ML18200A034
| ML18200A034 | |
| Person / Time | |
|---|---|
| Site: | 03030429 |
| Issue date: | 07/18/2018 |
| From: | Pruett T W Division of Nuclear Materials Safety IV |
| To: | Gadd T J. P. Mascaro & Sons |
| References | |
| Download: ML18200A034 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV Mr. Terry Gadd 1600 EAST LAMAR BOULEVARD ARLINGTON, TEXAS 76011-4511 July 18, 2018 Environmental Compliance Manager J.P. Mascaro & Sons dba Solid Waste Services, Inc. 2650 Audubon Road Audubon, PA 19403
SUBJECT:
ISSUANCE OF AN EXEMPTION TO J. P. MASCARO & SONS DBA SOLID WASTE SERVICES, INC., FROM THE REQUIREMENT TO OBTAIN A LICENSE FROM THE NUCLEAR REGULATORY COMMISSION FOR A SPECIFIC TYPE OF ACTIVITY
Dear Mr. Gadd:
By this letter, the U.S. Nuclear Regulatory Commission (NRC) grants J. P. Mascaro & Sons dba Solid Waste Services, Inc., permission to accept for disposal well-logging sandouts and well returns containing residual radioactive materials regulated by the NRC and generated by ProTechnics Division of Core Laboratories LP (ProTechnics) without the need for J.P. Mascaro & Sons dba Solid Waste Services, Inc., to obtain an NRC license for this type of activity.
By letter dated June 15, 2018, ProTechnics submitted to the NRC a request to amend ProTechnics' License 42-26928-01.
This request involved the disposal of well-logging sandouts and well returns containing residual radioactive materials at the Wetzel County landfill, owned and operated by J.P. Mascaro & Sons dba Solid Waste Services, Inc., in New Martinsville, West Virginia, as an alternate disposal method pursuant to Title 10 of the Code of Federal Regulations (CFR) 20.2002. The NRC developed a Technical Evaluation Report (TER) in support of the licensee's previously submitted exemption request and found that the proposed alternate disposal method to be acceptable and in compliance with NRC public dose limits. A copy of the TER is enclosed.
Based on the conclusions of the TER, the NRC approved ProTechnics' June 15, 2018, request by issuing License Amendment 51 on July 11, 2018, granting the request for an alternate disposal method pursuant to 10 CFR 20.2002. In accordance with the terms of NRC License 42-26828-01, ProTechnics' approved alternate disposal method needs to be permitted by the State of West Virginia prior to any disposal to occur at the Wetzel County landfill in New Martinsville, West Virginia.
ProTechnics provided to the NRC a copy of West Virginia regulation, Solid Waste Management Rule, 33 C.S.R. 1A, that became effective on August 1, 2017, as evidence of the permit for disposal of well-logging sandouts and well returns containing residual T. Gadd 2 radioactive materials in West Virginia.
The State of West Virginia regulation is applicable to commercial waste facilities that are permitted to take drill cuttings and drilling waste generated from horizontal oil and gas well sites, but does not include any waste containing radioactive tracers regulated by the NRC unless the generator of the waste has obtained permission from the NRC to dispose of this type of waste in a West Virginia landfill.
By this letter, the NRC is informing you that ProTechnics is permitted to dispose of logging sandouts and well returns containing residual radioactive materials regulated by the NRC at the Wetzel County landfill in New Martinsville, West Virginia, under the terms of NRC License No. 42-26928-01.
In accordance with 10 CFR 2.390 of the NRC's "Agency Rules of Practice and Procedure," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or form the Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/readinq-rm/adams.html.
Please contact Mr. Roberto Torres if you have any questions concerning the above. He can be reached at (817) 200-1189.
