**NRC INSPECTION MANUAL** CHPB

INSPECTION PROCEDURE 80522

PART 52, RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (REMP)

PROGRAM APPLICABILITY: 2504

80522 - 01 INSPECTION OBJECTIVE

01.01 To inspect for compliance with 10 CFR 20.1301 and 20.1302, 10 CFR
50, Appendix I, and 40 CFR 190. Based on, the programmatic controls of
the Radiological Effluent Technical Specifications (RETS) as expressed
in the Offsite Dose Calculation Manual (ODCM).

01.02 To determine if the radiological environmental monitoring program
meets its intended objective of ensuring conformance with public dose
limits published in 10 CFR 20, ensuring public radiation doses are
maintained As Low As Reasonably Achievable (ALARA) in accordance with
the requirements of 10 CFR 50, and ensuring that the Radiological
Environmental Monitoring Program (REMP) provides an independent check on
the adequacy of the RETS. This inspection procedure focuses on the
REMP=s readiness for use by plant personnel.

80522 - 02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 [Readiness of the Radiological Environmental Monitoring Program
(REMP).]{.underline} Determine that the REMP is ready to operate under
normal and emergency conditions by conducting verification and
inspection of the following:

a\. Verify that the licensee/applicant established offsite sampling and
monitoring stations consistent with guidance in Regulatory Guides 4.1
and 4.8 and NUREGs 1301 and 1302. Consider site characteristics, plant
design, and operations to ascertain that the licensee has identified the
relevant exposure locations. Compare the radiological monitoring program
described in section 6.2 of the most recent version of the Environmental
Report (ER) to that implemented and to that described in the ODCM.
Determine if the monitoring and sampling stations are consistent with
the ER, ODCM, and current land use census

b\. Inspect the monitoring and sampling equipment. Determine that they
are correct for their use and are operational. Compare the monitors to
the monitoring system described in the ER and ODCM to ensure
consistency. This is a readiness inspection, and the inspector is
reminded to walk-down all sampling and direct monitoring stations to
determine that they are properly sited and consistent with the ODCM.

[Guidance:]{.underline} Technical guidance can be found in Regulatory
Guides 4.1, 4.15, 4.8, 1.97, NUREG-1301 (PWR) or NUREG-1302 (BWR), ESRP
6.2, Radiological Assessment Branch Technical Position (Rev.1, November
1979) and ANS N320-1979.

c\. Review the licensee=s Standard Operating Procedures (SOPs) for the
operation and use of instruments and samplers. Review the SOPs for
sample handling and processing to insure that the procedures are correct
and satisfy regulatory requirements (for example, sample transport,
preservation, change-out, and chain of custody.) Verify that the staff
has been trained on the purpose and scope of the REMP and is
implementing the SOPs.

d\. Verify that the licensee has a program in place to ensure that
sampling stations and equipment are properly maintained, inspected, and
repaired.

[Guidance]{.underline}: The program should include evaluating the dose
consequences associated with equipment that is inoperable or out of
calibration.

e\. Compare the radiological environmental monitoring program controls
and surveillance requirements in the ODCM to those in sections 3.12.1
and 4.12.1 of NUREG-1301(PWR) or NUREG-1302 (BWR). Verify that the REMP
meets the minimum specifications.

[Guidance]{.underline}: These requirements and controls should include
the exposure pathway to be monitored, number of representative samples
and sampling location, sampling/collection frequency, types of analysis,
reporting levels, lower limits of detection (LLD), remedial actions when
actual performance deviates from the program and when reporting levels
are exceeded.

f\. Determine that the volumes or mass of the samples specified in the
sampling SOPs are enough to attain the desired detection limits in
NUREG-1301 or 1302. Verify that the REMP contains reporting provisions
consistent with NUREG-1301 or 1302.

[Guidance:]{.underline} Inspectors are referred to NUREG-0133, and
Regulatory Guides 1.21, 4.1, and 4.8, and Radiological Assessment Branch
Technical Position (Rev.1, November 1979).

g\. Confirm that environmental samples include milk animals and food
products in addition to all other sample media specified in NUREGs-1301
and 1302. If some types of media are not available, confirm that the
licensee has provided adequate justifications for their omissions and
substituted alternate media in maintaining the objectives of the REMP.

