AMSA Works with EPA, NRC on Policy Development
In 1996, AMSA continued to address implications of evolving
policy to control radioactive contamination of biosolids, as the
U.S. Environmental Protection Agency (EPA) and Nuclear Regulatory
Commission (NRC) considered regulatory approaches. During the
year, AMSA conducted an anonymous survey of publicly owned treatment
works (POTWs) to assess radioactivity levels in biosolids, and
worked with the NRC and EPA to determine appropriate control strategies.
The agencies' interest in radioactive contamination of biosolids
was sparked in the early 1900s following the discovery of contamination
at several POTWs caused by the reconcentration of certain radioactive
isotopes during the wastewater treatment process. In response,
the NRC revised its sewer disposal criteria for its licensees,
and began working with EPA to develop a coordinated review and
response to the problem. Currently, the NRC does not require
POTWs to test for radioactive materials in biosolids unless evidence
of a problem exists, and EPA standards for the use and disposal
of biosolids do not include radionuclides. EPA had planned to
include analysis of radiation in biosolids and incinerator ash
in its 1996-97 national biosolids survey, but does not have sufficient
funding to do so.
While the Association conducted a survey of 75 of its members
this year, the NRC determined that the effort was limited in scope
and has planned to conduct a more extensive survey that will support
future rulemaking efforts. The results of this comprehensive
survey could lead to NRC/EPA rulemaking to further control the
concentration of radionuclides discharged to POTWs by NRC licensees.
Any rulemaking arising from the survey is expected to apply additional
restrictions to NRC licensed industries and businesses that discharge
radioactive materials into sewer systems, but will not be used
for enforcement purposes by either NRC or EPA. The results of
the survey could also be used to determine whether POTWs should
be given more authority to impose local limits or controls on
NRC licensees discharging into their sewer systems.
Survey information will also be used to further develop NRC/EPA
guidance for POTWs to help them characterize sources of radioactivity,
describe sampling and analysis procedures, and advise them on
appropriate responses for addressing the presence of radioactive
material in their biosolids. AMSA has been providing information
to the agencies to help them with the development of this guidance,
and stands ready to provide them with more technical support in
1997 as they continue to craft their policy to control
radioactivity in biosolids.
AMSA Advocates Changes to EPA Radiation Rule
Earlier in 1996, AMSA assisted EPA in revising a planned radiation
site cleanup regulation (40 CFR Part 196) for the beneficial use
of biosolids management program. EPA's Office of Radiation &
Indoor Air had planned to issue proposed regulations to set cleanup
standards based on a risk assessment model for soils at federal
facilities contaminated with radioactive materials. A "lookup
table" limit of 15 millirems for
radionuclides in soil based upon protection of human health and
the environment was proposed in the rule.
In 1995, and during a meeting in March, 1996, representatives
of AMSA and the Water Environment Federation (WEF) expressed concerns
that the proposed soil cleanup rule could ultimately affect municipal
biosolids applied to land or landfills. While the Part 196 soil
cleanup standards do not apply to municipal biosolids management,
AMSA and WEF were concerned that the risk assessment methodology
used to arrive at the cleanup standards would be precedent setting
for future radioactivity standards for municipal biosolids. The
look-up table, which was part of the draft proposal, lists acceptable
radiation levels in soils for 62 individual radionuclides and,
if applied to biosolids, could have a significant impact on beneficial
use in land application projects. A preliminary review of the
numbers in the look-up table indicated that the proposed regulatory
limits for some radionuclides were at or below background soil
levels normally found in the environment.
AMSA's concerns, combined with the results of the Association's
anonymous survey -- which indicated that a majority of AMSA members
sampled exceed proposed limits for potassium-40 and Radium-226
-- prompted the agency to drop its proposed lookup table from
the Part 196 rule.