ML20205S252
| ML20205S252 | |
| Person / Time | |
|---|---|
| Issue date: | 01/30/1987 |
| From: | Goller K NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Browning R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20195E797 | List: |
| References | |
| FRN-53FR32914, RULE-PR-20, RULE-PRM-20-15 AC14-1-19, NUDOCS 8811100306 | |
| Download: ML20205S252 (9) | |
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E . JAN 3 01N7 A '1ANDUM FOR: Robert E. Browning, Director Division of Waste Management Office of Nuclear Material Safety and Safeguards ,
Themis P. Speis, Director' '
Division of Safety Technology Office of Nuclear Reactor Regulation
" Karl R. Goller, Director FROM:
4 Division of Regulatory Applications 4
Office of Nuclear Regulatory Research SUNECT: DRAFT RECOMMENDATIONS TO E00 CONCERNING-
' INITIATION OF RULEMAKING SPONSORED BY RES l Ai.tached for your consideration is a draft recomendati n supported by a draft office review concerning the initiation of a rulemaking to amend 10 CFR Part 20.305 to' allow the incineration of certain low activity hvel waste oils generated in nuclear power plants. Beth the Division of Waste Management.
offices for this action.
a This memorandum constitutes my concurrence in the attached draft recomendation. i I plan to dispatch this memorandum with the attached draft office review to the Researen Independent Review Board 2 weeks from the above date. j Please acknowledge receipt of this memorandum by returning it with or without 4
coments on the draft recomendation as indicated on the attached notation 2
sheet. l Karl R. Golla.; , Director !
i Division of Regrlatory Applications Office of s cl M r Regulatory Research j Enclosu e: As stated Reflects agreements reached between RES, NHSS and 0GC staff at !
RECORD NOTE: -
meeting on 1/5/87. l t
- 20-15 PDR ,
- DRA/RE5pt)M;DRA/RES P ' : : : :
0FFt DRA/RE5 :
NAME: C8artlett:sh:GHMarcuWR' :KRGoller :
DATE: 01/05/87 V ' '"" :01/#7/87 , : : : : j
- c' Draft RES Office Staff Review Rule to Amend 10 CFR Part 20.305 DISPOSAL OF WASTE OIL BY INCINEPATION A. Rackground The Edison Electric Institute (EEI) and the Utility Nur. lear Waste Management Group has petitioned the Commission (PRM 24-15, dated July 31, i 1984) to initiate rulemaking to define a level of radioactivity in reactor-generated waste oils which would permit disposal of such oils without regard to their radioactive material content. This petition responded to Commission views as expressed in the Supplemer.tary-Information accompanying publication of 10 CFR Part 61. In that statement,theCommissionrecognizedthattheestablishmentofajg minimis waste standard would be beneficial and would, among other things, reduce disposal and long-term disposal site maintenance costs and would help preserve the limited capacity of the regional, licensed waste f disposal sites for the disposal of wastes which had higher levels of activity. The petitioner suggested that, based on recent Commission decisions, a 2 millirem /yr individual dose limit would be an appropriate I basis for establishing a cut-off level for def;nino those wastes which were "below regulatory concern." Further, the petitioner presented i several examples where combinations of waste radionuclide concentrations and waste disposal methods would satisfy that 1 millirem /yr dose limit and proposed wordina to revise 10CFR Part 20 to reflect these recommendations.
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q B. Screening Criteria
- 1) Issue To Be Addressed By Rulemaking Process A response to this petition requires a staff determination of the need for a generic rulemaking to allow disposal of reactor-generated, slightly contaminated waste oil by means other than by burial at a licensed disposal site. Among the factors which must be considered in this determination are the following:
(1) The financial costs and land use requirements associated with disposing of the very small quantities of radioactive material contained in typical waste oil.
(2) Current licensing requirements imposed on each reactor operator limiting the release of radioactive materials to the general environment to ALARA levels.
(3) The existence of Comission regulations which permit the use of alternate waste disposal practices subject to license amendment.
(4) The authority of the EPA to regulate the release of both I
radioactive and non-radicar.tive materials to the environment.
(5) The authority of the EPA which assumed Federal Radiation Council responsibilities to develop Presidential guidance on acceptable levels of radiation exposure of the general public for use by other federal agencies.
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- 2) Urgency The Commission has recently established a policy and related procedures (51 FR 30939, August 29, 1986) for the expedited handling of petitions requesting exemption of specific radioactive waste streams from current rules reouiring their disposal in licensed
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low-level waste disposal sites. While the subiect petition does not qualify for expeditad handling (because it predates the policy, and does_not satisfy the rigorous information requirements which were set forth in the referenced notice) we believe that action on this petition should be concluded as soon as possible in keeping with the spirit of Comission policy.
-3) Alternatives to Rulemaking In responding to this petition there are three alternative courses of action which could be taken; i.e., to deny the petition, to defer action on the petition or to initiate the rulemaking process. RES does not believe that a categorical dismissal of this petition 6t this time is consistent uith either the spirit of Comission policy set forth in 10 CFR Part 61 (and recently reaffirmed in 51 FR 30839),
or the need to ensure effective use of licensed low level waste disposal capacity.
