ML20210H952

Responds to Re Public Health & Safety Concerns Concerning Proposal to Bury Potentially Radioactive Contaminated Wastes at Facility.Matl Proposed Consists of 34,000 Cubic Ft of Very Low Level Sludge Every 5 Yrs

ML20210H952
Person / Time
Site:	Davis Besse
Issue date:	03/26/1986
From:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	Oakar M HOUSE OF REP.
Shared Package
ML20210H955	List: ML20210H952 ML20210H958 ML20210H964 ML20210H979 ML20210H988
References
NUDOCS 8604030277
Download: ML20210H952 (6)

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1. %g UNITED STATES j l NUCLEAR REGULATORY COMMISSION j y, j WASHINGT ON. D. C. 20655

\*****/ MAR 2 61986 i y c3 - M The Honorable Mary Rose Oakar United States House of Rep,resentatives Washington, DC 20515

Dear Congresswoman Oakar:

Your letter o'f January 28, 1986, to Chaiman Palladino has been referred to me by Judge Plaine. I will address the NRC's-actions with regard to your public health and safety concerns regarding the proposal to bury potentially radioactively contaminated wastes at the Davis-Besse Nuclear Power Plant site.

Judge Plaine, in his February 25, 1986 letter, explained that the Comission had ordered an informal public hearing on this issue which addresses one of your concerns. The purpose of this letter is to address the other issues raised in your letter. _

The material proposed for disposal consists of approximately 34,000 cubic feet i ~ every five years of very low level radioactive sludge. The material would be deposited in shallow trenches and covered with topsoil. There are several pathways for exposure to the material that can be postulated. These include standing over the disposal area, eating food grown on the disposal arei,.

inhalation of wind borne dried sludge, and drinking ground water. Because the

, disposal site is on land owned by Toledo Edison Company, the first two paths l

are unlikely and the method of disposal virtually eliminates the third path.

The total body dose from the remaining path, drinking ground water, is

estimated to be less than 0.1 millirem per year. The U.S. EPA has issued i

standards for the exposure of individuals to radioactivity from the nuclear fuel cycle. These standards specify that no member of the public receive an l annual dose in excess of 25 millf rem from planned discharges from nuclear fuel

(, cycle operations. This dose would be only 0.4% of that exposure. When ~

, compared to the U.S. EPA drinking water standards applicable to community water supplies, the dose is 2.5% of the 4 millirem standard. This low level of exposure does not represent a threat to public health and safety nor will it damage aquatic and wildlife in the vicinity.

With regard to disposal of this material under the recently enacted Midwest Interstate Low Level Radioactive Waste Compact, it is import' ant to note that t

the compact only establishes the framework under which the member states will l~ work. No site has yet been identified or agreed to and neither has the host I state. Although the Low Level Radioactive Waste Policy Amendments Act of 1985 l mandates an operating site by 1993, there is no assurance that such a site will be available by then. Indeed, the Compact, itself, allows for member states to withdraw from the Compact. Furthermore, it is not likely that an approved site could be available much before 1993 even if agreement on the site, engineering, construction, and licensing proceeded expeditiously. If this deadline is not met, the Act provides that the State of Ohio would be obligated to take possession of the waste and it would be liable for direct and indirect damages if the State failed to take possession of the waste.

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_2 It should be noted that approved space suitable for the disposal of Icw level radioactive waste is a limited and valuable national resource. As such, it should not be needlessly consumed by burial of wastes which are only slightly contaminated and which can be safely disposed of at other locations. On October 16, 1981, in its Policy Statement on Low-level Waste Volume Reduction published in the Federal Register, the NRC recognized the need to minimize the quantity of waste generated and shipped to waste disposal sites.

