ML20207N159
| ML20207N159 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1988 |
| From: | Timothy Mccartin NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Roles G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20205F142 | List:
|
| References | |
| FOIA-88-361 NUDOCS 8810180533 | |
| Download: ML20207N159 (13) | |
Text
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tY Note to: Gary Rcles, NMS5 From: Tim McCartin, RES/- e.y I have reviewed the book entitled "Living Without Landfills". The author has' combined facts, generalities, and a premise that any radioactive release is "hazardou", to write a very opinionated book on a nct so technically controversial subject. Dr. Resnikoff cites examples of large exposures in foreign ecuntries and talks cf "eternal vigilance" to further sensationalize the disposal of low-level waste. Dr. Resnikoff's zero release premise causes wonder as to how mankind has survived natural background radiation.
The author is using the book to condemn nuclear power rather than provide a meaningful discussion or, near-surface disposal of low-level waste.
Dr. Resnikoff uses most of the book detailing how the nuclear power industry is creating a "low-level radioactive waste crisis" while giving only a token discussion on the hydrologic / geologic considerations important to near-surface disposal. The author's ignorance of hydrology is no more evident than in his invention of hydrologic terminology such as: "water _inmigration to trenches".
A formi review of this book supplies it with credibility it does net deserve.
Unless NRC plans to fonnally review all books dealing with low-level waste, I do not understand why valuable staff time should be expended on a formal review of this book. ,
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i 8910100533 000916 p i
, RESNIKOBO-361 PDR (/
RlLEASEOFLONG-LIVEDRADI0ACTIVEMATERIAL TO SANITARY SEWAGE SYSTEMS BY D. M. COLLINS i
i Within the past few years, the NRC and Agretrent States have noted instances where releases of radioactive material to sanitary sewer systems have resulted 4
in the low level contamination of the sewer p!oing and sewage sludge. In most i
instances these releases were planned and well within regulatory limits or were inadvertent releases of very low concentrations of radioactive material to the sanitary sewer systems. This paper will outline the circumstances surrounding ,
several of these cases and will discuss specific licensees' corrective actions.
l NRC regulations, in 10 CFR Part 20.303, authorize the disposal of low concentrations of radioactive material into sanitary sewerage systems. >
j Agreement States have similar authorizations in their regulations. Those !
l regulations limit monthly average concentrations of radioactive material ,
released to those listed by isotope, allow consideration of dilution with other l l
l licensee sewage input, and specify an annual quantity limit of one Curie for {
i most radioactive material. The regulation clearly specifies that r4terial
- released into a sanitary sewer system must be "readily soluble or dispersible i '
in water." This regulation, when promulgated in 1957, assumed that such
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! releases would mix with a much larger volume of sewage from other sources and f l result in negligable impact on the public. Recent experience has shown that
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the effectiveness of current state-of-the-art water treatment plants may need to be., considered as part of the decision-making process for releases of
, radioactive material te sanitary sewers. Listed below are outlines of several cases where such releases have had impacts offsite.
- In March of 1984, a radiation survey (using Na! probes) of soil that had been excavated around a sewer line showed low levels of radiation above background.
The surveyors checked inside a manhole near this a,rea and found elevated !
radiation readings and detected radioactive contamination. Soil samples from ;
the area showed approximately 400 pCi/g Cs-137 and 1000 pCi/g Co 60. The survey team notified the State for followup. I i
i State represtntatives promptly responded to the area. Using Na! and pancake t
probes they traced the sewer line contamination back to its likely source, a u
l company that decontaminated equipment from nuclear power plants.
l l Comprehensive surveys of the sewer lines were instituted. The highest direct radiation level found in the sewer lines was 45 microR/hr ($ times background). l l '
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l The cogany involved ceased all releases to the sanitary sewer and agreed to decontaminate the contaminated soil offsite, to decontaminute the onstte sump, and to assist the city in the future whenever repas neceLary on a l potentially contaminated sewer line, j l
l In addition, surveys were made of the city Waste Treatment Plant (WTP). This plant, which began operation in 1982, consisted of a grit separator, settling 1
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tanks, aeration tanks, sand filters, sludge digesters and sludge storage tanks.
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l.ow level contamination of the sludge at the WTP sludge was detected. Samples of thi,s sludge during 1984 showed Cs-137 concentrations in the 10-5 to 10*6 uC1/ml range with a maximum of 5.4 x 10~6 uC1/mi in wet sludge or 79.6 pCi/gm in driod sludge. A complicating factor was that the sludge from the WTP had been spread since November 1983 on land within a DOE reservation. The sludge was being used as a nutrient supplement for trees planted on poor quality forest sittn Upon notification of the detection of low level radioactive contamination in the sludge, DOE ceased spreading sludge on the site.
An evaluation of impact on pubite health and safety was made by DOE and the State. A detailed pathway dose analysis for the material spread on- DOE property showed the dose comitment to the whole body of 1.1 mrem / year and the dose cor:initment to the endosteal cell (bone - critical organ) of 4.2 mrem / year.
