Environmental Monitoring Annual Compliance Report 2011

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1 Environmental Monitoring Annual Compliance Report 2011 Name of Facility: Shield Source Incorporated Name of Licensee: Shield Source Incorporated Reporting Period: January 1, 2011 to December 31, 2011 License Number: NSPFOL 12.00/2012 Operators Business Address: 925 Airport Road RR#5, Municipal Airport Peterborough, ON K9J 6X6 Submitted to: Canadian Nuclear Safety Commission, Nadia Petseva Submitted: March 30, 2012 Approved/ Issued by: Original Signed Lisa McMurray General Manager Original Signed Leisha Newton Radiation Safety Officer Licensee Signing Authority or delegate: Leisha Newton, Radiation Safety Officer 925 Airport Road, RR#5, Municipal Airport, Peterborough, ON K9J 6X6 Phone: , Fax: Licensee Contact information: Shield Source Incorporated 925 Airport Road, RR#5, Municipal Airport, Peterborough, ON K9J 6X6 Phone: , Fax:

2 Table of Contents 1.0 INTRODUCTION GENERAL INTRODUCTION COMPANY INTRODUCTION LAND USE WITHIN THE MONITORING PROGRAM AREA FACILITY OPERATION PRODUCTION DETAILS ENVIRONMENTAL MONITORING STACK EMISSIONS MONTHLY STACK EMISSIONS RESULTS ANNUAL STACK EMISSIONS RESULTS CNSC RELEASE LIMITS, ACTION LEVELS AND ADMINISTRATIVE LEVELS LIQUID EFFLUENTS ENVIRONMENTAL MONITORING LOCATIONS AMBIENT AIR SAMPLING METHOD SAMPLE AVAILABILITY RESULTS AMBIENT WATER SAMPLING METHOD SAMPLE AVAILABILITY RESULTS MONITORING WELL WATER SAMPLING METHOD SAMPLE AVAILABILITY RESULTS VEGETATION SAMPLING METHOD SAMPLE AVAILABILITY RESULTS FUTURE PLANS CALCULATED DOSES TO THE CRITICAL RECEPTOR DOSE CALCULATION METHODOLOGY MODEL INPUT DATA RECEPTOR DOSE ESTIMATION RESULTS INFANT RECEPTOR CHILD RECEPTOR ADULT RECEPTOR MODELED DOSE INTERPRETATION SSI QA/QC FIELD BLANKS RESULTS TRAVEL BLANKS RESULTS REPLICATE SAMPLES ii

3 4.3.1 RESULTS LABORATORY QA/QC SUMMARY EMISSIONS LIQUID EFFLUENT AMBIENT AIR SAMPLING AMBIENT WATER MONITORING VEGETATION SAMPLING MONITORING WELL WATER SAMPLING DOSE TO THE CRITICAL RECEPTOR A1.1 SELECTION OF AGE GROUPS...52 A1.2 SELECTION OF INHALATION RATES...52 A1.3 SELECTION OF FOOD INGESTION RATES...52 Tables Table TECR1101: Total Tritium Processed Table TECR1102: 2011 Monthly Tritium Stack Emissions... 7 Table TECR1103: Air Emissions released from the facility ( )... 9 Table TECR1104: Licence Limits and Internal Levels for Tritium Emissions Table TECR1105: Liquid Effluent released into the sewer system ( ) Table TECR1106: SSI EMP Sampling Locations Table TEAR1107: SSI EMP Sampling Locations continued Table TECR1108: Ambient Air Environmental Sampling Results Table TECR1109: 2011 Ambient Air Monitoring Data (Bq/m 3 ) Table TECR1110: Ambient Water Environmental Sampling Results Table TECR1111: 2011 Ambient Water Monitoring Data (Bq/L) Table TECR1112: Monitoring Well Water Sampling Results Table TECR1113: Monitoring Well Water Data (Bq/L) Table TECR1114: 2011 Vegetation Sampling Results (Bq/L) Table TECR1115: Vegetation Sampling Results (Bq/L) Table TECR1116: Age Classes Considered in Dose Calculations Table TECR1117: Transfer Parameters used in Human Dose Calculations Table TECR1118: Transfer Parameters used in Vegetation Dose Calculations Table TECR1119: Transfer Parameters and Transfer Factors used in Animal Dose Calculations Table TECR1120: Maximum Measured Tritium Activity Table TECR1121: Average Measured Tritium Activity Table TECR1122: Average and Maximum Monthly Tritium Concentrations in Ambient Air at Each Monitoring Location for 2006 to Table TECR1123: Pathway Breakdown of Estimated Doses to Infant Using Maximum Activities Table TECR1124: Pathway Breakdown of Estimated Doses to Infant Using Average Activities Table TECR1125: Total Tritium Dose (All Forms) to Infant Using Maximum Activities Table TECR1126: Total Tritium Dose (All Forms) to Infant Using Average Activities iii

