ML20237G229

Forwards Branch Technical Position on Disposal or Onsite Storage of Thorium or U Wastes from Past Operations,Per 870623 Meeting.Nrc Prepared to Respond to Battelle Hot Cell Trust Funds Upon Receipt of Request

ML20237G229
Person / Time
Site:	07000008
Issue date:	08/11/1987
From:	Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Langsam M ENERGY, DEPT. OF
References
NUDOCS 8708130367
Download: ML20237G229 (1)

Text

1 AUG 1.11987 5 Docket No. 70.-8

.Mr. Martin A. Langsam, Chief Acquisition & Assistance Operations Office U.S. Department of Energy Chicago Operations Office 9800 South Cass Avenue Argonne, Illinois 60439

Dear Mr. Langsam:

The June 23, 1987, meeting among representatives of the Department of Energy (DOE),

the Nuclear Regulatory Commission (NRC) and Battelle was most useful to us in airing some issues of common interest concerning the planned decontamination and decommissioning (D&D) of Battelle's Columbus Laboratories facilities. At the meeting, Mr. Loysen agreed to send you a copy of our Branch Technical Position (BTP) on Disposal or Onsite Storage of Thorium or Uranium Wastes from Past Operations and other applicable guidance that should be referenced in the Battelle contract modification for D&D work. The BTP is enclosed. We have used this document for the past 6 years as guidance in considering applications for disposal pursuint to 10 CFR Part 20.302, and we expect to continue to use it in the foreseeable future. The BTP does not address the disposition of soil contaminated with plutonium or other transuranic elements. However, we have used a value of about 30 pCi/gm for Pu-238, Pu-239, and Am-241 in soil in consideration of meeting the equivalent of Option 2 of the BTP. We believe that such a value would be appropriate in the case of disposal of transuranic compounds in soil at Battelle's West Jefferson site.

One of the issues that was discussed at the July 24 meeting involved NRC action on release and use of funds in Batte11e's Hot Cell Trust Funds. We are prepared to respond to Battelle or the trustee on this issue upon receipt of a recuest from Battelle. Following this action, we shall respond to your letter of June 12, 1987, regardin fulfillment of DOE and NRC responsibilities for D&D of the Columbus Laboratories facilities.

Sincerely, Original Signed by i

Leland C. Rouse, Chief Fuel Cycle Safety ur gh . g '

Division of Indust dnd d3 VGIBUm -

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7590-01 NUCLEAR REGULATORY COMMISSION DISPOSAL. OR ONSITE STORAGE OF THORIUM OR URANIUM WASTES FROM PAST OPERATIONS AGENCY: Nuclear Regulatory Commission (NRC) _,

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ACTION: Discussion of Options for NRC Approval of Applications for f i

Disposal or Onsite Storage of Thorium or Uranium Wastes -

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Interim Use and Public Comment

SUMMARY

This notice discusses five options for NRC approval of disposal or onsite storage of thorium or uranium wastes from past nuclear operations.  ;

i The options are contained in a Branch Technical Position for administration f

by the Uranium Fuel Licensing Branch, Division of Fuel Cycle and Material i l

Safety, Office of Nuclear Material' Safety and Safeguards.

l DATES:

Comments on the options for disposal or onsite storage of thorium or uranium are encouraged. Such comments will be considered in any i subsequent revision of the Branch Technical Position. Comments are due l

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Note: Comments receiV'ed after the expiration date will be considered if it is practical to do so, but assurance of consid-I eration cannot be given except as to comments filed on or before that date.

FOR ADDITIONAL INFORMATION CONTACT: Ralph G. Page, Chief, Uranium Fuel Licensing Branch, Division of Fuel Cycle and Material Safety. Office of Nuclear Material Safety and Safeguards, Washington, D.C. 20S55, telephone 301-427-4309.

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SUPPLEMENTARY INFORMATION:

1. Introduction

- Some of the sites fonnerly used for processing thorium and 1

uranium are known today to be contaminated with residual e ,

radioactive materials. Some are currently covered by NRC licenses. Others were once licensed, but the licenses to possess and use material have expired. In many cases, the total amount of contaminated soil is large, but the activity concentrations of radioactive materials are believed sufficiently f I

low to justify their disposal on privately owned lands or l storage onsite rather than their transport to a licensed radioactive materials disposal (commercial) site. In many instances packaging and transporting these wastes to a licensed disposal site would be too costly and not justified from the standpoints of risk to the public health or cost-benefit.

Furthermore, because of the total volume of these wartes, limit )d i

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commercial waste disposal capacity, and restrictions placed on receipt f long-lived wastes at commercial sites, it is not presently feasibie to dispose of these wastes at commercial low-level waste disposal sites.

