**NRC INSPECTION MANUAL** RNRP

INSPECTION PROCEDURE 69004

CLASS I RESEARCH AND TEST REACTOR EFFLUENT AND

ENVIRONMENTAL MONITORING

PROGRAM APPLICABILITY: 2545

69004‑01 INSPECTION OBJECTIVE

To determine if the licensee\'s environmental monitoring program has
been effectively maintained to meet regulatory requirements and licensee
commitments, since the last inspection.

69004‑02 INSPECTION REQUIREMENTS

02.01 [Effluent Reports]{.underline}. Determine if effluent releases
reported in the licensee\'s Annual Report or other required report were
within regulatory limits.

02.02 [Effluent Control, Monitoring and Records]{.underline}. Determine
if radiological releases, were controlled, monitored, and recorded as
required.

02.03 [Environmental Monitoring]{.underline}. Determine if the facility
environmental monitoring program meets regulatory requirements and
licensee commitments.

02.04 [As Low As Reasonably Achievable (ALARA)
Considerations]{.underline}. Determine if facility effluent releases are
maintained as required by the licensee\'s ALARA program.

02.05 [Waste Storage]{.underline}. Determine if gaseous, liquid, and
solid radioactive wastes are accounted for and stored as required.

02.06 [Cold Water Chemistry]{.underline}. Determine if the licensee has
controlled cold water chemistry as required.

02.07 [Constraint on Radioactive Air Effluents]{.underline}. Determine
whether the licensee meets 10 CFR 20.1101(d) requirements on the
magnitude of radionuclides annually emitted to the ambient air from the
facility, and if not, determine if the licensee meets 10 CFR 20.1101(d)
requirements for reporting.

69004‑03 INSPECTION GUIDANCE

[General Guidance]{.underline}

General guidance may be found in the ANSI/ANS Section 15 Standards
listed in Appendix B to Inspection Procedure 69001, \"Class II Non‑Power
Reactors.\" Additional general guidance may be found in the Division 2
Regulatory Guides, and the \"Other Regulatory Guides of Possible
Interest to Division 2 Recipients\" listed in the Division 2 Regulatory
Guides Table of Contents. This guidance is to aid in the technical
evaluation of licensee programs and is not to be used as requirements
unless the licensee has committed in writing to the NRC for the use of
the specific guidance document.

The sample sizes suggested in this inspection procedure are provided for
broad planning purposes and to define the typical depth of the
inspection. They are not intended to be rigid requirements on the
inspector.

[Specific Guidance]{.underline}

03.01 [Effluent Reports]{.underline}. Regulatory requirements for
concentrations of radiological nuclides that may be released to the
ambient air can be found in Table 2 of Appendix B to 10 CFR Part 20 and
in some cases the licensee\'s Technical Specifications (TS). Regulations
for the release of liquid effluents to the sanitary sewage system is
provided in Table 3 of Appendix B to 10 CFR Part 20. The report of
effluent releases is normally found in the licensee\'s Annual Report or
other report as required by TS. These reports are usually available in
the office. If the licensee\'s report on effluents is not available in
the office, it can be obtained from the licensee. The report of effluent
releases, the TS, the Safety Analysis Report (SAR), and the Safety
Evaluation Report (SER) are to be reviewed before conducting the onsite
inspection. Discharge paths and reporting requirements for the release
of radiological materials into the environment are identified in the TS,
SAR and SER. Comparison of these documents to the as‑built condition of
the facility are to be made to assure that no new release paths were
created by such things as design changes and maintenance.

