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RE: question



This particular Information Notice can be located at:



http://www.nrc.gov/NRC/GENACT/GC/IN/1994/in94007.txt



Attached is a copy (as an Adobe .PDF file) of the Information Notice, however, here it is quoted again;



                                                UNITED STATES

                                    NUCLEAR REGULATORY COMMISSION

                          OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

                                       WASHINGTON, D.C.  20555



                                          January 28, 1994





NRC INFORMATION NOTICE 94-07:  SOLUBILITY CRITERIA FOR LIQUID EFFLUENT

                               RELEASES TO SANITARY SEWERAGE UNDER THE

                               REVISED 10 CFR PART 20





Addressees



All byproduct material and fuel cycle licensees with the exception of

licensees authorized solely for sealed sources.



Purpose



The U.S. Nuclear Regulatory Commission is issuing this information notice to

emphasize the changes in 10 CFR Part 20 with respect to liquid effluent

releases to sanitary sewerage and to encourage you to prepare for these

revisions.*  It is expected that licensees will review this information for

applicability to their operations, distribute it to appropriate staff, and

consider actions to prepare for, and incorporate, these changes.  Suggestions

contained in this information notice are only recommendations; therefore, no

specific action nor written response is required.



Background



On December 21, 1984, NRC released an information notice documenting several

instances of reconcentration of radionuclides released to sanitary sewerage

(IN No. 84-94, "Reconcentration of Radionuclides Involving Discharges into

Sanitary Sewage Systems Permitted under 10 CFR 20.303").  Several other

instances have since occurred in Portland, Oregon; Ann Arbor, Michigan; Erwin,

Tennessee; and Cleveland, Ohio.  The primary contributors, in some of these

cases, appear to have been insoluble materials released as dispersible

particulates or flakes.  This issue was addressed again on May 21, 1991, by

NRC, when it published its revision of Part 20 in the Federal Register

(56 FR 23360), which removed insoluble non-biological material from the types

of material that may be released to sanitary sewerage.  Relative to this

issue, the NRC Office of Nuclear Regulatory Research is conducting a study to

clarify the mechanisms underlying reconcentration in sanitary sewerage and

sewage treatment facilities.







9401240059



    *  Sanitary sewerage is defined by 10 CFR 20.1003 as "a system of public

sewers for carrying off waste water and refuse, but excluding sewage treatment

facilities, septic tanks, and leach fields owned or operated by the licensee

[emphasis added]." 



                                                            IN 94-07

                                                            January 28, 1994

                                                            Page 2 of 5





Description of Circumstances



To help prevent further reconcentration incidents at public sewage treatment

facilities, 10 CFR 20.2003(a)(1), effective January 1, 1994, was written as

follows:



    20.2003  Disposal by release into sanitary sewerage

      (a) A licensee may discharge licensed material into sanitary sewerage

     if each of the following conditions is satisfied:

      (1) The material is readily soluble (or is readily dispersible

     biological material) in water; and...



However, this revision to Part 20 did not contain an operational definition of

solubility, and this precipitated many questions, from licensees, concerning

how the solubility of a material may be demonstrated.  Without the ability to

demonstrate compliance, these licensees were unable to determine whether new

procedures should be developed, new treatment systems installed, or whether

they should apply for an exemption, based on the principle of maintaining all

doses as low as is reasonably achievable (ALARA).



Discussion



In some of the known reconcentration incidents, the greatest reconcentrations

appear to have been due to compounds released to sanitary sewerage that were

not soluble.  There are many approaches that may be used to determine a

chemical compound's solubility in water.  The following discusses two of the

more common approaches:



    1.  Direct Determination of Compound Solubility Class, Formal Solubility,

        or Solubility Product (Ksp)



        This approach would be applicable whenever there is sufficient

        knowledge of the chemical form of all materials contained in the

        liquid effluent at the point of release.  With this knowledge, it

        would be possible to use one (or more) of the following methods:



        (a) Solubility Class Determination:



            The solubility class of the compound to be released could be

            determined directly from common literature data (e.g., Handbook of

            Chemistry and Physics - CRC Press, and Lange's Handbook of

            Chemistry - McGraw- Hill Book Company).  If a compound is

            classified as "v s" (very soluble) or "s" (soluble), this would

            indicate the compound is "readily soluble."  On the other hand, if

            it is classified as "i" (insoluble), "sl s" (slightly soluble), or

            "v sl s" (very slightly soluble), this would indicate materials

            that are "not readily soluble."  Certain compounds are designated

            as class "d" (decompose).  If the decomposed species of these

            compounds are classified as either "v s" or "s," this would

            indicate that the parent compound is "readily soluble."  If these

            decomposed species are simple ions, such compounds (class "d")

            should be considered "readily soluble."