Effective January 28, 1981, NRC regulations in 10 CFR 20,

" Standards for Protection Against Radiation", were amended (45 FR 71761-71762) to delete Section 20.304 which provided general authority for disposal of radioactive materials by burial in soil. Under the amended ' regulations, licensees 1

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radioactive materials in this manner under the provisions of 10 CFR 20.302. A case-by-case review was believed needed to I

assure that burial of radioactive wastes would not present an ;

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,, unreasonable health hazard at some future date.

The deleted provisions of Section 20.304 previously permitted burial of up to 100 mil 11 curies of thorium or natural uranium at any one time, with a yearly limitation of 12 burials for each type of material at each site. The only disposal standards specified were (1) burial at a minimum depth of four feet, and (2) successive burials separated by at least six feet. Thus a total of 1.2 curies of th'ese materials were permitted to be disposed of each year by burial in a 12 foot by 18 foot or larger plot of ground.

Under the amended regulations, it is incumbent on an applicant who wants to bury radioactive wastes to demonstrate that local land burial is preferable to other -disposal alternatives. The evaluation of the application takes into account the following information:  ;

- Types and quantities of material to be buried

- Packaging of waste i

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- Burial location

- Characteristics of burial site

- Depth of burial _ . . . .

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- Access restrictions to disposal site

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' - Radiation safety procedures during disposa1' operations se

- Recordkeeping

- Local burial restrictions, if any For applications involving disposal of soils contaminated with low level concentrations of thorium and cranium (other than concentrations not exceeding EPA cleanup standards), the matters of' principal importance are:

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- Concentrations of thorium and uranium (either in secular equilibrium with their daughters or without daughters present)

- Volume of contaminated soil

- Costs for offsite and ons1te disposal ,,

- Availability of offsite burial space _

- Disposal . site characteristics

- Depth of burial and accessibility of buried wastes

- State and local government views  :

11. Branch Technical Position  !

There are five acceptable options for disposal or onsite storage of thorium and uranium contaminated wastes. Applications for disposal or storage will be approved if.the guidelines discussed under any option are met. Applications for other methods of + .

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1 disposal may be submitted and these will be evaluated on their os merits.

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1. Otr.posal of acceptably low coimntrations -(which mest EPA

% cleanup standards) of natural thorium with daughters in secular equilibrium, depleted or enriched . uranium, and uranium ores with daughters in secular equilibrium with no ' .

restriction on burial method.

Under this option, the concentrations of' natural thorium and depleted or enriched uranium wastes are set sufficiently low that no member of the public is expected to receive a radiation dose comitment from the disposed materials .in

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excess of 1 millirad per year to the lung or 3 millirads  ;

per year to the bone from inhalation and ingestion, under any foreseeable use of the material or. property. These radiation dose guidelines were recommended by the

- Environmental Protection Agency (EPA) for protection against transuranium elements present in the environment as a result of upplanned contamination (42.FR 60956-60959F.

In addition, the concentrations'are sufficiently low so that no individual may receive an external dose in excess of 10 microroentgens per hour above background. This is compatible with guidelines EPA proposed as cleanup standards for inactive uranium processing sites (46 FR 2556-2563).

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l For natural uranium ores having daughters in equilibrium, the concentration limit is equal to that set by the EPA

' (46 FR 2556-2563) for radium-226 (i.e., 5 pCi/gm including i i

background) and its decay products.

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.. The concentrations specified below are believed appropriate to apply. It is expected, however, that currently licensed I operations will be conducted in such a manner as to minimize the possibility of soil contamination and when such occurs 1 the contamination will be reduced to levels as low as reasonably achievable.

Concentration (pCi/gm)

Kind of Material ,

Natural thorium (Th-232 plus Th-228)ifalldaughtersare l 10 present and in equilibrium 35 Depleted Uranium _

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• Enriched Uranium '

10 Natural Uranium Ores (U-238 plus U-234) if all daughters are present and in equilibrium l

The analysis upon which the Branch Technical Position is based is available for inspection at the Commission's Public Document Room at 1717 H St. . . H.W. , Washington, D.C.

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1 The concentrations specified under this option may be compared with naturally occurring thorium and uranium ore

' concentrations of 1.3 pCi/gm in igneous rock and ura_nium I

concentrations of 120 pCi/gm in Florida phosphate rock

. ~s and 50-80 pCi/gm in Tennessee bituminous shale.

Concentration limits for natural thorium and natural uranium ore wastes containing daughters not at secular equilibrium can be calculated on a case-by-case basis using the applicable isotapic activities data.

