ML20127G534
| ML20127G534 | |
| Person / Time | |
|---|---|
| Issue date: | 10/18/1984 |
| From: | Nussbaumer D NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Cobb L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20127C176 | List: |
| References | |
| FOIA-84-781 NUDOCS 8506250475 | |
| Download: ML20127G534 (1) | |
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C OCT i 81984 Ref: SA/JOL MEMORANDUM FOR: Leonard I. Cobb Chief Safeguards and Materials Programs B.anch. Office of Inspection and Enforcement FR0!!:
Donald A. Hussbaumer Assistant Director for State Agreements Program Office of State Programs
SUBJECT:
PROPOSED TEMPORARY INSTRUCTIO!I (TI) 2800/5 We concur in the issuance of a Temporary Instruction (TI) regarding inspections of licensees where reconcentrations of discharged radionuclides may occur at sewerage treatment plants. On September 25, 1984, with your concurrence, we furnished an advisory to the Agreement States on this (enclosure 1). You may wish to consider including in the TI guidance on how to apply the specific requirements of 10 CFR 20.303.
Our experiences as a result of the EAD episode suggest some may be needed.
See especially footnotes 4 and 5 of the enclosed note to Paul Lohaus from Joel Lubenau (enclosure 2). We also suggest asking that, whenever practicable, radiation surveys be performed by inspectors of the sewer lines leading from the licensecs' facilities.
Oricin'reneedy%,
J. O.Lubenau Donald A. NussbaumEr Assistant Director for State Agreements Program Office of State Programs l
Enclosures:
As stated Distribution:
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SA/JOL SEP 2 51984 ALL AGREE!4E!!T STATES SEWER SLUDGE CONTAMINATIO;i In 1984, three instances of contaminated sludae from sewabe. treatment piants have been reported. The first involved a Tennessee licensee in the reactor component decentamination business discharging liquid wastes tc a sanitary sewer system.
Sludge samples contained 10-100 pCi/gm gross activity.
Co-50, Cs-137 and Cs-134 were identified.
Radiation levels in the sewer pipe ranged up to 16 millirem per hour. The second end third incidents invcived ?!ew York facilities licensed to manufacture ic-241 foils for fire detectors.
In one case, the sluope was incinerated and ths resulting ash contained Am-241 at levels up to 500 pCi/gn.
In the other tiew York case, the sludge contained 100 p i/g:. dry weigh..
Siudce disposai varied:
In Tennessee it was usec as fertilizer.
In New Yeri. i. v:as incinerated and disposed of at a landfill by one sew 3ge tr6 ament plant and disposed ov directly to landfills by the ciner.
It is not clear that all cf these licensees met applicable regulatory requirements at all times.
tionetheless, HRC staff is considering reexamining the regulatory requirements for sanitary sewer system disposal (10 CFR 20.303).
We will kecp you advised of i4RC actions.
In the maantime we suggest that you take the following actions:
(1)
Ensure that your regulatory staffs have a working knowledge of ycur equivalent to 10 CFR 20.303.
We have attached a guide highlightinc points that your staffs should be familiar with.
(2)
In cases where licensees are utilizing icng-lived unsealed radioactive inaterials and discharging liquid wastes to the sanitarv sewer system, have surveys perfomed of the sewer
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lir.es (e.c., at man-noles), and collect and anElyze sludge sa=les from the sewagt treatmer.t plant for radioactivity.
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Dri.=tnc signet by:
I.2;cestau=er Donald A. tiussbaumer Assistant Director for State Agreements Progran Office of State Programs Enciosure:
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f Enclosure
'l Considerations fcr Discharge of Licuid Wastes to Sanitary Sewer Systems (SSS) o Discharges te septic tank systems, leach field and other. closed systems are not cons.idered to be sanitary sewer systems.
The provisions OTTO CFR 20.303 are not applicable.