Sincerely, L ??r Troy W. Pruett, Director Division of Nuclear Materials Safety Docket No.: 030-30429 License No.: 42-26928-01 Control No.: 609095 and 588388
Enclosure:
Technical Evaluation Report cc: Will C. Williams, Radiation Safety Officer ProTechnics Division of Core Laboratories LP 6510 West Sam Houston Parkway North Houston, TX 77041 Jason R. Frame, Chief Radiation, Toxics and Indoor Air Division Office of Environmental Health Services 350 Capitol Street, Room 313 Charleston, WV 25301-1798 RESPONSE TO TECHNICAL ASSISTANCE REQUEST, DATED AUGUST 5, 2015, FOR THE REVIEW OF THE PROTECHNICS DIVISION OF CORE LABORATORIES' REQUEST FOR APPROVAL OF AN ALTERNATE WASTE DISPOSAL METHOD UNDER 10 CFR 20.2002 Enclosure MEMORANDUM TO: FROM:
SUBJECT:
March 8, 2016 Mark R. Shaffer, Director Division of Nuclear Materials Safety Region IV John R. Tappert, Director IRA/ Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards RESPONSE TO TECHNICAL ASSISTANCE REQUEST, DATED AUGUST 5, 2015, FOR THE REVIEW OF THE PROTECHNICS DIVISION OF CORE LABORATORIES' REQUEST FOR APPROVAL OF AN ALTERNATE WASTE DISPOSAL METHOD UNDER 10 CFR 20.2002 Region IV submitted a Technical Assistance Request (Agencywide Documents Access and Management System (ADAMS) Accession Number ML 15218A608), dated August 5, 2015, requesting a review of the ProTechnics Division of Core Laboratories' (ProTechnics) request for an alternate waste disposal method under 10 CFR 20.2002. The U.S. Nuclear Regulatory Commission (NRC) has previously approved ProTechnics use of two alternate waste disposal methods: 1.) on-site earthen pit burial; and 2.) Class II wells for disposing of well returns containing small concentrations of radioactive tracer material.
ProTechnics is now requesting NRC approval for a third option, disposal of the well returns at the Meadowfill Landfill in Bridgeport, West Virginia.
The NRC staff evaluated ProTechnics' request for a third alternate waste disposal method that considers the placement of well returns containing small concentrations of radioactive materials at the Meadowfill landfill.
Based on a review of the analyses provided by ProTechnics (ML 15211A594), the responses to the request for additional information (ML 15292A061), and the independent analyses discussed in the accompanying Technical Evaluation Report (TER), the NRC staff find this disposal option to be acceptable and in compliance with the regulations in 10 CFR 20.2002. The expected doses are a very small fraction of the public dose limit and lower than calculated doses for other alternates already approved for the licensee.
The expected dose is less than 0.01 mSv/yr (1 mrem/yr) to the average member of the critical group and doses are maintained as low as reasonably achievable.
Region IV will use the information provided in this TER to issue a license amendment to ProTechnics and an exemption letter to Waste Management, owners of the Meadowfill Landfill, CONTACT: Adam L. Schwartzman, NMSS/DUWP (301) 415-8172 M. Shaffer granting them permission to dispose of the well returns without an NRC license. The NMSS staff agreed to include an example exemption letter (ML 15086A427), Enclosure 2, with this response.
Enclosures:
- 1. 2. Technical Evaluation Report Example Exemption Letter
' M. Shaffer granting them permission to dispose of the well returns without an NRC license. The NMSS staff agreed to include an example exemption letter (ML 15086A427), Enclosure 2, with this response.
Enclosures:
- 1. 2. DISTRIBUTION:
Technical Evaluation Report Example Exemption Letter D. Collins, MSTR H. Gonzalez, MSTR ADAMS Accession No.: ML 16041A076 (Pkg.) ML 16020A283 (Memo & TER) ML 15086A427 (Ex.) "'concurred via email OFFICE NMSS NMSS:LA NMSS:BC NMSS:D OGC NMSS NAME A. Schwartzman T. Moon C. McKenney (M. Norato for) S. Clark* A. Schwartzman J. Taooert DATE 1/21/16 2/1/16 1/28/16 2/2/16 2/25/16 3/8/16 OFFICIAL RECORD COPY TECHNICAL EVALUATION REPORT RESPONSE TO TECHNICAL ASSISTANCE REQUEST REGARDING THE PROTECHNICS DIVISION OF CORE LABORATORIES' REQUEST FOR APPROVAL OF AN AL TERNA TE WASTE DISPOSAL METHOD UNDER 10 CFR 20.2002 DOCKET: 030-30429 LICENSEE:
Core Laboratories, Inc. dba ProTechnics Division of Core Labs LICENSE NUMBER: 42-26928-01 BACKGROUND The ProTechnics Division of Core Laboratories (ProTechnics) is a well-logging licensee (Materials License# 42-26928-01) authorized to use unsealed byproduct material during tracer operations.
