ML20136G795

Summary of Oct 1996-Jan 1997 Meetings of Interagency Steering Committee on Radiation Stds Subcommittee

ML20136G795
Person / Time
Issue date:	02/27/1997
From:	Sobel P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-3 NUDOCS 9703180202
Download: ML20136G795 (43)

Text

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• -4 UNITED STATES

. -& E NUCLEAR REGULATORY COMMISSION

• ' If WASHINGTON, D.C. 20666-4001 o%,...**/ February 27, 1997 MEMORANDUM T0: 'LW(TP -

FROM: Phyllis Sobel kh [> f

SUBJECT:

MEETING SUMMARIES INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS (ISCORS) SUBCOMMITTEE MEETINGS Attached are summaries of ISCORS subcommittee meetings in October 1996 through January 1997. These meeting summariet are being placed in the NRC's Public Document Room.

Attachment:

As stated- ,

cc: Paula Goode, EPA /0RIA ')

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\

l 97-96 NRC R.E CENTS COPY 9703180202 970227 ,

PDR WASTE PDR WM-3 180076 i

. i February 27, 1997 MEMORANDUM T0: File FROM: Phyllis Sobel [0riginal signed by]

1

SUBJECT:

MEETING SUMMARIES OF INTERAGENCY STEERING COMMITTEE ON j RADIATION STANDARDS (ISCORS) SUBCOMMITTEE MEETINGS

, Attached are summaries of ISCORS subcommittee meetings in October 1996 through January 1997. These meeting summaries are being placed in the NRC's Public Document Room.

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Attachment:

As stated cc: Paula Goode, EPA /0RIA l

TICKET: N/A DISTRIBUTION: Central File LLDP r/f PUBLIC .

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DOCUMENT NAME: S:\DWM\LLDP\ PAS \SUBSUMM OFC LLDP LLDV7)[//

NAME PSobelk/ RNe[sh DATE 2/8 7/97 2ft)97 0FFICIAL RECORD COPY i 1 ACNW: YES _x_ NO Category: Proprietary or CF Only l

, IG : YES N0 x LSS : YES N0 x Delete file after distribution: Yes No ___

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INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS SUBCOMMITTEE MEETING SUMMARIES Subcommittee Meetinas Mixed Waste October 31, 1996 Recycle November 19, 1996 Risk Harmonization November 20, 1996 December 18, 1996 Sewage November 7, 1996 January 22, 1997 l

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DISCLAIMER These ISCORS subcommittee meeting summaries result from interagency discussions. The subcommittees are composed of representatives from the Environmental Protection Agency, Nuclear Regulatory Commission, Department of Defense, Department of Energy, Occuptional Safety and Health Administration, Department of Transportetion and Department of Health and Human Services. The subcommittee meeting summaries have not been approved by the respective federal agencies and do not represent the official position of any participating agency at this time.

ISCORS MIXED WASTE SUBCOMMITTEE MEETING NOTES o DATE & PLACE: Thursday, October 31, 1996 at 00E Hq, Forrestal o PARTICIPANTS: Sign-in list attached; five federal agencies, EPA, NRC, D00, DOT and DOE, represented.

o AGENDA: description attached I

o DISCUSSION:

The meeting generally followed the suggested agenda with member agencies first providing summaries of their MW-related activities since the July 10, 1996 meeting. NRC mentioned three initiatives in progress; the Cs 137 source baghouse dust technical position paper now expected to be issued by the end of '96. Two joint MW initiatives with EPA one on storage and one on testing are moving forward; both are at EPA, the former for resolution of questions and the latter is being reviewed by OGC. (Handouts: NRC provided two; these are publicly available and copies attached. One on NRC's Interim Radiological Clean-up Criteria, provided to the subcommittee only as an existing reference, and the second on a newly released report on LLW and MW treatment technologies).

EPA /0SWER has had ongoing discussions with commercial MW treatment companies. LBL, recently in touch with EPA /0SWER, has some tritiated, (mw) waste and is considering submitting a proposal under EPA's EXCEL program aimed at promoting innovative treatment technologies. A November '96 ASME-sponsored MW course at Baltimore, MO will include NRC, EPA and DOE talks. EPA /0RIA has completed a draft strategy for developing disposal alternatives for LLW. It is now beginning to look at performance assessments (pas) and to consider DOE's experience on pas where applicable.

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4 - , 2 DOT mentioned an upcoming comparative risk meeting in December 1996 and l i followed up with an E-mail copy of the meeting announcement, y

D00 provided an update on a couple of items which were reported at prior meetings. In regard to the disposal of 9000 ft3 of old shredded Navy ,

missiles, a radiological risk assessment on the mag / thorium metal was j performed by ChemNuclear for the state of South Carolina. As a result '

the material was disposed at a RCRA landfill. At the Lake City Army j munitions facility there are 40000 ft3 of sand and soil contaminated with DU and heavy metals. Since this is an active site, scheduling  ;

j clean-up is a problem.

DOE opened discussion on the second draft of the RCC ALARA analysis and heard members' preliminary comments regarding the analysis. In general, j

the members found the draft much easier to read and follow. DOE also 1 reported on its efforts regarding the groundwater screening.

4 o MEETING ACCOMPLISHMENTS: l

-Mixed waste and regulatory initiatives considered are summarized in the i Discussion section above.

-The members discussed the ALARA re-draft and, very briefly, the groundwater screening level assessment being done.

1 j o ACTION ITEMS:

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1. Member agencies to provide comments and suggestions on the ALARA

) analysis by mid-January, before next meeting.

! 2. DOE to provide member agencies a draft of the ALARA groundwater screening assessment before next meeting.

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i' o' NEXT MEETING: Tentatively planned for mid January 1997 at the Forrestal ,

l building.

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4 Andy Wallo, III, Chair December 18, 1996 4

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Subcommittee Distribution:

Sonya Barnette, DOE /EM-37 Ambika Bathija, EPA /0RIA

, Gershon Bergeisen, EPA /0 ERR 4

Jerry Coalgate, DOE /EH-413 Kelly Crooks, D0D/ Army Fred Ferate, DOT /RSPA i James Gruhlke, EPA /0RIA .

Nancy Hunt, EPA /0SWER  !

