ML20086D965

Advises That Util Intends to Bury Polychlorinated Biphenyl Sediments,Containing Low Levels of Radioactivity,Onsite.Util Will Pursue NRC Approval Per 10CFR20.302.Requests Concurrence Re Disposal of Matl

ML20086D965
Person / Time
Site:	Sequoyah
Issue date:	11/13/1991
From:	Mcarthur W TENNESSEE VALLEY AUTHORITY
To:	Jeanne Johnston ENVIRONMENTAL PROTECTION AGENCY
References
NUDOCS 9111270008
Download: ML20086D965 (2)

Text

- _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _

4 o

A Tennewe vavy Aen,iy om une se cunwwa ten,mee v4c November 13, 1991 Mr. Jon Johnston Title III and Toxics Section Chief Unites States Environmental Protection Agency 345 Courtland Street, NE Atlanta, Georgia 30365

Dear Mr. Johnston:

SEQUOYAH NUCLEAR PLANT (SON) - FACILITY IDENTIFICATION NUMBER TN5640020504 - POLYCHLORINATED BIPHENYLS (PCB) CLEANUP OF THE LOW VOLUME WASTE TREATMENT POND (LVWTP)

The cleanup of PCB sediments from the LVWTP at our SQN plant was completed on September 6, 1991, in accordance with our November 20, 1989 letter to Robert Stryker. A portion of these sediments were found to contain low levels of radioactivity, with a concomitant PCB concentration of 3.8 parts per million (ppm). prohibiting disposal solely as PCB wastes. TVA proposes to de::lare this material non-PCB and dispose of it as radioactive waste.

It was necessary to remove more sediments than originally anticipated in our November 20 letter. A total of approximately 360 cubic yards of sediment was removed. The final phase of cleanup resulted in approximately 60 cubic yards of sediment which remain piled onsite for disposal. Seven core samples taken from the sediment pile were analyzed for radioactivity and, subsequently, PCB concentrations. Isotopic analyses of the seven individual core samples revealed maximum, minimum, and average Cobalt 60 concentrations of 0.7, 0.2 and 0.45 pico-curies per gram, respectively. A composite of the seven core samples had a PCB concentration of 3.8 ppm. The enclosure describes the compositing procedure. Prior to removal, in situ sampling of the area from which this sediment was extracted revealed PCB concentrations ranging from less than 1 ppm up to 69 ppm. Because the above levels of radioactivity were detected, this material must be treated as radioactive waste.

Our obvious dilemma is disposal of this material. To our knowledge, the only disposal facility which can accept such a waste mixture is the Department of Energy (DOE) facility in Oak Ridge, Tennessee. However, this facility has such a backlog of material for disposal that it is unwilling to accept wastes from sources other than DOE facilities.

4111270003 911112 pna p

ADocK 05000327 ran

,p I

j i l h

e e

9 2

Mr. Jon Johnston November 13, 1991 TVA proposes to dispose of this material as radioactive waste in a manner approved by the Nuclear Regulatory Comraission (NRC). Specifically, TVA intends to pursue NRC approval under 10 CFR 20.302 to bury this material on the SQN site. TVA believes this to be appropriate action based upon the overall PCB concentration exhibited by the material in question, the relative inaobility of the PCB in this predominantly clay medium, and the fact that preenutions utilized to protect the public from the radioactive component of this waste will be entirely sufficient protection from the de minimus level of PCB present.

TVA requests your concurrence with disposal of this material as non-PCB waste. If you require additional information to assict in your '

evaluation of our request, pleasu contact Jim Mantooth of my staff at (615) 751-4033 in Chattanooga, Tennessee.

Sincerely,

? .

. . - L6  %

W. C. McArthur Manager Technical Programs Enclosure cc: Ms. Nancy Redgate United States Environmental Protection Agency Region IV Toxics Section

'345 Courtland Street Atlanta, Georgia 30365 Mr. Phillip Stewart, Manager Chattanooga Field Office Division of Water Pollution Control Tennessee Department of Environment and Conservation 2501 Milne Street Chattanooga, Tennessee 37406-3399 yt.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _