8011 Environmental Monitoring Program
The primary objectives of Jefferson Lab’s Environmental Monitoring Program are to:
· Develop remedial actions as required and monitor results.
Program elements incorporate requirements of Department of Energy (DOE) Orders 450.1A, Environmental Protection Program and458.1, Radiation Protection of the Public and the Environment.
The program establishes requirements for examining all actual and potential chemical, oil, and radioactive releases from or contamination at the facility. An integral part of the program is routine sampling, analysis, and tracking of environmental media including groundwater, surface water, industrial wastewater, soil, and air. These media are measured and monitored to ensure that releases from the laboratory remain within an acceptable range resulting in no negative impact on the surrounding environment (which includes all living things).
This program is included in the laboratory’s Environmental Management System (EMS) as these environmental aspects require monitoring:
Specific environmental monitoring program requirements are presented in Appendix EPS 11-T1 Environmental Monitoring Program.
Environmental monitoring focuses on the examination of the laboratory’s air, water, and soil to assess against preoperational conditions whether certain chemicals, oils, and radionuclides are present and to what extent. Environmental monitoring also examines responses to releases from site operations and activities.
The laboratory’s monitoring program includes characterization of all environmental media and potential exposure pathways::
· Ambient air at the site boundary
· Groundwater activation
· Surface water discharges
· Discharges to the sanitary sewer
· Soils that could be affected by site operations
· Radioactive materials destined for storage or disposal
A major element of this program is the routine submission of monitoring data required by permits. In addition, to keep stakeholders, such as the DOE, and laboratory staff, informed about its environmental monitoring performance, a comprehensive annual report titled, “The Thomas Jefferson National Accelerator Facility Site Environmental Report for Calendar Year ----” (SER) is prepared and widely distributed.
Jefferson Lab performs a great deal of radiological monitoring, but uses subcontracted analytical laboratories to perform sampling and analysis required by permit in accordance with Environmental Protection Agency (EPA) and Commonwealth of Virginia regulations, and DOE contractual requirements.
3.1 Supervisor/ Responsible Line Manager
· Selects Subcontracting Officer’s Technical Representative (SOTR) to manage permit requirements involving subcontracted sampling and/or analysis.
· Informs Environmental, Safety, Health, and Quality (ESH&Q) of any unusual monitoring results.
· Prepares/receives data, including providing for quality control/quality assurance data review.
· Provides permit data in required format and any supporting information to the ESH&Q Associate Director at agreed advance times to meet permit due dates.
· Consults with ESH&Q to determine if new projects or activities may require a change to the environmental monitoring program.
· Ensures that systems under his/her control that contain hazardous or radioactive material are properly maintained.
3.2 Facilities Management and Logistics
· Coordinates all non-radiological sampling and analysis under the terms of our permit with Hampton Roads Sanitation District (HRSD).
· Coordinates all sampling required for compliance with the terms of the permit that regulates cooling water discharges to surface water.
· Obtains data on air emissions from boilers and generators to meet regulatory or contractual requirements.
· Performs assigned sampling and analysis activities using documented procedures and practices, or procures a qualified subcontractor to accomplish the activity.
· Ensures the consolidation and on-time delivery of data meeting all quality objectives to ESH&Q.
· Maintains permit-related information, such as that related to equipment calibration and inspections.
· Reports unusual situations and monitoring results that approach or exceed site-wide maximum allowable limits and other applicable information involving permit result anomalies to the Facility Manager and other involved parties.
3.3 ESH&Q Division
· Establishes an environmental monitoring program to ensure compliance with permits, regulatory requirements, and other contract commitments.
· Ensures the collection and analysis of samples in accordance with this plan.
· Ensures that the program provides for detection and quantification of unplanned releases to the environment of all materials including those that are radioactive.
· Ensures the consolidation and on-time delivery of data meeting all quality objectives, to DOE and/or regulatory agencies.
· Performs assigned sampling and analysis activities using documented procedures and practices, or procure a qualified subcontractor to accomplish the activity.
· Obtains data on air emissions for National Emission Standards for Hazardous Air Pollutants (NESHAP) reporting.
· Reviews modified/new site activities to determine the need for modifications to the monitoring program or permit conditions.
· Maintains all permit related information, except as noted with Facilities Management & Logistics and Accelerator Division.
· Reports unusual situations and monitoring results that exceed site-wide maximum allowable limits and other applicable information involving permit result anomalies to the Facility Manager and other involved parties.
· Ensures that any significant concern, such as any that could indicate the possibility of adverse impacts, regarding monitoring and surveillance sample data or the integrity of the analysis process is brought to the attention of other senior management, the DOE, and other appropriate agencies.
· Maintains environmental monitoring program data and follow-up reports for results indicating adverse environmental impacts.
· Ensures that all sampling and analytical equipment is calibrated and maintained in accordance with regulatory or manufacturers’ requirements.
3.4 Laboratory Director
· Designates the ESH&Q Associate Director to manage permit compliance and makes available the necessary resources.
· Designates organizations to take responsibility for meeting sampling and analysis requirements in site permits.
4.0 Expectations and Process Steps
Sampling and analysis for environmental monitoring and surveillance for permit compliance is performed in compliance with EPA, Commonwealth of Virginia, and HRSD regulations and DOE contractual commitments. The laboratory’s analytical work in support of environmental monitoring involving radionuclides:
· is implemented using a consistent system for collecting, assessing, and documenting environmental data of known and documented quality;
· represents a validated and consistent approach for sampling and analysis of radionuclide samples to ensure laboratory data meets program-specific needs and requirements. This is accomplished under current programs that strive to be within the framework of a performance-based approach for analytical laboratory work; and
· is representative of an integrated sampling approach to avoid duplicative data collection.
