ML20126H366
| ML20126H366 | |
| Person / Time | |
|---|---|
| Issue date: | 11/01/1984 |
| From: | Lohaus P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Bradley F NEW YORK, STATE OF |
| Shared Package | |
| ML20126H305 | List: |
| References | |
| FOIA-85-210 NUDOCS 8506180324 | |
| Download: ML20126H366 (1) | |
Text
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ff o,, UNITED STATES 8 .G%/ h
. n NUCLEAR REGULATORY COMMISSION
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%, g,g KING OF PRUSSIA, PENNSYLVANI A 19406 November 1,1984 Francis J. Bradley, Ph.D.
Principal Radiophysicist Radiological Health Unit New York State Department of Labor 2 World Trade Center New York, New York 10047
Dear Dr. Bradley:
During our review of the New York State Department of Labor Agreement Materials Program, we reviewed the Department's file for EAD Metallurgical, Inc. Based on the review of records in this file, we cannot conclude that EAD liquid dis-charges met the applicable New York criteria for discharges to sanitary sewer systems.
In this regard, I have attached for your information copies of internal NRC correspondence that provide the details and reasons for our conclusion. The results of our file review were discussed with you at the conclusion of our review on August 24, 1984, and in further detail with you on September 11, 1984.
It was suggested to you that the various State organizations involved in the EAD case take the opportunity to review the Department's EAD file, if they had not already done so.
I am providing these materials to you for ycur information and whatever action you believe is appropriate. No formal response to this letter is needed although we would appreciate knowing if you have reached a similar or different conclusion.
If you have any questions or if I may be of further assistance, please call me on (215) 337-5246.
Sincerely, W
sP 061h 210 PDR Paul H. Lohaus W DONO State Liaison Officer
Enclosure:
As Stated cc: (w/ Encl.)
W. Stasiuk K. Rimawi P. Merges bj
, / "%4 UNITED STATES t NUCLEAR REGULATORY COMMtsSION f
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WASHINGTON, D.C. 20655
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NOTE FOR: Paul Lohaus, Region 1 4 COR,RESPONDENCE RE DISCHARGES TO SANITARY SEWERS Enclosed are copies of NY and NRC correspondence concerning discharges to sanitary sewer systems. I believe that you may have some of them.
- Relative to EAD's discharges, I wish to iterate my views: Based on the review of the NYDOL EAD file including Kelly's inspection reports, I could not conclude that EAD discharges met the applicable New York criteria for discharges to the sanitary sewer system. There are, instead, strong suggestions that this was not the case.
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Enclosure:
As stated cc: R. Woodruff, RII, w/ encl.
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%,;,';./ . JG 17 it?4 MEMORANDUM FOR:
Donald A. Nussbaumer, Assistant Director State Agreements Program Office of State Programs FROM:
William A. Mills, Chief Health Effects Branch Division of Radiation Programs and Earth Sciences Office of Nuclear Regulatory Research
SUBJECT:
REQUEST TO REVIEW CURRENT REGut.ATIONS GOVERNING DISCH TO SANITARY SEWERS ,
s I appreciate your memorandum of August 1, 1984 which requested further reevaluation of our limits for disposal of radioactive wastes via sanitary sewers. We are aware that processed sewer sludge has been suggested for use as fertilizer and that there has been concern over resultant heavy metal buildup in the soil. The two cases that are enclosed with your request document problems with contamination of sewer treatment plants and sludge and indicate that accumulation can occur with radioactive materials.
One concern with the current Part 20 is that 520.303 pennits the concentration values listed in Appendix B, Table I, Column 2, to be used as limits for release into sanitary sewerage. The Table I values were calculated to result in 5 rems / year, or equivalent doses to specific organs, if a " reference man" used water at the specified concentration as the sole source of intake of fluids. The Table I values are approximately 30 times higher than values in Table II applicable to release in effluents to unrestricted areas (120.106).
In view of this concern, the provisions applicable to release to sanitary sewerage in the proposed revision to Part 20 include a number of modifications.
The concentration limits, specified in Table 3 of the new Appendix B, were calculated to result in 0.5 rem / year conunitted effective dose equivalent to a reference man, again with the very conservative assumption that sewerage was the only source of fluids. ,The tenn "dispersible" would be removed such that radioactive materials released to sanitary sewerage must be "readily soluble" in water.
While these proposed changes may not totally resolve such problems I feel that The they are in the regulatory direction requested by the correspondents.
