ML20134M948
| ML20134M948 | |
| Person / Time | |
|---|---|
| Issue date: | 09/27/1995 |
| From: | Clint Jones NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Fonner R NRC |
| Shared Package | |
| ML20134M945 | List: |
| References | |
| FOIA-96-444 NUDOCS 9702210114 | |
| Download: ML20134M948 (4) | |
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Mreate Rill has sont us an " urgent" request for toch assistance on the potential disposal of the slightly contaminated (with Co 60) water to Geneva newer treatment facility. Both the NRC and AMS tested for solutsty por IN 94-07, and by that definition (less than 0.45 micron particles), the Region beleves that the discharge is soluble.
If we can agree, for the moment that the water is soluble, the question is, are there any NRC regulations that would prohiit this discharge? If not, would AMS be required to obtain permission from NRC before discharging (See attached). The total quantity of Co-60 in the 2500 gals is much less than the exempt concentration listed in 10 CFR 30.70.
Although I have some questions for Rlli about their sampling technique & the number of samples that should have been taken, can you help us out with the legal side of the question?
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wra y t e 5+g et tp e M Q ae c.Ln REGIONAL TECHNICAL ' SSISTANC$ REQUEST FORM A
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Date: 9/28/95 Mail or E-Mail to: Don Cool (DAC), Mail Stop: 6H3-OWFN, If E-mail, cc:CLE i
From:
J. caldwell (JLC11 (Name and E-mailinitials) Region llL__
l Deputy Division Director, DRSS i
Licensee: AMS License No.: 34-190s9-01 f
I Problem / issue:
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Backpound: Advanced Medical Systems (AMS), located in Cleveland, OH, is currently storing 100,000 gallons of slightly contaminated, processed water in its facility. The water contains 40 uCl of Co-60, thus j
the average Co-60 concentration is 106 pCi/l. As discussed below, i
filtration tests show that the Co-60 is soluble, in the very naar future, l
AMS may receive permission from Geneva, OH to discharge its 100,000 i
j gallons of water into Geneva's waste treatment plant.
l Questions: Are there any NRC regulations which would prohibit this action? If not, is AMS required to obtain permission from NRC before l
discharging this water into Geneva's waste treatment plant? Also, are the l
methods used to determine solubility (described below) acceptable?
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i For the following reasons, Region ill is of the opinion that Discussion:
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AMS may discharge its water into Geneva's waste treatment plant, and I
that prior NRC approval is not necessary. We also believe that the l
methods used to determine solubility are acceptable.
n limit for Co-60 in liquid is SE-4 uCi/mi =
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6FT) The exempt concentra i
g4 2i00,000 pCi/l (10 CFR 0.7 Schedule A), which is orders of magnitude t 44 centra ion of Co-60 in AMS' water.
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Ph 4d4 At allows esposal of licensed material into a sanitary 4
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- 2) 10 CFR 20.200 sewerage system if the material is soluble and d
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appendix B are not exceeded. (There are more requirements, but they
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don't apply here.)
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- 1. Solubility: AMS water samples have proved to be soluble.
At AMS, the processed water was first pumped into a 2500 gallon sampletank. Here, the water was recirculated for three hours, and then two 500 mi samples were taken - one for AMS, one for NRC.
AMS' sample was counted on a gamma spec system at one of two offsite labs. The MDA at each lab was 20 pCi/l. If no Co-60 was detected, then the water in the 2500 gallon sample tank could be pumped to one of four 25,000 gallon storage bladders. If Co-60 was detected at a level at or below 200 pCill (on June 9, this was changed by NRC to 1000 pCi/l), then a solubility test was performed. The method used was the American Public Health Association's " Gross Alpha and Gross Beta Radioactivity (Total, Suspended, and Dissolved)," which is listed in IN 94-07 as one of the two acceptable methods which may be used for the radioanalysis of suspended solids in water. If no Co-60 was detected on the filter, then the Co-60 was considered soluble and the water in the sample tank could be pumped to a storage bladder.
On the other hand, if any Co-60 was detected on the filter, then theD
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Co-60 was considered insoluble if the Co-60 concentration (yh even exceeded 200 ncl/l lahar lona 9.1000 ociML Aus wruu he notified and the water in the sample tank would be reprocessed.
t All AMS samples tested have proved to be soluble.
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NRC's sample was counted on a gamma spec system in the Rill mobile lab, or in the Rlli lab. The MDA at each lab varied between approximately 20 and 60 pCi/l. If Co-60 was detected above the MDA, then a solubility test was performed. The method used was ASTM D-1888-78, " Standard Test Methods for Particulate and Dissolved Matter, Solids, or Residue in Water," which is listed in IN 94-07 as one of the two acceptable methods which may be used for the radioanalysis of suspended solids in water. If no Co-60 was detected on the filter, then the Co-60 was considered soluble. On the other hand, if any Co-60 w.5s detected on the filter, then the Co-60 was considered insoluble.
All NRC samples tested have proved to be soluble. 6
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- 2. Table 3, Appendix B: The monthly sewer concentration limit is i
3E-5 uCi/mi or 30,000 pCi/1, which is orders of magnitude greater than the average concentration of Co-60 in AMS' water.
j Date Needed: No later than Sept. 29,1995. Negotiations between AMS and the City of Geneva are ongoing, so we need the response ASAP.
Y Headquarter Reviewer:
Regional Reviewer:
Reviewer Code:
+
Reviewer Phone No.: I 1 FAX No.:
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Request Needed by: 9/29/95 (date) 4 i
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