The staff might elect to defer action on this specific retition while awaiting public comments on the recently published Advanced Notice of Proposed Rulemaking (51 FR 43367, Dec. 2, 1986). That notice solicited coments on the broad question of classifying certain wastes as being "below regulatory concern" (BRC). The staff could also elect to defer action pending issuance by the Environmental Protection Agency of standards on guidance on de minimis or BRC levels of radioactivity or dose.
PES, however, recognizes the current problems associated with the disposal of waste oil and believes that in the spirit of established Comission policy and consistent with the need to use limited burial ground space as efficiently as possible, the rulemaking procedure should be initiated and carried out as expeditiously as possible.
RES does not believe that EPA guidance a standard on de minimis or BRC levels of radioactivity will be forthcoming in the near future nor does it believe that in the absence of such action, a definition 3
of a BRC level for waste oil can be established without full consideration of the comments received in response to the Advanced Notice of Proposed Rulemaking published on December 2, 1986 (51 FR 43367). The proposed action reflects these considerations.
- 4) How issue Will Be Resolved Throuch Rulemaking As presently envisioned, the EEI petition would be partially granted by amending 20.305 to permit on-site incineration of waste oil with the addition of clarifying language which would note that this treat-ment alternative may be used for the disposal of waste oil without specific license amendment providing the licensee demonstrates that the requirements of the licensee's technical specifications, established to satisfy 10 CFR Part 50, Appendix I, are maintained and other applicable federal and state statutes are satisfied.
This action by the Comission would not preclude the petitioner from resubmitting a future request to declare waste oils or other classes of waste to be "below regulatory concern" pursuant to Comission policy (51 FR 43367).
- 5) Impact of Proposed Action Information provided by the petitioner and in a Rrookhaven National Laboratory Report (NUREG/CR-4730, to be published) indicates that on average, an operating power reactor produces approximately 1500-3000 gallons per year of slightly contaminated waste oil. Reported contamination levels are usually in the range of 10-5 to 10-7 u Ci/ml, although higher levels have been reported. The principal ,
radioisotopes pruent in these waste oils include the usual activation and fission products (Co, Ni, Mn, Cs).
Because of restrictions imposed on the disposal of oil wastes in licensed land burial grounds, oil wastes must be stabilized prior to transport to these sites; sorption and solidification are the 4
i prevalent treatment methods. Several plants are storino waste oils on an interim basis pending a decision on ultimate disposal.
According to both the BNL report and information provided by the petitioner, solidification of oil wastes effectively doubles the volume of waste requiring disposal while sorption can increase waste volumes by as much as a factor of six.
If directly released to the environment, a typical reactor would, on average, discharge a total of 10"# Curies of radioactivity per year via the waste oil pathway. This quantity is 20,000 times lower than typical releases in liquid effluents and hundreds of thousands of times lower than atmospheric releases allowed under existing plant discharge limits, as reported in NUREG/CR-2907 "Radioactive Materials Released from Nuclear Power Plants - Annual Report." Thus, the 4
addition of the small quantities of radioactive material present in waste oil to normal plant effluents should have a negligible impact on public health or environmental quality.
By permitting use of less restrictive disposal methods for this waste, savings in the range of $5-$18 million/ year in direct disposal costs can be projected for a mature reactor economy (100 reactors).
More importantly, permitting use of alternative disposal options would conserve around 100,0003 ft /yr of limited low-level burial ground space.
NRC Resources and Scheduling Wo estimate that to complete action on this rulemaking 1.5 staff years (combined RES, NRR, NMSS) will be required. If adopted, this rule should significantly reduce the potential workload in processing individual requests for specific license amendments to permit incineration. ( 10 man years total) l 5
1
The tentative schedule for processing this rule'is as follows:
Notice of Proposed Rulemaking Sept 1, 1987 Comment Period End- Oct 15, 1987-Final Action, n'fice Review Feb 15, 1988 Final Action, ommission Review May 30, 1988 Publication in Effective Form July 30, 1988 Preliminary Judgment Based on our preliminary assessment of all the factors involved, including consideration of the need to conserve limited burial arour.d space, we believe the proposed rulemaking process should be initiated.
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REGULATORY AGENDA TITLE:
Disposal of Low-level Radioactively Contaminated Waste Oil from Nuclear Power Plants CFR CITATION:
10 CFR 20 ABSTRACT:
The proposed rule, which is being initiated in partial response to a petition filed by Edison Electric Institute and the Utility Nuclear Waste Management Group (PRM-20-15, dated July 31,1984), would amend NRC regulations to allow on-site incineration of waste oil at nuclear power plants subject to specified conditions. Currently, the only generically approved disposal method for low-level, radioactively contaminated waste oil from nuclear power plants involves absorption or solidification, transportation to and burial at a licensed disposal site. There is a clear need to allow, for very low activity level wastes, the use of alternative disposal methods which are more cost-effective from a radio-logical health atd safety standpoint and which conserve the limited disposal capacity cf low-level waste burial sites. Increased savings to both the public and the industry could thereby be achieved without imposing additional risk to the public health and safety. There would be, in a mature reactor economy, an estimated industry-wide economic savings of approximately $5 mi' lon to $18 million per year if such a rule were promulgated. Alternatives to this rulemaking action are to maintain the status quo or to wait until the Environmental Protection Agency develops Standards on acceptable levels of radioactivity which may be released to the environment on an unrestricted basis. It is estimated that approxi-mately 1-2 person-years of NRC staff time will be required to process this oroposed rule.
