Information Notice 1988-22, Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations

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Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations
ML031150216
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date: 05/12/1988
From: Rossi C
Office of Nuclear Reactor Regulation
To:
References
IN-88-022, NUDOCS 8805060148
Download: ML031150216 (9)


V4 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555 May 12, 1988 NRC INFORMATION NOTICE NO. 88-?2: DISPOSAL OF SLUDGE FROM ONSITE

SEWAGE TREATMENT FACILITIES AT

NUCLEAR POWER STATIONS

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

This information notice is being provided to alert licensees to two recent

events indicating that not all licensees are fully aware of the potential

for contamination of sewage sludge and the relevant regulatory requirements.

It is expected that recipients will review the information for applicability

to their facilities and consider actions, as appropriate, to avoid similar

problems. However, suggestions contained in this information notice do not

constitute NRC requirements; therefore, no specific action or written response

Is required.

Related Documents:

IE Bulletin 80-10 (Reference 1) requested that licensees review the design

and operation of their facilities to identify systems that are considered non- radioactive (or described as non-radioactive in the facility's Final Safety

Analysis Report (FSAR)) but that could become radioactive through interfaces

with radioactive systems and result in unmonitored, uncontrolled releases In

liquid and gaseous effluents. This bulletin stated that special consideration

was to be given to particular systems, including the sanitary waste system;

however, sludge from the sanitary waste system was not discussed specifically.

IE Information Notice No. 83-05 (Reference 2) called attention to the provi- sions of 10 CFR 20.302, "Method For Obtaining Approval Of Proposed Disposal

Procedures," as a means for obtaining approval for disposal of, among other

things, large volumes of material radioactively contaminated at very low

levels. IE Information Notice No. 86-90 (Reference 3) informed licensees

that, in Agreement States, applications to obtain approvals for such disposals

should be sent to the Agreement State and not to the NRC.

8805060148

IN 88-22 May 12, 198R IE Information Notice No. 85-92 (Reference 4) emphasized the need for careful

surveys of materials that may be contaminated and that are to be disposed of

as "clean" waste; i.e., as waste that does not contain licensed radioactive

material.

Description of Circumstances

During an inspection at the Point Beach Nuclear Power Plant, it was found that

the licensee had made onsite disposals of slightly contaminated sludge removed

from aeration ponds and the aerobic digester in the onsite sanitary sewage

treatment facility. The sludge was spread on licensee-owned land and mixed

into the soil by plowing. Radionuclides identified by the licensee in the

sludge included chromium-51, manganese-54, cobalt-58, cobalt-60, cesium-134, and cesium-137. The total activity for six onsite disposals was 300 micro- curies. Licensee representatives indicated their belief that these disposals

were in compliance with regulatory requirements because (1) they met the re- quirements of 10 CFR 20.303, "Disposal By Release Into Sanitary Sewerage

Systems," for disposal into a sanitary sewerage system and (2) their subsequent

disposition of sludge was consistent with measures that would be taken by any

operator of a sanitary sewerage system. The licensee was informed that these

disposals were contrary to 10 CFR 20.301, "General Requirements (Waste Disposal),"

and that 10 CFR 20.303 does not apply to contaminated sludge removed from onsite

sewage treatment facilities. 10 CFR 20.303 only allows a licensee to discharge

radioactive material Into a sanitary sewerage system under limited conditions.

It does not cover removal and land disposal of contaminated sludge from the

licensee's sanitary sewage treatment facilities. Considering the very low

level of radioactive contamination of the sludge and the licensee's estimate

that these disposals would result in very low annual doses, the licensee ap- plied for, and obtained, approval of future disposals of this type pursuant

to 10 CFR 20.302.

Subsequently, during an inspection at the Surry Nuclear Power Station, it was

found that the licensee had disposed of dried sludge from the onsite sewage

treatment facility at the county sanitary landfill without determining If the

sludge was contaminated with licensed material. Licensed radioactive material

was found in sludge that had not yet been disposed of. The licensee was informed

that failure to determine, before disposal, if the sludge was contaminated was

contrary to 10 CFR 20.201, "Surveys," and that disposal of contaminated sludge

by this means would be contrary to 10 CFR 20.301.

