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Friday, June 20, 1997
NRC Releases Draft Guidance on Radioactive Materials in Biosolids/Ash
The Nuclear Regulatory Commission (NRC) and U.S. EPA circulated for review this week its draft guidance for POTWs on radioactive materials in sewage sludge (biosolids)/ash. AMSA had met with both agencies during the May National Environmental Policy Forum and urged the expeditious release of the document to allow for review by AMSA member agencies and to help POTWs identify where NRC licensees are located within their service area. The guidance provides background information about the regulatory policies of NRC and EPA, sources of radioactive materials in biosolids, guidance on sampling and analysis of these materials in biosolids and incinerator ash, and methods to assess levels of radioactive materials in these byproducts of wastewater treatment. NRC and EPA do not currently have regulations addressing radioactive materials in biosolids products at POTWs. NRC and EPA are developing a "lookup table" to describe concentrations of radioactive materials in biosolids or ash. These estimated concentrations will be based on dose modeling calculations which assume how individuals could be exposed to these radioactive materials. So far, a dose level has not been chosen for the calculations. NRC and EPA are soliciting comments on the need for this table and the appropriate dose level for the calculations. The document, though incomplete, is currently under review by the Interagency Steering Committee on Radiation Standards Subcommittee. AMSA members will receive the draft via Regulatory Alert 97-15 and will be requested to comment on the document’s comprehensiveness, content, and presentation. Comments are due back to the National Office by July 18. NRC plans to conduct a survey of 300-400 POTWs for radionucleide content later this year. Contact Sam Hadeed at the National Office (202) 833-4655 for questions regarding the document.AMSA Comments on Draft Source Water Protection Programs Guidance
On June 13, AMSA submitted comments on EPA’s recently released draft guidance titled, "State Source Water Assessment and Protection Programs Guidance," which is intended to assist states in the development of new Source Water Assessment Programs mandated by the Safe Drinking Water Act amendments of 1996. The draft guidance outlines time frames, processes, public involvement requirements and the scope of what constitutes an approvable state source water protection program, and provides information on coordinating the program with other state and federal pollution control efforts. In its comments, AMSA supports the concept of source water protection and strongly encourages measures to link watershed management and source water protection efforts. AMSA suggests that a practical methodology for the addition of watershed planning to the source water assessment process and vice-versa must be developed, and recommends that the methodology discuss competing time frames, regulatory agency coordination, continual assessment, and cross-funding issues. AMSA also urges EPA to recognize the potentially significant implications of a susceptibility analysis in the source water assessment process, and ensure that the analysis is based on good science and good data. Other issues discussed in AMSA’s comments include: recognition of state and local government, and water supplier cooperation in the assessment program; technical issues concerning delineation, such as the lack of "credit" for vertical travel times; source inventory information; community volunteer programs; timeframes in the approval process; and technical/financial assistance in the petition process. AMSA concludes that in order to develop meaningful source water assessments, states will need more than two years to complete the assessments and that the guidance should recognize the significant need to include local governments and water purveyors in the development of a state’s assessment program, and especially , in the completion of the source water assessments. EPA plans to finalize the guidance in August 1997, whereupon, states will have 18 months to submit their Source Water Assessment Program to EPA.