1. REMP Ramblings 2006 RETS/REMP Workshop Jim Key Key Solutions, Inc. www.keysolutionsinc.com

2. Regulatory Requirements for the REMP The Radiological Environmental Monitoring Program is Required by 10 CFR 50, Appendix I, Section IV.B.2 and IV.B.3. Focus Is On: –Dose to Individuals –Principal Pathways of Exposure

3. The NRC and REMP Radiological Assessment Branch Technical Position, Rev 1, Nov 1979, “An Acceptable Radiological Environmental Monitoring Program” Guidance for details of REMP provided in NUREGs 0472, 0473, 1301 and 1302.

4. The NRC and REMP Branch Technical Position Sets Forth an “Acceptable Minimum Radiological Monitoring Program” An Acceptable Monitoring Program Does Not Guarantee an Effective Monitoring Program

5. Original NRC REMP Program Design Was Driven By: Monitoring of Human Food Chain –Does not necessarily insure accurate assessment of environmental impact. –More environmentally sensitive indicators may be overlooked. Assumed Demographics Assumed Environmental Usage (Agricultural) Assumed Likely Critical Exposure Pathways

6. REMP Program Based On NRC Assumptions (30 years ago) Are Assumed Demographics Still Valid at Your Site? Is Assumed Environmental Usage Still Valid at Your Site? Are Assumed Critical Pathways Still Valid at Your Site? Are There Non-Critical Pathways That Need Monitoring – More Environmentally Sensitive?

7. Ground Water Grumblings Average per capita Consumption of Water is 185 gal/da. Subdivision of 50 Houses (3 individuals per house) ~ 10,000,000 gal/yr Could Have Significant Effect on Local Aquifer

8. Ground Water Grumblings UFSAR Hydrology Data Decades Old Consumption from Local Aquifers –Potential to Modify Aquifer Gradient –Aquifer Flow May Be Retarded or Increased –Result  Transport of H-3 in Groundwater Not Properly Understood If in Doubt “Back of the Envelope” Calculations Should be Considered to Determine Need for Additional Study

9. Spills and Thrills Need to Review Past Site Contamination Incidents –Attitude Towards On-Site Spills Was Different in Past Hot Spills or High Volume Spills –How Much Activity Was Recovered –How Much Activity Unaccounted For (and Still Out There?) –What is the Potential for Migration on Site and Off Site?

10. How Low Do We Go?

11. Where Did the LLD Number Come From? LLDs in Current Guidance Based On “What (we thought) the technology would be capable of by the time the RETS were in force.” Based on 30+ Year Old Technology

12. How Low Do We Go? Reg Guide 4.1 “…the detection capability of environmental measurements should be the most sensitive that is practicably achievable for measuring plant- contributed radionuclides in the environment.”

13. NRC Environmental Reporting Levels NuclideWaterAirborneFishMilkFood pCi/lpCi/m 3 pCi/KgpCi/lpCi/Kg H-320,000 Mn-541,00030,000 Fe-5940010,000 Co-581,00030,000 Co-6030010,000 Zn-6530020,000 Nb-95400 Zr-95400 I-13120.93100 Cs-13430101,000601,000 Cs-13750202,000702,000 Ba-140200300 La-140200300

14. Annual Doses Associated With Reporting Levels NuclideWaterAirborneFishMilkFood mrem H-32.1 Mn-5410.28.8 Fe-599.97.1 Co-5811.09.5 Co-608.88.4 Zn-656.26.5 Nb-956.1 Zr-959.0 I-1319.214.613.814.9 Cs-1347.011.33.213.910.0 Cs-13710.118.14.814.117.0 Ba-14011.316.9 La-14013.511.8

15. NRC Environmental LLDs NuclideWaterAirborneFishMilkFoodSediment pCi/lpCi/m 3 pCi/KgpCi/lpCi/Kg H-32000 Mn-5415130 Fe-5930260 Co-5815130 Co-6015130 Zn-6530260 Nb-9515 Zr-9515 I-13110.07160 Cs-134150.051301560150 Cs-137180.061501880180 Ba-14015 La-14015

16. Annual Doses Associated With Environmental LLDs NuclideWaterAirborneFishMilkFoodSediment mrem H-30.21 Mn-540.150.04 Fe-590.740.19 Co-580.170.04 Co-600.440.11 Zn-650.620.08 Nb-950.23 Zr-950.34 I-1314.591.144.598.92 Cs-1343.480.060.413.480.604.8E-03 Cs-1373.630.050.363.630.682.0E-03 Ba-1400.85 La-1401.010.59

17. How Low Do We Go? Ideally Environmental Detection Limits Should be a Small Fraction of the Reporting Limits This Implies LLDs of 1% – 5% of Reporting Limit NUREGs Specify (Drinking Water) –10% for Tritium –36% for Cs-137 –50% for I-131

18. Tritium LLD Should We Go Lower? Yes – Why? –Reg. Guide 4.1 – “the detection capability of environmental measurements should be the most sensitive that is practicably achievable…” –State-of-the-Art Has Improved Dramatically in 30 years. –Public Relations –Must Get Out of Reactive Mode

19. Where Do We Stop? Depends – How Paranoid Are You?

20. Tritium – How Low Do We Go? 2000 pCi/L 1000 pCi/L 500 pCi/L 400 pCi/L 200 pCi/L 100 pCi/L

21. What Is Good Stopping Point? % Rpt Lmt Comments 2000 pCi/L10 % Current Requirement 1000 pCi/L5 % Could Do Better 500 pCi/L2.5 % Good 400 pCi/L2 % Good 200 pCi/L1 % Some Plants Are Currently Measuring In This Range 100 pCi/L0.5 %

22. Washing Vegetation IAEA Technical Report 364 Lists Decontamination Factors for Food Preparation Factors Provided For: –Total Contamination of Plant (root and leaf) –External Contamination (deposition on leafy portion)

23. Decon Factors for Washing (External Contamination) SrCsI Cabbage 0.90.5 Cauliflower 0.05 – 0.20.03 Lettuce 0.2 – 1.00.1 – 0.5 Spinach 0.20.2 - 0.90.07 – 0.8

24. To Wash or Not to Wash? RETS-REMP Steering Committee Recommendation –Wash if used for human consumption. –Do not wash if used for animal consumption. Caveat –Important to Maintain Consistency for Purposes of Historical Comparison

25. There Are Others Out There… NRC and EPA Regs Are Not the Only Requirements Don’t Forget State Environmental Regs One Utility Hit By Recent Change (2002) in State Regs Which Required Reporting of Any Environmental Results Above LLD Background

26. Meteorology How Old is the Met Data Used to Generate Your  /Q and D/Q? FSAR Values Probably 20 – 30 Years Old How Many Years of Met Data Are You Using for  /Q and D/Q? –1 Year? – Should Update Annually –5 Years? – Good But How Old?

27. Meteorology Does Your  /Q and D/Q Still Adequately Characterize Current Atmospheric Transport? Can You Prove It? –Need to Look at Wind Rose Data –Need to Look at Stability Class Frequency Be Prepared to Answer this Question…

28. Industry Has Been Content to Carry Around REMP Box as Defined by Regulatory Guidance –Assumed No Need to Look Outside of Box –Is Current Guidance Too Narrowly Focused? – Could Be Time to Think Outside the REMP Box