1. REMP Sampling Strategy 2004 RETS/REMP Workshop Jim Key Key Solutions, Inc. www.keysolutionsinc.com

2. Reasons for Radiological Environmental Monitoring Document Compliance with Regulations Verify Functioning of Effluent Controls Assess Impact of Releases Provide Timely Assessment of Accidental Releases

3. Reasons for Radiological Environmental Monitoring Provide Information to Public Provide Documentation for Litigation Defense Identify Trends Related to Plant Releases

4. Many Different Sources of Radiological Materials in the Environment Natural Power Production Industrial Military Medical

5. REMP Program Must Be Able To Answer the Question…

6. Who Made the Release?

7. REMP Monitoring Pathways Generally Focuses on Monitoring Pathways Likely to Generate the Highest Dose to Man Looks Only at Groups or Individuals Most Likely to Receive the Highest Dose May or May Not Be the Best Indicator of Environmental Impact

8. REMPGuidance NRC –NUREGs 0472, 0473, 0475, 1301, 1302 –Reg Guides 4.1, 4.8 EPA –“Environmental Radioactivity Surveillance Guide”, June 1972, ORP/SID 72-2. ANI

9. Some Considerations for Sampling Air Particulate Liquid Shoreline and Sediment Vegetation

10. Factors That Impact Representative Air Sampling Micrometeorological Conditions Vegetation that Serves as a Sink Shielding from Nearby Structures Resuspension Caused by Human Activities

11. Guidelines for Air Sampling EPA –“Network Design and Optimum Site Exposure Criteria for Particulate Matter, “ EPA-450/4-87-009. www.epa.gov/ttn/amtic/files/ambient/critera/reldocs ASTM –“Standard Guide for Choosing Locations and Sampling Methods to Monitor Atmospheric Deposition at Non- Urban Locations,” ASTM D 5111-95, American Society for Testing and Materials, 1995.

12. Guidelines for Air Sample Location Homogeneous Ground Cover Naturally Vegetated or Grass Open Level Slope No Greater Than 15%

13. 2-15 m Above Ground –As Near to Breathing Height as Possible Orient Towards Average Prevailing Wind Minimum 2 m Away Horizontally from Supporting Structures or Walls Guidelines for Air Sample Location

14. Maintain Seasonal Vegetation at Site at Least 1 m Below Sampling Intake Minimum 20 m from Tree Drip Line Guidelines for Air Sample Location

15. No Nearby Obstructions to Air Flow in Direction of Prevalent Wind From: –Buildings –Structures –Terrain Guidelines for Air Sample Location

16. Want to Sample Particulates Transported into Area, Not Local Dust Avoid Areas of High Resuspension Potential –Within 40 m of Major Highways –Unpaved Roads –Construction Sites –Areas of Heavy Agricultural Use Guidelines for Air Sample Location

17. Liquid Sampling Considerations Control Sample Location Should Be Upstream Such That Facility Has No Influence on Sample Content Avoid Locations Where Current Reversal from Tidal Flow Could Contaminate Control Samples

18. Liquid Sampling Considerations Primary Sample Should Be Located: –Near Discharge –But Outside of Turbulent Mixing Zone (Near Field) –Rule of Thumb for Rivers: 10 x Stream Width to Allow for Mixing

19. Liquid Sampling Considerations Liquid Releases Tend to be Periodic Grab Sampling of Questionable Value NUREGs Require Composite Samplers If Grab Sampling Performed, Need: –Date/Time of Sample –Plant Discharge Rate –Stream Flow Rate

20. Shoreline Sediment Considerations NUREGs Require –Sample from Downstream Area with Existing or Potential Recreational Value –Control Location Not Required, But Very Good Idea

21. Sediment Sampling Additional Locations Should Be Sampled to Determine Appropriateness of Routine Sample Sites Downstream Sample Should Be Taken Where Stream Flow is Greatest Samples Should Also Be taken in Areas that Favor Sedimentation

22. Sedimentation Greatest At: Inner Bank of River Behind Dams River Widenings Freshwater/Saltwater Interfaces –Precipitation –Flocculation

23. Sedimentation Samples Activity in Sediment Samples Do Not Necessarily Reflect Most Recent Release Only Top Layer or Most Recent Sediment Should Be Sampled

24. Sediment Sampling Locations

25. Leafy Vegetation Sampling Required to Sample “Broad Leaf Vegetation” –“Similar to Lettuce and Cabbage” –Turnips (leafy portion) –Spinach –Celery

26. Broad Leaf Vegetation Well Defined Leaf Blades Relatively Wide in Outline –(Not Needle or Linear) Leaf Area Typically Greater than 1 Square Inch http://biology.usgs.gov/fgdc.veg/standards/appendix3.htm

27. Broad Leaf Vegetation Examples of Edible Broad Leaf Vegetation Where Leafy Portion is Consumed –Cabbage, Lettuce, Turnips (the leafy portion), Spinach, Celery

28. Edible Broad Leaf Vegetation Examples of Edible Broad Leaf Vegetation Where Leafy Portion is Not Consumed –Corn, Sugar Beet, Peas, Beans, Soybean, Potato, Cucumber, Kohlrabi, Tomato, Zucchini, Pokeweed

29. Leafy Vegetation Sampling What if Broad Leaf Unavailable? Reg Guide 4.8 –“Nonedible Plants With Similar Characteristics [Broad Leaf] May Be Substituted.”

30. Non-Edible Broad Leaf Vegetation Examples of Nonedible Broad Leaf Vegetation –Tobacco, Fast Growing Ornamentals –Avoid Slow Growing Plant Which Would Integrate Activity Over a Long Period

31. Does Not Qualify for Sampling Why Not? –Not Broad Leaf –Not Typical Ingestion Pathway –May Be Inhalation Pathway (Unless can Document “Did not inhale.”)

32. Potential Problems Regulatory Guidance –Monitor Pathways With Highest Dose Potential to Man –Monitor Populations With Highest Dose Potential –Monitor Agricultural Food Pathways Problems –Ag Food Pathways Disappearing –Some REMP Samples Difficult to Obtain –Measurable Environmental Concentrations Exist in Media that We Do Not Routinely Monitor

33. Time For A New Paradigm? Interveners –Monitor Other Pathways and Locations –C-14 (Europe) –Sr-90 (Tooth Fairy Project) –I-131 (Medical Sources) –Co-60/Cs-137/Am-241/etc. (Industrial Sources)

34. Or Time For Paranoia? ANI –“While most releases to the environment are below regulatory limits, discharging within regulatory limits does not preclude a claim.” –“…litigation potential is increasing as reactor years of operation are accumulating.”