ML20235T912
| ML20235T912 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/08/1987 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-87-104 TAC-61882, VPNPD-87-430, NUDOCS 8710130280 | |
| Download: ML20235T912 (51) | |
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e 1 WISCONSIN Electnc eowra couranr s 231 W. MICHIGAN, P.o. BOX 2046, MILWAUKEE, Wl 53201 (414)277-2345 h VPNPD-87-430 NRC-87-104 October 8, 1987 1 U.S. NUCLEAR REGULATORY COMMISSION Document Control Desk Washington, D.C. 20555 Gentlemen: l DOCKET NOS. 50-266 AND'50-301 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR 10 CFR 20.302 APPLICATION POINT BEACH NUCLEAR PLANT On July 14, 1987, Wisconsin Electric Power Company submitted an application, under the provisions of 10 CFR 20.302, for approval of a proposed procedure to dispose of sewage treatment sludge containing minute quantities of radioactive materials. Sub-sequent to the application, Mr. Ted Quay of the NRC staff requested additional information regarding the environmental characteristics of the area surrounding the Point Beach-Nuclear Plant. The responses to this' request were furnished in our submittal dated August 6, 1987. By letter dated September 9, 1987, the NRC has requested Wisconsin Electric supply additional information in order.to complete the review of oar _ application. This Request for Additional Information (RAI) contains ten-specific items which require responses or' commitments from Wisconsin Electric. In addition, the NRC requests the previously_ submitted information and the information supplied in response to the RAI be. compiled into "one complete, extensive, and self-contained _ package" . To facilitate your review, Attachment'I-is included.to provide direct responses to the ten items contained in the RAI. Attachment II is provided as the complete application, including the information from our letters dated July.14, 1987, and-August 6, 1987, and information supplied in response to the NRC RAI. 1 i We request that you complete your' review of.this complete, ! self-contained package and issue an approval of our application 8710130200 871000 PDR ADOCK 05000266 I D PDR g i l
4 October'8, 1987 Page 2 as soon as possible. In order to facilitate your review and to expedite processing, we would be pleased to discuss these matters or provide additional information by telephone. Please feel free to contact us. Very truly yours, f
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bb' / C. W. Fay Vice President Nuclear Power bjm Attachments Copies to NRC Resident Inspector l NRC Regional Administrator, Region III l
_----,y.. , . . h ATTACHMENT I RESPONSES TO QUESTIONS CONTAINED IN THE REQUEST FOR ADDITIONAL INFORMATION (RAI) ON POINT BEACH 1 AND 2 REQUEST FOR DISPOSAL OF LOW LEVEL RADI0 ACTIVITY CONTAMINATED SEWAGE SLUDGE BY LAND APPLICATION WISCONSIN ELECTRIC POWER COMPANY UNDER 10 CFR 20.302(a) l 1 l l i
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The. numbering system used in these responses corresponds directly to. numbering used in the NRC RAI, dated September 9, 1987.
- 1. a. This request is for multiple applications, approximately 2 to 4 per year.
- b. This request is for multiple years, expiration to coincide with conclusion of decommissioning activities associated with retirement of PBNP Units 1 & 2.
- c. Please refer to the response to question number 10.
- 2. The pathways used to determine doses to both the maximally exposed individual and the inadvertent intruder are documented in Attachment II, Appendices D and E.
Due to the extremely low concentrations of radionuclides in the sewage sludge and the associate low doses, Wisconsin Electric will-control access to the disposal sites by conditions.of use defined in lease agreements with the lease. Use.of the land is not controlled beyond the conditions of the lease, thereby not restraining a casual visitor _- from the disposal site. However continuous occupancy would be readily observed, and remedial action would'be taken.
- 3. Inform? tion contained in previous submittals has been included in Attachment II with modifications to provide specific commitments to the NRC.
- 4. Please refer to the response to question number 10.
- 5. Site maps have been updated and are included in Attachment II, Appendix C.
- 6. The direct grazing of cattle on the proposed disposal sites is j l controlled by restrictions contained in the lease agreement. j There will be no restrictions placed on fishermen on Lake Michigan.
Calculations of doses due to all pathways associated with a release to Lake Michigan (Attachment II, Appendix E) do not indicate a need to apply restrictions to fishermen.
- 7. Please refer to revised site maps included in Attachment II, 1 Appendix C. Site number 5 is located on company owned land i beyond the PBNP site boundary. All other sites are within the !
PBNP site boundary area. i l 8. a. Please refer to Attachment II, Section 3.2, Disposal Procedure, j
- b. Please refer to Attachment II, Section 3.2, Disposal Procedure. !
- c. Please refer to Attachment II, Section 3.2, Disposal Procedure.
I d. Please refer to Attachment II, Appendix A. ! l Please refer to Attachment II, including Appendix D and Appendix E
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for additional pathways analyzed for this submittal. These identified ; pathways will be analyzed prior to all subsequent disposals to insure doses are maintained within' prescribed limits, i.e., 1 mrem / year to'the i maximally exposed individual and 5 mrem / year to the inadvertent intruder.
- 10. A limiting concentration level for the sludge contained in the storage tank is discussed, in Attachment II, Appendix F. Since this application is for multiple applications over multiple years, Attachment II, Appendix F also addresses an activity limit.
5 l ATTACHMENT II COMPLETE ANALYSIS AND EVALUATION POINT BEACH NUCLEAR PLANT 10 CFR 20.302(a) APPLICATION 1 l l I I l 4 1 i t )
e i 1.0 Purpose By this submittal Wisconsin Electric Power Company requests approval of the U.S. Nuclear Regulatory Commission for a proposed procedure to dispose of sewage treatment sludge containing trace quantities of radionuclides generated at the Point Beach Nuclear Plant. This request is submitted in accordance with the provisions of 10 CFR 20.302(a). 2.0 Waste Description The waste involved in this disposal process consists of the residual solids remaining in solution upon completion of the aerobic digestion sewage treat-ment process utilized at PBNP. The PBNP sewage treatment plant is used to process waste water from the plant sanitary and potable water systems. These systems produce non-radioactive waste streams with the possible exception of wash basins located in the radiologically controlled area of the plant. These wash basins are believed to be the primary source of the extremely small quantities of radionuclides in the sludge. l l The sewage sludge generated at PBNP is allowed to accumulate in the sewage I plant digestor and aeration basin. Two to four times annually, depending l on work activities and corresponding work force at PBNP, the volume of i the sludge in the digestor and aeration basin needs to be reduced to allow l continued efficient operation of the treatment facility. The total volume of sludge removed during each disposal operation is typically on the order of 15,000 gallons. The maximum capacity for the entire PBNP treatment l facility and hence the maximum disposal volume is about 30,000 gallons. In the case of a maximum capacity disposal, doses would not necessarily increase in proportion to the volume, since more than one disposal site may be used. Trace amounts of radionuclides have been identified in PBNP sludge currently being stored awaiting disposal. The radionuclides identified and their l concentrations in the sludge are summarized below: j Nuclide Concentration (pCi/cc) Co-60 2.33E-07 Cs-137 1.50E-07 The total activity of the radionuclides in the stored sludge, based on the identified concentrations and a total volume of 15,000 gallons of sewage sludge, are as follows: Nuclide Activity (pCi) Co-60 13.2 Cs-137 8.5 These concentrations and activities are consistent with expected values based on prior analyses of sewage sludge. The radionuclides concentration in the sewage sludge has remained relatively constant during sampling conducted since December 30, 1983. A detailed summary of the results of this sampling program are contained in Appendix A for your review.
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i In addition to monitoring for the radionuclides content of the sludge, the WDNR requires several other physical and chemical properties of the sludge to be determined. These properties are the percent total solids, percent total. nitrogen, percent ammonium nitrogen, pH, percent total phosphorus, percent total potassium, cadmium, copper, lead, nickel, mercury, zinc, and boron. An example of a typical sludge sample analysis is included in Appendix B. ] 3.0 Disposal Method In the context of this application, Wisconsin Electric commits to the j following methodology. No distinction is made or intended between "shall" ' or "will", as used in the descriptions contained in this section. 3.1 Transport of Sludge The method used to dispose of the sludge shall utilize a technique approved ! by the WDNR. The process of transporting the sewage sludge for disposal ! involves pumping the sludge from the PBNP sewage treatment plant storage l tanks into a truck mounted tank. The truck mounted tank shall be required i to be maintained tightly closed to prevent spillage while in transit to ! the disposal site. The sludge shall be transported to one or more of the j six sites approved by the WDNR for land application of the sewage sludge I from PBNP.
- 3. 2 Disposal Procedure The radionuclides concentrations in the sludge shall be determined prior i to each disposal by obtaining three representative samples from each of the sludge storage tanks. The sludge contained in the sludge tanks is prevented from going septic by a process known as complete mix and continuous aeration. This process completely mixes the sludge allowing for representative samples to be obtained.
