Ti Relative Dose, H i Total Relative Dose Potential, R i 1Sr-909.00E+004.00E-016.70E-022.20E+035.31E+02 2Cs-1371.30E+011.00E+003.70E-037.80E+023.75E+01 3Co-601.11E+001.00E+001.70E-024.20E+027.93E+00 4H-31.00E+001.00E+001.00E+001.00E+001.00E+00 5Cs-1341.80E-011.00E+003.70E-031.10E+037.33E-01 6I-1295.50E-061.00E+001.00E+004.30E+032.37E-02 7Ni-632.50E-011.00E+003.30E-039.00E+007.43E-03 8C-141.25E-041.00E+001.00E+003.30E+014.13E-03 9Pu-2382.60E-013.00E-051.80E-035.00E+047.02E-04 10Am-2411.50E-017.00E-055.30E-045.70E+043.17E-04 11Fe-554.00E-031.00E+006.10E-039.50E+002.32E-04 12Pu-2413.90E+003.00E-051.80E-031.10E+032.32E-04 13Pu-2403.10E-023.00E-051.80E-035.50E+049.21E-05 14Pu-2391.80E-023.00E-051.80E-035.50E+045.35E-05 16Nb-93m1.90E-034.00E-016.30E-038.20E+003.93E-05 15Cs-1359.50E-051.00E+003.70E-031.10E+023.87E-05 17Cm-2441.80E-012.00E-052.50E-043.20E+042.88E-05 18Cd-113m1.20E-033.00E-042.50E-022.50E+032.25E-05 19Nb-948.10E-054.00E-016.30E-031.10E+022.25E-05 20Ni-591.90E-031.00E+003.30E-033.30E+002.07E-05 Groundwater Monitoring Guidance for Nuclear Power Plants. EPRI, Palo Alto, CA: 2005

14. REMP Programs are Well Established REMP Programs are Well Established The BTP is Ambiguous in Many Requirements The BTP is Ambiguous in Many Requirements –Subject to Different Interpretations –Forcing Changes in these Programs The Following Examples Demonstrate where Potential Confusion Exits in the BTP The Following Examples Demonstrate where Potential Confusion Exits in the BTP Changing Interpretation of Program Requirements

15. Example 1 Given the following BTP requirements for an acceptable air monitoring program Three samples (A1-A3) from close to the three SITE BOUNDARY locations, in different sectors, of the highest calculated annual average ground-level D/Q Three samples (A1-A3) from close to the three SITE BOUNDARY locations, in different sectors, of the highest calculated annual average ground-level D/Q What is meant by “Close to the three site boundary locations… with the highest calculated annual average ground-level D/Q”? 1. Does it mean that air stations have to be relocated each year if the annual D/Q values change or is historical data based on long term (3-10 year) averaging acceptable? 2. Must air stations be located at the highest D/Q points or are the highest three D/Q sectors determined by averaging the data and then locating the sampling equipment near the site boundary where other environmental factors such as accessibility, tree cover, location to power lines acceptable?

18. Example 2 Given the following BTP requirements for an acceptable ingestion (milk) monitoring program Samples from milking animals in three locations (1a1-1a3) within 5 km distance having the highest dose potential Samples from milking animals in three locations (1a1-1a3) within 5 km distance having the highest dose potential What is meant by “highest dose potential”? 1. Is it strictly defined as highest D/Q, that is given the data presented above, the cows must be located in the E, ESE and N sectors at 396 meter from the vents? 2. Pathway must be available to have a dose potential. That is if sector E has no cows then regardless of D/Q factor there is zero dose potential. The BTP requirements continue: If there are none, then one sample from milking animals in each of three areas (1a1-1a3) between 5 to 8 km distant where doses are calculated to be greater than 1 mrem per year. If there are none, then one sample from milking animals in each of three areas (1a1-1a3) between 5 to 8 km distant where doses are calculated to be greater than 1 mrem per year. Clearly, the writers of the BTP did not expect the industry to minimize their gaseous releases.

19. Example 2 Given the following BTP requirements for an acceptable ingestion (milk) monitoring program The BTP requirements for the ingestion pathway continues with Food Products: Samples of three different kinds of broad leaf vegetation grown nearest each of two different offsite locations of highest predicted annual average ground level D/Q if milk sampling is not performed. Samples of three different kinds of broad leaf vegetation grown nearest each of two different offsite locations of highest predicted annual average ground level D/Q if milk sampling is not performed. –Recent Inspection interpreted this requirement to mean that cows must be housed at the highest D/Q location or vegetation sampling must be performed. The cows must be located in the E, ESE and N sectors at 396 meter from the vents. At many sites, because there are no gardens in the area, they substitute tree leaves 1. How is one to interpret activity found on tree leaves? What is the consumption rate of an oak leaf? 2. What are we really trying to measure? If it is deposition, then grass sampling would provide as good a measure as tree leaves. Data could be reported in pCi/m 2

20. Example 3 The BTP LLD table as detailed in NUREG 1301/1302 contains two subtle changes

21. Summary Are the Requirements of Our Primary Guidance Document the BTP Still Relevant? Are the Requirements of Our Primary Guidance Document the BTP Still Relevant? Existing Requirements Need Clarification Existing Requirements Need Clarification

22. Conclusion Words have no meaning. People have meaning. Interpretation of these Requirements should not be left to a Few. Interpretation of these Requirements should not be left to a Few. The NRC with the Membership of this Workshop should Remove the Ambiguity Present in the BTP and if Necessary Develop New Requirements for the Next Generation of Radiological Environmental Monitoring Program. The NRC with the Membership of this Workshop should Remove the Ambiguity Present in the BTP and if Necessary Develop New Requirements for the Next Generation of Radiological Environmental Monitoring Program.