**4. Reporting and compliance**

In many areas, it is mandatory to provide complete and periodic reports to regulatory agencies or customers on the release of airborne radioactive material. The comprehensive report should allow for the discussion of error analysis and provide quantifiable impacts to the public and the environment. Exceeding a regulatory limit, compliance level, or permit condition requires an event notification to the appropriate regulatory agency. Compliance is a cooperative effort between the facility and the local community and regulatory agencies and requires a fully implemented quality assurance (QA) program.

### **4.1 Annual reporting**

An annual report on the emissions of radioactive material has several aspects to consider, and it may be required to include specific information based on applicable regulations or permits and be certified by a responsible individual. Results of reported emissions can then be converted to an off-site dose. Basic elements are identified below:


A facility description will include historical background on the reporting site, detail the activities conducted resulting in releases of radioactive materials, and offer information on

Concepts for Environmental Radioactive Air Sampling and Monitoring 277

of work, additional sampling and monitoring, and estimated impacts to the public and

Regulators may request additional information or formal report and may also assign additional actions. Resuming normal work would be coordinated with the regulators. Depending of the severity of the event, additional actions such as a compliance plan submittal, inspections and assessments, more frequent and additional reporting, and assessment of fines and penalties may be initiated. Work with the regulators and management to identify the appropriate actions and cooperatively agree to the resumption

Assessment and conformance to the regulations and permit authorization requirements enable the facility to demonstrate compliance. An organization should evaluate its activities and document its baseline compliance. Additionally, compliance requires the

There are two applicable standards for continual improvement and quality: *Environmental Management Systems* (ISO, 2004), and *Quality Management Systems* (ISO, 2008). *Sampling and Monitoring Releases of Airborne Radioactive Substances From the Stacks and Ducts of Nuclear Facilities* (ANSI, 2011) also outlines a basic QA program plan, the standard components of

implementation of a robust QA program capable of passing an external audit.

Shown in Fig. 8, these QA components form a complete, interdependent program.

the program must be available for analyses, audits, and archival purposes.

The QA program describes administrative and organization roles. The program details data handling and procedures that govern data collection and analysis. It also incorporates the organizations proactive and cooperative relations with the regulators and

Record keeping is integral to the QA program. A management system for the records is necessary and would include the basis for the collection, identification, storage and retention, and retrieval of the documents related to the program. Documentation related to

Characterization of system and equipment components as part of a QA program includes the description of the source term under consideration, the characteristics of the system and equipment, and the design and construction features of the program elements. For example, Fig. 6 could be a QA program drawing showing the basic equipment components of a field-

Individuals involved in the program must be trained to conduct the specific role they have in the program. Training may cover many areas including assessment, data collection or analysis, and reporting. The training records would be managed under the documentation

environment.

of normal work.

which include: 1. Program Aspects 2. Documentation

4. Training

6. Calibration

8. Assessment

key stakeholders.

**4.3 Compliance aspects** 

3. System and Equipment Characterization

5. Maintenance and Inspection Requirements

7. System Performance Criteria

deployed air sampling station.

requirements of the QA program.

the buildings where operations are conducted. This section provides information on related nearby facilities and their impacts on the results.

The emission point description is used to brief the type of emission unit and the associated characteristics. For example, an emission unit may be a point source that releases radioactive gases (and potentially particulate materials), while a fugitive emission source may be a contaminated waste pile. Careful itemization and clear description of the emission type are essential elements to reveal the impact to overall operations.

Emissions reporting may be in the form of specific sample analyses or theoretical calculations. Specific analyses can be from point sources collected from a sampling system, or they can equally be from environmental surveillance monitoring stations; a combination of both may be necessary to cover all the types of emissions at a particular site. If environmental surveillance monitoring data is not collected, then theoretical calculations can also be used to supplement the reporting of (potentially) released radioactive materials into the environment. The emissions report is a primary factor in the dose assessment.

Input parameters to the dose assessment include the reported emissions. However, other inputs can include meteorological data for joint frequency wind speed distributions, dose conversion models, and exposure pathway parameters (e.g., inhalation, and food stuffs). Dose models such as CAP88-PC also require information on the clearance type, particle size, a scavenging coefficient, and deposition velocity used (EPA, 2007; Simpkins, 2000).

Non-routine releases from upset conditions such as spills or accidents should be reported separately and may be a permit requirement. Stack sampling or environmental surveillance monitoring stations can sample and detect non-routine releases, which would be included in the dose estimates to the public and/or environment.

Supplemental information to an annual report can include collective (population) dose estimates, results from environmental surveillance measurements, and status of methods confirming emissions. The collective dose differs from the dose to the maximally exposed individual, where the latter receives the maximum dose from the reported emissions and the former is the product of the number of persons in a general area (e.g., within 80 km of the facility) and the average dose per person (ENS, 2003). Results of environmental surveillance sampling and other sampling events can be reported in an appendix or as part of the overall results. Finally, the methods of confirming emissions should be discussed in relation to the emission unit; in such cases, a table indicates whether the emissions were measured by a sample or calculation. If sampling was conducted, it should further be noted whether it was continuous or periodic.

