ML20126H744
| ML20126H744 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20126H305 | List: |
| References | |
| FOIA-85-210 2800-5, NUDOCS 8506180435 | |
| Download: ML20126H744 (2) | |
Text
- - - - . .. . - - ~ _ _ = - - - - -_ - - . -
~
)
DQASIP TEMPORARY INSTRUCTION 2800/5
,i
, RECONCENTRATION OF RADIONUCLIDES IN SANITARY SEWERAGE SYSTEMS 1
2800/5-01 PURPOSE This temporary instruction (TI) specifies requirements for inspecting a
- specific set of licensees to determine if there is a problem with reconcen-
> tration of radionuclides at sewerage treatment plants. The list of licen-sees below was provided by NMSS as having a potential for radionuclide i reconcentration in sanitary sewerage systems.
I
- 2800/5-02 OBJECTIVE
' To expedite inspections of certain licensees with a potential for reconcen.-
tration of radionuclides in sewerage systems. The regions should also be sensitive to this issue during routine inspections of other licensees if l they have reason to believe that a potential for reconcentration may exist.
, 2800/5-03 LICENSEES TO INSPECT Following is a list of licensees that NMSS believes have a real potential for releasing radionuclides into sanitary sewerage systems that later reconcentrate at sewerage treatments plants. The list may not be all inclusive and, except for one, does not involve americium-241.
Large Manufacturers Large Institutions with Broad Licenses New England Nuclear Harvard University l Gamma Diagnostics Dept. of the Army - Fort Detrick
- Monsanto Chemical National Institutes of Health l Mallinckrodt Corporation I
3 M Comany Other .
Abbott Laboratories Amersham in Illinois - AM-241
- Advanced Medical Systems (does not make' foils but sometimes Minneapolis Honeywell cuts them out) 2800/5-04 PROGRAM Prior to July 31, 1985, the regions should inspect each named licensee to i
determine whether a reconcengation problem exists. The special inspection should include the taking of actual samples of sludge at the licensees'
- i. holdup tanks for analysis and, if practicable, a survey should be made of
! g 61 g 5 85041I Issue Date: 11/27/84 j WELDON85-210 PDM
..-a. --.
- ? .
~
RECONCENTRATION OF RADIO-
_ 2800/5-04 NUCLIDES IN SANITARY SEWERAGE SYSTEMS licensees' sewer lines where the material is actually dumped. If contami-nation is found in the sludge or sewer lines at the licensee's facilities, reasonable efforts should be made to conduct a survey and take samples for analysis at the nearest sewerage treatment plant. If a problem is found, the Safeguards and Materials Programs Branch (SMPB), IE, should be notified promptly. A short written report showing the results of analyses, even if negative, should be sent to SMPB. The report should include a summary page showing the name and license number of the licensee and locations where samples were obtained. The report can be the report of the inspection if it contains the results of sanple analysis.
2800/5-05 EXPIRATION This TI will remain in effect through July 31, 1985.
2800/5-06 IE CONTACT Questions regarding this TI should be addressed to J. R. Metzger, SMP8.
Telephone (301) 492-4947.
2800/5-07 PRIORITY The inspections requested in this TI have a high priority and should be done as soon as practicable with consideration given to other high priority inspection work. The list of licensees in 2800/5-03 are mostly all high priority licensees and a complete inspection may be done while implementing the provisions of this TI.
END Issue Date: 11/27/84 2
_ _ - _ _ _ _ - ~ _ _ _ _. _ - - - _ _ _ - _ _ _ _ _ _ - - _ _ _ -_ . _ _
SSINS No. 6835 IN 84-94 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, DC 20555 December 21, 1984 IE INFORMATION NOTICE NO. 84-94: RECONCENTRATION OF RADIONUCLIOES INVOLVING DISCHARGES INTO SANITARY SEWAGE SYSTEMS PERMITTED UNDER 10 CFR 20.303 Addressees:
All NRC materials licensees other than licensees that use sealed sources only.
