ML20217H419
| ML20217H419 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/1997 |
| From: | Dennise Orlando NRC |
| To: | |
| References | |
| NUDOCS 9804290369 | |
| Download: ML20217H419 (6) | |
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4th Biennla! Mixed Waste Symposium Baltimore, Mar /mrd, August 18-21,1997 OVFRVIEW OF THE NRC'S TFI'HNICAI. PORITION ON THE DISPORITION OF CFRIIIM-137 CONTAMINATED FMIRRION CONTROI. DTIRT AND (YrHER INCIDENT RFI ATED MATERIAI.
l Dominick A. Orlando l U.S. Nuclear Regulatory Commission j Washington DC 20555 !
(301) 415-6749 ABSTRACT As the result of inadvertent meltings of cesium-137 ('"Cs) sources, several steel producers possess approximately 9,000 metric tons (10,000 tons) of emission control I
dust, most of which contains '"Cs concentrations ofless than 3.7 Becquerels / gram
! (Bq/g)'(100 picoeuries/ gram (pCi/g)). This material is typically being stored onsite l because of the lack of disposal options that a considered cost-effective by the steel companies. The Nuclear Regulatory Commission has developed a technical position l
that may be used to evaluate case-by-case requests to dispose of treated emission control dust contaminated with 8"Cs at hazardous waste disposal facilities. The position, which has been coordinated with the U.S. Environmental Protection Agency (EPA), provides a public health-protective, environmentally sound, and cost-effective disposal alternative for a large part of this material. Provisions of the technical position are that: the material results from the inadvertent melting of a sealed source; the concentration of '"Cs in the material does not exceed 4.8 Bq/g (130 pCi/gm) for packaged material or 3.7 Bq/g (100 pCilgm) for bulk material; the total activity of l "Cs in the hazardous waste disposal facility does not exceed 37 gigabequerel (1 l
Curie); the material is stabilized prior to transfer and; the disposal facility operator and the NRC are notified prior to the transfer of the mnterial.
l l Emission control (beghouse) dust and other incident-related materials (the term, " incident-related material," is frequently used in the technical position to refer to the total spectrum of '"Cs-contaminated materials resulting from an inadvertent melting event) contaminated with2 "Cs are currently being stored as mixed radioactive and hazardous waste at several steel company sites across the country. In current situations, most, but not all, of this material would be classified
! as mixed waste henuse it contains lead, cadmium, and chromium. The ""Cs contamination of i
this hazardous waste results from a series of three principal events: (1) the loss of control of a radioactive source by an NRC or an Agreement State licensee; (2) the inclusion of the source within the recycle metal scrap supply used by the steel producers; and (3) the inability to screen out the radioactive source as it progresses along the typical scrap collection-to-melt pathway.
Most of the current material is subject to joint regulation as mixed waste under the Resource Conservation and Remvery Act (RCRA) and the Atomic Energy Act of 1954, as amended, or the 5
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equivalent laws of Authorized States and Agreement States.
The disposal options for these materials, specifically the large volumes of material with the lower concentrations of '"Cs, have been limited because of their " mixed-waste" classification and the costs associated with the disposition of large volumes of mixed or radioactive waste.
I2mg-term solutions addressing the control and accountability of licensed radioactive sources are being considesed by NRC and Agreement States. In addition, various Federal and State regulatory authorities and the U.S. Department of Energy are currently considering solutions addressing the disposition of mixed wastes. Nevertheless, NRC believes that, pending decisions on improved l licensee accountability and the ultimate disposition of mixed waste, appropriate disposal of the l
existing inci: lent-related, mixed-waste material is preferable to indefinite onsite storage.
To address this issue NRC published a technical position in early 1997 that defines the l bases that the NRC staff would find w*puble fc authorizing a licensee, possessing '"Cs-contaminated emission control dust and other incident-related materials to transfer treated "Cs-contaminated material, below levels specified in the technical position, to a Subtitle C, RCRA-permitted hazardous waste disposal facility and not licensing the possession and disposal of these incident-related materials by the RCRA-permitted disposal facility. The technical position does
! not address disposal at a Subtitle D facility. Because of its radioactivity (i.e., '"Cs concentration levels), some of the incident-related material may not be suitable for disposal at a Subtitle C, RCRA-permitted dispossi facility. 'Ihis material may be disposed of at either a licensed low-level l radioactive waste disposal facility after appropriate treatment ofits hazardous constituents or at l a mixed-waste disposal facility, if applicable acceptance criteria are met.