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2 actions taken by the State of Tennessee appear to be compatiable with proposed changes.
As to the suggested evaluation of " reconcentration" processes that may be involved with modern sewerage treatment technology,and potential exposure pathways from materials present in sewage, we will keep this suggestion in mind but unfortunately we do not have resources available for such an evaluation in the near future. ,
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- o$ e AWillia'm A. Mills, Chief Health Effects Branch Division of Radiation Programs and Earth Sciences Office of Nuclear Regulatory Research I
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e DISTRIBUTION FCUF 160 BSinger RGPage NMSS R/F LCRouse FC Central File GATerry REC.iningham CEMacDonald LARoche Regional Administrators VLMiller LHigginbotham, WM DANussbaumer.- ggg 1 7 1934 FCUF R/F MEMORANDUM FOR:
Leonard I. Cobb, Chief Safeguards and Materials Program Branch, IE FROM:
R. G. Page, Chief Uranium Fuel Licensing Branch
SUBJECT:
DISCHARGES INTO SANITARY SEWERAGE SYSTEMS UNDER 10 CFR 20.303 Two occurrences of reconcentration of radioactive materials in the sanitary sewerage systaus have come to our attention, Enclosed or.e in Tonawanda, are reports describing New theYork and the other in Oak Ridge, Tennessee.We believe the two incidents may have occurred as two incidents.
disposal of substances not "readily soluble or dispersible in water" as .
required by Section 20.203 of 10 CFR 20.
We suggest that an IE Bulletin be issued to call attention to materials discharged into sanitary sewerage systems are soluble or dispersible in water to the extent necessary.to prevent reconcentration in the sewerage system. The bulletin should explain that 'a dispersed system is one characterize by "no aggiameration of its constituent particles" under the conditions encountered in the sewerage system. .
For example, Attention could be directed to some possible misinterpretations.
liquid scintillation media are generally not *readily soluble or dispersible" in water.
Ash may or may not be "readily dispersible*,Licensees depending whoondischarge its degree of commiinution and tendency to agglomeration.
materials in accordance with 10 CFR 20.303 have a burden to demonstra the materials are indeed readily soluble or dispersible, e.g., by filtration
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before discharge or some other means.
Enclosed for your information ,is a moorandum that we have sent to RES requestin that they consider a rule change to delete Action onthe ourters *or dispersible" proposal will undoubtedly from the provisions of 10 CFR 20.302.Meanwhile, we believe an IE Bulletin should be require many months of study. issued at any early date calling attention to th that all substances that they place into sanitary sewerage systems are readily soluble or dispersible as discussed above.
1 Dr. Lidia Roche' is our point of contact on this matter.
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RECunningham FC Central File REPage Regignal Administrators gg GATerry DAT.ussbaumer BS;nger LCRouse LARoche LHigginbotham, WM CEMacDonald VLM111er FCUF R/F NMSS R/F Karl Goller, Director MEMORANDUM FOR:
Division of Facility Operations, RES Richard E. Cunningham, Director FROM:
Division of Fuel Cycle and Material Safety
SUBJECT:
DISCHARGES OF RADI0 ACTIVE MATERIALS INTO SEWERAGE SYSTEMS UNDER 10 CFR 20.303 Two occurrences of reconcentration of radioactive materials in sanitary One that occurred in Tonawanda.
sewerage systems have come to our attention.
New York, was described in Donald A. Mussbaumer's memorandum of August 1,19 to you.
Inforuation concerning the second occurrence is enclosed.
We believe the incidents may have occurred because the materials were not In "readily soluble or dispersible in water" as required by 10 CFR 20.303.
any event, we believe the "dispersible" provisions of 10 CFR 20.303 are particularly troublesome and recouniend that RES censide sanitary systen.
sewerage system that may reconcentrate after place proposed rulemaking would have on licensee operations.
The tem "or dispersible" probably has caused introduction of substances into sanitary sewerage systems that do not qualify as readily dispersible, such as liquid scintillation media and ash. Ash is a special case which may or may not be "readily dispersible", depending on its degree of comminution and tendency We believe that licensees under the provisions of 10 CFR l to aggiameration.20.303 should not be permitted to dispose of any substances if th l removed by filtration. .