TIMETABLE:
A tentative schedule has been established as follows:
NPRH: September 1, 1987 NPRM Comment Period End: October 15, 1987 Final Action, for Office Review: February 15, 1988 Final Action, Package to Commission: May 30, 1988 Final Action, Published: July 30, 1988 LEGAL AUTHOP!TY:
[42 USC 2201; 42 USC 2167; 42 USC 2073]
2 AGENCY CONTACT:
Catherine R. Mattsen Nuclear Regulatory Comission Office of Nuclear Regulatory Research Washington, DC 20555 (301) 443-7689 EFFECTS ON SMALL BUSINESS AND OTHER ENTITIES: None i
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".I*.".Ud.'".1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Att,entior}: Chief, Docketing and Service Branch Re Petition for Rulemaking Regarding the Disposal of Radioactively Contaminated Waste Oil from Nuclear Power Plants Which Is Below Regulatory Concern
Dear Sir:
The enclosed Petition is submitted on behalf of the
, , Edison Electric Institute (EEI) and the Utility Nuclear Waste Management Group (m&HG) for the issuance of a regulation governing the disposal of low-level radioactively contami-nated waste oil from nuclear power plants.__Specifically,.
EEI/mmHG are requesting that a regulation be promulgated establishing radionuclide concentrations in waste oil from nuclear power plants below which disposal may be carried out without regard to the radioactive material content of the waste. Only waste oil with radionuclide concentrations above -
limits set forth in the regulation would be considered to be of regulatory concern. EEI/m&HG ground this request upon the information contained in the Petition, as well as the technical analyses and data set forth in a report entitled "Development of Recommended Regulatory Cutoff Levels for Low-Level Radioactively Contaminated Oils from Suelear Power Plants," a copy of which is aise enclosed.
In view of the current complexity of procedures associ-ated with the disposal of slightly contarrAnated waste oil --
and especially because the levels involved are believed to be below regulatory concern -- EEI/mmHG would appreciate your
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f S3crotary July 31, 1984 ,
, Page Two prompt attention to, and action on, the enclosed Petition.
Further, action now would be particularly apptopriate in view of the recent Advisory Committee on Reactor Safeguards state-ment expressing strong support for the establishment of values identifying levels below regulatory concern.
If you have any questions or if we can otherwise be of assistance, please let me know.
Sincerely, ADU-Michael A. Bauser MAB:mjh Enclosures O e
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! , ., t ,e UNITED STATES OF ANERICA I '
NUCLEAR REGULTORY COMMISSION
- cgyfD d ":
In the Matter of *) '-j p~e.m *-
)
RULEMAKING )
) Docket No. -
Disposal of Radioactively Contaminated )
Waste Oil from Nuclear Power Plants at )
Levels Below Regulatory Concern )
) -
I. Introduction .
- Pursuant to 10 CFR S 2.802, the Edison Electric Institute
("EEI") and the Utility Nuclear Waste Management Group ("UNWMG")
hereby petition the Nuclear Regulatory Commission ("NRC" or "Commission") to issue a regulation governing the disposal of low-level radioactively contaminated waste oil from nuclear power plants. Specifically, EEI/UNWMG request that a regula-tion be promulgated establishing radionuclide concentrations in waste oil at which disposal may be carried out without regard to the radioactive material content of the waste. Only
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disposal of waste oil with radionuclide concentrations above limits set forth in the regulation would be considered of regulatory concern. EEI/UNWMG ground this Petition upon the information contained herein, as well as the technical analyses and data set forth in the enclosed report entitled "Develop-ment of Recommended 13egulatory Cut off Levels for Low-Level Radioactively Contaminated Oils from Nuclear Power Plants"
("Report") .
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- m, f OYh [hN [ '
. . -2 II. Background '
On December 27, 1982, the Commission published its final rule establishing licensing requirements for the land disposal of low-level radioactively contaminated waste (10 CFR Part 61). 47 Fed. Reg 57,446.
In the supplementary informa-tion accompanying the rule, the Commission noted that numerous commentors had requested that it develop a ,"de minimis" .
standard pursuant to which certain wastes could be dispored of by less restrictive means than existing practices. Id. at 57,453. .The Commission expressed its agreement that establish-ment of such de minimis standards would reduce disposal and long-term site maintenance costs, help preserve disposal capacity for wastes with higher activity levels, enhance over-all stability of disposal f acilities and tend to reduce ground-water migration impacts. Thus, the Commission expressed its villingness "to accept petitions for rulamaking . . . for i
i declaring certain waste streams to be of no regulatory concern,"
and identified some of the information necessary to support ,
such a petition.
_Id.
More recently, the Advisory Committee on Reactor Safe-guards (ACRS) recommended that de minimis levels of radiation exposure be established, finding that the development of such values "would complament the Commission's efforts to establish safety goals." Letter, Jesse C.