                                                            IN 94-07

                                                            January 28, 1994

                                                            Page 3 of 5





        (b) Solubility Product (Ksp) Determination:



            The solubility product constant of the compound could also be used

            to determine if a compound is readily soluble in water.  The

            solubility product constant, Ksp, for a strong electrolyte MmAa,

            is expressed as:

                       m   a

            Ksp  =  [M] [A]



            where [M] and "m" are the ionic concentration (mole/liter) and the

            number of moles, respectively, of the dissolved cation; and [A]

            and "a" are the ionic concentration and the number of moles,

            respectively, of the dissolved anion.



            For a simple electrolytic compound, with one mole of a dissolved

            cation species and one mole of a dissolved anion species, a Ksp

                                       2      2

            greater than 1.00 E-05 mole /liter  would indicate that a compound

            is "readily soluble."  For other compounds with more complex

            dissolution reactions (i.e., more than one mole dissolved for each

            species and/or more anionic or cationic species present in the

            dissolved products), the Ksp constant would increase

            exponentially, based on the number of moles and/or the number of

            dissociated species.  For example, if three moles are present (two

            for the anion and one for the cation), the unit of Ksp would be

                3      3                                             3/2

            mole /liter , and the corresponding Ksp would be (1 E-05)    or

                         3      3

            3.2 E-08 mole /liter ;  the same principle could be applied for

            more complex dissolution reactions.



        (c) Formal Solubility Determination:



            Compound solubilities (g/100 ml or mole fraction per 100 ml) are

            also listed in the chemical literature.  From a review of general

            scientific literature, "formal solubilities"** greater than 0.003

            mole/liter would indicate that a compound is "readily soluble."







   ** The general relation between the formal solubility, Sf, and the

solubility product, Ksp, of a strong electrolyte MmAa in water is given by:

                       m a  1/(m+a)

           Sf = (Ksp/(m a )),

where Ksp is the solubility product, [M] is the molar concentration of the

metal ion (cation), [A] is the molar concentration of the anion, "m" is the

number of moles of dissolved cation per mole of dissolved substance, and "a"

is the number of moles of the dissolved anion per mole of dissolved substance.



For further discussion on the determination of solubility products and formal

solubility, refer to Chapter 6, "Precipitation and Dilution," from Water

Chemistry, by Vernon L. Snoeyink and David Jenkins (John Wiley and Sons: 1983)

or texts relating to physical and/or analytical chemistry.



                                                            IN 94-07

                                                            January 28, 1994

                                                            Page 4 of 5



            Formal solubilities less than 0.003 mole/liter would indicate

            compounds that are "not readily soluble."



        It should be pointed out that all values mentioned above (e.g.,

        solubility class, formal solubility, and solubility product)

        correspond to measurements taken under standard conditions (e.g.,

        25øC, 101.3 kPa, pH of 7, and Eh of 0).



    2.  Filtration and Radiometric Analysis of Suspended Solids



        This approach may be used if knowledge of the chemical form of all

        materials contained in the liquid effluent at the point of release is

        incomplete.  It is most applicable when releases are made in a batch

        mode.  This approach involves the use of standard laboratory

        procedures to test representative samples of the waste stream for the

        presence of suspended radioactive material.



        The following two laboratory procedures were developed specifically to

        determine the suspended solids content of water: ASTM Method D 1888-

        78, "Standard Test Methods for Particulate and Dissolved Matter,

        Solids, or Residue in Water," and the American Public Health

        Association's Method 7110, "Gross Alpha and Gross Beta Radioactivity

        (Total, Suspended, and Dissolved)" from Standard Methods for the

        Examination of Water and Wastewater.  It should be noted that ASTM

        Method D 1888-78 was developed to measure the total suspended solids

        content of water, not just the radioactive portion.  In either case,

        activity in the suspended solids portion of effluent greater than that

        found in similarly processed background water samples would indicate

        the presence of insoluble radioactive material.