The samples shall be counted utilizing a GeLi detector and multi- ) channel analyzer with appropriate geometry. The detection system is 1 routinely calibrated and checked to ensure the lower limits of l detection are within values specified in the Radiological Effluent I Technical Specifications (RETS). i I To insure the samples are representative of the overall concentration ! l in the storage tanks, the radionuclides concentration determination for i each of the three samples shall be analyzed to insure each sample is i l within two standard deviations of the average value of the three i samples. If this criteria is not met, additional samples will be l obtained and analyzed to insure a truly representative radionuclides i concentration is utilized for dose calculations and concentration l limit determinations. The average of all statistically valid i concentration determinations will be utilized in determining'the i storage tank concentration values. ; 1
4 Prior to disposal the waste stream will be monitored to determine the physical and chemical properties of the sludge, as discussed in the last paragraph of Section 2.0, Waste Description. The results will be compared to State of Wisconsin limits to insure the sludge does not pose a chemical hazard to people or to the environment. The radionuclides identified in the sludge, along with their respective concentrations, will be compared to concentration limits prior to disposal. The methodology discussed in Appendix F will be used in determining compliance with the proposed concentration limit. The total activity of the proposed disposal will be compared to the proposed activity limit as described in Appendix F. If the concentration and activity limit criteria are met, the appropriate exposure pathways (as described in Appendix D) will be evaluated prior to each application of sludge. These exposures will be evaluated to insure the dose to the maximally exposed individual will be maintained less than 1 mrem / year and the dose to the inadvertent intruder is maintained less than 5 mrem / year. The exposures will be calculated utilizing the meth-odology used in Appendix E, including the current activity to be landspread along with the activity from all prior disposal. The remaining radio-activity from prior disposals will be corrected for radiological decay prior to performing dose calculations for the meat, milk, and vegetable ingestion pathways, the inhalation of resuspended radionuclides, and all pathways associated with a release to Lake Michigan. The residual radio-activity will be corrected for radiological decay and, if appropriate, the mixing of the radionuclides in the soil by plowing prior to performing external exposure calculations. The sewage sludge is applied on the designated area of land utilizing the WDNR approved technique and adhering to the following requirements of j WPDES Permit Number WI-0000957-3. Discharge to the land disposal system shall be limited so that during surface spreading all of the sludge and any precipitation falling onto or flowing onto the disposal field shall not overflow the peri-meter of the system. Sludge shall not be land spread on land with a slope greater than 12L During the period from December 15 through March 31 sludge shall not be land spread on land with a slope greater than 6% unless the wastes are injected immediately into the soil. Sludge shall not be surface spread closer than 500 feet from the nearest inhabited dwelling except that this distance may be reduced with the dwelling owner's written consent. l Sludge shall not be spread closer than 1,000 feet from a public water supply well or 250 feet from a private water supply well. Sludge shall not be land spread within 200 feet of any surface water unless a vegetative buffer strip is maintained between the surface watercourse and the land spreading system, in which case a minimum separation distance of at least 100 feet is required between the system and the surface watercourse.
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- Depth to groundwater and bedrock'shall be greater than 3 feet from-the land surface elevation during use of any site.
Sludge shall not be land spread in a floodway. Sludge shall not be land spread within 50 feet of a property line road or ditch unless the sludge is incorporated with the soil, in which case a minimum separation distance'of at least 25 feet is required. The pH of the sludge-soil mixture shall be maintained at 6.5 or higher. Low areas of the approved fields, subject to seasonally high ground-water levels, are excluded from the sludge application. l
- Crops for human consumption shall not be gro'wn on the land for up to one year following the application of the sludge.
The sludge shall be plowed, disked, injected or otherwise incorporated into the surface soil layer at appropriate intervals. The flexibility implied in the latter provision for soil incorporation is intended to allow for crops which require more than a one year cycle. For the Point Beach disposal sites, alfalfa is a common crop which is harvested for several years after a single planting. Sludge disposal on an alfalfa plot constitutes good fertilization, but the plot cannot be' plowed withcut destroying the crop. The alfalfa in this case aids in binding the layer of sludge on the surface of the plot. At a minimum, however, plowing (or disking or other method of injection and mixing to a nominal depth of 6 inches) shall be done prior to planting any new crop, regardless of the crop. i 3.3 Administrative Procedures Complete records of each disposal will be maintained. These records l will include the concentration of radionuclides in the sludge, the j total volume of sludge disposed, the total activity, the plot on j which the sludge was applied, the results of the chemical composition determinations, and all dose calculations. The annual disposal rate for each of the approved land spread sites i will be limited to 4,000 gallons / acre, provided WDNR chemical composi-tion, NRC dose guidelines, and concentration and activity limits are j maintained within the appropriate values. l The farmer leasing the site used for the disposal will be notifi.ed ' of the applicable restrictions placed on the site due to the land y spreading of sewage sludge. ; 4.0 Evaluation of Environmental Impact 4.1 Site Characteristics 4.1.1 Site Topography The disposal sites are located in the Town of Two Creeks in the northeast corner of Manitowoc County, Wisconsin, on the
l o west shore of Lake Michigan about 30 miles southeast of the l center of the city of Green Bay, and 90 miles NNE of Milwaukee. This site is located at longitude 87 32.5'W and latitude 44 17.0'N. The six sites are on property owned and controlled by Wisconsin Electric and are within or directly adjacent to the Point Beach site boundary. The sites are described below and are outlined on the map contained in Appendix C as Figure 3. Site No. PB The approximately 15 acres located in the NE { 1/4 of the NE 1/4 of Section 23, T. 21N - R. 24E. I Site No. PB The approximately 20 acres located in the SE 1/4 of the SE 1/4 of Section 14, T. 21N - R. 24E. i Site No. PB The approximately 5 acres located in the NW l 1/4 of Section 24, T. 21N - R. 24E. l l Site No. PB The approximately 5 acres located in the NW l 1/4 of the SW 1/4 of Section 24, T. 21N - R. 24E. Site No. PB The approximately 5 acres located in the NE ; 1/4 of the NW 1/4 of Section 25, T. 21N - R. 24E. Site No. PB The approximately 5 acres located in the NE 1/4 of the SW 1/4 of Section 14, T. 21N - R. 24E. The overall ground surface at the site of the Point Beach Nuclear Plant is gently rolling to flat with elevations varying from 5 to 60 feet above the level of Lake Michigan. Subdued knob and kettle topography is visible from aerial photographs. The land surface slopes gradually toward the lake from the higher glacial moraine areas west of the site. Higher ground adjacent , to the lake, however, diverts the drainage to the north and I south. l The major surface drainage features are two small creeks which I drain to the north and south. One creek discharges into the , lake about 1500 feet above the northern corner of the site and the other near the center of the site. During the spring, ponds of water may occupy the shallow depressions. As mentioned in Section 3.2, Disposal Procedure, these low areas are excluded from the sludge application. A site topographic map covering details out to a 5 mile radius may be found in the FSAR at Figure 2.2-3 and is included in Appendix C as Figure 2. The disposal of sewage sludge at these six sites will have no impact on the topography of this area. 4.1.2 Site Geology Prior to construction of the Point Beach Nuclear Plant, an evaluation of the geological characteristics of the area in and surrounding the site was made. The geologic structure of the region is essentially simple. Gently dipping sedimentary rock
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- strata of Paleozoic age outcrop in a horseshoe pattern around a shield of Precambrian crystalline rock which occupies the western part of the region. -The site is-located on the western flank of the Michigan Basin, which is a broad downwarp ringed j by discontinuous outcrops of more resistant formations. The bedrock _ formations are principally limestones, dolomites, and sandstones with subordinate shale layers. The rocks form a succession of extensive layers that are relatively uniform in thickness. The bedrock strata' dip very gently towards Lake ;-
Michigan at rates from 15 to 35 feet per mile. The uppermost bedrock under the site is Niagara Dolomite. j Bedrock does not outcrop on the site but is covered by glacial till and lake deposits. The soils:contain expansive clay minerals and have moderately high base exchange capacity. In the area of the site, the overburden _ soils are'approximately 70 to 100 feet in thickness. Although:the character of the i glacial deposits may vary greatly within relatively short distances, a generalized section through the overburden soils adjacent to Lake Michigan at the site consists of the following i sequence: i
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- 1. An upper layer of brown clay silt topsoil underlain with several feet of brown silty clay with layers of silty' sand;
- 2. A layer of 20 feet of reddish-brown silty clay with some. )
sand and gravel and occasional lenses of silt;
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- 3. A layer of 25 feet of reddish-brown silty clay with layers of silty sand and lenses of silt;
- 4. A layer of 50 feet of reddish-brown silty clay with some sand and gravel, the lower portion of which contains gravels, cobbles, and boulders resting on a glacial eroded surface of Niagara dolomite bedrock.
