REMP Ramblings

1
REMP Ramblings
2006 RETS/REMP Workshop Jim Key Key Solutions,
Inc. www.keysolutionsinc.com
2
Regulatory Requirementsfor 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?
LLD
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
Nuclide Water Airborne Fish Milk Food
pCi/l pCi/m3 pCi/Kg pCi/l pCi/Kg
H-3 20,000
Mn-54 1,000 30,000
Fe-59 400 10,000
Co-58 1,000 30,000
Co-60 300 10,000
Zn-65 300 20,000
Nb-95 400
Zr-95 400
I-131 2 0.9 3 100
Cs-134 30 10 1,000 60 1,000
Cs-137 50 20 2,000 70 2,000
Ba-140 200 300
La-140 200 300
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Annual Doses Associated With Reporting Levels
Nuclide Water Airborne Fish Milk Food
mrem mrem mrem mrem mrem
H-3 2.1
Mn-54 10.2 8.8
Fe-59 9.9 7.1
Co-58 11.0 9.5
Co-60 8.8 8.4
Zn-65 6.2 6.5
Nb-95 6.1
Zr-95 9.0
I-131 9.2 14.6 13.8 14.9
Cs-134 7.0 11.3 3.2 13.9 10.0
Cs-137 10.1 18.1 4.8 14.1 17.0
Ba-140 11.3 16.9
La-140 13.5 11.8
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NRC Environmental LLDs
Nuclide Water Airborne Fish Milk Food Sediment
pCi/l pCi/m3 pCi/Kg pCi/l pCi/Kg pCi/Kg
H-3 2000
Mn-54 15 130
Fe-59 30 260
Co-58 15 130
Co-60 15 130
Zn-65 30 260
Nb-95 15
Zr-95 15
I-131 1 0.07 1 60
Cs-134 15 0.05 130 15 60 150
Cs-137 18 0.06 150 18 80 180
Ba-140 15 15
La-140 15 15
16
Annual Doses Associated With Environmental LLDs
Nuclide Water Airborne Fish Milk Food Sediment
mrem mrem mrem mrem mrem mrem
H-3 0.21
Mn-54 0.15 0.04
Fe-59 0.74 0.19
Co-58 0.17 0.04
Co-60 0.44 0.11
Zn-65 0.62 0.08
Nb-95 0.23
Zr-95 0.34
I-131 4.59 1.14 4.59 8.92
Cs-134 3.48 0.06 0.41 3.48 0.60 4.8E-03
Cs-137 3.63 0.05 0.36 3.63 0.68 2.0E-03
Ba-140 0.85 0.85
La-140 1.01 0.59
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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

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Tritium LLDShould 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/L 10 Current Requirement
1000 pCi/L 5 Could Do Better
500 pCi/L 2.5 Good
400 pCi/L 2 Good
200 pCi/L 1 Some Plants Are Currently Measuring In This Range
100 pCi/L 0.5 Some Plants Are Currently Measuring In This Range
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)

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Decon Factors for Washing(External Contamination)
Sr Cs I
Cabbage 0.9 0.5
Cauliflower 0.05 0.2 0.03
Lettuce 0.2 1.0 0.1 0.5
Spinach 0.2 0.2 - 0.9 0.07 0.8
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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
• Dont 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

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• 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