Whether one of the above approaches or a self-developed alternative is used,

it is a good health physics practice to document this approach in the form of

a procedure.  Procedures such as these usually include provisions for the

documentation of any models, calculations, analytical measurements, and/or

quality control measures used.  This information is usually maintained with

the applicable release records, to demonstrate that the developed procedure

will ensure compliance with the regulations.



If material to be released would not qualify as being "readily soluble,"

  10 CFR 20.2003(a)(1) would prohibit release to sanitary sewerage unless an

exemption has been granted.  Exemptions will be judged on a case-by-case

basis, when it is demonstrated that release to sanitary sewerage is in

accordance with the ALARA principle, consistent with applicable regulations,

and in the public interest.



It is expected that licensees will review this information for applicability

to their operations, and consider actions, as appropriate to their licensed

activities.  However, suggestions contained in this information notice are not

NRC requirements; therefore, no specific action nor written response is

required.





                                                            IN 94-07

                                                            January 28, 1994

                                                            Page 5 of 5



If you have any questions about the information in this information notice,

please contact one of the technical contacts listed below or the appropriate

regional office.



/s/'d by RFBurnett                        /s/'d by CJPaperiello





Robert F. Burnett, Director               Carl J. Paperiello, Director

Division of Fuel Cycle Safety             Division of Industrial and

  and Safeguards                            Medical Nuclear Safety

Office of Nuclear Material                Office of Nuclear Material

  Safety and Safeguards                     Safety and Safeguards





Technical contacts:  Rateb (Boby) Abu-Eid, NMSS

                     (301) 504-3446



                     Cynthia G. Jones, NMSS

                     (301) 504-2629



Attachments:

1.  List of References

2.  List of Recently Issued NMSS Information Notices

3.  List of Recently Issued NRC Information Notices



                                                            Attachment 1

                                                            IN 94-07

                                                            January 28, 1994

                                                            Page 1 of 1



                                             REFERENCES





Annual Book of ASTM Standards. Volume 11.01, "Water (I)."  American Society

for Testing and Materials, Easton, MD, 1989.



CRC Handbook of Chemistry and Physics.  CRC Press, Inc., Boca Raton, FL, 65th

ed, 1984.



Lange's Handbook of Chemistry.  McGraw-Hill, Inc., New York, NY, 13th ed,

1985.



Snoeyink, Vernon L. and David Jenkins, Water Chemistry. John Wiley & Sons,

Inc., New York, NY, 1980.



Standard Methods for the Examination of Water and Wastewater.  American Public

Health Association, Washington, DC, 17th ed, 1989.











Robert N. Young, X-ray Registration & Machine / Device Permitting Manager



TN - Division of Radiological Health

3rd Floor, L & C Annex

401 Church Street

Nashville, TN 37243-1532



(615) 532-0364 Voice

(615) 532-0385 FAX

e-mail: ryoung3@mail.state.tn.us



>>> <Marty.Bourquin@GRACE.COM> 4/19/01 5:42:02 PM >>>

The NRC issued a NRC Information Notice 94-07 "Solubility Criteria for 

Liquid Effluent Releases to Sanitary Sewerage Under the Revised 10CFR 

Part 20".



It provides guidance in determining if you meet the requirements in 

20.2003(a)(1).  If you dont have it, it may be available online or I 

can fax you a copy if you need it.



Marty Bourquin

W.R. Grace and Co.

Marty.Bourquin@grace.com 

-----Original Message-----

From: ahp@ICUBED.COM [mailto:ahp@ICUBED.COM] 

Sent: Thursday, April 19, 2001 4:38 PM

To: radsafe@list.vanderbilt.edu 

Cc: ahp@ICUBED.COM 

Subject: question





Can anyone tell me why a licensee would be required to test for 

solvability

if the effluent has been passed through a 0.5 micron filter with 

analytical

test results indicating less than the release criteria to the sanitary

sewer?



Cindy Barto

ahp@icubed.com 



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