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Regulatory - Alert (RA 99-9)

Member Pipeline - Regulatory - Alert (RA 99-9)

To:

Members & Affiliates

From:

National Office

Date:

May 26, 1999

Subject:

POTW Radioactivity Guidance Document For Biosolids

Reference:

RA 99-9

Enclosed is a copy of “Characterization of Radioactivity Sources at Wastewater Treatment Facilities - A Guidance Document for Pretreatment Coordinators and Biosolids Managers” which was sponsored by the National Biosolids Partnership (AMSA, Water Environment Federation, and U.S. EPA) to address potential radioactivity issues at your facility. As you are probably aware, the Nuclear Regulatory Commission (NRC) regulates its licensees' discharges of radioisotopes into the sanitary sewer system. Since the 1980s, however, concerns have been raised primarily from biosolids and incineration ash contamination incidents that have occurred at a few POTWs. While these incidents have not posed significant health and safety risks to the public or to POTW employees, several have resulted in significant remediation costs.

Surveyed to Examine Radioactivity Levels
The NRC, in conjunction with U.S. EPA, has received Office of Management & Budget (OMB) approval to conduct a voluntary survey of radioactivity levels in biosolids and ash samples from about 300 POTWs. The survey is to be completed by June 2001. The Sewage Subcommittee of the Interagency Steering Committee on Radiation Standards (ISCORS) assisted in the development of the survey, which is scheduled to begin by early-June 1999. Two POTW representatives (from AMSA members) and one State representative are actively participating in the meetings of the ISCORS Sewage Subcommittee.

The ISCORS survey will be conducted in two phases. Within the next few weeks, as many as 1,000 POTWs nationwide will receive a questionnaire. Approximately 300 POTWs will be selected for sampling from those who complete and return the questionnaires based on a combination of factors, including but not limited to, recommendations from state radiation and water pollution control agencies, the number and type of radioactive material users with the ability to discharge into the collection system, and level of natural background radiation in the local area and water supply. This survey is being structured to obtain samples from POTWs that have the greatest chance of concentrating radioactive materials in their solids to elevated levels. Questionnaire recipients will be asked to voluntarily provide certain information that will assist the ISCORS subcommittee in their final selection of sample sites. Those POTWs that respond to the survey will receive a listing of NRC licensees located within the zip codes covered by their collection systems. Many of the AMSA members and other agencies are likely to be receive an ISCORS survey questionnaire, and other

information for their review.

In phase two of the ISCORS survey, 300 POTWs (about 25 per month for a year) will be requested to send grab sample(s) of their final wastewater solids materials (either biosolids or ash samples) that are beneficially used or disposed of to either the NRC or EPA laboratory for radionuclide analysis. Prepaid shipping containers with sampling kits will be provided to each POTW. The sample analysis will be performed without charge to the POTW. Each participating POTW will be asked if they want to receive a copy of the analysis results for its sample(s) and be responsible for any release of these data to the public. In the final survey report that will be issued by NRC and EPA, all results will be coded in such a manner that the identity of individual samples will not be readily ascertainable. While this arrangement will provide some degree of confidentiality, there can be no guarantee that information on specific POTWs will not ultimately be required to be released to the public pursuant to a Freedom of Information Act Request, etc., since in most states lab results sent to a POTW will be a public record. In addition, the identity of POTWs may be disclosed if there are elevated levels of radioactive materials that would cause a health and safety problem.

Naturally occurring radiation is present in nearly all substances, including wastewater solids. However, potential problems with elevated radiation levels in biosolids will most likely be confined to a relatively small number of POTWs receiving specific types of discharges. A prior AMSA survey of 55 POTWs throughout the nation in 1995 demonstrated that radionuclide concentrations in wastewater solids are generally similar to those found in natural substances such as soils, thus partially confirming the believe that any problems which may exist are not widespread.

Very few of the approximately 24,000 licensed users of radioactive materials create a quantity or type of radioactive waste that is likely to concentrate to elevated levels in municipal solids. Also, very few of these licensees that do discharge to the sewers possess materials in sufficient quantities and of a type that would cause a contamination problem in a POTW.

Regulation of NRC Licensees is Survey's Goal
The far-reaching purpose of the survey is to obtain information that can be used for further regulation of NRC licensees. The rules and policies that may emerge from this effort could result in significantly enhanced legal authorities for POTWs, as well as tighter control of discharges from licensees. In response to radioactivity issues over the past decade, NRC has revised its sewer discharge regulations to ban the discharge of insoluble materials other than readily dispersible biological materials. NRC has indicated that unless a national survey of POTWs demonstrates a significant problem from the discharge of licensed material, there is no basis for them to modify how sanitary disposal of radioactive waste is controlled.

AMSA believes this survey will demonstrate that the vast majority of POTWs do not have levels of radiation above expected background levels, although certain POTWs may be exceptions. The most likely cause for elevated radiation in wastewater solids is the discharge of radioactive waste from a specific discharger. Most regulated users of radioactive materials are authorized under current law (Atomic Energy Act) to discharge radioactive waste to the sanitary sewer pursuant to existing NRC regulations. No special discharge permit is required nor is the discharger required to report such discharges. As a result, few records, other than the discharger's on-site log, are available on radioactive discharges to the sanitary sewers.

Some POTWs, in recognition of this lack of information on radioactive discharges, have opted to incorporate radioactive materials into their pretreatment programs. The enclosed guidance document is designed to assist

POTW personnel in identifying sources of radiation in the collection system, in determining whether any such discharges are causing a problem at the plant or with solids use or disposal, in controlling incoming radioactive wastes if necessary, and in extreme cases, in responding to a contamination situation. Later this year, the National Biosolids Partnership will issue a radiation dose modeling report that will assist wastewater agencies in comparing radioactivity levels in biosolids to a number of other everyday exposures.

The ISCORS national survey is expected to demonstrate, as did the AMSA national survey, that radiation is not generally a problem in biosolids. As a result, public confidence should be boosted with regard to all forms of beneficial reuse or disposal of wastewater solids. AMSA and the National Biosolids Partnership therefore encourage your agency to carefully consider participating in this voluntary survey.

In the unlikely event that a POTW must be remediated as a result of the discovery of elevated radiation levels, it will be the POTW that is responsible for the costs. While a POTW=s only remedy to recover its remediation costs may be via the court system, AMSA can offer guidance in the unlikely event that such action becomes necessary.

In addition to plant remediation costs, the POTW could be liable for any disposal or land application sites that are found to have elevated radiation levels, and could be subjected to legal action by employees and the public. Therefore, it is important that you have as much information as needed to assess the potential for elevated levels of radioactivity in your facility. The enclosed document provides guidance to facilitate an evaluation of your facility and serves as a basis for determining your level of participation in the ISCORS survey.

AMSA's National Office hopes that you find the enclosed document useful in preparation for the ISCORS survey. For additional information, please contact Sam Hadeed, AMSA Director of Government Affairs at 202/833-4655.

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