Ebersole to Honorable l e
,l* . i
.. Nunzio J. PC11cdino (Fcbruary 13,.1984). Tho ACRS concludcd that the development of de minimis values would foster consistency, equity and reasonable-ness in regulation; it would help in setting -
regulatory priorities; and it would help axpedite the solving of certain regulatory problems. In addition, such values would reduce regulatory and complianew costs by obviating the need to devote resources to consideration of trivial 1sysis of radiation exposure. Establishment of such values would also promote better public under-standing and acceptance of the potential -
effects of radiation.
Id.
The* Commission has already developed certain criteria defining regulatory cut 6ff levels for radioactively contami-nated waste. For example, 10 CFR 5 20.306 authorizes the disposal of liquid scintillation media and animal tissue containing no greater than 0.05 microcurie per gram of H-3
- cnr C 14 without regard to t!:mir radioactivity
- . On page l nine of the value/ impact appraisal accompanying the l
regulation when it was proposed, the commission concluded that "since the probable dose to exposed members of the public is less than 1 mrem per year, it is concluded that the proposed amendment.= have no significant impact on the environment."
It is also our understanding that, in draft proposed revisions to 10 CFR Part 20, the NRC Staff has defined de minimis exposure as that exposure to radiation which would present a calculated risk of biological harm so low,
- e e
rolctiva to tua risks fcc d routinoly frva dcily cctivitics, that the risk from radiation would be a trifle and of no ,
regulatory concern. We understand further that a numerical dose level of one mram was determined to represent this negligib1'/ small risk.1,/
In addition, the Commission has approved alternative methods of disposing of very low-level radioactively con-taminated waste at several nuclear power. plants pursuant to <
individual requests filed under 10 CFR $ 20.302. In several of these instances, dose estimates for various postulated
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in'dividu'als have' exceeded 1 mram per year.
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In sum, commission policy, as evidenced by its ongoing regulatory activities, recognizes a dose rate of 1 mram/ year
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It should be noted that a distinction can be made between a truly de minimis level of exposure to radioactivity, and a level of exposure below regulatory concern. A do minimis level of exposure is one which has been deter-mined to represent a negligibly small risk to the public such that it may be disregarded in evaluating compliance with NRC regulations without a consideration of the costs or resources associated with compliance. The Commission's proposed 10 CFR Part 20 revisions reflect such a truly -
de minimis value. On the other hand, the determination o? a level of exposure deemed to be below regulatory con-cern (i.e. , where the expenditure of additional resources for further reduction is unwarranted) , does net necessarily mean that that level of exposure may be considered insig-nificant without regard to the costs of compliance and enforcement.
The purpose of this Petition is to provide the analyses and information needed to support an amendment to NRC regulations identifying a level of exposure frem waste oil which may be deemed below regulatory concern when con-sidered in conjunction with the costs of continued dis-posal at licensed burial facilities. It should be pointed out, however, that the 1 mrem per year standard suggested herein has been considered to be a truly de minimis standard in the Commission's draft revisi5ns to 10 CFR Part 20.
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. t cs d7 rinimis, or prosOnting an insignifictnt icval ef risk' to the public.*/ -
Each year, quantities of waste oil containing very low levels of radioactive contamination are produced at nuclear power plants. At present, however, .the only generally approved disposal method for low-level radioactively con-taminated waste oil involves absorption or solidification, transportation to, and burial at, a licensed disposal faci,11ty.
Disposal of waste oil in this manner is costly, inconsistent with the NRC's policy in f avor of volume reduction, and represents an inefficient use of Commission, licenses and burial site resources. See Report V-1 to VI-3.
As this Petition demonstrates, however, waste oil, under certain conditions, may be disposed of in a considerably ,
more efficient manner, while providing adequate protection for both the environment, and public health and safety. Accord-ingly, the Co= mission should adopt .the. regulation proposed herein establishing radionuclide concentrations in waste oil below which disposal may be carried out without regard to the .
radioactive content of the waste.
III. The Waste Stream Low-level radioactively contaminated waste oil is generated at all operating nuclear power plants. The principal
-*/ An individual total body effective dose of 1 mrem / year is also within the operating guidelines of 10 CFR Part 50, Appendix Is is a small fraction of both the 40 CFR 190 environmental radiation dose standard and regional variations in natural background radiations and represents an annual health effect risk factor of approximately 10-7 i
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, snurces of cuch westo cil oro primary system pump motaro (including reactor coolant pumps) at pressurized water
- reactors ( " PWR s " ) , and turbines and pump motors, such as recirculation and feedwater pump motors, at boiling water reactors ("BWRs ") . Wa'ste oil also collects in turbine and radwaste building sumps, equipment drain trays and during maintenance operations (miscellaneous waste oils).1/
Report at V-1. -
Radioactivity levels for sources of waste oil such as pump tyrkines and motors at both PWRs and BWRs are
-0 typically in the 10" t.o 10 ,p Ci/mi range with Mn-54, Co-58, !
Co-60, Cs-134 and Cs-137 the dominant radionuclides. Miscal-laneous waste oils at PWRs and BWRs -- from sumps, drains, etc. -- generally contain the same dominant radionuclides,
.. . but concentrations are more variable, typically ranging
~7 ~4 from 10 jaC1/mi to 10 jaci/ml. These often are oil-
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water mixtures.' ~Piior processing might be necessary before
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disposal by some of the methods addressed in this Petition.**/ ,
See Report at V-1 to -5. -
- / Other oily wastes consist predominantly of oily rags, -
heavy sludges and oily absorbents. These wastes are better characterized as a miscellaneous waste product and are not within the scope of this Petition. Report at V-1.