David Levenstein, EPA /FFE0 j 1 Dominick Orlando, NRC/NMSS l Edward Regnier, DOE /EH-412 ,

Gus Vazquez, DOE /EH-412 Paula Goode, EPA 1

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[5'5] From: GUSTAVO VAZQUEZ at EH-0910/29/96 3:43PM (1646 bytes: 15 in)

To: JERRY COALGATE, sonya barnette at EM, lee stevens at EM, levenstdin. david @eaamail. epa. gov at INTERNET, bathija.ambika@epamail. epa. gov at INTERNET, gru ilke. james @epamail. epa. gov at INTERNET, dao@nrc. gov at INTERNET, kerooks@ria emh2. army.

INTERNET, bergeisen.gershon@epamail. mil epa. gov at at INTERNET, INTERNET, feratef hunt. nancy rspa. dot. gov @ep@amail. epa. g at INTERNET, hank himpler at EM, henry himpler at EM, kcrooks@ria-emh2. army. mil at INTERNET cc: EDWARD REGNIER, ANDREW WALLO

Subject:

Reminder-ISCORS MW Subcommittee Meeting Message Contents ----------------------------

Colleagues, Please make note of a change in our meeting time and place. The DOE Forrestal building,1,pm on Thursday, October 31,1996. The room number is 6E-081. I expect all of you have received a copy of the ALARA re-Draft in the mani. We expect to provide you a draft of Appendix F, Groundwater Screening, at the meeting too. We suggest j the menda include agency reports on MW activities.

an in ormal discussion /first impression of the draft you 6E just received and, if time permits. a little on niir .

3 groundwater screenina effort in the event of a failure of .

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I A Summary of NRC's Interim Radiological Cleanup Criteria and Current Dose Bases Decommissioning and Regulatory Issues Branch, U. S. Nuclear Regulatory Commission November 1992 Implementation of residual contamination criteria is dependent on the establishment of acceptable dose or risk cr'iteria for unrestricted use of nuclear facilities. The NRC has been using a patchwork of remediation criteria to define acceptable levels for cleanup of radioactive contamination. However, these criteria are not currently binding on licensees and are generally not consistent with one another or with comparable requirements being established and imposed by other agencies (e.g., Environmental Protection Agency (EPA)). In addition, the scientific basis for some of the criteria established in the 1970s and early 1980s is out of date. Further, some of the criteria are only indirectly related to the protection of the public health and safety and the environment. 4 I

In the mid-1980s, NRC staff initiated development of the l technical basis to support a rulemaking to codify final cleanup  !

standards for radiological contamination. This rulemaking was an outgrowth of the NRC's long-term effort to establish s decommissioning requirements (53 EB 24018; June 27, 1988).

! However. the rulemaking to establish radiological criteria for j decommissioning may not be completed for another two years or so, posing the problem of what criteria should the NRC use in the interim to determine whether sites have been sufficiently decontaminated so that they may be released for unrestricted use.

In preparing this paper, the NRC staff identified the full range of existing cleanup criteria used by the NRC and estimated the doses associated with the criteria.

1.1 NRC Cleanup Criteria NRC has developed or used the criteria in the following references coupled with the concept of maintaining exposures from residual radioactive material as low as is reasonably achievable (ALARA) for guiding the cleanup of contaminated soils, structures, and equipment for unrestricted use:

1. Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, and Special Nuclear Material, Policy and Guidance Directive FC 83-23, November 4, 1983; Termination of Operating Licenses for Nuclear  !

Reactors, Regulatory Guide 1.86, June 1974 -- These two documents provide criteria in terms of fixed and removable i contamination and acceptable radiation exposures associated l with beta- and gamma-emitting surface contamination. The.FC 83-23 guidance also provides acceptable volumetric concentrations of uranium, thorium, americium and plutonium in soil. The uranium and thorium criteria are identical to l the option 1 position in he Branch Technical Position i described in item 2. Regulatory Guide 1.86 has been combined with a 5 4R/hr at 1 meter external dose criterion l

for "Co, "'Cs, cnd uzEu that may exist in concrete,

. . components, and structures at nuclear reactor research

. facilities, with an overall dose ob]ective of 10 millirem / year (cf. Letter to Stanford University from James 1

R. Miller, Chief, Standardization and Special Projects Branch, Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, April 21, 1982, Docket No. 50-141).

2. Disposal or Onsite Storage of Thorium and Uranium Wastes from Past Operations, Branch Technical Position, October 23, 1981, 46 EB 52061 -- This document provides acceptable activity concentrations of uranium and thorium (with and without decay products) in soil under a variety of conditions.

3. The Environmental Protection Agency's (EPA's) Interim National Primary Drinking Water Regulations, 40 CFR Part i 141, July 9, 1976, 41 FR 38404 -- This EPA regulation '

4 provides maximum contaminant limits for radionuclides in )

public drinking water, which can be extended to apply as  !

acceptable activity concentrations in groundwater and surface water (see FC 83-23). Drinking water standards have been established for radium-226/228, gross-alpha particle emissions, and man-made radionuclides emitting beta particles and photons. The Environmental Protection Agency recently (July 18, 1991) proposed adding standards for uranium and radon and revising the existing standards for radium and gross-alpha (56 EB 33050).

4. The EPA's Persons Exposed to Transuranium Elements in the i Environment, November 30, 1977, 42 EB 60956 -- This document provides draft radiation dose guidelines recommended by EPA for acceptable levels of transuranium elements contamination j in soil.

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Doses Associated with Existing NRC Criteria NMSS Policy and Guidance Directive FC 83-23

! NMSS Policy and Guidance Directive FC 83-23 provides guidelines j for acceptable average and maximum surface contamination levels for a wide variety of radionuclides. It also provides average

and maximum radiation levels of 0.2 and 1.0 millirad per hour at i 1 centimeter for beta- and gamma-emitters. In addition, the Directive provides an acceptable external radiation exposure rate for soil contamination of 10 microroentgen above background per i hour at 1 meter. An enclosure to the Directive lists acceptable I soil contamination levels based on the 1981 Branch Technical I

Position and includes concentration values for plutonium and j americium compounds. For byproduct materials, the Directive

states that acceptable soil concentration levels will be i determined on a case-by-case basis. The criteria in FC 83-23 and

!- their associated doses are summarized in Table 1. The right hand j column indicates " dose bases" calculated using the computer code i RESRAD that contains contemporary dosimetry and exposure assumptions.