Site drainage is poor due to the high clay content of the soil combined with the pock-marked surface. Additional information on site geology may be found in Section 2.8 of the FSAR. The use of these sites for disposal of sewage sludge will not impact the geology of the area. 4.2 Area Characteristics 4.2.1 Meteorology ' The climate of the site region is influenced by the general storms which move eastward along the northern tier of the United States and by those which move northeastward from:the south-western part of the country to the Great Lakes. This conti-nental type of climate is modified by Lake Michigan. During spring, summer, and fall months the lake temperature differs. markedly from the air temperature. Wind shifts from westerly to easterly directions produce marked cooling of day-time i temperatures in spring and summer. In autumn the relatively warm water to the lake prevents night-time temperatures from falling as low as they do a few miles inland from the shoreline. Summer time temperatures exceed 90 F for six days on the average. Freezing temperatures occur 147 days and below'zero on 14 days of the winter on the average. Rainfall averages about 28 inches per year with 55 percent falling in the months of May through September. Snowfall averages about 45 inches per year. Sludge spreading shall be managed such that the surface spreading together with any precipitation falling on the field shall not overflow the perimeter of the field. Additional information on site meteorology may be found in Section 2.6 of the FSAR. There will be no impact on the meteorology of the area due to the disposal of the sewage sludge. 4.2.2 Hydrology The dominant hydrological feature of this site is Lake Michigan, one of the largest of the Great Lakes. The normal water level in Lake Michigan is approximately 580 feet above mean sea level. In the general vicinity of the site, the 30 foot depth contour ; is between 1 and 1-1/2 miles offshore and the 60 foot contour is 3 to 3-1/2 miles off shore. The disposal sites are twenty or more feet above the normal lake level. There is no record' that the sites have been flooded by the lake during modern times. There are no rivers or large streams which could create a flood hazard at or near the sites. The subsurface water table at the Point Beach site has a definite slope eastward toward the lake. The gradient indi-cated by test drilling on the site is approximately 30 feet per mile. It is therefore extremely unlikely that any release of radioactivity on the site could spread inland. Furthermore, the rate of subsurface flow is small due to the relative impervious nature of the soil and will not promote the spread of releases. Further information on site hydrology is detailed in the PBNP FSAR Section 2.5. There will be no adverse impact on hydrology of the area due to disposal of sewage sludge by land spreading. 4.3 Water Usage 4.3.1 Surface Water Lake Michigan is used as the source of potable water supplies in the vicinity of the site for the cities of Two Rivers (12 miles south), Manitowoc (16 miles sourth), Sheboygan~(40 miles south), and Green Bay (intake at Rostok 1 mile north of Kewaunee, 13 miles north). No other potable water uses are recorded within 50 miles of the site along the lake shore. All public water supplies drawn from Lake Michigan are treated in puri-fication plants. The nearest surface water used for drinking other than Lake Michigan are the Fox River 30 miles NW and I
4 Lake Winnebago 40 miles W of the site. Lake Michigan is also utilized by various recreational activities, including fishing, swimming and boating. There will be no impact on surface water usage due to the disposal of sewage sludge. 4.3.2 Ground Water Ground water provides the remaining population with potable supplies. Public ground water supplies within a 20 mile radius of the site are listed in Table 2.5-3 of the FSAR. Additional wells for private use are in existence throughout the region. The location of private wells within a two mile radius of PBNP are indicated on Figure 3, Appendix C. The potable water for use at the Point Beach Nuclear Plant is drawn from a 257 feet deep well located at the southwest corner of the plant yard. Water from this well is routinely sampled as part of the environmental monitoring program. I l There will be no adverse impact on ground water usage due to the disposal of sewage sludge. 4.4 Land Usage l Manitowoc County, in which the site is located, and the adjacent I counties of Kewaunee, Brown, Calumet, and Sheboygan are predominantly rural. Agricultural pursuits account for approximately 90% of the total county acreage. With the exception of the Kewaunee Nuclear Plant located 4.5 miles north, the region within a radius of five miles of the site is presently devoted exclusively to agriculture. Dairy products and livestock account for 85% of the counties' farm i production, with field crops and vegetables accounting for most of I the remainder. The principal crops are grain corn, silage corn, oats, barley, hay, potatoes, green peas, lima beans, snap beans, beets, cabbage, sweet corn, cucumbers, and cranberries. Within the township of Two Creeks surrounding the site (15 sq. miles), there are about 800 producing cows on about 40 dairy farms. Some beef cattle are raised 2.5 miles north of the site. Cows are on pasture from the first of June to late September or early. October. During the winter, cows are fed on locally produced hay and silage. Of the milk produced in this area, about 25 percent is consumed as fluid milk and 50 percent is converted to cheese, with the remainder being l used in butter making and other by products. It has been the policy of Wisconsin Electric to permit the controlled use of crop land and pasture land on company owned property. No direct grazing of dairy or beef cattle or other animals is permitted on these company owned properties. Crops intended for human consump-tion shall-not be grown on the disposal sites for at least one year l following the application of the sludge. The proposed land application of sewage sludge will not have any direct effect on the adjacent facilities. Additional land use
information may be found in Section 2.4 of the FSAR. 4.5 Radiological Impact The rate of sewage sludge application on each of the six proposed sites will be monitored to insure doses are maintained within applic-able limits. These limits are based on NRC Nuclear Reactor Regulation (NRR) staff proposed guidance (described in AIF/NESP-037, August, 1986). These limits require doses to the maximally exposed member of the general public to be maintained less than 1 mrem / year due to : the disposal material. In addition, NRR guidance requires doses of. l less than 5 mrem / year to an inadvertent intruder. 1 To assess the doses received by the maximally exposed individual and I the inadvertent intruder, six credible pathways have been identified for the maximally exposed individual-and four credible pathways for the inadvertent intruder. The identified credible pathways are i l described in Appendix 0. 1 Calculations detailed in Appendix E demonstrate the disposal of the currently stored PBNP sewage sludge would remain below these limits. l The total annual exposure to the maximally exposed individual based ! on the identified exposure pathways is equal to 0.072 mrem. The dose to a hypothetical intruder assuming an overly conservative occupancy factor of 100% is calculated to be 0.115 mrem / year. By definition, the inadvertent intruder would not be exposed to the processed food pathways (meat and milk). The calculational methodology used in determining doses for the proposed disposal of sludge stored at PBNP shall be utilized prior to each additional land application to insure doses are maintained less than those proposed by NRR. This calculation will include radio-nuclides disposed of in previous sludge applications. The activity from these prior disposals will be corrected for radiological decay prior to performing dose calculations for the meat, milk, and vegetable ingestion pathways, the inhalation of resuspended radio-nuclides, and all pathways associated with a potential release to Lake Michigan. The residual radioactivity will be corrected for radio-logical decay and, if applicable, the mixing of radionuclides in the soil prior to performing external exposure calculations. In addition, the dose to a farmer potentially leasing more than one application site will be addressed by summing the doses received from the external exposure from a ground plane source and resuspension inhalation pathways for each leased site. In addition, the maximum site specific dose due to the other pathways identified in Appendix 0, will be utilized in the total exposure estimation. 1 5.0 Radiation Protection The disposal operation will follow the applicable PBNP procedures to maintain doses as low as reasonably achievable. Technical review and guidance will be provided by the PBNP Superintendent - Health Physics.
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U information may be found in Section 2.4 of the FSAR.' 4.5 Radiological Impact The rate of sewage sludge application on each of the six proposed sites will be monitored to insure doses are maintained within applic-able limits. These limits are based on NRC Nuclear Reactor Regulation (NRR) staff proposed guidance (described in AIF/NESP-037, August, 1986). These limits require doses to the. maximally exposed member of the general public to be maintained less than 1 mrem / year.due to the disposal material. In addition NRR guidance requires doses of-less than 5 mrem / year to an inadvertent intruder. To assess the doses received by the maximally exposed individual and the inadvertent intruder, six _ credible pathways have been identified for the maximally exposed individual and four credible pathways for 1 the inadvertent intruder. The identified credible pathways are j j- described in Appendix D. l Calculations detailed in Appendix E demonstrate the disposal of the f currently stored PBNP sewage sludge would remain below these limits. l The total annual exposure to-the maximally exposed individual based ) on the identified exposure pathways is equal to 0.072 mrem. The i dose to a hypothetical intruder assuming an overly conservative ' occupancy factor of 100% is calculated to be.0.115 mrem / year. By definition, the inadvertent intruder would not be exposed to the l processed food pathways (meat and milk). The calculational methodology used in determining doses for the proposed disposal of sludge stored at PBNP shall be utilized prior to . each additional land application to insure doses are maintained less J than those proposed by NRR. This calculation will include radio-nuclides disposed of in previous sludge applications. The activity from these prior disposals will be corrected for radiological decay ! prior to performing dose calculations.for the meat, milk, and l vegetable ingestion pathways, the inhalation of resuspended radio- i nuclides, and all pathways associated with a potential release to Lake -l Michigan. The residual radioactivity will be corrected for radio-logical decay and, if applicable, the mixing of radionuclides in the soil prior to performing external exposure calculations. In addition, the dose to a farmer potentially leasing more than one application J site will be addressed by summing the doses received from.the external ] exposure from a ground plane source and resuspension inhalation pathways for each leased site. In addition, the maximum site specific dose due to the other pathways identified in Appendix D, will be utilized in the total exposure estimation. 5.0 Radiation Protection The disposal operation will follow the applicable PBNP procedures to maintain doses as low as reasonably achievable. Technical review and , guidance will be provided by the PBNP Superintendent - Health Physics. l 1 l
4 APPENDIX A
SUMMARY
OF RADIOLOGICAL ANALYSES OF SEWAGE SLUDGE SINCE DECEMBER 30, 1983
4 Tank Tank Radionuclides Concentration Sample (pCi/cc) Date Volume (Gallons) 8400 Co-58 5.58E-07 12-30-83 Digester 1.87E-06 Co-60 Cr-51 4. 88E- 07 Cs-134 1.59E-07 Cs-137 3.57E-07 7560 Co-60 7.89E-07 4-06-84 Digester 6667 Co-60 1.87E-07 Aeration Digester 7560 Co-58 1.75E-07 12-05-84 8.29E-07 Aeration 6667 Co-60 Digester 7560 Co-60 8.29E-07 6-03-85 2.46E-07 Cs-137 Aeration 6700 Co-60 3.27E-07 ; Cs-137 1.33E-07 I Digester 7560 Co-60 6.79E-07 4-10-86 Cs-137 1.72E-07 Mn-54 4.91E-08 Co-60 1.65E-07 11-04-86 Digester 7560 Co-58 8.04E-08 Aeration & Clarifier 25100 Co-58 1.37E-07 Co-60 2.18E-07 Cs-137 1.64E-07
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1 l l i l APPENDIX B
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l i i i CHEMICAL COMPOSITION ANALYSIS 0F SEWAGE SLIJDGE l l
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.D STATE OF WISCONSIN SLUDGE CHARACTERISTIC
,- DEPARTMENT OF N ATURAL RESOURCES Wisconsin Administrative Code NR 110.27(6)
FORM 340049 REV. s 040 Scwage Treatment Plant Sludge Please complete this form and send to the Department of Natural Resources appropriate District / Area Office. Keep one copy for Your records. Fcr additional forms, please contact your appropriate District / Area Office. WPOES PERMIT NUMBER e E nMITT EE WI 00 L IL L .5._ .J Wisconsin Electric Power Company COUNTY
$TREET OR ROUTE 231 N. Michigan Street Milwaukee CIT Y, ST ATE, Ilp CODE nT*LEPHONE NUMBER (INCLUDE AREA CODE)
"ilwau!:se . 'G 53203 l :13-277-2153
- 1. Please report laboratory testing results for the following paramettrs:
Result
- Parameter Abbreviation Result
- Parameter Abbreviation 1 Cr Total Solids, % -
Chromium, p, 10 Cu 00 Total Nitrogen, % TOT N Copper, ppm O 34 Pb 190 Ammonium Nitrogen,% NHj-N Lead, ppm 4 0.01 Hg 30 Total Phosphorous, % P Mercury, ppm 0.25 g;Ck*l' Ni 12 Total Potassium, % K m 1.O Zn 2M0 Arsenic, ppm As Zinc, ppm 12* I*0 Cd pH - Cadmium, ppm i
' Suggested analysis proadures for the above parameters can be found in NR 219, analytical tests and procedures, Wisconsin Administrative Code. All parameters other than percent solids and pH shallbe reported on a dry weight basis.