4 Table TECR1127: Total Tritium Dose (All Forms) to Infant Using Maximum Activities without Ingestion of Cow Milk Pathway Table TECR1128: Total Tritium Dose (All Forms) to Infant Using Average Activities without Ingestion of Cow Milk Pathway Table TECR1129: Total Tritium Dose (All Forms) to Infant Using Maximum Activities for Air, Water and Maternal Milk Pathways Table TECR1130: Total Tritium Dose (All Forms) to Infant Using Average Activities for Air, Water and Maternal Milk Pathways Table TECR1131: Pathway Breakdown of Estimated Doses to Child Using Maximum Activities Table TECR1132: Pathway Breakdown of Estimated Doses to Child Using Average Activities Table TECR1133: Total Tritium Dose (All Forms) to Child Using Maximum Activities Table TECR1134: Total Tritium Dose (All Forms) Child Using Average Activities Table TECR1135: Total Tritium Dose (All Forms) to Child Using Maximum Activities without Ingestion of Cow Milk Pathway Table TECR1136: Total Tritium Dose (All Forms) to Child Using Average Activities without Ingestion of Cow Milk Pathway Table TECR1137: Total Tritium Dose (All Forms) to Child Using Maximum Activities for Air and Water Pathways Table TECR1138: Total Tritium Dose (All Forms) to Child Using Average Activities for Air and Water Pathways Table TECR1139: Pathway Breakdown of Estimated Doses to Adult Using Maximum Activities Table TECR1140: Pathway Breakdown of Estimated Doses to Adult Using Average Activities Table TECR1141: Total Tritium Dose (All Forms) to Adult Using Maximum Activities Table TECR1142: Total Tritium Dose (All Forms) to Adult Using Average Activities Table TECR1143: Total Tritium Dose (All Forms) to Adult Using Maximum Activities without Ingestion of Cow Milk Pathway Table TECR1144: Total Tritium Dose (All Forms) to Adult Using Average Activities without Ingestion of Cow Milk Pathway Table TECR1145: Total Tritium Dose (All Forms) to Adult Using Maximum Activities for Air and Water Pathways Table TECR1146: Total Tritium Dose (All Forms) to Adult Using Average Activities for Air and Water Pathways Table TECR1147: Field Blanks Data (Bq/L) Table TECR1148: Travel Blanks Data (Bq/L) Table TECR1149: Ambient Air Replicate Sample Data (Bq/L) Table TECR1150: Ambient Water Replicate Sample Data (Bq/L) In statistical summary calculations, values that were <DL were set to DL 1 in Bq/L Table TECR1151: Monitoring Well Water Replicate Sample Data (Bq/L) Figures Figure FECR1101: Peterborough Airport, August Figure FECR1102: SSI Manufacturing Facility... 3 Figure FECR1103: SSI Organizational Structure... 4 Figure FECR1104: Five Year Comparison of Tritium Processed... 5 iv

5 Figure FECR1105: 2011 Monthly Tritium Stack Emissions... 7 Figure FECR1106: Annual HTO Emissions ( )... 9 Figure FECR1107: Annual HT Emissions ( ) Figure FECR1108: Annual Volume of Water Released (L) Figure FECR1109: Annual Liquid Effluent Tritium Release (TBq) Figure FECR1110: Environmental Locations within a 1 km Radius Figure FECR1111: Environmental Locations within a 10 km Radius Figure FECR1112: Monitoring Well Locations Figure FECR1113: Tritium Exposure Pathways Considered in Dose Calculations v

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7 1.0 Introduction 1.1 General Introduction This report is Appendix A (Environmental Monitoring Annual Compliance Report) of the 2011 Annual Compliance Report for Shield Source Incorporated (SSI). A summary of the 2011 environmental monitoring results including stack emissions, air, water, monitoring wells and vegetation monitoring data is contained within this report. Stack emissions have been compared with the environmental monitoring data and dose to the receptor group has been calculated. 1.2 Company Introduction Shield Source Incorporated (SSI) operates a Class 1B Nuclear Facility under Nuclear Substance Processing Facility Operating Licence NSPFOL 12.00/2012 issued by the Canadian Nuclear Safety Commission on August 1st, We submit this Annual Compliance Report in fulfillment of condition 8.4 of our Licence including the information provided in Annual Compliance Monitoring and Operational Performance Reporting Requirements for Class 1 A & B Facilities (CNSC, EDoc# ). Our current expires on July 31, An application for the renewal of this licence was submitted in the Fall of Our current Licence allows SSI to operate a nuclear substance processing facility to possess, use, transfer, process, manage, and store nuclear substances that are required for, associated with or arise from the operation of the facility. There have been no changes to licensed operations in In 2011, SSI participated in a mid term licence hearing to review the status of our current licence. The feedback received from the CNSC Commission was encouraging and included no major issues of concern. The Commission did request that we review our Public Information Program and consider a more proactive approach to communicating with the public. SSI updated our Public Information Program in September 2011 to reflect the suggestions and add additional information as well as expand the current program. In 2011, SSI achieved certification to the ISO AS9100 Quality Management System which introduces more structure to the existing processes and procedures and included the creation of procedures for Change Control, Use of Experience and Maintenance. SSI did not have any reportable events in 2011, which include Action Level or Release Limit exceedances. Through our programs and our commitment to keep exposure as low as reasonably achievable (ALARA), SSI has kept radiation exposures to our employees and the public significantly below the allowable dose limits. Environmental emissions including both liquid and air are monitored and limited to levels that are considerably below regulatory limits thereby safeguarding the public and the environment. 1

