sanitary sewer, solubility

["Les Slaback, Health Physics" <SLABACK@micf.nist.gov>]

Supposedly there will be more guidance on the solubility issue coming out
soon.  Also I have heard that this is being further studied within NRC,
in addition to other related actions like Ohio's PRM.

Aside from the existing guidance, which really necessitates a chemistry
experiment, one can characterize the waste stream via filtration
experiments to determine the most practical filter, i.e., the largest pore
size, useable for your waste stream.  There is no need to go below 0.45 (!)
micron since NRC has endorsed that for use, however impractical it might be.

I would guess that most releases are well below the Table 2 values
(environmental release levels), and the NRC implementation of the solubility
criterion is simply a regulator's way of saying that solutions at this
level are best released to the environment rather than to the sanitary
sewer. [Sorry, that was my cynical twin that took control for a few minutes.
I doubt that that sort of balanced comparision was done as part of the
process of adopting the solubility rule.]
The oversight of anticipating the impact of the solubility rule at least
partially rests in our (the licensees) laps.  While the writers of the
rule privately indicate a less strigent interpretation was intended the
licensees did not ask the right questions (if any at all) to get this
clarified during the 10CFR20 rule making.  The end result is that we
are spending tens of thousands of dollars the clean up waste to dump to
the sewer that technically (if not politically) that we could release to
nearby streams, lakes, etc.While NRC has clearly documented several
violations, they were even violations of the old rule so that the revised
rule more directly addresses the concerns of the sewer plant operators
regarding radioactivity accumulations in solids.  But interestingly, the
solubility criteria does not really answer that question since some
'soluble' elements are chemically extracted and reconcentrated by the
treatment processes.

So, in short (!), to answer one of your questions, the best (and probably
future answer by most licensees) is not to have sewer releases and to pay
carefully attention to your radioanalysis sensitivities.

SLABACK@MICF.NIST.GOV
   ...a little risk, like a bit of spice, adds flavor to life
X-Comments:   Converted from OV/VM to RFC822 format by NOVA V2.1