2. Disposal of certain low concentrations of natural thorium with daughters in secular equilibrium and depleted or enriched uranium with no daughters present when buried under j

prescribed conditions with no subsequent land use restrictions and no continuing NRC licensing of the material.  ;

Under this option the concentrations of natural thorium and i

' uranium are set sufficiently low so that no member of the  ;

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j public will receive a radiation dose exceeding those discussed under option 1 when the wastes are buried in an approved manner i

absent intrusion into the burial grounds. This option will require establishing prescribed conditions for disposal in the license, such as depth and distribution of material, to I

minimize the likelihood of intrusion. Burial will be permitted only if it can be demonstrated that the buried materials will be' stabilized in place and not be transported away from _ the site.

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- 8-Acceptability of the site for disposal will depend on topographical, geological, hydrological and meteorological characteristics of the site. At a minimum, burial depth will be'at least four feet below the surface. In the event that

% l there is an intrusion into the burial ground, no member of e

the public will likely receive a dose in excess of 170 I millirems to a critical organ. An average dose not exceeding l l J l

170 millirems to the whole body for all members of a general population is recommended by international and national radiation expert bodies to limit population doses. With respect to limiting doses to individual body organs, the concentrations are sufficiently low that no individual will receive a dose in excess of 170 millirems to any organ from exposure to natural thorium, depleted uranium or enriched l '

uranium.

The average activity concentration of radioactive material that may be buried under this option.in the case of natural-thorium (Th-232 plus Th-228) is 50 pCi/gm, if all daughters are present.and in equilibrium; for enriched uranium it is 100 pCi/gm if the uranium is soluble and 250 pCi/gm if insoluble; for depleted uranium it is 100 pCi/gm if the uranium is soluble and 300 pCi/gm if insoluble. Natural uranium ores containing radium 226 and its daughters are not included under this option, because.of possible radon 222 emanations and resultant higher than acceptable exposure of individuals in private residences if houses were built over buried materials.

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3. Disposal of low concentrations-of natural uranium ores, with 1 j

all daughters in equilibrium, when buried under prescribed i conditions in areas zoned for industrial use and the_.

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recorded title documents are amended to state that the

% specified land contains buried radioactive materials and are conditioned in a manner acceptable under state law to impose, a covenant running with the land that the specified land may not be used for residential buiiding. (There is no continuing NRC licensing of the material.) l Disposal will be approved if the burial criteria outlined in i option 2 (including burial at a minimum of 4 feet) are met. .

I Depending upon local soil characteristics, burials at depths i j

greater than 4 feet may be required. .In order to assure protection against radon 222 releases (daughter in decay chain of uranium 238 and uranium 234), it is necessary that the recorded title documents be amended to state in the permanent land records that no residential building should be permitted over specified areas of land where natural uranium ore residues (U-238 plus U-234) in concentrations exceeding 10 pCi/gm has been buried. Industrial building is acceptable.so long as the concentration of buried material does not exceed 40 pCi/gm of uranium (i.e., Ra-226 shall not exceed 20 pCi/gm).

4. Disposal of land-use-limited concentrations of natural thorium or natural uranium with daughters in secular equilibrium and depleted or enriched uranium without daughters present when .

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buried under prescribed conditions in areas zoned for industrial use and the recorded title documents are amended to state that the land contains buried radioactive material and I

are conditioned in a manner acceptable under state law to

. sg impose a covenant running with land that the land (1) may not be excavated below stated depths ;in specified areas of land .

unless cleared by appropriate ' health authorities, (2) may not be used for residential or industrial structures over specified areas where radioactive materials in concentrations higher than specified in options 2 and 3 are buried, and (3) may not be used for agricultural purposes in the specified areas.

(There is no continuing NRC licensing of the disposal site.)

Under this option, conditions of burial will be such that no member of the public will receive radiation doses in excess of those discussed under option 1 absent intrusion into the burial ground. Criteria for disposal under these conditions 1

is predicated upon the assumption that intentional intrusion is less like}y to occur if a' warning is given in land documents of record not to excavate below burial depths in specified areas of land without cletrance by health authorities; not to construct residential or industrial building on the site; and not to use specified areas of land for agricultural purposes.

Because of this, we believe it appropriate to apply a maximum critical organ exposure limit of 500 millirems per year to thorium

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and uranium buried under this restriction instead of 170 millirems as used in options 2 and 3. In addition, any exposure to such materials is likely to be more transient than assumed I

(essentially continual exposure) under those options. These two a factors combine to increase the actisity concentration limits calculated under option 2 by about 10. Tros, the, average concentration that may be buried under this option for thorium l (Th-232 plus Th-228) is 500 pCi/gm if all daughters are present and in equilibrium; for enriched uranium it is 1000 pCi/gm if the uranium is soluble and 2500 pCi/gm if insoluble; and for depleted uranium it is 1000 pCi/gm if the uranium is soluble and 3000 pCi/gm if insoluble.

