Environmental Monitoring
Effective Date 1/15/01
EV-PD
Radiation Safety
Revision 1


Environmental Monitoring and Surveillance Plan
For
Future Disposal of 11e(2)/ LLRW


1.0 PURPOSE

Waste Control Specialists, LLC (WCS) is the holder of Texas Department of Health, Bureau of Radiation Control Radioactive Material License Number L04971 issued November 3, 1997. This license authorizes, in part, the receipt and processing of radioactive material received as waste and interim storage of radioactive material received as waste. In anticipation of WCS applying for future amendments to their radioactive materials license or acquiring other operating permits, additional pre-operational environmental monitoring is planned to establish background information to accommodate these activities. The purpose of this document is to provide WCS the plan for conducting this additional pre-operational and operational environmental monitoring.

This Plan is being developed in advance of potential 11e(2) and/or Low Level Radioactive Waste (LLRW) management disposal operations. The protocols contained in this plan are intended to augment and complement the existing monitoring being performed by WCS in accordance with their storage and treatment license. Results obtained from the monitoring contemplated in this plan will be integrated with existing data to form a pre-operational environmental baseline against which the effectiveness of future facility operations will be measured.

2.0 DISPOSAL FACILITY SETTING

The WCS facility is located adjacent to the Texas-New Mexico State line some 30 miles west of Andrews, Texas in Andrews County. The site is comprised of approximately 1,338 acres on the north side of Highway 176 and is surrounded by another 15,000 acres also owned and controlled by WCS. The closest community is Eunice, New Mexico, 6 miles to the west of the facility and the nearest residence is a ranch house owned by WCS. No other residential areas are located within 3 miles of the 1,338-acre facility. The closest industrial facility is the Wallach gravel and crushing facility approximately one mile to the west of the WCS facility. The site location is shown on Figure 2.1.

The Andrews County setting is extremely arid, receiving less than 14 inches of average annual rainfall with pan evaporation potential exceeding 63 inches annually. Temperatures are characterized as hot in the summer and relatively mild to cool in the winter. The annual mean temperature is 63° F. The prevailing wind direction is from the south and south east with occasional shifts to the southwest during the winter months.

The facility is situated near the southwestern edge of the Southern High Plains, a stable geomorphic and relatively featureless landscape with very subtle topographic relief. There are no surface waters, natural drainage features, major aquifers, wetlands, or food crops within 3 miles of the facility. The WCS facility is underlain by the Triassic Dockum group, a thick clay formation with large isolated lenses of silt and sand deposited under alluvial conditions.

3.0 ENVIRONMENTAL MONITORING PROGRAM

The WCS Facility's existing environmental monitoring program for the Andrews County site consists of collecting samples and measuring concentrations of radionuclides in groundwater, air, soil, vegetation and fauna, direct radiation, and physical properties of specific environmental media. This existing program is designed to provide environmental data to allow WCS staff to demonstrate that it meets effluent release standards contained in the Facility's Material License No. L04971. This pre- operational/operational monitoring program is intended to supplement and revise their existing monitoring program and to establish background levels for the additional parameters to be added under this plan. The environmental data gathered will be evaluated for possible seasonal fluctuations and used as a baseline once future disposal operations are licensed. The critical isotopes, which are to be monitored under the pre- operational environmental monitoring program, for both 11e(2)/ LLRW monitoring are shown in Table 3.1. These isotopes are important from an environmental prospective due to factors such as their radiological half-life, mobility, radiotoxicity, and presence within LLRW waste streams. The data generated under the pre-operational program will be used to establish concentration setpoints for monitoring future site performance. The operational monitoring program will be used to evaluate the potential health and environmental impacts during operation of an 11e(2)/ LLRW disposal facility and any possible long-term environmental impacts.

TABLE 3.1 ENVIRONMENTAL MONITORING KEY ISOTOPES

Ra-226	TH-228	Cs-137
Ra-228	TH-232	Co-60
Pb-210	U-234	H-3
Sr-90	U-238	C-14
Tc-99	U-235	I-129

Pre-operational monitoring as discussed in the Plan will be initiated prior to submitting any license application for LLRW disposal and will continue during the remaining pre-operational period. Operational monitoring will begin when waste is disposed, continue through the operational period and ends when waste is no longer accepted and the facility is closed. Although monitoring during each phase is related to the performance objectives mandated by state and federal regulations, the emphasis, scope, and level of monitoring will vary. The pre-operational monitoring program has been developed using procedures and methods which will be incorporated into the operational monitoring program so that data collected during each phase will be compatible.

3.1 Environmental Monitoring Program Philosophy

WCS presently operates the Andrews County facility in a manner to minimize the potential for releases from the storage and treatment of radioactive waste. The projected performance of the Andrews County site has undergone rigorous scrutiny by the State of Texas in granting the facility's present materials license. Any proposed 1 le(2)/LLRW disposal facility license amendment designed for radioactive material isolation also must include a revised performance assessment based upon site characteristics, projected waste volumes and activity, administrative controls imposed during disposal operations, disposal cells and covers design, and the buffer zone. Operational monitoring results allow regulatory agencies and the facility operator to verify disposal system performance. After waste is disposed, the disposal system must still remain within regulatory compliance.

Since the results of the environmental monitoring program are critical to understanding the disposal system performance, the monitoring program must be designed to render usable data upon which informed decision can be made. For example, the quantitative threshold for facility performance must not be set so low that environmental monitoring results which represent expected variations in sample media concentrations are viewed as evidence of unexpected waste constituent migration. Rather, data trend analyses would be performed and, if necessary, additional or expanded sampling undertaken to better determine the significance of the monitoring results. Investigative and action levels agreed to by the Texas Department of Health, Bureau of Radiation Control (TDH) would guide stepwise response activities including corrective actions, if necessary. This plan provides the analyses and statistical bases for carrying out these activities.

