Information Notice 1994-07, Solubility Criteria for Liquid Effluent Releases to Sanitary Sewerage Under the Revised 10 CFR Part 20

Solubility Criteria for Liquid Effluent Releases to Sanitary Sewerage Under the Revised 10 CFR Part 20

ML031070039
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, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	01/28/1994
From:	Burnett R, Paperiello C NRC/NMSS/FCSS, NRC/NMSS/IMNS
To:
References
IN-94-007, NUDOCS 9401240059
Download: ML031070039 (9)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 January 28, 1994 NRC INFORMATION NOTICE 94-07: SOLUBILITY CRITERIA FOR LIQUID EFFLUENT

RELEASES TO SANITARY SEWERAGE UNDER THE

REVISED 10 CFR PART 20

-

Addressees

All byproduct material and fuel cycle licensees with the exception of

licensees authorized solely for sealed sources.

Purpose

The U.S. Nuclear Regulatory Commission is issuing this information notice to

emphasize the changes in 10 CFR Part 20 with respect to liquid effluent

releases t: sanitary sewerage and to encourage you to prepare for these

revisions. It is expected that licensees will review this information for

applicability to their operations, distribute it to appropriate staff, and

consider actions to prepare for, and incorporate, these changes. Suggestions

contained in this information notice are only recommendations; therefore, no

specific action nor written response is required.

Background

On December 21, 1984, NRC released an information notice documenting several

instances of reconcentration of radionuclides released to sanitary sewerage

(IN No. 84-94, "Reconcentration of Radionuclides Involving Discharges into

Sanitary Sewage Systems Permitted under 10 CFR 20.303"). Several other

instances have since occurred in Portland, Oregon; Ann Arbor, Michigan; Erwin, Tennessee; and Cleveland, Ohio. The primary contributors, in some of these

cases, appear to have been insoluble materials released as dispersible

particulates or flakes. This issue was-addressed again on May 21, 1991, by

NRC, when it published its revision of Part 20 in the Federal Register

(56 FR 23360), which removed insoluble non-biological material from the types

of material that may be released to sanitary sewerage. Relative to this

issue, the NRC Office of Nuclear Regulatory Research is conducting a study to

clarify the mechanisms underlying reconcentration in sanitary sewerage and

sewage treatment facilities.

9401240059 PI) XD E 4o+#.e. 9t-..7 cL~oI~-

• Sanitary sewerage is defined by 10 CFR 20.1003 as "a system of public

sewers for carrying off waste water and refuse, but excluding sewage treatment

facilities, septic tanks, and leach fields owned or operated by the licene

[emphasis added]."

IN 94-07 January 28, 1994

Description of Circumstances

To help prevent further reconcentration incidents at public sewage treatment

facilities, 10 CFR 20.2003(a)(1), effective January 1, 1994, was written as

follows:

§20.2003 Disposal by release into sanitary sewerage

(a) A licensee may discharge licensed material into sanitary sewerage

if each of the following conditions is satisfied:

(1) The material is readily soluble (or is readily dispersible

biological material) in water; and...

However, this revision to Part 20 did not contain an operational definition of

solubility, and this precipitated many questions, from licensees, concerning

how the solubility of a material may be demonstrated. Without the ability to

demonstrate compliance, these licensees were unable to determine whether new

procedures should be developed, new treatment systems installed, or whether

they should apply for an exemption, based on the principle of maintaining all

doses as low as is reasonably achievable (ALARA).