[Guidance:]{.underline} Samples from milk animals are a better indicator
of radioiodine in the environment compared to vegetation. If however,
the census reveals that no milk animals are available for sampling, then
vegetation can be sampled in lieu of milk.

h\. Determine if direct radiation monitoring stations are located as
described in the ODCM consistent with the Branch Technical Position.
Verify that thermo luminosity detector (TLD) stations are positioned in
a sufficient number of areas to assess the public dose impact from any
sources of external radiation located in areas near the site boundary.

[Guidance:]{.underline} The inspectors should determine that special
interest areas such as population centers, residences near the site
boundary, schools, and radioactive waste storage buildings are monitored
appropriately.

02.02 [Implementation of the Meteorological Monitoring
Program.]{.underline} Determine that the meteorological monitoring
program is operational and adequate for normal and emergency operations
by conducting verification and inspection of the following:

a\. Verify that the licensee/applicant has established a working
meteorological program according to the guidance in Regulatory Guide
1.23. Compare the monitoring program described in section 2.3.3 of the
most recent version of the Final Safety Analysis Report (FSAR) to that
in actual use. Determine that meteorological monitoring program is
consistent with the FSAR.

b\. Determine if the equipment and instrumentation described in FSAR
section 2.3.3 is operable, properly calibrated, and maintained. Verify
that a program is in place to ensure its operability and calibration.

c\. Review the licensee=s procedures for the operation, calibration, and
maintenance of meteorological instruments to ensure that procedures are
consistent with Regulatory Guide 1.23. Verify that the staff has been
trained on the SOPs for use and maintenance of meteorological
instruments.

d\. Review the equipment maintenance records to assure that the licensee
performs preventative maintenance and repairs/replaces inoperable
equipment in a timely manner.

e\. Determine through direct observation that the meteorological tower
(and backup tower if present) is located to eliminate interferences from
man-made or natural obstructions which could impair the quality of the
meteorological data. Determine that meteorological tower instrumentation
is properly positioned to eliminate interferences from the tower itself.

[Guidance:]{.underline} Technical guidance can be found in Regulatory
Guide 1.23, ANSI/ANS-3.11-2005 and IAEA Safety Series No. 50-5G-S3.

f\. Verify that the licensee has properly identified the highest
locations for dispersion and deposition and used these locations for
placement of monitoring equipment.

02.03 [Program Management.]{.underline} Determine that the licensee has
a management program to maintain the REMP by verification of the
following:

a\. Review the REMP to determine if the Quality Assurance/Quality
Control measures recommended in Regulatory Guides 4.15, 4.8 and 1.21,
NUREG-1301 or NUREG-1302, and NUREG-0133 are being followed.

b\. Verify that the licensee is following quality control measures
specified in the OCDM, the licensee=s QA program, and SOPs. This
verification should include:

1\. a review of licensee's procedures for calibration and maintenance of
environmental air samplers and composite water samplers;

2\. a review of the licensee/applicant procedures for calibration and
quality control (e.g., daily QC checks) for analytical instrumentation
(count room equipment) used for environmental sample analyses;

3\. a review of the licensee/applicant=s program which verifies its
capabilities to perform adequate environmental sample analyses such as
participation in a inter-laboratory comparison program;

4\. a determination, if applicable, of participation in an
interlaboratory comparison program of a vendor laboratory so as to
verify the adequacy of the vendor=s analytical capabilities; and

5\. a review the most recent land-use census to determine if the type
and the location of environmental sample media coincide with the land=s
use.

c\. Determine if the laboratories in the licensee=s program are
following the guidance in Regulatory Guide 4.15. Verify that the
laboratories participate in an inter-laboratory comparison program
specified in NUREG-1301 or NUREG-1302.

d\. Verify that the licensee has a program in place to ensure that a
land use census is conducted every year and the results of the census
are used to review and modify the REMP to ensure monitoring of all
appropriate pathways.

e\. Confirm that there is adequate documentation confirming the
verification and validation of digital computer software used in
processing and evaluating the results of the REMP. This confirmation
includes software developed by the licensee, purchased through a vendor,
or software included with the instrumentation.

> [Guidance:]{.underline} Regulatory Guide 4.15 provides a list of
> references that can be used as guidance for software documentation,
> and verification/validation.

f\. Confirm that the data reduction and reporting of radiological
measurement data occurs according to the NUREG-1301 or 1302 and
Regulatory Guides 4.1, 4.15 and 4.8.

g\. Confirm that the data reduction and reporting of meteorological
measurement data occurs according to Regulatory Guides 1.23.

h\. Confirm that the licensee has a mechanism to document and
incorporate changes to the REMP. Determine that changes in the annual
census information will be incorporated into the REMP and ODCM.

