L-96-083, Clarifies & Corrects Certain Points Made in . Wastes Shipped Not Considered Mixed Radioactive & Hazardous Waste.Prior Approval of NRC Commission & CA State Dept of Health Services,Matls Shipped Solely as Hazardous Wastes
| ML20138H444 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 10/22/1996 |
| From: | Moulia T PACIFIC GAS & ELECTRIC CO. |
| To: | Yuhas G AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20138H419 | List: |
| References | |
| FOIA-96-451 PML-96-083, PML-96-83, NUDOCS 9701060048 | |
| Download: ML20138H444 (1) | |
Text
- TA"5 -> M VM W Itcific Grs and Electric Company 1000 Kine Sihnon Avenue
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Humboldt Bay Power Plant Eureks CA 95503 TOh! A. A10UUA '*##**
Plant Afanager October 22,1996 PML-96-083 Greg Yuhas 790 West J Street Benicia, California 94510 Greg:
I would like to clarify and correct certain points that we made in the August 23rd letter to you and describe the assumptions made by PG&B. First, and perhaps most important, the wastes shipped was not considered mixed (radioactive and hazardous) waste. With prior approval of the Nuclear Regulatory Commission and the California State Department of Health Services, these materials were shipped solely as hazardous wastes. Please refer to enclosure 1, which is an evaluation of the approval process for the stdpments made between 1984 and 1987.
Our lette.t also described the shipments made from Humboldt Bay Power Plant to IT Corporation facilities. In that letter, the 1983 shipment to the IT Martinez Treatment Facility was identified, by us as containing " trace amounts" of nuclear power plant radioactivity. Tids was not the case. The pond sludge shippea in August of 1983 was found to have only naturally occurring radioactivity. Also in the August 23rd letter, most Humboldt wastes were stated to have been shipped to the Martinez facility for treatment and subsequent transfer to the Benicia facility for disposal. This was an assumption on our part of how the waste was handled by IT Corporation. Some of the shipments were made from Humboldt Bay Power Plant directly to Benicia, (the 1984 shipment of the plant's oily water separator sludge, and a 1986 shipment of boiler flyash). Other shipments were made to Martinez (waste treatment pond and oily water separator sludge in 1983,1986 and 1987). Please refer to enclosure 2 which annotates, in the August 23rd letter, those areas of concern.
I hope that this letter helps to clarify our previous correspondence to you. I also hope that it provides you with a better explanation of the shipping process and the shiprnents made to IT Corporation. If you have any concerns or comments please contact me.
Sincerely yours, A
TOM A. MOULIA Enclosures cc w/o enclosures:
Richard Dudley NRC Vincent Everett NRC Dave McMurtry IT Corporation Steve Shu DHS Wei-Wei Chui DTSC I l 9701060048 961231 '/ I PDR FOIA HAYES96-451 PDR
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.. Pacific Gas rnd Electric Company 1000 King S*1 mon Avenue Humboldt Bay Power Plant Eurcka, CA 95503 7071444 s700 TOh! A. A10ULIA Plant Afanager October 22,1996 PML-96-081 Dave MeMurtry International Technologies Corporation 4585 Pacheco Blvd.
Martinez, Califonua 94553 Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit 3 Clarification of Aucust 23.1996 letter to Gren Yuhas of Benicia. California Dave I wish to apologize for not providing the IT Corporation with a copy of our August 23,1996 correspondence with Greg Yuhas. This was an unfo tunate and unintentional oversight.
The letter of August 23,1996 was written in response to a request made by Mr. Greg Yuhas of Benicia, California. In this request, Mr. Yuhas stated that he was reviewing the " Closure Plan" for the IT Benicia waste disposal facility and requested information on shipments made from Humboldt Bay Power Plant to that facility. Mr. Yuhas is a former Regional Inspector for the Nuclear Regulatory Commission and had inspection responsibility for Humboldt Bay Power Plant's Radiation Protection program on various occasions.