Dr. Lidia Roche' is our point of contact on this satter. ,
Original signed 6 Richard E. Cunningh Richard E. Cunningham, Director Division of Fuel Cycle and Material Safety, MMSS
Enclosure:
As stated i
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- .. e gd OFFICE TATE OF NEW YORK OF PUBLIC HEALTH
)EPARTMENT OF HEALTH e AL&ANY N.Y.12237 oRNING TOWER e THE GOVERNOR NELSON A. MODEFELLEM EMPtRE#ASTATE PLAZA ' " 'O ' "
AVID AxEut00. M.D C- -
WAL&AM F LEAVY Eammene asuary Ormever June 25, 1984 Mr. Paul Ichaus NPC Begion I 631 Park Avenue 19406 King of Prus ia, PN 7 %
Dear Mr. /
se faus:
Please find at+=r-had a copy of a letter fran Sen:y m ntal B. Willie.s, Conservation Nissioner, New York State Depar=nent4 of Envi (DEC) , addW to David Axelrod, W nsioner, New York State Department of Bealth (ICE) , in which a Imp is made frantoareview the -
cm. H. regulations govern 2ng dianharges to sanitary sewersAs you public health y s ;+rdve. sanitary sgwer syste in 'Danawanda, 'Ibe dis- Ne up to 750 - 190 pCi/g in ash at the sewage treatmmt plant.
charges may have been made in accardance with the existing regula limits in both State and P3n1==v Pegulatory Cattnission's regulations.
In view of We agree with DEC that such an evaluation is paadaM. !
nedern sewage treatment technology, one can no longer assute that te r a ricn of all r= din =rtive ma*asewer systen will be em=4d-Wy w,
for
'me re-evaluation needs to take 2nto ac: cunt the staitia r+ w - a ninn of the radioactivity in the 51= h or ash .wetionthat areThe of h generated in -dam sewage treatment plants.
r=dieivity in sludge and the incineration dw of the the current maxinnan pam4-=4hia ww.%.Hnn t=hla= ncr idin allo the di=-harge of one curie per year regardless of the character
'me fact that the dierhage is limited to s* es of the material ralamaad. 0.e in water does not &
- =*-Hals raaM1y soluble or disperil: sufficient to ixevent its situation. W In view of the above, NRC is requested to re-evalu ons M,me exenption of patient wer.a shculd also be part o.
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the eraluation since the incineration of sludge which may correain
- 1.31 results in exposure pat! ways that we do rot believe were pre- '
viously considered.
Yocr assistance in this review is appreciated. Please let me kncw if you need additicmal information.
Sirm. rely, .
E Earim Rimawi, Ph.D.
Director Barasu of Envim m Jal Radiation b A ion Attsac Itlent ec: G. Wayne Kerr Dr. Paul Me9 ges .
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Dear Comissioner ,
s.w' rod:
The Department of Environmental Conservation (DEC) is cresently engaged in efforts to characterize the Americium-2a1 contamination problem causec by EAD t'etallurgical in Tonawanda, N.Y. During CCC's initial evaluatior: o# tns problem a question has been raised concerning the adecuacy ofFor certain examoie,
.applicaole touclear R?gulatory Com..ission and DEC standercs.
10 CFR 20.303 and Part 380.5 both allow the sewer discr.arge of one curie per-year of any radionuclide. However, the ccdes do not ca.e the icoor ant w
distinction between the sewer discharge cf Tritium which nas a low potential for environmental and health impacts, and a similar ni, charge of a transuranic such as Americium-241 which has a much greater potential for harm.
First, they no not We see two.other problems with the current standards.
account for the possibility that certain radienuclides will be rc:oncentrated-
'by the sewage treatment processes and end up being incinerated er otherwise disposed of in a manner not consistent with environme'nt:lly desirable levels.
Seccnd, existing standards do not address the cumulative impacts of a series of radiological discharges of relatively long half-life radionuclidos, to a single sewer system.
In view of the Tonawanda problems, it is recuested th?.: the Depcrtment of Health review regulations governing discharges to sanitary sewers (6 i;YC*>.R Part ~380.5) from a public health perspective. If ycur Departe:ent determines that revision is necessary in order to provide protcction of the public from radiological discharges to sanitary sewers, please advise me as soon as possible. As you cre aware, there are many permittcd discharges of radioactive wastes to the sanitary sewers in this Statc. If exist'.ng stancards do not adequately cover public health objectives, DEC may need to take prompt action to avoid future situaticns such as that enccuntered in
. Tonadanda, N.Y.
