REMP ReportsREMP Reports

Improvements?Improvements?

Why? Why now?Why? Why now?

NRC/Public Interest (plant life extension, new plants, NRC/Public Interest (plant life extension, new plants, Fukushima)Fukushima)

Differences at various sites (Millstone, IPEC, and others Differences at various sites (Millstone, IPEC, and others (e.g. my assist visits), NRC recommendations on model (e.g. my assist visits), NRC recommendations on model programs, vendor concerns about differences)programs, vendor concerns about differences)

Corporate “models”Corporate “models” MARLAP, NUREG/CR-4007, NUREG-0475, HASLMARLAP, NUREG/CR-4007, NUREG-0475, HASL RADNET RADNET NAS Cancer StudyNAS Cancer Study Revisions to Regulations, Reg. Guides and NUREGsRevisions to Regulations, Reg. Guides and NUREGs

Items for ImprovementItems for Improvement

User Friendly Information (generally for User Friendly Information (generally for the Public)the Public)

Plots and TrendsPlots and Trends Summary TablesSummary Tables Raw Data presentation – my primary Raw Data presentation – my primary

concernconcern

User Friendly InformationUser Friendly Information

Pilgrim and Millstone have nice discussions on Pilgrim and Millstone have nice discussions on how nuclear power plants work and the potential how nuclear power plants work and the potential environmental impacts, including background environmental impacts, including background radiation information from NCRP 160 – planning radiation information from NCRP 160 – planning to do the same for IPECto do the same for IPEC

Also want to tie in the RERRs with the AREORs Also want to tie in the RERRs with the AREORs - Millstone has a thorough discussion of effluents - Millstone has a thorough discussion of effluents and effluent monitoring in its RERR – planning to and effluent monitoring in its RERR – planning to do something similar at IPECdo something similar at IPEC

Plots and TrendsPlots and Trends

Beaver Valley, Southern Nuclear and others have great Beaver Valley, Southern Nuclear and others have great information (however, some plots which show pre-information (however, some plots which show pre-operational data may actually show operational data may actually show “less than” values“less than” values – – some of these have plots showing fallout levels in air some of these have plots showing fallout levels in air particulates from the early 70’s thru today (Chinese particulates from the early 70’s thru today (Chinese weapon tests, Chernobyl, etc.) – these reports are good weapon tests, Chernobyl, etc.) – these reports are good examples for these plots/trendsexamples for these plots/trends

Millstone has several good trends (see Figure 2.12 in Millstone has several good trends (see Figure 2.12 in NAS Phase I - Draft)NAS Phase I - Draft)

5 year, 10 year, and lifetime trends (pros & cons, e.g., 5 year, 10 year, and lifetime trends (pros & cons, e.g., complete history vs. “resolution”)complete history vs. “resolution”)

Millstone figureMillstone figure

Millstone figureMillstone figure

MillstoneMillstone

Summary TablesSummary Tables NUREG 1301 & 1302 (BTP on REMP) – recommends format for NUREG 1301 & 1302 (BTP on REMP) – recommends format for

Summary Table –average only positive results – bad practice, overly Summary Table –average only positive results – bad practice, overly conservative especially when only a small percentage of the conservative especially when only a small percentage of the samples are positive – NAS Phase I Draft uses the summary table samples are positive – NAS Phase I Draft uses the summary table results in their report (Tables 2.14, 2.15)results in their report (Tables 2.14, 2.15)

NUREG/CR-4007 –NUREG/CR-4007 – pages 57-60 , 76pages 57-60 , 76 – “Quality data, poorly – “Quality data, poorly reported, leads to needless information loss…” “…, the reported, leads to needless information loss…” “…, the experimental result and its associated uncertainty should be experimental result and its associated uncertainty should be recorded, even if it should be a negative number. (Proper averaging recorded, even if it should be a negative number. (Proper averaging is otherwise impossible, except with certain techniques devised for is otherwise impossible, except with certain techniques devised for “censored” (but not truncated) data.)”“censored” (but not truncated) data.)”

