ML20248B067

Refers to 830708 Telcon Re Ead,Inc Shipment of Matls in Storage at Lorado,Tx Containing Packaged Am-241 Foils & Unpackaged Equipment,Including Wet Mops in Pails,Fume Hoods & Ducts.Plans to Investigate Violations Requested

ML20248B067
Person / Time
Issue date:	07/13/1983
From:	Campbell M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bradley F NEW YORK, STATE OF
Shared Package
ML20248B055	List: ML20248B050 ML20248B067 ML20248B084
References
NUDOCS 8908090113
Download: ML20248B067 (2)

Text

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July 13, 1983 F. J. Bradley, Ph.D.

Principal Padiophysicist

'ew York Departraert of Labor Division of Safety & Health No World Trade Center

• v tork , fiew Ytrk 10047

+ar Dr. lir a dl ey :

lis refers to the telephone conversation between yourself anc Mr. Donald A. Nussbaumer. Assistant Director for State Agreements, Of fice of State Prograv..

Mr. Janes M. Allan, Deputy Regioral Administrator and myself on July 8,1983, discussing the EAD, Inc. shipment of materials in storage at Lorodo, Texas.

We had been informed by the State of Texas and the NRC Region IV office that this shipment consisted of two and one-balf truckloads of items and materials, mcluding peckaged americium-241 foils, and unpackaged equipment such as wet

. ops in pails, fume hoods, and ducts. These items have been surveyed for e stamination by the Texas Department of Health, who found levels of americium-N' icntamination exceeding DOT limits for contamination on packaged radioactive n.sterials by as much as a factor of fa r. As a result of partial unloading of oc of the trucks, removable contamination has also been found in the warehouse in Iorada, vou informed us that you had understood f rom your telephon? .s nversations with

?*-e Texas Department of Health that the shipper was only in violation of DOT requirements for failure to include radioactive materials on the shipping papers and external contamination nominally exceeding DOT limits. You also inf ormed us that an inspector f rom your staf f had visited the EAD, Inc.

facility, but that his inspection was limited to confirming the licensee's surveys af ter all oi the equipment used for work with americium-241 was removed.

f rom this conversation, we understand that you plan to contact EAD, Inc. and inf orm them that you will not cancel their license until the shipment of soterial end equipment now in Lorado, Texas, has been sent to a facility which is authorized to receive the shipment and the warehou e has been decontaminated.

.;e agreed to request the State of Texas Department of Health to provide you with documentation on levels of contamination measured by their inspectors and o description of the shipment.

would else appreciate your informing me of your plans to investigate the

<pparent violations of NY DOL regulations anc DOT regulations by EAD, Inc.,

the protective measures taken by EAD, Inc during cleanup of their facility, I

8908090113 890713 PDR ORG NGPZ )

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the exposures received by cleanup personnel, and any notifications made to your staff by EAD', Inc., while the cleanup was taking place.

Your cooperation with us is appreciated.

Sincerely,

/

1 C.$ $3.7 fl-c'Yk -

Myu A. Campbell '

State Agreements Officer I

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• s Enclosure 2 s' Sep tectie r 21, 1913 PMLIPIKARY Noi tFICATION OF EVENT OR UNUSUAL OCCURRENCE -- PNO-IV-83-22A This preliminary notification constitutes EARLY notice of events of P015!BLE safety or public interest significance. The information is as initial 1y received without verification er evaluation, and is basically all that is t.nown by NRC staff on this date.

FACILITY: E.A.D. Metallurgical. Inc. Licelesee Emergency Classificattor:

Tonawanda New York __,,,,,, No t i f i c a t i o n o f Un u s u a l E v e n t (New York Agreement State _,_ Alert Licensee) ___ Site Area Emergency General Emergency

'_T Not Applicable

$UNECT: TRANSPORTATION OF 48ERICIUM-241 CONTAMINATED EQUIPMENT This is to provide en 6pdate on the omcricium-211 contaminated equistrient the+

=as shtoped f rom E. A.0, Metallurgical (a state-licensed smoke-detector manu-facturer in New York) through Laredo, Texas, with final destination to have been Monterrey, Mexico. The contaminated material is currently still irpounded by the Texas Bureau of Radiation Control in an isolated corner of a warehouse in Laredo, Texas.