Si ncereiy,
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Henry G. riilliams The Honorable David Axelrod Contr.i ss:cner New York State Department of Health Tower Building
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(b) A person must file an amolication for a license to receive racio- -
active waste from etner persons for oisposal at a lano cismosal facility unoer Part 51 of this enanter or at a geologic repository uncer Part 60 of this chacter.
5 20.1003 Discosal bv release into sanitarv sewe-ace.
(a) A licensee may disenarge licensac material into sanitary sewer-age if each of the following conditions is satisfied.
(1) The material is readily soluble in water.
(2) The quantity of licensed or other radioactive material that the licensee releases into the sewer in one month divicec by the average monthly volume of water released into the sewer by the licensee coes not exceed tne concentration listed in Table 3 of Appencix B of this part.
(3) If more than one radionuclide is released, the following conci- .
tions must also be satisfied.
(i) The licensee shall determine the fraction obtained by dividing ne actual monthly average concentrations of each radionuclide released by the licensee into the sewer by tne monthly average concentration of the radionuclide listed in Table 3 of Appendix B. '
(ii) The sum of the fractions for each radionue,lide required by paragraph (a)(3)(i) of this section does not exceed unity.
(4) The gross quantity of licensed and other radioactive material that the licensee releases into the sanitary sewerage system in a year i
i l
does not exceed 5 curies of hydrogen-3,1 curie of carcon-la, and 1 curie l of all other radioactive materials.
l (b) d$creta from individuals undergoing medical diagnosis or therapy with radioactive material shall be exempt from any limitations contained in paragraph (a) of this section.
5 20.1004 Treatment or dismosal bv incineration.
A. licenses may trtat er disposa -f licenseo material by incineration only in the amounts and forms specified in S 20.1005, or as specifically ttoroved by the Co=cissior. pursuant ti.I 20.1000, and within the cor.-
straints in 55 20.301 and 20.303.
122 Enclosure 1
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NUCLEAR REGULATORY COMMisslON S
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ATLANTA. GEOnGIA 30303 _
Richard E. Cunningham, Director MEMORANDUM FOR:
Division of Fuel Cycle and Materials Safety _3 A8: l0 Office of Nuclear Materials Safety and Safeguards -
FROM:
J. Philip Stohr, Director Y Division of Radiation Safety and Safeguards w
SUBJECT:
POTENTIAL FOR CO-60 RECONCENTRATION IN MUNICIPAL SLUDGE (PNO-II-84-24, 24A AND 248, (3/27/84, 3/29/84, AND 4/4/84))
Recent detection of significant Co-60 and Cs-137 contamination in Oak Ridge, Tennessee, municipal sludge by ORAU has prompted Tennessee officials to trace its apparent origin to Quadrex, Inc., a licensee engaged in decontamination and refurbishment of commercial nuclear fuel storage racks and associated apparatus.
Quadrex, Inc., is apparently occasionally discharging a few thousand gallons per day of primarily Co-60 at MPC (66-110 dpm/mi depending on solubility), into a .
municipal sewage system that processes 4 to 5 million gallons per day.
ORAU recently found elevated readings at the treatment plant outfall during a routine uranium survey, and the Co-60 sludge is being used to fertilize a USDOE background now exhibits 2 to 3 times reforestation area that
(- 10gR/hr) radiation levels. The sewer line between Quadrex andORAU the has treatment plant also exhibits significant dose rates and contamination.
completed a preliminary pathway and external dose analysis, apparently indicatirg no reason for immediate concern, but reserving judgment for the long-terin implications of any continued discharges. .
i It appears that the Co-60 discharges, presumably at MPC (~ 100,000 dpe/ liter),
have reconcentrated (20,000-200,000 dpm/Kg) in the sludge solids, even though l
they were perhaps only 0.1% of the treatment plant influent. Quadrex has now
' installed improved filtration, an ion exchange bed, and has been limited by Tennessee officials to discharges under the equivalent of 10 CFR 20.106 rather than 10 CFR 20.303 rules. Hopefully, this will prevent a recurrence.
Soil decontamination criteria for Co-60 in soil (Memo, R. G. Page, 10/.17/83) indicates that large areas should not exraed 10v R/hr, or about twice background in many areas. The Oak Ridge sludge appears to have, in some areas, exceeded this criteria.
We recommend that the NMSS/LLWB revitw this matter with ORAU and OSP to de whether the above circumstances may rave generic implications for other $20.303 sewerage disposals. Your . views on the applicability of 520.302(a) to municipal sludge would also be appreciated, even snough the radwaste was properly dis-charged under 520.106 or $20.303.