As subcontracted laboratories are often used to perform analyses of samples, specific qualifications must be verified. Line managers shall determine where samples will be analyzed. Subcontractor laboratory selection must take into account the requirements of permits, regulations, and DOE requirements. ESH&Q is familiar with the capabilities of many laboratories and should be consulted for assistance.
4.1 Air Monitoring
Jefferson Lab complies with the requirements of Title 40 CFR Part 61, Subpart H, “National Emission Standards for Emissions of Radionuclides Other Than Radon from DOE Facilities” through use of approved atmospheric dispersion models. This regulation is the radionuclide National Emission Standards for Hazardous Air Pollutants. No radionuclide emission monitoring is required during current operations, as calculated values of emissions are below regulatory thresholds. As well, there are no non-radiological emission sources that require monitoring under National Emission Standards for Hazardous Air Pollutants. Monitoring for any emissions is not expected to be required under current requirements.
No laboratory activities or processes involving air require a permit or other authorization.
4.2 Water Monitoring – Groundwater
The accelerator beam causes radiation that could activate nearby soil and groundwater. Preoperational baseline data were collected between September 1989 and July 1996, the effective date of VPDES Permit No. VA0089320. Quarterly sampling and analysis of groundwater was performed and is now performed under DEQ Permit No. VA0089320. Additional information on groundwater monitoring, including well locations, is available in ES&H Manual Chapter 8030 Appendix T3, Groundwater Protection.
4.3 Water Monitoring – Surface Water
Groundwater is collected at the end stations and is pumped to the surface, and is sampled quarterly for pH and indicator radionuclides under Permit No. VA0089320. The cooling tower discharge from the CHL cooling tower is also sampled quarterly under VA0089320. This discharge is sampled for temperature, ammonia-N, total residual chlorine, hardness, pH, total dissolved copper, total dissolved zinc, and total phosphorus.
Surface water at various locations
around the site is sampled and analyzed by gamma spectroscopy and for
tritium. Surface water samples are taken
at various locations at frequencies that vary from monthly to annually.
4.4 Water Monitoring – Sanitary sewer
The HRSD, under Permit No. 0117, allows discharge of 5 Curies (Ci) of tritium and 1 Ci of all other radionuclides annually to the sanitary sewer, as authorized under Commonwealth of Virginia Department of Health Radiation Protection Regulations, 12VAC5‑481). All radioactivated effluents to the sanitary sewer are monitored for activity. That monitoring is used to document the quantity of radioactivity released and is documented and available on request to HRSD and the DOE.
HRSD also limits the pH of wastewater, and monthly compliance sampling is conducted at two discharge locations [HRSD sampling Manholes D and EF]. Extensive internal monitoring of pH is conducted at cooling towers and at neutralization systems to ensure that discharges remain within permit limits.
4.5 Soil and Sediment Monitoring
Soil and sediment in the vicinity of an accelerator enclosure can become activated or may serve as a sink for radionuclides released to the environment during facility operations. Long-term trends may be assessed by analyzing soil samples collected on the site grounds for radionuclides. Samples are collected periodically from selected sites at Jefferson Lab. The soil samples are analyzed via gamma spectroscopy. The need for samples, sampling location, frequency, and type is determined by periodically reviewing Jefferson Lab operations and the potential for radionuclide production.
Facilities Management & Logistics manages soil affected by construction activities with monitoring performed only in special cases. In the event that construction or demolition activities may involve activated soil, Radiation Control Department (RadCon) will monitor soil to determine its proper disposition. Any activated soil would typically be returned to the location where it was found. If this is not possible, RadCon staff will determine the proper disposal method and manage the disposal.
4.6 Monitoring for Direct Radiation
Prompt or “direct” radiation has a potential impact only within close proximity to a working accelerator on the site. This radiation is produced within the beam enclosure and its production stops when an accelerator is turned off. Almost all direct radiation is absorbed by extensive shielding, which is an integral part of accelerator design. Any possible exposure to this radiation is at a maximum on-site and decreases with distance, and has been shown to be insignificant at the site boundary.
Jefferson Lab has an extensive monitoring network in and around the accelerator. There are approximately 50 active, real-time radiation monitors and a series of associated passive integrating detectors deployed around the accelerator site. Included in this monitoring network are six site boundary monitoring stations equipped with specialized detectors, optimized for measuring radiation at close to background levels These data are analyzed routinely and reported in the SER. The results of the monitoring are used to track and minimize potential exposures to members of the public, and to demonstrate compliance with reporting requirements in DOE O458.1.
State and Sanitation District Permits and Guidance Document:
DEQ 0089320 (on site and off site groundwater)
DCR VAR040079 (municipal separate storm sewer systems)
HRSD 0117 (discharges to sanitary sewer system)
Virginia Department of Environmental Quality Guidance Memo No. 04-2020, Significant Figures for Discharge Monitoring Reports
Laboratory Programs and Plans:
ES&H Manual Chapters:
DOE and Executive Orders:
DOE O 458.1 Radiation Protection of the Public and the Environment
Health Physics Procedures:
HPP-REM-003, Discharges of Radionuclides to the Hampton Roads Sanitation District via the Hall Floor Drain
HPP-REM-004, Environmental Monitoring of Surface Water, Soil, and Sediment
6.0 Revision Summary
Revision 0.1 – 12/10/12 – Updated to reflect compliance with DOE Order 458.1 Radiation Protection of the Public and the Environment.
Revision 0 – 04/23/09 – Original Content.