Discussion

In some of the known reconcentration incidents, the greatest reconcentrations

appear to have been due to compounds released to sanitary sewerage that were

not soluble. There are many approaches that may be used to determine a

chemical compound's solubility in water. The following discusses two of the

more common approaches:

1. Direct Determination of Compound Solubilitv Class, Formal Solubilitv, or Solubility Product (K~fs

This approach would be applicable whenever there is sufficient

knowledge of the chemical form of all materials contained in the

liquid effluent at the point of release. With this knowledge, it

would be possible to use one (or more) of the following methods:

(a) Solubility Class Determination:

The solubility class of the compound to be released could be

determined directly from common literature data (e.g., Handbook of

Chemistry and Physics - CRC Press, and Lange's Handbook of

Chemistry - McGraw- Hill Book Company). If a compound is

classified as "v s" (very soluble) or "s" (soluble), this would

indicate the compound is "readily soluble." On the other hand, if

it is classified as "i" (insoluble), "si s" (slightly soluble), or

"v sl s" (very slightly soluble), this would indicate materials

that are "not readily soluble." Certain compounds are designated

as class "d". (decompose). If the decomposed species of these

compounds are classified as either "v s" or "s," this would

indicate that the parent compound is "readily soluble." If these

decomposed species are simple ions, such compounds (class "d")

should be considered "readily soluble."

IN 94-07 January 28, 1994 (b) Solubility Product (Kp) Determination:

The solubility product constant of the compound could also be used

to determine if a compound is readily soluble in water. The

solubility product constant, K8p, for a strong electrolyte MmAa is

expressed as:

KSP NM]' [A]a

where [M] and "m" are the ionic concentration (mole/liter) and the

number of moles, respectively, of the dissolved cation; and [A]

and "a" are the ionic concentration and the number of moles, respectively, of the dissolved anion.

For a simple electrolytic compound, with one mole of a dissolved

cation species and one mole of a dissolved anion species, a K

greater than 1.00 E-05 mole2/liter would indicate that a comp und

is "readily soluble." For other compounds with more complex.

dissolution reactions (i.e., more than one mole dissolved for each

species and/or more anionic or cationic species present in the

dissolved products), the Kp constant would increase

exponentially, based on the number of moles and/or the number of

dissociated species. For example, if three moles are present (two

for the anion and one for the cation), the unit of K wculd be

mole'/liter3, and the corresponding Ks would be (1 E!%5) / or

3.2 E-08 mole 3 /liter ; the same principle could be applied for

more complex dissolution reactions.

(c) Formal Solubility Determination:

Compound solubilities (g/100 ml or mole fraction per 100 ml) are

also listed in the chemical literature. From a review of general

scientific literature, "formal solubilities" greater than 0.003 mole/liter would indicate that a compound is "readily soluble."

The general relation between the formal solubility, Sf, and the solubility

product, K8p, of a strong electrolyte MA. in water is given by:

S5f K ap

\f+j

m '"a

where K is the solubility product, (M] is the molar concentration of the metal

ion (cafion), (A] is the molar concentration of the anion, "m" is the number of

moles of dissolved cation per mole of dissolved substance, and "a" is the number

of moles of the dissolved anion per mole of dissolved substance.

For further discussion on the determination of solubility products and formal

solubility, refer to Chapter 6, "Precipitation and Dilution," from Water

Chemistry, by Vernon L. Snoeyink and David Jenkins (John Wiley and Sons: 1983)

or texts relating to physical and/or analytical chemistry.

1 be94-07 January 28, 1994 Formal solubilities less than 0.003 mole/liter would indicate

compounds that are "not readily soluble."

It should be pointed out that all values mentioned above (e.g.,

solubility class, formal solubility, and solubility product)

correspond to measurements taken under standard conditions (e.g.,

25*C, 101.3 kPa, pH of 7, and Eh of 0.

2. Filtration and Radiometric Analysis of Suspended Solids

This approach may be used if knowledge of the chemical form of all

materials contained in the liquid effluent at the point of release is

incomplete. It is most applicable when releases are made in a batch

mode. This approach involves the use of standard laboratory

procedures to test representative samples of the waste stream for the

presence of suspended radioactive material.