Regulatory Guide 1.86 NRC issued Regulatory Guide 1.86 in 1974. This guide provides i the same basis for the acceptable surface contamination levels described in Policy and Guidance Directive FC 83-23. When combined with an exposure rate limit of 5 #R/hr above background at 1 meter, this guide has been used in decommissioning and terminating licenses for a number of research reactors. The 5 ,

yR/hr criterion for indoor contamination corresponds to an annual '

whole body dose of about 10 milliram for an assumed indoor occupancy period of 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year. The 5 #R/hr criterion has been applied to "Co, "'Cs, and n2Eu that may exist in concrete, components, and structures at nuclear reactor research facilities, with an overall dose objective of 10 millirem / year (cf. Letter to Stanford University from James R. Miller, Chief, Standardization .id Special Projects Branch, Division of 1 l

Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, April 21, 1982, Docket No. 50-141).

l Tablo 1. Acceptcblo Contamination Criteria and l Associated Dose Bases in NMSS Policy and Guidance i . Directive FC 83-23 i

Stated Estimated l Dose Done Basis footamiastaon Cnterion Ba sis + (EDE) +

Average. 5000 dpm/100 cm' None - 13 mre m/y r' U-net, 8"U, 8U, and decay producta Average, .w dpm/100 sm8 None - 0.2mremiy r' 1

"'Ra , "Ra . I treneuronica, etc.

Average- 1000 dpm/100 cm8 None -28 miem/yr' n-nat, 8'%,

"$r, etc.

Avg. and men. 0.21 mrad /hr None - 20 mrem /yr*

external at I cm beta-gamme dose U net with decay 10 pCi/gm - 500 mrem /yr - 2.4 to 260 mrem /yr*

products in mod Gesed on 5 pCi "'Ra - 1.8 to 49 per gram mremiyr*

standard in 40 CFR 192:

hfetime nsk 3

of 0 02)

Depleted Uranium 35 pCi/gm i mradlyr - 2.4 to 8 in mod dung) mmm/yr*

3 mredlyr - 1.8 to 18 (bone) mrem /yr*

n-not wish decay 10 pCi/gm 24 mrem /yr -35 to 82 producte is soil mrem /yr* i Enriched Ursaium 30 pCi/gm I mrodlyr 2.4 to 5 in soil Gung) mrem /yr 8 l

3 mradlyr - 1.8 to 16 j (bone) mrem /yr*

"Tu in sou 25 pCi/gm None -15 mrem /yr* l l

% in soil 30 pCi/gm None -19 to 325 mrem / yr*

4 External th= 10 A at None ~24 mnm/yr*

1 meter above background

+. Does besse generolly expressed in terms of potential does to the mesimum reasonably exposed individual.

f. Calculated usias denA NUREG/CR 5512. FC 83-23 criterie sto based more on technological capabilities (i.e., levels of detectabihty)

, thee on an explicit does besia.

• . Easmanne bened om does et i mener for 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> occwy.

g. Lower sosiesses repressate coeversion or repotstaos of meted does beeis, while upper estimate based on RESRAD calculation (default values used for input pesemeners).

A. Based on ana AD calculas-a without and wish water pathways considered, respectively.

. F- bened om effective, unshielded occupancy of about 2360 hours0.0273 days <br />0.656 hours <br />0.0039 weeks <br />8.9798e-4 months <br /> for -am e xposure.

. 1 l Branch Technical Position (BTP) on Disposal or Storage l.,

- . of Thorium and Uranium Wastes A

s e I

f On October 20, 1981, NRC published this technical position (46 EE i

52061) to provide guidance on decommissioning and cleanup of fuel cycle and other facilities contaminated with relatively large

volumes of wastes with low activity concentrations of uranium and  !

thorium. In combination with the disposal provisions in 10 CFR I i 20.302, the technical position provides four " options" for j disposal of uranium and thorium wastes, which vary in activity l concentration and corresponding potential radiological dose. As ,

i directed in the Commission's April 6, 1992, staff requirements

! memorandum, only the lower activity concentration limits and l 3 disposal methods provided in options 1 and 2 of the technical l 1

i position can be applied as criteria for the release of a site for

! unrestricted use. Options 3 and 4 require deed restrictions that j i would be inconsistent with the Commission's regulations that '

] require sites to be cleaned up so that they may be released for unrestricted use.

Under Option 1 of the Branch Technical Position, licensees may j dispose of wastes containing natural thorium, depleted or i

enriched uranium, and natural uranium without restrictions for l burial method or post-termination land use. The activity l

concentrations for this option are consistent with the levels i identified in Policy and Guidance Directive FC 83-23. The j maximum activity concentration for natural uranium is based on

EPA standards for cleanup and stabilization of uranium mill l tailings for "Ra (5 pCi/g) including its decay products (42 EE j 2556-2563). The activity concentrations for natural thorium and

depleted or enriched uranium are based on internal radiation dose i guidelines recommended by EPA for protection against transuranium f j elements present in the environment as a result of unplanned i contamination (42 EB 60956-60959). As shown in Table 1, i committed doses were expected to be on the order of one millirad i per year to the lung or three millirad per year to the bone from j inhalation and ingestion. The resulting concentrations would i also limit external exposures to less than 10 microroentgens per

! hour above background.

j: Under Option 2 of the 1981 BTP, concentrations of natural thorium

! and depleted or enriched uranium are required to be buried under l prescribed conditions without requiring land use restrictions i after license termination. Disposals performed under Option 2 i guidelines must be covered by four feet or more of clean soil.

Acceptable activity concentrations for burial were calculated i based on the criteria that (1) radiation doses to members of the

? public should not exceed Option 1 levels when the waste is buried l

in an approved manner under routine exposure conditions, and (2)

, radiation dossa to an inadvertent intruder should not exceed 170 i millirens to a critical organ or whole body.

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- When applying Option 2 of the technical position, the staff i

evaluates the human intruder pathway. In addition, consistent j with the technical position, groundwater considerations are also j evaluated, when necessary, because of site specific hydrogeologic

features and groundwater use. Dose from the ground water pathway should not exceed 3 mrad /yr to the bone (approximately 1.8 i

i ~ , ._ _- _ __ _. .

nron/yr committed EDE) consistent with the stated dose basis for '

. the option 1 concentration values. Dose from the human intruder

. . pathway should not exceed 170 mrem /yr to the critical organ. For

. soluble uranium, the critical organ is the bone. For insoluble i uranium, the critical crgan is the lung. For thorium, both soluble and insoluble, the critical organ is the whole body.

The dose of 170 mrem /yr to the whole body, from Option 2 concentrations of thorium, via the human intruder pathway, may be

,. unacceptably high. Further, this 170 mrem /yr whole body dose

) assumes a 0.8 occupancy factor and a 0.5 shielding factor. If j the occupancy and shielding factors are set to 1, the dose from 4

thorium may be as high as 420 mrem /yr to the whole body.

