Proposed radioactive liquid effluent monitoring requirements at the Savannah River Site

Clear regulatory guidance exists for structuring a radiological air monitoring program, however, there is no parallel guidance for radiological liquid monitoring. For Department of Energy (DOE) facilities, there are no existing applicable federal regulations, DOE orders, or DOE guidance documents that specify at what levels continuous monitoring, continuous sampling, or periodic confirmatory measurements of radioactive liquid effluents must be made. In order to bridge this gap and to technically justify and document liquid effluent monitoring decisions at DOE's Savannah River Site, Westinghouse Savannah River Company has proposed that a graded, dose-based approach be established, in conjunction with limits on facility radionuclide inventories, to determine the monitoring and sampling criteria to be applied at each potential liquid radioactive effluent point. The graded approach would be similar to--and a conservative extension of--the existing, agreed-upon SRS/EPA-IV airborne effluent monitoring approach documented in WSRC's NESHAP Quality Assurance Project Plan. The limits on facility radionuclide inventories are based on--and are a conservative extension of--the 10 CFR 834, 10 CFR 20, and SCR 61-63 annual limits on discharges to sanitary sewers. Used in conjunction with each other, the recommended source category criteria levels and facility radionuclide inventories would allow for the best utilization of resources and provide consistent, technically justifiable determinations of radioactive liquid effluent monitoring requirements