REMP Sampling Strategy

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

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

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

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

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

6. Who Made the Release?

7. 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 REMP Monitoring Pathways

8. 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 REMP Guidance

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

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

11. 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. Guidelines for Air Sampling

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

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. 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 Liquid Sampling Considerations

18. 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 Liquid Sampling Considerations

19. 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 Liquid Sampling Considerations

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

21. 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 Sediment Sampling

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

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

24. Sediment Sampling Locations

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

26. 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 Broad Leaf Vegetation

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

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

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

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

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

32. 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 Potential Problems

33. 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) Time For A New Paradigm?

34. 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.” Or Time For Paranoia?