Aquesous Waste disposal under 10CFR 20.2003

["Patrick D. Beyer" <pbeyer@post.its.mcw.edu>]

I would like some help settling a difference in interpretation in Part
20.2003. We have a broad scope license and currently are allowing each
investigator to pour their aqueous radioactive waste (within specific
activity limits) directly into a designated "Hot Sink". We then collect
the disposal logs annually and calculate the sewer disposal.  With the New
part 20 this must change so our dilema is how often must we calculate our
sewer effluent release. Are we limited to calculating the effluent
concentrations each month as stated in a.2 or can we average the
concentrations over a period of several months and have an Average
concentration for each month (from a.3.i). What is confusing is the
following statement... 

3.i  The licensee shall determine the fraction of the limit in table 3 of 
appendix B to 20.1001-20.2401 represented by discharges into the sanitary 
sewerage by dividing the actual monthly average concentration of each 
nuclide released by the licensee into the sewer by the concentration of 
that nuclide listed in table 3.....

The confusing part is "the ACTUAL monthly AVERAGE".... How can an average 
be actual? My guess is that the word actual refers to the activity 
released and average refers to the monthly average volume of water 
used to calculate the release.  

The two viewpoints that are being suggested here are,

1) 2003.a.2 states "in one month" so the actual activities released must 
be used for each month, therefore the disposal activities must be 
collected each month and totaled. Because of the number of users we have 
100+, I feel we need to collect all aqueous waste (minus glassware washing 
residue) and release it in a controlled manner.

2) 2003.a.3.i states "the actual monthly average" so we could collect the
activities released by each investigator quarterly and take an average. I
disagree with this in that its only an average due to allowance of an
average water volume used to calculate the concentrations released



So basically i need help in choosing the best interpretation so i can 
sell it to my boss. Any and all responses are appreciated.