With respect to natural uranium with daughters present and in equilibrium, the concentration that may be buried under this option is 200 pCi/gm of U-238 plus U-234, i.e.,100 pCi/gm Ra-226. This concentration is based on a limited exposure of 2.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per day to limit the radon dose to less than 0.5 working level month (Wd4) which is equivalent to continuous exposure to 0.02 working level (WL). Depending upon local soil characteristics, burials at depths greater than 4 feet may be required.

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SUMMARY

OF MAXeIMUM CONCENTRATIONS PERMITTED UNDER DISPOSAL OPTIONS N Disposal Options a b c 4 d

Kind of Material l 2 3 j.

Natural Thorium (Th-232 + Th-228) 10 50 - 500 with daughters present and in equilibrium Natural Uranium (U-238 + U-234) 10 - 40 200 (

l with daughters present and in equilibrium Depleted Uranium o Soluble 35 100 -

1000 o Insoluble 35 300 - 3000 Enriched Uranium o Soluble 30 100 - 1000 o Insoluble 30 250 -

2500 a Based on EPA cleanup standards.

b Concentrations based on limiting individual doses to 170 mrem /yr.

c Concentration based on limiting equivalent exposure to 0.02 working level or less. ,

d Concentrations based on limiting individual doses to 500 mrem /yr and, in case of ne'. iral uranium, limiting exposure to 0.02 working -l l 1evel or less. j 1

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5. Storage of licensed concentrations of thorium and uranium onsite pending the availability of an appropriate. disposal site.

l N. When concentrations exceed those specified in option 4, long tenn disposal other than at a license disposal site will not normally be a viable option under the provisions of 10 CFR 20.302. In such cases, the thorium and uranium may be pennitted to be stored onsite under an NRC license until l a suitable method of disposal is found. License conditions

.will require that radiation doses not exceed those specified in 10 CFR Part 20 and be maintained as. low as reasonably achievable.

Before approving an application to dispose of thorium or uranium under options 2, 3, or 4, NRC will solicit the view of -

l appropriate State health officals within'the State in which the disposal would be made. -

Dated at Silver Spring, Maryland this/9%f day of O g ger , 1981.

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Richard E. Cunningh Director, Division of Fuel Cycle and Material' Safety I

Office of Nuclear Material Safety and Safeguards e

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l U S*NUCitAR RLcutAQRY j )j a selex 24 5454 C) C0gMtSMO,M '

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Mr. Leland G. Rouse, Chief Advanced Fuel and Spent Fuel Licensing Branch

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Division of Fuel Cycle and Material Safety CS man."sN?noy U.S. Nuclear Regulatory Commission y Washington, D.C. 20555 DOCKET CLEMy  ;

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SUBJECT:

DECONTAMINATION AND DECOMMISSIONING OF THE BATTELLE i MEMORIAL INSTITUTE'S COLUMBUS LABORATORIES NUCLEAR FACILI- i TIES UNDER THE DEPARTMENT OF ENERGY'S CONTRACT NO. W-7405-ENG-92 i

The Department of Energy (DOE) has phased out nuclear research performed for DOE and its predecessor agencies (ERDA, AEC, MED) by Battelle MemorialInstitute (BMI) at its Columbus Laboratories over a period of forty-three years under Contract No.

W-7405-ENG-92 (ENG-92 Contract). Coincidental with the phase out of this con-l tract, Battelle Columbus Division (BCD), the division of BMI having responsibility l l for administration of the contract, has elected to discontinue all experimental nuclear l l

materials research activities. )

As a result, some fifteen buildings or portions thereof will require decontamination and decommissioning (D&D) in onier to restore them for unrestricted use. ' DOE has accepted responsibility for the cleanup of the contamination of these buildings which resulted from DOE sponsored work. The cleanup activities will be conducted as the final task under Contract No. W-7405-ENG-92. The buildings have been accepted into DOE's Surplus Facilities Management Program (SFMP) as a D&D Major Project and, at the present time, are in Surveillance and Maintenance mode under this contract.