CONTACT:
John-Potter 242-5571 O m t- I th (h Wn mgot yIu g f-
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.,*$ k NUCLEAR REGULATORY COMMisslON W ASHINGTON. D. C. 20555 s, . ,
- ~~ ocT 1 1 1984 Ref: SA/J0L NOTE FOR: Paul Lohaus EAD SANITARY SEWER SYSTEM DISCHARGES On September 4,1984 I indicated to you that 1 could not conclude that EAD discharges to the sanitary sewer system (SSS) met the applicable criteria for such discharges based on the review of New York Department of Labor (NYDL) files and that there are strong suggestions in the files that they did not. The following set out my reasons for those conclusions.
The primary NYDL sources of information on EAD SSS 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 EAD SSS
' discharges (month and date not noted)
SSS discharges in New York are governed by the NY Department of L Environmental Conservation (NYDEC) Part 380. Industrial Code Rule 38.23 and State Sanitary Code 16.8 (c) also provide regulatory guidance.
EAD did not possess a NYDEC permit for liquid effluents. Therefore the applicable regulatory criteria for SSS discharges of Am-241 were the same as for NRC licensees (See 10 CFR 20.303):
l l 1. The material must be "readily soluble or dispersible in water"
- 2. The dail quantity discharged does not exceed the larger of the o owing:
(a) that quantity which, if diluted by the average quantity of sewerage released into the SSS in any day, would result in an average concentration equal to the MPC in Col. 2 of "able I of Appendix B of Part 20.
E (b) 10X the quantity set fort h in Appendix C of Part 20 or 10 x 0.01uci or 0.luCi.
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Attachment Quant 1.y Criteria for Discharging Radioactive Materials to Sanitary Sewer Systems Example:
Isotope: Co-60 Daily Sewage Volume Average 5000 gallons Monthly Sewage Volume Average: 152,000 gallons Daily: 20.303(b)(1) or (b)(2) which ever is larger.
20.303(b)(1): 1 x 10-3uci x 5 x 103 gal x 1 x 10 3,3 ml 0.264 gal T
=18.8 x 103 uti or 18.8 mci 20.303(b)(2): 10 x luci or 10 uti The daily limit is the larger of the two or 18.8 mci Monthly: 20.303(c): 1 x 10-3uci x 1.52 x 105 gal x 1 3
x 10 m1 ml .264 gal 1-
=5.76 x 105 uci or 576 mci Annual: 20.303(d): 1 Ci (1,000mC1)
A discharge of sewage contaminatedit the MPC for 200 workdays in a year would result in exceeding the annual limit:
18.8 mci x 200 days = 3,780 mci vs. 1,000 mci.
day If this licensee produced records only showing that the SSS discharges
! did not exceed the Schedule 1 MPC, compliance with all parts of 10 CFR l Part 20.303 was not demonstrated.
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- 3. The monthly quantity discharged does not exceed that quantity which, if diluted by the average quantity of sewage released into the SSS in any day, would result in an average concentration equal to the MPC in Col. 2 of Table I of Appendix B of Part 20.
and
- 4. The annual quantity discharged does not exceed 1 Ci.
Thus there are four criteria to be met by the licensee:
o the material must be readily soluble -or dispersible in water o there is a daily quantity limit o there is a monthly quantity limit o there is an annual quantity limit Some licensees, in an attempt to demonstrate compliance with daily and monthly limits, calculgte the concentration in the sewage discharge and
- - compare it to the MPC. The assertion is that if the conce within the MPC, then the criteria of 10 CFR 20.303 are met.pgations are In the NYDL files, the available data cover'ing SSS discharges for the years 1977-80 were yearly average concentrations and annual totals:
Year Yearly Average Conc. , uCi/ml Total Quantity, mci 1977 0.57x10~4 0.35 1978 0.97x10-4 31.7 1979 2.7x10-4 85.5 1980 1.5x10-4 40.2 From these data, the only quantity criterion than can be said to have been met by EAD for these years is criterion 4.
For the years, 1981-83, the available data appeared to be fragmentary.
In May,1983. EAD started action to transfer their operation to Mexico.
lWhen utilizing the sewage volume for making this calculation, there must be a substantive basis for the value for the volume, e.g. a sewer or water bill.
2 Regarding the daily discharge criterion, the underlying assumption is that the concentration multiplied by the SSS discharge volume will result in a quantity greater than criterion 2(b) and therefore 2(a) applies.
