ML20147B299
| ML20147B299 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1996 |
| From: | Sobel P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9701300196 | |
| Download: ML20147B299 (15) | |
Text
o.-
October 29, 1996 1
)
MEMORANDUM T0:
File FROM:
Phyllis Sobel
[0RIGINAL SIGNED BY:]
{
SUBJECT:
MEETING SUMMARIES OF INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS (ISCORS) SUBCOMMITTEE MEETINGS.
Attached are summaries of ISCORS subcommittee meetings in July and August 1996. These meeting summaries are being placed in the NRC's Public Document Room.
l
Attachment:
As stated cc:
Paula Goode. EPA /0RIA TICKET:
N/A DISTRIBUTION:
Central File LLDP r/f PUBLIC l
DOCUMENT NAME:
S:\\DWM\\LLDP\\ PAS \\SUBSUMM 0FC LLDP LLDPa/h
,LL,DP NAMi PSobe @ ' ~RNed5d
[MWeber l
l l DATE 10 6)/96 10M96 10/7/96
[
1 0FFICIAL RECORD COPY l
l ACNW: YES X
NO n Category:
Proprietary or CF Only l
IG
- YES NO l
LSS. YES NO
% Delete file after distribution:
Yes / No 1
i (9 a u) l l
l l
AJ L l'/ ' I yJ17)d T3CfIA g.; j)). (o > YU NI]
l P)
O $'
Eo RETURN TO REGULATORY CENTMt Fl! F i
[6 Y A
_-___..~._.... __.. - _.. - _.
s ** "8 cog
[-
f*.
UNITED STATES j
.j NUCLEAR REGULATORY COMMISSION
's WASHINGTON, D.C. 20555 0001 j
o
%q o
g October 29, 1996 l
MEMORANDUM T0:
File FROM:
Phyllis Sobel
- h. dc.y.[edb
SUBJECT:
MEETING SUMMARIES OF NTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS (ISCORS) SUBCOMMITTEE MEETINGS.
l Attached are summaries of ISCORS subcommittee meetings in July and August 1996.
These meeting summaries are being placed in the NRC's Public Document Room,
Attachment:
As stated cc:
Paula Goode. EPA /0RIA I
I L
,3 9
-23
- - -w--
g w--
g
,-y w,-
,g-,-
n
+w-
-4 m
INTERAGENCY STEERING COMMITTEE ON RADIATION STANDARDS SUBCOMMITTEE MEETING SUMMARIES Subcommittee Meetinas in July and Auoust 1996 Mixed Waste July 10 Recycle August 15 Sewage July 30 and August 14 t
l l
l Attachment
4 DISCLAIMER These ISCORS subcommittee meeting summaries result from interagency b
discussions.
The subcommittees are composed of representatives from the Environmental Protection Agency. Nuclear Regulatory Commission. Department of Defense. Department of Energy. Occupational Safety and Health Administration. Deaartment of Transportation and Department of Health and Human Services.
T1e 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: Wednesday July 10. 1996 at DOE Hg. Forrestal o PARTICIPANTS: Sign-in list attached: five federal agencies. EPA. NRC. D00.
o AGENDA: copy attached o DISCUSSION:
The meeting generally followed the attached agenda with member agencies providing summaries of their MW-related activities since the May 7,1996 meeting.
DoD discussed two current MW disposal issues they are working on: one has to do with the disposal or recycle of DU tank armor plate, the other with the disposal of 9000 ft3 of old shredded Navy missiles.
EPA /0RIA is developing its strategy for LLW. which includes source, byproduct and special nuclear material.
An office cross-cutting team has completed an EPA Laboratory MW survey and prepared a draft report.
NRC reported that it had provided several briefings (eg. ASTSWMO LLW Forum) regarding its technical position paper on contaminated steel mill baghouse dust scheduled to be published soon.
NRC is continuing to work with EPA on MW storage and testing requirements.
DOE also reported providing several external briefings on its Rad Control Criteria feasibility study (eg. ASTSWMO. CRCPD, LLW Forum).