3.2 Objectives of Pre-Operational Monitoring

The principal objectives of a radiological pre-operational environmental monitoring program are as follows:

(a) Obtain background or baseline data - background radiological data is used to establish baseline data on the natural radiological constituents on the site. These data are to be used to establish reference levels to measure any impact from future facility operations. They will also provide the basis to establish levels of measurement at which further investigations must be undertaken to determine if radioactive materials have migrated from the site.

(b) Provide records for regulatory review - the records of environmental data serve as a regulatory record that may be used to assess the environmental impact and overall performance of the facility throughout its life cycle.

WCS and its subcontractors have collected and analyzed environmental monitoring data for both radiological and non-radiological parameters during the licensing (for storage and treatment only) and permitting phases. The WCS RCRA Part B Permit governs the non-radiological monitoring program. The data indicate that the Andrews County site can be successfully monitored, (i.e., Pre-existing radiological and non-radiological conditions at the site will not preclude the licensee from successfully conducting the required monitoring activities during the three phases of 11e(2)/LLRW disposal facility life; pre-operation, active operation and post-operation. The duration of pre-operational monitoring period is a minimum of one year).

3.3 Objectives of Operational Monitoring

The principal objectives of an operational environmental monitoring program are as follows

(a) Demonstrate compliance with applicable environmental and radiation protection standards - Analysis of samples from environmental media provides quantitative evidence of meeting federal and state environmental and radiation protection standards. The monitoring system must be capable of providing early warning of releases of radionuclides from the disposal site before they reach the site boundary. WCS will compare results obtained in this phase to levels detected in the pre-operational phase to identify problems and initiate the appropriate corrective action.

(b) Obtain data on critical pathways. Monitoring data obtained from environmental media provides information to perform calculations of potential doses, if any, to the public and to evaluate overall facility performance in relation to radiological assessments presented in the license application. Operational environmental monitoring is designed to enable comparisons of site impacts to performance objectives and to ensure environmental impacts are as low as reasonable achievable (ALARA).

(c) Provide records for regulatory review - The records of environmental data will serve as a regulatory record throughout the lifecycle of the facility.

During facility operations, WCS staff will collect monitoring data in accordance with the handled, packaged, and analyzed and results recorded in accordance with approved procedures. The environmental data gathered during the one-year pre-operational period will be evaluated to determine if revisions are necessary to the Investigation Levels (IL) and Action Levels (AL) that have been established for the operational phase. The values are discussed in Appendix A and the preliminary values are tabulated in Procedure EVPD7.

4.0 ORGANIZATIONAL STRUCTURE AND QUALITY ASSURANCE PROGRAM

WCS senior management and operating personnel have extensive experience in hazardous and radioactive waste management disciplines. This experience is directly applicable to the safe and efficient operation of an 11e(2)/ LLRW disposal site. WCS will continue to provide and maintain expertise in health physics, environmental monitoring and analysis engineering; geotechnical sciences; regulatory compliance; management, administration, and data base management; quality assurance/ quality control; occupational health and safety; and heavy equipment maintenance and operation.

4.1 Staffing and Chain of Authority

Programmatic responsibility for pre-operational and operational environrnental monitoring resides with the Vice President, Operations and General Manager. Vice President, Operations and General Manager, is responsible for providing training for the facility staff and implementation of all aspects of the environmental monitoring program. Responsibility for technical adequacy of the environmental monitoring program resides with the Vice President, Nuclear Affairs. The facility Radiation Safety Officer (RSO), who reports to the Vice President, Facility Manager, is responsible for implementing sample collection, chain-of-custody to analytical laboratories and subsequent data acquisition. The RSO will review the data and data trends.

The Vice President, Operations and General Manager makes supplemental resources and assistance available from the corporate staff and contractor organizations as necessary for quality assurance activities and technical support. For the most part, however, technical resources necessary to manage and implement the environmental monitoring program are dedicated to the WCS Andrews County facility. Figure 4.1 depicts the organization for the WCS facility including the environmental monitoring staff.

Click here for Fig 4.1 Andrews Site Organizational Chart

4.2 Facilities and Equipment

The Vice President Operations/ Facility Manager will ensure that the facility is equipped with the proper tools and equipment required to perform environmental monitoring, and that it is staffed with properly trained personnel to perform the required maintenance on equipment. Maintenance of facility equipment will be performed by WCS staffwho report to the Operations Manager. Broken or improperly functioning equipment will be returned to the appropriate vendor if timely repairs are beyond the staffs expertise. All maintenance and repairs will be documented.

The purchase and maintenance of the facility's environmental monitoring equipment will be the responsibility of the RSO, who will ensure that all monitoring equipment conforms to specified requirements, is maintained and operated in accordance with approved procedures. Monitoring equipment calibrations or repairs will be performed by qualified on-site personnel or a vendor approved calibration/repair facility. Any on-site calibrations will be performed in accordance with written and approved procedures.

4.3 Training

Key facility personnel, including the Vice President, Operations and General Manager, Radiation Safety Officer, and Operations Manager have appropriate experience working at facilities involving industrial hygiene and safety concerns for hazardous materials or radioactive waste management. Minimum qualifications for these positions are addressed under the Facility's QA program. Facility personnel receive periodic on-the-job training while performing their duties at the WCS site to guarantee that they are fully qualified to perform their duties. Training begins as soon as new employees are hired, and is an ongoing process that continues throughout the operation of the facility. Training in most cases includes successful completion of tests related to required skills before employees are allowed to perform a particular task.

WCS's basic training program does not differentiate levels of training based on experience. Each new site employee, who will be involved with radioactive material handling, undergoes basic radiation worker training. This training assumes that the employee has no prior knowledge of radioactive waste management. Each employee, whether a high school or college graduate, undergoes the same training. Beyond this basic training program, each position at the facility has specific qualification requirements.

