ML20246E041
| ML20246E041 | |
| Person / Time | |
|---|---|
| Issue date: | 05/02/1989 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20246E044 | List: |
| References | |
| REF-WM-3 NUDOCS 8905110122 | |
| Download: ML20246E041 (3) | |
Text
O 1
t-RICHARD CUNNINGHAM DUP. MEMORANDUM FOR:
Richard E. Cunningham, Director Division of Industrial and Medical MAY - 21939 Nuclear Safety, NMSS FROM:
John T. Greeves, Acting Director Division of Low-Level Waste Management and Decommissioning, NMSS
SUBJECT:
LLTB'S RESPONSE TO PR0 TECHNICS INTERNATIONAL'S REQUEST FOR DISPOSAL OF RADI0 ACTIVE FRAC SANDS This memorandum is in response to your April 12, 1989 request for LLTB to review Pyrotechnics International's April 6, 1989 request for NRC authorization to bury radioactive frac sand from their recent " sand-out" on the Mobil location (Gregory Lease Unit #1 --Northeast of Elk City, Oklahoma).
The frac sand is contaminated with Ir-192, a gamma emitter, and the major pathway for human exposure is through external exposure.
The volume of the licensee's proposed burial is rather small, less than about 1 m x 1 m x 2 m.
Total activity is about 2.5 millicuries, but concentration is about 900 picocuries per gram.
LLTB is proposing criteria for approving on-site burials of this type meant to I
ensure proper control of the material consistent with the March 27, 1987 Brookhaven National Laboratory (BNL) report, titled, " Generic Asessment of Onsite Disposal of Frac Sand," based on where applicable, computer programs and methods described in volumes 1 and 2 of NUREG-1101.
The criteria should ensure that during the control period, allowing for radioactive decay, the l
material will not be unintentionally excavated, and spread to the environment 1
or misused by individuals, and that there is adequate protection of usable water resources.
The criteria are:
1.
Half-life less than 100 days.
l 2.
Total activity less than 4.0 millicuries, 3.
Concentration less than 550 picocuries per gram.
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4.
Cover thickness greater than 1.2 meters.
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5.
Predominately cationic species in groundwater.
6.
Distance to groundwater greater than 3.0 meters.
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7.
Distance to nearest residence, potable water well or irrigation well greater than 200 meters.
8.
Administrative controls for two years by posting a sign indicating no excavation, and notification to contact licensee NSid in case of problems.
8905110122 890502 g
FDR AASTE 1-WM-3 ODC Q
o Richard E. Cunningham 9.
Assurance that all State and local requirements have been met.
LLTB reviewed information provided by Pyrotechnics International concerning the Gregory Lease " sand-out", provided in an April 6,1989 letter and in supplemental information provided on April 21, 1989.
The licensee's information shows that the concentration of Ir-192 is about 900 picocuries per gram, and exceeds the LLTB NRC criterion of less than 550 picocuries per gram.
The staff, therefore, analyzed an intruder scenario and assumed an individual working in the area exposed directly to this material for a full day (24 hrs.).
The calculated direct gamma radiation dose is less than 1 mrem. The licensee has assured staff that no work will be conducted in this area for a period of at least 74 days or one half life of Ir-192.
In addition, the licensee will post a sign at the burial area indicating that no excavation is to be conducted at this site, and bearing a notice'to contact the licensee in case of any problem.
The sign will not be removed during a period of two years. Thus, the concentration of 900 picocuries of Ir-192, which exceeds the LLTB NRC proposed less than 550 picocuries per gram, is accounted for by the licensee's commitment to provide administrative control for two years rather than one year.
The staff, now, concludes that information presented and commitments made by Pyrotechnics International, provide assurance that they can properly control the disposed material and no adverse effect to the public or the environs is expected from this burial.
We recommend that the licensee's proposed action for the Gregory Lease sand-out be approved subject to the licensee's commitments as described in their letters dated April 6, 1989 and supplement dated April 21, 1989.
For this proposed burial, the staff consulted with Charles L. Cain (NRC -
Region IV) by telephone, and coordinated this response with Michael Lamastra and Bruce Carrico of your staff.
They have no objection to this proposed action.
OriginnI Ei M D John T. Greeves, Acting Director Division of Low-Level Waste Management and Decommissioning, NMSS cc:
Charles L. Cain
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