80522 - 03 RESOURCE ESTIMATES

100 hours of direct inspection effort should be budgeted for executing
this Inspection Procedure. An inspection of the REMP and the
Meteorological Monitoring Program will require: a health physicist who
is trained in environmental measurements and monitoring, and a
meteorologist who is trained in meteorological instrumentation and
measurements.

80522 ‑ 04 REFERENCES

ANSI N320 - 1979. APerformance Specifications for Reactor Emergency
Radiological Monitoring Instrumentation. Reaffirmed 1993.

ANSI/ANS-3.11 - 2005. ADetermining Meteorological Information at Nuclear
Facilities.

ESRP 6.2. AEnvironmental Standard Review Plan, Section 6.2, Radiological
Monitoring@. NUREG-1555.

International Atomic Energy Agency (IAEA). 1980. AAtmospheric Dispersion
in Nuclear Power Plant Siting@, Safety Series No. 50-SG-S3, 1980.

NUREG‑0133. \"Preparation of Radiological Effluent Technical
Specifications for Nuclear Power Plants.\"

NUREG‑1301, \"Offsite Dose Calculation Manual Guidance: Standard
Radiological Effluent Controls for Pressurized Water Reactors.\" (With
Generic Letter 89-01,Supplement 1).

NUREG‑1302, \"Offsite Dose Calculation Manual Guidance: Standard
Radiological Effluent Controls for Boiling Water Reactors.\" (With
Generic Letter 89-01, Supplement 1).

Regulatory Guide 1.21, \"Measuring, Evaluating, and Reporting
Radioactivity in Solid Wastes and Releases of Radioactive Materials in
Liquid and Gaseous Effluents from Light‑Water‑Cooled Nuclear Power
Plants.\"

Regulatory Guide 1.23, AMeteorological Monitoring Programs for Nuclear
Power Plants.@

Regulatory Guide 4.1, APrograms for Monitoring Radioactivity in the
Environs of Nuclear Power Plants.@

Regulatory Guide 4.15, \"Quality Assurance for Radiological Monitoring
Programs (Normal Operations) ‑ Effluent Streams and the Environment.\"

Regulatory Guide 4.8, AEnvironmental Technical Specifications for
Nuclear Power Plants.@

Generic Letter 89-01, Implementation of Programmatic Controls for
Radiological Effluent Technical Specifications in the Administrative
Controls Section of the Technical Specifications and the Relocation of
Procedural Details of RETS to the Offsite Dose Calculation Manual or to
the Process Control Program.

80522 ‑ 05 PROCEDURE COMPLETION

This procedure will be completed when there is sufficient sampling to
allow transition to inspection under the ROP.

END

Attachment 1: Revision History for IP 80522

Attachment 1

Revision History Sheet for IP 80522

Radiological Environmental Monitoring Program (REMP)

+--------+---------+-------------+-------+-------------+---------------+
| Comm   | Issue   | Description | Tra   | Training    | Comment       |
| itment |         | of Change   | ining | Completion  | Resolution    |
| Tr     | Date    |             | N     | Date        | Accession     |
| acking |         |             | eeded |             | Number        |
| Number |         |             |       |             |               |
+--------+---------+-------------+-------+-------------+---------------+
| NA     | 0       | Completed   | None  | Not         | ML072851219   |
|        | 7/01/08 | review of   |       | Applicable  |               |
|        |         | CNs for     |       |             |               |
|        | CN      | previous 4  |       |             |               |
|        | 08-019  | years with  |       |             |               |
|        |         | none found. |       |             |               |
|        |         |             |       |             |               |
|        |         | Initial     |       |             |               |
|        |         | issue to    |       |             |               |
|        |         | support     |       |             |               |
|        |         | inspections |       |             |               |
|        |         | of          |       |             |               |
|        |         | operational |       |             |               |
|        |         | programs    |       |             |               |
|        |         | described   |       |             |               |
|        |         | in IMC      |       |             |               |
|        |         | 2504,       |       |             |               |
|        |         | NON-ITAAC   |       |             |               |
|        |         | INSPECTIONS |       |             |               |
+--------+---------+-------------+-------+-------------+---------------+