I would like to clarify and correct certain points that we made in the August 23rd letter to Mr.
Yuhas and describe the assumptions made by PG&E. First, and perhaps most important, the wastes shipped to your facilities was not considered mixed (radioactive and hazardous) waste.
With prior approval of the Nuclear Regulatory Commission and the California State Department of Health Services, these materials were shipped to you solely as hazardous wastes. Please refer to enclosure 1, which is an evaluation of the approval process for the shipments made to your facility between 1984 and 1987.
Our letter to Mr. Yuhas also described all the shipments made from Humboldt Bay Power Plant to your facilities. In that letter, the 1983 shipment to the IT Martinez Treatment Facility was identified, by us as containing " trace amounts" of nuclear power plant radioactivity. This was not the case. The pond sludge shipped in August of 1983 was found to have only naturally occurring radioactivity. Also in the letter to Mr. Yuhas, most Humboldt wastes were stated to have been shipped to the Martinez facility for treatment and subsequent transfer to the Benicia facility for disposal. This was an assumption on our part of how the waste was handled by IT Corporation. Some of the shipments were made from Humboldt Bay Power Plant directly to Benicia, (the 1984 shipment of the plant's oily water separator sludge, and a 1986 shipment of O W
. PG&E Letter No. PML-96-081 boiler flyash). Other shipments were made to Martinez (waste treatment pond and oily water separator sludge in 1983,1986 and 1987). Please refer to enclosure 2 which annotates, in the August 23rd letter, those areas of concem.
I hope that this letter helps to clarify our previous correspondence with Mr. Yuhas. I also hope that it provides you with a better explanation of the shipping process and the shipments made to your facilities.
Sincerely yours TOM A. MOULIA Enclosures cc: NRC Document Control Desk Richard Dudley NRC Vincent Everett NRC Greg Yuhas Steve Shu DHS Wei-Wei Chui DTSC l
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PG&E Letter No. PML-96-031
, ENCLOSURE 1 DESCRIPTION OF WASTE SIIIPMENTS TO i
IT CORPORATION'S TREATMENT AND DISPOSAL FACILITIES During the period of 1984 through 1987, four waste shipments were made from Humboldt Bay Power Plant in Eureka, Califomia to the International Technology (IT) Corporation Class I waste disposal facility in Benicia and treatment facility in Martinez, California. These shipments consisted of sludge from the fossil power plant waste water surface impoundments, sludge from the plant oily water separator system and flyash from the fossil boiler ' firebox *. These wastes are classified as hazardous in the State of Califomia due to the concentration of metals and/or used oil. These wastes were also very slightly contaminated with radionuclides as a result of past operation of the nuclear powered portion of the plant.
All of these shipments were made in accordance with the Federal, State of Califomia and disposal site criteria for hazardous wastes.
These materials were not required to be described as ' radioactive' for transportation because they were well below the level that the USDOT defmes as ' radioactive'. Disposal of these waste materials as a radioactive waste was not required due to the very low levels of radioactivity present in the wastes. Extensive sampling, analysis and assessment was performed to verify the lack of radiological hazard posed by these wastes. The Nuclear Regulatory Commission (NRC) and Califomia State Department of Health Services (DHS) approvals recognized that the wastes were no longer regulated as " radioactive waste" subject to the provisions of 10 CFR part 20 and part 61, and were subsequently received by the IT Corporation sites, to be handled and disposed of only as hazardous waste.
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- The decision to send these wastes to a IT Corporation Class I hazardous waste site was based on a comprehensive assessment of the relative hazards of the concentrations of the chemical constituents, primarily metals, as compared to the extremely low concentrations of radioactive nuclides in the waste. Approvals by the NRC and the State of California for disposal of the waste at the Class I site were based on the lack of radiological hazard posed by the waste and on the disposal site characteristics. The disposal site characteristics and the administrative controls for the protection of the health and safety of the workers, the public and the environment from the chemical content of the waste were considered more than adequate for protection from the waste's radioactive content.