Before receiving the application from Point Beach, the NRC had received only

one application pursuant to 10 CFR 20.302 for disposal of radioactively contam- inated sewage sludge from a sanitary sewage treatment facility at a nuclear

power station. This was a request from the Duke Power Company for disposal of

contaminated sludge at its Oconee Nuclear Station. In this case, the requested

method of disposal was by transfer to a contracted vendor for transport to a

publicly owned treatment works. The NRC found the request acceptable; however, because Oconee is in an Agreement State, South Carolina, it was necessary for

the licensee to obtain approval of the State for this disposal of byproduct

material.

IN 88-22 May 12, 1988 Discussion:

Licensees may wish to consider the following:..

1. Sludge from onsite sewage treatment plants may be contaminated with

licensed radioactive material which has been concentrated-by the

treatment system.

2. The provisions of 10 CFR 20.303 do not apply to the disposal of contami- nated sludge removed from sanitary sewerage systems at nuclear power

stations.

3. 10 CFR 20.201 covers surveys required before disposing of sewage treatment

sludge, to determine if the sludge is contaminated.. Gamma-ray spectrometry

can be performed on representative samples of the sludge under conditions

that provide a lower limit of detection (LLD) appropriate to measurements

of environmental samples. Such measurements make it possible to distinguish

licensed material from other radioactive materials (natural radioactive

materials and world-wide fallout) that may be present in the sludge.

4. 10 CFR 20.301 covers the disposal of sewage sludge from a licensee's sewage

treatment facility when contaminated with licensed radioactive material.

5. Licensees may apply in accordance with the provisions of 10 CFR 20.302 to

dispose of sewage sludge containing very low levels of licensed radio- active material in a manner not otherwise authorized in the regulations.

Applications for approval of such disposal may be made to the NRC or

Agreement State, as appropriate.

No specific action or written response is required by this information notice.

If you have any questions about this matter, please contact the technical

contact listed below or the Regional Administrator of the appropriate regional

office.

hals E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contacts: John D. Buchanan, NRP

(301) A92-1097 W. Wayne Meinke, NRR

(301) 492-3152 Attachment: List of Recently Issued NRC Information Notices

IN 88-?2 May 12, 1988 References

1. IE Bulletin No. 80-10, "Contamination of Nonradioactive System and

ing Potential for Unmonitored, Uncontrolled Release of RadioactivityResult- Environment," May 6, 1980. to

2. IE Information Notice No. 83-05, "Obtaining Approval for Disposing of

Very-Low-Level Radioactive Waste - 10 CFR Section 20.302,"

February 24, 1983.

3. IE Information Notice No. 86-90, "Request to Dispose of Very-Low-Level

Radioactive Waste Pursuant to 10 CFR 20.302," November 3, 1986.

4. IE Information Notice No. 85-92, "Surveys of Waste Before Disposal from

Nuclear Reactor Facilities," December 2, 1985.

Attachment

IN 88-22 May 12, 1988 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

88-21 Inadvertent Criticality 5/9/88 All holders of OLs

Events at Oskarshamn or CPs for nuclear

and at U.S. Nuclear power reactors.

Power Plants

88-20 Unauthorized Individuals 5/5/88 All holders of OLs

Manipulating Controls and or CPs for nuclear

Performing Control Room power, test and

Activities research reactors, and all licensed

operators.

88-19 Questionable Certification 4/26/88 All holders of OLs

of Class 1E Components or CPs for nuclear

power reactors.

88-18 Malfunction of Lockbox on 4/25/88 All NRC licensees

Radiography Device authorized to

manufacture, distribute, and/or operate radio- graphic exposure

devices.

88-17 Summary of Responses to NRC 4/22/88 All holders of OLs

Bulletin 87-01, "Thinning of or CPs for nuclear

Pipe Walls in Nuclear Power power reactors.

Plants"

88-16 Identifying Waste Generators 4/22/88 Radioactive waste

in Shipments of Low-Level collection and

Waste to Land Disposal service company

Facilities licensees handling

prepackaged waste, and licensees operating

low-level waste

disposal facilities.