The draft ALARA analysis report will receive further review.
The 10 CFR 834 DOE rulemaking, being readied for CMB. also covers waste management issues.
i Regarding issues considered by the main ISCORS Committee. DOE reported l
that there were discussions at the full ISCORS meeting regarding federal i
radiation standards and risks associated with regulated and unregulated i
sources.
The Risk Harmonization subcommittee will be considering a risk comparative study of these sources and will be providing the information to the ISCORS.
o MEETING ACCOMPLISHMENTS:
-Mixed waste and regulatory initiatives considered are summarized in the Discussion section above.
s j
-The members were briefed on DOE's two HWIR proposals. Immobilization of Mixed Waste Debris and Vitrification of Mixed Waste. by Environmental a
Management's staff and provided a copy of the brief.
}
o ACTION ITEMS:
o NEXT MEETING: Planned for Thursday. October 31. 1996 at the Forrestal building.
Andy Wallo. III. Chair September 24, 1996
AGENDA ISCORS MW Subcommittee Meetina-7/10/96 (Room 2E-071) o Member Agency Sumnaries of MW Activities each member o
Briefing on DOE HWIR Proposals Susan Jones DOE o
Member Comments & Suggestions on RCC members ALARA Analysis
l 4
DISCLAIMER l
l 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, 1
Occupational Safety and IIealth Administration, Department of Transportation and
]
Department of Ilealth and lluman 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 Subcommittee on Recycling j
Final Meeting Notes l
August 15,1996 4
l John Karhnak (EPA) chaired the meeting. The group concurred with the minutes of the j
February 5,1996 meeting. The final minutes were distributed to the group.
- 1. Public participation and outreach (20 minutes)
Miles Kahn (EPA) gave a status of EPA's plans for stakeholder meetings with environmental groups, States, industry, and other interested parties. The purpose of the meetings is to gain input from these groups before decisions are made on EPA's scrap metal rule. Miles also outlined EPA's grant to the Environmental Law Institute (ELI) to conduct a workshop on the issue of recycling scrap metal contaminated with residual levels of radioactivity. Bob Meck (NRC) requested that NRC be involved in EPA's stakeholder meetings. Ken DuVall (DOE) asked for an overall strategy or EPA roadmap for EPA's rulemaking. Ken also suggested that the ISCORS Recycling Committee's next steps be focused to coordinate with tl.e EPA rulemaking. EPA agreed to prepare the roadmap and next steps before the next Subcommittee meeting.
- 2. Status of cost-benefit analysis (20 minutes)
The status of the EPA cost-benefit analysis of the scrap metal rule was presented by Reid liarvey (EPA). The strategy is to continue collecting information on the costs, volumes of scrap metal, and other factors to develop an analysis of the existing practice (baseline) and potential regulatory options. By the end of the year, a draft cost-benefit report will be made available to the committee for their review and comment. A full draft Regulatory Impact Analysis (RIA) for the rule will be developed after the pre-proposal draft of the rule is issued. Greg Gorsuch (DoD) offered to help with collecting information on DoD scrap metal volumes. IIe has already contacted the Naval Reactors Office and will soon contact the Army's IOC Radwaste Management operations in Rockville, MD.
- 3. Radionuclide partitioning paper (30 minutes)
An EPA contractor, Bill Thurber (Sandy Cohen and Associates), presented the findings and preliminary conclusions of the radionuclide partitioning paper. This paper is an outcome of the
s 2
collaborative effort between EPA, NRC, and DOE to agree on one set of values for the modeling of scrap metal scenarios. Bob Meck pointed out that he would like to see more involvement from DOE's Argonne National Laboratory (ANL). Ken DuVall and Stephen Warren (DOE) agreed to follow up with ANL. Stephen Warren also requested that EPA and NRC address his earlier comments on the mass balance model.
- 4. DOE Issues (15 minutes)
J Stephen Warren gave a brief overview of the upcoming DOE Recycle 2000 policy statement, now referred to as the Policy on Radioactively Contaminated Carbon Steel Recycimg.