Since the issuance of the order impounding the shipment on July 1,1983, several meetings have been conducted 4th representatives from the Department of Transportation, the Texas Bureau of-Radiation Control, E. A.D. Metallurgical, and the NRC Of fice of $ tate Programs.

To date, the issue remains of how to rbpackage and trinsfer the equipment to approortate f acilities in Mexico, ,'

the State and Federal agencies involved are continu17ig Chef r' investigations c'

'ba incident and age 3pt_injLt_o_y,esu1ve the issue with E.A.D. officials. Ttere has been media interest concerning 'tle incident CONTACT: R. $. Heyer, RIV, 728-8252 DISTRIBUTION:

H. $T, MNBB Pht111ps E/W W1115te MAIL:

Chen Palladino EDO NRR IE NMSS 00T: Trans On' Cosa. G111nsky PA 01A RES OMB (Orig 1 C ~;

MPA AE00 INPO Comm. Roberts '~ ~ ~

NSAC Com. Asselstine ELD Comm. Bernthal SECY Air R'p ~ts ACR$ U~~~~

CA - - - - . . - _ . _ _ . _ . . . . . . . . . _ . .

(Reactor Licensees)

SGR$h SGR TPBh DV& h1 P RFeye r:sj RDoda GBrdwn RBa tiWt C#hner lins 9/'y/83 /83 9/ft/83 /83 7/p/83 9g/83 9/)

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Ref: 5A/J0. i LOTE FLf: Paul Lchaui l

I EAD SANITARY SEL:ER SYSTEli DISCHARGES On Septerter 4,19E41 indicated te you ths.t ! could not ctr.clude thi.t <

EAD discharges to the sanitary sewer syster (555) tret the applicitle j critcrie f or such dischargrs based on tFC review cf fev York Deptrtren* l of L7ber (MDL) files and that there are strcrg suggesticris in the files tr.6t they did not. The folicwing set cut ry reasons for those conclusions.

The primary kyDL sources of informattor en EAD 555 discharges were:

o October 16, 1976 EAD License Application o R. Kelly Inspection Report for February 13, 14, 20, 1979 o R. Kelly Inspection Report for May 5, 6, 7, 13, 1981 o 1984 F. Bradley to Dr. Stasiuk memo re EAC 555 discharges (month and date not noted)  ;

555 discharges in New York are governed by the NY Department of Environmental Conservation (NYDEC) Part 380. Industrial Code Rule 38.23  ;

and State Sanitary Code 16.8 (c) also provide regulatory guidance. j 1

EAD did not possess e GYDEC permit for liquid effluents. Therefore the appliceble regulatory criteria for 555 discharges of Am-241 v:ere the same as for NRC licensees (See 10 CFR 20.303):

1. The material must te "readily soluble er dispersible in water" i

2. Tbc daily cuentity' cischarged doet not exceec the larger cf the To % wing:

(c) that Cuantity which, if diluted by the average quantity of sewerage released into the 555 in any day, would result in ar* average concentration ecual to the KPC ir. Col . 2 of Table 1 of Appendix B of Fart 20.

2.[

(b) 107 ttc cuar.i.y set forth in Appendix C cf P6rt 20 cr 10 x 0.C M i or 0.luti.

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Cuanti.y Criter'a for Distnarging Racicactive t'atertals 1 to 5aritary Sewer Systems {

i Evarrie:

Isotcce: Cc-60 Oai'.i Se.e;e Veture 'vera;e 500C gete5 Menthly Se age volure Average: 152,CCC geiic*

Daily: 20.303(b)(1) er (b)(2) whien ever is larger.