88-15 Availability of U.S. Food 4/18/88 Medical, Academic, and Drug Administration and Commercial

(FDA)-Approved Potassium licensees who possess

Iodide for IJse in Emergencies radioactive iodine.

Involving Radioactive Iodine

OL = Operating License

CP = Construction Permit

IN 88-22 May 12, 1988 Discussion:

Licensees may wish to consider the following:

1. Sludge from onsite sewage treatment plants may be contaminated with

licensed radioactive material which has been concentrated by the

treatment system.

2. The provisions of 10 CFR 20.303 do not apply to the disposal of contami- nated sludge removed from sanitary sewerage systems at nuclear power

stations.

3. 10 CFR 20.201 covers surveys required before disposing of sewage treatment

sludge, to determine if the sludge is contaminated. Gamma-ray spectrometry

can be performed on representative samples of the sludge under conditions

that provide a lower limit of detection (LLD) appropriate to measurements

of environmental samples. Such measurements make It possible to distinguish

licensed material from other radioactive materials (natural radioactive

materials and world-wide fallout) that may be present in the sludge.

4. 10 CFR 20.301 covers the disposal of sewage sludge from a licensee's sewage

treatment facility when contaminated with licensed radioactive material.

5. Licensees may apply in accordance with the provisions of 10 CFR 20.302 to

dispose of sewage sludge containing very low levels of licensed radio- active material in a manner not otherwise authorized in the regulations.

Applications for approval of such disposal may be made to the NRC or

Agreement State, as appropriate.

No specific action or written response Is required by this information notice.

If you have any questions about this matter, please contact the technical

contact listed below or the Regional Administrator of the appropriate regional

office.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contacts: John D. Buchanan, NRR

(301) 492-1097 W. Wayne Meinke, NRR

(301) 492-3152 Attachment: List of Recently Issued NRC Information Notices

  • Transmitted by memo to C. H. Berlinger from L. J. Cunningham dated

April 1, 1988

  • SEE PREVIOUS CONCURRENCES

DA8Wt NBR *D:DRPEP *C/OGCB:DOEA:NRR *PPMB:ARM

a PStohr CHBerlinger TechEd

05/R, /88 05/03/88 04/12/88 03/21/88

  • OGCB:DOEA:NRR *PRPB:DREP:NRR *SC/PRPB:DREP:NRR *C/PRPB:DREP:NRR *OGC

PCWen JDBuchanan JEWigginton LJCunningham RFonner

04/12/88 03/23/88 03/23/88 03/24/88 04/12/88

IN 88-XX

May xx, 1988 Discussion:

Licensees should be aware of the following:

1. Sludge from onsite sewage treatment plants may be contaminated with

licensed radioactive material which has been concentrated by the

treatment system.

2. The provisions of 10 CFR 20.303 do not apply to the disposal of contami- nated sludge removed from sanitary sewerage systems at nuclear power

stations.

3. Before disposing of sewage treatment sludge, to conform with 10 CFR 20.201, licensees must perform a survey to determine if the sludge is contaminated.

Gamma-ray spectrometry can be performed on representative samples of the

sludge under conditions that provide a lower limit of detection (LLD)

appropriate to measurements of environmental samples. Such measurements

make it possible to distinguish licensed material from other radioactive

materials (natural radioactive materials and world-wide fallout) that may

be present in the sludge.

4. If the sewage sludge from a licensee's sewage treatment facility is

contaminated with licensed radioactive material, it must be disposed of as

radioactive waste in accordance with 10 CFR 20.301.

5. Licensees may apply in accordance with the provisions of 10 CFR 20.302 to

dispose of sewage sludge containing very low levels of licensed radio- active material in a manner not otherwise authorized in the regulations.

Applications for approval of such disposal should be made to the NRC, or

to the Agreement State, as appropriate.

No specific action or written response is required by this information notice.

If you have any questions about this matter, please contact the technical

contact listed below or the Regional Administrator of the appropriate regional

office.