The RSO, who reports to the Vice President Nuclear Affairs, is responsible for directing training for personnel involved in radiological environmental monitoring. The Quality Assurance Manager is responsible for providing quality assurance training for site personnel involved in quality-related activities. The Vice President Operations/ Facility Manager is responsible for ensuring that all facility personnel attain the proper training specific to their responsibilities.

Effectiveness of the training and employees' understanding of theory and application will be verified by re-qualification examinations administered by the RSO every two years. Employees must achieve a passing score to continue participation in environmental monitoring activities. Test scores, quality assurance sweillance, and employee feedback will be used to gauge the overall effectiveness of the training program. The training program's effectiveness is also evaluated during both radiological control and safety audits and during regulatory compliance and management audits.

The facility's formal training program for this pre-operational/operational program will be developed and approved by the RSO. All training will be documented and incorporated as part of individual employee training files. Training topics will include license and permit requirements, procedural compliance, quality assurance, and environmental monitoring protocols.

4.4 Quality Assurance Program

The organizational structures for the Quality Assurance (QA) program is contained in the WCS Quality Assurance Program Plan (QAPP). Functional responsibilities, lines of communication within the individual organizations, and the interfaces with peer groups for activities affecting quality are contained in the QAPP. The persons and organizations performing quality assurance functions have sufficient authority and organizational freedom to identify potential problems adverse to quality; to initiate, recommend, or provide solutions; and to verify the implementation of the solutions.

The WCS QA Manual, the QA Procedures Manual, and the facility's Operating Procedures contain the requirements for managing and controlling quality related activities for the WCS facility. The QA Manual addresses the requirements recommended by NRC NUREG-1293, Quality Assurance Guidance for Low-Level Radioactive Waste Disposal Facility and follows the 18-criteria format of 10 CFR Part 50, Appendix B. The controls provided by the QA program ensure that the systems, structures, components, and activities meet facility design and performance objectives. The general aspects of WCS's QA Program are discussed in Appendix B.

The QA Program has been developed and implemented to control activities affecting quality to the extent consistent with their importance. Assurance of quality is typically verified by checking and reviewing all work and materials (including site characterization data and design input data) against prescribed quality standards, established scientific data, and facility performance criteria. Conformance to drawings and specifications is also verified by inspection of procured activities. The QAPP contains provisions for planning, reviewing, and verifying that project activities meet applicable criteria and standards. WCS applies controls to work activities and items based on their relative importance with regard to public health and safety, environmental protection, reliability, and project objectives.

QA program controls are established and implemented at the earliest time practical consistent with the schedule for accomplishing the activities. The site management team determines and identifies the extent to which the QA controls are to be applied to specific items and activities.

For the pre-operational and operational monitoring program each analytical laboratory utilized is required to submit documentation of its QA program and be audited on-site by the QA Manager or his designee prior to procurement of services. Included in the QA specifications are requirements for EPA verification, NIST traceability, and the necessity to have quality control samples to determine the precision and accuracy of the monitoring processes.

4.5 Audits and Managerial Controls

A comprehensive system of planned and periodic QA surveillance of the environmental monitoring activities is implemented to verify compliance with the QA manual, applicable QA plans, procedures, standards, policy statements, and instructions. The WCS QA Manager is responsible for planning and implementing QA audits in coordination with the Vice President Operations/ Facility Manager and the RSO. These planned and scheduled audits are performed in accordance with written procedures, plans, and checklists and continued at intervals appropriate to the importance of the activity. The audit program includes provisions to determine the effectiveness of the QA program in controlling the activities in accordance with applicable codes, standards, and regulations.

5.0 PRE-OPERATIONAL MONITORING PROGRAM

5.1 Media/ Analysis Matrix and Site Map

The environmental monitoring sample media, analyses, frequency, locations, and number of samples are tabulated in Table 5.1. The approximate sample locations on the site are shown on Figure 5.1.

[Click here to obtain Figure 5.1.]

5.2 Sampling and Analytical Methods

Once an environmental sample has been collected, in general, it is converted into a form that achieves the best instrument sensitivity prior to analysis.

5.2.1 Sample Acquisition

Some of the processes performed are outlined below in Table 5.2:

Table 5.2

MEDIA	SAMPLING METHODS
Air	Air is drawn through a particulate filter
Air-Radon	Radon Track Etch stations trap radon daughters
Groundwater	Samples are collected using pumps or bailers from wells
Surface Soil/Sediment	Surface sample taken form undisturbed areas using a standard volume (12" X 12" X 1")
Vegetation	Clip stems from new growth on plants from at least 4 species.
Wildlife	Harvest a primary herbivore.

5.2.2 Sample Preparation

a) For Gross Alpha and Beta
An aliquot of the ample is evaporated to dryness in a pre-weighed stainless steel planchet. (in the case of soil or vegetation, the sample must be ashed by heat). The sample now can be counted in a gas flow proportional counter.

b) For Alpha Spectrometry
An aliquot of the sample has chemistry performed on it such that the solution can be electro-deposited on a small stainless steel planchet. The sample now can be counted in an alpha spectrometer.

c) For Gamma Spectrometry
A known weight of sample (i.e., soil) is placed into a container (usually a Marinelli beaker) and then placed into the spectrometer for analysis. For water, the sample is placed in a one gallon cubitainer and a small quantity of acid is added. The sample is then placed into the gamma spectrometer

d) For Low Energy Beta Counting (i.e., H³ or C¹⁴)
The sample is distilled and a small amount is then mixed with solvents and a liquid compound that emits light when exposed to radiation. The sample is then counted in a liquid scintillation counter.

e) For Uranium Fluorometry
An aliquot of sample is placed on a platinum dish, evaporated to dryness, and ashed at high temperature. After cooling, a pellet of fluorescent material is placed on the platinum dish and heated until the pellet melts and has no bubbles. Once the dish has cooled, it is placed into the fluorometer for counting.