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For the mixtures, pr!.or processing to remove the bulk of
. the water would be required, for example , in order for the wastes to have any recycle potential. For the purposes of evaluating regulatory cutoff levels, these oily, water mixtures f all within the scope of this Petition and the Report to the extent that the activity levels are within the bounds of the Report analysis, and the nature of the oil (either before or after any pro-cessing needed to separate the bulk of the water) is suitable for the identified disposal process. See Report at V-1.
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- 4 Th3 cbjccuiva of tha analysis pros nsed in tho R; port, and upon which this Petition is largely based, was to deter- ,
mine the maximum concentration of a mixture of fission and activation product radionuclides in waste oil, such that the waste oil can be disposed of by one or more methods without resulting in a' postulated radiation dose to the most exposed person greater than a regulatory cutoff level of one mram per year. Data on generation rates, radionuclide concentra-
,, tions and content vere gathered from 15 operating plants, including 29 units (16 PWRs and 13 BWRs). A number of specific 'isposa1' d methods were considered individually.
Those methods were to burn the oil on the nuclear reactor site in a controlled location; to burn it offsite; to spray it on an unpaved . road, as is done for dust controls to solidify it and bury it in a landfill; and to recycle it in the same manner as is done commercially with waste oil.
Report at VII-1 to VIII-3. The ultimate objective was to identify mechanisms by which waste oil at specific levels of contamination could be disposed of in an efficient, environ-mentally acceptable, cost-beneficial manner while assuring that the postulated radiation dose does not exceed the
. regulatory cutof f level. e V. Results The detailed analysis presented in the Report yields --
in essence, for each specified disposal scenario -- the limiting concentration of each radionuclide which would producean(effectivedose_ equivalent (ofonemilliremper year of exposure. See Report at VII-l to IX-3. Below, in 4
Tablo 1, ic o summary of tha dicposal 11 ts, which would t
r0sult in c dosa of cno eilliram per yocr, oc prosanted in Table IX-2 on page IX-5 of the Report.
- Table 1
SUMMARY
OF DISPOSAL LIMITS Disposal Limit Key Limiting scenario -
vCi/cm3 Isotopel* Pathways Burti on-site 3.9E-04 Co-60 Ata-Ground-Irradiation Short Stack 7.1E-04 Sr-90 Ata-Veget-Ingest 8.1E-04 Cs-137 Ata-Ground-Irradiation 1.2E-03 Cs-134 Ata-Ground-Irradiation 2.4E-03 Ag-110m Ats-Ground-Irradiation Burn on-site 3.lt-03 Co-60 Ata-Ground-Irradiation Tall Stack 7.1E-03 Sr-90 Ata-Veget-Ingest 8.1E-03 Cs-137 Ata-Ground-Irradiation
. .. .. 1.2E-02 Cs-134 Ata-Ground-Irradiation
. 2.4E-02 Ag-110m Ata-Ground-Irradiation turn off-site 3.95-05 Co-60 Ata-Ground-Irradiation Short Stack 7.1E-45 Sr-90 Ata-Veget-Ingest 8,1E-0S Cs-137 Ats-Ground-Irradiation 1.2E-04 Cs-134 Atm-Ground-Irradiation 2.4E-04 Ag-110m Ata-Ground-Irradiation Spray on Road 2.9E-03 Ag-110m Irradiation .
3.1E-03 Co-60 Irradiatico 4.1E-03 Sr-90 Resuspend-Inhale-Resident 4.4E43 Cs-134 Irradiation '
6.6E43 Fe-59 Irradiation i
7.5E43 Co-58 Irradiation ,
9.1E-03 Mn-54 Irradiation !
1.1 E-02 Zr-Nb-95 Irradiation 1.3E-02 Cs-137 Irradiation ~
1.3E-02 Zn-65 Irradiation 1.4E-02 Ru-106 Resuspend-Inhale-Resident 1.5E-02 Ru-103 Irradiation l 1.5E-02 Ce-144 Resuspend-Inhale-Resident l Solidify-Bury-t.andfill 3.8E-05 Sr-q0 Ata-Veget-Ingest :
l 2.1 E44 Cs-137 Atm-Veget-Ingest '
l Recycle 5.9E-05 Ag-110m' Sludge-Irradiation 6.3E-05 Co-60 Sludge-Irradiation 8.9 E-05 Cs-134 Sludge-Irradiation 1.3E-04 Fe-59 Sludge-Irradiation ,
l 1. 5 E-04 Co-58 Sludge-Irradiation l
- 1. 8 E-04 Mn-54 Sludge-Irradiation
- 2.1E-04 Zr-Nb-95 Sludge-Irradiation ,
- 2. 5 E-04 C s-137 Sludge-Irradiation 2.7E-04 Zn-65 S1udge-Irradiation 3.0E44 Ru-103 Sludge-Irradiation l .
- All isotopes whose limits are within a f actor of ten of the most limiting isotope are listed.
