Action Please By: July 18, 1997
To: Members & Subscribers From: National Office Date: June 23, 1997 Re: RA 97-15 NRC Draft Guidance on Radioactive Materials in
Biosolids/Ash at POTWsThe Nuclear Regulatory Commission (NRC) and U.S. EPA circulated for review in mid-June their draft guidance for POTWs on radioactive materials in sewage sludge (biosolids)/ash. AMSA had met with both agencies during the May 1997 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 may wish to determine potential sources of radioactive materials from NRC licensees in their jurisdiction. POTWs that are located in an NRC-Agreement State should contact the appropriate State regulatory authority (Appendices B and E). If AMSA POTWs are located in a non-Agreement State, contact the NRC regional office (Appendix C). The appropriate regulatory authority should be able to help trace the origin of the radioactive material. Specifically, the NRC or Agreement State can provide a list of licensees in the wastewater collection system if they are provided a list of zip codes in your collection system.
AMSA members are 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 and will ultimately incorporate the results into the final guidance document. AMSA will request that NRC and EPA establish a steering committee that would include representatives of AMSA to review survey results. Contact Sam Hadeed at the National Office (202) 833-4655 for questions regarding the document.
ATTACHMENT: NRC Draft Guidance on Radioactive Materials in Biosolids/Ash at POTWs (Please contact AMSA’s National Office at 202/833-AMSA for a copy of this document)