ML20135H364

Forwards Request for Addl Info Required to Evaluate Util 850523 Request Under 10CFR20.302(a) to Dispose of Low Level Radioactivity Contaminated Sewage Sludge by Land Application Onsite

ML20135H364
Person / Time
Site:	LaSalle
Issue date:	09/17/1985
From:	Butler W Office of Nuclear Reactor Regulation
To:	Farrar D COMMONWEALTH EDISON CO.
References
NUDOCS 8509230107
Download: ML20135H364 (6)

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SEP 171985 Docket Nos.: 50-373 and 50-374 Mr. Dennis L. Farrar Director of Licensing Concionwealth Edison Company Post Office Box 767 Chicago, Illinois 60690

SUBJECT:

ADDITIONAL INFORMATION REQUIRED TO EVALUATE LA SALLE'S REQUEST UNDER 10 CFR 20.302(a) TO DISPOSE OF LOW LEVEL RADI0 ACTIVITY CONTAlilNATED SEWAGE SLUDGE BY LAllD APPLICATION By letter dated May 23, 1985, Commonwealth Edison requested approval under 10 CFR 20.302(a) to dispose of low level radioactivity contaminated sewage sludge by land application on-site at the La Salle County Station. We find that we need additional information to complete our evaluation. You should revise your submittal by addressing the items listed in the Enclosure.

- These itens were discussed with your staff (Mr. Massin et. al) by telecon on September 9,1985.

If there are any question's concerning this information, please contact Dr. Anthony Bournia, Project Manager, (301) 492-8535.

Sincerely, Walter R. Butler, Chief Licensing Branch No. 2 Division of Licensing

Enclosure:

As stated cc: _See next page DISTRIBUTION

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Philip P. Steptoe, Esquire John W. McCaffrey Suite 4E00 Chief, Public Utilities Division One First National Plaza 100 f: orth La Salle Street, Roon 900 Chicago, Illinois 60603 Chicago, Illinois CC601 Assistant Attorney General 188 Vest Randolph Street Suite 2315 Chicago, Illinois 60601 Resident Inspector /LaSalle, NPS U.S. fiuclear Regulatory Commission Rural Route I:o. 1 Fost Office Box 224 Harseilles, Illinois 61341 Chai rman La Salle County Board of Supervisors La Salle County Courthouse Ottawa, Illinois 61350 Attorney General 500 South 2nd Street Springfield, Illinois 62701 Chairman Illinois Cor.nerce Ccrrission Leland Building 527 East Capitol _ Avenue Springfield, Illinois 62706 Mr. Gary N. liright, llanager Nuclear Facility Safety Illinois Departrent of Nuclear Safety 1035 Outer Park Drive, 5th Ficor Springfield, Illinois 62704 Regional Administrator, Region III U. S. Nuclear Regulatory Commission 799 Rossevelt Road Glen Ellyn, Illinois 60137

ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION REGARDING COMMONWEALTH EDIS0N'S PROPOSAL TO DISPOSE OF LOW LEVEL RADI0 ACTIVELY CONTAMINATED SEWAGE SLUDGE BY LAND APPLICisTION ON-SITE AT LASALLE COUNTY STATION DOCKET NOS. 50-373/374

1. On page 2 of Attachment 1 to the May 23, 1985 letter, the licensee assumes that the sewage sludge may be spread from 3 inches to 3 feet thick on an area of about 100 meter radius (8 acres) with no top soil cover. The area of disposal of about 100 meter radius or 8 acres does not agree with the licensee's statement on page 3 of Attachment 1 that the sludge will be applied to a 3 acre area. Reconcile this difference and describe the method by which dried sludge will be spread over land including the thickness of the sludge disposed, the area of disposal (square meters), as well as mixing and dilution with clean soil, if any.

2. Provide conservatively realistic occupancy times at the sludge disposal site for workers and for a member of the public. Describe any administrative controls and barriers to prevent a person from residing on top of the disposed sludge.

> 3. On page 3 of Attachment 1 to the May 23, 1985 letter, in step 3 the licensee proposes an administrative limit of 1 pCi/cc for each of three ,

nuclides (i.e., Co-60, Co-58, and Mn-54) and 3 pCi/cc for total gamma activity in the wet sludge. This limit translates to a total radionuclide concentration of about 160 pCi/cc in the dried sludge. Using an occupancy time of 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> /yr, the administrative limits for the radioactivity

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proposed by the licensee and a 3" layer of dried sludge, the staff l estimates a direct radiation dose of 200 mrems/yr to the total body of j a member of the public. Revise the submittal and propose lower l administrative limits for radioactivity in the sludge to be land applied i and/or propose other measures to reduce the potential radiation exposures

! .to the workers and to members of the public. In addition, analyze the other major pathways of exposure (e.g., drinking water from nearby wells, inhalation of resuspended particulates, and ingestion of food), or briefly state that these pathways are non-existent or negligible and provide a brief basis for this statement.

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{ 4. Item 3 on page 3 of Attachment 1 and Table 1 on page 1 of Attachment 4 to ,

licensee's May 23, 1985 letter: Describe the methods and data base for

} the licensee's determination of the radionuclide concentrations.in the wet sludge in the digester, e.g., the number of samples analyzed and

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representativeness of sampling.

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5. Page 3 of Attachment 1 to licensee's May 23, 1985. letter, items 6 and 7:  :

Licensee did'not' state at what time or season of the year the land i - application will take place. Since there may be a period of time between land application and planting of vegetative cover when the uncovered sludge l

1 and its contaminants would be exposed to the ambient weather conditions.

conditions such as strong winds or heavy rains could create a potential for wind erosion and runoff leading to transport of pollutants from the waste disposal area onto the adjacent property. State why erosion is not a problem, or describe the control procedures to prevent runoff and wind erosion of the disposed material (such as covering with clean top soil prior to growing vegetative cover).

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6. Commit to the following administrative procedures in a revised submittal:

a. For each batch of sludge generated and sent to the digester, instead ,

of taking only one sample from the whole digester as proposed by the licensee, samples from different parts of the digester should be taken for radionuclide analysis to ensure representativeness of sampling, and the results documented.

b. The dried sludga will be transported to the disposal site in such a way that spills will be kept to a minimum.

c. Measures shall be taken to prevent removal of the dried sledge from the land spread site for unauthorized purposes,

d. The alfalfa grown as the proposed vegetative cover will not be harvested for either animal or human consumption. Otherwise, the licensee should consider growing other vegetative cover which is not an attractive food for animals or humans. -

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e. The workers handling the waste disposal should be properly dressed in accordance with station Health Physics procedures and station directives.

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