- 2. What is the name of the laboratory that did the analysis and when was it performed?
Acril 12, 1933 Laboratory Name Wisconsin Eleetric Power Co. Date sent to tab Laboratory Services Division Where at the treatment plant was the sample taken? c re . sludge heldir.g tank prior to h::uling 3. 4 . When was the sample taken? AUY11 12+ 1983 j i i TIT LE DATE SIGNATURE . .- ~~ 7', ,. j e-
- r. j /. , ' f.[#' Water Quality Engineer ;
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e 1 I I i i Ii 1 APPENDIX D 1 i EXPOSURE PATHWAYS i l l
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li I i I l l l l l I a
.i l
1 i
I. EXPOSURE PATHWAYS - MAXIMALLY EXPOSED INDIVIDUAL ) i
- 1. External whole body exposure due to a ground plane source of ,
radionuclides. i
- 2. Milk ingestion pathway from cows fed alfalfa grown on plot.
- 3. Meat ingestion pathway from cows fed alfalfa grown on plot.
- 4. Vegetable ingestion pathway from vegetables grown on plot.
- 5. Inhalation of radioactivity resuspended in air above application !
site.
- 6. Pathways associated with a release to Lake Michigan. Ingestion of potable water at Two Rivers, Wisconsin municipal water supply, ingestion of fish from edge of initial mixing zone of radionuclides release, ingestion of iresh and stored vegetables irrigated with l
water source as Lake Michigan, ingestion of milk and meat from j cows utilizing Lake Michigan as drinking water.f;ource, swimming ' and boating activities at edge of initial mixing zone, and shoreline i deposits. l
- 7 1 II. EXPOSURE PATHWAYS - INADVERTENT INTRUDER I 4,*'
- 1. External whole body exposure ~due to a ground plane sourcf of
~
radionuclides. /
- 2. Vegetable ingestion pathway from vegetables grown on plot.
i
- 3. Inhalation of radioactivity resuspeaded in air above application - j site.
- 4. Pathways associated with a release to Lake Michigan. Ingestion of potable water at Two Rivers, Wisconsin municipal water supply, ingestion of fish from edge of initial mixing zone of radionuclides
! release, ingestion of fresh and stored vegetables irrigated with I water source as Lake Michigan, ingestion of milk and meat from cows utilizing Lake Michigan as drinking water source, swimming and boating activities at edge of initial mixing zone, and shoreline deposits. The milk and meat pathways are not included in calculating the dose to the inadvertent intruder. The doses due to these pathways are calculated based on feeding the cows alfalfa grown on the sludge applied land. Since direct grazing on these lands is prohibited, the alfalfa must be cropped prior to being used as feed. This effectively removes the availability of these pathways to the inadvertent intruder, who by definition occupies the sludge applied land continuously. U_____.________
III. GROUND WATER PATHWAY The ingestion of groundwater is not a credible exposure pathway. The two factors contributing to this determination are as follows:
- 1. The site' map in Appendix C, Figure 3 details the spatial- relation-ship between the proposed disposal sites and the local ground water wells. The flow gradient of ground water was determined for the PBNP FSAR to be towards Lake Michigan. Reviewing the sites and local wells shows no private well located in the path of radionuclides migration towards Lake Michigan.
The PBNP site well is: located on the plant. site, potentially in a-path of radionuclides migration. The PBNP well is routinely sampled
-as a requirement of the PBNP environmental monitoring program.
- 2. The cation exchange capacity'(CEC) of the soils at each site has been determined.
l Site Cation Exchange Capacity (MEQ/100g) l 1 16 2 11 3 11 4 10 5 8 6 9-The cation exchange capacity of soil is dependent on the valance of the radionuclides and is determined by the relation: MEQ = ATOMIC VALANCE WEIGHT
- 1.0E-03 Radionuclides Valance CEC (MEQ/100g)
Co-60 +2 3.00E-02 Co-58 +2 2.90E-02 Cs-137 +1 1.37E-01 Mn-54 +2 2.70E-02 l Cr-51 +3 1.70E-02 Cs-134 +1 1.34E-01 Using the values for Cs-137 and site 5 which has the lowest CEC, the total exchange capacity of the soil is 1.10 grams of Cs-137 100 grams of soil , Calculating the specific activity of Cs-137, 3.578E+05 .= 3.578E+05 Specific Activity = T1/2(yrs.) . ATOMIC MASS 30 137
= 87.1 Ci/ gram
x
.f ' (
The estion t< change capacity of tIhe soil expressed in the number.. of Curies, of radionuclides per 100 grams of soll is J~ T . .*. 95.8 Li Cs-1 W $ 100 grims of.soTI ., if -
"i Sidhetheproposeddisposalofsewage'sludgecoatainsquantities~
; of radionuclides on the order of'10-100 pCi the'soll at.each site.
f 4 '( has the capacity radionuclides to' effectively to ground water.- eliminate the migration of the
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6 'i h l I J APPENDIX E l EXPOSURE ANALYSIS i I
)
l l l u 1 1 4 d i 4
-1 GENERAL ASSUMPTIONS 1.. Sewage sludge is uniformly applied over plot acreage.
- 2. Sewage sludge is applied to one of the 5 acre plots, site PB-03, i
PB-04, PB-05, or PB-06. (Assuming the smallest site size is. conservative for the calculation methodology herein.)'
- 3. Based on the sewage sludge currently stored at PBNP, the following data is used in'the calculations.
Ground Plane Sludge Volume Activity " Concentration Concentration Radionuclides (Gallons) (cm3) (pC1) (pCi/cm3) (pCi/cm2) 00-60 15,000 5.68E+07 13.2' 2.33E-07 6.53E-08 Cs-137 15,000 5.68E+07 8.5 1.50E-07 4.21E-08 I. CALCULATION OF EXTERNAL EXPOSURES A. Specific Assumptions
- 1. Conservatively assume radioactivity remains on surface of land plot.
Calculation ignores any plowing or mixing of radioactivity within. soil. Calculations for the proposed disposal will therefore ignore self absorption or shielding from soil. The external exposure at the application site due to prior disposals will be calculated utilizing the methodology in Appendix G and added to that calculated for the proposed disposal.