Therefore, for thorium concentrations above the option i limit,

< the 10 CFR 20 limit of 100 mrem /yr TEDE may be the appropriate unrestricted use release limit. The intruder exposure pathway could possibly be ignored when the disposal method makes the chance of future human access very remote, such as via deep

disposal, or disposal by mine backfill.

Disposals under Option 2 that involve depleted or enriched i uranium, are evaluated for buildup of decay products for a period of 1000 years. The original dose assessments to determine the Option 2 limits for depleted and enriched uranium did not include decay products because the decay products are removed in processing the uranium. Significant ingrowth of the decay i products requires more than one thousand years and has not been routinely considered in assessing the acceptability of the disposals under' option 2 aven though potential doses may increase considerably with time (i.e., beyond 10,000 years).

1 Table 2 lists the option 2 concentrations along with their stated.

dose bases and estimated current dose bases calculated using the RESRAD computer code that contains contemporary dosimetry and exposure assumptions. It should be noted that the use of RESRAD and its default parameter assumptions may not be appropriate for ,

specific regulatory decisions depending on site conditions and '

characteristics, which may render RESRAD estimates too

conservative or non-conservative.

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Tablo 2. Concentrations and Doso Bases for Option 2 of the 1981 Branch Technical Position (BTP).

Stated Estimated Dose Dose Basis Contamination Criterion Basis (EDE)

Natural Thorium 50 pCi/gm 170 mrem /yr 170 - 420 mrem / yr Depleted Uranium 100 pCi/gm 170 mrem /yr 5 - 50 (soluble) (bone) arem/yr 300 pCi/gm 170 mrem /yr 20 - 68 1 (insoluble) (lung) arem/yr 1

l Enriched Uranium 100 pCi/gm 170 mrem /yr 5 - 52 I (soluble) (bone) mrem /yr l 250 pCi/gm 170 mrem /yr 20 - 42 (insoluble) (lung) mrem /yr I

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. EPA's National Primary Drinking Water Standards

. . for Radionuclides i

j

NRC staff has applied EPA's National Primary Drinking Water

Standards on a case-by-case basis to the cleanup and l decommissioning of contaminated sites to ensure adequate l

protection of groundwater and surface water resources. These standards could be applied as criteria for limiting radiation i exposures via the ingestion pathway. This approach is explicitly l recognized in NMSS Policy and Guidance Directive FC 83-23. EPA l promulgated interim drinking water standards for radionuclides in i 1976 at 40 CFR 141.15 and 141.16 for combined "Ra/"Ra (5 pci/1), gross-alpha particle activity (15 pCi/1, excluding radon  ;

! and uranium), and beta particle and photon emitters (4 mrem /yr i i for " man-made" radionuclides). The standards are applicable to

! public drinking water systems and are enforced at the tap. ,

i Although they are not strictly applicable to the protection of l 1

groundwater and surface water resources, NRC and other agencies 1 (including EPA and States) have applied these standards as i l objectives and guides for water resource protection. This extension of the applicability of the drinking water standards

! has been justified based on the paucity of other suitable

, criteria for water resource protection and on the health and  ;

l technological feasibility basis of the drinking water standards. l l' This approach is also consistent with EPA policy for groundwater )

protection. In recent years, EPA has actually adopted the l drinking water standards for groundwater and surface water {

protection purposes at uranium mill tailings sites (40 CFR Part i 192, Subparts D and E and proposed Subparts A - C). The dose associated with the standard for beta and photon emitters is 4 area /yr. Assuming ingestion of 2 liters of drinking water per day over a 50-year period, the dose associated with the 5 pCi/l standard for "Ra would be about 5 mram/yr using the dose conversion factors provided in EPA's Federal Guidance. Report No.

11. It is difficult to convert the 15 pCi/l standard'for gro.s- i alpha particle activity to dose because gross-alpha is a screening parameter for a variety of alpha ~ emitting radionuclides and the dose is a function of the energy and characteristics of

)

the alpha decay and biological parameters for each radionuclide.

On July 18, 1991, EPA proposed an increase in the drinking water standard for radium from 5 pCi/l combined "1ta/*Ra to 20 pCi/l for each radionuclide (56 EE 33050) . EPA has also proposed in the same rulemaking new drinking water standards for uranium (20 ug/l or 30 pCi/1) and for radon-222 (300 pCi/1). The values of the beta / photon and gross-alpha standards would remain the same, except that the gross-alpha standard would now exclude alpha activity contributed by radium-226. NRC's October 16, 1991 comments to EPA on the proposed rulemaking raised significant concerns about the proposed revisions to the drinking water standards, including ambiguity associated with the documented risk and radiological dose assessments that support the proposed drinking water standards; the need for EPA to assess indirect impacts of the new drinking water standards caused by their.

applications to other program areas (e.g., decommissioning and waste management); and the need for guidance on how to apply the

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uraniun standard in si'"ations whnre the uranium has been

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l4 COMMERCIALLY I AVAILABLE LOW-LEVEL l$

- RADIOACTIVE AND MIXED '

WASTE TREATMENT E TECHNOLOGIES E

NationalLow-Level Waste i Management Program

g October 1996 i

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L oc xxu so ma n ring weae veronet Enginerfng tenorstery Lockheed Martin Idaho Technologies Company P. O. Box 1625 Idaho Ts:Is. ID 83415 2423

'eiepene cC8 5:6-cm Fe:iiriite i:04) 526 t65 October 3,1996 i

nieributinn TRANSMITTAL OF THE DOCUMENT ENTITLED COMMERCIALLTA PA1LABLE LOW-LEVEL RADIOACTIVE AND MLYED WASTE TREA TMENT TECHNOLOGIES. DOEILLW-240

- RSG-16-96 Enclosed you will find a copy of the report er. titled. Commercially Avallable Iow-Level Radioacrae and Mixed Waste Treatment Tecimo!o.eies. DOE'LLW-240. for vou use.

This report provides a disemier. oflow level radioactive waste (LLW) and mixed waste (MW) streams that are commercially generated in the Uni:ed States. Treatment technologies that are currently available to cormnercial LLW and MW generators are also discussed. Discussions include what LLW and MW streams exist in tFe commercial sennt, the current commercially available treatments for those wastes, technical information regarding those specific waste uvatements, and venders that are currently availab!c to provide a service to treat waste. Vendors listed have the capability of treating waste at their facility. bring a mobile unit into the field for on site treatment, or provide a unique product for trea: ment nicomtmercially-generated i LW or MW.

this document will be upda:ed periodically as treatment technologies and vendors become more sophisticated to meet industry demands. If you have questions re2arding this inthrrnation, please contact me at (208) 526 0483.

