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Thomas Jefferson National Accelerator Facility

EP SupplementEPS-11 Environmental Monitoring

EPS-11

Environmental Monitoring

Introduction

Environmental monitoring is one of the primary methods used by the Lab to assess environmental conditions and ensure an effective environmental protection program.

The environmental monitoring program examines actual and potential chemical, oil, and radioactive effluents from the facility. An integral part of the Jefferson Lab Environmental Monitoring Program is routine sampling of environmental media (air, industrial wastewater, and groundwater) to ensure that Jefferson Lab effluents are not having a negative impact on the surrounding environment and that effluent parameters are within the acceptable range.

This chapter and its appendices are intended for all staff involved with the environmental monitoring program at Jefferson Lab.

Related Chapters 6315 Environmental Monitoring of Ionizing Radiation 6730 Water Quality Management 6731 Groundwater Protection

Environmental Management System (EMS) aspects addressed in this chapter include:• Ionizing Radiation

- air activation- soil activation- groundwater activation

• Wastewater Discharge- sanitary sewer, industrial- surface - activated water- surface - storm water

AppendicesEPS 11-T1 Environmental Monitoring ProgramEPS 11-T2 Environmental Monitoring QA GuidanceEPS 11-R1 Environmental Monitoring ProceduresEPS 11-R2 Selection Criteria for Subcontracted Environmental Monitoring

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Key Terms

Chapter 6710 Environmental Protection Program contains descriptions of relevant laws, regulations, standards, terms, and agencies that are fundamental to the environmental protection (EP) program. Many of these laws and standards apply to environmental monitoring and are referenced herein. The following environmental monitoring-specific terms and acronyms are used in this chapter.

audit Planned and documented activity performed in accordance with procedures to determine, by examination and evaluation of objective evidence, the adequacy of and extent to which applicable elements of the program have been developed, documented, and effectively implemented in accordance with specified requirements.

certification A document assuring that an individual has received the necessary

training to carry out a particular task.

chain of custody A set of procedures used to provide an accurate written record that traces the possession of a sample from the moment of its collection, through its analysis, and introduction into a data set.

Data Quality Objective (DQO) Determine the degree of total variability (uncertainty or error) that can be tolerated in the data. DQOs differ from measurement quality objectives (such as precision and accuracy) in that they are limits for the overall uncertainty of results, while the latter are only limits for the uncertainty of specific measurements.

effluent Any treated or untreated air emission or liquid discharge, including stormwater runoff, at a site or facility.

environmental baseline The approved delineation of chemical, biological, physical, and radiological characteristics of the preoperational Jefferson Lab environment that represents the starting level from which to evaluate the effect of Jefferson Lab operations on the environment.

effluent monitoring (A subset of environmental surveillance, described below.) The collection and analysis of samples or measurements of liquid, gaseous, or airborne effluents for the purposes of characterizing and quantifying contaminants and process stream characteristics, assessing radiation exposures to members of the public, and demonstrating that applicable standards are met.

environmental medium A discrete portion of the total environment, animate or inanimate, that may be sampled or measured directly.

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environmental surveillance The all-encompassing act of monitoring the environment, measuring, collecting and analyzing samples of air, water, soil, foodstuffs, biota, and other media from DOE sites and their environs. Its purpose is to show that applicable standards are met, to assess radiation exposures to members of the public, and to assess effects, if any, on the environment.

Quality Assurance (QA) Planned and systematic actions necessary to provide adequate confidence that a facility, structure, system, or component will function satisfactorily and safely while in service. Quality assurance includes quality control.

Quality Control (QC) Refers to those actions necessary to control and verify the features and characteristics of a material, process, product, service, or activity to specified requirements. The aim of quality control is to provide quality that is satisfactory, adequate, dependable, and economical.

Radiation Control (RadCon) Group The Jefferson Lab organization responsible for carrying out the radiological and related non-radiological portions of the Environmental Monitoring program.

Refer to Table 1 in Chapter 2420 Permits and Authorizations from External Agencies for more information on the permits discussed within.