Charles E. Rossi, Director

Division of Operational Events Assessment

Oftice of Nuclear Reactor Regulation

Technical Contacts: John D. Buchanan, NRR

(301) 492-1097 W. Wayne Meinke, NRR

(301) 492-3152 Attachment: List of Recently Issued NRC Information Notices

  • Transmitted by memo to C. H. Berlinger from L. J. Cunningham dated

April 1, 1988

  • SEE PREVIOUS CONCURRENCES

D/DOEA:NRR D:D *C/OGCB:DOEA:NRR *PPMB:ARM

CERossi PSt r CHBerlinger TechEd

05/ /88 05 /88 04/12/88 03/21/88

  • OGCB:DOEA:NRR *PRPB:DREP:NRR *SC/PRPB:DREP:NRR *C/PRPB:DREP:NRR *OGC

PCWen JDBuchanan JEWigginton LJCunningham RFonner

04/12/88 03/23/88 03/23/88 03/24/88 04/12/88

IN 88-XX

April xx, 1988 No specific action or written response is required by this information notice.

If you have any questions about this matter, please contact the technical

contact listed below or the Regional Administrator of the appropriate regional

office.

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contacts: John D. Buchanan, NRR

(301) 492-1097 W. Wayne Meinke, NRR

(301) 492-3152 Attachment: List of Recently Issued NRC Information Notices

References

1. IE Bulletin No. 80-10, "Contamination of Nonradioactive System and Result- ing Potential for Unmonitored, Uncontrolled Release of Radioactivity to

Environment," May 6, 1980.

2. IE Information Notice No. 83-05, "Obtaining Approval for Disposing of

Very-Low-Level Radioactive Waste - 10 CFR Section 20.302,"

February 24, 1983.

3. IE Information Notice No. 86-90, "Request to Dispose of Very-Low-Level

Radioactive Waste Pursuant to 10 CFR 20.302," November 3, 1986.

4. IE Information Notice No. 85-92, "Surveys of Waste Before Disposal from

Nuclear Reactor Facilities," December 2, 1985.

  • Transmitted by memo to C. H. Berlinger from L. J. Cunningham dated

April 1, 1988

  • SEE PREVIOUS CONCURRENCES

D/DOEA:NRR C/OA *& NRR *PPMB:ARM

CERossi CHBerlinger TechEd

04/ /88 04//it/88 03/21/88 A

OGCB:DOEA:NRR *PRPB:DREP:NRR *SC/PRPB:DREP:NRR *C/PRPB:DREP:NRR OGC

PCWen 7~LA JDBuchanan JEWigginton LJCunni ngham RFonn w

04/J4/88 03/23/88 03/23/88 03/24/88 04//

IN 88-XX

March xx, 1988 Information Notice.

No specific action or written response is required by this the Regional

If you have any questions about this matter, please contact office.

Administrator of the appropriate NRC regional office or this

Charles E. Rossi, Director

Division of Operational Events Assessment

Office of Nuclear Reactor Regulation

Technical Contacts: John D. Buchanan, NRR

(301) 492-1097 W. Wayne Meinke, NRR

(301) 492-3152 References

System and Result-

1. IE Bulletin No. 80-10, "Contamination of Nonradioactive Radioactivity to

ing Potential for Unmonitored, Uncontrolled Release of

Environment," May 6, 1980.

Disposing of

2. IE Information Notice No. 83-05, 'Obtaining Approval for

Very-Low-Level Radioactive Waste - 10 CFR Section 20.302,0

February 24, 1983.

XE Information Notice No. 86-90, "Request to Dispose of 3, 1986.

Very-Low-Level

3.

Radioactive Waste Pursuant to 10 CFR 20.302," November

Disposal from

4. IE Information Notice No. 85-92, 'Surveys of Waste Before

Nuclear Reactor Facilities," December 2, 1985.

Attachment: List of Recently Issued NRC Information Notices

D.NR C:OGCB:DOEA:NRR D/DOEA:NRR

REP NRRRM CERossi

JDBuchanan: AThomas J iglnton CHBerlinger

03/21/88 0W/2-/88 03/ /88 03/ /88

03/Z?/88