03.02 [Effluent Control, Monitoring, and Records]{.underline}. The
observation of the actual conduct of two releases of radionuclides to
the ambient air and two liquid effluent releases is an acceptable sample
for this inspection requirement. If actual releases cannot be observed,
the licensee\'s records for two gaseous and two liquid effluent releases
since the last inspection are to be reviewed. Are the records current
and maintained in accordance with 10 CFR Part 20, Subpart L? If the
licensee was authorized to release concentrations above the limits in
Tables 2 or 3 of Appendix B to 10 CFR Part 20, do the licensee\'s
records confirm compliance with the applicable conditional release
limits in the TS or license? Liquid effluent from research and test
reactors is normally discharged to the sanitary sewer system with credit
taken for dilution by normal flow in the system. The liquid effluent
concentration limits and dilution factors used by the licensee should be
reviewed relative to site specific data in the TS and SAR.

Some facilities may use online monitoring instrumentation. If online
instrumentation is used, the observation of online monitoring during
selected portions of two operational periods is an acceptable sample for
this inspection requirement. Alarm setpoints and surveillance
requirements for online monitoring instrumentation may be found in the
TS. If the online instrumentation is inoperable, the TS may allow
acceptable alternatives such as grab sampling, calculational estimates,
or some combination of both as the acceptable monitoring methods.

TS required monitoring instruments are required to be operable,
calibrated, and maintained. The calibration frequency for this
instrumentation is normally specified in the licensee\'s procedures. A
schedule for maintenance, consistent with the manufacturer\'s
recommendations, is usually established by licensee administrative
controls, or the licensee may simply refer to the manufacturer\'s
recommendations to schedule these tasks. Argon‑41 is normally the most
common radionuclide identified in gaseous releases. ANSI/ANS‑15.11,
\"Radiological Controls at Research Reactors,\" 1993, provides general
guidance for acceptable methods for the calibration of effluent
monitors.

Liquid releases are generally reactor dependent. Does the licensee have
the capability to identify all radionuclides released from the facility?
If not, what provisions are available? The normal method for detecting,
identifying, and quantifying gamma emitting radionuclides is gamma
spectrometry. Liquid scintillation counting is normally used to detect
and identify beta emitting isotopes such as tritium, Sr‑89, Sr‑90 and
Fe‑59. Is instrumentation used for isotopic analyses operable,
calibrated and maintained?

Licensees usually monitor and dispose of normal effluents effectively.
However, many licensees conduct experiments that produce radioactive
gases or liquid waste directly. Cleaning highly contaminated
experimental equipment can also release radioactive gases and liquid
waste. Does the licensee have precautions or procedures to monitor and
control such discharges, consistent with the respective hazards
associated with them?

The design objectives of the effluent systems are to be examined to
assure that the licensee is not using the systems in a manner for which
they were not intended. Circumstances may arise during operation that
were not considered in the design of the system. For example, the
licensee may be venting fission fragments from an experiment through an
Argon‑41 discharge system or discharging a variety of activation
products to the atmosphere from irradiated experiments, when only
Argon‑41 was considered in the design of the system.

Licensees may keep primary coolant and other liquid waste in a holdup
tank to allow radioactive liquids to decay to near background levels.
The licensee\'s methods for sampling before discharge are to be
examined. Radioactive particulates may settle to the bottom of the tank.
If the effluent is sampled from the surface, the water may appear clean.
The activity in the sample must be representative of what is actually in
the system. Particular attention is to be given to undetected release
paths from experiments for tritium and from coolant storage for heavy
water reactors.

03.03 [Environmental Monitoring]{.underline}. The frequency of air,
water, soil and vegetation sampling is normally specified in the TS,
SAR, SER or other applicable regulatory documents. It should be noted
that some licensees will also use Thermoluminescent Dosimeters (TLDs)
placed at specific locations, as environmental monitors. Environmental
monitoring records, since the last inspection, are to be reviewed for
omissions; obvious mistakes; anomalous measurements; observed biases and
trends in the data. If required by the licensee\'s environmental
monitoring program, the licensee is to be observed taking and analyzing
a soil sample downwind from a gaseous discharge point if practical. If
required by the licensee\'s environmental monitoring program, the
licensee is also to be observed taking and analyzing a water sample
downstream from a liquid effluent discharge point, if practical. This
need not be done if the licensee discharges liquid effluents to the
sanitary sewer system. Are the results of the analyses comparable with
the latest results recorded by the licensee?