- 2. The plots are owned by Wisconsin Electric and have been approved by the Wisconsin Department of Natural Resources (DNR) as disposal
, sites. The land is leased and potentially farmed. Occupancy of the land can be realistically expected only during plowing, planting and harvesting. Occupancy has been estimated to be 64 hours per year. B. Summary of Calculational Methodology
- 1. Calculate ground plane radionuclides concentrations in pCi/cm2, j
- 2. The dose from a plane of uniformly deposited radionuclides is
)
calculated using Regulatory Guide 1.109, Revision l', Appendix C, 1 Formula C-2. l
- 3. Dose rates were calculated assuming continuous occupancy then adjusted for realistic occupancy factors. ;
I
'l b
_ _ _ - - - 1
C. External Exposure Rate Calculations The dose from a plane of uniformly deposited radionuclides is calculated using Regulatory Guide 1.109, Revision 1, Appendix C, formula C-2
'D (r,0) = 8760 Sp{Cf(r,0)DFG $3 where D (r,0) = yearly dose 8760 = hours per year S
p
= 1.0, since no dose reduction due to residential shielding is applicable.
Cf(r,0)=groundplaneradionuclideconcentration(pCi/m2) DFG(i,j) = external dose factor for standing on contaminated ground as given in Table E-6 of Regulatory Guide 1.109, Revision 1. Ground Plane Ground Plane y Dose y Dose Factor Concentration Concentration Rate Radionwlide (mrem /hr per pCi/m2) (pCi/cm2) (pCi/m2). (mrem /yr) Co-60 1.70E-08 6.53E-08 6.53E+02 9.72E-02 Cs-137 4.20E-09 4.21E-08 4.21E+02 1.55E-02 TOTAL: 1.13E-01 mrem / year These calculated dose rates assume continuous occupancy. In reality, these sites will be occupied only during plowing, planting, and harvesting. Assuming an occupancy of 2 hours per day, 1 day per week, and 32 weeks (8 month growing season) per year, the occupancy factor becomes _ i 2 hr/ day
- I day / week *. 32 weeks /yr
- 1/8760 hours /yr = 7.3E-03. q i
EXTERNAL EXPOSURE DOSE RATE (mrem / year) d Radionuclides Continuous Occupancy Realistic Occupancy Co-60 9.72E-02 7.10E-04 Cs-137 1.55E-02 1.13E-04 TOTAL: 1.13E-01 8.23E-04
-1 i
1 1
4 II, CALCULATION OF MEAT AND MILK INGESTION PATHWAY EXPOSURES A. Specific Assumptions
- 1. All feed consumed by cow is grown on sludge applied acreage.
- 2. All meat and milk consumed by human is from cattle exclusively fed feed from sludge applied land.
- 3. Stable element transfer coefficients (B are utilized from-Regulatory Guide 1.109 to estimate the Na)ction of radioactivity which is transferred from the soil to the feed.
O Radionuclides iv Co-60 9.4E-03 Cs-137 1.0E-02
- 4. Alfalfa has typically been grown on the plots. Soil tests have indi-cated a minimum alfalfa yield of 4.1 tons per acre can be expected.
B. Summary of Calculational Methodology 4
- 1. The ccocentration of radionuclides in feed grown on the disposal plots is estimated. Transfer coefficients (B from Table E-1 of RegulatoryGuide1.109wereusedtoestimatetk)fractionofradio-nuclide which may be expected to transfer to the feed from the soil.
- 2. Concentrations of radionuclides in milk and meat were estimated using Formula A-11 from Regulatory Guide 1.109.
- 3. Ingestion dose rates were estimated using Formula A-12 from Regulatory Guide 1.109.
C. Milk and Meat Ingestion Pathway Dose Rate Calculation Concentration in feed. ' I 1. Activity in Feed = B $y
- Activity in Soil ;
l Concentration in Feed = Activity in Feed /(kg o Feed
- 5 Acres) l Radionuclides Activity in Activity in Concentration in
' Radionuclides Soil (pCi) Feed (pCi) Feed (pCi/kg)
Co-60 13.2 1.24E-01 6.67E+00 l Cs-137 8.5 8.50E-02 4.57E+00
- 2. Concentration in Milk and Meat Calculate concentrations of radionuclides in milk and meat using
4 i 4 Formula A-11 in Regulatory Guide 1.109, Revision 1 which is cia = FiA *Cgp Qp where cia = radionuclides concentration of i in component A F stable element transfer coefficient'whose values are'in. iA = Table E-1 of the Regulatory Guide , C '= radionuclides concentration in feed
= consumption rate of feed = 50 kg/d-(wet weight) from
-Q Regulatory Guide 1.109 l Use the following Regulatory Guide 1.109 values for F iA Element fiA"m (d/1) for milk FiA*ff (d/kg) for meat Co 1.0E-03 1.3E-02 Cs 1.2E-02 4.0E-03 Concentration in Concentration in Radionuclides Milk (pCi/1) Meat (pCi/kg)
Co-60 3.34E-01 4.34E+00 Cs-137 2.74E+00 9.14E-01
- 3. Calculated Dose rates The formula for. total dose from eating animal products fed vegeta-tion (alfalfa) grown on PBNP sludge applied land'is given by Regulatory Guide 1.109, Revision 1, Formula A-12, page 1.109-16.
But, as noted following equation A-13, it is'necessary to compute separately the milk and meat portions of the dose. DOSE = I(U,p*D $ ,pg*exp(-A g3t )) where U = C $ == consumption conc of radionuclides.irate.of in animalanimal product A.. product' D "P9 =average dose factor time between milking or. slaughtering and tf consumption U,p by. Age Group I Infant Child Teenager Adult Milk (1/yr) 330 330 400 310 Meat (kg/yr) - 41 65 110 C iA = concentration calculated above iap9 = DF whole body dose factors, Regulatory Guide 1.109, D Revision 1. l l
j
.i; Whole Body Oose Factors (mrem /pCi' Ingested)
Infant Child Teenager Adult Nuclide Ingestion Ingestion Ingestion Ingestion q Co 2.55E-05 -1.56E-05 6.33E-06 4.72E-06 Cs-137 4.33E-05 4.62E-05~ 5.19E-05 -7.14E-05 i T = s = 020fordays milkfor (assume consumptionGuide meat (Regulatory on farm) 1.109, Revision 1 Table E-15)- ! l MILK INGESTION 00SE RATE (mrem / year) Radionuclides Infant Child Teenager Adult Co-60 2.81E-03 1.72E-03 8.46E-04 4.89E-04 Cs-137 3.92E-02 4.18E-02 5.69E-02 6.06E-02 TOTALS: 4.20E-02 4.35E-02 '5.77E-02 ~6.11E-02 MEAT INGESTION DOSE RATE (mrem / year) Radionuclides Infant Child Teenager Adult Co-60 - 2.76E-03 1.77E-03 2.24E-03 Cs-137 - 1.73E-03 3.08E-03 7.18E-03 TOTALS: - 4.49E-03 4. 85E-03 9.42E-03 MEAT AND MILK INGESTION PATHWAY 00SE RATES (mrem / year) Infant - 4.20E-02 Child
- 4,80E-02 Teenager - 6.26E-02 Adult - 7.05E-02 III. CALCULATION OF VEGETABLE INGESTION PATHWAY EXPOSURES
'A. Specific Assumptions
- 1. The WPOES permit issued to PBNP for the disposal of sewage !
sludge prohibits the growing of crops for human consumption ' for one year following the application of the sewage sludge. Therefore, prior to planting vegetables on the application site, the soil would be plowed. Plowing is assumed to uni-formly mix the top 6 inches of soil. I l 1 1
- _ . . _ _ . . _ _ . ._ __-._______n________ _ _ _ _J
m 4
- 2. The soil density is assumed.to be 1.3 grams /cm3
- 3. All vegetables consumed by the, individual of interest are grown on the sludge applied. acreage.
- 4. Stable element transfer coefficients (B. ) from Regulatory Guide 1.109areusedtoestimatethefrlEtionofradio-activity transfered from the soil to the vegetables.
O Radionuclides iv Co-60 9.4E-03 Cs-137 1.0E-02
- 5. The consumption factors of food medium (Ua ) and the mass basis distributions from Regulatory Guide 1.109 pTable E-5 are used to determine annual consumption of vegetables.
U,p by Age Group
- Infant Child Teen Adult 280 kg/yr 340 kg/yr 280 kg/yr
- Based on 54% vegetable consumption by mass of fruit, vegetable, and grain.
- 6. The Ingestion Dose Factors by age group are from Regule< -
Guide 1.109, Tables E-11, E-12, E-13, and E-14. Whole Body Ingestion Dose Factors (mrem /pCi ingested) i Radionuclides Infant Child Teen Adult , 1 Co-60 2.55E-05 1.56E-05 6.33E-06 4.72E-06' j Cs-137 4.33E-05 4.62E-05 5.19E-05 7.14E-05 l l
- 7. Radiological decay of the radionuclides applied to the plot is i not taken into account in these calculations.