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Russell S. Garcia National Low Level M aste Management Program sif Enclosure

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h ISCORS Subcommittee on Recycling 1

Meeting Notes November 19,1996 j 1:00 - 4:0n p.m.

Summary I EPA has been meeting with interested stakeholders, such as States, nuclear groups, the steel

i. industry, environmentalists, and EPA regional offices. Many stakeholders confused the scrap

metal rulemaking with BRC (Below Regulatory Concern) efforts, which dealt with exemptions 1 p from regulatory control. EPA found that few groups were aware of the on-going recycling )

j. practices or the existing NRC Regulatory Guide 1.86 criteria. As a result, stakeholders 1 j expressed a wide range of views on EPA's proposal.

i'

{ In mid-October, the Environmental Law Institute held a workshop with the stakeholders on

recycling scrap metal from nuclear facilities. A draft report will be available in December, i

i EPA plans to continue meeting with specific stakeholders, such as steel industry companies.

Following release of a pre-proposal rule in 1997, EPA is considering a workshop and articles l

]

in tradejournals. EPA is still in favor of replacing the current guidance in NRC Regulatory

Guide 1.86 with a dose- or risk-based standard.

L John MacKinney presented some preliminary calculated doses for various radionuclides based f

~

on the IAEA document TECDOC-855 and Reg Guide 1.86. EPA plans to assess collective

impacts in December and conduct uncertainty and sensitivity analysis in January.

. At the October 10 ISCORS meeting, the ISCORS members were concerned that the NRC and

EPA rulemaking models are compatible, but not identical, and therefore produce different

results. The members suggested the subcommittee chose one model or explain the differences l- in the NRC, EPA and DOE models and then resolve them. Based on this ISCORS direction, NRC, EPA and DOE resumed discussions from earlier meetings on the possibility of replacing l

the models under development at each of their agencies with one model. Each agency came to l the meeting with a set of criteria for selecting an ideal code (see Attachment 1). The criteria included (1) the ability to include both recycle and reuse scenarios, (2) the ability to address j various metals and scenarios, and (3) flexibility to update the code. Bob Meck stated concerns

) that the exercise to define characteristics of an ideal code might be an empty exercise, because j all of the agencies already have well developed models. Further, understanding the differences and resolving them is not only inevitable for arriving at a uniform model, but is what EPA, DOE, and NRC have been doing since April 1996. The group agreed to continue

! this discussion at the next meeting by bringing specific purposes for the ideal code. John MacKinney and Bob Meck will work on' consolidating the decision criteria for selecting a

^

1 1

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single code for future development. '

The next meeting will be December 20, at 9 am at EPA.

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Attachment 1: Model Selection Criteria Group Model Criteria Presented on the Flip Chart (November 19,1996)

1. Comprehensive Assessment which includes surface and mass measures and recycle, reuse scenarios

2. Model Purpose - Support the metal rulemaking.

3. Flexible - Able to include various metals and scenarios  !

4. Model should be expandable with relative east and cost.

1, Model Criteria Stephen Warren / Daniel D. Burns I DOE-EM 40/ Trinity Environmental Systems, Inc.

Overview The first question which requires resolution is, what is the purpose of the model and who will it be used by? The desired model attributes are significantly more complex if the model chosen is to be used by field organizations for site specific assessment rather than to provide a technical base for rules and regulation development. The remaining sections of this paper are organized in a manner to describe the model attributes consistent with its intended use; by regulators and their support staff for rule development and by field personnel for site specific implementation.

The following general questions are used to organize the ensuing discussion. Questions 17 2 and 3 are applicable to the attributes needed for the more limited needs associated with regulators and their support staff for rules development, while all five are appropriate for site level implementation.

1. Does the release scenario reflect reality; is it independently supported?

2. Does the dose estimating code utilize accepted mathematical models for calculating dose?

3. Has the model been validated; is it accepted in the scientific / regulatory community?

4. Is the model responsive to site specific inputs; is it user friendly?

5. Does the model generate reports adequate to review / reconstruct the dose assessments

1) Is the basis for selecting the release scenario (s) modeled independently supported? Does the documentation for the model reference independent source material (e.g.,

industry / association

reports, engineering analyses, feed and product specifications, rule making background information documents) to adequately support:

feed material specifications and constraints definition of mass m.J constituent balances material handling practices material processing conditions process yields and waste generation rates  !

product and waste stream compositions i

Is the basis for pathways assumptions supported independently? Does the documentation for l the model reference independent sources (e.g., ICRP, NCRP, regulatory exposure limits, I administrative controls, industrial hygiene monitoring reports, sampling and analysis results, )'

time / motion studies, chemical / physical property databases) to adequately support:

l exposure pathways modeled l partitioning factors for radionuclides l basis for number ofindividuals exposed- )

basis for duration of exposures basis for conversion, and fate and transport factors

2) Does the model adopt and properly utilize accepted mathematical models for calculating dose?

mathematical models described in documentation simplifying assumptions required for implementation described user ability to influence mathematical model justified

3) Has the model been validated? Is it accepted in the scientific / regulatory community?

has the model (code) been peer reviewed and the review documented has the model been verified using an alternate computational method (e.g.,

spreadsheet) have actual worker exposures been monitored and compared to predicted values has the model been published in a technical or trade journal what regulatory agencies are currently using the model how many projects has the model been used on to date has the model been used to support final release of slightly contaminated material have results from completed modeling efforts been peer reviewed / published

l I

4) Is the model responsive to site specific inputs? )

can the user fully specify feed input characteristics can the user select processing steps to be modeled can the user define unit operations process parameters Is the model user friendly? Criteria which may be useful evaluating include:

can an end user run the software or does it require a specialist if a user can run the software, is training required to run the code or is it self explanatory

• does .he code guide the user through a session does the code issue warnings when user specified parameters are outside advisory ranges what are the platform / system requires to run the software .]

what type of technical support is available to run the software

5) Does the model generate reports adequate to review / reconstruct the dose assessment?

are all feed stream characteristics documented )

are unit operations / process through which materials pass defined are process parameters defined j does the code generate tables which break down dose by:

exposure pathway radionuclide process step / unit operation could the dose assessment by reconstructed solely using the reports generate Code Selection Criteria for Settling Standards for Reuse or Recycle of Radioactively l

Contaminated Material and Equipment Andy Wallo DOE - Office of Environment, Safety, and Health -

1 I

$ Code could be designed for a comprehensive assessment of dose and risk associated with release of radioactive material and reuse of tools and equipment.

