ML20126H848
| ML20126H848 | |
| Person / Time | |
|---|---|
| Issue date: | 02/19/1985 |
| From: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20126H305 | List: |
| References | |
| FOIA-85-210 NUDOCS 8506180458 | |
| Download: ML20126H848 (2) | |
Text
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FEB 191985 MEMORANDUM FOR: Paul H. Lohaus, State Liaison Officer Region I FROM:
W. T. Crow, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS
SUBJECT:
REVIEW AND COMMENT ON " AMERICIUM DECONTAMINATION PROPOSAL FOR THE TOWN OF TONAWANDA SEWAGE TREAT-MENT PLANT AND RELATED FACILITIES - BY ENSA, INC."
We have reviewed the above proposal for the decontamination of the Tonawanda, New York sewage treatment plant and related facilities. Our major concern with the proposal is the pemanent disposal of the Am-241 contaminated ash at the Tonawanda Landfill.
In this document, ENSA, Inc., proposes the cleanup of the Tonawanda sewage treatment plant such that it is suitable for unrestricted release, placing all contaminated ash in 55-gallon drums, and permanently disposing of this material in the Tonawanda Landfill which is already contaminated with about 10,000 tons of Am-241 ash from past operations.
ENSA proposes to stabilize the area with a 4 foot clay cap and incorporate land use restrictions similar to the Option 4 criteria in our Branch Technical Position for the disposal of uranium and thorium wastes. However, in our Option 4 criteria for pennanent burial, it has to be demonstrated that the wastes will be buried under conditions so that no member of the public will receive radiation doses in excess of those in Option 1, except for intrusion into the burial ground. The subject proposal does not provide information and firm technical basis to demonstrate the burial will meet our Option 4 criteria.
The hydrogeological analysis in this proposal is too simplistic and conservative, resulting in a much higher concentration compared with the EPA's drinking water standard. We therefore suggest ENSA use site-specific hydrogeological information, conduct a more realistic analysis, and with appropriate monitoring as a supplement, ensure the suitability of the site for permanent disposal of the Am-241 wastes to meet our Option 4 criteria.
In addition, we disagree with some of the ENSA'A decontamination criteria as listed in Appendix B of the document. Specific coments on the above proposal are as follows:
P.4.
Comparative Leaching Hazard: A more comprehensive hydrological analysis should be conducted.
If a drinking water standard is used for comparison, the dose limit should be based on the EPA's standard, not the NRC's 10 CFR Part 20 limit. The actual groundwater use in the area should be described in the document.
8506180458 850417 PDR FOIA WELDONB5-210 PDR Pl
FEB 191985 Paul H. Lohaus P.15.
First paragraph:
It is not an appropriate comparison.
P16.
The simplistic worst case groundwater analysis results in a high Am-241 concentration compared with EPA's drinking water standard.
The groundwater use in the area should be described.
If the groundwater 'in the area can be used for potable water, then the EPA's drinking water standard should be used for comparison.
P.17.
It is pointed out that Am is a soluble compound in accordance with ICRP-30 and is classified as a W compound.
B-1.
Appendix B: Water concentration 4 x 10~6 uCi/ml is not a drinking water standard.
If the groundwater is used for
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drinking, the EPA standard (4 mrem /yr) should apply. The 50 (uCi) max daily discharge should be reevaluated.
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l4. T. Crow, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS i
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