ML20028F817
| ML20028F817 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 01/21/1983 |
| From: | Kirk W UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 21838, NIS-83-01-22, NIS-83-1-22, NUDOCS 8302040447 | |
| Download: ML20028F817 (9) | |
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UDC RRVAL PRODUCTS 70- 3 W
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A unc assouaces company unc In Reply, Please Refer co To: NIS 83-01-22 h
?[Ob' January 21, 1983 Mr. Richard E. Cunningham, Director JAH 2 4 h
Division of Fuel Cycle and
" **8$7 Y Material Safety, NMSS
(
e U. S. Nuclear Regulatory Commission u ~d Washington, D. C. 20555
Subject:
Docket 70-371 SNM License #368 Environmental Sampling for Non-radioactive Materials
References:
(1)
Letter R. E. Cunningham to W. F. Kirk Dated January 14, 1983 (2)
Letter W. F. Kirk to R. G. Page Dated December 1,1982 (3)
Letter R. G. Page to W. F. Kirk Dated November 24, 1982 (4)
Letter W. F. Kirk to R. G. Page Dated February 26, 1982 (5) Letter R. G. Page to W. F. Kirk Dated December 15, 1981 (6)
Letter W. i. Kirk to R. G. Page Dated April 30, 1981
Dear Sir:
With respect to your coments on items 1 of ref. (1) titled " Environmental Sampling for Nonradioactive Materials". As you noted, ref. (5) requested:
"----The rationale for discontinuing the NRC monitoring requirements.
The rationale should include past monitoring data and/or approval from appropriate state and federal authorities for discharging non-radiological effluents."
We consider that when the words"and/or" are used, it gives the option of submitting either one or both types oT infonnation requested.
We chose to reply by directing the attention of your personnel to the "/or_
approval from appropriate state and federal authorities for discharging non-radiological effluents" by stating our rationale and denoting our
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- The rationale was that we are currently-subject to Connecticut DEP regulations for facility effluent and discharge control and not to the NRC.
The pennits for the discharges were listed in both ref. (2) and ref. (4).
The most important pemits were for water discharge (DEP/WRC-086-008)and for discharge to the septic system (DEP/WRC-086-020 and DEP/RCU-81-295).
1.
Copies of WRC-086-008 and the requested increase in discharge to 250,000 gallon per day were previously supplied to the AEC in the original environmental reports of 1972-73.
(See Attachment 12.1-4b and12.1-4a). The AEC Environmental. Impact Appraisal dated January 30, 1974 recognized these documents as shown in Table 1 of that report which is attached to this letter. Although there has been some additional comunication with the DEP, no additional pennics have been issued.
2.
The septic system remains as stated in the AEC Environmental Impact Appraisal Table I attached and sup(ported by documentation previously(Se supplied, to the AEC in 1972-73, the expansion of the septic field in 1979 as approved by Attachment I (Letter S.J Pac,DEP to J. L. Lawrence,UNC Dated February 29,1979) 3.
DEP/RCU-81-295 is applicable to radioactive discharges and was listed J
in error.
I consider that we have been straightforward in answering the requests of your personnel, exercising the option given to us in their letters, in addressing the request for infomation concerning " Environmental Sampling for Nonradioactive Materials". Should they now want past monitoring data i
l in addition to pemit infomation, we will supply it upon a clear request.
With respect to item 5 of ref. (1) titled "DeMinimus Uranium Release Concentrations", we are dropping further pursuit of this item by off site l
burning. We now hope to resolve disposition of this material by filtration i
or burial.
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Please reconsider the position stated in your 1etter"of ' January 14, 1983 - ~
with respect to item.1 of our ref. (6) submission.
We do not believe that a hearing is a cost effective way of resolving this subject. However if this method is the only path open to us under the current request (ref. (6))' please r.otify me promptly so that we may i
proceed accordingly.
i Very truly yours 8
U W. F. Kirk, Manager Nuclear & Industrial Safety
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1-2 Table 1 List of Regulatory Approvsis and Permits Government Agency Purpose of~ Contact Outcome Atomic Energy Com-Request exemption from the provisions Exemption mission (Regula-of 70.21(f) and 70.23(a)(7) of Title granted tory) 10 CFR Part 70 so that construction could compence Atomic Energy Com-Special Nuclear Material license for License SNM-mission (Regula-possession and use of special nuclear 368 issued tory)
Feb. 28, 1969 material Atomic Energy Com-Application to operate Building A License SNM-mission (Regula-without the discharFe of liquid 368 amended.
l tory) effluents Amend. No. 17 June 26,1973 C
Atomic Energy Com-Application to operate Building A LicenseSliM-7,$.;
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mission (Regula-with the discharge of liquid 368 amended, l
tory) effluents Amend. No. 19 Sept. 26, 1973 At@mic Energy Com-Application to perform limited License SNM-mission (Regula-operations in Building B 368 amended,
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tory)
Amend. No. 22 Nov. 9, 1973 Connecticut State Applied for a permit to discharge.