03.04 [As Low As Reasonably Achievable (ALARA)
Considerations]{.underline}. Requirements to minimize the release of
radioactive material to the environment can be found in 10 CFR
20.1101(b), 20.1301, 20.1302 and 10 CFR Part 20, Subpart K. ALARA
considerations are to be discussed with operations or radiation
protection personnel, as appropriate, to determine what measures and
considerations have been taken to maintain effluent releases consistent
with the facility ALARA program. This may include discussion of the
considerations given to activities that resulted in the largest
radiological effluent contribution from the reactor facility. If the TS
or licensee procedural controls do not include requirements for ALARA,
professional judgement is required to determine whether the licensee is
maintaining effluent releases ALARA.

03.05 [Waste Storage]{.underline}. If practical, one gaseous, liquid and
solid waste storage installation is to be examined to determine whether
they meet the requirements of the TS, and 10 CFR Part 20. Are gaseous,
liquid and solid wastes appropriately stored in engineered storage tanks
or areas? It is to be recognized that some licensees do not store or
hold up gaseous releases but rely on online monitoring capabilities. A
description of the storage facility and location can be found in the
SAR. If the facility has liquid holdup tanks, tritium storage
facilities, and solid waste drums that provide radwaste storage
capability, storage is required to be consistent with 10 CFR Part 20,
the TS and the licensee\'s procedural requirements. Does the licensee
maintain a current inventory of all radioactive waste stored onsite? Be
alert for unmonitored release pathways, and changes in the facility that
could create unmonitored release pathways.

03.06 [Cold Water Chemistry]{.underline}. Observation of one required
chemical analysis is an acceptable sample for this inspection
requirement. Does the licensee maintain and implement policies and
procedures, as required, for the control of plant process water to
minimize corrosion and out of core radiation fields? These policies and
procedures identify the chemical variables to be monitored such as
chemical composition, pH, conductivity; the monitoring locations;
schedules for sampling; provisions for taking representative samples and
the diagnostic actions to be taken when critical limits are reached or
exceeded. One of the contributing factors of metal attack is the
formation of locally corrosive environments resulting from the ingress
of impurities during plant operation and shutdown. Are chemicals and
reagents used in the chemical analyses fresh (within the recommended
shelf life)? Are records of required non‑radioactive chemical analyses
consistent with the TS, licensee procedures and the description in the
SAR?

03.07 [Constraint on Radioactive Air Effluents]{.underline}. Licensee
records are to be reviewed to determine the magnitude of the annual air
effluent releases from the licensee\'s facility and whether they meet 10
CFR 20.1101(d). This regulation applies a constraint of 10 millirem in a
year to the exposure resulting from air effluents. The difference
between this constraint and the limits in 10 CFR 20.1301 is that
exceeding a constraint level does not necessarily result in enforcement
action, whereas exceeding a limit always results in enforcement action.
Acceptable methods to estimate the dose from air emission, and thereby
show compliance, are described in Regulatory Guide 4.20, \"Constraint on
Releases of Airborne Radioactive Materials to the Environment for
Licensees Other than Power Reactors.\" Licensees may also use their own
site-specific methods for showing compliance, subject to NRC approval
before use (e.g., SAR methods for effluent dose calculations). In cases
where the constraint is exceeded, the licensee is required to notify NRC
that the constraint was exceeded, describe the corrective actions to be
taken, and the schedule for completion of such actions to ensure the
constraint will not again be exceeded. Enforcement action may be taken
if such reports are not filed as required by 10 CFR 20.2203 or if
corrective action does not prevent recurrence.

69004-04 RESOURCE ESTIMATE

For Planning purposes, the estimated direct onsite inspection effort to
complete this procedure is 10 hours. Actual inspection at any facility
may require more or less effort depending on past inspection history,
conditions at the facility, and safety significance of the inspection
findings.

END