ML20057B729
| ML20057B729 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/1993 |
| From: | Combs F NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Joseph Austin NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20055C211 | List: |
| References | |
| FOIA-93-115 NUDOCS 9309230191 | |
| Download: ML20057B729 (2) | |
Text
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UNITED STATES
,a NUCLEAR REGULATORY COMMISSION, 4-V WASHINGTON, D. C. 20655 e
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HAR 191993 MEM0PANDUM FOR:
' John H. Austin, Chief Decommissioning and Regulatory _
's Issues Branch, LLWM i
FROM:
Frederick C. Combs, Chief Operations Branch, IMNS
SUBJECT:
QUESTION FROM NORTHEAST OHIO REGIONAL SEWER DISTRICT We have reviewed the February 22, 1993, letter from Thomas Lenhart--to Mr. Bangart that requested an interpretation on how 10 CFR 20.2003 applies to releases of cobalt-60. As with any interpretation, your response should go through OGC. However, our reading of 10 CFR 20.2003 is that releases of cobalt-60 are permissible under that section if all of the provisions are met.
The provisions are as follows.
1.
The cobalt-60 must be in a form readily soluble in water, or in readily dispersible biological material (usually ground animal carcasses). With regard to_ being readily soluble in water, the NRC has not established criteria for determining when a material has~ dissolved. We have asked ^
RES to address this issue (see memo from Bangart to Beckjord dated 2/25/93).
In the Statements of Consideration for the revised Part 20, the Commission expressed its intent to prohibit releases of radioactive materials that could be reconcentrated in sewage treatment systems.
With regard to_ readily dispersible biological material, we are not-aware of any animal research applications that use cobalt-60. However, if research activities' produced animal carcasses contaminated with cobalt-60, grinding the tissue into a readily dispersible form would satisfy this provision.
2.
The average monthly concentration of cobalt-60 in discharges to _the sanitary sewer must not exceed the concentration listed in Table 3 of i
Appendix B to Part 20. The Statements of Consideration for revised Part 20 state that the " prohibition for insoluble materials is the reason
.there are no values listed for insoluble materials in Table 3 of Tame 3 lists no acceptable concentration for cobalt-60 in t aride, hydroxide, halide, or nitrate. Therefore, rel S-44 in any of these forms is prohibited. We suggest tha what form of cobalt-60 is authorized by the AMS lic describe.this in the letter back to Mr. Lenhart.
3 r-3.
If other radionuclides are released with the cobalt-60, the sum of the 2
fractions for each radionuclide must not exceed one (i.e., unity).
4.
The total quantity of cobalt-60 released in a year combined with all i
other radioactive materials released (except for H-3 and C-14) must not i
exceed I curie (37 GBq).
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s John H. Austin If all of these provisions are satisfied, the release of cobalt-60 into a sanitary sewer system would be permissible under section 20.2003.
In addition, if the cobalt-60 is in excreta from individuals undergoing medical diagnosis or therapy, the release of contaminated excreta to the sanitary sewer is not subject to any of the limitations listed above. However, the use of cobalt-60 in medical treatments that would produce contaminated excreta is extremely rare and we do not expect such releases to be a significant concern.
If you have any questions, please contact Kevin Ramsey at 504-2534.
Original Signed Bv
- 6. Pan bkrn hrFrederick Combs, Chief Operations Branch, IMNS DISTRIBUTION:
IHOB r/f IMNS r/f NMSS r/f Sam Nalluswami Tim Johnson
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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'.'AR 2 2 G93 Docket No.:
030-18276 License No.:
34-17726-02 (Not a licensed facility for Co-60)
MEMORANDUM FOR:
John H. Austin, Chief Decomissioning and Regulatory Issues Branch Division of low-level Waste Management and Decomissioning, NMSS THROUGH:
Timothy C. Johnson, Section Leader Decomissioning and Regulatory Issues Branch Division of low-level Waste Management and Decommissioning, NHSS FROM:
M. (Sam) Nalluswami, Project Manager he d '
Materials Decomissioning Section M
Decomissioning and Regulatory Issues Branch Division of low-level Vaste Management and Decomissioning, NMSS
SUBJECT:
SUMMARY
OF THE MEETING BETWEEN NORTHEAST OHIO REGIONAL SEWER DISTRICT / SOUTHERLY PLANT (NE0RSD/SP) STAFF AND NRC STAFF DATE & TIME:
Wednesday, January 27, 1993 - 9:30 a.m.
LOCATION:
One White Flint North 11555 Rockville Pike, Room 6813 Rockville, MD 20852 Sumary:
This is the sumary of the discussions during the meeting between NE0RSD/SP staff and the Nuclear Regulatory Comission staff on January 27, 1993, in Rockville, Maryland.
