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To: Members & Subscribers
Pretreatment & Hazardous Waste Committee
Biosolids Management Committee
From: National Office
Date: December 12, 1997
Re: RA 97-26

AMSA Meets With NRC/EPA To Discuss
POTW Radioactivity Survey

Representatives from AMSA, WEF, Nuclear Regulatory Commission (NRC), and EPA met this week to discuss issues related to a planned survey of POTWs to determine if levels of radioactive materials are present in biosolids. The NRC published a notice in the Dec. 2 Federal Register outlining its plans to conduct a joint NRC/EPA survey during the summer of 1998 to characterize radioactive materials in sewage sludge/ash at POTWs and NRC-agreement states.

For the planned survey, NRC/EPA will send questionnaires to some 600 POTWs associated with NRC licensees having the highest potential to discharge radioactive material to the sewer system. Using the information gathered, NRC and EPA will identify approximately 300 POTWs for sampling. The objectives of the joint survey are to: 1) obtain national estimates of high probability occurrences of elevated levels of radioactive materials in biosolids and ash at POTWs; 2) estimate the extent to which radioactive contamination comes from either NRC/agreement state licensees or naturally occurring radioactivity; and 3) support rulemaking decisions by NRC and EPA. The information will be used in developing joint NRC/EPA guidance for POTWs to determine sources of radioactive materials, describe sampling and analysis procedures, and advise whether a response is needed to the presence of radioactive material in biosolids.

During the recent meeting, AMSA asserted that the POTW community, as environmental stewards, desires active participation as full partners with the NRC and EPA in conducting and evaluating a radioactivity survey and supports NRC supplemental rulemaking of its licensees that discharge such wastes into sanitary sewers. Potential concerns with adverse public reaction to any levels of radioactivity in biosolids, in the absence of a background exposure comparison table and the impact of such findings on future land application practices were also voiced. In particular, AMSA expressed the desire to implement reasonable safeguards to minimize future problems that may result from licensee dischargers of radionuclides into sanitary sewers. AMSA did, however, express the belief that any development of national POTW standards for the control of radionuclides in biosolids/ash is premature and unnecessary until evidence of widespread problems are found, and appropriate mechanisms are implemented by the discharger of such radioactive material.

AMSA provided NRC and EPA with a copy of several action items that would facilitate POTW active participation in a survey (see attached). AMSA focused its attention on several specific activities deemed important to allow for such a collaborative effort. Specifically, AMSA recommended the: 1) creation of a Survey Committee including AMSA, WEF, and interested parties to plan and evaluate results; 2) clarification of legal authority of POTWs to regulate licensees under the pretreatment program; 3) development of exposure comparison table to evaluate survey results against background sources of radioactivity; 4) NRC provision, to POTWs, of a list of licensees with potential to discharge elevated levels and a mechanism to report the type of radionuclide discharged; and 5) incorporation of AMSA's recommendations in a proposed guidance document to assist the POTW community in addressing radioactivity in sanitary sewers. NRC and EPA were receptive to the creation of the Survey Committee which will provide opportunities to ensure that other action items can be implemented.

Comments on the enclosed, proposed survey are due to OMB by January 2, 1998. Due to the short time available, the National Office would appreciate an immediate review focusing on the draft questionnaire, that will be mailed to the 600 POTWs, to ensure that the appropriate questions are included in the survey. Comments can be FAXed to Sam Hadeed of AMSA’s National Office at 202/833-4657 or e-mailed to shadeed@amsa-cleanwater.org, no later than December 29, 1997.