ProTechnics is currently authorized under conditions of its license to use two alternate waste disposal methods previously approved by the U.S. Nuclear Regulatory Commission (NRC) under 10 CFR 20.2002. On-site earthen pit burial was approved on December 18, 1995 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML 12243A217).
Disposal into Class II wells was approved as a result of the issuance of license amendment 30 on November 4, 2003 (ML033080194).
SUMMARY
OF PREVIOUS EVALUATIONS The NRC and several Agreement States have already evaluated the impacts associated with the disposal of these well returns containing radioactive materials and have included license conditions authorizing the on-site burial of the material in both shallow pits and Class II disposal wells. In December 1995, the NRC staff concluded a "Finding of No Significant Impact (FONSI)" for the generic disposal of this material in on-site burial pits provided specific restrictions are met. A licensing amendment was added to ProTechnics' license for this generic disposal option. Prior to this point, the NRC staff reviewed and approved these disposals on a case-by-case basis. In November 2003, the NRC amended ProTechnics' license to allow the disposal of radioactive material associated with well returns in Class II disposal wells that had been previously approved to accept non-hazardous oil and gas waste by State agencies.
As discussed in the NRC's response to "Core Laboratories' Request to Inject Well-Logging Waste in Class II Disposal Wells" (ML041200730), acceptance of this second disposal option by the NRC staff was based on a combination of NRC policies and stringent construction, operating, and monitoring requirements for Class 11 disposal wells. Use of the Class 11 disposal wells allows for greater control over the waste once it is disposed and limits possible access to the material compared to the previously accepted disposal process of using disposal pits with a soil cover. Additional details related to the use of Class II disposal wells are provided in NUREG/CR-3467, "Environmental Assessment of the Use of Radionuclides as Tracers in the Enhanced Recovery of Oil and Gas." ENCLOSURE 1 PROPOSED ACTION By letter dated June 19, 2015 (ML 15211A594), ProTechnics requested approval for a third alternate disposal method, allowing for the disposal of well returns containing small concentrations of radioactive tracer material (less than 120-day half-life) at the Meadowfill Landfill in Bridgeport, West Virginia.
Contingent on NRC approval and acceptance by the West Virginia Department of Environmental Protection and the West Virginia Department of Health and Human Resources, Waste Management, Inc., the owner and operator of the Meadowfill Landfill, has already agreed to accept the material in cases when on-site earthen pit burial and injection into Class II disposal wells are determined not to be viable options. The need for a third disposal option is due to the fact that some locations where tracer operations are conducted do not allow shallow disposal pits to be used to hold well returns and costs associated with the construction and maintenance of Class II disposal wells, as well as the transport of the well returns to the well sites can be high. As indicated above and emphasized in the submittal, the NRC staff has already acknowledged the low risks associated with the tracer materials through its review and acceptance of on-site burial in shallow burial pits. The NRC staff agrees that disposal in a landfill, which would occur at greater depths and include a deeper cover, would provide additional shielding as well as greater assurances that the tracers would not be prematurely uncovered or handled. As discussed in the submittal, risk and exposure during the transport of tracer material to the Class II disposal wells, which has already been authorized by the NRC, is minimal. Transporting the tracer material to the Meadowfill Landfill, which is closer in proximity, would further minimize risk and exposure to the public. NRC STAFF'S REVIEW AND EVALUATION As part of its tracer operations, ProTechnics injects three radionuclides (Iridium [lr]-192, Scandium [Sc]-46, and Antimony [Sb]-124) into *the wells during hydraulic fracturing activities.
The small increase in radioactivity above background assists well operators in optimizing well operations.