The following participated in the meeting:
Nuclear Reculaton Northeast Ohio Reaional Sewer District!
Comission Southerly Plant (NE0RSD/SP)
Richard Bangart Erwin Odeal Bill Brach Bill Schatz John Austin Tom Lenhart Tim Johnson Richard Connelly Robert Fonner Barry Koh Sam Halluswami Ted Adams Tony Huffert Don Sreniawski, RIII Mike McCann, RIII
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MAR 2 : m3 2
Spillace on January 25. 1993 The meeting started with a discussion on the spillage of ash slurry over the banks of the lagoons on January 25, 1993. Survey measurements taken indicated that exposure rates were at background levels.
The matter was reported to the Ohio Environmental Protection Agency (0 EPA). The Ohio Department of Health (ODH) staff from the Northeast Ohio Regional Office visited on January 26, 1993, and collected soil samples.
The results were not available as of January 27, 1993.
NRC Region III staff mentioned that they will collect soil samples and perform independent verification of the radioactive concentration.
Lagoon Cleanina and Remediation Plan Schedules Submitted on Dec. 2 & 30. 1992 The NE0RSD/SP staff expressed concern regarding the longer than expected review time requested by NRC staff at various stages.
Tim Johnson mentioned that if the review of verification survey data is not done properly and the lagoons are put back into operation prematurely, then there may be a risk that additional remediation may be needed and additional expenses may be incurred.
The principal concerns related to the review of the verification survey data and the time to complete a confirmation survey report. NE0RSD/SP staff stated that they needed the use of at least one pond by early summer of 1993 to maintain sewage treatment.
R. Bangart indicated that NRC will do what is necessary to ensure that plant operations will not be affected.
O eration and Radiological Control Plans J
The operation and radiological control plans were submitted on January 11, 1993.
It was agreed that the review comments will be completed approximately within a month and can be directly provided to Barry Koh and Ted Adams.
Estimation of cobalt-60 The NRC Region III staff is developing an estimate of the total Co-60 in the sludge material, based on ORISE data. NE0RSD/SP staff asked if there was sufficient information to develop this estimate.
So far, the estimates are based on partial surveys, and other factors. NRC staff indicated that the objective of the estimate would be to obtain a general value to describe the extent of contamination. NE0RSD/SP staff wanted a very thorough estimate to help them address who was responsible for the contamination.
Richard Bangart mentioned that for NRC dose assessment evaluations the total activity is secondary and concentration is critical. '
Advanced Medical Systems (AMSl NRC Region III is working on a report regarding potential releases of Co-60 by AMS to sanitary sewers in excess of NRC limits. Region III and OGC will review the document before releasing it.
It was mentioned that the report will be available before the next meeting. NE0RSD/SP staff indicated that they wanted this information by the end of March 1993 to ensure that, if a suit was filed, it could be filed within the time set out in local statutes of limitations.
They indicated that they had a two year period to take legal action from the date they were notified of the contamination. NE0RSD/SP staff
3 MAR 2 2 W were critical of NRC's practices for allowing effluent releases and stated that they were discussing this issue with other sewage treatment operators.
Options for Reculatory Control A question was asked whether to extend the Advanced Medical Systems (AMS) license to NE0RSD/SP. NE0RSD/SP indicated that they do not want to become a licensee and they want NRC to participate financially in the remediation.
NE0RSD/SP staff suggested that NRC staff consider two possibilities to avoid licensing the site:
J
- extend AMS license to NE0RSD/SP
- agree upon conditions under which NE0RSD/SP does not need a license Robert Fonner declined to provide a legal opinion on these options without further consideration.
Whether Cleveland Sewer Lines are Contaminated NE0RSD/SP staff indicated a concern that the sewer lines might contain contamination.
NRC staff indicated that ORAU had performed surveys in the city sewer lines and had found no contamination.
Further Action There will be a meeting after March 1,1993, that will address further issues and developments.
C:is :.i cc:
Ms. C. Trepal, Earth Day Coalition, Cleveland g %//,,md Ms. J. McCourt, Senator Metzenbaum's Office, Washington Mr. T. Brady, Cuyahoga County Board of Health l
Mr. R. Owen, Ohio Dept. of Health Mr. R. Beals, Ohio Env. Prot. Agency Mr. E. Odeal, Northeast Ohio Sewer District l
Mr. W. Schatz, Northeast Ohio Sewer District Mr. T. Lenhart, Northeast Ohio Sewer District Mr. R. Connelly, Northeast Ohio Sewer District Mr. B. Koh, B. Koh & Associates Mr. T. Adams, B. Koh & Associates DISTRIBUTION: Central File LLWM r/f RBangart WBrach THuffert PLohaus i
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Category:
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