Acronyms

DEQ Virginia Department of Environmental Quality

HRSD Hampton Roads Sanitation District

LAFB Langley Air Force Base

NPDES National Pollutant Discharge Elimination System

SER Site Environmental Report

VPDES Virginia Pollutant Discharge Elimination System (Permit)




Responsibilities

Chapter 6710 Environmental Protection Program summarizes staff EP responsibilities. The following detailed guidance will assist staff in fulfilling the Lab’s environmental monitoring goals and objectives.

Qualified Staff/Subcontractors involved in monitoring programs❖ Perform sampling and analysis work using documented procedures and practices.❖ Maintain control of samples that require chain of custody until the appropriate person

has accepted responsibility for the samples and has signed the custody log.❖ Note any unusual or reportable monitoring results and inform the SOTR or line

manager who will notify ESH&Q Reporting (ext. 7308) of non-radiological concerns and RadCon of radiological concerns (ext. 7551).

Supervisor/SOTR/Responsible Line Manager❖ Coordinate any required environmental sampling, analysis, and quality assurance

activities.❖ Using ESH&Q staff resources, determine the need for environmental monitoring with

any new project or activity.❖ Develop data quality objectives for a new environmental monitoring project.❖ Assure contracts require subcontractors to comply with environmental monitoring

procedures and protocols required by regulatory agencies and internal procedures.❖ Develop Statement of Work for subcontract bidding process (see Chapter 3420 EH&S

Aspects of Procured Services & Construction).❖ Review material sent from offering laboratories prior to selection of subcontractor.❖ Work with procurement to determine which offering laboratories have appropriate

credentials (include in the Request for Proposal (RFP).❖ Audit subcontracted laboratories, as necessary, to ensure that they are conducting work

as required in the contract.❖ Advise on sampling and analysis procedures and suggest procedural changes when

necessary.❖ Report incidents involving spills or improper releases to the Facility Manager or

designee at 876-1750 (24 hours).❖ Coordinate the preparation of sampling and analysis procedures.

Division ESH&Q staff❖ Provide resources for environmental monitoring and sampling to support line

management.

Facilities Management Director❖ Coordinate all non-radiological sampling activities under the terms of our HRSD

Permit and general permits.




❖ Coordinate all sampling activities under the terms of our VPDES Cooling Water Discharge general permits.

❖ Coordinate all sampling activities under the terms of our VPDES Surface Water System permit.

❖ Coordinate monitoring for non-radioactive air emissions upon request.❖ Collect sufficient data to enable preparation of required reports.

Radiation Control (RadCon) Group❖ Manage all activities involving accelerator and experiment-related monitoring

for both normal operations and in the event of a radiological spill or release.❖ Under the surveillance program, characterize the on-site radiological and

non-radiological conditions. Keep ESH&Q Reporting informed about conditions and changes.

❖ Under the surveillance program, estimate public doses from both ionizing radiation and from air emissions due to Jefferson Lab activities. Keep ESH&Q Reporting informed about conditions and changes.

❖ Manage site-wide environmental monitoring to meet reporting requirements and to track environmental issues.

❖ Collect sufficient data to enable the preparation of required reports.❖ Manage division input for various reports that are submitted to governmental

agencies including DOE.❖ Determine the types and quantities of radioactive or potentially radioactive

effluents from new or modified equipment, systems, or operations and establish an associated environmental surveillance program as appropriate.

RadCon Group Manager❖ Manage all radiological and non-radiological sampling under the VPDES water

quality permit.❖ Manage all radiological sampling:

• under the HRSD permit.• involving air.• of surface water in the vicinity of the accelerator and experimental areas.

ESH&Q Reporting Manager❖ Maintain permit-related information and submit to the appropriate authority as

required.❖ Review the environmental monitoring program annually and update every three

years, or as needed.❖ Ensure that any significant concern regarding sample data or the integrity of the

analysis process is brought to the attention of the DOE and other appropriate regulatory agencies.

❖ Report monitoring results that exceed site wide maximum allowable limits.❖ Review and request release permits as needed.❖ Determine if reports from specific monitoring programs should be kept longer

than three years. Notify responsible line manager.