Because radioactive materials can accumulate in such closed systems, discharges.to them should not be permitted except after careful review of the need and the consequences and approval by the State by license condition.
o Material that is dischargec te 555 must be "readily ioluble or dispersible."
Care should be exercised in accepting assertations by licensees that discharged materials meet this criterion.
Absent formai guidance from NRC we recommend taking a conservative view ir, al; cases.
o Limits on discharges to 555 are expressed in cuantities. nct MpC's.
There are daily, monthly and annual limits.
One of the daliy limits and the monthly limit are functions of the Appendix E Schedule 1, col. 2 value and the sewage discharge volume.
Licensees should be required to show cg pliance with these limits, not the MPC.
Sample calculations for Co are attachea and show the importance of this difference.
o Sewage volumes must be documented.
Water or sewer bills are acceptabie documentation. ~
o Ensure that samples are representative.
Holding tanks should be thoroughly mixed before sampling.
o Review sample preparation, counting, calibration and qalculation procedures.
How does the licensee show the material is readily soluble or dispersible?
Are samples evenly dried? How are counting efficiencies determined? Are self-absorption and backscatter factors appropriately applied?
Sample a licensee's calculations and confirm the results.
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CMruN Y m,, m L h Gil Att'achment to Enclosure aww/
Quantity Criteria for Discharging Radioactive Materials to Sanitary Sewer Systems Example:
Isotope: Co-60 Daily Sewage Volume Average 5000 gallons Monthly Sewage Volume Average: 152,000 gallons Daily:
20.303(b)(1) or (b)(2) which ever is larger.
20.303(b)(1): 1 x 10-3uti x 5 x 10 gal x 1
x 10,3 3
3 ml 0.264 gal T
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=18.8 x 10 uCi or 18.8 mci 20.303(b)(2): 10 x luci or 10 uCi The daily limit is the larger of the two or 18.8 mci Monthly: '20.303(c): 1 x 10-3uci x 1.52 x 10 gal x 1
x 10,3 5
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.264 gal 1-5
=5.76 x 10 uCi or 576 mci Annual:
20.303(d):
1 C1 (1,000mC1)
A discharge of sewage contaminated at the MPC for 200 workdays in a year would result in exceeding the annual limit:
18.8 mci x 200 days = 3,780 mci vs. 1,000 mC1.
day If this licensee produced records only showing that the SSS discharges did not exceed the Schedule I MPC, compliance with all parts of 10 CFR Part 20.303 was not demonstrated.
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SA/J0L NOTE FOR:
Paul Lohaus EAD SANITARY SEWER SYSTEM DISCHARGES
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On September 4, 1984 I indicated to you that I could not conclude that EAD discharges to the sanitary sewer system (SSS) met the applicable criteria for such discharges based on the review of New York Department of Labor (NYDL) files and that there are strong suggestions in the files that they did not. The following set out my reasons for those conclusions.
The primary NYDL sources of infomation en EAD SSS discharges were:
o October 16, 1976 EAD License Application o
R. Kelly Inspection Report for February 13, 14, 20, 19i9 o
R. Kelly Inspection Report for tiay 5. 6, 7, 13, 1981 1984 F. Bradley to Dr. Stasiuk memo re EAD SSS o
discharges (month and date not noted)
SSS discharges in New York are [overned by the NY Department of Environmental Conservation (NYDEC) Part 380.
Industrial Ccde Rulc 33.23 and State Sanitary Code 16.8 (c) also provide regulatory guidance.
EAD did not possess a NYDEC permit for liquid effluents. Therefore the applicable regulatory criteria for SSS discharges of Am-241 were the same as for NRC licensees (See 10 CFR 20.303):
1.
The material must be "readily soluble or dispersible in water" 2.
The daily quantity discharged does act exceed the larger of the following:
(a) that quantity which, if diluted by the average quantity of sewerage released into the SSS in any day, would result in er, average concentration coual to the MPC in Col. 2 ef Table I of Apper. dix B of Part 20.