With enly one exception, existing regulations provide no minimum level of radioactivity.in waste from a licensee's facility that may be disposed of in a manner other than as radioactive waste. The Commission has recognized the need for similar provisions for other wastes that would be exempt and of no regulatory concern. The need for this is recognized by the Low Level -

Radioactive Waste Policy Amendment Act. Section 10 of the Act requires the Commission to establish standards and procedures and the technical capability  :

to act upon petitions to exempt specific radioactive wastes from regulation by the Commission due to the presence of sufficiently lou quantity of radiation to be of no regulatory concern.

There are presently few alternatives to burying these wastes on the plant site. The wastes could be processed as low level wastes, packaged in appropriate containers, and shipped to a licensed low level radioactive waste disposal site. There are only three such sites --Barnwell, SC, Richland, WA ,

and Beaty, NV,-- which are now accepting such wastes. Each shipper, however, is under a volume allotment because of the limited availability of burial "

space at these sites. Utilizing the limited capacity of these sites for very low level waste would needlessly consume a valuable national resource. The ,

wastes could be left in the settling ponds at Davis-Besse and new ponds could be made. This is not a practical solution because it delays the problem instead of solving it and the cost and time required to construct new ponds would be prohibitive even if a suitable location for such ponds could be found onsite.

- The NRC's action with respect to the Davis-Besse proposal is consistent with the Consnission policy as stated on October 19, 1981 and is not inimical to the health and safety of the public.

.To understand why this material is acceptable for on-site burial, it is useful to under. stand its source. .The waste material consists of water purification resin sludge which has been accumulating in two on-site settling ponds since facility operation was authorized in 1977. The resin is used in the plant in two separate but similar applications. One application, the one that produces the most waste, is to purify raw water before it is used in the plant. This application does not result in any radioactively contaminated waste. The other application is to purify secondary system water before it is returned to the steam generators to produce steam for use in the power conversion cycle.

Possible leaks through the steam generator tubes from the primary water cooling the reactor will carry some radioactive material into the steam system which can be removed by the water purification resins located in the secondary system.

Radioactive contamination of these resins is normally very low since Davis-Besse has had an excellent record with respect to steam generator tube leakage. The longest half-life associated with the contamination does not exceed 30 years and about 65% of the contamination has a half-life of 5 years or less.

4 When the power conversion secondary system resins are no longer effective in performing the purification function, they are transferred to a holding tank for monitoring and are replaced with fresh resin. Samples are taken to measure the amount of radiation present on the used resin. If significant radioactivity is present, the resins are transferred within the plant to be

further processed and prepared for shipment to licensed radioactive waste disposal sites. If no significant radioactivity is measured, the resins are discharged to the settling ponds. This process provides assurances that only very low level wastes are transferred into'the settling ponds, i The resins which are discharged to the settling ponds settle to the bottom of the ponds where they accumulate along with resins discharged from the raw water purification process. The water which is used to flush the resins to the settling ponds is discharged to Lake Erie. Periodically, the accumulated resins must be removed from the ponds by dredging and disposed of.

- We trust that this letter has been fully responsive to the issues raised in your letter. Please contact us if we can be of further assistance.

Sincerely, Original Signed by Victor Stello ,

1 Victor Stello, Jr.

Acting Executive ~ Director i for Operations DISTRIBUTION Docket File or Central File OCA i NRC PDR w/inc.

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The Honorable Mary Rose Oakar United States House of Representatives Washington, DC: 20515-

Dear Congresswoman Oakar:

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Your letter of January 28,~1986, to Chairman Palladino has been referred,to'me by Judge Plaipe. I will address the NRC's actions with regard to your'public

' health and sahty concerns regarding the proposal to bury potentially radioactively cohtaminated wastes at the Davis-Besse Nuclear Ro dr Plant site.