8 1.3 Land Use within the Monitoring Program Area A description of the land use within the SSI monitoring area was given in SSI s report entitled 2000 Annual Report on Environmental Monitoring Program Shield Source Inc. (Golder Associates) and submitted to the CNSC in April SSI conducted an additional survey in November 2005 and found that much of the wooded area within the Peterborough Airport property had been cleared and marsh lands within the property have been filled in to support commercial development as reported in the 2005 Environmental Monitoring Program Annual Report. In 2008, the Peterborough Airport began construction expanding the tarmac over additional portions of the airport property as the first phase of commercial expansion development. In 2010, new roadwork within the Airport facility changed the layout of the land to the west of the facility by extending the road to access the future terminal area. Completion of the realignment of the Cavan Creek, Apron II and the runway expansion on the southwest end of the airport property has been completed in Additional work at the Airport was completed in the summer of 2011 and included a grass tie down area, parking lots, new terminal building completion, commercial lot preparation and completion of the access roads as shown in Figure FECR1101. Further construction of hangers, signage and landscaping has been continuing into Facility Operation The nuclear facility is located in Peterborough, Ontario at 925 Airport Road. The site is located at the Peterborough Municipal Airport and is part of the industrial area of the airport. The building is a two storey structure containing more than one tenant. The remaining part of the building is utilized for aircraft support industry and services. SSI occupies 300 m 2 of licensed area at the northwest corner of the building encompassing production, warehousing and office space. An aerial shot of the SSI facility is provided in Figure FECR1102. SSI continues to strive for operational excellence with programs that encourage quality, education and growth through continuous improvement while ensuring the safety of the environment, the public and our workers. Processes and procedures, including those for Radiation Safety, Waste Management, Environmental Monitoring, Purchasing, Maintenance and Quality are outlined in both our Quality Management Program (QMP) and AS9100 Quality Management System documents. 2

9 Figure FECR1101: Peterborough Airport, August 2011 Figure FECR1102: SSI Manufacturing Facility There are six members of our on site Management Team: the General Manager; Operations Manager; Production Engineer; Radiation Safety Officer (RSO); Office Manager and Plant 2 Supervisor. With input and guidance from the President and Chief Financial Officer (CFO), the Management Team is 3

10 responsible for all operations within our facilities. Our organizational structure is shown in Figure FACR1103. Figure FECR1103: SSI Organizational Structure Production Details In 2011 SSI processed TBq of Tritium and produced 695,381 gaseous tritium light sources as outlined in Table TECR1101 and seen in Figure FECR1104. The amount of Tritium processed and tube production numbers are slightly more than in The maximum amount of tritium processed in 2011 was during the month of March, in which TBq was used. 4

11 Table TECR1101: Total Tritium Processed TRITIUM PROCESSED (TBq) MONTH JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV DEC TOTAL TRITIUM PROCESSED MAXIMUM AVERAGE NUMBER OF TUBES PRODUCED Figure FECR1104: Five Year Comparison of Tritium Processed 5

12 2.0 Environmental Monitoring SSI has created an EMP to monitor levels of tritium emitted from SSI to the environment. The EMP is implemented not only to satisfy SSI s licence conditions within the Nuclear Safety and Control Act and its regulations, but to ensure protection to SSI s employees, the public and the environment. Sampling is done to obtain a comprehensive picture of SSI s footprint on the surrounding environment. Our EMP includes monitoring liquid effluent (water released to the sewer) and stack emission (air releases from our stack) from SSI s facility on a daily basis. In addition, SSI collects samples from all possible pathways of contamination, which includes Ambient Air & Water; Monitoring Well Water; Drinking Wells; and Vegetation. The SSI EMP was updated in 2011 and approved by the CNSC in January The 2011 sampling program consisted of the collection of six types of samples stack emissions, liquid effluent, ambient air samples, ambient water samples, monitoring well samples and vegetation samples. Stack emissions and liquid effluent were measured continuously from the SSI facility. Ambient air, ambient water samples and the monitoring well samples were collected monthly from sample locations located within a 16 km radius of the SSI ventilation stack. Vegetation samples were collected during harvest time, which was between July and October. In October 2009, SSI made changes to its ventilation stack, which included increasing the height and exit velocity. In October 2009, to better evaluate the effect that the height increase of the ventillation stack has on the environment we increased our sampling frequency for all sample locations greater than 1 km from the SSI stack from quarterly to monthly. The sampling results are described in the following sections. 2.1 Stack Emissions SSI monitors both Tritium Gas (HT) and Tritium Oxide (HTO) continuously. Total HT+HTO stack emissions are recorded daily and HTO activity readings are calculated weekly. The weekly, monthly and yearly stack emissions are then calculated. The current Release Limits as set in our Licence were used to create the basis for all Action and Administrative Levels. SSI s facility did not change the Action and Administrative Levels. As a result of SSI s production process, tritium is emitted into the environment through stack emissions. Emissions consist of tritium gas (HT) and tritium oxide (HTO). HTO is formed when HT mixes with water in the environment to form HTO. 6

13 2.1.1 Monthly Stack Emissions Results Monthly tritium stack emissions results are presented in Table TECR1102 and illustrated in Figure FECR1105. Table TECR1102: 2011 Monthly Tritium Stack Emissions Month HTO HT Total Released Released Activity Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total Average Maximum Minimum Figure FECR1105: 2011 Monthly Tritium Stack Emissions 7