A five year Water Respurces 60,000. gallons per day of water to permit granted i
Co= mission the ground adjacent to the facility (Attachment 12.1-4b)
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Connecticut State Applied for a permit t'o increase dis-Initial approval Water Resources charge of water from 60,000 gallons per granted. Final Comsission day to 250,000 gallons per day approval after installation (Attachment 12.1-4a)
State of Connecti-Registration of sources of ionizing Completed Jan.
cut, Dept. of radiation 1973 Environmental Protection State of Connecti-Request for approval of sewage dis.
Approval granted cut, Dept. of posal system (Attachment 12.1-7)
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State of Connecti-Request for approval of elevators Initial approval cut, Labor Dept.
granted. Final approval after installation.
,'fovn of Montville, Zoning permit for buildings and Permits granted Dept. of Public sewerage disposal facility Works
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i Atta:hment 12.1 14b yg..
. gg STATE OF CONN ECTICUT Y A TER RESOURCES COMMisslos
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STATE OFFICE DitttEING e
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1;g2 PERMIT j
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P.O. Box 1883 New Haven, Connecticut 06508 g;,
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......g Re: WRC-086-008 Town of Montville Thames River Watershed
_,, _ Attention: Mr. D. F. Gronin, Manager o
Nuclear & Industrial Safety Naval Products Division
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Gentlemen:
United Nuclear Corporation has applied for a PERMIT to discharge 60,000 gallons per day of cooling water to the groundwaters in the watershed of the Thames River without treatment.
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The Water Resources Comnission finds ~ that such discharge will not cause
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pollution of the waters of the state and therefore this letter shall be con-sidered as the PERMIT required by Section 25-541 of Chapter 464a of the 1967 Supplement to the General Statutes and is issued with the following provisions:
- 1) That this PERMIT shall be subject to the provision of Sec-tion 25-54j of Chapter 474a of the 1967 Supplement to the General Statutes.
- 2) That this PERMIT shall expire five (5) years frota the date of issuance.
- 3) That this PERMIT may be renewable for like periods in accor-l dance with procedures and requirements established by the water Resources Commission.
Very truly yours, e
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fohn J' Ourry
{ / Dir,ector
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ATTACIMENT 12.81-4n
'.g9 STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION P
STAn Omcz Buitmwc HAanoan, con 8tencur 06115 o
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May '4, 19 7'g g Mr. D. F. Cronin
- '" ' ',2 Manager Nuclear & Industry Safety '
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365 Winchester Avenue New Haven, Connecticut m _.r'
Dear Mr. Cronin:
( _,~..-... I The Deputy Commissioner of Environmental Protection, Environmental Quality Division, following review oT the transcript and the report, finding of fact and recommendation of the hearing examiner on your 7
application for a permit to discharge 250,000 gallons per day of process waters subdivided as shown below to the groundwaters in the-.
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watershed of the Thames River in the Town of Montville, concurred, in a decision dated May 2, 1973, with the finding of fact and recommendations which are as follows:
FINDING OF FACT 1.
The total estimated flow of 250,000 gallons per day is
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subdivided as follows:
b) sanitary sewage - 28,000 gallons per day a
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cooling and process - 218,000 gallons per day d) radwaste - 4,000 gallons per day c
J octergent - a few hundred gallons per week 2.
Cooling and process waters will be discharged to a seepage lagoon located approximately 1800 feet from the Thames River.
Anticipated quality is slightly purer then the municipal water supply and temperature will normally be ambient, but may reach 125 F.
It 0
is anticipated that if there should be an overflow from the lagoon, such overflow will seep into the ground within a few hundred feet.
3.
The septic tank system, which has been approved by health authorities and installed, will receive sanitary sewage, treated radwaste and probably detergent.
4.
Solvents used in degreasing will be reclaimed.
5.
An extensive monitoring program will be employed.
6.
Depending on accumulated amounts of rad solids, septic tank cleanings will be disposed of at a Federal approved burial area or in a conventional manner.
ATTACM:EST 12.1 La Mr. D. F. Cronin May 5, 1973 7.
Spent resins will be disposed of at a Federal approved burial area or transported to a fuels recovery plant "to reclaim uranium concentrations if recovery is economical.
8.
Uranium-containing samples processed in the laboratory will be recovered for uranium values and not discharged.
9.
The discharge of liquid effluent from the radwaste system into the subsurface septic system is interp(in this case t1e groundwater). 'reted, for purposes of as a discharge to unrestricted areas Therefore, the limiting criteria which apply are prescribed in Table II, Appendix B, Part 20 of Title 10 - Code of Federal Regulations.
