ML20134K602

Informs That Info Contained in Licensee Request to Determine Whether Protocol,Submitted by Interstate Nuclear Sys,Meets Requirement in 10CFR20.2003,not Sufficiently Complete to Permit Comprehensive Licensee Review

ML20134K602
Person / Time
Issue date:	02/05/1997
From:	Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP)
To:	Floyd W NEW MEXICO, STATE OF
Shared Package
ML20134K606	List: ML20134K602 ML20134K625
References
NUDOCS 9702140105
Download: ML20134K602 (1)

Text

.

8 Q ps Y

7 g t UNITED STATES

• , NUCLEAR REGULATORY COMMISSION U WASHINGTON, D.C. 30606 4 001 i

\*****[! February 5, 1996 Mr. William M. Floyd, Program Manager

Radiation, Licensing and Registration Hazardous and Radioactive Materials Bureau Environment Department State of New Mexico 2044 Galisteo Road P.O. Box 26110 Santa Fe, NM 87502 l

Dear Mr. Floyd:

The NRC staff has completed its review of your request to determine whether a protocol, submitted to you by Interstate Nuclear Services (INS), meets the solubility requirements in Section 20.2003 of 10 CFR Part 20. The material reviewed consisted of your November 12,1996 letter to me with attachments, and the December 19,1996 note to me from Walter Medina enclosing supplemental material, in particular, a December 2, 1996 letter to you from Chriso Petropoulou of Patterson and Associates, Inc.

Based on our review, we do not believe that the information submitted is sufficiently

. complete to permit a comprehensive licensing review to determine whether or not the system proposed for use by INS at their Santa Fe facility meets the requirements in 10 CFR Part 20, as supplemented by the guidance in the NRC's Information Notice (IN) 94-07, " Solubility Criteria for Liquid Effluent Releases to Sanitary Sewerage Under the Revised 10 CFR Part 20." Although the treatment methods appear to be standard industry practice for treating the wastewater, the INS protocol makes no mention of sewer discharges nor does it mention testing of the discharges for meeting compliance with the regulations. For example, information to confirm system capabilities and specifications and on the testing and quality assurance program that would be performed during operations are areas that should be addressed in the application. The protocol does not 4

address testing of discharges for compliance with regulatory requirements nor compliance with the protocol specifications. ,

The INS needs to confirm the proposed system capabilities and specifications as well as confirm that proposed operations would continue to meet the specifications necessary to comply with regulatory requirements. Of particular concern is a statement in the INS protocol that indicates that the proposed system would be designed to use a screen shaker with a 44 micron filter pore size, and a wastewater filter capable of removing portions of suspended solids with a size down to 1 micron. One of the recommended procedures /

referenced in IN 94-07 (ASTM D1888-78, " Standard Test Methods for Particulate and Dissolved Matter, Solids, or Residue in Water") states that a 0.45 micron pore size filter I[

should be used. Thus, it appears radioactive particles with a diameter of less than 44 microns could be contained in the effluent sewer discharge. If so, that radioactive material C5GM 13001 %g gig cmTFR COPY 9702140105 970205 PDR STPRG ESGN g []y 'J

t ,

W. M. Floyd -2 FEB 0 51997  !

] >

i in the discharge would not be soluble, per the guidance in IN 94-07. Two other INS

facihties, Royerford, PA and Columbia, SC, respectively, are approved for operation with  !

i wastewater filter sizes of 20 25 microns. The NRC recognizes that alternative criteria, l'

other than that identified in the IN, may be acceptable on a case-by-case basis, yet INS has provided no supporting documentation to support the use of any alternate criteria for 1 sanitary sewer discharge. ,

i Given that the provided documentation was inadequate for a determination of the solubility ,

l requirements per 10 CFR 20.2003, we consider this technical assistance response to fall l within the purview of routine technical assistance, and as such, it is not cost reimbursable '

by New Mexico.

l Finally, we are providing copies of this response to Patricio Loerrerortiz, Santa Fe Public

Utilities Department Director and to Caron Balkany, Concerned Citizens for Nuclear Safety, j who have written to us expressing interest in your technical assistance request.

t We trust this responds to your request. If we may be of further assistance, please do not l

hesitate to contact us. .