20.303(b)(1): 1x IC" uti x'5 5 103 cal x 1 x 10 3mi mi- 0.;cagai T- j i

=12.8 x 10" vCi or IE.E mci 20.3C3(c)(2): 10 x luCi or 10 u:1 The caily limit is the larger of the twc or 18.8 mci e ,

Perthly: 20.2C3(c)- 1x 10 3uti x 1.!2 x 10' cal x ~

1 10 r' FT .264 gai 1 "-

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=5.76 x 10'uti er j_7_6 mci I Arraal: 20.303(d): 1 C1 (1,000 mci)

A d'scharge of sewage contanttated at the MPC for 200 workdays in a yee-would result in exceeding the annual limitt j 18.8 mci y 200 days ='3,780 mci vs. 1,000 mC1 )

4 dty

!! '915 licensee produced records cr.ly-shewirg that the 555 discharges j cic not exceed the Schedule ! MFC, cor.pliance with :11 parts of 10 CF:

cer: 20.303 was net demonstrated. ,

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EnclostLTe 4 S.

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l,., -; NUCLE AH HEGULATORY COMMISSION ,-

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November 7,1984 Kari;a Rimawi, Ph.D. , Director

-Bureau of Environmental Radiation Protection New York State Department of Health Empire State Plaza, Corning Tower Albany, New York 12237

Dear Dr. Rimawi:

This is in further response to your September 13, 1984 request for technical assistance and our discussion on October 2, 1984. I have listed below several documents which provide information about the stabilization of LLW and U-mill tailings disposal facilities. These documents may be of assistance in your efforts to evaluate stabilization of the Tonawanda landfill. Under separate cover, I am sending you a copy of each one.

1. NUREC/CR-3144 " Trench Design and Construction Techniques for Low-Level Radioactive Waste Disposal Facilities."

2. NUREG/CR-2471 - Vols. 1&2 "A Study of Trench Covers to Minimize Infiltration at Waste Disposal Sites "

3. NUREC/CR-3356 "Geetechnical Quality Control: Low-Level Radioactive Waste and Uranium Milling Tailings Disposal Facilities."

4. NUREG-2397 - Design Considerations for Long-Term Stabilization of Uranium Mill Tailings Improvements.

5. Draf t Regulatory Guide " Design of Long-term Erosion-Protection Covers for Reclamation of Uranium Mill Sites."

(Please see handwritten note on first page.)-

6. NUREG/CR-3027 " Overload Erosion of Uranium Mill Tailings Improvements: Physical Processes and Computational Methods.

7. UMTRA-DOE /AL-140 " Remedial Action Plan for Stabilization of the Inactive Uranium Mill Tailings Site at Canonsburg, Pennsylvania.

If I may be of further assistance, please call me at (215) 337-5246.

Sincerely, 0$W Paul H. Lohaus State liaison Officer

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Enclosure 5 t.

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"!MORANDUM IDR. Robert D. Martin, Regiona Administrator Region IV ]

j FRDM: Pobert J. Doce, Chief )

State and Governmental Affairs Staff i

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SUBJECT:

LETTER TO CHAIRHAN PALLADIND FROM MR. DAv!D SEGOVIA-KANE j OF HONTERREY, MEXICO j

This is in reference to the subject letter (copy attached), which was dated October 18, 1984, and to our ef forts to obtain information concerning the (

proposed shipment to the U.S. of contaminated equipment and materials -

originally owned by EAD Metallurgical, Inc. , Tonawanda, New York.

Since the letter indicated the possibility of a shipment during November 1984, Region IV staff felt that an immediate telephone call to Mr. Segovia-Kane was necessary to determine the exact disposition of the proposed shipment. It was agreed during a discussion between J. D. Lafleur, IP. and J. O. Lubenau, SP, j

that Region 14 make this telephone contact. The call was completed on l November 15, 1984, with the f=ollowing results:

(1) The contaminated equipment and materials are still locoted in Monterrey, Mexico with no presently established shipment date.

(2) Mr. Segovia-Kane is seeking guidance on how to get rid of the contaminated equipment and materials.