3 This assertion is tenuous. Given large enough volumes of sewage, it is possible for repeated daily sewer discharges containing MPC concentrations to result in an annual dir. charge exceeding 1 Ci. See
- attachment for an example.
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More critical to the evaluation of EAD SSS discharge data is the matter of whether or not criterion 1 was met: that the material was "readily
- soluble or dispersible in water." In his 1977 inspection report, the NYDL inspector recorded his concern over the solubility of the primary material being discharged, americium oxide. He went on to note that Code 38 says it must be dispersible, adding "(it better be!)."
Americium oxide is indeed to be considered insoluble and there is no information in the NYDL files indicating EAD demonstrated that t americiumbeingdischargedwas,atleast,"readilydispersible,"ge Therefore, one cannot conclude, from examination of NYDL EAD files, that criterion 1 was met.
These are further reasons to doubt EAD's compliance with the criteria.
In 1977, the NYDL inspector cited EAD for not having any records of the counting efficiencies used except for the last three discharges. (The inspector, incidently, did a comendable job in digging into the licensee's data to this extent). Further the inspector reported that on checking discharge calculations, discrepgncies were found, although the corrected values did not exceed the MPC.
The 1981 report adds more doubt about the validity of EAD's SSS discharge data. Problems with calculations of volumes of discharges were noted. The inspector reports observing sampling of the tank and notes "no stirring of the mixture was done," thus raising a question about how representative the sample was (an especially significant, item keeping in mind that the americium is in insoluble form). The inspector goes on to record:
o "I feel 'skitish' about the waste water," and o "Ican'thelpbutthinkthatthewatgrreleasedcould conceivably be completely ' fudged'."
4 In infomal discussions held on September 14, 1984 with regional health physicists, none indicated that they were aware of guidance on detemining dispersibility and at least one expressed doubt that americium oxide could be shown to be "readily dispersible." Reference to " Standard Methods for the Examination of Water and Wastewater,"
particularly the tests to determine residues, might provide a rational basis for developing guidance.
5 There is some question over which value for 241 Am in Col. 2 of Table 1 of Appendix B should be used, soluble or insoluble? The material is obviously not soluble but, given the content and intent of the requirement for the discharged material to be readily soluble or dispersible, is the use of the higher MPC (for insoluble) appropriate?
A canvas of regional health physicists on September 14, 1984 disclosed that there is no guidance and there was no consensus developed on which MPC to use.
6 The 1979 and 1981 inspections disclosed numerous violations including for example, failures to make certain surveys and failure to take outside air and soil samples. Notices of violations were issued by the inspector after each' inspection.
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There were no records in the NYDL EAD files indicating that the 1 inspector's concerns were absolved. In my discussion with Dr. Bradley
- on August 24, 1984 on the results of my review of the EAD file, I specifically mentioned the inspectors' concerns. I was offered no information that they had ever been addressed. I understand that in a ,
subsequent telephone conversation you had with the inspector, he stated 1
he received no feedback from NYDL management over these concerns.
Finally, the original license application contains building plans including of the drain system. Floor drains, and drains from the washer, sinks, change room sinks and shower, all in the controlled area, drain to the sump area (where the effluents were held in tanks). The water closet drains in the controlled area, however, join other water closet and sink drains in the uncontrolled area which connected directly
- to the SSS. Absent information to the contrary, this would constitute an unmonitored effluent path from the EAD controlled area. The license application did not contain detailed procedures for ensuring representative sampling or for sample analysis of liquid effluent sampling.
In summary:
o NYDL files do not contain infomation that can pemit a detemination that EAD met all the criteria applicable to pemissible quantities of radioactive materials discharged to sanitary sewer systems, o There is no infomation' demonstrating that the americium discharged to the sanitary sewage system was "readily soluble
. or dispersible," and o Observations by and concerns expressed by the NYDL inspector throw doubt upon the validity of the available data.
1 The foregoing applies to the period when EAD was in operation. The liquid effluent tanks and filters were reportedly removed in the Spring of 1983 and subsequent decontamination activities progressed with work waters discharged directly to the SSS according to information we were
- given by ENSA staff during out visit to EAD on August 15, 1984 We were also infomed during that visit that no records of analyses existed for these discharges.
Thus, I cannot conclude that EAD discharges met the applicable New York criteria for SSS discharges. There are strong suggestions, instead, that this was not the case.
Joel enau 4
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