#### **4.2 Event reporting**

When compliance with permit conditions, emission or concentration limits, or other requirements are not met, the facility must report the information to the appropriate authority. Additionally, non-routine releases or transient abnormal conditions are reported separately and may also be a required by regulation. Often, the stack sampling or environmental surveillance monitoring stations can sample and detect these events, with the results used for dose estimates to the public and/or environment. Specific event reporting may be governed by internal procedures, licenses, and relevant regulations.

It is a good practice to report events to the appropriate regulatory agency within 24 hrs of discovery. It should cite the specific requirement(s) that is out of compliance and the current status of the situation. Immediate actions taken are reported and may include the shutdown of work, additional sampling and monitoring, and estimated impacts to the public and environment.

Regulators may request additional information or formal report and may also assign additional actions. Resuming normal work would be coordinated with the regulators. Depending of the severity of the event, additional actions such as a compliance plan submittal, inspections and assessments, more frequent and additional reporting, and assessment of fines and penalties may be initiated. Work with the regulators and management to identify the appropriate actions and cooperatively agree to the resumption of normal work.

### **4.3 Compliance aspects**

276 Environmental Monitoring

the buildings where operations are conducted. This section provides information on related

The emission point description is used to brief the type of emission unit and the associated characteristics. For example, an emission unit may be a point source that releases radioactive gases (and potentially particulate materials), while a fugitive emission source may be a contaminated waste pile. Careful itemization and clear description of the emission type are

Emissions reporting may be in the form of specific sample analyses or theoretical calculations. Specific analyses can be from point sources collected from a sampling system, or they can equally be from environmental surveillance monitoring stations; a combination of both may be necessary to cover all the types of emissions at a particular site. If environmental surveillance monitoring data is not collected, then theoretical calculations can also be used to supplement the reporting of (potentially) released radioactive materials into the environment. The emissions report is a primary factor in the

Input parameters to the dose assessment include the reported emissions. However, other inputs can include meteorological data for joint frequency wind speed distributions, dose conversion models, and exposure pathway parameters (e.g., inhalation, and food stuffs). Dose models such as CAP88-PC also require information on the clearance type, particle size,

Non-routine releases from upset conditions such as spills or accidents should be reported separately and may be a permit requirement. Stack sampling or environmental surveillance monitoring stations can sample and detect non-routine releases, which would be included in

Supplemental information to an annual report can include collective (population) dose estimates, results from environmental surveillance measurements, and status of methods confirming emissions. The collective dose differs from the dose to the maximally exposed individual, where the latter receives the maximum dose from the reported emissions and the former is the product of the number of persons in a general area (e.g., within 80 km of the facility) and the average dose per person (ENS, 2003). Results of environmental surveillance sampling and other sampling events can be reported in an appendix or as part of the overall results. Finally, the methods of confirming emissions should be discussed in relation to the emission unit; in such cases, a table indicates whether the emissions were measured by a sample or calculation. If sampling was conducted, it should further be noted

When compliance with permit conditions, emission or concentration limits, or other requirements are not met, the facility must report the information to the appropriate authority. Additionally, non-routine releases or transient abnormal conditions are reported separately and may also be a required by regulation. Often, the stack sampling or environmental surveillance monitoring stations can sample and detect these events, with the results used for dose estimates to the public and/or environment. Specific event reporting

It is a good practice to report events to the appropriate regulatory agency within 24 hrs of discovery. It should cite the specific requirement(s) that is out of compliance and the current status of the situation. Immediate actions taken are reported and may include the shutdown

may be governed by internal procedures, licenses, and relevant regulations.

a scavenging coefficient, and deposition velocity used (EPA, 2007; Simpkins, 2000).

nearby facilities and their impacts on the results.

dose assessment.

essential elements to reveal the impact to overall operations.

the dose estimates to the public and/or environment.

whether it was continuous or periodic.

**4.2 Event reporting** 

Assessment and conformance to the regulations and permit authorization requirements enable the facility to demonstrate compliance. An organization should evaluate its activities and document its baseline compliance. Additionally, compliance requires the implementation of a robust QA program capable of passing an external audit.

There are two applicable standards for continual improvement and quality: *Environmental Management Systems* (ISO, 2004), and *Quality Management Systems* (ISO, 2008). *Sampling and Monitoring Releases of Airborne Radioactive Substances From the Stacks and Ducts of Nuclear Facilities* (ANSI, 2011) also outlines a basic QA program plan, the standard components of which include:


Shown in Fig. 8, these QA components form a complete, interdependent program.

The QA program describes administrative and organization roles. The program details data handling and procedures that govern data collection and analysis. It also incorporates the organizations proactive and cooperative relations with the regulators and key stakeholders.

