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

2. Reasons for Environmental Monitoring
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

3. 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.

4. Critical Components of the REMP
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

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

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

7. Dispersion and Deposition in Environment
Reg Guide 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

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

9. Transitory Exposure Pathway
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.

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

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

12. Integrating Exposure Pathway
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.

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

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

15. Cumulative-Integrating Exposure Pathway
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.

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

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

18. Sampling 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.

19. Useful Aquatic Indicators
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
Mention San Onofre and Kougergh Kelp Problems
Kubergh from Medical discharges
Mention Algae event at Big Rock Point

20. Leafy Vegetation 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.”

21. Leafy Vegetation - Substitute
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

22. Other Vegetation
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.

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

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

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

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

27. Relationship of the REMP to the ODCM - I
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.

28. Relationship of the REMP to the ODCM - II
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.

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

30. Relationship of the REMP to the ODCM - IV
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.

31. Relationship of the REMP to the ODCM - V
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.

32. Site Specific ODCM Parameters Which Have Greatest Effect On Dose - I
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

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

34. Site Specific ODCM Parameters Which Have Greatest Effect On Dose - III
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

35. Correlation of Effluent Concentrations with Concentrations in the Environment
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.

36. Correlation of Effluent Concentrations with Concentrations in the Environment
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

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. Predicted Cow Milk Concentrations
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