According to the submittal, no more than 37 Bq/g (1000 pCi/g) of radioactive material is injected into a well at any one time. The submittal does not clearly indicate if this 37 Bq/g (1000 pCi/g) concentration is for a single radionuclide or for a combination of all three radionuclides.
As part of its independent analysis the NRC staff considered a combination of all three radionuclides with input concentrations of 37 Bq/g (1000 pCi/g) for each, three times the highest concentration of radioactive material that would be associated with the well returns assuming all of the radionuclides were removed from the well. The manufacturing process for the radioactive tracer, known as ZeroWash, embeds the water soluble radioactive tracer material inside the matrix of a ceramic particle.
As a result, there is minimal to no deleterious effects on the environment from the use of ZeroWash.
According to ProTechnics, internal and external exposure to ZeroWash will be negligible to the public because the material cannot be absorbed through the skin, will not be inhaled, and ingestion of hundreds of pounds of material would be needed in order to reach an Annual Limit of Intake (ALI). The analysis provided with the submittal consisted of a series of mathematical calculations that considered an individual standing directly over a 7 .3 m 2 (78.54 ft: 2) shallow pit containing well return waste to a depth of 0.88 m (2.29 ft) with a 0.61 m (2 ft) cover consisting of clean soil on top. The dose, assuming that an individual stood on top of the disposal pit for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day for 365 days, was calculated to be 0.056 mSv/yr (5.56 mrem/yr).
A similar analysis performed by the NRC staff using RESRAD, Version 6.5, and the same assumptions resulted in a dose of 0.011 mSv/yr (1.1 mrem/yr).
Ultimately the use of realistic parameter values associated with disposal in a landfill, including disposal over larger areas, at greater depths, and with a larger cover, would yield doses that are even less significant.
Considering the characteristics of the Zero Wash and the short half-lives of the associated radionuclides, the NRC staff performed a second analysis to evaluate the impacts to the dose associated with the disposal of the well returns in a landfill.
In this scenario, the waste is assumed to be spread over a larger area and a deeper cover would be installed.
The NRC staff assumed that the same volume of well return material considered in the submittal, 6.4 m 3 (227ft3), was distributed over a larger area within the landfill (10 m 2 or 33 ft 2) to a depth of 0.64 m (2.1 ft) and covered with a 2 meter (6.6 feet) deep cover. The same exposure pathways were considered for the landfill worker. This scenario resulted in a peak dose of 6E-10 mSv/yr (6E-8 mrem/yr).
Table 1 compares the RESRAD input parameter values and resulting doses for the two scenarios e'(aluated by the NRC staff. Table 1. Comparison of RESRAD parameter values and resulting doses calculated by the NRC staff using RESRAD, Version 6.5 8 Parameter Burial Pit Analysis Exposure Pathways External Gamma Radionuclides Contaminant area (m 2) Contaminant depth (m) lr-192 Sc-46 Sb-124 Length parallel to aquifer flow (m) Cover depth (m) Ingestion Inhalation 1000 pCi/g 1000 pCi/g 1000 pCi/g 7.3 m 2 0.9m 2.7m 0.61 m Doseb 1 .1 E-02 mSv/yr a Default values were used for the remaining RESRAD parameters b Multiply mSv/yr by 100 to get mrem/yr FINDINGS Landfill Analysis External Gamma Ingestion Inhalation 1000 pCi/g 1000 pCi/g 1000 pCi/g 10 m 2 0.64 m 3.64 m 2m 6E-10 mSv/yr The NRC staff evaluated ProTechnics' request for a third alternate waste disposal method that considers the placement of well returns containing small concentrations of radioactive materials at the Meadowfill Landfill.
Based on a review of the analyses provided by ProTechnics and the independent analyses discussed above, the NRC staff finds this disposal option to be acceptable and in compliance with the regulations in 10 CFR 20.2002. The expected doses are a very small fraction of the public dose limit and lower than calculated doses for other alternates already approved for the licensee.
The expected dose is less than 0.01 mSv/yr (1 mrem/yr) to the average member of the critical group and the proposed disposal method would keep doses as low as reasonably achievable.