Record keeping is integral to the QA program. A management system for the records is necessary and would include the basis for the collection, identification, storage and retention, and retrieval of the documents related to the program. Documentation related to the program must be available for analyses, audits, and archival purposes.

Characterization of system and equipment components as part of a QA program includes the description of the source term under consideration, the characteristics of the system and equipment, and the design and construction features of the program elements. For example, Fig. 6 could be a QA program drawing showing the basic equipment components of a fielddeployed air sampling station.

Individuals involved in the program must be trained to conduct the specific role they have in the program. Training may cover many areas including assessment, data collection or analysis, and reporting. The training records would be managed under the documentation requirements of the QA program.

Concepts for Environmental Radioactive Air Sampling and Monitoring 279

Finally, as a part of the overall QA program, the compliance status should be documented in periodic reports and provided to management and/or appropriate regulatory agencies. These reports should include the status of compliance to the specific permit requirements and regulations. When non-compliance is identified, it must be addressed, and corrective actions should be tracked to completion. Notification to regulatory agencies must also be

In addition to the periodic use of internal and external assessments, the researcher should prepare to embrace opportunities to improve the sampling and monitoring base of knowledge. The assessment process provides for the necessary feedback to make incremental changes in a program to improve the overall result. The reporting of new or unique operations, special studies, or a resolution to a monitoring question provides information valuable to other

Below are two examples of current, evaluative research areas: air sample volume measurements, and the deposition of material on a sample filter paper. However, there are

Determination of the sample volume is critical in collecting ambient air samples for environmental monitoring. Errors in the sample volume measurement are directly proportional to errors in the calculated sample concentration (Fritz, 2009). A variety of instruments are available to measure flow and can include rotameters, electronic mass flow controllers, and venturi meters (Wight, 1994). Fritz (2009) reported on the implementation of a dry-gas meter application to air sample volume measurements in lieu of a more cumbersome and less accurate two-point manual airflow measurement and sample duration. The new method showed improved reliability and measurement resolution, reduced error, and more accurate concentration calculations. The evaluation was conducted over two phases that included a system set-up identical to the field configuration and a testing phase where the new dry-gas meters were installed in the actual sampling network. With reported results, users can apply the basics of their work into their own evaluations applicable to their particular situation. Consider for example that the air sample volume measurement evaluation is being evaluated for an area without adequate electricity or based on filter flow characteristics. In the first case where electricity is necessary to run a sample pump, solar arrays may be an alternative. One could reasonably create a limited project for the facility to determine the appropriateness of such a system and recommend whether to utilize it in a broader program. For this second case, evaluating sample filters for pressure drop (Barnett & Kane, 1993) may be studied to determine if alternative filter sizes are adequate to meet the air sample volume requirements; however, other considerations may impact the final decision such as the ability to reliably analyze the filter, the overall spectral properties of the radioisotope(s), and the ability to ash the filter easily for additional

Researchers have probed into the major factors affecting the measurements of radioactivity on air samples collected on filters (Stevens & Toureau, 1963; Higby, 1984). These factors

many areas for improvement, and individuals can make their own contributions.

evaluated and may be required.

programs.

laboratory analyses.

**5.2 Sample filter deposition evaluation** 

**5. Case studies for continual improvement** 

**5.1 Air sample volume measurement evaluation** 

Fig. 8. Basic components of a QA program

Periodic maintenance and inspection requirements may often be prescribed by regulations. However, the QA program should address the frequency by which maintenance and inspections are conducted. These requirements can easily be adapted into a preventive maintenance program.

In addition to periodic maintenance and inspection, measurement and test equipment are to be calibrated periodically. The specific calibration methods utilize prescribed methods and traceable reference standards. Generally, calibrated equipment is labeled with the calibration and expiration dates.

System performance criteria assures overall satisfactory program operation. Performance criteria can cover the operational requirements, transmission factors, and flow ranges, which are used to identify normal system operations. Tracking and trending of data can supplement and monitor the criteria by enabling the user to see outlier data and observe trends in data over time. The tracking and trending of data can also indicate potential changes to program emissions or in equipment operations.

Self-assessment programs are intended to provide a mechanism for continual improvement in programmatic elements (e.g., procedures, management systems) and operational elements (e.g., monitoring systems, permit compliance) of a program. Periodic review of program elements begins with the planning of an assessment. Once the assessment scope and intent are established, criteria can be evaluated, and strengths and weaknesses identified. Corrective actions can then be assigned and implemented to improve areas of weakness or non-compliance. Once actions are complete, an effectiveness review should be conducted to verify adequate corrective action implementation.

Finally, as a part of the overall QA program, the compliance status should be documented in periodic reports and provided to management and/or appropriate regulatory agencies. These reports should include the status of compliance to the specific permit requirements and regulations. When non-compliance is identified, it must be addressed, and corrective actions should be tracked to completion. Notification to regulatory agencies must also be evaluated and may be required.
