UPOTW Participation In
NRC/EPA Radioactivity SurveyDecember 8, 1997
Meeting of
AMSA, WEF, NRC, and EPA
POTW OBJECTIVES
- The POTW community desires to actively participate as full partners with the NRC and EPA in conducting and evaluating a radioactivity survey to obtain national estimates of levels of radioactive materials in sludge/ash at publicly owned treatment works (POTWs) to support rulemaking decisions by NRC of its licensees that discharge such wastes into sanitary sewers and to clarify legal authorities available to POTWs in addressing potential problems.
- POTWs desire implementation mechanisms that will provide reasonable safeguards to minimize any future problems that may occur from licensees that discharge radionuclides into the sanitary sewers.
- Development of national standards for POTWs for the control of radionuclides in sewage sludge and ash is premature and unnecessary until evidence of widespread problems are found and appropriate remediation mechanisms are implemented by the discharger of such radioactive materials.
BACKGROUND
- The subject of radioactivity in sewage sludge and ash at POTWs has been under consideration by NRC and EPA for several years.
- Various analyses conducted by both agencies have found some reconcentration of radioactivity from both man-made and natural sources in sludge and ash.
- No imminent threat to public health and safety or the environment has been caused by such reconcentration.
- In 1994, NRC revised its sewer disposal criteria partially in response to evidence that certain radioactive materials were reconcentrating in sewage sludge or incinerator ash. NRC amended its sewer discharge rules as part of revisions to 10 CFR Part 20 based on an individual dose of 50 mRem/year and in accordance with recent international radiation protection guidance. Releases are restricted to materials that are readily soluble or readily dispersible biological material. The EPA standard for the use and disposal of sewage sludge in 40 CFR Part 503 does not include radionuclides.
- In 1994, the U.S. General Accounting Office (GAO) issued a report entitled "Action Needed to Control Radioactive Contamination at Sewage Sludge Treatment Plants." The GAO Report recommends that NRC:
(1) Determine the extent to which radioactive contamination of sewage sludge, ash, and related by-products is occurring;
(2) Directly notify the treatment plants that receive discharges from NRC’s and the agreement states’s licensees of the potential for radioactive contamination because of radioactive materials’ concentrating and of the possibility that they may need to test or monitor their sludge for radioactive content; and
(3) Establish acceptable limits for radioactivity in sludge, ash, and related by-products that should not be exceeded in order to ensure the health and safety of treatment workers and public.
- AMSA conducted a national survey of radioactivity in biosolids in 1995-96 and confirmed that the level of naturally-occurring radioactive material (NORM) in sludge is within the normal range of background concentrations of NORM in the environment.
- AMSA and WEF have met several times since 1995 to discuss continued interest in a joint NRC/EPA guidance document addressing reconcentration of radioactive materials at POTWs and the status of the NRC/EPA survey.
- NRC issues a notice in the December 2, 1997 Federal Register outlining its plans to conduct a joint NRC/EPA survey of POTWs for determining the extent of radioactive materials found in sewage sludge and ash during 1998.
- Meeting of AMSA, WEF, NRC, and EPA on December 8, 1997 to discuss efforts to engage in a collaborative effort to conduct the POTW survey.
POTW PERSPECTIVES
- POTWs are stewards of the local environment. It is incumbent upon them to know if there are any problems with radioactivity in their biosolids. POTWs also understand that both NRC and EPA are trying to comply with the GAO recommendations to investigate this issue and believe that a collaborative effort undertaken before, during, and after the survey will minimize public concerns.
- POTWs have successfully administered the industrial pretreatment program for the past 25 years which in turn has produced high quality biosolids that have nutrient value equaling or exceeding that of commercial fertilizers.
- Many POTWs are applying sewage sludge to land as a management option under the 40 CFR Part 503 sewage sludge regulations. The general public is still not comfortable with such practices and often resist these activities at the local level.
- Sufficient planning is needed before the survey is conducted. Public agencies anticipate that there will be public anxiety if elevated levels of radioactive materials are found. The public generally will not discern what is a safe or non-safe level of exposure. POTWs believe that failure to anticipate such a response could easily kill the practice of land application of biosolids.
- Biosolids are heavily regulated by the U.S.EPA whereas commercial fertilizers and animal manures are mostly unregulated.
- Licensees do not routinely monitor for their discharges of radioactive materials to the sanitary sewers. If contamination problems occur, POTWs are concerned that they will be liable for the cost of cleanup for discharges from licensees.
- POTWs are not clear on their legal authority to regulate NRC licensees and what options that have to enforce compliance with pretreatment requirements under the Clean Water Act. POTWs also do not have experience with development of local limits for radionuclides and need guidance in the event that such activity is warranted.
ACTION ITEMS
- Form Survey Committee (not FACA group) comprised of NRC, EPA, AMSA, WEF, industry, and Agreement States to participate in the planning, conduct, and evaluation of survey and results. The Committee would also participate in any future rulemaking or criteria development.
- Develop radionuclide exposure table for comparing exposures to everyday sources of radiation (i.e., airplane travel, sunlight, X-rays, etc.) as well as occupational exposures. Develop protocol for assessing exposure risk.
- If NRC licensees are subject to EPA’s industrial pretreatment program, then POTWs need clarification over whether radioactive discharges/materials are covered.
- POTWs recognize that potential problems may result in contamination of biosolids and/or ash. POTWs need assistance from NRC in reaching an amicable resolution to issues regarding liability for cleanup costs. The issue of radionuclides in sewage solids should not be viewed as a POTW/EPA problem alone.
- Request NRC amend the terms of its licensees’ agreement to require:
(1) Annual reporting of radionuclides discharged to the sanitary sewer system to inventory, characterize, analyze, and where necessary, control discharges;
(2) Compliance with local emergency planning committee provisions with the local POTW; and
(3) Pretreatment Program equivalent for NRC licensees.
- NRC should provide participating POTWs with a list of the licensees with a high probability of discharging elevated levels of radioactive materials in sludge and ash at POTWs.
- NRC needs to develop and implement a supplemental control mechanism and/or enforcement action plan with its licensees if elevated levels of radioactive materials are found in POTW sludges and ash. POTWs need reasonable assurances that NRC is ensuring compliance by its licensees and they are not illegally discharging materials that are not contained in their license.
- NRC needs to include a table for each radionuclide of concern to compare results of survey to background levels and other standards by analogy.
- NRC needs to develop a database on users of radioactive material:
(1) List of licensees grouped by states, including zip codes;
(2) List of licensees with high potential to discharge elevated levels of radioactive materials that would be found in sludge and ash;
(3) NRC disclosure of the basis for selecting POTWs downstream of the "highest risk" licensees; and
(4) Expand the current POTW guidance effort to include information that covers sample collection and analysis; surveying user drains and lateral sewers with radiation meters; synopsis of legal authority in event that licensee refuses to cooperate; comparison numbers of radiation in the world around us to use with employees, media, and the public; and establishing a mechanism for POTW to set up a program whereby licensed discharger routinely notifies the POTW of the type, level, and timing of discharges to the sewer system.