Re: Aquesous Waste disposal under 10CFR 20.2003

[Ninni Jacob <njacob@gsosun1.gso.uri.edu>]

We have a similar problem. We have a holding tank that we release every
three months or so.
 We thought we could average the volume over three months, but according to an
NRC inspector who visited us recently, we cannot do that.  We have to average
it over a month, meaning that we cannot take credit for the volume of water
released into the sewer in three months.  We can only use the total
volume of water released into the sewer in one month to calculate the monthly
average.