5.2.3 Sample Measurement Techniques

a) Gas Flow Proportional Counters
Gas flow counters work by flowing a gas over the sample and counting the pulses collected from the electrode in the counting chamber.

b) Alpha Spectroscopy Systems
Alpha spectrometers work by using a semiconductor material coated with an extremely thin gold foil. It is biased with a voltage to form a region that will collect ions created in the semiconductor material. Computer analysis of the spectral peaks results in the determination of activity.

c) Gamma Spectroscopy Systems
Similar to alpha spectrometers, gamma spectrometers also use a semiconductor material. However, a thin aluminum sheath covers them since gamma rays can easily traverse through air and thin materials. Computer analysis of the spectral peaks results in the determination of the photon energy activity of radionuclide present.

d) Liquid Scintillation Counters
For low energy beta radiation, liquid scintillation is the best choice. The sample is physically mixed with a scintillation fluid that will fluoresce when it absorbs radiation. The fluorescence is counted to determine the activity of the sample.

e) Fluorometry Systems
The sample is illuminated with a high energy light source such that the material in the sample will fluoresce and the light output is read as a percentage.

5.3 Determining Baseline Mean Values

During the pre-operational phase of the facility the receipt of timely analytical results is not as critical as during operations. However, it is appropriate to employ the same counting methods as for the operational phase of monitoring for determining baseline mean values for background environmental radioactivity and for excluding components which are not present at the site. These analyses would include the primary radionuclides expected to be present within the source term for the 11e(2)/ LLRW disposal facility at Andrews County. Additionally, analyses will be performed for other radionuclides that may be part of a future source term.

Since existing laboratory analytical methods can generally detect radioactivity below those levels found in the environment, such methods are appropriate when seeking to perform pre-operational monitoring for a site. However, the data review will consider the fact that at low background concentrations, minute variations in background concentrations have the potential to statistically affect analytical results.

Very low concentrations of radioactivity can be analyzed only through rigorously controlled, delicate, and time-consuming methods. This limits the number of laboratories able to provide such services.

5.3.1 Determining Lower Limit of Detection Values

With baseline mean values established using results from the 11e(2)/LLRW pre-operational environmental monitoring program, establishing LLDs for the operational environmental monitoring phase of the facility is the next task. Considerations for establishing these LLDs include the timeliness in receiving the results from the laboratory, relevance of the values to regulatory limits, and the degree to which it is necessary to track any changes in background radioactivity concentrations.

Thus, there must be a judgement as to which method yields the necessary information for assessing site performance in a timely fashion. Establishing LLDs and the corresponding investigation levels at levels that are too low presents the problem of frequent investigations of inconsequential trends. Establishing LLDs that are too high presents the problem of not having an adequate safety margin between the LLDs and regulatory limits. LLDs must therefore be set at practical levels to obtain the optimum level of utility and safety. Appendix A to this Plan contains additional information pertaining to the task of setting acceptable LLDs for the environmental monitoring programs. The apriori LLD's are presented in tables included with Procedure EV-PD7.

5.4 Description of Pre-operational Program

5.4.1 Air Sampling
Six sampling locations were chosen based on the general wind direction. A meteorological station is used to verify that the wind rose used to locate the air samplers is appropriate. Air sampling stations 32-7 and 36-11 to the west of the proposed 11e(2)/ LLRW site will serve as the upwind stations. A sampling location near the city of Andrews, Texas will serve as the background location.

WCS staff will collect particulate samples from air drawn through filter paper mounted within the six fixed air samplers. The air particulate samples will be taken continuously to achieve weekly volumes of approximately 571 m³ and a monthly composite total of approximately 2447 m³. The particulate will be analyzed for the constituents listed in Procedure EV-PD7. Additionally, Radon-222 will be measured using radon track etch detectors situated at each of the process area air sampling stations. The background location in Andrews also will include a track etch detector.

5.4.2 Groundwater
Wells 6B1, 6B2, 11D, 2G, 7G, and the service water well form the network of upgradient wells for the proposed 11e(2)/ LLRW disposal trench to be located within the existing licensed WCS facility. Wells A-16, A-22, and A-24 will be used as downgradient wells. Sampling will occur at each of these on-site wells at quarterly intervals. Livestock Water Source as off-site sample within 2 Km of proposed 11(e)2/ LLRW Site. Since the yields of some of the wells on the WCS facility do not allow sufficient water to be extracted during a sampling event for a complete analysis or for a duplicate/split sample, the RSO may specify that a sampling event be extended to allow a well to recover. Samples will be analyzed for the constituents listed in Procedure EV-PD7.

5.4.3 Surface Soil
Samples will be collected monthly near the five air sample stations during the pre-operational phase. Additionally, sarnples will be taken at two locations along the upwind southern perimeter of the 1,338 acre licensed area and other points designated by the RSO. These samples will be composited and submitted quarterly for analysis. Archive samples also will be taken on a quarterly basis for the pre-operational period, which is expected to last up to two years. Should the pre-operational period be shorter there will be sufficient sample volume to assure an adequate number of analysis for determining baseline levels. These archive samples will be held for possible future analysis. Soil samples will be analyzed for the constituents listed in Procedure EV-PD7. Also, soil samples will taken one time at 50-meter grid locations on the proposed 11e(2)/ LLRW site.

5.4.4 Vegetation
While a human consumption pathway for vegetation has not been identified, monitoring of site vegetation will continue to be performed to gather additional data concerning the natural radioactivity in local vegetation. Samples will be collected semi-annually near the five air sample stations and the two southern site border locations during the beginning and end of the growing season. Vegetation samples will be analyzed for the constituents listed in Procedure EV-PD7.

5.4.5 Ambient Gamma

a) TLD Measurements Plan

Thermoluminescent dosimeters (TLDs) will be used to measure ambient gamma exposure during the 11e(2)/ LLRW pre-operational environmental monitoring phase. The TLDs will be located at intervals along the site perimeter fence and at locations specified by the RSO that correspond to TDH TLD locations. A TLD also will be located in Andrews, Texas for background control. The TLDs will be collected and processed on a quarterly basis. Comparisons will be made between the site and the background TLDs to identify any differences in background during the pre-operational monitoring program.