This policy states that radioactively contaminated carbon steel scrap that cannot be free released under existing DOE orders will be recycled into containers for low level radioactive waste. The specific radioactivity in the containers will not exceed the DOT threshold value of 2 nanocuries/ gram. Ken DuVall also gave an update on DOE's handbook supporting 10 CFR 834.
- 5. NRC Commission Paper (15 minutes)
Bob Meck presented an overview of the NRC's commission paper on recycling of radioactively contaminated scrap metal. This commission paper will update the Commission on the status of EPA's rule and review potertial options available to NRC. Since the paper is " pre-decisional," it is not yet available for distribution. The commission paper is requesting no action from the Commission at this time. It is NRC's intention to stay closely coordinated with EPA.
Bob will distribute the paper when it clears the Commission.
- 6. Process for resolving key issues (15 minutes)
The next agenda item started with a brief discussion on ensuring that each Agency closely coordinate with each other as this process moves closer to a proposed rulemaking. All agreed that it is in the interest of everyone to resolve technical issues at the Subcommittee level and raise major policy issues (dose, scope, etc.) to the ISCORS for consideration if necessary. The Subcommittee's role is to frame the policy issues at the staff level and ask the ISCORS Committee to review these issues. The Subcommittee suggested that the main ISCORS December meeting could be the forum to resolve any major outstanding policy differences that cannot be resolved by the agencies before EPA goes forward with its pre-proposal draft rule.
Administrative Procedures Act (APA) and Federal Advisory Committee Act (FACA) requirements were also discussed. EPA noted that these requirements will affect the way the Subcommittee conducts business after EPA proposes its rulemaking. EPA will ensure that FACA is not violated.
- 7. Next Steps (15 minutes)
The Subcommittee then agreed on a set of dates for future Subcommittee meetings. The upcoming Subcommittee meetings will be held on Friday, October 18, and Tuesday, November l
- 19. Both meetings will be held from 1 to 4 p.m. in the EPA Judiciary Square Building, sixth floor conference room. Draft agendas will be circulated before each meeting.
r l
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. Occupational Safety and Health Administration. De]artment of Transportation and Department of Health and Human Services.
T1e subcommittee meeting summaries have not been approved by the respective federal agencies and do not represent the official j
position of any participating agency at this time.
ISCORS SEWAGE SUBCOMMITTEE FINAL MEETING
SUMMARY
Date/ Time: July 30, 1996. 9:00 a.m. to noon Location:
NRC. Two White Flint North
Subject:
Meeting of the ISCORS Sewage Subcommittee Attendees:
NRC:
Phyllis Sobel. Donna Moser. Bob Neel. Lee Abramson.
Charleen Raddatz EPA:
Bob Bastian Paula Goode. Mark Doehnert DOE:
Jim Bachmaier EPA /NAREL:
Dave Saunders. Clint Cox. Dave Cappelman ORISE:
Dale Condra Agenda:
Sewage survey List of radionuclides Data Quality Objectives Division of Analytical Work Decision Tree Letter to accompany sampling packages Facility Selection Contacts with Agreement States Schedule for test sites Status of Guidance document I
Summary:
The subcommittee discussed the latest list of radionuclides compiled by Donna Moser. NRC, and their detection capabilities.
NRC was circulating the list to several NRC offices for their review.
The subcommittee discussed those radionuclides which would be difficult or impossible to detect using just gamma analysis and gross alpha and beta
l i
screening.
In some cases, the gamma results can explain the gross alpha and beta screening results.
To determine the need to analyze additional specific
]
radionuclides with alpha and beta emissions an action level will be chosen based on the measured levels derived from the alpha and beta screening of the j
POTW samples.
1 In discussing how the publicly owned treatment works (POTWs) would be selected. the subcommittee considered looking for concentrations of licensees l
and then finding the associated POTWs.
Phyllis Sobel pointed out that most of the POTWs are in Agreement States and it will be difficult to identify these locations of these licensees.
She suggested we remain with the current plan to ask each POTW to state the zip codes associated with that POTW.