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Comparican o thesa c3nsentraticn voluco with th3so darivcd from the 15 plant study discussed in the Report reveals that .
some. of the reported oils can be disposed of by all of the disposal scenarios, and all of them can be disposed of by some such scenario, without exposing any individual to more than 1 mram per year.
. The Report notes that, from the values tabulated above !
and by conservatively assuming that all activity is from the most restrictive isotope, it is possible to specify limiting !
l gross activity levels for each disposal method. Specifically, i waste olis can be disposed of via the six scenarios considered if the gross activity levels are less than those shown below.
Table 2 GROSS ACTIVITY LEVELS i Gross "
Activity Limit i
,. Disposal Scenario FCi/cm3 (1) Burn on-site' 4E-04 Short Stack (2) Burn on-site 4E-03 Tall Stack i (3) 4E-05 Burn off-site -
Short Stack l (4) Spray on Road 3E-03 (5) Solidify-Bury 4E-05 (6) Recycle 6E-05 Report at IX-2 to -3, IX-6. , ,
It should be noted that, for disposal by methods (1),
(2), (3) and (6) , limiting concentrations of radionuclides i
L i
a in ocntaminotcd oil cro invorcoly prcportional t9 tho volume of oil disposed of each year. For these scenarios, the concentration limits presented in the above table are based on the most limiting radionuclide and disposal of no more than 1,000 gallons of' oil per year. Appendix C of the Report contains concentration limits for individual nuclides, based on disposal of 1,000 gallons of oil per year. If the amount of oil actually disposed of during a year at a site by one' of these scenarios differs from 1,000 gallons, the sum of the ratios.o,f each n.uclide present to the concentration limit for the same radionuclide should not exceed the value of 1,000 divided by the number of gallons disposed of during the year.
See Report X-1 to -3.
l VI. Conclusion Both the Commission and the ACRS have expressed support for the development of regulatory cutoff levels. The Co= mis-sion, in particular, has invited petitions for rulemaking on particular waste s: reams which might be considered below regulatory concern, and has formulated seme criteria identi-fying exposure levels deemed de minimis , and certainly below regulatory concern.
Waste oil generated in nuclear
- power plants appears to be particularly suitable for such treatment. Current methods of disposal are unnecessarily costly, inconsistent with NRC L
( .
policy fcvaring voluma rcduction, cnd rcpecscnt en inoffi-
. cient use of NRC, licensee and burial site resources.
The analyses described herein, and set forth in detail in the accompanying Report, demonstrate that techniques are available by which waste oil can be' disposed of without resulting in exposures to the public in excess of 1 mram/ year.
The 1 mram/ year standard is a conservative value which is consistent with current NRC policy. Thus, the radionuclide concentrations set forth in the attached Report should be
, utilized by the NRC in establishing guidelines for the dis-posal of waste oil without regard to its radioactive content.
I Specifically, the Commission should amend its regulations as described in the Attachment to this Petition, which is incorporated herein by reference. ,
- - Respectfully submitted,
., a./L, Michael A. Bauser Dated: July 31, 1984 NE}RUdi & HOLTZINGER, P.C.
1025 Connecticut Avenue, N.W.
Washington, D.c. 20036 l (202) 862-8400 l
l Counsel to Edison Electric Institute Utility Nuclear Waste Management Gro; 4
t l0
In tho M2tte, of RULEMAKINJ Disposal of Radioactively Contaminated Waste oil from Nuclear Power Plants at Levels Below Regulatory Concern Attachment Amend 10 C.F.R. Part 20 by:
(1,) Add,ing a new subsection (c) to section 20.306 reading as i
follows: ,
(c) Waste oil not exceeding the following gross activity 1Leits by the indicated methods, pro-vided that, the total quantity of oil disposed of at a single location by methods (1), (2),
- * (3) and (6) either not exceed 1,000 gallons per years or that i
the sum of the ratios of each radionuclide present to the
'~ ~ - ~ ~ ~ concentration of that radio-nuclide in Part 20, Appendix E not exceed the value of 1,000 divided by the number of gallons disposed of per year at that -
location, i.e.,
i 1,000
{concentrationofradionuclidt - 4
~~
g radionuclide i Part 20, App. E volume of gallons dis-concentration posed of at location (gal./yr) .
i
. . (, -)
Gross
- Activity Limit .
, Disposal Method #Ci/cm3 (1) Burn on-site 4x10~4 Short Stack
~
(2) Burn on-site, '
4x10 Tall Stack (3) Burn off-site 4x10 -5 ;
Short Stack (4) Spray on Road 3x10 ~3 ,
(5) Solidify-Bury 4x10-5 (6) Recycle 6x10-5 (2) Redesignate existing subsections "(c)" and "(d),"
" (d) " and " (e)" respectively.
(3) Add a new Part 20, Appendix E, as follows:
, , Appendix E -- Concentration Limits for Wasta 011 Disposal Under the Provisions of 10 CFR S 20.306 (c) by Element and Disposal Method CONCEN.