5 Code should address both volume and surface contamination.

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$ Code should have a sufficient radionuclide database covering all radionuclides of i interest and a state-of-the-science dose conversion factors database.

$ Code should address both short-term and long-term (lifetime of the product) risk. (That is, radioactive decay and daughter ingrowth should be considered.)

$ Code should address both workers aud users of finished products.

R Code should address both individual and collective risks and doses.

$ Code should incorporate all processing steps and representative scenarios that are significant to the entire recycling problem.

$ Code should have the capability to accommodate modifications of parameters as well as modifications of geometry for various scenarios.

M Code should use the latest methodology and parameters available in recent studies and literature.

5 Code should be able to perform probabilistic uncertainty analysis.

$ Code should have a user's manual documenting its methodology and databases.

$ Code should be easy to use and the results can be verified and reproduced.

Criteria for Selection of Recycling Rule Modeling Tool - General Criteria John MacKinney EPA- Office of Radiation and Indoor Air ,

1 l

1. Code should be verified (to detect program errors, test algorithms)

2. Should be validated against field observations (if possible)

3. Should be a compiled executable code that runs rapidly

4. Hardware requirements should be compatible with those available (PC based, runs directly under DOS or Windows), and does not require possession of, and expertise in other proprietary software (e.g., spreadsheets).

5. Code should be well documented

4

6. Should have a basis for regulatory acceptance (e.g., components like CAP-88, GENII,...)

7. Should have widespread scientific acceptance (source code should be available for inspection).

8. Must be flexible such that it can be used to derive radiation doses for multiple pathways, a broad range of radionuclides, can be readily modified to accommodate alternative assumptions and calculated parameters.

9. Should explicitly address radioactive decay and progeny in growth

10. Should use EPA Federal Guidance for dose and risk factors.

11. Should present results in terms of committed effective dose equivalents.

12. Should present results in terms of lifetime risk of cancer, morbidity and fatality. 1 l

13. Should present collective impacts in dose in person-rem and cancer morbidity and fatality.

14. Should perform sensitivity and uncertainty analyses.

l Specific Criteria R Capable of calculating the committed effective dose equivalent to industrial workers I and members of the public, and collective impacts te populations who may come into contact with the radionuclides contained in residually contaminated scrap, and the various end products associated with metal recycling, including steel products, bag house dust, and slag.

-5 Capable of deriving impacts from the full range of exposure pathways, including direct radiation for various geometries, dust inhalation, soot ingestion, and the ingestion of food items and water that may become contaminated as a result of the free release of scrap 5 Capable of modeling short-term and chronic atmospheric release rates, airborne dispersion and deposition, and the exposures associated with a full range of airborne pathways, including external exposure to airborne

radionuclides, inhalation exposure from airborne radionuclides, external exposure to deposited radionuclides, and internal exposure from the ingestion of foods contaminated as a result of the airborne deposition of radionuclides.

Modeling Criteria Bob Meck NRC - NMSS I) Applicable to Agency needs.

A) Choices of:

I) materials ii) radionuclides lii) scenarios - human activities a) Occupancy b) Geometry c) Breathing d) Significance of pathways B) Regulatory Stability II) Technical Defensible A) Transparency of model, assumptions, equations B) QA/QC documentation C) Conservatism vs. Realism D) Uncertainty quantitation E) Internal Consistency (SC&A uses different parameters for different uses but same physical process)

III) Useable A) Flexibility (encode for PC vs. Spreadsheet for PC)

B) Ease of updating C) AUser friendliness 0

')

Attachment 2: Final Agenda ISCORS Recycle Subcommittee Meeting November 19, 1996

. 1-4 p.m.

4 First Floor Conference Room i EPA Judiciary Square Building i

4 i

1:00 - 1:10 Introduction - John Karhnak (EPA) 1:10 - 1:30 EPA Public participation and outreach - Miles Kahn (EPA)

- Status of stakeholder meetings

- Future outreach activities I

1:30 - 2:00 EPA Risk Assessment Preliminary Results - John MacKinney (EPA) l 2:00 - 3:00 Model Selection - John Karhnak (EPA) and Cheryl Trottier (NRC) 3:00 - 3:20 DOE Issues 3:20 - 3:40 NRC Issues 3:40 - 4:00 Next Steps

-list action items

- set-up next meeting (within three months)

. o Attachment 3: Attendance List Name Agency Phone Fax e-mail John Karhnak EPA (202) 233 - 9280 x9650 karhnak. john @epamail. epa. gov i Reid Harvey EPA (202) 233 - 9429 x9650 harvey.reid@epamail. epa. gov Paul Bubbosh EPA (202) 233 - 9383 x9650 bubbosh. paul @epamail. epa. gov Ben Hull EPA (202) 233 - 9382 x9650 hull. benjamin @epamail. epa. gov John MacKinney EPA (202) 233 - 9487 x9650 mackinney. john @epamail. epa. gov Carey Johnston EPA (202) 233 - 9341 x9650 johnston.carey@epamail. epa. gov Miles Kahn EPA (202) 233 - 9384 x9650 kahn. miles @epamail. epa. gov l Bob Meck NRC (301) 415 - 6205 x5389 ram 2@nrc. gov Phyllis Sobel NRC (301) 415 - 6714 x5397 pas @nrc. gov Frank Cardile NRC (301) 415 - 6185 492-3866 Jim Firth NRC (301) 415 - I Andy WalloDOE (202) 586 - 4996 896-4996 l Stephen Warren DOE (301) 903- 7673 x3479 stephen. warren @em. doe. gov ]

. e DISCLAIMER These ISCORS subcomittee meeting sumaries result from interagency discussions. The Risk Harmonization Subcommittee is composed of representatives from the Environmental Protection Agency, Nuclear Regulatory Comission, Department of Defense, Department of Energy, Department of Transportation, and Department of Health and Human Services.

The subcommittee meeting sumaries have not been approved by the respective federal agencies and do not represent the official position of any participating agency at this time.

ISCORS RISK HARMONIZATION SUBCOMMITTEE MEETING NOVEMBER 20, 1996 MEETING

SUMMARY

ATTENDEES: From NRC: Margaret Federline, Judi Greenwald, Charlie Willis, Bob Nelson. From EPA: Dennis O'Connor, Allan Richardson, William Russo, Jackie Dzutian. From DOE: Andy Wallo, G. Roles, Colleen Ostrowski. From D00: Mike Schaeffer. From DOT: Fred Ferate.