Then for each POTW. NRC vould produce list of (1) NRC licensees associated with that POTW that coui-be discharging radionuclides to the sewer system and (2) NRC licensees associated with that POTW that should not be discharging radionuclides to the sewer system.
Although NRC has this information in a i
data base for NRC licensees, NRC will have to determine how to access this i
information for POTWs in Agreement States..The subcommittee agreed that for i
l the next 7 test cases, this would be the plan; and after determining the licensees associated with each POTW, a decision would be made about additional l
analysis for radionuclides with alpha and beta emissions.
The next meeting was scheduled for August 14 at EPA /NAREL to observe the
]
analytical process and examine the results from the first two test cases.
Action Items:
1.
NRC to review list of radionuclides.
2.
Everyone to consider action levels for gross alpha and beta screening.
3.
EPA /NAREL and ORISE to determine zip codes of local STPs.
4.
NRC and EPA to consider dose modeling.
5.
Bob Bastian to send risk assessment report to Charleen Raddatz BRIEFING FOR PAPERIELLO AND TROVATO On August 7. 1997, the NRC and EPA members of the ISCORS Sewage Subcommittee briefed their office diractors. Carl Paperiello and Ramona Trovato. on the subcommittee's activities.
We provided background information such as a discussion of the GA0 report and the AMSA survey, and we briefly described the current subcommittee discussion topics such as the list of radionuclides and the analysis procedures.
The office directors agreed with the objectives of the survey.
In discussing the radionuclides to be analyzed we decided to go with routine environmental sampling methods. but NRC is checking to determine if there is a need to examine additional radionuclides.
EPA will examine earlier studies to determine how sludge is mixed with soil for farming and whether sludge piles differ from uranium mill tailings piles.
c --
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. Occupational Safety and Health Administration. Department of Transportation 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 SEWAGE SUBCOMMITTEE FINAL MEETING
SUMMARY
Date:
August 14. 1996 l
Time:
8:30 am to 3:00 pm Location: EPA's National Air and Radiation Environmental Laboratory (NAREL)
Montgomery. Alabama Attendees:
ORISE:
Dale Condra. Jack Beck EPA NAREL:
Clint Cox. Dave Saunders. Mary Wisdom EPA. Wash.. DC:
Robert Bastian. WWM:
Paula Goode. ORIA NRC. Wash., DC:
Robert B. Neel. DWM. NMSS Agenda:
Review results of sampling and analysis of sludge / ash for Toct Cases Problems encountered during the sampling and analysis Need for a Quality Assurance Program Plan (OAPP)
Formulation of Data Quality Objectives (D00)
SUMMARY
e OBJECTIVES OF THE SAMPLING PROGRAM FOR SEWAGE SLUDbE/ ASH The members of the workgroup re-affirmed the objectives of the study presented to C. Paperiello. NRC. and R. Trovato. EPA. during their conference call on August 7. 1996.
These objectives are to:
---Characterize the levels of radionuclides (both naturally-occurring and AEA) in sewage sludge and ash on a national (regional) scale.
Both EPA and NRC seem to approach this objective in the same manner.
---Determine the extent to which radioactive contamination occurs in sewage sludge, ash and related byproducts.
Dose levels are to be determined for the occupationally-exposed plant workers and for the public's exposure to end products.
---Support rulemaking decisions by NRC and EPA.
EPA will use this data to decide if limits on concentrations of radionuclides in sludge / ash from POTWs are necessary relative to the regulation of sludge /use disposal practices.
NRC can use the data to help make decisions on whether further rulemaking is needed to avoid possible reconcentrations of radionuclides in sludge / ash during processing at the POTWs.
Bastian indicated that EPA's Office of Science and Technology would address the first objective.
EPA will provide funds for the first two objectives above, but not for NRC's study of trends in "re-concentration" of radionuclides in sewage sludge / ash.
e RESULTS OF TEST SAMPLES AT TWO TREATMENT WORKS Members of the staffs of the Oak Ridge Institute of Science and Education (0 RISE. NRC's contractor), and NAREL (EPA's laboratory) each reported the concentrations of radionuclides found in split samples of sludge / ash taken from two different POTWs in the vicinity of the two laboratories (one in Montgomery. Alabama, and the other in Oak Ridge. Tennessee).