4 A similar analysis by the State for an individual using the sludge as a i
fertilizer in a garden thewed a maximum dose of 6 mrem /ycar.
- the licensee was cited for releasing material to the sewerage system that was not "dispersible. After the licensee installed an irtproved filtration and ion exchange system to treat effluent, the licensee was eventually allowed to release process effluent to the sanitary nwage systems. This authorization l 3
added much tighter restrictions on the concentretions of radioactive material j
- allowed in releases. !
i l It should be noted that the maxirrum cue.entration of Cs-137 in sludge necurred in January 1986, several years af ter the 11ctnsee ret.uced releases. This is an indication of the time required for materials to be fully processed through the sewage treatment system, especially the digaster, which is only partially
4 decanted periodica1'ly. This discovery by the State led to initiation of a progr.4m to minimize certain Itcensees' release of radioactive material to sanitary sewers and a program to routinely analyze sanitary waste treatment plant sludge for radioactivity. It is this routine sampling and analysis program that led to the finding in 1986 of another plant with elevated levels of radioactivity.
The 1984 finding by this State and two other events,, where contamination wi.:
found at sewerage treatment plants, led to the issuance cf NRC Infonnation Notice No. 84-94, "Reconcentration of Radionuclides Involving Otscharges into Sanitary Sewage Systems Permitted Under 10 CFR 20.303." !
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The other two cases noted in the Information Notice involved Am-241. In one case, Am-241 contamination was found in tons of ash at a concentration of
, 500 pC1/g. This ash was the product of incineratton of the sludge at the
! treatment plant. About 10,000 tons of ash haa been disposed of in a landfill. ,
I About 30 tons of ash remained in the sewage treatrent plant and ancillary equipment. ,
The other example listed in the Information Notice outlined the finding of concentrations of about 100 pC1/g of Am-241 in the sludge at ar.other sewage treatment plant. This sludge had been disposed of in a sanitary landfill.
Both occurrences of Am-241 contar.ination resulted from releases of Am-241 to sanitary sewage systems by two separate licensees who manufactured As.241 foils for use in smoke detectors. .-
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These occurrences of unexpected buildup of radioactivity in sewage treatment systems were not the first instances of contamination buildup in sewage sludge that had resulted in an Infonnation Notice. During the late 1970s, power reactor licensees, during their routine environmental monitoring, found low levels of radioactiwity in pathways around nuclear power plarets that were not planned discharge paths to the environment. As a result, the NRC issued to l
power reactor licensees Bulletin No. 80-10. "Contamination of Nonradioactive 2
System and Resulting Potential for Unmonitored. Uncontrolled Release of Radioactivity Trs Environment." This Bulletin directed special attention to the sanitary waste system. In response to this Bulletin, reactor licensees began avomented monitoring of nonradioactive systems that could become contaminated.
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One powat reactor licensee found, iri performing surveys of the sewer drain lines, radiath>n levels two to three times background. The licensee operated the sewage treatae t plant for their site. The licensee had been monitoring r
the liquids released from the sewage treatment plant, but had not been monitoring the sludge. The waste treatment process had concentrated into the sludge the low concentrations of radioactivity in the untreated liquid. Sludge ten:ples showed approximately 10-6 micro C1/g of Co-60. Two truckloads of :
sludge had been disposed of on offsite fields. The fields had been used for grazing beef cattle. Soil and grass samples from the field showed l concentrations of Co-60 up to 100 pC1/g. The highest concentration of Co-60 in I grass wo 5 pC1/g. The area where the sludge had been dumped was detennined i
using aerial helicopter surveys and on ground surveys. The licensee excavated !
I the cont.minated soil from an area of 20 ft, by 60 f t, to a depth of 6 to
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12 inches. The soil was reenoved from this broad a'rea until the remaining l
levels were belcv 0.5 pC1/g. Soil was removed from other, smaller, discrete (
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/* areas untti the reimaining levels were 5 pct /g for each small ama. The !
licensee-performed a cogrshensive environmental survey that included grass. ,
1 l soil, ground water and pond water analyses. The removed din was buried as ;
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j contaminated waste. !
} l Also certain ' licensees have made releases of sludge to onsita locations using i measurement systems with an "operational" MDA. Several years later, using j "environmental" M)As. these licenseas have detected very low levels of ;
j contamination in the sludge. )
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j Recently, other power reactor licensees and a fuel facility have been cited by j the NRC for failure to survey sludge from their sewage treatment plants prior to oisposal in landf' ills or by spreaoing on licensee owned land. The NRC piant to issue an additional Information Notice to power reactor licensees providing !
information on recent power reactor problems with contaminated sludge disposal.
I j But power reactor licensees are not the only licensees who have encountered i
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recent problems with 194 cts from releases of process and other radioactivity !
j to the sanitary sewer. !
