ML20137V652

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Requests Technical Assistance to Determine If Passing Radioactive Liquid Effluents Through 0.45 Micron Filter Adequate Methodology to Insure Compliance with 10CFR20.2003(a)(1),licensed Matl Readily Soluble in Water
ML20137V652
Person / Time
Issue date: 02/20/1997
From: Madera J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Cool D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20137V631 List:
References
NUDOCS 9704170367
Download: ML20137V652 (3)


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REGIONAL TECHNICAL ASSISTANCE REQUEST FORM Dste: Februarv 20.1997 MaH or E-Mail to:

Donald A. Cool (DAC), Mail Stop: 6H3-OWFN, If E-rnail, cc: CLE Division ofinaustrial and Medical Nuclear Safety, NMSS From: John htadern A-

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- Region M Chief, Nucles als inspection Branch I Licensee: CERAC. Inc.

License No. SMB-1402 0 ControlNo.

(if applicable)

O Letter dated:

(if applicable) a Suggested change in licensing procedure (enclosed):

O Problern//ssue:

The licensee possesses an NRC license to process natural thorium which results in radioactive liquid and air effluent releases to the environment. On December 18,1996, the NRCidentified the licensee had not determined the activity or solubility ofliquid effluent discharges into the sanitary sewer system. The licensee's immediate corrective action was to hold allliquid effluent discharges generatedfrom licensed cctivities in 55 gallon drums until the liquid could be analyzedfor activity and solubility. Prior to placing the liquid efluent into 55 gallon containers, the licenseefiltered the water with a 0.45 micronfilter to remove suspended solids in the liquid. In addition, thelicensee also possesses a water scrubber which removes licensed materialfrom air effluent discharges prior to release to the environment.

Tise licensee sent afaxed letter to the NRC dated February 19,1997 which contains analysis data of water s:ngpies takenfrom 13 55 gallon (2.09ES milliliter) containers (One samplefrom each container) and the scrubber holding reservoir. According to the licensee, each sample was analyzedfor dissolved (soluble) and suspended (insoluble) licensed material. The licensee stated that allgross alpha activity was assumed to be thorium-232 decay. According to the licensee, licensed activities generate approximately 14 55 gallon drums (2.93E6 milliliters)per month.

In afaxed letter to the NRC dated February 11,1997, the licensee stated that approximately 5.44E5 gallons (2.07E9 milliliters) of waterpr month was used by the licensee and sent through the sanitary sewer system.

According to the licensee's calculations in the above letter, one 55 gallon container containing 3E5 microcuries per milliliter oflicensed material would be approximately 1% ofthe monthly sanitary sewer release limit (see 10 CFR 20, Appendix B, table 3: thorium-232). In addition assuming the licensee generates approximately 14 55 gallon ofradioactive liquid effluent per month into the sanitary sewer system, the licensee's water dilutionfactor is approximately 3 orders ofmagnitude.

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The licensee is requesting that radioactive liquid effluentfiltered through a 0.45 micronfilter be placed directly into the sanitary sewer system withoutfurther testing. The licensee stated that NRC Information Notice 94-07 referencing ASTM D 1888-78 " Standard Test Methodsfor Particulate and Dissolved Matter, l

Solids, or Residue in Water" infers that alllicensed materialpassing through a 0.45 micronfilter is considered solublefor the purposes ofreleasing licensed materialinto the sanitary sewer system and that the mentionedfiltering system can be used to demonstrate solubility ofradioactive liquid effluent discharges into the sanitary sewer system.

O Action Required:

Determine sfpassing radioactive liquid effluents through a 0.45 micronfilter is an adequate methodology to l

insure compliance with 10 CFR 20.2003(a)(1), licensed materialis readily soluble in water.

l 0 RecommendedAction (with revisions): D Approve or D Reject l

The region believes thatpassing radioactive liquid effluents through a 0.45 micronfilter is an adequate methodology to insure compliance with 10 CFR 20.2003(a)(1). As supporting evidence, NRCInformation l

Notice 94-07 referencing ASTM D 1888-78 " Standard Test Methodsfor Particulate and Dissolved Matter, 1

Solids, or Residue in Water" does appear to infer water passed through a 0.45 micronfilter does not contain significant quantities ofsuspendedsolids. In addition, the region believes the small quantity of"suspendcd" l

licensed materialidentsfied by the licensee in the SS gallon containers and scrubber holding reservoir combined with the 544,000 gallon dilution waterfrom the licensee'sfacility into the sanitary sewer system does notpose a significant health risk to members ofthe generalpublic.

Remarks:

Enclosed are the documents, in whole or in part, as stated above.

Ifyou have any questions, please contact Michael M. LaFranzo by phone, 630-829-9865 or E-mail, address MML.

l AttachmentA:

Licensec letter dated February 19,1997 l

Attachment B:

Licensee letter dated February 11,1997 Attachment C:

NRCInformation Notice 94-07 Attachment D:

ASTM D 1888-78 " Standard Test Methodsfor Particulate and Dissolved Matter, Solids, or Residue in Water" Headquarters Reviewer: Joseph DeCicco RegionalReviewer: MichaelLaFranzo Reviewer Code: M7L Reviewer Phone No.: (630) 829-9865 Fax No.: (708) 515-1259 l

Request Needed by: 3 /3 /97 (date) i i

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l Inspector, RIII Form TAR-1010/96 l

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