Judge Plaine, in his February 25, 1986 letter, explained that'the Commission had ordered an inform,al public hearing on this issue whjch addresses one of your concerrs. The purpose of this letter is to address the other issues raised in your letter. \ /

\ /

The material proposed for ' disposal consists of approximately 34,000 cubic feet every five years of very lowNevel radioa,ctive sludge. Using an estimate of the maximum radioactivity in the sludge at the time of dredginc, t.he NRC estimated the maximum radiation'exposu're to individuals from possible exposure paths including external exposure)from standing over the disposal area, eating food grown over the disposal ar water from the nearest well,,an,ea (notofawindborne d inhblation likely possibility), drinking dried sludge-(not a ground likely possibility). By this conservative estimate, the total body dose from all these ' routes, when combined for a slagie individual ~are less than 4 millirem per year. ,eThe average dose frq naturally occurring radioactivity in Ohio is about 100' millirem per year. These estimates were reported in the NRC's notice in the Federal Register on Octobi 9, 1985.

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With regard,td Interstate't.ow disposal Level of this Radioactive material Waste Compact,under t g(recently it s important enacted to note that Midwest the compe'ct only establishes the framework under which the member states will work /No site has yet been identified or agreed to andweither has the host state. Although the Low Level Radioactive Waste Policy Ainendments Act of 1985 mandates an operating site by 1993, there is no assurance that such a site will be available by then. Indeed, the Compact, itself, allow's for member states to withdraw from the Compact. Furthermore, it is not likely that an approved site could be available much before 1993 even if agreement on the site, engineering, constructicn, and licensing proceeded expeditiously. If this deadline is not met, the Act provides that the State of Ohio would be

-obligated to take possession of the waste and it would be liable for direct and indirect damages if the State failed to take possession of the waste.

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. . l 3-When the power co.nversion secondary system resins are no longer effective in performing the purification function, they are transferred to a holding tank

~ for monitoring and are replaced with fresh resin. Samples are taken to ,

measure the amount of radiation present on the used resin. If significant '

radioactivity is present, the resins are transferred within the plant to be further processed and prepared for shipment to licensed radioactive waste disposal sites. If no significant radioactivity is measured, the resins are discharged to the settling ponds. This processs provides assurances that only very low level wastes are transferred into the settling ponds.

The resins which discharged to the settling ponds settle to the bottom of the ponds where they a'ecumulate along with resins discharded from the raw water purificaiton proce h . The water which is used to flush the resins to the settling poinds' is discharged to take Erie. Periodically, t b accumulated resins must be removed from the ponds by dredging and disposed of,

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Wetrustthatthisletterhasbeekullyresponsivetotheissuesraise.

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your letter. Please contact us if we an be of further assistance.

/

Since eJy,

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yJc' tor Stello, r.

ActingExecutive'Qirector for Operations \

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DISTRIBUTION.

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RIngram PBD-6 Green ticket file, P-214 V. Stello J. Roe T. Rehm G. Cunningham

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EDO PRINCIPAL CORRESPONDENCF CONTROL l'7' FROM: ,

DUF: 03/67/86 EDO CONTROL: 001451 DOC DT: 01/2S/86 REP. MARY ROSF OAKAR FINAt RFPLY:  !

(REFERRED BY MEMO MAlSCH.OGC TO REHM, 2/21/86 l

TO:

CHAIRMAN PAL LADINO FOR SIGNATURE OF: ** PRIORITY ** '

SFCY NO:

EXECUTIVE DIRECTOR l

DESC: ROUTINO:

DURIAL OF LOW-LEVEL WASTF NEAR DAVIS-BFSSE STFLLO

. DATE: 02/21/S6 'J/g ~

ROE RFHM ASSIGNED TO: NRR CONTACT: DENTON SNIF7EK

'N DAVIS OCUNNINGHAM SPECIAL INSTRUCTIONS OR RFMARKS: TAYLOR COORDINATF RFPLY WITH NMSS & ELD. M NRR RECEIVED: 2/25/o6 j ACTION: OPL-B: MIRAGCA j dp NRR ROUTING: DENTON/EISENHUT PPAS i M0SSBijRG l

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