Additional acceptance requirements, beyond those covered in the technical position may be established by: (1) an Agreement State; (2) the permit conditions or policies of the RCRA-permitted disposal facility; (3) the regulatory requirements of the RCRA disposal facility's l permitting agency; or (4) other authorized parties, including State and local governments. These requirements may be mare stringent than those covered in the technical position. The licensed entity transferring the '"Cs-contaminated incident-related materials must consult with these l parties, and obtain all =*===y approvals, in addition to those of NRC and/or appropriate Agreement States, for the transfers defined in the technical position. The conditions established in the position pertain to NRC staff and licensee actions. Therefore, in those instances where an Asc.;.: State is the sole regulatory authority for the radioactive material, the Agreement State has the option of usirig the technical position in reviewing requests for the disposal of the material.
NRC used the following criteria in developing the technical position: (1) any person at a Subtitle C, RCRA-permitted disposal facility involved with the receipt, movement, storage, or disposal of contaminated materials should not receive an exposure greater than 10 microsievert (pSv) (1 millirem (mrem)) per year (i.e., one-hundredth of the dose limit for individual members 2
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of the public as defined at 10 CFR 20.1301, above natural background levels *; (2) members of the gesteral public in the vicinity of storage or disposal facilities should not receive exposures and no individual member of the public should be likely to receive a dose greater than 10 uSv (1 mrem) per year above background as a result of any and all transfers and disposals of contaminated materials; (3) handling or processing of the contaminated materials, undertaken as a result ofits radioactivity, should not compromise the effectiveness of permitted hazardous waste disposal operations; (4) clean-up, collection, treatment, and packaging of contaminated materials must be accomplished by persons operating under a licensee's radiation protection program (note that the licensee can be the steel facility or the entity that treats the incident-related material, either on- or offsite); and (5) transportation of contaminated materials will be subject to U.S.
Department of Transportation (DOT) regulations and, as applicable, transportation of contaminated, hazardous materials must be performed by hazardous material employees, as defined in DOT regulations. Two disposal options are availiable for the material, depending on
'"Cs levels and whether the material is packaged or unpackaged.
For packaged waste, contaminated materials must be treated through stabilization to comply with all EPA and/or State waste treatment requirements for land disposal of regulated hazardous waste. The treatment operations must be undertaken by either the owner / operator of the EAF or foundry (licensed by NRC or appropriate Agreement State to possess, treat, and transfer '"Cs-contaminated, incident-related materials) or by an NRC- or Agreement State-licensed service mntractor (operating either on- or offsite). A licensee could be authorized by NRC or an Agreement State to transfer the treated incident-related materials to a Subtitle C, RCRA-permitted, disposal facility if:
(a) The '"Cs-contaminated emission control dust and other incident-related materials are the result of an inadvertent melting of a sealed source or device; (b) The emission control dust and other incident-related materials have been stabilized to meet requiremen a for land disposal of RCRA-regulated waste, and have been stored (if applicable) and transferred in compliance with a radiation protection program as specified at 10 CFR 20.1101; (c) The total '"Cs activity, contained in emission control dust and other incident-related materials to be transferred to a Subtitle C, RCRA-permitted, disposal facility, has been specifically s,pd by NRC or the appropriate Agreement State (s) and does not exceed the total activity amaaciatM with the inadvertent melting incident. Moreover, NRC or the appropriate Agreement State will maintain a public record of the total incident-related "Cs activity, received by the facility over its operating life, to ensure that the total disposed of '"Cs activity does not
- The use of t mese (10 pSv) has no signincance or precedential value as a health and safety soal. It was selected only for the purpose of analysis of the levels at which the referenced materials could be partitioned to allow the bulk of the masenal to be treasferred to unlicensed persons, it does not represent an NRC position on the seneric s -f M of dose levels. Such levels are established only by rule.
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exceed 37 GBq (1 Ci);
(d) The RCRA disposal facility operator has been nN!I.ed in writing of the impending transfer of the incident-related materials and has agreed in writing to receive and dispose cf the packaged maserials*;
(e) The licensee providing the radiation protection program required in paragraph (b),
notifies, in writing, the Commission or Agreement State (s) in which the transferor and transferee are located, of the impending transfer, at least 30 days before the transfer; (f) The an= hili =wi material has been packaged for transpottation and disposal in non-bulk steel packagings as defined in DOT regulations at 49 CFR 173.213. (Note that this is a condition catahlished under this technical position and is not a DOT requirement. Under DOT regulations, material with concentrations ofless than 74 Bq/g (2000pCi/g) is not considered radioactive);
(g) In any package, the emission control dust and other incident-related materials, that have been stabilized and packaged as defined in (b) and (f) above, contain pretreatment average concentrations of '"Cs that did not exceed 4.8 Bq/g (130 pCi/g) of material; and (h) The dose rate at 3.28 feet (1 meter) from the surface of any package containing stabilized waste does not exceed 0.20 Sv/hr (20 rem /hr), above background.
Unpackaged materials must also be treated through stabilization to comply with all EPA and State waste treatment requirements for land disposal of RCRA-regulated hazardous waste.