'ncorely, (N

Paul H. Lohaus, Deputy Director Office of State Programs cc:

C. Balkany j P. Guerrerortiz f

2 i

i 4

4 1

I 1

l f

t

, 0,

• e .

g

. n, , .

W. M. Floyd -2 FEB 0 51997

,q ,

.4

,e . #

~

'/ / in the discharge would ndt de soluble, per the guidance in IN g4-07. Two other INS  :

I y - facilities, Royerford, PA and Columbia, SC, respectively, are approved for ormation with wastewater filter sizes of 20 25 microns. The NRC recognizes that alternatwo criteria,

~

other than that identified in the IN, may be acceptable on a case-by-case basis, yet INS has provided no supporting documentation to support the use of any alternate criteria for

, sanitary sewer discharge.

Given that the provided documentation was inadequate for a determination of the solubility requirements per 10 CFR 20.2003, we consider this technical assistance response to fall within the purview of routine technical assistance, and as such, it is not cost reimbursable by New Mexico.

Finally, we are providing copies of this response to Patricio Guerrerortiz, Santa Fe Public Utilities Department Director and to Caron Balkany, Concerned Citizens for Nuclear Safety, '

who have written to us expressing interest in your technical assistance request.

We trust this responds to your request. If we may be of further assistance, please do not hesitate to contact us.

Sincerely, OrignalSigned Br.

PAUL H.LOHAUS Paul H. Lohaus, Deputy Director Office of State Programs cc:

C. Balkany P. Guerrerottiz Distribution:

DlR RF (65286) lDCD (SP08i  !

RLBangart PDR (YESfj_ NO_)

PLohaus SDroggitis LRakovan BO'Connell, NMSS CJones, NMSS DCool, NMSS New. Mexico Filei DOCUMENT NAME: G:\PHL\lNSOSP. TAR r g vi ,.ce. . c.,, .e sur e i. i.e in th. 6. : c- @vknhoui .it.ch 4 ao.ur. T - Copy wMh .tt.chment/.ncio.ur. "N" = No copy OFFICE OSP f , ,, , [ OSy:f)D( l lMNS/NWSQ OSPg,7 l l NAME LRakovan:rlb V ' , PHLohapsf ) DCool T1hs\

k RLBanGapt*/d DATE 02/5 /97 02/\ /97 02/5/97 02/f5/97 4

-OSP FILE CODE: SP-AG -

s y 0 q

4-

• k

1

.r~ . \

& i  !

i m aiiie i --ee .-e i EXECUTIVE TASK MANAGEMENT SYSTEM

,r) ......... .... .......... ......

g P <<< PRINT SCREEN UPDATE FORM >>>

TASK # - 6S286' gV _ M DATE- 11/20/96 MAIL CTRL. - 1996 g( ..........

TASK SARTED - 11/20/96 TASK DUE - // TASK COMPLETED -

/ /

TASK DESCRIPTION - 11/12/96 - TAR - PROTOCOL MEETS SOLUBILITY REQUIREMENTS

.............. ~

FOR RELEASE OF RADIONUCLIDES INTO SANITARY SEWER l REQUESTING OFF. - NM REQUESTER - W. FLOYD WITS - 0 FYP - N PROG.- PERSON - STAFF LEAD - PROG.

AREA -

PROJECT STATUS - OSP DUE DATE:

PLANNED ACC. -N LEVEL CODE - 1 Cd14L- i

/W--

- O eb b ~- O bc g a,u p d4n e ss Aosm l J.. J. h"',F e "t (t i

,b.sg s i h uq yc#c 4 %f < (L k.

n "' aju fd, -}<

f pu #w h# g Ill', de g

* v

1. ~

vf 1 M u

MI f[ pl$ OP ,

1

_ __ l