NUCLIDE LIMIT DISPOSAL SCENARIO (pci/cm3 )
A9110m S.9x10 l Recycle 2.4x10 2 Burn offsite-short stack
, v- 2.4x10 3 Burn onsite-short stack -
2.9x10 3 Spray on road 2.4x10 4 Burn onsite-tall stack
%.3x10 5 Solidify-bury / landfill 4
4 4
s
i CONCEN. .
NUCLIDE LIMIT DISPOSAL SCENARIO *
(pCi/cm3)
. I Cel41 1.9x10 Recycle 1.9x10 4 surn offsite-short stack 9.'6x10 4 Spray on road 5
r 1.9x10 Burn onsite-short stack 1.9x10 0 surn onsite-tall stack 1.0x10 12 Solidify-bury /lanofill Ce144 6.5x10 2 Burn offsite-short stack 3.3x10 3 Recycle v 6.5'x10 3 surn onsite-short stack 1.5x10 4 Spray on road 6.5x10 4 Burn ensite-tall stack 2.2x10 5 Solidify-bury / landfill Cc58 1.5x10 2 Recycle 2.2x10 3 Burn offsite-short stack 7.5x10 3 Spray on road 5 2.2x10 4 Burn onsite-short stack 2.2x10 5 Burn ensite-tall stack 1.6x10 9 Solidify-bury / landfill co60 3.9x10 1 -
Burn offsite-short stack 6.3x101 Recycle 1.6x10' solidify-bury / landfill
.- 3.9x10 2 Burn onsite-short stack (
3 3.1x10 Spray on road
, 3.9x10 3 Burn ensite-tall stack !
+
I I
(
. ~ . - . _ _ _ _ _ - -
CONCEN.
I NUCLIDE L.tM.IT DISPOSAL SCENARIO
~
(pci/cm3)
Cr51' 4.9x10 3 Recycle a
1.8x10" surn offsite-short stack 2.'4x105 Spray on road
- 1.tx10 6 Burn onsite-short stack 7 '
1.8x10 surn ensite-tall stack 1.0x10 12 Solidify-bury / landfill I Cs134 8.9x10 1 Recycle
~ '
".' 1.2x10 2 Burn offsite-short stack 1.2x10 3 Burn onsite-short stack !
1.7x10 3 Solidify-bury /3N2dfill I 4.4x10 3 spray on ror.d I 1.2x10 4 Burn onsite-tall stack ,
8.1x10 1
'Cs137 Burn offsite-short stack 2.1x10 2 solidify-bury / landfill 2.5x10 2 Recycle
- 8.1x10 2 Burn onsite-short stack 8.1x10 3 Burn ensite-tall stack 1.3x10 4 Spray on road i
4 Fe55 2.6x10 . Burn offsite-shcrt stack 6 2.6x10 Burn onsite-short stack 1.8x10 6 Solidify-bury / landfill 2.3x10 6 Spray on road 2.6x10 6 Burn onsite-tall stack 1.0x10 12 Recycle ,
i t
r
1 . t
~
' CONCEN.
NUCLIDE LIMIT DISPOSAL SCENARIO -
. (pCi/cm3) 2 Fe59 1.3x10 g,,y,y, 3.0x10 3 Burn offsite-short stack 6.'6x103 Spray on road
- 3.0x10 4 Burn onsita=1hort stack 3.0x10 5 Burn onsire tall stack 3.7x10 11 solidify-hury/ landfill
. Mn54 1.tx10 2 3,,y,1,
~ ~' '
6.2x10 2 Burr. offsite-cho: .. .:*ack -
y 6.2x10 3 Burn onsite-short stack 9.1x10 3 Spray on road 6.2x10 4 Burn ensite-tall stack
, 5.2x10 5 solidify-bury / landfill Nb95 2.1x10 2 Recycle 6.1x10 3 Burn offsite-short stack 1.0x10 4 Spray on road 4
v 6.1x10 Burn onsite-short stack 6.1x10 5 Burn ensite-tall stack 1.0x10 12 Solidify-bury / landfill Ni63 8.5x10 Solidify-bury / landfill 2.1x10 4 Burn offsite-short stack e 2.1x10 5 Burn onsite-short stack 2.0x10 6 Spray on road 2.1x10 6 Burn ensite-tall stack 12 1.0x10 g,,y,1,
.s.
CONCEN.
NUCLIDE ~ LIMIT DISPOSAI, SCENARIO _ .
(pCi/em3)
Pr.143 , 2.6x10 4 Burn offsite-short stack 5
, 2.6x10 Burn ensi'.e-short stack 2.6x10 6 .
Durn onsite-tall stack 1.3x10 7 $ pray on zoad 1.0x10 12 3,,y,3, ,
1.0x10 12 solidify-bury /*.andfill Tel27 1.1x10 5 ,,,y,1, 4.2y,10 6 Burn offsite-short stack 5.3'106 x Sprav on road
, 4.2x10 Burn onsite-short stack i 4.2x10 I Burn onsite-tall stack-
,, As86 1.7x10 3 Recycle 8.tx10 _.