The following two laboratory procedures were developed specifically to

determine the suspended solids content of water: ASTM Method D 1888-

78, "Standard Test Methods for Particulate and Dissolved Matter, Solids, or Residue in Water," and the American Public Health

Association's Method 7110, "Gross Alpha and Gross Beta Radioactivity

(Total, Suspended, and Dissolved)" from Standard Methods for the

Examination of Water and Wastewater. It should be noted that ASTM

Method D 1888-78 was developed to measure the total suspended solids

content of water, not just the radioactive portion. In either case, activity in the suspended solids portion of effluent greater than that

found in similarly processed background water samples would indicate

the presence of insoluble radioactive material.

Whether one of the above approaches or a self-developed alternative is used, it is a good health physics practice to document this approach in the form of

a procedure. Procedures such as these usually include provisions for the

documentation of any models, calculations, analytical measurements, and/or

quality control 'measures used. This information is usually maintained with

the applicable release records, to demonstrate that the developed procedure

will ensure compliance with the regulations.

If material to be released would not qualify as being "readily soluble,"

10 CFR 20.2003(a)(1) would prohibit release to sanitary sewerage unless an

exemption has been granted. Exemptions will be judged on a case-by-case

basis, when it is demonstrated that release to sanitary sewerage is in

accordance with the ALARA principle, consistent with applicable regulations, and in the public interest.

It is expected that licensees will review this information for applicability

to their operations, and consider actions, as appropriate to their licensed

activities. However, suggestions contained in this information notice are not

NRC requirements; therefore, no specific action nor written response is

required.

IN 94-07 January 28, 1994 If you have any questions about the information in this information notice, please contact one of the technical contacts listed below or the appropriate

regional office.

Robert F. Burnett, Director Carl J. Paper llo, Director

Division of Fuel Cycle Safety Division of Industrial and

and Safeguards Medical Nuclear Safety

Office of Nuclear Material Office of Nuclear Material

Safety and Safeguards Safety and Safeguards

Technical contacts: Rateb (Boby) Abu-Eid, NMSS

(301) 504-3446 Cynthia G. Jones, NMSS

(301) 504-2629 Attachments:

1. List of References

2. List of Recently Issued NMSS Information Notices

3. List of Recently Issued NRC Information Notices

NMSS Editor

EKraus

01/03/94 *See Drevious concurrence

OFC IMOB* I IMOB* I IMOB* lI LW LLWM I FC

NAME BRadcliffe CJones FCombs BEid* JGreeves RBurnett

DATE 12/15/93 - 12/16/93 , 12/16/93 12/29/93 12/21/93 ,01 I/94 OFC RES* I OGC* I IMNS* I IMiS. /2 II

NAME BMorris STreby EWBrach C}P4II

Pi eil Io

DATE 12/21/93 12/30/93 01/06/94 401//94 DOC NAME: IN94-07.CGJ

Attachment 1 IN 94-07 January 28, 1994 REFERENCES

Annual Book of ASTM Standards. Volume 11.01, "Water (I)." American Society

for Testing and Materials, Easton, MD, 1989.

CRC Handbook of Chemistry and Physics. CRC Press, Inc., Boca Raton, FL, 65 th

ed, 1984.

Lange's Handbook of Chemistry. McGraw-Hill, Inc., New York, NY, 13th ed,

1985.

Snoeyink, Vernon L. and David Jenkins, Water Chemistry. John Wiley & Sons, Inc., New York, NY, 1980.

Standard Methods for the Examination of Water and Wastewater. American Public

Health Association, Washington, DC, 17 ed, 1989.

tchment

% 2 IN 94-07 January 28, 1994 LIST OF RECENTLY ISSUED

NMSS INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

93-100 Reporting Requirements 12/22/93 All U.S. Nuclear Regulatory

for Bankruptcy Commission licensees.

93-80 Implementation of the 10/08/93 All byproduct, source, and

Revised 10 CFR Part 20 special nuclear material

licensees.

93-77 Human Errors that Result 10/04/93 All nuclear fuel cycle

in Inadvertent Transfers licensees.

of Special Nuclear Material

at Fuel Cycle Facilities

93-69 Radiography Events at 09/02/93 All holders of OLs or CPs

Operating Power Reactors for nuclear power reactors

and all radiography

licensees.

licensees.