14 The maximum release of HT and HT + HTO occurred during the April 2011 sampling period, when activities of TBq of HT and TBq of HTO + HT were recorded. This is due to increased production in late March and early April. The maximum release of HTO occurred during the September 2011 sampling period, when an activity of 5.69 TBq was recorded. The minimum stack emission for HTO released occurred during the May 2011 sampling period when an activity of 1.42 TBq was recorded. The minimum HT and HT + HTO release occurred during the August 2011 sampling period when activities of 5.86 TBq of HT and 8.27 TBq of HT + HTO were recorded Annual Stack Emissions Results Stack emissions for the last 5 years are shown in Table TECR1103 and Figures FECR1105 and FECR1106. As the Table and Figures show, the HTO emission values increased significantly in 2010 and The timing of these increased emission levels coincided with the modifications that we made to our exhaust stack system. When these increases first appeared, we began an investigation process to determine the cause. As there had been no quantifiable change in our production levels or processing procedures, we were unable to immediately identify the cause for these increases. As an initial step, we replaced the gas flow meter based on our belief that we were getting incorrect gas flow values which would influence our HTO calculations. Due to problems with the supplier, it took six months to implement this corrective action. When the new meter was installed, our gas flow readings returned to our normal range, but the HTO emissions remained higher than we expected. We then performed a maintenance overhaul of the impinger system replacing hoses, lines and fittings. When this failed to correct the problem, we hired a third party to run a sampling system in parallel with ours to compare results. Initial third party sampling data was consistent with our data thereby forcing us to re evaluate the problem. Within the next 12 months, SSI will be exploring options for the installation of an air make up system to improve the air flow within the facility. We will also be replacing the existing stack fan and motor as part of our preventive maintenance program. The increase of HT in 2010 was as a result of our accidental release of TBq of HT on February 1st,

15 Table TECR1103: Air Emissions released from the facility ( ) HTO EMISSIONS (TBq) HT EMISSIONS (TBq) MONTH January February March April May June July August September October November December TOTAL: AVERAGE: MAX: MIN: Figure FECR1106: Annual HTO Emissions ( ) Based on our research efforts to date, we have recently identified that the increased HTO emissions may be the result of less than adequate air flow through our system. It was suggested by an outside consultant that low air flow levels could cause gas to convert to HTO while in the copper tubing in our tritium fill machine. We have subsequently introduced outside air into the system to improve air flow 9

16 and have started to see a drop in our HTO emissions. As there is insufficient data to draw any conclusions, we will continue to monitor results and take appropriate action. Although the oxide emissions were higher than our expected values, we did not exceed our Action Levels during this period. Figure FECR1107: Annual HT Emissions ( ) CNSC Release Limits, Action Levels and Administrative Levels The CNSC licence number NSPFOL 12.00/2012 issued on August 1st, 2009, imposed Release Limits at the facility which are 70 TBq of HTO and 500 TBq of Total Tritium (HT + HTO). SSI s current licence requires the CNSC to be notified if, at any time, the Action Level or Release Limits are exceeded. In 2011, SSI did not exceed any Action Levels. All Limits and Levels for tritium emissions are shown in Table TECR1104. In addition, in order to meet radiation protection requirements, SSI has set Administrative Levels to alert the company prior to Action Levels being reached. If HTO emissions exceed 35 TBq/year or 1 TBq/week, or if the HT emissions exceed 119 TBq/year or 3.4 TBq/week, SSI evaluates the situation and, where appropriate, implements procedures to prevent reoccurrence and reduce risk to persons and/or the environment. SSI exceeded the weekly HTO administrative levels for the weeks of January 18 th to January 25 th, February 1 st to February 8 th, March 1 st to March 8 th, June 21 st to June 28 th, August 30 th to September 6 th, September 20 th to September 27 th, September 28 th to October 4 th, November 15 th to November 22 nd, November 22 nd to November 29 th and December 6 th to December 13 th when SSI released 1.08, 1.05, 1.44, 1.19, 1.89, 1.35, 3.16, 1.25, 1.89 and 1.12 TBq respectively. The weekly HT administrative levels were exceeded the week of January 4 th to January 11 th when SSI released 4.05 TBq. 10

17 Table TECR1104: Licence Limits and Internal Levels for Tritium Emissions Tritium Oxide (HTO) Tritium Gas (HT) Total Tritium (HT + HTO) Release Limits 70 TBq/Year 500 TBq/year Action Levels 5 TBq/Week 17 TBq/Week n/a 50 TBq/Year 170 TBq/Year n/a Administrative 1 TBq/Week 3.4 TBq/Week n/a Levels 35 TBq/Year 119 TBq/Year n/a 2.2 Liquid Effluents Liquid effluents containing tritium contamination result from the following process: the decontamination of the GTLS and parts, water from laundering of personnel protective equipment, air conditioning condensation and general cleaning of the tritium fill room and decontamination room. These effluents are captured in holding tanks and tested prior to being released. We have kept our 5 year average release for liquid effluents below 4% of the licensed limit of 100 GBq/year. Our liquid effluent releases during our Licence period are summarized in Table TECR1105 and illustrated in Figures FECR1108 and FECR1109. In 2010, to reduce the amount of contaminated solid waste sent for burial, we initiated a procedure to wash low level contaminated waste to make it suitable for the normal waste stream. While we were successful in reducing the quantity of contaminated solid waste sent to a licensed facility for burial, we also found that this activity had the adverse effect of increasing our contaminated liquid effluents. As the tables to follow show, in 2010, solid waste decreased to 4 m 3 from 7 m 3 in 2009, however, there was a corresponding higher than anticipated increase in the contaminated liquid effluents released from 2% of our allowable licence limit in 2009 to 7% of our allowable licence limit in Based on this result, we discontinued our cleaning procedure in 2011 and reverted to sending contaminated solid waste to a licensed facility for burial. There were no unplanned releases of liquid tritium effluents or any other type of hazardous material from SSI during our licensed period. 11

