ML20195D170
| ML20195D170 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 10/27/1988 |
| From: | Toy H Battelle Memorial Institute, COLUMBUS LABORATORIES |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 24797, NUDOCS 8811040235 | |
| Download: ML20195D170 (8) | |
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M US Nuclear Regu atory Commission hg W" # dp Washington DC 20555
Dear Mr. Rouse:
This is in response to your letter of September 23, 1988 requesting additional information in connection with our requested amendment, dated August 5, 1988 to authorize up to three (3) Curies of carbon-14 to be utilized in field studies.
The following items 1., 2. and 3. are presented in the same sequence as requested in your letter.
1.
"A DESCRIPTION OF THE AMOUNT OF RADIOACTIVE MATERIAL TO BE RELEASED IN THE FIELD".
A fraction of the labelled compounds to be used i' these studies are estimated to be irrecoverably released in the field during the progress of individual experiments for normal, to what might be considered normally severe, weather conditions. These releases can be reduced by the applica-tion of additional constraints and control measures but cannot be en' heb eliminated in a practical perspective. Fcr discussion aurposes rela:.ses of labelled compounds are discussed with respect to the p1ysical iors'of release, namely; ' Aerosols" or "Other Releases" and, with respect to the activity from which the release resulted. Aerosol releases are assumed to result mainly from the "Application"; "Plant Growth and Processing"; and i
"Soil Management" activities. These categories are discussed individually in terms of C-14 activity per plet and are based upon a maximum application of 50 millicuries per 10 mz plot. "Other Releases" includes discussions of "C-14 Activity Remaining in Plot Soil"; "Translocation of Labelled Compounds"; and "Extreme Upset Weather Conditions". (The following discussion is based on the case of pre-emergence application of the labelled compound on the plot, the over-all release for which is a bit higher than for post-emergence and therefore considered the conservative representation. The time sequence of the partitioning of the compound between soil and plants is also different for the two cases).
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Aerosol Releases Application.
A tent of sheet plastic will be constructed to completely enclose the plot or the specific area to which the compound is applied during application. Electrostatic or air-assist application techniques will be used to increase the adherence of applied material to plants and soil, and limit pressurizing the volume enclosed by the tent. In this discussion release during application includes the fraction of the compour.d directly released as an aerosol from the tent during the actual spraying of the com)ound on the )1ot and the fraction of the compound airborne within t1e tent, whici may adhere to tho applier's protective gear and the interior surface of the tent, and which may also be released as an aerosol during removal and handling of the protective gear and tent soon after the spraying task is completed. The sum of these is estimated at 0.9 microcuries.
Plant Growth and Management.
This includes all releases as aerosols from plants which may occur during plant growth, handling during harvesting for analyses and evaluation and removal and packaging for waste management of all residual plant parts and tissues. Based upon an uptake of 40 millicuries in the plant tissues this release is estimated at 0.4 microcuries.
Soil Management.
This includes all the aerosol releases from the soil during the plant growth period, harvesting and during soil excavation and handling.
Based upon the partition of 10 millicuries of the applied activity to the soil this is estimated at 1.7 microCuries.
Total.
The total C-14 aerosol release resulting from the above three activities, per experiment per plot is 3.0 microCuries.
Other Releases C-14 Activity Remaining in Plot Soil, it is estimated that, on the average, no residual C-14 activity greater than background will remain in plots. When an experiment is terminated several depth profile soil samples will be taken on a grid uniformly distributed over the plot area. If the C-14 activity in any sample exceeds 2 times average background (142 disintegrations per minute per gram of soil), the soil in the entire plot will be excavated to a uniform depth at which no sample exceeds 142 dpm/ gram soil.
3 The C-14 background in soil in the Battelle West Jefferson area is found to range from 40 to 102 dpm/ gram, the arithmetic average being 71 dpm/ gram of soil.
Plant Parts.
l Plant parts, including roots, remcining in the plot will either be removed with soil and waste managed as described for soil in the paragraph above or removed from the plot and waste managed separately according to the same criteria as for soil dis)osal. All plants and r
plant parts grown in these field studies will )e controlled to the extent they will be unavailable for human consumption or animal feed.
Translocation of Labelled Compounds in Soil.
Translocation of labelled compounds and their degradation products i
carrying the label within the soils found in the West Jefferson area, l
is a very slow process which is characteristic of clayey soils. The labelled compounds and any degradation products carrying the C-14 label are expected to remain within the spacial realm of control by the l
measures outlined in the discussions above on "C-14 Activity Remaining l
in Plot Soil" and "Plant Parts" during the lifetime of an experiment.
Extreme Upset Wr.ather Conditions.
It is anticipated that extremely severe upset weather conditions could cause the surface translocation of a major portion of the C-14 label applied to experimental plots. The conditions of principal concern i
would be severe rainstorm and tornado activity.
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r Severe Rainstors. A severe rainstorm could produce surface washing of soils cnd carry contaminated soils and plant parts in the runoff path. Contamination thus dispersed could eventually find its way.