____Rurn offsite-short stack S.4x10 4 Spray on road 8.Bx10 4 Burn onsite-short stack l 5
8.tx10 Burn ensite-tall stack-1.0x10 12 solidify-bury / landfill 3
Tel27m 1.7x10 Burn offsite-short stack 4
& l.7x10 Burn ensite-shor stack I 1.7x10 5 Burn ensite-tall stack 9.7x10 5 3,,y,y, j 1.3x10 4 spray on road 3.3x10 Solidify-bury / landfill 6-
--...--,----,-vn. - -
- -----w ,,m.n.-y-,---,-,,,_,9 - - , , , - - . . , . - , _mgn,---- - -._.., ,ng--- .s-- - - ------ -- -m -- >---
.+
(
i
' CONCEN.
NUCLIDE 4
LIMIT DISPOSAL SCENAR.,.
~
(pci/en3 ) ' '
t i Te129 1.5x10 3 Recycle 4
7.4x10 spray on . sad
' i 7
1.3x10 Burn offsite-short stack
,1.3x10' 1
Burn onsite-short stack 1.3x10' Burn onsite-tall stack Te29m 1.4x10 3 Reeycle 3.tx10 3 Burn offsite-short stack I
< 3.tx10 4 Burn onsite-short stack 6.9x10 4 spray on road t
5 3.8x10 Burn ensite-tell stack l
1.0x10 12 solidify-bury / landfill i
'
- 2 Rul03 3.0x10 g,,7,3, 7!6d0 3 Burn offsite-short stack !
1.5x10 4 spray on road !
4
- 7.6x10 Burn onsite-short stack j 5
7.6x10 Burn onsite-tall stack 1.0x10 12 Solidify-bury / landfill ,
Rul06 5.9y10 2 Burn offsite-short stack 7.1x10 2 3,,y,y, l
' / 5.9x10 Burn onsite-urort stack l 1.4x10 4 1
spray on road !
J 4 i 5.9x10 Burn onsite tall stacx 4.7x10 5 Solidify-1.me landtill I i
I [
- l l
4 , . ', :
CONCEN.
NUCLIDE LIMIT DISPOSAL SCENARIO .
pCi/cm3) 3 5r09 3.1x10 Burn offsite-short stack e 3.1x10 4 Burn onsite-short stack 5
4.9x10 Spray on road 6
1,9x10 ,,,y,y, 2.1x10 6 Burn onsite-tall stack 2.9x10 10 Solidify-bury / landfill Sr90 3.8x10 1 solidify-bury / landfill 7.1x10 3 Burn offsite-short stack 2
4 7.1x10 Burn ensite-short stack 4.1x10 3 Spray on road 7.1x10 3 Burn ensite-tall stack 1.0x10 12 Reacycle Y91 2.9x10 3 Burn offsite-short stack 2.9x10 0 Burn onsite-short stack 4.4x10 4 Recycle 5
2.9x10 Burn ensite-tall stack' 4.4x10 5 Spray on road
, 6.2x10 8 Sclidify-bury / landfill
- 2.7x10 2 ,,,ygg, Zn65 1.0x10 3 Burn offsite-short stack 5.0x104 Burn onsite-short stack 1.3x10 4 Spray on road 1.0x10 5 Burn ensite-tall stack 5.8x10 5 Solidify-bury / landfill m
(
C011CEN .
DISPOSAL SCENARIO
- LIMIT (pCi/em3)
NUCLIDE g,,ygy, ,
2 2.1x10 Burn offsite-short stack :,sl; c 3
Er95 *n- ~
3.4x10 Spray on road ;, t . i ;
4 a,I 1.1x10 Burn onsite-short stack 4 .
i 3.4x10 lurn onsite-tall stack 5
3.4x10 Solidify-bury / landfill 4.0x10' O $
e
- e
MAY 191987 A0 MEMORANDUM FOR: Eric S. Beckjord, Director Office of Nuclear Reoulatory Research FROM: Victor Stello, Jr.
Executive Director for Operations
SUBJECT:
CONTROL OF NRC RULEMAKING By memorandum of February 13,1984, "Control of NRC Rulemaking by Offices Reporting to the EDO," Offices were directed that effective April 1, 1984, (1) all offices under EDO purview must obtain EDO approval to begin and/or continue a specific rulemaking, (2) resources were not to be expended on rulemakings that have not been approved, and (3) RES would independently revie# rulemaking proposals fomarded for EDO approval and make reconr'endations to the ED0 concerning whether or not and how to proceed with the rulemakings.
In accordance with this directive, the following proposal concerning rulemaking has been forwarded for my approval.
Proposal to initiate rulemaking, "Amendment to 10 CFR Part 20.305 (Disposal of Waste Oil by Incineration)". (Sponsored by RES . memorandum, Beckjord to EDO dated March 11,1987).
I approve initiation of this rulemaking which should be issued in final fonn for inplementation within two years. The NRC Regulatory Agenda (NUREG.0936) should be modified to reflect the status of this rulemaking.
- e. m .
Victor Stello, Jr.
Executive Director for Operations cc: J. Taylor T. Murley H. Thompson W. Mcdonald H. Denton W. Parler kegional Administrators Distribution:
V5tello GMarcus,RES[
MTaylor DGrimsley, ARM WSchwink Central Files EDO r/f s>\/
)FC :0EDO 0EDO A0/EDO plEDO : : :
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RME :LRoch .:: day 1 r :TRehm L:VStt ,o : : :
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OFFICIAL RECORD CCFY f0(*2l 000 Q.
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