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U.S. Nuclear Regulatory Commission

Agency Information Collection Activities: Submission for OMB Review;
Comment Request

AGENCY: U. S. Nuclear Regulatory Commission (NRC)
ACTION: Notice of the OMB review of information collection and solicitation of public comment.
SUMMARY: The NRC has recently submitted to OMB for review the following proposal for the collection of information under the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35). The NRC hereby informs potential respondents that an agency may not conduct or sponsor, and that a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.

1. Type of submission, new, revision, or extension: New

2. The title of the information collection: Joint NRC/EPA Survey of Sewage Sludge/Ash

3. The form number if applicable: None

4. How often the collection is required: This is a one-time collection.

5. Who will be required or asked to report: Selected publicly owned treatment works (POTWs), and Agreement States.

6. An estimate of the number of responses: 600 POTWs for the questionnaire and 300 POTWs for sample collection, plus 30 Agreement States for reporting of licensees associated with Zip Codes.

7. An estimate of the total number of hours needed annually to complete the requirement or request: An average of 1 hour per respondent for questionnaire and 6 hours each for selected respondents for collecting samples, plus 8 hours each for 30 Agreement States. The total burden is 2,640 hours.

8. An indication of whether Section 3507(d), Pub. L. 104-13 applies: Not applicable.

9. Abstract: The survey will obtain national estimates of high probability occurrences of elevated levels of radioactive materials in sludge and ash at POTWs, estimate the extent to which radioactive contamination comes from either NRC/Agreement State licensees or from naturally-occurring radioactivity, and support possible rulemaking decisions by NRC and EPA. NRC and EPA will send questionnaires to selected POTWs. Based on the results of that survey, NRC and EPA will identify approximately 300 POTWs from which samples of sewage sludge/ash will be taken and analyzed. Results of the full survey will be published for use by Federal agencies, States, POTWs, local POTW officials and other interested parties.

A copy of the draft supporting statement may be viewed free of charge at the NRC Public Document Room, 2120 L Street NW (lower level), Washington, DC. OMB clearance packages are available at the NRC worldwide web site (http://www.nrc.gov) under the FedWorld collection link on the home page tool bar. The document will be available on the NRC home page site for 60 days after the signature date of this notice.

Comments and questions should be directed to the OMB reviewer by January 2, 1998 to:

Norma Gonzales
Office of Information and Regulatory Affairs (3150)
NEOB-10202
Office of Management and Budget
Washington, DC 20503

Comments can also be submitted by telephone at (202) 395-3087.

The NRC Clearance Officer is Brenda Jo Shelton, (301) 415-7233.

Dated at Rockville, Maryland, this 24th day of November 1997.

For the Nuclear Regulatory Commission

____________________________________
Brenda Jo. Shelton, NRC Clearance Officer


SUPPORTING STATEMENT FOR
JOINT NRC/EPA SURVEY OF SEWAGE SLUDGE/ASH

Description of the Information Collection
The U.S. Nuclear Regulatory Commission and the U.S. Environmental Protection Agency (EPA) are sponsoring a joint effort to characterize radioactive materials in sewage sludge and ash from publicly owned treatment works (POTWs). Sanitary sewer disposal of radioactive material and sludge reconcentration became issues in the 1980s with the discovery of elevated levels in sewage sludge or incinerator ash at several POTWs. Although the NRC expected that compliance with revisions in its sewer disposal criteria would prevent future reconcentration problems, NRC and EPA have continued to work together to ensure a coordinated regulatory review effort concerning sewage treatment with respect to radioactive material. EPA had planned to include analysis of radioactivity in sewage sludge and incinerator ash in its second National Sewage Sludge Survey during 1996-97. (The first national survey conducted in the late 1980s did not include analysis of radioactive material.) Based on the current budget situation, EPA did not move forward with a second national survey. As a result, NRC and EPA will perform a joint survey of radioactivity in sewage sludge and ash at POTWs.

Because existing information is not adequate, NRC is requesting Office of Management and Budget (OMB) approval to conduct the survey to obtain this information. The survey will sample radioactive materials in sewage sludge and ash at POTWs in all regions of the country. For the planned NRC/EPA survey, we will send questionnaires to the POTWs associated with types of NRC licensees that have the highest potential to discharge radioactive material to the sewer system and POTWs in all geographic areas of the United States. Using the information from the questionnaires, NRC and EPA will identify approximately 300 POTWs to be sampled. NRC and EPA tested the survey methods and procedures on nine POTWs. The results of the full survey will be published as a joint NRC/EPA report for use by Federal agencies, States, POTWs, local POTW officials, and other interested parties.

A. JUSTIFICATION

1. Need for and Practical Utility of the Collection of Information
The objectives of this joint NRC/EPA sewage sludge/incinerator ash survey are to (1) obtain national estimates of high probability occurrences of elevated levels of radioactive materials in sludge 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.

Specific amounts and concentrations of radioactive material are legally authorized to be disposed into the sanitary sewer system by Federal or State law. 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. Regulations in 10 CFR 20.2003 currently permit disposal into a sanitary sewer of specific quantities of soluble material. The EPA standard for the use and disposal of sewage sludge in 40 CFR Part 503 does not include radionuclides.

This survey also responds to a recommendation in the General Accounting Office (GAO) report, "Actions Needed to Control Radioactive Contamination at Sewage Treatment Plants," published in May 1994. That report recommended that NRC determine the extent of elevated levels of radionuclides at POTWs and establish acceptable limits for radioactive materials in sewage sludge and ash.