Refer to Chapter 6315 Environmental Monitoring of Ionizing Radiation for specific duties involving the radiological monitoring




Qualifications

All on-site environmental monitoring and sampling are performed by qualified Jefferson Lab or subcontractor staff. Environmental monitoring training requirements are established by the responsible line organization. Federal, state, and/or local training certification requirements for conducting routine environmental monitoring and surveillance shall be met. As well, standard sampling protocols will be followed by all monitoring personnel. Sampling protocols can be found in Appendix EPS 11-R1 Environmental Monitoring Procedures.

Subcontracting laboratorySelecting a laboratoryAs subcontracted laboratories are generally used to perform analysis of collected samples, specific

qualifications must be verified. Line managers shall determine where samples will be analyzed. Subcontractor selection will be dependent on whether the analysis can be done satisfactorily at the prospective laboratory. Contact appropriate ESH&Q staff to ask about known laboratory capabilities.

If it is determined that the subject analyses will be conducted by an outside laboratory, line management should consider the applicable factors presented below.

❖ Does the laboratory perform all required analysis in house? How experienced is the laboratory in conducting the requested analysis? Do they perform the analysis frequently enough to be competent?

❖ If subcontractor laboratories are used, are they, at a minimum, state certified to conduct the requested analysis? (Other certifications, such as from EPA and DOECAP, may be necessary depending on the analysis being requested.)

❖ Does the subcontractor laboratory have a current client list? (Clients can give insight to the capabilities of the laboratory.)

❖ Can the subcontractor laboratory meet required turnaround times?❖ Will the subcontractor laboratory provide a copy of its written Quality

Assurance/Quality Control program?❖ Can the laboratory meet required method detection limits and is this documented?❖ Does the laboratory use state-of-the-art methods and equipment?❖ Does the standard laboratory reporting format meet required needs, or will they

customize the report?❖ Can the subcontractor laboratory satisfy all necessary procedures/protocols of

regulatory agencies with jurisdiction?

Subcontractors performing environmental monitoring and surveillance activities at Jefferson Lab will be certified under applicable DOE, EPA, or other standards. Subcontractors are responsible for certifying that their personnel have the appropriate training necessary to accomplish the monitoring task (by providing copies of training records, certificates, etc.). Subcontractor training records will be reviewed and kept on file by the responsible line manager/SOTR.




Qualified Jefferson Lab staffQualified environmental monitoring staff are individuals who have been instructed

by a designated Jefferson Lab trainer or supervisor or have received training from a qualified outside source and have appropriate experience. Qualified Jefferson Lab staff shall be trained as necessary in applicable monitoring requirements, including:

• Regulatory requirements• Environmental monitoring and surveillance procedures• Information on how to establish data quality objectives• Identification of field and laboratory controls• Sampling protocols• Chain-of-custody procedures• Background information on the auditing process• Instructions on preparing for an audit• How to verify independent data

ESH&Q Reporting works with division ESH&Q Officers to periodically review environmental programs and ensure required training is complete and current.

Note: Appendix 2210-R1 Current EH&S Staff Assignments contains a current list of ESH&Q staff




Program Overview

The primary purposes of the Jefferson Lab Environmental Monitoring Program are to: • establish a strategy for environmental monitoring and surveillance in

accordance with the legal and regulatory requirements of federal, state, and local agencies and contractual requirements;

• identify potential environmental problems;• provide data to support environmental management decisions; and,• evaluate the need for remedial actions or mitigative measures.

The program establishes guidelines for examining all actual and potential chemical, oil, and radioactive effluents from the facility. An integral part of the program is routine sampling and tracking of environmental media (groundwater, surface water, industrial wastewater, and air). These media are measured and monitored to ensure that Lab effluents do not have a negative impact on the surrounding environment and that effluent parameters remain within the applicable acceptable range.

This program documents a comprehensive site-wide monitoring plan that assesses the effect of past, current, and future Jefferson Lab activities by measuring and monitoring effluents from facility activities and accelerator (including CEBAF, the FEL, and any other accelerators) operations and by surveillance through measuring, monitoring, and calculating the effects of those activities and operations on the environment and public health.

The environmental monitoring program conducted at the laboratory is presented in Appendix EPS 11-T1 Environmental Monitoring Program.


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