B. Summary of Calculational Methodology
- 1. The radionuclides concentration in the soil is calculated in units of pCi/kg based on uniform application over 5 acre plot, plowing ;
to a depth of 6 inches, and a soil density of 1.3 g/cm3
- 2. The B 4y values are applied to the soil concentration values to obtain the radionuclides concentration in the vegetables. i
- 3. The consumption factors (U for each age group are then used todeterminetheannualra8So)nuclideintakebyagegroupdue !
to eating these vegetables. I
e
- 4. Finally, the: age' dependent' ingestion dose factors are used to obtain annual doses by age group. i C. Vegetable Pathway Ingestion Dose-Rate Calculations
- 1. Concentration in soil Concentration Activity Soil Volume Soil Mass In Soil-Radionuclides Applied'(pCi)' (cm3 ) (kg) (pCi/kg)
Co-60 13.2 3.08E+09 4.00E+06' 3.30E+00' Cs-137 8.5 3.08E+09 4.00E+06 2.13E+00
- 2. Concentration in vegetables Concentration Concentration In In Vegetables B
Radionuclides Soil (pCi/kg) iv (pCi/kg) Co-60 3.30E+00 9.4E-03 3.10E-02 Cs-137 2.13E+00 1.0E-02 2.13E-02
- 3. Calculated Dose Rates The dose rate for direct ingestion of vegetables grown on the j sludge applied land is given by the equation.
DOSERATE=IU,pfD,p)*EXP(-At)*C4 $ $ where U a
= consumption rate _of food medium Dp A
apj ==radiological dose factordecay for radionuclides, constant i t = time between harvest and consumption C
= concentration of radionucli6e, i, in food '
medium. : t, the time between harvest and ingestion, is assumed t'o be zero ~ for this calculation. ! i I i VEGETABLE INGESTION DOSE RATE (mrem / year) Radionuclides Infant Child Teen Adult Co-60 - 1.35E-04 6.67E-05 4.10E-05 Cs-137 - 2.76E-04 3.76E-04 4.26E-04 1 TOTAL - 4.11E-04 4.43E-04 4.67E-04 l
d IV. CALCULATION OF INHALATION OF RESUSPENDED RADIONUCLIDES PATHWAY EXPOSURE A. Specific Assumptions
- 1. The model used to determine the radionuclides concentration in air above the sludge applied land is taken from WASH-1400, USNRC, Reactor Safety Study - An Assessment of Accident Risks in Commercial Nuclear Power Plants, Appendix VI.
- 2. The radionuclides concentration in air remains constant for year of interest, i.e., radiological decay and decrease in resuspension factor are not taken into account for this calculation.
- 3. The maximally exposed member of the general public is assumed to be the farmer using the plot of land with an occupancy of 64 hours per year.
- 4. The inadvertent intruder is assumed to occupy the plot of land for the entire year.
- 5. The Inhalation Dose Factors by age group are from Regulatory Guide 1.109, Tables E-7, E-8, E-9, and E-10.
WHOLE BODY INHALATION DOSE FACTORS (mrem /pCi inhaled) Radionuclides Infant Child Teen Adult Co-60 8.41E-06 6.12E-06 2.48E-06 1.85E-06 Cs-137 3.25E-05 3.47E-05 3.89E-05 5.35E-05 LUNG INHALATION 00SE FACTORS (mrem /pCi inhaled) Radionuclides Infant Child Teen Adult __ Co-60 3.22E-03 1.91E-03 1.09E-03 7.46E-04 Cs-137 5.09E-05 2.81E-05 1.51E-05 9.40E-06
- 6. The age dependent inhalation rates are obtained from Regulatory Guide 1.109, Table E-5.
Inhalation Rates (m3/yr) Infant Child Teen Adult 1400 3700 8000 8000 1 B. Summary of Calculational Methodology
- 1. The ground plane radionuclides concentrations in pCi/m2,
- 2. Calculate the resuspension factor utilizing equation given in WASH-1400. .
I
- 3. Obtain the radionuclides concentration in air (pCi/m3) above j plot utilizing methodology in WASH-1400. '{
i
- 4. Using parameters contained in Regulatory Guide 1.109, j calculate annual dose for continuous occupancy and for j realistic occupancy.
C. Inhalation of Resuspended Radionuclides in Air Pathway Dose Rate Calculations - Resuspension of Radionuclides in Air
- 1. Ground plane radionuclides concentration Ground Plane Ground Plane 3 Radionuclides Concentration (pCi/cm2) Concentration (pCi/m2)
Co-60 6.53E-08 6.53E+02 Cs-137 4.21E 08 4.21E+02 ; 1 i
- 2. Calculation of resuspension factor, K (m ) j l
From WASH-1400, ! K(t) = 1.0E-09 + 1.0E-05
- EXP [-0.6769
- t] l 1
where t = time since radionuclides were deposited on ground surface. ]
'I t is assumed to be 0 for these calculations, thereby maximizing I the resuspension factor.
Therefore, K = 1.0E-05 m'
- 3. Calculate radionuclides concentration (pCi/m3) in air.
J From WASH-1400, 1 l K(m ) _ air concentration (pCi/m2) surface deposit (pCi/m2) 1 or .1 j Air Concentration (pCi/m3) = surface deposit (pCi/m2)
- K(m )
AIR CONCENTRATIONS Radionuclides Air Concentrations (pCi/.m3) Co-60 6.53E-03 Cs-137 4.21E-03 j i
- 4. Dose Rate Calculations Dose Rate (mrem /yr) = Inhalation Rate (m3/yr)
- Air Conc. (pCi/m3 ) * !
Dose Conversion Factor (mrem /pCi) i 4 WHOLE BODY INHALATION DOSE RATE (mrem / year) Radionuclides Infant Child Teen Adult j Co-60 7.69E-05 1.48E-04 1.30E-04 9.66E-05 Cs-137 1.92E-04 5.41E-04 1.31E-03 1.80E-03 j i TOTAL 2.69E-04 6.89E-04 1.44E-03 '1.90E-03 f LUNG INHALATION DOSE RATE (mrem / year)
-l Radionuclides Infant Child Teen Adult Co-60 2.94E-02 4.61E-02 5.69E-02 3.90E-02 Cs-137 3.00E-04 4.38E-04 5.09E-04 3.17E-04 >
l TOTAL 2.97E-02 4.65E-02 5.74E-02 3.93E-02 l i l INHALATION OF RESUSPENDED RADIONUCLIDES IN AIR DOSE RATES ) l WHOLE BODY DOSE RATE (mrem / year) Occupancy Infant Child Teen , Adult '! Continuous 2.69E-04 6.89E-04 1.44E-03 1.90E-03 Realistic 1.96E-06 5.03E-06 1.05E-05 1.39E-05 1 LUNG DOSE RATE (mrem / year) ' l Occupancy Infant Child Teen Adult Continuous 2.97E-02 4.65E-02 5.74E-02 3.93E-02 Realistic 2.17E-04 3.39E-04 4.19E-04 2. 87E-04 ! 1 i V. CALCULATION OF WHOLE BODY EXPOSURES DUE TO RELEASE TO LAKE MICHIGAN A. Specific Assumptions
- 1. The methodology contained in the PBNP Offsite Dose Calculation Manual (0DCM) is used to perform this calculation. '
i
- 2. . The entire activity contained in.the sludge is released into Lake Michigan.
- 3. The exposure pathways addressed by:the ODCM methodology are ingestion of potable water from~Two Rivers, WI water' supply, ingestion of fish at odge of' initial mixing-zone, ingestion of fresh and stored vegetables, irrigated with Lake Michigan as source of water, ingestion of milk and meat from cows utilizing Lake Michigan.as drinking water source, swimming and boating activities at edge of initial mixing zone, and shoreline: deposits.
B. Summary of Calculational Methodology-
- 1. The activity released in the sludge is converted into Co-60 dose equivalent Curies.
- 2. The annual design release limit from the ODCM is 94.7 Co-60 equivalent curies.
- 3. The annual design release. limit is based on a limiting dose of 6 mrem adult whole body. The annual dose due to sewage. .
sludge is calculated by a ratio of calculated release compared to release limit. C. Whole Body Exposure Calculations
- 1. Co-60 equivalent Curies Activity Co-60 eq.
Radionuclides (pCi) 0Fi /DF Co-60 Activity (pC1) Co-60 13.2 1.00E+00 13.2. Cs-137 8.5 1.51E+01 128.4 TOTAL 141.6pC1.Co-60
- equivalent
- 2. Ratio of dose limit to annual design release limit 6 mrem 94.7 Co-60 equivalent curies
- 3. Whole Body Dose Calculation Dose- = 6 mrem 141.6pCi 94.7x106pCi Dose = 8.97E-06 mrem-WHOLE BODY DOSE RATE (mrem / year) 8.97E-06 I
-__.____.___.U_. I_ _m-
4' OOSE
SUMMARY
i Maximally' Exposed Individua_1 The identified credible exposure pathways for the maximally exposed individual are:
' 1. ) External exposure from ground plane source (realistic occupancy).
- 2. ) Milk ingestion pathway 3.) Meat ingestion pathway i 4.) . Vegetable ingestion pathway j 5.) Resuspension-inhalation pathway (realistic occupancy) i
-6.) ~ Pathways identified due to release to Lake Michigan, q
-AGE GROUP i hthway Infant Child Teen Adult External 8.23E-04 8.23E-04 8.23E-04 8.23E-04 ;
Milk 4.20E-02 4.35E-02 5.77E-02 6.11E-02 'l I Meat - 4.49E-03 4.85E-03 9.42E-03 Vegetable - 4.11E-04 4.43E-04 4.67E-04 Inhalation 1.96E-06 5.03E-06 1.05E-05 1.39E-05 Water 8.97E-06 8.97E-06 8.97E-06 8.97E-06 l TOTAL: 0.043 0.049 0.064 0.072 (mrem / year) ! { Inadvertent Intruder 4 i The identified credible exposure pathways for the inadvertent intruder are: - 1.) External exposure from ground plane source (continuous occupancy) .