Purpose:
This information notice is provided to alert recipien,ts cf a potentially signi-ficant problem involving reconcentration of radionuclides released to sanitary sewage systems. It is expected that recipients will review the information for applicability to their facilities and consider actions, if appropriate, to pre-clude a similar problem occurring at their facilities. However, suggestions contained in this information notice do not constitute NRC requirements; there-fore, no specific action or written response is required. -
Description of Circumstances:
Three recent occurrences have pointed out the need to focus attention on the possible reconcentration of radionuclides that are discharged into sanitary sewage systems under the provisions of 10 CFR 20.303. In these occurrences,
. radioactive contamination was found in sewer lines and in the municipal sewage treatment facility.
During a routine radiation survey, Oak Ridge Associated Universities found radioactive contamination in the sludge from the sewage treatment facility in Oak Ridge, Tennessee. The principal contaminant was cobalt-60 (Co-60). The State of Tennessee traced the apparent source of the contamination to a State licensee who occasionally discharged a few thousand gallons per day of liquid into the sanitary system at concentrations of 66-110 dpm/ml of Co-60. Although the discharge from the licensee's facility was mixed with 4 to 5 million gallons of liquid from other sources in the city, concentrations of 20,000-200,000 dpm/Kg were measured in the sludge from the treatment facility. Sludge had been used to fertilize a Department of Energy reforested area with the result that radiation levels 2 to 3 times background were measured there (about 10 pR/hr). As a result of the discovery of the problem, the licensee has installed an improved filtration and ion exchange system.
'V 04/d 1 Omo iIV I / yqJ ~ $gp
t .
IN 84-94 December 21, 1984 l
- . Page 2 of 3 l l
In the second occurrence, americium-241 (Am-241) contamination was found in ash l that remained in an incinerator used as a final treatment step at the Tonawanda, New York sewage treatment plant and in ash disposed of at the Tonawanda landfill.
About 10,000 tons of ash containing about 500 picocuries per gram of ash has been disposed of at the landfill. About 30 tons of contaminated ash currently remain in the sewage treatment plant incinerator and in ancillary equipment.
The contamination resulted from liquid releases made to the sanitary sewage ,
system by a New York Agreement State licensee who formerly manufactured Am-241 '
foils at its Tonawanda facility. The licensee has since relocated its foil manufacturing operation to Mexico. Some decontamination of the licensee's Tonawanda facility was undertaken following the move.
The homes, . clothes, or cars of four former licensee employees were found to be contaminated. Because.of exposure to airborne dust at the sewage treatment plant, six plant workers received whole-body counting to examine the potential for internal depositicn. Two of the six were among 58 plant workers who received lung scans. No uptake of Am-241 was detected. Several issues remain to be resolved. These involve disposal of the contaminated ash at the sewage treatment plant, dealing with contaminated ash disposed to the landfill before identification of the contamination problem, decontamination of the sewer lines, and decontamination of the licensee's facility.
In a third occurrence, Am-241 contamination also was found in sludge at a sewage treatment plant in Grand Island, New York. The contamination resulted from liquid releases made to the sanitary sewage system by another New York
, Agreement State licensee also engaged in the manufacture of An-241 foils. The
! measured concentration in the sludge was about 100 picocuries per gram of
. sludge dry weight. (For purposes of comparison, if this sludge were incinerated, concentrations of about 500 picocuries per gram would result in the ash produced.)
- In this case, however, the sludge is disposed directly to a local sanitary i landfill.
4
- The NRC regulation 10 CFR 20.303 permits discharges of small quantities of
! radionuclides into sanitary sewage systems within the limits specified in that I section provided that the materials "are readily soluble or dispersible in wate r. " Licensees who rely on this section have the burden of demonstrating l that the materials they are discharging are indeed readily soluble or dispersible.
- The term "dispersible" may have caused introduction of substances into sanitary sewerage systems that do not qualify as readily dispersible, such as liquid
- scintillation media and ash. Ash is a special case, which may or may not be l "readily dispersible" depending on its degree of comminution and tendency to agglomeration. In order to detect and correct any reconcentration problems involving NRC licensees, inspectors will pay particular attention to the possibility of reconcentration of radionuclides during their inspections of licensees who discharge materials into sanitary sewage systems.
f i
l
-.,._,..-,____,-,._,_.----,-,,m_ _.-__ - . - .-.~. ,_._ _ _ _ . ._ , ,. - . - - , - -
IN 84-94 December 21, 1984 Page 3 of 3 No specific action or written re'sponse is required by this information notice.