A set of TLDs will also be placed at 50-meter grid intervals over the proposed 11e(2)/ LLRW sites, at one meter above the ground and then removed after 90 days. After these TLDs are removed another set of TLDs will be placed at 150- meter intervals to 1500 meters in eight directions from the center of the site and placed one meter above the ground. This group of TLDs will also be removed and shipped to be read after 90 days.

A set of control TLDs will be included whenever badges are shipped to or from the site. These TLDs will be processed along with the field TLDs in order to verify that they did not receive an appreciable exposure while in transit. TLD field exposures will be determined by reducing the calibrated reading from the field cycle dosimeters by the background, transit dose indicated by the transit controls, and the TLD background (self-dosing component) as determined from control TLDs retained in a lead shielded storage cask. In conformance with ANSI N545-1975, WCS will retain a lead cask at a control station at the WCS facility for purposes of measuring the self-dosing component.

A blind testing QA program will be used. Periodically, per the RSO's instructions, at least four TLDs will be sent to an offsite irradiation facility and exposed to known doses of CS-137. The irradiated TLDs will be sent to the dosimetry processor along with the TLDs exposed in the field.

6.0 OPERATIONAL ENVIRONMENTAL MONITORING PROGRAM

The operational environmental monitoring program will monitor site performance and verify that the facility is in compliance with any license amendment issued for disposal of 11e(2)/ LLRW. The parameters to be monitored during the operational phase are chosen for their ability to yield timely results. The use of indicator parameters as screening indicators is an effective means to monitor the radiological impact of facility operations. These parameters are a more timely and cost-effective means of monitoring facility performance than full spectrum analyses. However, follow up investigations (including re-sampling and extensive isotopic analysis) will be performed when required.

The sampling program for the operational phase is similar to that used for the pre- operational phase except that operational monitoring includes a reduced periodicity for sampling, less complex analysis, and relies on indicator parameters to allow timely analysis of potential releases.

A tabulation of the parametric measurements to be used during the facility's operation phase is included in Procedure EV-PD7 and a general discussion of the media to be sampled and frequency of analysis is in the following section:

6.1 Description of Operational Program

6.1.1 Air Sampling
The sample locations, frequency, and sampling methodology will be similar to those used in the pre-operationai phase. However, laboratory analyses will be reduced from those listed in Table 5.1 as follows:

- Alpha isotopic only if IL exceeded for gross alpha;

- Sr-90 only if IL exceeded for gross beta;

- C-14/ H-3 only after receipt of waste containing these isotopes.

6.1.2 Groundwater
The sample locations, frequency, and sampling methodology will be identical to those used in the pre-operational phase. However, laboratory analyses also will be reduced from those listed in Table 5.1 as noted in Section 6.1.1.

6.1.3 Surface Soil
The surface soil monitoring program will be scaled back to sample quarterly only those locations used for air monitoring. The sampling methodology will be identical to that used in the pre-operational phase. However, laboratory analyses also will be reduced from those listed in Table 5.1 as noted in Section 6.1.1.

6.1.4 Vegetation
The sample locations, frequency, and sampling methodology will be identical to those used in the pre-operational phase. However, laboratory analyses will also be reduced from those listed in Table 5.1 as noted in Section 6.1.1.

6.1.5 Ambient Gamma

a) TLD Measurements Plan
The TLD measurement plan is identical to the pre-operational phase except for the one time TLD measurements.

b) Survey Meter Mapping Plan
During site operation a micro-R survey will be performed over each trench after it has been filled and capped. The same general grid system used during the pre- operational phase will be used to guide the surveyors with the frequency reduced to an approximate 10 m grid. Each 10 m grid line will be surveyed with a NaI meter at approximately 1 meter above the ground. The highest exposure rate measured within a grid (i.e., 10 m in length) will be recorded. Results from this mapping will be used for evaluating future trench cap stability and for locating the presence of radionuclides in the operational area.

7.0 DATA ANALYSIS AND TWO-TIERED RESPONSE SYSTEM

7.1 Routine Data Analysis

WCS is committed to reviewing all environmental data and implementing an appropriate response to the environmental monitoring results. Data reviews and responses are a two- tiered process. First, data is checked in accordance with QA procedures and if deemed acceptable entered into the database for incorporation into ongoing trend analyses. Should results be questioned because of possible errors in the sampling or sample analysis process then any discrepancies are to be resolved prior to data acceptance. Secondly, corrective action is taken, if necessary, in response to elevated values of environmental monitoring data. Trend analyses are begun when sufficient data is available to support a statistical review. Trends are plotted to provide evidence of a possible release of constituents from the disposal area. The sample results for each location will be plotted to observe trends.

WCS will verify the validity of all environmental sample results, as they become available. Verifying sample results is necessary to ensure that the results are accurate as reported. This verification may include recalculation of results, comparison to results from replicate samples sent to other laboratories, review of quality control used for sampling, analysis and calculations, and comparison to other parametric analyses. An evaluation of a sample result's significance will normally take place after verifying its validity. However, in the event such a sample exceeds an action level or approaches a regulatory limit, evaluation and verification may be performed concurrently. In all cases, when a sample result exceeds an action level, TDH will be notified immediately so that a corrective action can be planned should the sample result prove valid.

All valid data will be entered into the environmental monitoring database used for the periodic trend analysis performed by WCS. Trend analysis results will be reported to TDH on a routine basis if required by license. Trend analyses will consist of a statistical evaluation of subsets of environmental data for verifying that the samples are (or are not) all within a background population, considering seasonal variability. The evaluation also will include a narrative interpretation of the data and the statistical analyses performed by WCS radiation protection personnel. The pre-operational environmental database will be used as input to the facility's performance assessment that will be completed as part of the license application for disposal of 1 1 e(2)/LLRW waste. Any future revisions to the projected site performance assessment because of changes in the source term will be accomplished only with the full knowledge and consent of TDH. Interpretations and conclusions based on the revised performance assessment will be valid only if agreed upon by TDH.