(3) Mr. Segov18-Kane believes he is not the legal owner of the equipment.

(4) Mr. Segovia-Kane stated that his intention is to ship to LAD, Laredo, Texas.

(5) Mr. Segovia-Kane was told that the company (EAD) was no longer in business ,

and that the company's license did not authorize the receipt of the equipment i and materials in question.

(6) Mr. Segovia-Kane was told that NRC personnel would contact him again soon with f urther inf ormation.

The above information was called in to R1, IP, and SP staff on November 15, 1984 i

'e - .r.ca cy, F.. J. OccA" Robert J. Ooda, Chief State and Governmental Affairs Staff bce; R. D. Martin R. J. Everett J. O. Lafleur, IP P. 5. Check R. J. Dode . D. A. Nussbaumer, 50 R. L. Bangart G. F. Sanborn ~ P. Lohaus, R1 W. L. Brcwn R. 5. heyer J. Hickey, NM55 C. v. Wisner Texas Fi'e

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OCTOSDt 13, 1984 f // g. C.

• 1 U.S. AUCLEAR FIGAMVRY CEMISSION AT'N: FR. N.NZIO,J. PA11ADIlO [ff/ g

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Dear Mr. Palladino,

my re.s is . David.Segovia-Kane, Iam from bbnterrey, Inxico and President of IRSEKA FEIALURGICA DE F2XICD,$.A. DE C.V. I The purporse of this letter is to let you know that we he.ve had many problems in trying to set up a plant that used to be own tr/

EAD METALLURGICAL INC., located in Tonswanda, N.Y., U.S.A.; Mr. Lee Walker (EAD's president) has failed on delivering to us the *2sistance of technology (or know how), with such edquences ~that we have not )

been able to start any operation in wr plant in Mexico; my belief is that he rever will. .

I Ibus, the actual situation is, that we are sending back the equi;snent to Mr. Walker, and our snainly reasons are the following: j

. 1

1) EAD has failed to deliver technical assistence. ' l

2) h*e have invested too much money in this venture. {

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3) Mr. walker assured us (letter enc)osed), that he would accept j

• full responsibility for the proper' disposal of any waste material;  !

from our stand stand point, all.the equipment and inventory is l u ste material, since we can not use them for prodution. 1

4) Mr. Richard A. natliff, from the Texas departament of health (letter enclosed) that the radioactive materials shiped by LC to us, are under the low specific activity limits of ,

tittle 49 CFR 173.403 (n) (5) with SS gallon druns containing ,)

americium 241 in accordance with the U.S. NJCLEAF. PIGULATOKr 1 COFMISSION CERTIFICATE of Ccxnpliance No. 6141 ns amended. .l Tnu, assuring that everything is in complete accordance with '

the rules and reguistions of the U.S. ICT and Texas departament of health. l 4

-) *3 have been inspe.:ted by the 11exienn NRC (the persons in l

curge of the insp:ction wrc Mr. Andr.*s Lope: Eautista arx! )

.:r. tmere;il.lo *laldon!do), stating that crewthini.18 in  !

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Ane.no at Ot.oaco 1733 Csate.1 Calenls DDisado 7sl 484&N

c. r. ssono men.ney. u. g Our paceduti, to send back these equipment a:d inventary muld be the sollowirg: ,

1)Wewil1$Nt:1&ce the 55 gallon dnas inside of 2 steel containers, in ottler to be t'ransported safely.

2) The port of entry to the United St,ates will be Laredo, Texas.

3) The transportation of th!s equipment and inventory will be

• fr.ade in the aanth of November /1984

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4). We am send'ag a lettsr to the U.S. DOT. .

Please let me 1 mow if you have sometFkrgore to add on this matter I would really appreciate your assistance ans understanding.

Thank y'ou for eveiythiv, truly you:s r  ?

nAvro -rne DASEKA METAWRGICA MEXICD, S.A. DE C Y.

PRESIDENT.