As with packaged materials, the treatment operations must be undertaken by either (i) the owner /opember of the EAP or foundry or a licensed service contractor. These licensees could be authorized to transfer the stabilized incident-related materials to a Subtitle C, RCRA-permitted, disposal facility if:
(a) 'Ihe '"Cs<xmtaminated emission control dust and other incident-selated materials are the result of an inadvertent melting of a sealed source or device; (b) The emission control dust and other incident-related materials have been stabilized to meet requirements for land disposal of RCRA-regulated waste, and have been stored (if applicable), and transferred in compliance with a radiation protection program as specified at 10
% NBC staff believes the contract between the licensed facility and the RCRA facility operator is an appropriate vehicio for counplyias with this provision, provided that the contract specifies the volume of waste, the radionuclide and its average canoestrasson in the waste is picoeuries per sram, the total assregated amount of r=d-etive matsnal la the skipeneet, the hazardous waste code of the waste. and the EPA identification number of the RCRA despanni imedsty receivias the waste. The NRC staff will evaluate requests for license amendments to transfer incident-related saaternal based upon the liceasse desmonstratins that the RCRA disposal facility operator has asreed to the transfer and has made provisecas to retain the information about the radioactive material in the waste, along with the infonnasson that is regaired to be retained by the RCRA facility operator under 40 CFR 263.22.
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CFR 20.1101; (c) The total '"Cs activity, contained in emission control dust and other incident-related materials to be transferred to a Subtitle C, RCRA-permitted, disposal facility, has been specifically approved by NRC or the appropriate Agreement State (s) and does not exceed the total activity associated with the inadvertent melting incident. Moreover, NRC or the appropriate Agreement State will maintain a public record of the total incident-related '"Cs activity, received by the facility over its operating life, to ensure that the total disposed of '"Cs activity does not exceed 37 GBq (ICi);
(d) The RCRA disposal facility operator has been notified in writing of the impending transfer of the incident-related materials and has agreed in writing to receive and dispose of these materials *
(c) The licensee providing the radiation protection program required in paragraph (b) notifies, in writing, the Commission or Agreement State (s) in which the transferor and transferee are located, of the impending transfer, at least 30 d ~s before the transfer; and (Note that conditions (a) through (ej are identical to those applicable to packaged disposal of treated waste)
(f) 'Ihe emission control dust and other incident-related materials, that have been stabilized as defined in (b) above, contain pretreatment average concentrations of '"Cs that did not exceed 3.7 Bq/g (100 pCi/g) of material.
'Ihe EAF or foundry licensed to pouess and transfer '"Cs-contaminated emission control dust, or a licensed service contractor, is authorized to transfer emission control dust and other incident-related materials as if they were not radioactive, provided that the '"Cs concentration within the emission control dust and other incident related materials is 0.074 Bq/g (2 pCi/g) of material or less. 'the !"Cs concentration may be determined by the licensee by direct or indirect (e.g., external radiation) measurements, and must be performed in accordance with an NRC- or Agreement State approved sampling program. 'Ihe sampling program must be sufficient to ensure that '"Cs contamination in the stabilized emission control dust and in other incident-related materials, on a package-average basis, is consistent with the concentration criteria in this technical l position. 'Ihe sampling program must provide assurance that the quantity of '"Cs in any package j does not exceed the product of the applicable concentration criterion times the net weight of contaminated material in a package.
If applimble, aggregation of '"Cs-contaminated emission control dust and other incident-
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related material, before stabilization treatment, is acceptable if performed in compliance with a radiation protection program, as described at 10 CFR 20.1101, and provided that aggregation involves the same characteristic or listed hazardous waste, the waste': must be amenable to and undergo the same appropriate treatment for landwiisposal restricted waste. In addition aggregation may not increase the overall total volume nor the radioactivity of the incident-related waste and the materials, when aggregated, are subjected to a sampling protocol that demonstrates compliance with '"Cs-concentration criteria on a package-average basis. The term package, as used here, refers to packages used by the licensee to transfer the rnaterial to the disposal facility, irrespective of whether this package is also the disposal container.
CONCLUSION As the result ofinadvertent meltings of cesium-137 ('"Cs) sources, several steel producers possess approximately 9,000 metric tons (10,000 tons) of emission control dust, most of which contains '"Cs concentrations of less than 3.7 Bq/g (100 pCi/g). This material is typically being stored onsite W- of the lack of disposal options that are considered cost-effective by the steel companies. 'Ihe Nuclear Regulatory Commission has developed a technical position that may be used to evaluate case-by-case requests to dispose of treated emission control dust contaminated with '"Cs at hazardous waste disposal facilities. The position provides a public health-protective, environmentally sound, and cost-effective disposal alternative for a large part of this material.
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