7.2 Corrective Action Plan
The corrective action plan is a necessary part of the facility's environmental monitoring program. The plan establishes actions that will be taken by WCS if 11e(2)/ LLRW environrnental monitoring results exceed pre-established levels under the two tiered monitoring response program described in this section. This plan consists of a program for verification of monitoring results as discussed above and evaluation of the data with respect to site performance. The plan also calls for whatever procedural changes, administrative controls or other mitigation activities that may be necessary should this data evaluation indicate that regulatory limits could be exceeded.

7.2.1 Setting Investigation and Action Levels
Ideally, an environmental monitoring program spans a continuum that extends from the pre-operational LLD to a baseline mean, then to a practical LLD for operational monitoring, then to an IL, thence to an AL, and finally to a regulatory limit. Since radionuclides have different limits and require widely varying analytical techniques, this is not always possible. It is possible for the continuum to be compressed so that the various milestones overlap even to the extreme (though rare) that the LLD could be equal to the regulatory limit. More realistically, however, there is likely to be overlap between the statistically based baseline mean, the investigation levels, the performance based regulatory limit and the action levels.

Variances for these different levels could be so large that AL could be less than statistically based IL. This situation would require a different monitoring strategy. The proposed action levels are based on concentrations of dosimetric significance relative to the regulatory dose limits. The action levels are normally set at a higher value than the investigation levels, so that the causes of increased concentrations can be evaluated prior to taking any corrective actions. IL's and AL's are further discussed:

(a) Investigation Levels. An IL is set at some point above the baseline mean, usually based on some statistically significant benchmark above the baseline mean. The question which must be answered during operations is whether the data point collected belongs to the population which was used to establish the baseline statistic or to some other unknown population whose statistics are unknown. If the former is true, there is a high probability that there has been no increase in concentration due to facility operations. If the latter is true then there is the probability that there has been an increase due to site operations.

If monitoring indicates that regulatory limits may be exceeded at any time in the future, mitigating action would be required. However, variations in the projected site performance are not cause for such action if the revised projections remain within regulatory limits.

(b) Action Levels. The AL, or reporting level, is based on some percent of the regulatory limit. In no cases shall the AL exceed 25 percent of the regulatory limit. Exceeding an action level requires WCS to notify the TDH and to investigate the cause since regulatory limits might be in jeopardy of being exceeded. When the AL's are set at a very small percentage of the regulatory limit or when background radioactivity levels are a large percentage of the regulatory limits, reports of exceeding AL's become frequent, and both the licensee and the regulator must understand the results have little meaning. The radionuclides associated with l l e(2)/LLRW materials have relatively low regulatory limits in relation to their natural background levels, resulting in a "compressed" background-to-regulatory limit continuum.

7.2.2 Investigation Level Responses

Investigation level responses are those activities to be undertaken by WCS if; 1) IL's for environmental samples are exceeded, or 2) trend analyses indicate that IL's could be exceeded in subsequent samples but in neither case are AL's exceeded or in jeopardy of being exceeded.

If a sample is deemed to be a valid representative of the data, follow-up activities will be based on whether or not the sample exceeds the AL. If the sample exceeds the IL but not the AL, the RSO will evaluate the results within the context of the facility performance assessment to determine whether or not the result was expected. The RSO will evaluate the potential regulatory significance and submit a report to the Vice President Operations/ Facility Manager and the Vice President Nuclear Affairs.

Whether or not the elevated sample has potential regulatory significance, WCS will undertake an investigation of its cause and augment feasible operating practices to eliminate the cause of the elevated results in the sample. Investigation may include comparisons with regional data, investigations of possible climatic or offsite phenomena, which could have caused the elevated sample result, re-sampling and/or re-analysis, increased frequency of sampling and escalated analysis (in the case of Gross Alpha and Gross Beta results).

If results exceed investigation levels, the RSO will attempt to determine the cause to the extent practicable. Reasons may include but are not limited to: (a) sample collection quality control problems (b) laboratory quality control during their evaluation process; (c) the data point is a true outlier; or (d) there has been a true change in population mean, indicating an increase in constituent concentration has occurred. As a statistically meaningful number of samples become available during operations monitoring, statistical tests will be conducted using data subsets (e.g. pre-operations data and operations data or annual groupings of operations data) to test the null hypothesis that the statistics for each set of data are the same. This would indicate that the data are part of the same population (i.e., no change in constituent levels has resulted from facility operations).

If the data suggests that there has been a statistically significant change (the null hypothesis is rejected) the data's significance will be evaluated within the context of projected facility performance and regulatory limits. Augmentation of operating practices might be one course of action depending on the specific cause of an elevated sample. Such augmentation would be proposed and carried out in accordance with provisions for procedure revision in the license. A permanent record of the evaluation will be made.

Gross alpha and beta are indicator parameters and are therefore assigned investigation levels only. Exceeding the IL for these parameters requires an appropriate isotopic analysis as a minimum. An additional investigation may be dictated by the results of the isotopic analysis.

7.2.3 Action Level Responses

All environmental sample results exceeding prescribed AL's will be reported to the TDH immediately (with appropriate caveats if the results have yet to be verified). The AL, as defined for use at the WCS site, is that concentration of a radionuclide in a specific media that, if exceeded, requires that a complete report be made to the TDH. The report will be prepared by the RSO and will include monitoring results, investigations and findings, significance of the data, possible adverse effects, and proposed mitigating measures. If the follow up sample results are above the action level supplemental recommendation for follow-up action will be submitted to TDH for review and approval. The follow-up the potential regulatory significance and submit a report to the Vice President Operations/ Facility Manager and the Vice President Nuclear Affairs.