18 Table TECR1105: Liquid Effluent released into the sewer system ( ) Tritium Concentration Total Volume Released (L) Release Limit (TBq/year) % 1.9% 2% 7% 4% Figure FECR1108: Annual Volume of Water Released (L) 12

19 13 Figure FECR1109: Annual Liquid Effluent Tritium Release (TBq)

20 2.3 Environmental Monitoring Locations A list of the environmental monitoring locations is listed in Table TECR1106: Locations Description Table TECR1106: SSI EMP Sampling Locations Distance from the Stack (m) Direction from the stack AMBIENT WATER AND AIR SAMPLES A1 Airport Beacon Tower 40 north east A2 Fence at Fuel House 240 south east W2 Water from Washroom tap at Airport City Water 240 south east A3 Airport Road Turnabout, east side of the road 210 south east W3 Pond just to the north east of the Airport Road Turnabout 170 south east A4 Along Airport Road at Creek, across from the Pump House 250 north W4 Along Airport Road at Creek, across from the Pump House 250 north A5 Tree at House opposite SSI 220 north east WW5 Well water from house opposite SSI 220 north east WG5 Pond at house opposite SSI 220 north east W6 Wetland at tree line west of SSI 210 south west A6 Tree at wetland west of SSI 210 south west A7 Mel O'Brien Rd. at end of chain fence 200 north west A8 Pond/creek at west side of Airport Rd just prior to bend 870 south east A9 Cavan Creek 1500 south west W9 Cavan Creek 1500 south west A10 Culvert at Beardsmore Road 1500 north W10 Culvert at Beardsmore Road 1500 north A11 Marshy area 1.2 km due east of SSI adjacent to Otonabee River 1200 east W11 Marshy area 1.2 km due east of SSI adjacent to Otonabee River 1200 east A12 Airport Road near Hwy 115 Culvert 1000 north west W12 Pond on Airport Road near Hwy 115 Culvert 1000 north west A13 Mervin Line, swampy area 1000 west W13 Mervin Line, swampy area 1000 west A14 Adjacent to main runway, stake at pond 1000 south west W14 Adjacent to main runway, at pond 1000 south west A15 Fraserville access to Otonabee River 2500 south W15 Fraserville access to Otonabee River 2500 south W17 Background sample 16 km NE of stack Well Water north east A17 Background sample 16 km NE of stack north east W19 Airtech City Water 200 west 14

21 Locations Table TEAR1107: SSI EMP Sampling Locations continued Description Distance from the Stack (m) Direction from the stack VEGETATION SAMPLES V1T Apple Tree on Brealey Drive from the tree 4450 north V1G Apple Tree on Brealey Drive from the ground 4450 north V2 Grapes on Brealey Drive 4010 north V3 Grapes on Mervin Line 1870 north east V4 Grapes on Beardsmore Road 1170 north east V5T Apple Tree on Airport Road from the tree 220 north east V5G Apple Tree on Airport Road from the ground 220 north east MONITORING WELL WATER SAMPLES MW1 lawn in front of parking lot W of Airport Road 82 east MW2 Side Lawn fence 38 north east MW3 Adjacent to stack on back lawn 2 west MW4 Parking lot south east of stack 57 south east MW5 Lawn in front of parking lot W of Airport Road 130 north MW6 Lawn in front of parking lot W of Airport Road 100 north MW7A Lawn in front of parking lot W of Airport Road 110 north east MW7B Lawn in front of parking lot W of Airport Road 110 north east MW8 Lawn in front of parking lot W of Airport Road 120 east MW10 South of Mervin Line 310 west Figure FECR1110 and FECR1111 show the environmental sampling locations within 2 km and 10 km respectively. 15

22 Figure FECR1110: Environmental Locations within a 1 km Radius Figure FECR1111: Environmental Locations within a 10 km Radius 16

23 2.4 Ambient Air Ambient Air samples are collected regularly using an engineered passive air sampling system. In 2011, we commissioned a third party to conduct a parallel active air sampling program at our critical receptor. This was initiated in January 2012 with results expected in our 2012 Annual Compliance Report Sampling Method Passive air monitors were used to assess tritium activity in air. The samplers consist of containers filled with distilled water and capped with a diffusion cap (designed by Ontario Hydro Technologies). Tritium oxide and tritium gas diffuse into the vial and dissolve in the distilled water. Ethylene glycol is added to the distilled water during the winter months to prevent freezing. The samplers are deployed one metre above the ground by attaching them to an available surface (post, tree) or where no surface exists, stands are constructed. The sampler is attached so that it always faces the ventilation stack. A small plastic container with air holes is suspended in the inverted position over the sampler to protect it from the elements. The sampler is left for a one month period and then retrieved for analysis. The sampling liquid is analyzed by liquid scintillation counting through an independent third party. Energy Solutions Inc. was contracted by SSI to perform the analyses on the air samples collected in The passive air monitoring data must be converted from Bq/L in sampling liquid to Bq/m 3 in air. There is no standardized accepted calculation for this conversion. Numerous assumptions must be made in order to estimate the volume of air sampled by a passive device. The conversion calculations and the assumptions made are presented in Appendix A Sample Availability There were 240 planned ambient air sample collections in 2011 and 231 actual collections performed. Five samples were unavailable due to tampering of the samplers causing one sample to be knocked over, two to be cross contaminated and two were removed. Four samplers were unavailable due to flooding or access restrictions to collect the sample. Therefore 96% of valid ambient air sample collection was achieved compared to planned collection Results The ambient air monitoring data collected from January to December 2011 are provided in Table TECR1109. Comparisons of average and maximum ambient air monitoring results for each sample location for 2009 to 2011 are given in Table TECR1108. There were no changes to the location of air samplers in