A primary objective of these two test cases was to determine if each lab would find the same concentrations of radionuclides in split samples.
Dale Condra. ORISE.
who was present when the samples were drawn at the Oak Ridge POTW. reported no problems encountered during the sampling.
However. Saunders. NAREL. indicated that he was not sure who to contact to determine the zip codes of the facilities that feed the POTW that was sampled in Montgomery. Alabama.
A quantitative comparison of results of analyses of sludge / ash samples for gross alpha. beta and individual gamma radiations in slurries of various solids contents at the two test POTWs were presented by the labs.
The radionuclides found were:
U-238. Th-232 and some of the members of their decay chains: Iodine 131: Cobalt-60 (TN). Cesium-137. Thallium-201/208.
Potassium-40, and Bery'lium-7.
The analysts in both laboratories considered these results (without statistical comparisons) as a confirmation that the analytical techniques of both laboratories will produce essentially the same results for a given sample.
Both studies were conducted under a unique Quality Control / Quality Assurance program plan (OAPP) develoaed for the two test cases but for the remaining seven test cases and for t7e national sampling program, a much more comprehensive OAPP is necessary: it must consider the variety of designs and operations of the various POTWs at which sampling will occur.
QUALITY ASSURANCE PROGRAM PLAN (0 APP) 4 M. Wisdom and D. Saunders. NAREL. and D. Condra. ORISE. were tasked to develop a 0 APP with a scope that ranges from collection of samples to the reporting of results.
The ISCORS Sewage Subcommittee is expected to provide an interpretation of the results that are to be reported to them as raw data by the contractor labs.
Wisdom indicated that to develop a OAPP plan she needs to know the radionuclides to be analyzed, the number of samples be taken and the number of plants to be sampled.
The following paragraphs explain how the members of the laboratory rkgroup approached her request.
T1e workgroup decided that the classes of radionuclides to be sampled / analyzed daring the remaining test cases and during the national survey would be selected according to the following guidance suggested by C. Paperiello. NRC.
during a conference call to R. Trovato. EPA on August 7, 1996:
the
i
- analytical procedures to be used by ORISE and NAREL should follow their current protocols used for routine analysis of environmental samples.
NAREL and ORISE were asked to use this principle to prepare a list of radionuclides in sludge / ash that they will sample and analyze.
Thus. the nuclide list is to be based on typical laboratory procedures, not on the values for the residential scenario found in NUREG-1500. " Working Draft Regulatory Guide on Release Criteria for Decommissioning: NRC Staff's Draft for Comment." Both laboratories agreed to follow the same (or similar) protocols for sampling and analysis of sludge / ash samples, and neither laboratory intends to make heroic efforts to develop new protocols.
When a list of radionuclides and a sampling protocol have been prepared jointly by ORISE/NAREL they will send this information to NRC for review and comment.
The EPA members of the workgroup indicated that if NRC wants to analyze for radionuclides that are not included in the list of radionuclides, but are found in sludge / ash samples. NRC must use its own money to pay for the additional analysis without their matching funds Considerable discussion ensued about the number of samples of sludge / ash to be taken, and the number of POTWs to be sampled.
Someone suggested that two samples per POTW be assumed for development of the protocol.
P. Goode. EPA.
indicated that R. Trovato, EPA. was willing to split the costs of the sampling / analysis approximately 50/50 with NRC (at least up to a cost of
$300.000).
D. Saunders. NAREL. initially proposed that.500 samples be taken for the total national survey with OA procedures applied to 20% of the samples, and nuclide-specific analysis (e.g. for C-14. H-3. etc. ) applied to 10% of the samples.
But, the NAREL staff decided to refine this estimate since it was based on 100% effort toward the EPA /NRC sewage-sludge program.
and left no time for analysis of samples required for other national programs.