Some of the contaminated buildings have also been used for nuclear work performed .

by BCD under a Nuclear Regulatory Commission (NRC) license. The NRC-licensed ,

work accounts for approximately fix percent of the total work, based upon the total through-put of nuclear materials < taring the forty-three years. BCD will perform the D&D for DOE under the ENG-92 contract. Inasmuch as DOE D&D effort is impossible l to segregate from the commercia: effort, this action will simultaneously result in the D&D required for compliance with termination of the NRC license.

l BCD and DOE have had preliminary discussions regarding this dual authority and/or

responsibility. Since BCD is licer

ed by NRC, it is appropriate that NRC participate i in the resolution of the D&D proj ct in the discharge of its regulatory obligations and that BCD be responsible for me< ng all requirements associated with the termination of the NRC license.

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. 1 Mr. Leland G. Rouse 2 June 12,1987 BCD proposes, at the conclusion of the D&D, to perform a final radiological survey demonstrating that the facilities meet unrestricted use requirements as defined in NUREG 1.86, and then DOE would have an independent radiological verification certift-l cation survey performed to check the BCD results. This will assure that the unrestricted  ;

1 use requirements have been met. DOE will include in the contract modification for '

the D&D work language substantially as follows.  ;

"Upon completion of the D&D programmatic effort, DOE will certify that each facility meets the requirements of NRC's ' Guidelines for Decontamination of l

Facililles and Equipment Prior to Release for Unrestricted Use or Termination ,

of Licenses for Byproduct, Source, or Special Nuclear Material', d,ated July l 1982; the U.S. Atomic Energy Commission, Regulatory Guide 1.86, ' Termination i of Operating Licenses for Nuclear Reactors', dated June 1974; U.S. Department \

of Energy's ' Guidelines for Residual Radioactive Material at Formerly Utilized Sites Remedial Action Program and Remote Surplus Facilities Management l

. Program Sites (Revision 2)', dated March 1987; the proposed American National l Standarti ANSI N13.12 ' Control of Radioactive Surface Contamination on Materi- i l als, Equipment, and Facilities to be Released for Uncontrolled Use'; U.S. Depart-l ment of Energy, Oak Ridge Operations ' Radiological Guidelines for Application l

' l to DOE 2 Furmerly Utilized Sites Remedial Action Program'(ORO-831), dated March 1983; and U.S. Department of Energy, Oak Ridge Operations ' Pathways .

Analysis and Radiation Dose Estimates for Radioactive Residues at Formerly  ?

Utilized MED/AEC-Siles'(ORO-832), dated March 1983, and any other require-ments which may be applicable at the time of certification."

At this time we wish to follow-up on initial discussions you had with Mr. Harley Toy, of BCD, relative to a meeting of the interested parties. BCD and DOE suggest a meeting sometime during July to be held at DOE's Chicago Operations Office (CH) with attendees from NRC-Washington, DOE-Washington, NRC-Region HI, DOE-CH, and BCD.

We believe some of the issues relating to this D&D project which should be discussed at this meeting are:

a. The desirability for having one Government agency responsible for over- <

seeing the D&D effort and what is the role of the other agency. In this case, it seems appropriate for DOE to be responsible since DOE is ninety-four percent responsible for the D&D effort and must monitor the work which will be performed under contract to DOE.

b. Agreement on the standmits, criteria, etc., to which the D&D effort will be performed, to satisfy both Government agencies' requirements for unrestricted use.

c. Use of the funds in BCD A Ilot Cell Trust Funds, which were established for the D&D of the nuclear research facilities in West Jefferson, Ohio.

Along these lines, we feel that the interest of everyone concerned would best be served from a standpoint of cost, timc administrative effort, efficiency of accomplishing the D&D goals, etc., if NRC w id agree to a single-agency responsibility. In a similar BCD situation in the past, whic involved the D&D of its Plutonium Laboratory, also under the ENG-92 Contract, an igreement was reached whereby DOE exercised the J

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'1 l Mr. Leland G. Rouse 3 June 12,1987 .,

i responsibility for overseeing the entire project. The same or similar type arrangement {

would be most efficient for this D&D project. i 1

We hope that our request for a meeting would be amenable to you. If, however, you )

think these issues can be resolved by correspondence or telephone, we would certainly {

be glad to try. Should you desire to contact someone regattling this request, please l contact us on commercial numbers !!sted below, or Mr. William Murphie, Division of '

Facility and Site Decommissioning (DFSD), SFhfP, DOE-Washington, on commercial number (301) 353-5896.

Very truly yours, O= _

3 9 JUN 15198].

Jerome R. Bahlmann Martm A. Langsam, Chie General Counsel and Vice President Acquisition & Assistance Operations Office '

Battelle Columbus Division Chicago Operations Office (614) 424-7360 U.S. Department of Energy (312) 972-2136 JRB: MAL:cs i

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