Reporting Effluents (more/less) per Reg Guide 1.21

1. Reporting Effluents (more/less)per Reg Guide 1.21 Indian Point Energy Center S. Sandike June 2007

2. Reg Guide 1.21 • Main Body (Intro, Discussion, Regulatory Position) • Definitions, Details, Reg Guide 4.15 issues • Appendix A: • Measurement Details • Appendix B: • Effluent and Waste Disposal Report • Reg Guide is being updated per NEI/NRC

3. Appendix B, the report • Called both effluent and waste disposal • There was talk about separating the two • There are new and changing issues: • Ground Water – where do the doses go? • Is PWR SG Blowdown H-3 “liquid waste”? • C-14, include in dose to man, but not tables? • ISFSI and direct shine • how are we managing 25 mrem?

4. MPCs and E-bar • Reg Guide almost sounds like it’s looking for a discussion of control of RELEASE RATE per 10CFR20. • Listing MPCs (from 10CFR20, as it suggests) or average E-bar of noble gases does NOT provide this function. • If disclosure of release rate issues is desired: • Liquid: look at diluted concentration of each liquid release, and • Airborne: look at mrem/yr calculated dose rate • Do release rate issues belong in this report? • E-bar of noble gases no longer has value

5. MDA, N/D, “-”, 0, white space • What do we enter when we have determined that there is no activity present? • Per Main Body, section C, regulatory position, subsection 12, Expression of Results… • “not detected” should NOT be used • Report < max sensitivity with an actual value

6. All isotopes? • Certainly ALL isotopes should not be listed with a less than sign if not detected (?) • Define a typical MDA in the text? • Use ODCM? • Which isotopes need this? • Suggestion: Tables 1A & 2A only • Particularly Iodine

7. Batch Release Times • Why is this here? • NUREG 0133 definition of short term/long term application of MET data • The data can be skewed: • Some BATCH releases are purposefully split when entered into a database. • The resulting RG 1.21 report prints two or more smaller releases where in reality, one longer one was performed (VC Purge).

8. “Average Stream Flows” • The request is for a “flow rate of a stream”, it’s applicable only for periods of effluent into the stream. • This is not “dilution flow”, nor is it the Near Field Dilution Factor, nor the “applicable factor” from NUREG 0133 (mixing factor) • Leftover from LADTAP for use in old liquid dose calculations. Any value today ?

9. Abby- Normal vs Unplanned • “Abnormal” is defined in RG 1.21: “Unplanned or uncontrolled release of radioactive material from the site boundary” • From here, we can apply NRC HPPOS 254 for definition of UNPLANNED release.

10. Percent Tech Spec Limit • Limit in curies – ancient history • So do we continue to try to quote a % limit? • Iodine/Part/H-3 all have same limit. • Suggestion: Defer this objective completely to the dose to man section.

11. Liquid Waste Volume • Table 2A, section E = volume of waste • After NEI initiative and GW awakening: H-3 = Waste • PWRs will have H-3 in secondary loop • Is SG Blowdown “waste” ?

13. PWR waste volumes • Significant diversity suggests some are calling SG Blowdown “waste”, and some are not. • Suggestion: Since RG 1.21 is being evaluated…. Let’s consider subsections to Section E. • Processed Waste and Unprocessed Waste

14. Current (experimental?) IPEC liquid waste RG 1.21

15. Gross Alpha • Generally regarded as a less than value • What to do with one slight positive in a sea of sample results below MDA? • Verify any positive value • Perform critical level test • Investigate likelihood of an actual positive test • Trend these occurrences • Identify chosen method of reporting in text

16. Radiological Impact on Man • App B, Section E, seems to suggest a report of dose “to individuals and populations”… • Using “measured effluent and met data”? • Still talks about semi-annual • Other specific dose information, which EXCEEDS that routinely identified with Maximum Individual methodology.

17. Population Doses / Direct Shine • RG 1.12 also suggests a type of population dose assessment – out to 50 miles from site. • “If a significantly large population area is located just beyond 50 miles from the site, the dose”…should be considered. • TB doses due to direct radiation from the facility (adopted as 40CFR190 requirements).

18. How much is enough? • Our ODCMs generally do NOT included guidance or direction for population dose. • Dose to Man section of the report is generally only the 5 App I items: • Liq Whole Body & Critical Organ dose • Airborne Iodine/Particulate/H-3 mrem • Airborne noble gas air mrad, beta & gamma • Are we expected to construct a population dose model?

19. Effluents and Visitors on site • Wording of requirements suggests that the Dose to Man section include a determination of the accumulated dose of Members of the Public, visiting the site, DUE TO SITE EFFLUENTS. • Apply conservative occupancy factors • Demonstrate negligible • Is this a national standard or expectation with NRC?

20. Total Dose (40CFR190) • There are many components to total dose. • RG1.21, App B, Section E might include: • Effluents - will probably be the least significant, • Followed by Ground Water (w/Sr-90 if your unlucky), • Then C-14, based on Eff Full Power Hours, etc, • Then Radwaste Storage, Holding Pens, etc, • ISFSI No question, the most significant !

21. IPEC example, 2006

22. Notes • Note 1: Groundwater curie and dose calculations are provided in a Section H. (a later section in my RG 1.21 report) • Note 2: The direct shine component is indistinguishable from background. Seven mrem is conservatively used from a one mrem siting criteria established for each area.

23. Trying to sum the doses There are multiple issues with Note 2 ! For example… The Monte Carlo testing ensured < 1 mrem (or other bounding value) at the nearest SB point, for each area. These were siting criteria, not live, continuous, or even one-time actual measurements. Summing the siting criteria doses and displaying them as such is very conservative, and potentially MISLEADING. Oops…. My bad…. UCS made special note of this:

24. Dave Lochbaum, UCS "Even if the groundwater was 100 times more than it is presently thought to be, it would still be about 40 times lower than the radwaste storage dose“ "Or, there would be more to gain by putting up a wall to reduce the radwaste storage dose than to completely eliminate the groundwater leakage dose."

25. Fix the direct shine report • It appears we need either more discussion, or a better number reported here. • Do it now, before ISFSI • What are current ISFSI plants reporting?

26. Radiological Impact on Man • No uniformity between utilities • Little guidance as to how to determine or implement the SPIRIT of the guide. • Where / how is this data used ? • Not much chance of making ANY one plan work for all plants! • (which is probably why curies are used to track performance , rather than dose !)

27. MET data • Does it need to be included with each report? • OK to just have available on site? • Identify all instruments in service > 90% • Discuss use of annual average met data in text • Merge requirements with NUMUG.

28. The NEW reg guide • Standardization effort: • Content, then format • Electronic, online submittals • Industry peer group with NEI • How are volunteers identified? • How can we make our VPs aware • Help from NEI to VPs, not just us !