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via further runoff, into public streams or water bodies. The location of test plots on level terrain, as far as feasible from natural runoff routes and the insertion of barriers in anticipated runoff routes will retard this action. It is probable that after a severe rainstorm the route of runoff could be detected visually and serve as a guide for collecting soil samples to identify areas where a substantial portion of the C-14 could be recovered. Several of these contingencies would be required to disperse radioactivity
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into public areas or public waters.
Tornado Activity. It is credible that a severe tornado activity could remove part or all of the soil and plant parts from a plot,
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or several plats, and distribute these materials into public areas.
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4 Extreme Upset Weather Conditions. Summary.
It is credible that several severe rainstorns or a single tornado could remove C-14 from test plots and distribute the nuclide in the general environment in very dilute concentration. The maximum activity which could be involved in a single contingency would be 1250 mci for 25 active plots or 2500 mci for 50 active plots. It is doubtful that the C-14 concentration in soil or water in the wake of such a tornado would be distinguishable above normal C-14 background in the area soil or water. THE RADIOLOGICAL HAZARD WHICH IS LIKELY TO RESULT FROM A SEVERE RAINSTORM OR TORNADO IS INCONSEQUENTIAL. However, in the event of such a contingency and a substantial probability of additional occurrences the a6visability of continuing these field studies will be reevaluated, 2.
"A DESCRIPTION OF THE EXPECTED RADIATION DOSE TO HUMANS" For discussion of radiation dose to humans which may result from these studies persons who may be affected are considered in two groups, "Radiation workers" and "Public persons". The dose to humans will be almost totally internal dose from the possible intake of C-14 mainly by inhalation and ingestion. Some beta dose to the skin as well as skin absorption of the labelled compound could result from direct skin contamination by the j
compound for radiation workers. This is expected to be inconsequential since impervious protective gear will be required and used by radiation 1
workers in all operations where skin contamination is credible. There is no gamma radiation from the decay of C-14. Significant dose to radiation i
workers from beta bremsstrahlung is not considered credible since large l
quantities and very high labelling concentrations will not be used, l
Radiation Dose to Public Persons.
Population Locations.
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l The field studies plots will be in the vicinity of the West Jefferson f
Middle site, JH-1. Residences nearest the area where the field studies t
are planned are two dwellings about 1500 feet to the southwest and ona
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dwelling about 3500 feet to the northwest. A Girl Scout camp, Ken Jockety lies to the northeast on the east side of Big Darby Creek with the nearest border of the camp area about 2200 feet away. A housing area, Lake Darby Estates lies to the southeast, on the east side of Big Darby Creek, about 4600 feet away. Approximately 1200 persons live within a one-mile radius and most of these persons are beyond three quarters of a mile away. All of these except four persons are more than i
a half-mile away. Prevailing winds are from the south and west quadrant on the order of forty per cent of the time. A drawing of the Battelle West Jeffer sn Area is attached for reference.
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5 Dose to Public. Conclusien.
In consideration of the very small estimated releases from these studies, the population density and the distance of population groups from the site of the studies IT IS ESTIMATED THE DOSE TO ANY PUBLIC PERSONS WILL BE INCONSEQUENTIAL. Some additional perspective of the dose to the public may be gained by comparison of the dose to radiation workers, presented below, with the background dose to all persons in i
the area from all natural sources. The natural background dose in the i
West Jefferson area is about 135 mrem per year.
_ Radiation Dose to Radiation W3rkers.
i Intakes by Radiation Workers.
The dose to radiation workers is assumed to result from inhalation of the aerosol releases estimated for the categories "application", "plant i
growth and processing" and "soil management". The releases for these activities are, respectively 0.9, 0.4 and 1.7 microCuries for a total of 3 microcuries per plot and 75 microcuries for 25 plots. 'iince the releases are small and for conservative simplification of the dose computation we will assume radiation workers inhale a major portion of the aerosol releases from a plot.
The 50 year Constitted Effective Dose Equivalent.
The 50 year committed effective dose equivalent which could result from l
the intakes of the releases from one plot is estimated at 6.3 millirem and on the order of 160 mrem for 25 plots, or 320 mrem for 50 active plots.
3.
"A Copy of a letter From the Ohio State Health Department Indicatino tha_t They Have Reviewed Your Application and Concur with Your Request" A copy of a letter from the Ohio State Health Department is included herewith.
We trust this supnlemental information is responsive to your request and will
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enable you to proceed with the issuance of the amendment.
Should you desire t
further information, please call me at (614) 980-5228.
J Very truly yonrs,
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Harley L. Toy Manager i
Nuclear Services l
HLT:jv Enclosures (2)
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RICHARO F. CELESTE 244 N H+gn Street l g Post Office som 113 2
Governer CAmbus, Ohio 432644118 e
e Tc8echoas (4141446 3643 e or September 23o 1988 Mr. Harley L. Toy NBC Liccasing Coordinator Battelle Columbus Division 505 King Avenue Columbuso OH 43201-2693 Dear Mr. Toys Thank you for a copy of the letter to the USNRC dated August So 1988, subjects Request for Amendment to License No. SNM-71 Docket 70-8.
I reviewed the letter and concur in your request as long as the appropriate coordination with and notification of the Ohio Department of Health are made.
M erely, Robert M. Quillino CHP Radiological Health Program Administra tor RMQ/ka
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