1 The approvals for release from regulatory control of the very small amount of radioactisity in the waste sent to the IT Corporation disposal facilities confina that the radioactivity represents such an insignificant potential hazard (risk) that specific controls for its radioactive content were and are not required of the next recipient of the waste. Although the original licensee is still bound by applicable requirements of the regulations and specific license (s) for the handling of radioactive materials on its site, the only obligation of the receiving party is to handle the materials as described in the application for disposal (i.e. as hazardous waste).
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I#acific Gas and Electric Company 1000 Kinssanon Avenue
, flutnboldt 11ay l'ower I'lant Eurcks, CA 95503 TOM A. MOULIA 7071444-0200 l'lant Manager August 23,1996 PG&E Letter No. PML-96-081 PML-96-072 PG&E Letter No. PML-96-083 Mr. Greg Yuhas 790 West J Street Benicia, CA 94510
Dear Mr. Yuhas:
On Angust 14,1996 you requested from PG&E information on hazardous wastes gene the Humboldt Bay Power Plant and subsequently disposed at the I.T. Benicia site. 'Ihe information was requested to facilitate your review of the Closure Plan for that site As requested, PG&E is supplying the enclosed infonnation on hazardous waste disposed at the The wastes were contaminated with reactor fission products at a very low activity (gam emitter activity was less than 10 picocurie per gram (pCilgm)). Prior to disposal, PG&E provided analytical and isotopic information on the waste to federal and state agencies, a received approvals for disposal of the wastes at the Class I disposal site. Approvals were granted by either the Nuclear Regulatory Commission or the California Departnent of Health Services based on the understanding that the environmental and human health hazards o wastes due to the presence of heavy metals, exceeded the hazards due to very low-level radioactivity, and that a Class I hazardous waste site was appropriate for disposal.
The waste types, quantities, and other information are provided below
- 1. Wastewater treatment pond sludge This was an aqueous waste containing inorganic material comprised ofiron oxides, salt some relatively insoluble heavy metals (oxides and salts), flyash generateA dom combustion o fuel oil, and miscellaneous wind-borne and water-bome materials (soils, etc.). The waste generated by settling of solids from the following wastewaters:
fossil-fueled boiler blowdown contauung sulfates, phosphates, and trace amounts ofiron and copper exides; (2) evaporator llowdown containing hardness (scaling) deposits; and, (3) boiler fireside washes co{
l'yash with sulfur compounds and relatively insoluble heavy metal oxides and salts ji, ccoper, lead, nickel, and vanadium. Ileavy metal concentrations ranged in the tens to thousands j ofparis per million in the solid fraction of the waste. !
ChenVcal analyses have shown that it is not a RCRA Waste, but is a Califorma State hazar waste due to either the total and/or extractable (Califomia CAM W E T. methodI concentrations of several heavy metals in excess of Califomia State regulatory limits. No halogenated organics were present in the waste stream sources based on knowledge of processes generating the waste i
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ENCLOSURE 2 o PG&E Letter No. PML-96-081 PG&E Letter No. PML-96-083 Principal isotopes in the sludge were Cobalt 60 (Co69) at approximately 1.0 pCi/gm and Cesium 137 (Cs137) at approximately 6.0 pCi/gm. Other Lstopes are expected to have been present at lesser activities.
Disposal Dates:
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iA>u.s 4<- Stu p meat 983 Approximately 30,600 gallons of aqueous sludge shipped to the I.T. Martin z site for de-watering by evaporation, prior to disposal at the Benicia site.
1986 Approximately 17,100 gallonsof acucous sludge shipped to the I.T. Martiaez sit,e for de-watering by evaporation,@pftofdippedVe. at)2fep6nici@
&J by -the g(Wpeg disp (osa l M 8cdte
- 2. Boiler flyash, fireclay, and firebrick This inorganic material was comprised of ash deposits from the combustion of fuel oil, firebrick insulation and granular fireclay insulation. De material contained sulfur compounds, and relatively insoluble heavy metal oxides and salts, including copper, lead, nickel, and vanadium.