AGENDA:

1 to 1:15 p.m.: INTRODUCTION; APPROVE MEETING

SUMMARY

FROM LAST MEETING 1:15 p.m. to 3:15 p.m. PLANNING FOR FEBRUARY 11(?) ISCORS MEETING ON PARADIGM SHIFT

--Establish agenda for February (?) ISCORS meeting

--Establish schedule and action items

--Lay out what the paradigms are, and what the advantages and disadvantages are of each approach 3:15 to 3:45 p.m.: DISCUSS OTHER SUBCOMMITTEE ACTIVITIES; PRIORITIES 3:45 to 4 p.m. REVIEW ACTION ITEMS l SUPMARY:

Margaret Federline of NRC, the new co-chair (replacing Mike Weber) was l introduced. The subcomittee agreed to recomend that the full ISCORS l committee discuss the issue of interagency cooperation to maintain core {

research capabilities in a number of areas. The subcomittee agreed that, j once the agency views are exchanged in January, we will need to develop a path forward on the comparative risk paper.

We then moved on to a discussion of the paradigm shift. EPA, NRC, and DOE  ;

presented somewhat different views of what the paradigm is, and what we are i shifting from and to. We eventually agreed that the focus should be on the use of institutional controls. The subcomittee agreed to try to come up with

1 l

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} . a joint briefing and that, as a fallback position, each agency may need to do its own briefing.

The next meeting will be Wednesday, December 18 from 9 a.m. to 12 noon at EPA's Judiciary Square Offices.

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. . _ _ - ~ _ _ __ _ ___ _ . - . . - .. _ _ _ _ _ _ _ _ _ _ _ . _ _ . _.

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i DISCLAIMER These ISCORS subcommittee meeting summaries result from interagency 2 discussions. The Risk Harmonization Subcommittee is composed of

representatives from the Environmental Protection Agency, Nuclear Regulatory Commission, Department of Defense, Department of Energy, i Department of Transportation, and Department of Health _ and Human Services.

The subcommittee meeting summaries have not been approved by the respective l l federal agencies and do not represent the official position of any I participating agency at this time, i

FINAL MEETING

SUMMARY

ISCORS RISK HARMONIZATION SUBCOMMITTEE MEETING i WEDNESDAY, DECEMBER 18, 1996 l

The Interagency Steering Committee on Radiation Standards (ISCORS) Risk Harmonization Subcommittee met to plan for the presentation it is to make at the February 11 ISCORS Meeting. The presentation will describe the current use of institutional controls in waste management and options for such use in the future.

It was noted that federal agencies are struggling to implement often conflicting policies on the use of institutional controls and the analytical assumptions one should make on institutional controls. It was also noted that harmonization of institutional control policies is a prerequisite for harmonization on risk goals, because the same numerical risk goal can translate into very different risk management strategies, depending upon the institutional control regimes.

4 j . *#

• DISCLAIMER

. These ISCORS subcommittee meeting summaries result from interagency 4

discussions. The Sewage Subcommittee is composed of representatives from the Environmental Protection Agency. Nuclear Regulatory Commission.

Department of Defense, and Department of Energy. The subcommittee meeting

summaries have not been approved by the respective federal agencies and do

, not represent the official position of any participating agency at this time.

I I

ISCORS SEWAGE SUBCOMMITTEE MEETING

SUMMARY

I o

Date: November 7, 1996 l l

Time: 1:00 to 3:30 pm l

Location

NRC. Two White Flint North. T10A1 Attendees: NRC: Phyllis Sobel . Bob Neel . Lee Abramson. Chris Daily. I Tom O'Brien. Bob Nelson, Joe DeCicco j EPA: Bob Bastian. Mark Doehnert j DOE: Jim Bachmaier EPA /NAREL: Dave Saunders i Agenda: Sewage survey POTW Guidance document 4

s Summary:

The subcommittee members agreed on the list of radionuclides which will

! receive additional isotope-specific alpha or beta analysis. Rather than choosing an action level at this time, the labs will analyze all the test case Jl samples for the following radionuclides:

- Beta emitters C-14 (0 RISE only). Sr-89/90 i Alpha emitters -

j Ra-226. Th-227/228/230/232. U-234/235/238. Pu-238/239 Am-241 X-ray emitter - I-125 Bob Bastian will make several minor changes to the letter with the l questionnaire and send it to the POTWs. The subcommittee will send Phyllis Sobel their comments on the letter with the sample collection packages.

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Bob asked NRC to consider asking the licensees associated with the test case 1 POTWs for information about their discharges to the sewer system. The l subcommittee discussed the possibility of sampling sludge entering the sewer system from DOE sites associated with several of the-test cases..

! Phyllis has begun contacting Agreement States to request lists of licensees

! associated with.the zip codes in the POTW collection systems for the test cases.

Dave Saunders' summarized the draft radiochemical analysis decision tree. This l decision tree will be discussed further at the next lab working group conference phone call. This phone call will also discuss what are " elevated" levels of radionuclides. Saunders will send a spread sheet that NAREL plans

to use for comparison of gamma spectroscopy results to gross alpha and gross l beta radioactivity. This program will help decide if further wet chemical l

analyses are necessary.

The group discussed whether to restrict the survey to the contiguous United States'and the District of Columbia. We decided to also include Alaska.

Hawaii and Pwrto Rico. Results from Alaska and Hawaii POTWs will be grouped with the west coast sites and Puerto Rico with the southeastern U.S. sites in the final report.

Phyllis distributed the redrafted OMB Supporting Statement and will take comments from the subcommittee members before placing it in concurrence.

The NRC's Office of Research will estimate the exposures associated with handling and disposal of sludge and ash. These results will be used to prepare screening tables for the guidance document. The subcommittee reviewed and approved the generic scenarios associated with the modeling. The l screening table will be based on an exposure of 100 mrem /yr.  ;

1 Phyllis presented a outline of the revised guidance document and several  ;

members suggested changes. She will draft the revised document this month.

l Action Items:

1. Bob Bastian will send the letter with the questionnaire to the POTW test cases.

2. The subcommittee will send Phyllis Sobel any comments on the letter with the-sample collection packages by November 14.

3. NRC will consider asking the licensees associated with the test case POTWs

- for information about their discharges to the sewer system.

I j 4. Dave Saunders will check with Mary Wisdom on the status of the Quality i

Assurance Program Plan.

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5. Phyllis Sobel will schedule a lab working group phone call to discuss the i radiochemical analysis decision tree, the Quality Assurance Program Plan, and what are " elevated" levels of radionuclides.