- 2. ) Vegetable ingestion pathway 3.) Resuspension inhalation pathway (continuous occupancy) ,
4.) Pathways identified due to release to Lake Michigan. 1 AGE GROUP Pathway Infant Child Teen Adult ! External 1.13E-01 1.13E-01 1.13E-01 1.13E-01 Vegetable - 4.11E-04 4.43E-04 4.67E-04 Inhalation 2.96E-04 6.89E-04 1.44E-03 1.90E-03 Water 8.97E-06 8.97E-06 8.97E-06 8.97E-06 TOTAL: 0.113 0.114 0.115 0.115 (mrem / year) Reviewing these tables, the calculated limiting doses for both the maximally exposed individual and the inadvertent intruder occur for.the adult' age group. These doses are: ; Maximally Exposed Individual: 0.072 mrem / year j Inadvertent Intruder: 0.115 mrem / year ) 1 4
'9 e
APPENDIX F BASIS FOR SETTING CONCENTRATION LIMITS AND ACTIVITY LIMIT FOR DISPOSAL OF SLUDGE l l 1
l Analyses of previously disposed sewage sludge have identified six different radionuclides in the sludge. All six radionuclides did not occur in each disposal. Therefore, it is difficult to determine a single concentration limit for regulating the disposal of the sludge from the storage tanks. To provide a basis to regulate the disposal of the sewage sludge based on identified radionuclides concentrations, the following relation is proposed. N C.
$f0y .1 mpg I 1 where N = number of different radionuclides identified in the sewage sludge.
C
= concentration of the ith radionuclides in the sewage sludge.
MPC$ =sewage the MPC valueas sludge, of listed the ithinradionuclides 10 CFR Partin20the Appendix B, Table II, Column 2. If this criteria is met, the sewage sludge may be disposed of by land spread-ing provided the dose calculations (as identified in Appendix E) indicate dose rates within the prescribed limits. The attachment to this Appendix details calculations performed to determine doses from four radionuclides identified in the sludge. The calculations are based on an identified concentration equal to 10% of the 10 CFR Part 20, Appendix B, Table II, Column 2 valves. The calculations use the methodology in Appendix E along with the exposure pathways identified in Appendix D to determine the dose rates. These calculations indicate the use of this methodology will maintain radiation doses within the appropriate limits. j i The maximum allowable activity disposed of per year per acre is calculated i utilizing 10% of the MPC value, 10 CFR Part 20, Appendix B, Table II, Column 2, { for Co-58. Volume limit per acre has been proposed at 4,000 gallons / acre / year. l Then, j 1 1.0E-05 pCi/cc
- 4,000 gallons / acre / year x 3.785.43 cc/ gallon i
= 151.4 pCi/ acre / year t
l 1 I
l l
)
1 I l Cs-134 Concentration in Sludge: 9.0E-07 mci /ml Sludge Volume Concentration Activity Ground Plane (Gallons) (cm3) (pCi/cm3) (pCi) Concentration (pCi/cm2) 15000 5.68E+07 9.00E-07 5.11E+01 2.53E-07 . External Exposure y Dose Factor Ground Plane Concentration y Dose Rate j (mrem /hr. per pCi/m2) (pCi/m2) (mrem / year) ) 1.20E-08 2.53E+03 2.66E-01 l Continuous Occupancy: 2.66E-01 mrem / year Realistic Occupancy: 1.94E-03 mrem / year i Meat & Milk Pathway Activity in Activity in Concentration in Concentration in Concentration in Soil (pCi) Feed (pCi) Feed (pCi/Kg) Milk (pCi/2) Meat (pCi/kg) l 5.22E+01 5.11E-01 2.75E+01 1.65E+01 5.50E+00
- Milk Oose Rates (mrem / year) l l __ Infant Child Teenager Adult 1
3.87E-01 4.41E-01 6.03E-01 6.19E-01 i Meat Oose Rate (mrem / year) Infant Child Teenager Adult 1 1.83E-02 3.27E-02 7.32E-02 l l l l Vegetable Pathway Activity Soil Volume Soil Mass Concentration Concentration (pCi) (Cm3) (Kg) in Soil (pCi/Kg) in Vegetables (pCi/Kg) l 5.11E+01 3.08E+09 4.00E+06 1.28E+01 1.28E-01 Cs-134-1 ___________ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ - . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ . _ - - - - - _ _ _ --- J
Vegetable Pathway Dose Rates (mrem / year) Infant Child Teenager Adult 2.90E-03 3.98E-03 4.34E-03 Inhalation Pathway Ground Plane K Air Concentration Concentration (pCi/m2) (m'i ) (pCi/m3) 2.53E+03 1.0E-05 2.53E-02 Inhalation Pathway Oose Rates (mrem / year) Infant Child Teenager Adult Continuous Occupancy 1.88E-03 5.68E-03 1.39E-02 1.84E-02 Realistic Occupancy 1.38E-05 4.15E-05 1.01E-04 1.35E-04 j Release to Lake Michigan Activity 0F$j0FCo-60 Co-60 eq. activity ! (pCi) (pci) {q 5.11E+01 2.56E+01 1.31E+03 6 mrem ', 1.31E+03 x 1 Ci i 94.7 Ci 1.0E+06 pCi = 8.29E-05 mrem j l i Maximally Exposed Individual l l Infant Child Teenager Adult External 1.94E-03 1.94E-03 1.94E-03 1.94E-03 Milk 3.87E-01 4.41E-01 6.03E-01 6.19E-01 Meat - 1.83E-02 3.27E-02 7.32E-02 Vegetable - 2.90E-03 3.98E-03 4.34E-03 Inhalation 1.38E-05 4.15E-05 1.01E-04 1.35E-04 Water 8.29E-05 8.29E-05 8.29E-05 8.29E-05 Totals: 3.89E-01 4.64E-01 6.42E-01 6.99E-01 ) Inadvertent Intruder Infant Child Teenager Adult External 2.66E-01 2.66E-01 2.66E-01 2.66E-01 Vegetable - 2.90E-03 3.98E-03 4.34E-03 Inhalation 1.88E-03 5.68E-03 1.39E-02 1.84E-02 Water 8.29E-05 8.29E-05 8.29E-05 8.29E-05 Totals: 2.68E-01 2.75E-01 2.84E-01 2.89E-01 Cs-134-2
o-Cs-137 Concentration in Sludge: 2.0E-06 pCi/ml Sludge Volume Concentration Activity Ground Plane (Gallons) (cm3) (pCi/cm3) (pCi) Concentration (pCi/cm2) 15000 5.68E+07 2.00E-06 1.14E+02 5.62E-07 External Exposure y Dose Factor Ground Plane Concentration y Dose Rate (mrem /hr. per pCi/m2) (pCi/m2) (mrem / year) 4.20E-09 5.62E+03 2.07E-01 Continuous Occupancy: 2.07E-01 mrem / year ; Realistic Occupancy: 1.51E-03 mrem / year ! Meat & Milk Pathway j Activity in Activity in Concentration in Concentration in Concentration in Soil (pCi) Feed (pCi) Feed (pCi/Kg) Milk (pCi/f) Meat (pCi/kg) ! 1.14E+02 1.14E+00 6.13E+01 3.68E+01 1.23E+01 j l Milk Dose Rates (mrem / year) Infant Child Teenager Adult ! 5.26E-00 5.61E-01 7.64E-01 8.15E-01 i Heat Dose Rate (mrem / year) Infant Child Teenager Adult 2.33E-02 4.15E-02 9.66E-02 Vegetable Pathway Activity soil Volume Soil Mass Concentration Concentration (pCi) (Cm3) (Kg) in Soil (pCi/Kg) in Vegetables (pCi/Kg) 1.14E+02 3.08E+09 4.00E+06 2.85E+01 2.85E-01 Cs-137-1
~
Vegetable' Pathway Dose Rates (mrem / year) Infant -Child' Teenager Adult 3.69E-03 5.03E-03 '5.70E-03 Inhalation Pathway Ground Plane K- Air Concentration Concentration (pCi/m2) (m 2 ) (pCi/m3)' 5.62E+03 1.0E-05 5.62E-02 Inhalation Pathway Dose Rates (mrem / year)' Infant Child. Teenager Adult Continuous _0ccupancy- 2.56E-03 7.22E-03 1.75E-02 2.41E-02 Realistic Occupancy 1.87E-05 5.27E 1.28E-04_ 1.76E Release to Lake Michigan Activity 0Fj /0F Co-60 Co-60 eq. activity (pCi) (uCi) 1.14E+02 1.51E+01 1.72E+03 6 mrem , 1.72E+03 , 1 Ci 94.7 Ci 1.0E+06 pCi = 1.09E-04 mrem Maximally Exposed Individual Infant Child Teenager Adult l . External 1.51E-03 1.51E-03 1.51E-03 1.51E-03-- Milk 5.26E-01 5.61E-01 7.64E-01 L8.15E-01 Meat - 2.33E-02 _4.15E-02 5.70E-03 Vegetable - 3.69E-03 5.03E-03 5.70E-03 Inhalation 1.87E-05 5.27E-05' '1.28E-04 1.76E-04 Water 1.09E-04 '1.09E-04 1.09E-04 '1.09E-04 Totals: 5.28E-01 5.90E-01 8.12E-01 9.19E-01 Inadvertent Intruder Infant Child Teenager. Adult-External 2.07E-01 2.07E-01 2.'07E 2.07E-01~ Vegetable - 3.69E-03 -5.03E-03 5.70E-03 Inhalation 2.56E-03 7.22E-03 1.75E-02 2.41E-02 Water 1.09E-04 1. 09E- 04 1.09E-04 1.09E-04 Totals: 2.10E-01 2.18E-01 2.30E-01 2.37E-01: Cs-137-2
