ML20154N348

Responds to 880815 Request for Addl Info Re Disposal of Contaminated Sewage at Brattleboro Waste Treatment Facility. NRC Maintains Regulatory Jurisdiction Over Licensed Matl in Sludge.Util Did Not Perform Adequate Sewage Surveys

ML20154N348
Person / Time
Site:	Vermont Yankee
Issue date:	09/13/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mccandless R VERMONT, STATE OF
References
NUDOCS 8809290276
Download: ML20154N348 (3)

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, SEP 13 $8 Director Mr.RafmcadN.McCandlessDepartmentofHealth Vermon 10 Baldwin Street Montpelier, Vermont 05602

Dear Mr. McCandless:

This is in response to your le' tar dated August 15, 1958 in which you requested additionalinformationconcercMgthedisposalofcontamInatedsewageatthe Town of Brattleboro's Waste satment Facility. Below are answers to your specific questions.

Question 1:

Does NRC regulatory jurisdiction over licensed materials extend to the stockpiled sludge in Brattleboro whether or not the concentrations in water of 10 CFR 20, Appendix B had been met when sludge / sewage was transferred by Vermont Yankee?

NRC does maintain regulatory jurisdiction over the licensed material Yes,he in t sludge.

Question 2:

Have all other requirements recordkeeping, of 10 been satisfied by CFR 20, Yankee?such as sampling and Vermont The licensee did not perform adequate surveys on th e sewage before releasing it for dis)osal. In order to demonstrate compliance with requirements of 10 CFR 20.303, licensees wishing to dispose of licensed material are required to perform surveys in accordance with the requirements of 10 CFR 20.201. Initially when this sewage was released to the sanitary sewer system, the licensee was not aware that the sewage was contaminated, and did not attempt to demonstrate compliance with the regulations. Subsequent measurements of concentrations of radionuclides in the sludge at the Brattleboro Waste Treatment Facility have shown that they are well below the limits set forth in 20.303(bS(l). The 10 CFR 20, Appendix B Table I Column 2 concentration limht for water referred to by 10CFR20.503is0.001 micro-Ci/mlor 1000000 /kg. Measured concentrations in the sludge were below 200 pC g, or approximately 5000 times smaller than the release limit. This in ates the waste as disposed met the regulatory requirements relatin to concentration. Also the regulatory requirement of 10 CFR 20.303 d) relating to total activity was also met. The upper limit of total act vit total amount of sludge (1.500 cubic feet)and y was determined the maximum based on the measured concentration (200 pCi/kg and this was found to be less than the one Curie per year limit of 10 CFR 0.303(d). Regarding records, since the licensee did not perform adequate surveys of the sewage prior to disposal, reccrds

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of disposals were not maintained. Ve are currently in the process of resolving this issue with the licensee. The licensee has committed to us to perform an analysis to determine a best-estimate of the total amount of licensed material that was released in the sewage. The results of this analysis will become part of the station's records.

Question 3:

What recommendations can NRC provide concera.ing the disposition of an astimated 13,500 cubic feet of sludge, currently stockpiled at the Brattleboro sewaae licensed material treatment p?lant, which contains measurable amounts of (Cobalt-60)

No special precautions need be taken in disposing of the sludge from the standpoint of the radioactive material. The NRC release limits required of 10 CFR 20.303 for sewage are low enou handling and disposal of the sludge, even gh to ifpreclude the the waste need forprocess treatment special caused some reconcentration of the radioactivity in the sludge.

Measurements of the sludge stockpiled at the Town of Brattleboro's Treat'nent Facility Indicate Co-60 concentrations less that 200 pCi/kg.

This concentration is so low that exposure pathways to humans would result in only negligible doses. For example, ingestion of all the activity from a kilogram of sludge (200 pC1) would result in a dose of the order of 0.001 mrem.

Please do not hesitate to contact Dr. Ronald R. Bellamy of my staff at 215 337-5200 if we can be of any further assistance to you.

Sincerely, Original Signed By WILLIAH T. IwsszLL William T. Russell Regional Administrator cc:

J. Lash, Secretary, Natural Recourcet, State of Vermont G. Sterzin Public Service, State of Vermont W. Murphy,ger, Commissioner Manager of Opera [ ions,VYNPC J. Pelletier, Plant Manager, VYNPC D. Reed, Operations Support Manager, VYNPC

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Nuclear Safety Information Center (NSIC) bec:

Region I Docket Room (with' concurrences)

D. Haverkamp, Section Chief, DRP J.' Kaucher, Project Engineer, DRP G. Grant, SRI - Vermont Yankee H. Eichenholz, SRI - Yankee C. Warren, SRI - Pilgrim JV. Rooney, PM, NRR 1

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r State of Vermont AGEFtY OF HUMAN SERVills L

YERMONT DEPARTMENT OF REALTH DMdener W and namessake made Adad=8*=s amadhs N Baldwh terest Moneysser, Veraset esses (se2)8384006 August 15, 1988 i William T. Russell Bagforal Administ.rstor '

Nuclear Negulatory Ocmaission 475 Allendale Road King of Prussia, Pennsylvania 19406 RE: MIC Inspectim

1. 50-271/88-09 We would appreciate receiving additional inforantion omoeming the "potatial laproper disposal of licensed material" dich your inspection identitled. De in alth$ge of the Bmttleboro, Verwit sewmac his trentaant Cotalt 60 plant.inspectim presumably originated frum Venmont Yankee hiear Pcuer Plant in Vernon, Vermont.

(1)

Does Nr0 regulatory jurisdiction over licensed materials extend to the stockpiled slutlac in Brs.ttletoro whether or not the concentrutima in water of 10 by transferred GBVerwont 20, Apperrlix Yankee?B had been met een altdge/ sewage was (2)

Have all other keepirw, requirement.s bem satisfied of 10Yankee?

by Venamt Cm 20, amh as sampling and recorti-i (3) What reccessendatioru, can MIC provide omoernirw the di l

estianted 13,500 cubic feet of sludge, currently a ition of an '

l led at the j

Bruttleboro scure treatment plant, Wich omtains measurable anomta of 11oensed material (Cobalt. 60)?

1 hank you for your assintance in this matter.

1 R, kn um Itaymond N. M:Canriless

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.Vnsb 0: Dr. R. Coffin, Health Commissioner J.1AAh, ScCretary Natural Resources O. Sterzinger, caus,alsaloner, publio Service

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