If you have any questions about.this matter, please contact the Regional Administrator of the appropriate NRC regional office, or this office.
cp, -
J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs
- Office of Inspection and Enforcement Technical
Contact:
L. I. Cobb (301) 492-4935
Attachment:
List of Recently Issued IE Information Notices k
4 4
- - - , - , - - - - - - - - , , , , . - - . , - - - - , - - - , - - - - - - - - - - -- ~
- - , ~ -- , - -
- ~
Attachment IN 84-94
. December 21, 1984 LIST OF RECENTLY ISSUED IE INFORMATION NOTICES Information Date of Notice No. Subject Issue Issued to 84-93 Potential for Loss of Water 12/17/84 All boiling water from the Refueling Cavity reactor facilities holding an OL or CP 84-92 Cracking of Flywheel on 12/17/84 All boiling water Cummins Fire Pump Diesel reactor facilities Engines holding an OL or CP 84-91 Quality Control Problem 12/10/84 All boiling water of Meteorological reactor facilities Measurements Problems holding an OL or CP 84-90 Main Steam Line Break 12/7/84 All boiling water Effect on Environmental reactor facilities Qualification of Equipment holding an OL or CP 84-89 Stress Corrosion Cracking 12/7/84 All boiling water in Nonsensitized 316 reactor facilities Stainless Steel , holding an OL or CP 84-88 Standby Gas Treatment 12/3/84 All boiling water System Problems reactor facilities holding an OL or CP 84-87 Piping Thermal Deflection 12/3/84 All boiling water Induced by Stratified Flow reactor facilities holding an OL or CP 84-86 Isolation Between Signals 11/30/84 All boiling water of the Protection System reactor facilities and Non-Safety-Related holding an OL or CP Equipment l 84-85 Molybdenum Breakthrough 11/30/84 All NRC licensed from Technetium-99m medical institutions Generators and radiopharmaceutical suppliers 84-84 Deficiencies In Ferro- 11/27/84 All boiling water Resonant Transformers reactor facilities holding an OL or CP OL = Operating License ,
j CP = Construction Permit n ,m-- ,, -- -e.y,, - ,.,,,.,,--,.e,-,,,,,_r-.nm----,e-m ., ,.---, w- - -.--,,-,,,,,,---,-,,_.------m--.
bifghhtd)f14jif NRC Fonu 218 U.S. NUCLEAR REGULATO RY COMMIS510N DATE 14-72)
N Cu o24o 1/24/85 ME AM TELEPHONE OR VERBAL CONVERSATION RECORD p O INCOMING CALL 0 OUTGOING CALL O visit PEr. SON CALLING OF FiCE/AODRESS Marvin Peterson IP PHONE NUMBER l EXTENSloN PERSON CALLEO OFFICE / ADDRESS PHONE NUMBER l EXTENSloN Paul H. Lohaus Region I CONVE RSATION SU 8 JECT IiRC RESPONSE TO SEGOVIA-KANE LETTER
SUMMARY
Mary was returning my call. I had called Mary to discuss MRC's response to Segovia-Kane's letter. Marv indicated IP had received no feedback fro ,
Segovia-Kane or Mexican authorities regarding the response. I av;.essed concern relayed to me by Marty Haas, consultant to EAD, that a quantity of gold (possibly as much as 100 ounces) was on the shipment sent to Segovia-Kane. (After my call to Mary, I called Farty Haas and Frank Bradley of the NY Labor Department and asked then to review their records to see if they could identify the specific amount of gold that was on the :;hipment.) I indicated we should bring this to the attention of the Mexican authorities, if we had not already done so, so that they could check and make sure contaminated gold in the shi*pment did not inadvertently find its way into the commercial marketplace. Mary indicated IP would relay this infonnation to the Mexican authorities and let us know what the current status of the shipment was.
FYI cc: T. Murley J. Allar D. Nussbaumer J. Saltzman M. Peterson REFERRED TO:
O ADVISE ME OF ACTION REQUESTED ACTION TAKEN,
' INITIALS
,b JM Y
^"
INITIALS
)[2T$M ACTION TAKEN . .
\
i CATE -
{