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Hovember 25, 1983 Mr. David Segovip Kyne President ' *- T *

• Deseks Metalurgica De Mexico Arbol 9181 Col. Santa En Cructs . . I C.C. Nuevo Leon MEXICO

Dear David:

Enclosed is a letter from the Texas Departme# nt c ?'f. Heal'th providing the

. assurance that all of the equipment and inventory of EAD Metallurgical has been shipped in cnmplete accordance with the rules and regulations of the United States Papartment of Transportstlen and the Texas Department of Health.

l Also by copy cf this letter I would like to provide you and your '

company with the assurance that we,,.will take all necessary steps to assist you in removing any waste products th&1 may dtvelop as a consequence of your operations. I do not expect these amounts to be In any great quantity but should your operation develop any wasta we wll!

accept full responsibility for their proper dis;iosal.

I look forward to a successful operation wl}h you..

Sincerely, E. Lee Walker President eod metallurgical Inc.

P .O. It'ir 1 *4 2 Tent e..anda , t;cw Yt,r k

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I Enclosure 6 v hee, W '\

• y-DISTRIBUT10' DEC 10 W EDO-000133

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Mr. David Segovia-Kane President [D rf Daseka Metallurgical De Mexic $

Arbol #181 il t n Col. Santa En Gracia G.G. Nuevo Leon ,[an ~

MEXICO JShea JHickey

Dear Mr. Segovia 4ane:

LHiginb the-This is in response to your letter of October 18 to Chairman Palladino requesting assistance in the safe disposal of a quantity of waste material

' containing americium-241. The Comission staff has considered your proposal to return the material to EAD Metallurgical in Tonawanda. New York for disposal. While your intention to return the material to EAD is understandable, we have been advised by the New York nuclear regulatory officials, who have jurisdiction over the disposition of the material within New York State, that EAD is no longer authorized to receive and possess material containing americium-241.

With respect to alternative disposal locations in the United States, at this time neither the federal Nuclear Regulatory Comission nor any State nuclear regulatory agency has licensed the operator of a disposal site to receive ae.ericium-741 or any other transuranic bearing material in concentrated amounts for disposal.

As a result of the situation described above the Ccmission staff recotrnends that you seek either to sell these e.aterials to someone who S licensed to receive and possess them, or to find alternate means of disposal iithin Mexico. Some of the material may be of low enough activity to peme disoosa' as low-level waste. The Mexican Muclear Safety and Safeguards Commissbn should be able to assist you in this effort.

We appreciate your cooperation and patience in working to find a reasoneHe resolution of this problem. H erse write to me if you have additional questicas.

Sincerely, ELDr' gperW3amLL W IE"[,M JBecher 11/29/84 NMSS)I}h JHick 11/27/84 LCobb William J. Dircks 27/84 Executive Director for Operations cc: Cept. of State Amembassy Ne'xico i

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• rA i190U11 RILE CODEt RES-1-O:I . A.O

'O DISTRICT DIRECTOR, LAREDO, SAUTHWEST REGION

'H QRC, OPERATIONS, SOUTHWEST RFGION 7T 10BJECTt POSSIBLE ATTEMPT TO IMPORT RADIATION CONTAMINATED EOUIPMENT.

-E HA'iE BEEN ADVISED BY A REPRESENTATIVE OF THE -t40 CLEAR REGUL WC i THAT A SHIPHENT OF 25 BARRELS OF EOUIPMENT CO!4TAH1NATED H W EE PRESENTED FOR ENTPY AT THE PORT OF LAREDO OR CilOTHER OF YOU

'84SHUCH AS SUCH HATERI AL REQUIRES A LICENSE (HEC FORM 250) HHICH

'ES NOT.INTEt1D TO ISSUE, PLEASE DETAIN THE SHIPMENT IF IT IS PRESET 4TED 45 MERCHANDISE HAS DESCRIBED AS "EOUIPHENT" PACKED , WHICH IN 25 BARRELS LOBABLY HILL BE LOADED IN TNG STEEL CONTAINERS .. THESE CONTAINERS ARE-OPAOLY LOADED ON SEPARATE' TRUCKS. THE MATERIAL, ALTHOUGH DESCRIBED AS'

)T BE DETECTED BY YOUR PRESENT i?ARD IF IT RCHAINS UNOPENED.