24 Based on the assumptions used from Appendix A2 the passive sampling data was converted from Bq/L in sampling liquid to Bq/m 3. The highest annual average tritium activity in ambient air was 1.07 Bq/m 3 collected from sample location A3 which is located 210 metres SE of the SSI stack. The highest annual maximum tritium activity in ambient air was 4.61 Bq/m 3 collected in September from sample location A6 which is located 210 metres SW of the SSI stack. In 2011 the fan speed in the exhaust stack remained at a constant speed of 60 MHz during both production and non production hours. Table TECR1108: Ambient Air Environmental Sampling Results Location Average (Bq/m 3 ) Maximum (Bq/m 3 ) A A A A A A A A A A A A A A A A A A A A

25 19 Table TECR1109: 2011 Ambient Air Monitoring Data (Bq/m 3 )

26 2.5 Ambient Water Following the 2009 Ontario Drinking Water Advisory Council report regarding release limits for tritium in drinking water 1, SSI found and began using a laboratory capable of testing water samples for tritium contamination to a level of 8 Bq/L or lower in an effort to verify that drinking water levels and drinking water tested are well below the proposed annual average of 20 Bq/L. Drinking water locations include W2, WW5, W17 and W19. Since June 2009 all results have been well below the recommended proposed levels. In addition to the sampling that is included in our EMP, we also collect bi annual water samples from the Peterborough Waste Water Treatment Facility. The samples have always been below the lowest possible minimum detection limit Sampling Method Water samples were collected and analyzed on a monthly basis by liquid scintillation counting conducted by independent third party laboratories at Energy Solutions Inc. and Kinectrics Incorporated. Since June 2009 we used Kinectrics Incorporated exclusively for the testing of drinking water as their equipment was capable of lower detection limits. Water samples were collected in suitable laboratory containers and triple rinsed with the sample water Sample Availability There were 192 planned water sample collections scheduled for 2011 with 147 actual collections performed. During the winter months, January and February, all of the ground water sample locations were frozen and could not be obtained with only 4 samples available in both March and December. W6 was unavailable in 2011 due to changes to the airport landscape which removed the marsh area that was previously sampled. Therefore 77% of valid water sample collections were achieved compared to planned collection Results The ambient water monitoring data collected from January to December 2011 are provided in Table TECR1111. A comparison of average and maximum ambient water monitoring results for each sample location for 2009 through 2011 is given in Table TECR1110. The highest annual average tritium activity detected from Table TECR1110 in ambient water samples was 912 Bq/L from sample location W3 that is located 170 meters southeast of the SSI stack. The highest annual maximum tritium activity detected in ambient water samples was 1570 Bq/L from sample location W3 that is located 170 meters southeast of the SSI stack. A comparison of the 1 Report and Advice on the Ontario Drinking Water Quality Standard for Tritium, Ontario Drinking Water Advisory Council May 21,

27 average and maximum activities for each sample location from 2007 through 2011 is given in Table TECR1110. Table TECR1110: Ambient Water Environmental Sampling Results Location Average (Bq/L) Maximum (Bq/L) W2 26 <7 <7 <50 <7 <8 W W WW5 25 <7 <7 <50 <7 <8 WG W < <7 W W9 <50 74 <50 < <50 W10 <50 79 <50 < <50 W11 <50 58 <50 < <50 W < <50 W < <50 W W < <50 W17 18 <7 <7 <50 <7 <8 W19 30 <7 <7 <50 <7 <8 21

28 22 Table TECR1111: 2011 Ambient Water Monitoring Data (Bq/L)

29 2.6 Monitoring Well Water As part of our EMP, we sample monitoring wells which we installed around our facility. As a result of a 2009 Groundwater Study conducted by a third party consultant, SSI installed seven new monitoring wells in January 2010 to improve our understanding of the ground water hydrogeology around the SSI facility. After 6 months of sampling data, we were forced to decommission Well 9 due to the Peterborough Airport construction. Additional testing related to our Groundwater Study was completed in late 2011 to verify the water flow to the east of the SSI facility. The report will be completed and submitted to the CNSC in Figure FECR1112 shows the sampling locations of our monitoring well water. Table TECR1112 shows the sampling data for each well in Figure FECR1112: Monitoring Well Locations Sampling Method Monitoring Well water samples were collected and analyzed by liquid scintillation counting, conducted by an independent third party on a monthly basis. Monitoring Well water samples were 23