2.
(b) 10X the quantity set forth in Appendix C of Part 20 or 10 x 0.01uCi cr 0.luCi.
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The monthlb'uantity discharged does not Goed that quantit.','
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a which, if oiluted by the average quantity of sewage rel. cased into the SSS in any day, would result in an average concentration equal to the MPC in Col. 2 of Table I of Appendix B of Part 20.
and 4.
The annual quantity discharged does not exceed 1 Ci.
Thus there are four criteria to be met by the licensee:
o the material must be readily soluble or dispersible r
in water o
there is a daily quantity limit o
there is a monthly quantity limit o
there is an annual quantity limit Some licensees, in an attempt to deconstrate compliance with daily and monthlylimits,calculgtetheconcentrationinthesewagedischargeand within the MPC, then the criteria of 10 CFR 20.303 are met.gations are compare it to the HPC.
The assertion is that if the concent In the HYDL files, the available data ccvering SSS discharges for the years 1977-80 were yearly average concentrations and annual totals:
Year Yearly Averaae Conc., uCi/mi Total Cuantity mci 0.57'x10-j 0.35 1977 1978 0.97x10 31.7 197.9 2.7x30~4 85.5 1980 1.5xiO-4 40.2 From these data, the only quantity criterion than can be said to have been met by EAD for these years-is criterion 4.
For the years, 1981-83, the available data appeared to be fragmentary.
In iiay,1983, EAD started action to transfer their operation to Mexica.
1Whcu utilizing the sewage volume fcr making this calculation, there must be a substantive basis for the value for tne volume, e.g. a sewer or water bill.
2 Regarding the daily discharge criterion, the underlying assumptice is that the concentration multiplied by the SSS discherge volume will result in a quantity greater than criterion 2(b) and therefor? 2(1) applies.
3 This assertica is tenuous.
Given large enough volurcs of sewage, it is possible for repeated daily sewer discharges contoining MFC concentrations to result in an annual discharge exceeding 1 Ci.
See attachment for an example.
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sta is the matter licre critichl to thef aluation of EAD SSS dischargy 'ial was "readily
'of wh;ther or not criurion 1 was met:
that the mats..
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soluble or dispersible in water."
In his 1977 insp:ction report,'the
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NYDL inspector recorded his concern over the solubility of the primary material being discherged, americium oxide. He went on to note that Code 38 says it must be dispersible, adding "(it better be!)."
Americium oxide is indeed to be considered insoluble and there is no information in the NYDL files indicating EAD demonstrated that the americium being discharged was, at least," readily dispersible,"'
Therefore, one cannot conclude, from examination of NYDL EAD files, that criterion 1 was met.
These are further reasons to doubt EAD's compliance with the criteria.
In 1977, the NYDL inspector cited EAD for not having any records of the counting efficiencies used except for the last three discharges.
(The inspector, incidently, did a comendable job in digging into the licensee's data to this extent).
Further the inspectcr reported that on checking discharge calculations, discrepgncies were found, although the corrected values did not exceed the MPC The 1981 report adds more doubt about the validity of EAD's SSS discharge data.
Problems with calculations of volumes of discharges were noted. The inspector reports observing sampling of the tank and notes "no stirring of the mixture was done," thus raising a cuestion dbout how representative the sample was (an especially significant item keeping in mind that the americiun is in insoluble form).
The inspector goes on to record:
o "I feel 'skitish' about the waste water," and "Ican'thelpbutthinkthatthewatgrreleasedcould o
conceivably be completgly ' fudged'."
4 In informal ciscussions held cn Septenber 14, 1984 with regional health physicists, none indicated that they were aware of guidance on determining dispersibility and at least one expressed dcubt that americium oxide could be shown to be "readily dispersible."
P.eference to " Standard i!ethods for the Examination of Water and Wastowater,"
particularly the tests to deternine residues, mir:ht provide a rational basis for developing guidance.