EQUIPMENT.NTOMINATE AS DESCRIBED IT PRESENTS NO'

'06 ABLY FROtd NONTERREY.E tiERCHANDISE IS EXPECTED TO EE SHIPPED BY DAk

,,D.D."

HITH OFFICES IN HEN YORK AND TEMAS.THE CONSGNEE WILL L THIS FIRH IS DEFUNCT AND WILL T OBTAltJ THE APPROPRIATE LICEt1SE.

EASE TAKE APPROPRIATE STEPS

ruRTHER INFORMATION, TO ASSURE THAT THISOF MERCHA iutATORY COHH1SS10t4, TELEPHONECONTACT JERRV EVERETT, REPRESENTATIVE THE NUC 728-8187 (FTS), COHt1ERCIAL (817) 660-8167 41ED 0 A 00YETT dr ocet l

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Enclosure 7

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January 31, 1983 {

I 1

MEMORANDUM FOR: William T. Crow, Acting Chief, Uranium Fuel Licensing )

Branch, NMSS FROM: Paul H. Lohaus, State Liaison Officer, Region I. a

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE FROM NEW YORK STATE 4

We have received the enclosed request for technical assistance from Karim Rimawi to review and comment on the americium decontamination plan for the Town of Tonawonca' sewage treatment plant and related facilities. The plan was prepared .

and submitted by ENSA, Inc., and reflects comments made by the State of New I York on an earlier version. To meet State commitments, Karim would like to receive our comments by February 8,1985. Given the short time frame, I suggest we relay any initial comments to Karim by phone and follow-up with written comments later. In addition, Karim has sent us his only copy of the. plan because the blueprints in Appendix A are difficult to copy. I have enclosed his 1 original copy and two additional copies of the text. Please return Karim's i original copy so that we may return it to him. ),

We appreciate your assistance in this matter. Please call if you have any i questions or require additional information,

t. : .i :

G'  ;

p ., a. H . b: . .- . < j Paul H. Lohaus State Liaison Officer

Enclosure:

As Stated Distribution: (w/o Encl.)

T.. Murley J. Allan i' R. Cunningham R. Browning J. Saltzman '

i F. Costello -

J. McGrath

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Nussbaumer i J. Joyner  ;

J. Starmer  ;

P. Lohaus ,

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PLo.1aus/mrf j, 1/?)/85 0FFIC_IAL RECORD COPY _ _ _ _ _ _ _ _ _ _ ___ _i

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JAN 1519g5 ,-?$M8 I1 The Honorable David Axelrod, M.D. j Commissioner of Health j State of New York l Department of Health j Albany, NY 12237

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Dear Commissioner Axelrod:

I am responding to your letter of December 11, 1984, to Chairman Palladino  ;

regarding the two recent incidents in New York where sewers, sewage treatment ]

plants, and sewage sludge were contaminated by a radionuclides. We agree that j these incidents strongly suggest a need to reexamine the bases for nur regulations governing disposal of radionuclides via discharge into sanitary sewer systems.

Over the past several years, we have been developing a complete revision to our l radiatfor protection regulations in 10 CFR Part 20, including modifications to i the requirements for disposal into sewer systems. The proposed changes include I concentration limits based upon the 0.5 rem per year dose limit to the general l public rather than using the occupational concentration limits in Table I of Appendix B to 10 CFR Part 20, which are also the current sewer disposal limits and are based upon annual whole body dose limits of 5 rem per year. This change would reduce the allowable concentration limits by about a factor of 30 (a factor of 10 for the reduction in allowable dose limits and a factor of 3 for going from an 8-hour working day to a 24-hour exposure day). A second change which has been incorporated into the' current draft of the revised 10 CFR Part 20 is to make more restrictive the allowable. physicochemical form of radioactive materials for sewer disposal. The present requirement for a "dispersible" fann would be replaced by a requirement that the materials be

" soluble" in water. These changes were developed prior to the two recent incidents in New York State and, therefore, are not directly responsive to the presence of possible biophysica.' concentration processes in the sewage, at the sewage treatment plants, or sludge disposal processes. Nevertheless, the indicated changes, if adopted, would act to reduce both the possibility and magnitude of any recurrences of the 7onowanda and Grand Island int.idents.