30 collected in suitable laboratory supplier purchased containers and triple rinsed with the sample water Sample Availability There were 120 planned well water sample collections scheduled for 2011, with 120 actual collections performed. Therefore 100% of valid well water sample collection was achieved compared to planned collection Results The monitoring well water data collected from January to December 2011 is provided in Table TECR1113. The highest annual average tritium activity detected from Table TECR1112 in monitoring well water samples was 15,664 Bq/L from sample location Well 3 located approximately 2 m West of the SSI stack. The highest annual maximum tritium activity detected in monitoring well water samples was Bq/L from the same sample location Well 3 located approximately 2 m North of the SSI Stack in April A comparison of the average and maximum activity in 2009 through 2011 is given in Table TECR1112. SSI has compared the results of the monitoring well water data against stack emission data and corresponding weather data and have not found a direct correlation in the monitoring well water results. Table TECR1112: Monitoring Well Water Sampling Results Location Average (Bq/L) Maximum (Bq/L) Well Well Well Well Well Well Well 7A Well 7B Well Well 9* Well < <50 *Well 9 only includes 6 months of data because of decommissioning due to Airport construction. 24

31 Date Well 1 Table TECR1113: Monitoring Well Water Data (Bq/L) Well 2 Well 3 Well 4 Well 5 Well 6 Well 7A Well 7B Well 8 Well 10 Avg/ Month 27 Jan < < Feb < < Mar < < Apr < < May < < Jun < < Jul < < Aug < < Sep < < Oct < < Nov 11 < <50 < < < Dec < Average <50 Maximum < <50 Distance (m) Direction E N W E N N NE NE E W ( ) indicates no sample collected or analyzed. < indicates measured level is below detection limit (DL). In statistical summary calculations, values that were below the detection limit were set to DL 1 in Bq/L 25

32 2.7 Vegetation Vegetation sampling during our Licence period has consisted of apples and grapes within 5 km of the facility. It was found that in 2009 and 2010 the harvest cycle for wild vegetation was unpredictable and the monthly sampling requirement was inadequate. In 2011, we increased our sampling schedule to allow for more sampling in a shorter period and our results are presented in Table TECR1114. SSI plans to continue with this increased sampling schedule. In an effort to collect a true representation of the tritium concentration in the apples, SSI collected from both the tree and the ground for all 2011 apple sampling as shown in Table TECR1114. Table TECR1115 shows the average and maximum values for vegetation sampling during our Licence period Sampling Method Vegetation samples (apples and grapes) were collected during the 2011 harvest season. Samples were taken from the ground, and were sealed in plastic bags and analyzed by an independent third party for tritium by liquid scintillation counting Sample Availability There were 42 planned vegetation sample collections scheduled for 2011 with 38 actual collections performed. 4 samples of wild grapes were not collected due to lack of sample when sampling. Therefore 90% of valid vegetation sample collections were achieved compared to planned collection Results The vegetation monitoring data collected from July 2011 to October 2011 is provided in Table TECR1114. A comparison of average and maximum vegetation monitoring results for each sample location for 2009 through 2011 is given in Table TECR1115. The highest average tritium activity in 2011 detected from Table TECR1115 in vegetation samples was 1478 Bq/L from sample location V5G that is located 220 meters North east of the SSI stack. The highest maximum tritium activity IN 2011 detected from Table TECR1115 in vegetation samples was 2470 Bq/L from sample location V5G that is located 220 North east of the SSI stack. A comparison of the average and maximum activities for each sample location from 2009 through 2011 is given in Table TECR1115. The higher activity levels found in the samples from location V5G & V5T are due to the fact that apples are comprised of approximately 20% air and 80% water. Apple trees pull water from their roots, in which the roots of a tree will find the closest water source to draw from in order to obtain regular water. Many mature trees do not use the water from precipitation to gather water 26

33 (as this is not a consistent water source) but rather will extend their roots to water sources underground or nearby. In the case of the mature apple tree located at sample location V5, east of the stack, it would have extended its roots to the pond area, sample location WG5, as a nearby water source. SSI saw lower average and maximum tritium concentrations in pond values in 2011, which is reflected in the apples at location V5, as the average and maximum tritium concentration are lower in 2011 as well. Table TECR1114: 2011 Vegetation Sampling Results (Bq/L) DATE APPLES APPLES GRAPES GRAPES GRAPES APPLES APPLES V1G V1T V2 V3 V4 V5G V5T From Ground From Tree From Ground From Tree Jul 12, Aug 2, Aug 11, Aug 30, Sep 16, Oct 5, Future Plans Table TECR1115: Vegetation Sampling Results (Bq/L) Location Average Maximum V1G V1T V V V V5G V5T SSI will continue to monitor the environmental results to evaluate the needs for any future monitoring. We will review our EMP annually to ensure that we are following the procedures and to assess the need for modification to the program or any of the related activities. Upon the completion of the Peterborough Airport Construction and the report findings from the supplementary Ground Water Study, we will coordinate the replacement of Well 9. 27