HASL (now EML) - ("Reporting of Analytical Results from HASL," HASL (now EML) - ("Reporting of Analytical Results from HASL," letter by Leo B. Higginbotham letter by Leo B. Higginbotham

NUREG – 0475 – page 9NUREG – 0475 – page 9

NUREG 0475 - page 9NUREG 0475 - page 9

MARLAPMARLAP

MARLAP recommends that the reported value of a MARLAP recommends that the reported value of a measurement result: (1) be reported directlymeasurement result: (1) be reported directly

as obtained, with appropriate units, even if it is are as obtained, with appropriate units, even if it is are negative, (2) be expressed in an appropriatenegative, (2) be expressed in an appropriate

number of significant figures, and (3) include an number of significant figures, and (3) include an unambiguous statement of the uncertainty. Theunambiguous statement of the uncertainty. The

appropriate number of significant figures is determined appropriate number of significant figures is determined by the magnitude of uncertainty in theby the magnitude of uncertainty in the

reported value. Each reported measurement result reported value. Each reported measurement result should include the value and an estimate of theshould include the value and an estimate of the

combined standard uncertainty (ANSI N42.23) or the combined standard uncertainty (ANSI N42.23) or the expanded uncertainty.expanded uncertainty.

Raw Data presentationRaw Data presentation Since averaging should include “all results”, why not show all the Since averaging should include “all results”, why not show all the

results in the data tables? (some sites don’t even show these tables, results in the data tables? (some sites don’t even show these tables, why not?) why not?)

RADNETRADNET Location: Location: EPA Region 01EPA Region 01 Medium: Medium: SURFACE WATERSURFACE WATER Nuclides/Radiation: Nuclides/Radiation: TritiumTritium Units: Units: TraditionalTraditional Year Date Range : Year Date Range : 19781978 - - 20122012 Note: Note: Before September 1995, tritium results were calculated Before September 1995, tritium results were calculated manually and rounded to the nearest 100 pCi/L (or 0.1 nCi/L). manually and rounded to the nearest 100 pCi/L (or 0.1 nCi/L). Tritium results less than 100 pCi/L were recorded as 100 pCi/L. Tritium results less than 100 pCi/L were recorded as 100 pCi/L. Since September 1995 computer software has been used for the Since September 1995 computer software has been used for the calculation and all results have been recorded as obtained. The pre-calculation and all results have been recorded as obtained. The pre-1995 practice created a positive bias in the measured tritium 1995 practice created a positive bias in the measured tritium concentrations, which is clearly visible in graphs.concentrations, which is clearly visible in graphs.

Raw Data presentationRaw Data presentation A few sites have been reporting “all the data” for years – over 35 A few sites have been reporting “all the data” for years – over 35

years for Millstone – it hasn’t presented any problemsyears for Millstone – it hasn’t presented any problems

Although this does not seem to be “the norm” (for utilities, but it is for Although this does not seem to be “the norm” (for utilities, but it is for

the government), itthe government), it will provide more useful data (lessen misuses, will provide more useful data (lessen misuses, better trends/plots, better history, …), I really feel it is an important better trends/plots, better history, …), I really feel it is an important improvementimprovement

It’s time for change – let’s educate the public on it – any It’s time for change – let’s educate the public on it – any recommendations????recommendations????

ConclusionConclusion Improvements can be made by adding a few Improvements can be made by adding a few

pages on general informationpages on general information Trends/plots can be improved – better Trends/plots can be improved – better

comparisons to pre-operation or other “historical comparisons to pre-operation or other “historical data”data”

All data (+, zeros and -) need to be used when All data (+, zeros and -) need to be used when performing averagesperforming averages

All data should be presented (positive data, All data should be presented (positive data, especially plant related can be “highlighted” to especially plant related can be “highlighted” to indicate which are actually “positive”) – these indicate which are actually “positive”) – these should be discussed in the “discussion” anywayshould be discussed in the “discussion” anyway

Comments/QuestionsComments/Questions