6. The subcommittee will send Phyllis Sobel any comments on the OMB Supporting Statement by November 14.

7. Bob Bastian will meet with NRC to discuss the parameters in the exposure scenarios.

8. Phyllis Sobel will draft a revised guidance document. I

9. Phyllis Sobel will set up the next subcommittee meeting in January. It l will cover the following topics:  !

Results of analyses on test sites Licensees associated with the test cases Selection of POTWs to receive the questionnaire What are " elevated" levels of radionuclides Draft #2 of the guidance document Status of dose modeling I

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DISCLAIMER These ISCORS subcommittee meeting summaries result from interagency discussions. The Sewage Subcommittee is composed of representatives from the Environmental Protection Agency, Nuclear Regulatory Commission, Department of Defense, and Department of Energy. The subcommittee meeting summaries have not been approved by the respective federal agencies and do not represent the official position of any participating agency at this time.

ISCORS SEWAGE SUBCOMMITTEE MEETING

SUMMARY

Date: January 22, 1997 Time: 9:00 to 11:30 am Location: NRC, Two White Flint North Attendees: NRC: Phyllis Sobel, Bob Neel, Chris Daily, Tom O'Brien EPA: Bob Bastian, Paula Goode DOE: Jim Bachmaier D0": Roy Lovett EPA!HAREL: Dave Saunders, Clint Cox, Mary Wisdom ORISE: Mark Laudeman Agenda: P0TW Guidance document Sewage survey Summary:

The subcommittee discussed the December 1996 draft of the guidance document.

We agreed to move some of the background sections on radiation to an appendix and add an appendix with a case study. We also will consider adding some of the ideas in a paper submitted by Mark Miller, who is associated with the Albuquerque POTW. We will also consider adding a discussion of releases from facilities with unlicensed radioactive materials. Tom O'Brien suggested adding material from NRC Regulatory Guide 8.29 on consumer products. RES has not yet begun the dose modeling which will form the basis for a table of acceptable concentrations of radionuclides in sludge and ash.

The Federal Register notice on the OMB supporting statement for the survey was published January 6, 1997. The next Federal Register notice on the survey will be published after the public comment period ends (March 7) and after the analyses of the test sites are completed.

All the questionnaires were returned from the test sites and NRC is developing a summary of the responses. The sample collection packages were sent to the

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remaining 7 test sites in early January and several POTWs have returned the  :

! packages with the samples. Several DOE labs associated with POTW test sites l are sending samples from their sewer lines to ORISE and NAREL for analysis. '

i NRC is developing the list of licensees associated with the test sites from i

the zip code information in the questionnaire responses, j Among the lessons learned so far are that the questionnaire should include the ,

i location to send the sample collection packages and a question on the nature i

, of the material being sampled from each sludge use or disposal practice l i (liquid, dried cake, pellets, etc.) The Chain of Custody form will need to 1

add the name of the POTW and clearer procedures for completing the form.

$ Tom O'Brien and Bob Neel presented a revised decision tree for the additional radiochemical analysis. The action levels for additional radiochemical ,

analysis for specific radionuclides are tentatively set at 15 pCi/g for gross  !

alpha and 25 pCi/g for gross beta results, based on the results of the AMSA

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survey. These actions levels will be re-examined after the test sites are ,

analyzed and again after several months of survey results. Following current  !

practice, the MDAs should-be 10% of these AMSA values. It is expected that l most of the additional radiochemical analysis will be on ash samples from l incinerators, because in the AMSA survey most of the higher gross alpha and beta results were from the ash samples.

Mary Wisdom distributed a first draft of the Quality Assurance Program Plan (QAPP) and asked for inputs. Although ORISE can analyze samples under their own QA plan, ORISE must have the QAPP in place for each project. It is expected that the QAPP will be signed by NAREL, ORISE and EPA /HQ. .

Phyllis Sobel discussed the planned procedure for selecting POTWs for the ,

questionnaire. The procedure is designed to (1) maximize measurements of high i radioactivity at POTWs and (2) measure radioactive materials in sewage sludge and ash from the incineration of sewage sludge at POTWs across the U.S. The list of POTWs to be sent the questionnaire will be developed as follows: (1) determine POTWs associated with licensees with the greatest potential for discharge, (2) sample many of the P0TWs with incinerators, (3) ensure that the POTWs are in all geographic areas of the contiguous U.S. (if not, consider adding POTWs from the 479 POTWs selected to receive the questionnaire in the  ;

EPA 1988-89 National Sewage Sludge Survey (NSSS), (4) add any POTWs which for j some reason should be included (e.g. unusual sludge use/ disposal practices or the wastewater collection system receives discharges of drinking water treatment residuals), and (5) add POTWs requested by other ISCORS agencies or i other interested groups. NRC developed a list of NRC licensees that have the '

greatest potential for discharge. Bob Bastian will help establish a list of POTWs associated with these licensees.

The next meeting will be on March 12 from 9 to 11:30 am. At this meeting we will discuss the next draft of the guidance document, the results of dose modeling for the guidance document, the lab's results on the test sites, the first draft of the report on the test sites, the QAPP, and the next Federal Register notice on the survey.

Action Items:

1. The subcommittee will send comments on the guidance document to Phyllis

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Sob'el by February 3. She will send a revised draft to the subcommittee before the next subcommittee meeting.

2. The subcommittee will send Mary Wisdom comments on the QAPP by February 10 so she can circulate a revised draft by February 20.

3. Bob Neel will schedule a lab working group phone call on February 24 to discuss the QAPP and the analytical results of the test sites.

4. Phyllis Sobel will schedule a meeting with Bob Bastian, Chuck White, Lee .

Abramson, and Bob Neel to discuss the procedures for selecting POTWS to  !

receive the questionnaire and to be sampled. '

5. Phyllis Sobel will determine the licensees associated with the test sites.

6. The subcommittee will send comments on the outline of the report on the test sites to Phyllis Sobel.  !

7. ORISE will revise the Chain of Custody form.

8. The labs will analyze the samples before March 7 (if the samples arrive at the labs in time). (March 7 is the same date the public comments on the I Federal Register notice are due.)

9. Phyllis Sobel will draft a second Federal Register notice on the survey, which includes a revised OMB supporting statement, a revised questionnaire, and the report on the test sites.

Old Action Items Which Have Not Been Completed:

1. NRC (Nelson) will consider sending the test POTWs (1) a list of those i licensees who discharge into their collection system and (2) the analysis results for that POTW.

2. The labs will complete the additional radiochemical analysis on the samples from the first two test sites.

3. Bob Bastian will meet with NRC to discuss the parameters in the exposure scenarios.

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