We have initie.ted a study of possible reconcentration mechanisms and exposure pathways to man for radionuclides released into sanitary sewers. This r.tudy was initated in response to concerns expressed to us by Donald Nussbau;ner, Assistant Director for State Agreements Programs in our Office of State Programs, end by Dr. Thomas Murley, Regional Administrator for NRC Region I.

Their concerns in large part reflected the Tonowanda and Grand Island

- C ] ali

2 contamination incidents. I am enclosing a copy of the outline for that study which is in its initial data-gathering phase. Any comments or suggestions you or your staff might wish to make regaroing this study would be appreciated. We will be pleased to provide you with a copy of the final report from this study when it is completed. We expect that this study will be completed in about 6 months.

I hope that I have been responsive to your concerns and I welcome any comments or assistance from you or your staff regarding the pathway study.

Sincerely, crisismi sisood WF8' sI0BERT 5. MIEDRE ,

Robert B. Minogue, Director Office of Nuclear Regul6 tory Research

Enclosure:

Study Outline DISTRIBUTION: ED0-000227 RES-84-2798 ED0-000227 SECY-84-2064 JDavis WKerr GCunningham TMurley, RI PLohaus, RI l-ONU3sbaumer,OSP MBridgers DManson RMinogue Dross KGoller Econti WAMills HPeterson Subj. (C.7.20)

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Outline of Scoping Study for Evaluating Potential Hazards of Releases of Radioactive Wastes ,

to Sanitary Sewer Systems i,

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i I. Introduction A. Current Practice and Regulations ,

B. Impact of_ Revisions to 10 CFR Part 20 C. Incidents 1

1. - Description j

2. Imract

3. Remedies.

II. Sewage Treatment and Disposal i

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A. Characteristics B. Sedimentation Processes j C. Digestion Processes Treatment D.

E. Disposal Options III. Radiological Impact of Sewage Sludge Incineration q A. Process and Magnitude l B. Effluents and Control Measures C. Potential Pathways to Man D. Disposal Restrictions Required (on licensee)

IV. Radiological Impact of Sewage Sludge by 1.and Application and in Landfills A. Processes and Magnitude B. Soil-Plant Uptake C. Drinking Water Contamination D. Disposal Restrictions Required (on licensee) i V. Radiological Impact of Sewage Sludge by Other Methods A. Ocean Disposal (subject to EPA Pemit - not treated in detail)

B. Marketed Sludge Products C. Other D. Possible Disposal Restrictions on Licensees VI. Sumary and Conclusions l

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., Enclosure 8 f 1

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February 4, 1985' y [C:

Karim Rimawi, Ph.D. , Director Bureau of Environmental Radiaiion Protection New York State Health Department Empire State Plaza, Corning Tower Albany, New York 12237

Dear Dr. Rimawi:

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I have enclosed a memo and enclosures from R. John Starmer, Division of Waste l

Management that provides geochemical information on how americium might potentially behave in a landfill. Dr. Starmer's memo and enclosures, end the two additional enclosures on EPA Extraction Procedure Toxicity Characteristics-are in further response to your request for technical assistance regarding ash , _

j contaminated with AM-241 in the Town of Tonawanda landfill.

As Dr.. Starmer notes, if you have any questions or would like to discuss the

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information f urther, please let us know.  !

j Paul H. Lohaus State Liaison Officer

Enclosures:

As Stated Distribution:

TMurley JAllan J5altJman N ssbaumer FCostello JStarmer WCrow JMcGrath PLohaus q

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gf 2/l/85 0FFICIAL RECORD COPY