34 3.0 Calculated Doses to the Critical Receptor 3.1 Dose Calculation Methodology The CSA document Guidelines for Calculating Derived Release Limits for Radioactive Material in Airborne and Liquid Effluents for Normal Operation of Nuclear Effluents (CSA N288.1, 2008) was used as guidance to evaluate the transfer of tritium in the environment and the potential exposures by the general public. For transparency, the exposure assumptions for the critical receptors that are outlined by ICRP are provided in Appendix A to this report. Figure FECR1113 illustrates the potential exposure pathways considered in this evaluation for the transfer of tritium due to airborne releases of elemental tritium (HT) and tritiated water (HTO). Figure FECR1113: Tritium Exposure Pathways Considered in Dose Calculations To estimate the annual dose for tritium, the following three age categories were assessed with respect to radiation exposure (see TECR1116): Table TECR1116: Age Classes Considered in Dose Calculations Designation Age Range (years) Nominal age characteristics for dose coefficients Infant year Child years Adult adult 28

35 For each age group, multiple exposure pathways were considered in the dose calculations (see Figure FECR1113). These pathways include the following: Direct inhalation of HT and HTO in air (includes skin absorption pathway for HTO); Direct ingestion and immersion of HTO in water; Ingestion of vegetation containing HTO and OBT (organically bound tritium); Ingestion of animal produce containing HTO and OBT; and, Transfer of HTO and OBT via breast milk (infant receptor only). Exposure through skin absorption was accounted for in the inhalation of HTO in air pathway. The transfer parameter value for HTO includes a factor of 1.5 in the dose conversion factor (DCF) to allow for absorption of tritiated water vapour through the skin. The ingestion of aquatic plants and animals is an exposure pathway evaluated in previous Annual Environmental Monitoring reports (SENES, 2006 to 2008). However, this exposure pathway was excluded in the dose calculations provided herein because, given the facility setting, the pathway is not relevant for the receptor locations evaluated within the study area and its inclusion was considered to be overly conservative. The ingestion of animal produce considers consumption of beef, poultry, eggs, and cow milk. Based upon knowledge of the study area, at one point a dairy farm was identified to be greater than 2.5 km southeast of the SSI facility; however, the livestock was sold in Based on information received by SSI, it is understood that other farms in the area that include livestock are not being used for milking. Therefore, this pathway is considered to be an unlikely exposure pathway within the study area for the evaluated receptors. However, given that this pathway has driven the estimated annual doses in previous years, the calculation has been included for comparison purposes. The choice of a critical group and the critical radiation exposure pathways requires some professional judgement. While it is evident that there are no dairy herds in the immediate vicinity of the SSI facility at this time, the use of the property is not within the control of SSI. In other words, at least in theory, there is nothing to prevent someone from reestablishing a dairy herd on the property adjacent to the SSI facility at any time in the future. This is the primary reason why it was felt that the potential consumption of milk from cows grazing on land adjacent to the SSI facility had to be included in the dose estimates. Doses of HT, HTO and OBT for each age group were calculated using a series of transfer parameters provided in Appendix A of the CSA Guidelines (2008). The transfer parameters used in the dose calculations are summarized in Tables TECR1117, TECR1118 and TECR1119. The transfer parameters and transfer factors for plant and animal tissues are provided in terms of fresh weight (fw). 29

36 30 Table TECR1117: Transfer Parameters used in Human Dose Calculations Transfer Parameter Form of Tritium Infant Child Adult Units TP 1 HTO 2.2E E E 07 (Sv/year)/(Bq/m 3 ) HT 1.5E E E 11 TP 2ing HTO 1.9E E E 08 (Sv/year)/(Bq/L) OBT 4.7E E E 08 TP 2imm HTO 5.6E E E 10 (Sv/year)/(Bq/L) TP 7 HTO 1.6E E E 09 (Sv/year)/(Bq/kg fw) OBT 4.0E E E 09 TP 8meat HTO 6.3E E E 09 (Sv/year)/(Bq/kg fw) OBT 1.5E E E 09 TP 8milk HTO 2.0E E E 09 (Sv/year)/(Bq/kg fw) OBT 4.8E E E 08 Note: ing =ingestion of well water; imm =immersion in well water (i.e., bathing); meat =ingestion of meat; milk =ingestion of milk Table TECR1118: Transfer Parameters used in Vegetation Dose Calculations Transfer Parameter Form of Tritium Fruits and Vegetables Units TP 3 HTO 5.6E+01 (m 3 /kg fw) TP 5 HTO 9.0E 01 (L/kg fw) OBT 4.5E 02 Table TECR1119: Transfer Parameters and Transfer Factors used in Animal Dose Calculations Transfer Parameter Form of Tritium Cow Milk Beef Poultry Eggs Units TP 4 HTO 2.2E E E E+00 (m 3 /kg fw) OBT 1.3E E E E 01 TP 6 HTO 4.9E E E E 01 (L/kg fw) OBT 2.9E E E E 01 TF 1 HTO 2.7E E E E 01 Unitless OBT 5.9E E E E 02 OBT concentrations in plants were predicted through the synthesis of HTO in pond water and air using a partition coefficient of 60% HTO and 40% OBT. OBT concentrations in animals were modelled through the synthesis of HTO in pond water, air and plants using a 50% partition coefficient. Exposures to HTO and OBT by infants via breast milk transfer were estimated using conservative assumptions and using the estimated maternal doses of tritium from all pathways. It was assumed that 100% of tritium absorbed from nursing mother s ingestion of water and food, and inhalation of air are transferred to breast milk. Infants are assumed to nurse for a one year period with a breast milk ingestion rate of 0.8 L/day (CSA, 2008). The HTO and OBT transfer factors for maternal ingestion are 0.39

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