A related issue that wx briefly discussed with the contractor laboratories was: "What are the appropriate background concentrations of radionuclides for use in interpretation of the results of the sampling / analysis program?"
i Bastian indicated that the background that EPA /0W would likely recommend is that for sludges which contain no man-made contamination, not the background found in the local area (e.g., concentrations in soil, water, etc.) near the i
POTW.
This approach is in direct conflict with that presented by. NRC. on page 9 of the working draft of " Guide for Waste Water Treatment Plants." dated J
July 5. 1995.
NRC and EPA should resolve this issue prior to sending guidance i
to POTWs.
Another issue related to the number of samples was: "When does the survey end?" Goode. EPA. suggested that the workgroup must know the number of POTWs and the numbers of samples before this question could be answered.
Toward this ed. Bastian plans to confirm with L. Abramson, statistician, NRC whether 500.%0 samples of the sludge / ash from the 2500 largest POTWS under consideration for sampling is a statistically-significant number for this survey.
Bastian also plans to identify and contact seven POTWs as candidates to test the contractor's sampling and analysis protocols for seven more test cases.
He identified a number of potential candidate POTWs for the workgroup and also cited some bases for his selection. After Bastian identifies these candidate POTWs. he will send them the standard survey form prepared by P.
Sobel. NRC. Goode. EPA made a request that P. Sobel. NRC, modify the survey form before it is sent out to the next test cases to include two additional questions: "What is the end use of the sludge." and "Which processes were used
'to generate the sludge?" ORISE will mail sludge / ash sample collection kits to a POTW selected for the study only after Bastian receives completed survey forms from them.
When the seven remaining test cases are completed. the laboratory workgroup plans to prepare a report for the steering committee of ISCORS that will include an estimate of the number of samples to be taken when the samples are to be taken, the number of plants to be sampled. and the cost of the sample / analysis program.
CONFERENCE CALL:
DATA QUALITY OBJECTIVES (D00)
During a conference call f rom the workgroup to Mark Doehert. EPA. ORIA. he identified the items still needed to complete the D00 for the national survey.
These included: a list of radionuclides to be sampled / analyzed and appropriate threshold exposure levels for each:
values for the minimum detectable activity (MDA or MDC values) for each radionuclide: the number of samples and where they will be taken in the POTW: and, if samples are to be taken multiple times during processing of sludge / ash or only at one time.
Since the composition of the sludges / ashes generated by the POTWs are expected to contain varying amounts of radionuclides over time. Bastian noted that maybe the D00 should also contain procedures to sample POTWs at selected intervals throughout the year (such as seasonally).
The NRC staff recalls that, in the past. ISCORS had decided that this survey would be held only once.
Neither i
Doehert nor the workgroup responded to this suggestion.
Wisdom suggested that Doehert's current draft be modified to include these needs when an approved protocol for the radionuclides to be sampled and analyzed is available.
P. Goode. EPA plans to deliver the D00 information to Doehert as it becomes available.
The next meeting of the ISCORS Laboratory Workgroup will be via a conference call to take place between 10:00 am to noon EDST on September 4. 1996.
P.
Goode will provide the bridge number for the call.
ACTION ITEMS:
---R. Bastian. EPA. to send videos on sampling techniques and materials to ORISE NAREL.-R. Neel. NRC.
Also, to contact potential candidate POTWs for i
the next seven test cases. and to select seven of them for additional sampling and analyses by the contractor laboratories.
---M. Wisdom. EPA. NAREL to draft a 0 APP and distribute for review.
---R. Neel. NRC. to expedite NRC's review of the list of radionuclides.
---D. Saunders. NAREL. to determine the number of samples to accept for analysis.
---0 RISE /NAREL to determine criteria to select 10% of the samples for analysis of specific radionuclides.
---P. Sobel. NRC to complete Sewage Sludge / Ash Survey form. to add an explanation of "end product" to the form, and to request process information.
i 1
l
---P.' Goode. EPA. to deliver information and documents to M. Doehnert. EPA.
l ORIA.
i i
f a
4 i
i i
I l
i
]