4 In late September 1986, the NRC wss infereed by a State of preliminary results l of analyses of sludge from a waste water treatment plant (WTp'. s These results
! I were in the range of 700 to 800 pCi/g of uranium for a sample collected in j 4 August 1986. A March sample had shown approximately 340 pct /g of utantum, i
i Normal results would have been in the range of 10 pC1/g. The only potential l
} source of the uranium was a fuel processing plant located in the area and which 6
j was tied to the sanitary sewage system. The NRC and t State began a series l- Cf intensive inspections into and evaluation of this finding. Initial surveys j . . .
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7 and sample analyses
- in early October 1964 confinmed the finding that sludge at the sewage treatment plant had elevated levels of uranium. A two-fold approach was initiated for resolution of these and subsequent findings -- reduction and/or elimination of sources of radioactivity into the sewer system and evaluation of, and remedial action as necessary of, offsite impacts.
With regard to effluent reduction and elimination, reviews of effluent release records by tne licensee and the NRC showed that concehtrations of uranium released to tre sanitary sewer was and had been for several years less thaa 15 of limits. These concentration results had been confirmed b/ independent analyses of the effluent samples by the State under contract to the NRC. The majority of the inputs to the sanitary sewer system had been eliminated in the early 1980s. Very few of the process streams were still routed to the sanitary sewer. The licensee took prompt and successful action to eliminate, by the end of December 1986, more than 90% of the input of radioactive material into the sewer system. By June of 1987, all inputs into the sanitary sewer system, ext.tpt sanitary waste, were teminated.
The evaluation of the impact offsite was complex since, for the previous several years, the sludge had been distributed to an offsite location for use as fertilizer on pasture land. In addition, the sludge had been used as fill at the grounds of the WTP, Initial analyses of the pasture land showed less than 10 pC1/g uranium. These first few sample results showed that further detailed evaluation of the impacts was necessary.
Under contract to the NRC, Oak Ridge Associated Universities performed a comprehensive survey of the WTP to determine the extent of contamination. The O O
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WTF had scheduled to begin excavation for expansion of the facility in the early spring of 1987. The comprehensive survey of the area showed concentrations of uranium up to approximately 1000 pC1/g with an average of approximately 60 pC1/g and also identified thorium (up to 40 pC1/g) and low levels of plutonium (up to approximately 100 pCi/g). The licensee had implemented a program that did not purposely dispose of plutonium via the sanitary sewer system, and it is not clear how this material entered the
',anitary sewage system. Based on these results, the soil containing higher concentrations of radioactive material (greater than 300 pC1/g) was separated from the other soil excavated during construction of the new facilities. Air 1
sagling was performed during this excavation. No positive indications of i
airborne radioactivity were detected during this sampling. This soil,
.i approximately 6000 f t*, was set aside.
1 The licensee and NRC evaluated the impact of working with or utilizing the j contaminated sludge on pastures. Results showed the maximum dose to an I
j individual to be less than 1 mrem per year. The licensee estimated the dose to I be approximately the same as that received during the use of "normal" <
fertilizer which contains natural radioactivity. l j 1
] As coastruction of the expansion to the WTP is completed, the higher level soil will be placed at the deepest part of the excavation and mixed in with other fill. Additional sagling and analyses of the soil will be perforced l af ter construction is complete. I This example is one of a recent series of examples that indicates that release cf radioactive materials into sanitary sewer systems well below the NRC's
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limits may result in higher than anticipated concentrations of radioactive material in sewage treatment plant sludge. The NRC has under consideration chanses to NRC regulations to include evaluation of the very effective concentration of certain radioactive materials in sludge at modern treatment plants.
Those who operate their own sewage treatment plants should be aware that NRC regulations prohibit disposal of low-level contaminated sludge as nonnal waste
-- unless application is made for specific approval under 10 CFR 20.302(a). '
The NRC has issued two Infonnation Notices on the use of this portion of the t regulation, Information Notices 83 05, "Obtaining Approval for Otsposing of Very Low 4evel Radioactive Waste - 10 CFR Section 20.302." and 86-90, "Requests l
to Dispose of Very Low 4evel Radioactive Waste Pursuant to 10 CFR 20.302." At !
least one power reactor Itcensee has made application under 10 CFR 20.302 to !
dispose of low-level contaminated sludge from sanitary sewage systems. This proposal was found acceptable by the NRC, but also required State approval. !
The NRC has published a policy statement on residual uranium and thorium l l
entitled, "Disposal or Onlite Storage of Residual Thorium or Uranium (either as ,
Natural Ores or Without Daughters Present) from Past Operations." ;
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As shown by the examples above, the release of even low concentrations of j radioactive material to sanitary sewage systems can result in reconcentration 1 l
of radioactive materials at sewage treatment plants. Caution should be I exercised in such releases to assure that sludges from such plants do not {
contain significant concentrations of radioactive material.
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