-]
Co-58 3 Concentration in Sludge: 1.00E-05 pCi/ml Sludge Volume Concentration Activity Ground Plane (pCi/cma ) (pCi) Concentration (pCi/cm2). (Gallons) (cm3) 15000 5.68E+07 1.00E-05 5.68E+02 2.81E-06 { k ( External Exposure y Dose Factor Ground Plane Concentration y Dose Rate (mrem /hr. per pCi/m2) (pCi/m2) (mrem / year) 7.00E-09 2.81E+04 1.72E+00 4 Continuous Occupancy: 1.72E+00 mrem / year Realistic Occupancy: 1.26E-02 mrem / year Meat & Milk Pathway 1 Activity in. Activity in Concentration in Concentration in Concentration in Soil (pCi) Feed (pCi) Feed (pCi/Kg) Milk (pCi/E) Meat (pCi/kg) 5.68E+02 5.34E+00 2.87E+02 1.44E+01 1.87E+02 Milk Dose Rates (mrem / year) Infant Child Teenager Adult 4.27E-02 2.62E-02 1.29E-02 7.45E-03 j Meat Dose Rate (mrem / year) l Infant Child Teenager Adult 4.22E-02 2.72E-02 3.44E-02 Vegetable Pathway Activity Soil Volume Soil Mass Concentration Concentration z (pCi) -(Cm3) (Kg) in Soil (pCi/Kg) in Vegetables (pCi/Kg) ; 5.68E+02 3.08E+09 4.00E+06 1.42E-04. 1.33E+00 , Co-58-1 i i
i Vegetable Pathway Dose Rates (mrem / year) Infant Child Teenager Adult 2.05E-03 1.01E-03 6.22E-04 , l Inhalation Pathway
]
Ground Plane K Air Concentration Concentration (pCi/m2) (m 2 ) (pCi/m3) 2.81E+04 1.0E-05 2.81E-01 Inhalation Pathway Dose Rates (mrem / year) Infant Child Teenager Adult l Continuous Occupancy 5.11E-04 8 89E-04 7.80E-04 5.82E-04 Realistic Occupancy 3.74E-06 6.49E-06 5.70E-06 4.25E-06 l Release to Lake Michigan I Activity DF4 /DF Co-60 Co-60 eq. activity (pCi) (pCi) 5.68E+02 3.54E-01 2.01E+02 6 mrem, a 2.01E+02 pCi i 1 Ci 94.7 C1 1.0E+06 pC1
. = 1.27E-05 mrem Maximally Exposed Individual Infant Child Teenager Adult External 1.26E-02 1.26E-02 1.26E-02 1.26E-02 Milk 4.27E-02 2.62E-02 1.29E-02 7.45E-03 Meat -
4.22E-02 2.72E-02 3.44E-02 Vegetable - 2.05E-03 1.01E-03 6.22E-04 I Inhalation 3.74E-06 6.49E-06 5.70E-06 4.25E-06 Water 1.27E-05 1.27E-05 1.27E-05 1.27E-05 Totals: 5.53E-02 8.31E-02 5.37E-02 5.51E-02 l l Inadvertent Intruder Infant Child Teenager Adult External 1.72E+00 1.72E+00 1.72E+00 1.72E+00 Vegetable - 2.05E-03 1.01E-03 6.22E-04 Inhalation 5. 1E-04 8.89E-04 7.80E-04 5.82E-04 Water 1.27E-05 1.27E-05 1.27E-05 1.27E-05 Totals: 1.72E+00 1.72E+00 1.72E+00 1.72E+00 Co-58-2 l
1 e l Co-60 Concentration in Sludge: 5.0E-06'pCi/ml
-Sludge Volume. Concentration . Activity Ground Plane l (Gallons) (cm3 ) (pCi/cm3) (pCi) Concentration (pCi/cm 2) 15000 5.68E+07 5.00E-06 2.84E+02 1.41E-06 )
I 1 External Exposure y Dose Factor Gro'un'd Plane Concentration y Dose Rate ; (mrem /hr. per pCi/m2) (pCi/m2) (mrem / year) - 1.70E-08 1.41E+04 2.09E+00 i Continuous Occupancy: 2.09E+00 mrem / year Realistic Occupancy: 1.53E-02 mrem / year Meat & Milk Pathway l Activity in Activity in Concentration in Concentration in Concentration in 3 Soil (pCi) Feed (pCi) Feed (pCi/Kg) Milk (pCi/E) Meat (pCi/kg) ' 2.84E+02 2.67E+00 1.44E+02 7.18E+00 9.33E+01 ~ Milk Dose Rates (mrem / year) Infant Child Teenager Adult 6.04E-02 3.70E-02 1.82E-02 1.05E-02 ! Meat Dose Rate (mrem / year) Infant Child Teenager Adult ; 1 5.97E-02 3.84E-02 4.84E-02 1 l ~ Vegetable Pathway l Activity- Soil Volume Soil Mass Concentration Concentration (pCi) (Cm3 ) (Kg) in Soil (pCi/Kg) in Vegetables (pCi/Kg) 2.84E+02 3.08E+09 4.00E+06 7.10E+01' 6.67E-01 l Co-60-1 ! 1
j e Vegetable Pathway Dose Rates (mrem / year) J Infant Child Teenager Adult 2.91E-03 1.44E 8.82E-04 Inhalation Pathway Ground Plane K Air Concentration Concentration (pCi/m2) (m"2 ) (pCi/m3) 1.41E+04 1.0E-05 1.41E-01 Inhalation Pathway Dose Rates (mrem / year) Infant Child leenager Adult Continuous Occupancy 1.66E-03 3.19E-03 2. 80E-03 2.09E-03 Realistic Occupancy 1.21E-05 2.33E-05 2.05E-05 1.53E-05 Release to Lake Michigan Activity DFj /DF Co-60 Co-60 eq. activity i (pCi) (pCi) 6 mrem a 2.84E+02pCi a 1 Ci 94.7 Ci 1.0E+06 pCi = 1.80E-05 mrem Maximally E. posed Individual Infant Child Teenager Adult External 1.53E-02 1.53E-02 1.53E-02 1.53E-02 Milk 6.04E-02 3.70E-02 1.82E-02 1.05E-02 Meat - 5.97E-02 3.84E-02 4.84E-02 Vegetable - 2.91E-03 1.44E-03 8.82E-04 Inhalation 1.21E-05 2.33E-05 2.05E-05 1.53E-05 Water 1.80E-05 1.80E-05 1.80E-05 1.80E-05 Totals: 7.57E-02 1.15E-01 7.34E-02 7.51E-02 l Inadvertent Intruder Infant Child Teenager Adult External 2.09E+00 2.09E+00 2.09E+00 2.09E+00 Vegetable - 2.91E-03 1.44E-03 8.82E-04 Inhalation 1.66E-03 3.19E-03 2.80E-03 2.09E-03 Water 1.80E-05 1.80E-05 1.80E-03 1.80E-03 Totals: 2.09E+00 2.10E+00 2.10E+00 2.09E+00 Co-60-2 L___________
'l J
APPENDIX G I CALCULATIONAL METHODOLOGY FOR DETERMINING EXTERNAL DOSE RATES FROM RADIONUCLIDES AFTER INCORPORATION INTO S0IL i 1 4 l 1 l 1 i i l l l
Wisconsin Electric utilizes QAD, a nationally recognized computer code, to perform shielding and dose rate analyses. The QAD computer. code utilizes a- i point kernel methodology to calculate the dose rate _at a specified point l due to a given source of; radiation. I
.QAD will be used to calculate the dose rate due to standing on a plot of land utilized for sludge disposal after the radionuclides ~have been incorporated into the plot by plowing. The following parameters will be used in the calculation:
1 The total activity from all previous disposals will be l corrected for radiological decay and used as.the radio- i nuclide source term. Appropriate values will be used to represent the surface area of the plot. q The radionuclides will be assumed to be incorporated uniformly into the top six inches of soil. The dose rate will be calculated at a height of 1 meter above the ground plane at a depth of 5 centimeters in .l tissue. (Regulatory Guide 1.109 values).
.l The density of the soil will be assumed to be 1.3 grams / !
cubic centimeter. ' This calculated dose rate will be used to assess the' radiological consequences of past disposals in conjunction.with the consequences of proposed. future disposals. The total radiological dose consequence of the past and the pro-posed disposal will be compared to the applicable-limits to insure the dose is maintained at or below the limits. i i J l i i i l i __ _ __ _j}}