Criteria (concentrations in Table I) for re3 ease into a sanitary sewerage system do not apply.
This interpretation is presumed.to be in accord with that of the Federal agency having regulatory jurisdiction and, if not, the Department of Environmental Protection would expect to be informed.
Additional restrictions or limiting criteria which may be prescribed in technical specifications for the facility or by standards established by the contracting Federal agency will of course apply.
The Department's Administrative Regulations on Radiation Sources and
, TnRadioactive Materials are applicable.
Attention is particularly directed --
-^ ' to ' Sections 19-13-E47 and 19-13-E54(f) which require surveys and record's
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of waste disposal.
c 10.
As the septic tank system will receive significant amounts of l
wastewater in addition to sanitary sewage, plans and specifications l
must be submitted for review and approval.
RECOMENDATIONS It is recommended that the discharges _be authorized on tie basis
~~on 'the proposed types of treatment and disposal, that the staff be authorized to review and approve construction plans and specifications, and that the permits be issued with the specified statutory conditions, when the facilities are installed in full compliance with the~ approval thereof.
Testimony at the hearing indicated that the septic tank system has A
been installed and the seepage lagoon is under constructica, therefore, plans and specifications for all treatment and disposal systems should te submitted to this Department for review and approval at the earliest possible date.
Under the applicable statute, our authorization should be received before construction is commenced.
You will note in the recommendation that the necessary permits'will be issued when all facilities have been installed in compliance with approved plans and specifications.
Very truly yours, fx Merwin E. Hupfer,
Director MEH/am Water Compliance
.g I-Q CONNECTICUT STATF DEPAltTMENT OF. HEALTH u
ATTACHMENT 12.1-7 Septenber 19, 1972
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R C$fp D Mr. Ecvard Beethan, Jr.
First Select =n of Montvilla Tovn aan f
gEP25 Montville, Connecticut 06330 2
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Dear Mr. Beethmn:
- /tt, Ve have reviewed revised pinns for the c-M sewage ' posal system for the proposed ncy industrin1 cad or** t 'bui ng for.'
United nuclear Corporation, Montvilla,
_u _._c___._ Thece plans were preptred by FLAM'ff4.
T 1 O n Incorporated, consulting
- casineers, and cutaitted to tygi, p. ant to Section 19-13-320c of the
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Public Henith Code.
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letter of Septe$.behh_52. khh founk~E b7sEti$ facto 2h~as E cc-
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cozf.n=c vith the r,/ uire=cW oPfe Public Ecalth Code.
It is recocoended that they be apprq.pd. Hovf.fr, it is recerended that the location of the "T" which divides y sevacA Actveen the two icaching fields be coved to the ares betveen the 1 das so that the une may serve as a relief line in the event of overli of either field.
If you have r.ny gaestions,- please contact us.
Sincerely yours, Thaodore C. Yinerford Principal Sanitary En61 seer Envirorestal Health Services 7117.
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cc: Southcastern Re2;ional Office SEP 26 '72 PM l
2 State Dept. of Enviro = ental Protection I
Water Cocplinace Sect., Atta:
Mr. Grunican
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78-093 Attachment I j h
STATE OF CONNECTICUT
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Tidt DEPARTM ENT OF ENVIRONM ENTAL PR OTECTION 2
STATE OFFICE BUl!. DING HARTFORD, CONNECTICUT 06115 February 29, 1979 APPROVAL United Nuclcar Corporation 67 Sandy Desert Road Uncasville, Connecticut 06382 Attention:
Mr. John V. Lawrence Ret DEP/WPC-086-020
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Town of Montville I
Thames River Watershed Gentlemen:
United Nuclear Corporation is hereby authorized to. install scw'ers,
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l's; septic tank pump station, leaching field and appurtenances for the treat-ment of an average flow of 8360 gallons per day of sanitary sewage prior to being discharged to the groundwaters of the watershed of the Thames River in accordance with plans and specifications prepared by John V.
' Lawrence, P.E. and filed with this Department on September 11, 1978.
The applicant's attention is directed to the requirements of' Section
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25-54i of the Connecticut General Statutes as amended that a PERMIT must be obtained before initiation of a discharge.. Upon.verifi. cation that:
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the' facilities hereby approved have been constructed in accordance with- -
the plans and specifications submitted, said PERMIT shall be issued.
This APPROVAL is the notification required b[ Section 25-54i of, the Connecticut General Statutes a amended.
This Approval does not relieve the divharger of the obligation to obtain any other authorizations as may be
.: quired by other provisions
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of the Connecticut General Statutes, or regulations of Connecticut State Agencies.
Sincerely yours, Ou Stanley. Pac COMMISSI NER SJP:RCH:jmr f
cca John V. Lawrence State Tax Department 6
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