Whether or not the elevated sample has potential regulatory significance, WCS will undertake an investigation of its cause and augment feasible operating practices to eliminate the cause of the elevated results in the sample. Investigation may include comparisons with regional data, investigations of possible climatic or offsite phenomena, which could have caused the elevated sample result, re-sampling and/or re-analysis, increased frequency of sampling and escalated analysis (in the case of Gross Alpha and Gross Beta results).

If results exceed investigation levels, the RSO will attempt to determine the cause to the extent practicable. Reasons may include but are not limited to: (a) sample collection quality control problems; (b) laboratory quality control during their evaluation process; (c) the data point is a true outlier; or (d) there has been a true change in population mean, indicating an increase in constituent concentration has occurred. As a statistically meaningful number of samples become available during operations monitoring, statistical tests will be conducted using data subsets (e.g. pre-operations data and operations data or annual groupings of operations data) to test the null hypothesis that the statistics for each set of data are the same. This would indicate that the data are part of the same population (i.e., no change in constituent levels has resulted from facility operations).

If the data suggests that there has been a statistically significant change (the null hypothesis is rejected) the data's significance will be evaluated within the context of projected facility performance and regulatory limits. Augmentation of operating practices might be one course of action depending on the specific cause of an elevated sample. Such augmentation would be proposed and carried out in accordance with provisions for procedure revision in the license. A permanent record of the evaluation will be made.

Gross alpha and beta are indicator parameters and are therefore assigned investigation levels only. Exceeding the IL for these parameters requires an appropriate isotopic analysis as a minimum. An additional investigation may be dictated by the results of the isotopic analysis.

7.2.3 Action Level Responses
All environmental sample results exceeding prescribed AL's will be reported to the TDH immediately (with appropriate caveats if the results have yet to be verified). The AL, as defined for use at the WCS site, is that concentration of a radionuclide in a specific media that, if exceeded, requires that a complete report be made to the TDH. The report will be prepared by the RSO and will include monitoring results, investigations and findings, significance of the data, possible adverse effects, and proposed mitigating measures. If the follow up sample results are above the action level supplemental recommendation for follow-up action will be submitted to TDH for review and approval. The follow-up recommendations will include an evaluation of the significance of the result within the context of the facility performance assessment and an evaluation of the regulatory significance. If the sample is determined to have regulatory significance (by either TDH or WCS or both), WCS will submit a corrective action plan for approval to the TDH. Subsequent activities will proceed under the direction of the Vice President Operations/Facility Manager who will implement the plan upon approval of the TDH.

Action level responses may include, separately or in combination, procedural changes and escalated data evaluations, administrative changes, as well as mitigating activities involving permanent changes in facility design and engineering as well as structures emplaced for the sole purpose of mitigation.

Procedural changes and evaluations may include increasing the sampling frequency and the number of radionuclides for which a sample is tested, investigation of the facility source term to establish the likely cause of the elevated level, recommendations for modifying operations to minimize potential for future elevated levels. Any such action will be carried out with the full knowledge and consent of TDH and under their auspices.

Examples of mitigating administrative actions include operational modifications limiting waste storage periods in the event fenceline TLDs show elevated results, to requiring generators of certain waste types to pre-treat their waste to reduce radionuclide mobility.

Examples of structural or engineering mitigating measures include groundwater extraction or emplacement of grout curtains. Exhumation of waste is generally the least desirable alternative due to worker radiation exposure considerations. Specific remediation actions necessarily are based on the precise circumstances present. While prudent to note the possible use of these extensive measures in a corrective action plan, the facility's location, design, and proposed operating practices greatly reduce the likelihood that such measures would be necessary.

Response activities undertaken when action levels are exceeded are conducted to reduce or eliminate elevated concentrations of radioactivity associated with the disposal facility. Professional staff expertise will be required to evaluate each situation requiring mitigating action. In certain instances, it may be necessary to employ professionals from contracted companies to supplement WCS staff. In all cases, TDH will be consulted to assure that activities are conducted in accordance with applicable regulatory requirements.

7.3 Potential for Modification of Data Analysis and Response

WCS will use the data generated by the operational environmental sampling program to make refinements in predicting site performance. These refinements may prompt modifications to the facility environmental nnonitoring and corrective action plans.

Modifications may include revising investigation or action levels; shifting emphasis from one media to another; or focusing on other specific radionuclides or geochemical constituents that may serve as better indicators of site performance. While proposals for any such modifications to the basic program would be implemented only with the formal approval of TDH, WCS may elect to augment its program with additional sampling as recommended by the RSO.

8.0 GLOSSARY

Action level - The level of radiation at which remedial action will be taken to prevent further contamination of the environment. This level of radiation is typically set at some percentage of the equivalent derived concentration.

Activity - The number of nuclear transformations occurring in a given quantity of material per unit time. It is measured in units of Curies (Ci), microcuries (µCi), or picocuries (pCi).

Aliquot - A portion of material removed from a parent batch.

Background Value - The radiation levels or concentrations of radioactive materials present in air, water, soil, or vegetation from naturally occurring or global fallout radionuclides.

Baseline Value - The radiation levels or concentrations of radioactive materials present at a site, as determined through the site pre-operational monitoring program. These levels are recorded for specific environmental media, at a specific point in time.

Characterization - The process of obtaining information on a site to deterrnine its acceptability as a prospective location for waste disposal or other function. Characterization includes sampling the air, water, soil, and vegetation to establish the natural levels of radiation or chemicals present.

Committed Dose Equivalent - The dose that will be accumulated by a specific body organ over a 50-year period following an intake of radioactive materials.

Confidence Interval - A measure of the confidence associated with a dataset. For instance, for a Gaussian distribution, a one-sigma standard deviation denotes a 67% confidence that another measurement will fall within the specified confidence interval. Two sigma is a 95% confidence level.