93-60 Reporting Fuel Cycle and 08/04/93 All fuel cycle and materials

Materials Events to the licensees.

NRC Operations Center

93-50 Extended Storage of 07/08/93 All licensees authorized

Sealed Sources to possess sealed sources.

93-36 Notifications, Reports, 05/07/93 All U.S. Nuclear Regulatory

and Records of Misadmin- Commission medical

istrations licensees.

93-31 Training of Nurses 04/13/93 All U.S. Nuclear Regulatory

Responsible for the Commission medical

Care of Patients with licensees.

Brachytherapy-Implants

93-30 NRC Requirements for 04/12/93 All U.S. Nuclear Regulatory

Evaluation of Wipe Commission medical

Test Results; Cali- licensees.

bration of Count Rate

Survey Instruments

At\ chment 3 IN 94-07 January 28, 1994 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

94-06 Potential Failure of 01/28/94 All holders of OLs or CPs

Long-Term Emergency for boiling water reactors.

Nitrogen Supply for the

Automatic Depressurization

System Valves

93-85, Problems with X-Relays 01/20/94 All holders of OLs or CPs

Rev. 1 in DB- and DHP-Type for nuclear power reactors.

Circuit Breakers Manu- factured by Westinghouse

94-05 Potential Failure of 01/19/94 All holders of OLs or CPs

Steam Generator Tubes for pressurized water

with Kinetically Welded reactors (PWRs).

Sleeves

94-04 Digital Integrated 01/14/94 All NRC licensees except

Circuit Sockets with licensed operators.

Intermittent Contact

94-03 Deficiencies Identified 01/11/94 All holders of OLs or CPs

during Service Water System for nuclear power reactors.

Operational Performance

Inspections

94-02 Inoperability of General 01/07/94 All holders of OLs or CPs

Electric Magne-Blast for nuclear power reactors.

Breaker Because of Mis- alignment of Close-Latch

Spring

94-01 Turbine Blade Failures 01/07/94 All holders of OLs or CPs

Caused by Torsional for nuclear power reactors.

Excitation from Electrical

System Disturbance

93-101 Jet Pump Hold-Down Beam 12/17/93 All holders of OLs or CPs

Failure for boiling-water reactors.93-100 Reporting Requirements 12/22/93 All U.S. Nuclear Regulatory

for Bankruptcy Commission licensees.

OL = Operating License

CP - Construction Permit

K>

IN 93-XX

December XX, 1993 Page 5 of X

This information notice requires no specific action nor written response f

you have any question about the information in this notice, please co ct one

of the technical contacts listed below or the appropriate regional fice.

Brian K. Grimes, Director Carl . Paperiello, Director

Division of Operating Reactor Div ion of Industrial and

Support edical Nuclear Safety

Office of Nuclear Reactor ffice of Nuclear Material

Regulation Safety and Safeguards

Techinical Contacts: Rateb (Bob Abu-Eid, NMSS

(301) 50 3446 Cynth G. Jones, NMSS

(30 504-2629 Attachments:

1. List of Referens

2. List of Recen y Issued NMSS Information Notices

3. List of Rec ly Issued NRC Information Notices

OFC IMOB lO ,l MBB LLM LLWM l FCSS NRR/DRSS

NAME BRadcliffe go es Fl s' ___-d _ JGreeves RBurnett FCongel

DATE 12/AS-93 /IH/0/93 3 t /.2q/93 / /93 / /93 / /93 OFC RES _ OGC I MNS I IMNS l LNRR/DORS Ili

NAME BMorris STreby EWBrach CPaperiello BGrimes

DATE /93 / I 93 / /93 / /93

/ /_/93 _ ___

C . COVER E = COVER & ENCLOSURE N a NO COPY

OFFICIAL RECORD COPY: G:INFOSWR2.311