The waste was a California State hazardous waste due to either the total and/or extractable metal concentrations of several heavy metals in excess of Califonia State regulatory limits.
Principal isotopes in the sludge were Co60 at approximately 0.5 pCi/gm and Cs137 at approximately 0.4 pCi/gm. Other isotopes are expected to have been present at lesser activities.
Disposal Dates:
1986 Approximately 25 cubic yards of solids were shipped directly to the I.T. Benicia site for disposal.
- 3. Oil-water separator system sludge
%e sludge was a mixture ofinorganic and organic material comprised of soil, inorganic oxides, heavy fuel oil and lube oil residues, and miscellaneous detritus. He organics present were residuals from heavy fuel oil and lube oil and did not contain volatile and semi-volatile constituents or halogenated organics.
Chemical analyses have shown it is not a RCRA Waste, but is a California State hazardous waste due to either the total and/or extractable metal concentrations of several heavy metals in excess of California State regulatory limits. No halogenated organics were present in the waste stream sources based on knowledge of the processes generating the waste.
Principal isotopes in the sludge were Co60 at approximately 8.0 pCi/gm and Cs137 at approximately 4.5 pCi/gm. Other isotopes are expected to have been present at lesser activities.
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ENCLOSURE 2
. PG&E Letter No. PML-96-081
PG&E Letter No. PML-96-083 Disposal Dates:
1984 Approximately 20,400 gallons of aqueous sludge shipped to the(IM VapI pae-patynig)9 efapgrftipr( rpi6rjd'4sposaf aktfi@ Benicia site. ' '
1981 Approximately 5,300 gallons of aqueous sludge shipped to the I.T. Martinez site for de-watering by evaporation [gg6t yyp9saljftp6 gehpcapit]e / ten /dy 6-( g 4 $ ab WA,h/ bem vee @/f)& ed by ez /s
'1T Coppac44 tim Should you have any questions conceming this information, please contact me at (707) 444-0700.
Sincerely, Oh A. MOULIA cc: Vi,ncent Everett Region IV, NRC 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Edgar D. Bailey, Chief '
Radiologic Health Branch Dept. of Health Services P. O. Box 189024/1233 Q Street !
Sacramento, CA 95818 l
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i Mr.OngYuhas l 190 WestJ Staat j Beicia,CA 94510 3
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h August 14,1996 you requested tom PG&E infhanadan secretailp the Hanboldt Bay Power Plant and subsequently disposed at es I.T. Benicia sin T bd i on $azardous wa ~
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afbrmation was regnested to ibcilitsee your sview of tbs Closure Plan forthat she. Als ,
tequested, PO&E is supplying the enclosed infbanation on hazardous wasidispcsed aIthe site.
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'amtter activity was less than 10 picoCuris per gram (pci/sm)). Priorin disposal,PO% :
pnmded analydcal and isotopic infbsmation on the waste to ibderal and sute agosoies,!and l
l received approvals for disposal ofthe wastes at the Class I disposal site. ApprovalsM l M by sitber the Nuclear Raguistory CMa=laa orthe allewnia c Department ofHealth ,
l Services based on the understanding that the environmental and human hastthhadmis 6f tble- l wastes due to the presence of heavy metals, exceeded the basartis due to verylowjlevoi; radioactivity, and that a Class I hazardous waste site was appr paints fbrdsposal.
