ML13255A472
| ML13255A472 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/08/2013 |
| From: | Conatser R Office of Nuclear Reactor Regulation |
| To: | Madden C Energy Northwest |
| References | |
| FOIA/PA-2013-0265 | |
| Download: ML13255A472 (3) | |
Text
Page 1 of 3 From:
Conatser, Richard Sent:
Friday, March 08, 2013 10:45 AM To:
Madden, Clay R.
Cc:
Gibson, Lauren; Jim Key
Subject:
FW: State of Washington Questioning Release from Columbia Clay.
Based on the limited information in the email, it does not appear that the source of the Co-60 and Cs-1 37 is known.
As a result, application of the RIS to the resulting liquid effluents (i.e., relinquishing the need to report the liquid release in the Annual Radioactive Effluent Release Report) would not seem appropriate. RIS 2008-003 states:
... Furthermore, before returning radioactive materials to the environment, licensees must demonstrate that these radioactive materials were previously disposed of in accordance with 10 CFR 20.2001(a)(3), or that the material is naturally occurring background radiation....
In this case, it is not clear why the backwash water could not be collected and returned to an ODCM release point.
Again, this is based on the limited amount of information supplied below. If you would like the NRC to pursue a formal response to this and other questions, like the burial issues and resuspension from buried waste, you would need to go through your licensing manager to request an NRC response.
Best Regards, Richard L. Conatser Health Physicist Nuclear Regulatory Commission 11555 Rockville Pike [ Rockville, MD 20852 Tel: 301-415-4039 I Mobilej(b)(6)
Richard.Conatser@NRC.gov [I From: Madden, Clay R. [maiIto:CRMADDEN@enerciy-northwest.com]
Sent: Thursday, March 07, 2013 10:27 PM To: Conatser, Richard; jim kevykeysolutionsinc.com
Subject:
State of Washington Questioning Release from Columbia Lynn Albin of Washington State Department of Health is asking me if a specific release being planned at Columbia Generating Station needs to be processed and documented as a release in our annual effluent report. I gave her my opinion and told her I'd try to reach you two as a sanity check.
Detail of Release Scenario:
We are currently vacuuming sediment from our spray ponds. The vacuum exhaust (water and sediment) is being pumped onto some nets to capture the sediment and allow the water to pass through.
The sediment will be disposed of onsite iaw 10CFR50.75(g) based on an agreement with Washington State The water is collected, filtered through some sand filters, and then returned to the spray pond.
Soon, the sand filters will need to be backwashed. The plan is to backwash them and "release" the water and any suspended solids to a slit trench which we call "Outfall 3". Outfall 3 is onsite and is not described as a "release" or "discharge" point in the ODCM (only described in our NPDES permit).
mhtml:file://C:\\Users\\PKC\\AppData\\Local\\Microsoft\\Windows\\Temporary Internet Files\\Content.Outio...
07/02/2013 C/h0
Page 2 of 3 Activity:
Sediment; We have sampled and analyzed the sediment in the spray ponds.
Average Co-60 activity in wet sediment = 0.12 pCi/gm Average Co-60 activity in dry sediment = 1.25 pCi/gm Average Cs-137 activity in dry sediment = 0.05 pCi/gm Limits for disposal onsite law agreement with Washington State and consistent with a decommisioning dose of <15 mrem/yr to the public from direct exposure and resuspension.
Maximum Values Allowed for Sediment Disposal I
Isotope Limits (pCi/gm)
Co-60 5
Mn-54 30 Zn-65 50 Cs-134 10 Cs-137 20 Water:
We have continuous monitors on Service Water and no activity above background is observed.
We take monthly grab samples and no activity is seen in the water.
My position:
There are three possible sources of the sediment activity o Co-60 from Columbia River water sediment activity from DOE operations (REMP reports from the Hanford Site have shown Co-60 in some river bank samples upstream from Columbia Generating Station).
o Co-60 from Columbia Generating Station gaseous effluent which are trapped by the spray of the spray pond o Cs-137 as NORM (Columbia has not seen Cs-1 37 in gaseous effluents since 1990)
If I assume it is all from Columbia Generating Station, I turn to NRC RIS 2008-03 and conclude that The water can go into the slit trench as per scenario 2 on page 3 (third paragraph) of the RIS.
Now, we are planning to take periodic samples of the water and some soil samples in the trench following the activity.
" The RIS does not apply to activity in solid materials or soil but the soil is being disposed of onsite law with agreements with Washington State.
The activity in sediment is less than IOCFR30 exempt concentration limits Maximum Values Allowed for Onsite 10CFR30 Exempt Activity Seen Disposal Concentrations in Soil Isotope Limits (pCi/gm) pCi/gm pCi/gm dry Co-60 5
500 1.25 Mn-54 30 1000 Zn-65 50 1000 Cs-134 10 90 Cs-1 37 20 0.05 I am very open-minded to:
mhtml:file:1/C:\\Users\\PKC\\AppData\\Local\\Microsoft\\Windows\\Temporary Internet Files\\Content.Outlo...
07/02/2013
Page 3 of 3 a) Adding the slit trench or the onsite sediment/sludge disposal cells as onsite release points in the ODCM.
b) Documenting all this in the annual effluent report and start calculating dose to the public from resuspension of soil from the onsite sediment/sludge disposal areas if it would be helpful to the public or regulators.
Do either of you have an opinion as to what would be most helpful to all stakeholders?
Note: I use the terms "release" and "discharge" as per RG 1.21 Rev 2 Respectfully, Clay Clay R. Madden MS Certified Health Physicist Chemistry Department Columbia Generating System Energy Northwest POB 968 Richland, WA 99352 509.377.4460 mhtml:file://C:\\Users\\PKC\\AppData\\Local\\Microsoft\\Windows\\Temporary Intemet Files\\Content.Outlo...
07/02/2013