5 There is some question over which value for 41An in Col. 2 of Table 1 of Appendix B should be used, soluble or insoluble? The mat rial is obviously not soluble but, given the content and intent of the requirenent for the discharged material to be readily sclubla or dispersible, is the use of the higher iiPC (fcr insalubla) aopropriate?
a can'.vas of regional health physicists on September 14, 1984 disclosed that there is no guidsuce and there was no consensus deve1 0 ped on unich MPC to usa.
5 The 1979 and 1981 inspections disclosed numerous violations including for cxemple, failures to make certain surv9.ys snd failure to take outside air ano soil semples.
Motices of violations were issued by the inspector after each inspection.
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- There were no record "in th NYDL EAD files indicath,9 that the inspector's concerns were absolved.
In my discussion with Dr. Bradley on August 24, 1984 on the results of my review of the EAD file, I specifically mentioned the inspectors' concerns.
I was offered no information that they had ever been addressed.
I understand that in a subsequent telephone conversation you had with the inspector, he statad he received no feedback from NYDL management over these concerns.
Finally, the original license application contains building plans including of the drain system.
Floor drains, and drains from the washer, sinks, change room sinks and shower, all in the controlled area, drain to the sump area (where the effluents were held in tanks).
The water closet drains in the controlled area, however, join other watar closet and sink drains in the uncontrolled area which connected directly to the SSS. Absent infomation to the contrary, this would constitute an unmonitored effluent path from the EAD controlled area.
The license application did not contain detailed procedures for ensuring representative sampling or for sample analysis of liquid effluent sampling.
In summary:
o UYDL files do not contain information that can pemit a detemination that EAD met all the criteria applicable to pemissible quantities of radioactive materials discharged to sanitary sewer systems, o
There is no infomation demonstrating that the americium discharged to the sanitary sewage system was "readily soluble or dispersible," and Observations by and concerns expressed by the MYDL inspector o
throw doubt upon the validity of the available data.
The foregoing applies to the period when EAD was in operation.
The liquid effluent tanks and filters were reportedly removed in the Sprina of 1983 and subsequent decontamination activitics progressed with work waters discharged directly to the SSS according to infomation we were given by EMSA staff during out visit to EAD on August 15, 1984.
"a wr.re also infomed during that visit that no records of analyses existed 'or these discharges.
Thus, I cannot conclude that EAD discharges met the applicable New York criterie for SSS discharges. There arc streng suggestions, instcad, that this was not the case.
Distribution:
SA R/F J0Lubenau Jcel Lubenau dir R/F GWKerr DANussbaumer JRMcGrath N.YDL file (fc) 10/Y1/84
Attachment Quant 1;y Criteria for Discharging Radioactive Materials to Sanitary Sewer Systems Example:
Isotope: Co-60 Daily Sewage Volume Average 5000 gallons Monthly Sewage Volume Average: 152,000 gallons Daily:
20.303(b)(1) or (b)(2) which ever is larger.
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20.303(b)(1): 1 x 10-3uci x 5 x 10 gal x 1
x 10,)
ml 0.264 gal T
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=18.8 x 10 uCi or 18.8 mci 20.303(b)(2): 10 x luci or 10 uCi The daily limit is the larger of the two or 18.8 mci 5
Monthly:
20.303(c): 1 x 10-3uci x 1.52 x 10 gal x 1
x 10 mi ml
.264 gal 1-5
=5.76 x 10 uci or 576 mci Annual:
20.303(d):
1 C1 (1,000 mci)
Adischargeofsewagecontami$atefittheMPCfor200workdaysinayear would result in exceeding the annual limit:
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18.8 mci x 200 days =~3,780 mci vs. 1,000 mci.
day If this licensee produced records only showing that the 555 discharges did not exceed the Schedule I MPC, compliance with all parts of 10 CFR Part 20.303 was not demonstrated.
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