Dose - A measure of the energy imparted to matter by ionizing radiation per unit mass. The unit of dose s the rem or millirem (mRem).

Equivalent Derived Concentration - For the WCS facility, the concentration of each radionuclide in air, water, or soil, which, if maintained constant for a period of 50 years, would result in an annual dose equal to the regulatory limit.

Groundwater - Water present beneath the surface of the ground. Drilling a well accesses groundwater, sometimes referred to as an aquifer.

Investigation level - An administrative level of radiation or concentration of radioactive materials at which an investigation is triggered to determine the cause of the elevated level which is above the baseline value previously established. This level is typically set at some small percentage of the equivalent derived concentration.

Location - A point where environmental (e.g., air, water or soil) sampling occurs.

Log Normal Distribution - A statistical tool, often used for environmental data that fits skewed data sets. Environmental data are frequently skewed since there are often many less than detectable values. It is essentially a log-transform of the input data set to provide a cutoff point below which there is zero probability of occurrence.

Lower Limit of Detection (LLD) - A level established to guide the analytical laboratory in its required analyses. It is an a priori (before the fact) quantification of the smallest amount of a contaminant that can be distinguished in a sample by a given measurement procedure at a given confidence level.

Maximum Permissible Concentration (MPC) - Values specified by 10 CFR 20 Appendix B and by TRCR, Appendix 21-A Table II, Column 1 as limits on concentrations of radionuclides applicable to the general public.

Monitorability - A quality of a site that exhibits a stable condition and naturally low background radiation and chemical levels so that small increases in radiation levels can be detected to note migration of contaminants or radionuclides from the site.

National Institute of Standards and Technology (NIST) - Successor agency to the U.S. National Bureau of Standards.

Parametric - A measurement method based on parameters such as count time and background.

Pre-Operational Monitoring - Detailed radiological monitoring of the site to characterize its existing components of the natural state of the site before the operational phase begins.

Radionuclide - An element, that may occur naturally or be formed by man, which undergoes radioactive decay and thus spontaneously emits radiation.

Regulatory Limit - The dose or concentration of radioactive material specified in 10 CFR Part 61.41, 40 CFR Parts 141.15 and 141.16, and TDH regulations to protect public health.

Rem - A special unit of dose equivalent that is numerically equal to the absorbed dose in rads multiplied by the quality factor and any other necessary modifying factors.

Section - The United States Geological Survey (SGS) zone, which corresponds to a designated area of a USGS map.

Standard Deviation sigma - The statistical term used to denote the spread of the data set. Site - For the purposes of this report, the piece of land being considered as the location for an 11e(2) disposal facility.

Station - A location that has instrumentation available to monitor site conditions such as air quality or weather.

Surface Water - Water present on the surface of the ground, such as a river, pond, or lake.

9.0 REFERENCES

Autry, V., Cashman, T., Dornsife, W., Gronemyer, L., Patliff, R.A., and Vaden, J. (1985). "Suggested State Requirements and Criteria for a Low-Level Radioactive Waste Disposal Site Regulatory Program." NUREG/CR-4352, U.S. Nuclear Regulatory Commission, Washington, D.C.

National Council on Radiation Protection and Measurements, (NCRP). (1973). "Environmental Radiation Measurements." NCRP Report No. 50, National Council on Radiation Protection and Measurements, Washington, D.C.

National Council on Radiation Protection and Measurements, (NCRP). (1975). "Natural Background Radiation in the United States." NCRP Report No. 45, National Council on Radiation Protection and Measurements, Washington, D.C.

National Council on Radiation Protection and Measurements, (NCRP). (1976). "Environmental Radiation Measurements." NCRP Report No. 50, National Council on Radiation Protection and Measurements, Washington, D.C.

TRCR, 1996. Texas Regulations for Control of Radiation, Part 21 ("Standards for Protection Against Radiation") and Part 44 ("Licensing of Radioactive Waste Processing and Storage Facilities"), Texas Department of Health, Bureau of Radiation Control, Austin, TX.

Texas Department of Health, Bureau of Radiation Control (TDH). (1998). Radioactive Material License No. L04971. Issued to Waste Control Specialists, LLC. Texas Department of Health, Bureau of Radiation Control, Austin, TX.

Texas Natural Resource Conservation Commission (TNRCC). "Technical Guidance: Guidelines for the Preparation of Environmental Reports and Safety Evaluation Reports for In Situ Uranium Recovery Facilities." Texas Natural Resource Conservation Commission, Austin, TX.

US Ecology, 1991. "Environmental Monitoring Report for the Proposed Ward Valley California Low-Level Radioactive Waste (LLRW) Facility." US Ecology, Inc., December, 1991.

U.S. Nuclear Regulatory Commission (NRC). (1984). "Lower Limit of Detection: Definition and Elaboration of a Proposed Position for Radiological Effluent and Environmental Measurements." NUREG/CR-4007, U.S. Nuclear Regulatory Commission, Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). (1989). "Environmental Monitoring of Low- Level Radioactive Waste Disposal Facility." NUREG-1388, U.S. Nuclear Regulatory Commission, Washington, D.C.

WCS, 1996a. "Licensing Application for Class C Radioactive Waste Processing and Storage Facility," Waste Control Specialists, March 1996 (including subsequent submittals of additional information and revisions).

WCS, 1996b "Environmental Analysis for a Class C Radioactive Waste Processing and Storage Facility in Andrews County, Texas"

10.0 ATTACHMENTS

10.1 Appendix A and B

10.2 Procedures

EV-PD7 Radiological Environmental Monitoring Program

EV-7.1.2 Air Sampling

EV-7.1.3 Reserved

EV-7.1.4 Shipping Environmental Samples

EV-7.1.5 Soil Sampling

EV-7.1.6 TLDs and Direct Gamma Surveys

EV-7.1.7 Vegetation Sampling

EV-7.1.8 Groundwater Sampling