ML20149F674
| ML20149F674 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/1996 |
| From: | Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Floyd W NEW MEXICO, STATE OF |
| Shared Package | |
| ML20149F660 | List: |
| References | |
| NUDOCS 9707220265 | |
| Download: ML20149F674 (4) | |
Text
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UNITED STATES l,
I8' NUCLEAR REGULATORY COMMISSION 1
WAsN4NoToN. D.C. SB00HOM
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February 5,1996 i
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Mr. Wdliam M. Floyd, Program Manager i
Radiation, Licensing and Registration l
Hazardous and Radioactive Materials Bureau Environment Department i
State of New Mexico j-2044 Galisteo Road i
P.O. Box 26110 Santa Fe, NM 87502 i
i
Dear Mr. Floyd:
l The NRC staff has completed its review of your request to determine whether a protocol, I.
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 l
November 12,1996 letter to me with attachments, and the December 19,1996 note to i
ano from Walter Medina enclosing supplemental material, in particular, a December 2, 1996 letter to you from Chriso Petropoulou of Patterson and Associates,Inc.
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Based on our review, we do not believe that the information submitted is sufficiently i
complete to permit a comprehensive licensing review to determine whether or not the
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system proposed for use by INS at their Santa Fe facility meets the requirements in i
10 CFR Part 20, as supplemented by the guidance in the NRC's Information Notice (IN)
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94-07, " Solubility Criteria for Liquid Effluent Releases to Sanitary Sewerage Under the i
Revised 10 CFR Part 20." Although the treatment methods appear to be standard industry i
practice for treating the westewater, the INS protocol makes no mention of sewer i
discharges nor does it mention testing of the discharges for meeting compliance with the j
regulations. For example, information to confirm system capabilities and specifications and on the testing and quality assurance program that would be performed during i
operations are areas that should be addressed in the application. The protocol does not j
iddress testing of discharges for compliance with regulatory requirements nor compliance j
>ilth the protocol specirmations.
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 concem is a statement in the INS j
protocol that indicates that the proposed system would be designed to use a screen sheker with a 44 micron filter pore aire, and a wastewater fdter capable of removing portions of j
auspended solids with a size down to 1 micron. One of the recommended procedures L
referenced in IN 94 07 (ASTM D1888-78, " Standard Test Methods for Particulate and i
Dissolved Matter, Solids, or Residue in Water") states that a 0.45 micron pore size filter i
abould be used. Thus, it appears radioactive particles with a diameter of less than 44
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microns could be contained in the effluent sewer discharge. If so, that radioactive material I
i-4 3
9707220265 970716 ENCLOSURE 1 PDR STPRO ESGNM
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W. M. Floyd
-2 FEB 0 51997 in the dischstge would not be soluble, per the guidance in IN 94-07. Two other INS facilities, Royerford, PA and Columbia, SC, respectively, are approved for operation with wastewater filter sizes of 20 25 microns. The NRC recognizes that alternative criteria, ether than that identified in the IN, may be acceptable on a case-by case basis, yet INS l
has provided no supporting documentation to support the use of any afternate criteria for j
sanitary sewer discharge.
j 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 j
within the purview of routine technical assistance, and as such, it is not cost reimbursable j
by New Mexico.
i Finety, we are providing copies of this response to Patricio Guerrerottiz, Santa Fe Public l
Utilities Department Director and to Caron Balkany, Concerned Citizens for Nuclear Safety, l
who have written to us expressing interest in your technical assistance request.
l We trust this responds to your request. If we may be of further assistance, please do not j
hesitate to contact us.
l
- ncorely, M (M8 i
Paul H. Lohaus, Deputy Director i
Office of State Programs l
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C. Balkany 1
P. Guerrerortiz
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l Mr. Mark Perry
. Interstate Nuclear Services 295 Parker Street P.O. Box 51957 413 543-6911 l
SUBJECT:
MLB-033-91: Isotope Filtration Study /-
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Dear Mr. Perry:
Following are the values reported to you earier by telephone for the solubility study 1
performed on your wash water sample. The sample was counted for gamma prior to any fibration then counted again after passing through a 20,10,1. 0.45 and finalty 0.1 micron filter. After each filtration the flitrate was specl6cally monitored for Zn65, Co60, 4
and Cs137 along with Ni63 and Fe55. The residue at each step was analized for l
- Cs137, 2n65 and gross esta whh the following results.
I Before Fitration isotope uCi/ml Zn65 2.39E-6 Co60 1.21 E-6 j
Cs137 5.50E-7 11 After Fihration Dissotved Suspended isotope UCi/mi uCl/ml 20 micron filtration (F-1) 2n65 1.88E-6 3.72E-7 Co60 8.70E 7 2.48E 7 Cs137 6.70E 7 ND Fe55+NiS3 3.36E 6 4.38E-7 (gross beta) 10 micron filtration (F-2) 2n65 2.15E-6 ND Co60 9.58E 7 ND Cs137 6.44E 7 ND Fo55+NiS3 5.12E 6 4.70E 9 (gross beta)
ENCLOSlJRE 2 m m -wm.c.ou Y oo'o NcE E u T E i$ o.o. n. - - iv vc Ii i
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1 micron Ritration (F-3)
Zn65 1.90E 6 ND 4
Co60 8.94E 7 1.24E-8 Cs137 6.82E 7 ND l
Fe65+Ni63 3.72E 6 2.31E 8 (gross beta) 0.45 micron filtration (F 3)
Zn65 2.02E 6 ND i
Co60 8.51 E-7 ND Cs137 5.55E 7 ND Fe55+NiS3 3.71 E-6 b.5GE-9 (gross beta) j 0.10 micron filtration (F-3)
Zn65 1.97E 6 ND 2
Co60 8.45E 7 ND Cs137 5.55E-7 ND j
Fe55+NiS3 3.79E 6 5.75E 9 (gross beta)
It appears that some activity may have been mechanically removed in the first filtration due to the initial high total suspended solids but all activities remain i'
essentially the same on all successive filters which would lead you to believe that the contaminants are present in solution and not as a suspended solid.
Mark if you should have any questions or like us to go further with this study please do not hesitate to call me at 214 2471714.
A Sincerely,
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gy-(t chael L Buvinghau[ n i
Deputy Lab Director l
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TOTA P.05-
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