The waste types, quantities, and other infbanation are provided below: ',
- 1. Wastewatertrw=== pond sludge l This was an aqueous waste containing inorganic material w.y.imd ofiros oxides, saks. with some relatively insoluble heavy metals (anides and salts), flyush generated kom e@on of bel oil, and misceRaneous wind-bocas and waser bonne materials (soils, ass:.). Th wastnas -
I senerated by settling of solids inza the fbliowing westewaters: ftpssil-fbaletboils%N,
<xmenining sulfhtes, phosphates, and traos amounts ofiron and copper oxidw;(2) svgpg , ,
blowdown commining hardness (scaling) deposits; and, (3) boiler fimeide washes (M i . /'
flyash with sulfbr compounds and relatively insoluble heavy metal oxides and saltis, including copper, land, nickel, and vanadhan. Heavy metal conosaradons ranged in duteniiinthousands "-
of parts per millica in the solid Auction of the wests. .
Chemical analyses have shown tbst it is not a 1(CRA Wasta, but is a CalifteniaS waste due to either the total and/or extactable (Califbana CAM W.E.T. method) metal !
conocatrations of esveral heavy metals in exoses of Cahfbtnia Stars regulanxylintits. No i ~
halogenated organics were present in the waste stream sources based on kunwiedgh of tk I i
processes gaa .f the waste.
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y 1,0 pCVgl mand CW Principalisotopes in the shadge were Cobak 60 (Co60) se appie - ==5
- , 137 (Cs137) at approximasely 6.0 pCVam. Other isotopes are expected to have bsuapresa'nt a l .
lessor saltvities. ,
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! Itu Approximststy 30,600 saisons ataqueous sindse shipped to tim I.T.Martime she to'rj j
i y by evaponsica, prior to dispossl ar the Benicia sits. ' l 1 j l al
! . 12M A prominnesiy P 17,100 gnuens of aqueens shulge shipped io the I.T. Martines sim ibtdo. .
wesering by evaporation, priorto disposal at the Benicia she. !
- 2. Bauer flyssh, fimulay, and firebnait
" t j y ir. organic maassial was campsised of ash deposits o itent tbs c' tabastice,offhel
, J .!. od asulatim and gesenlar fssolayinsnistion. The massial contained sulfbr ounposxis , adi' d' retaintly impoluble besyy mets! asides and salts, including copper, land, akkal, ad vanadadi.
The wasse was a Califbrain Stass hasardous wasm das to either the ined ani/orannetable'aistal conosutrations offeveral haavy metals in atoess of Califbruip' Stats regulanwylinsu.. 'j .
I principal isotopos in the sindse were Co60 at .yr.4 'i0.5 pCVgm and Cs131 sit j.
appro4 r.d 0.4 f pCVgnL Otherisotopes an expeced to have been passaa atlaser activines.
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1216. Approximssaly 25 cubic yards of solids woes shipped directly to tim I.T. ILeniciasitir,hr disposal. .-
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- 3. Oil waser separatorsysumsindro l!
The sindse was a nnimate of E ;- 'c and organis aseenal m.M of me,inassaicasbis, heavy fbel oil sad inbo oil asiduss, and Maan=, desntos. The @ presaswere residuals timen heavy fhat oil and inbe oil and did not conmin volanie and ws.; d tne constnuants or halogmated @, '
I l ll J h1 analyses have shown it is not a RCRA Wases, but isca omma Stass)aar l '. i wasts due to eitbarthe total and/or auractable mata1 concentrations of seve sthemyin$ms)citals excess of Califbania Seses reguissory limits. No halogansted organics were pressa;in the ste wa,igc stressa sonreer based on knowledge of the proossnes ganaranas the wasts. ! i l
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TiMr.1 isotopes in the sindse were Co60 se - ,-E ri 8.0 pCVgm so!Cs!3f at r.,r.e-j+= 'y 4.$ pCi/gm. Other Isotopes are g+ 1--! to have been pnsent at lesser activities. ,
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M Approxhnetely 5,300 ganons of aqueous studes shipped to the I. '
wateringby evaporation, pdor to disposal at the Benicia site. i3 1
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Edgar D. Bailey, Chief i l Radmiogic Haakh Branch ,
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