2. Agency Use of Information
This is a new collection of information.

The information could lead to additional NRC rulemaking for licensees disposing material into sanitary sewer systems or to EPA rulemaking for the use or disposal of sewage sludge. EPA will determine, based on the results of this survey, whether additional random sampling will be necessary to support its own rulemaking, if warranted.

This information will be used in developing joint NRC/EPA guidance for POTWs. This guidance would provide information to help POTW operators determine sources of radioactive materials at POTWs, describe sampling and analysis procedures, and advise whether a response is needed to the presence of radioactive material in sludge. POTWs, local sewer district officials, and EPA have requested this guidance.

3. Reduction of Burden through Information Technology
POTWs will respond to a short questionnaire and send sewage samples to an NRC or EPA lab for analysis. There will not be an electronic collection of information because the information will be collected on a one-time-basis. Two letters co-signed by NRC and EPA will be mailed to each POTW - the first letter with the questionnaire and the second with the sample collection package. The questionnaire is attached.

4. Effort to Identify Duplication and Use Similar Information
There is no similar information available. The only previous national sewage survey, the 1988-1989 National Sewage Sludge Survey, did not include analysis of radionuclides.

Recently, the Association of Metropolitan Sewerage Agencies (AMSA) conducted a voluntary survey of radionuclide concentrations in some of its members' POTW sewage sludge and ash. However, the AMSA survey did not identify the facilities tested, and thus it is not possible to assess regional background levels of radionuclides or the effects of licensees that dispose of radioactive material into sanitary sewers. (See further discussion of the AMSA survey in Item 8.)

5. Effort to Reduce Small Business Burden
This survey does not directly involve small entities. However, because the information needs are the same for both large and small POTWs, it is not possible to reduce the burden on small entities.

6. Consequences to Federal Program or Policy Activities if the Collection is Not Conducted or is Conducted Less Frequently
If the collection is not conducted at all, NRC and EPA will not be responsive to the recommendation in the GAO report to determine the extent of elevated levels of radionuclides at POTWs. NRC and EPA will also not be able to obtain information providing a basis for developing potential future rulemakings and quantitative guidance for the proposed joint NRC/EPA guidance for POTWs. This is a one-time collection.

There are no technical or legal obstacles to conducting this data collection.

7. Circumstances Which Justify Variation from OMB Guidelines
There is no variation from OMB guidelines. The POTWs will have 30 days to respond.

8. Consultations Outside the NRC
In an October 11, 1994 letter, NRC and EPA notified the water and radiological officials of all States of the potential for reconcentration of radioisotopes in sanitary sewer systems. This letter mentioned the planned EPA national survey and the guidance document.

On March 6, 1996, EPA and NRC staff were briefed by AMSA and the Water Environment Federation (WEF) on the preliminary results of a voluntary (but anonymous) AMSA survey of radionuclide concentrations in sewage sludge and ash at POTWs (see also discussion in Item 4). To date, sewage sludge and ash samples from 55 wastewater plants in 17 states have been analyzed. These plants were distributed across the country and range in size from small to among the largest POTWs in the United States. Because of limitations in the AMSA survey, including the fact that the POTWs were anonymous, the possibility of a more extensive NRC/EPA jointly funded survey of sludge and ash to assess the need for NRC rulemaking was considered. The industry representatives stated their continued interest in a joint NRC/EPA guidance document addressing reconcentration of radioactive material at POTWs. NRC and EPA have met with the WEF Radioactivity Task Force to discuss the status of the NRC/EPA survey and the contents of the joint guidance. During the survey, NRC and EPA will continue to meet with representatives of industry.

The sewage sludge/ash survey is being coordinated by a subcommittee of the Interagency Steering Committee on Radiation Standards (ISCORS). ISCORS was formed in 1995 to coordinate resolution of interagency issues. The ISCORS Sewage Subcommittee is assisting NRC and EPA in the development of the survey, including sample collection and analysis procedures and the selection of facilities to sample.

The NRC contractor, the U.S. Department of Energy's Oak Ridge Institute for Science and Education (ORISE), in Oak Ridge, Tennessee and EPA's National Air and Radiation Environmental Laboratory (NAREL) in Montgomery, Alabama will analyze the sewage sludge and ash samples. These labs have also provided input on the survey design. For example, ORISE and NAREL collaborated to ensure that the analytical laboratory procedures and quality assurance programs that both labs will use will produce consistent, accurate, and reliable measurements.

An opportunity to comment on the information collection requirements in this survey was provided in the January 6, 1997 Federal Register notice on this clearance request. NRC received comments from five members of the public. The only change to the survey that resulted from the public comments was that one question was added to the questionnaire to determine if a previous analysis of radioactive materials was performed. If there is a question about the survey results at a specific POTW and an earlier analysis is available, we may compare the earlier analysis to the survey results. There were no changes in the cost or hourly burden as a result of the public comments.

Some of the public comments did not address the survey, and therefore, their resolution will have no impact on it. For example, some commenters asked the NRC to survey and sample its licensees, not POTWs. Several commenters noted the nearly complete absence of data in the NRC's possession regarding the licensees' discharges to the sewers. Some commenters also asked what the NRC would do for POTWs if they are found to have a contamination problem.

Some of the commenters objected to the survey. All the comments have been analyzed, and an analysis of the comments is attached.

9. Payment or Gift to Respondents
The POTWs will not receive payments or gifts; however, they will receive the results of the NRC/EPA analysis of sewage sludge and ash samples from their POTWs. Assuming an average of two samples analyzed per POTW, the analysis for each POTW is worth about two thousand dollars. The results will be provided to the POTWs in a joint NRC/EPA report.

10. Confidentiality of the Information
Each POTW will be assigned a code number to ensure confidentiality. Only NRC individuals with a need to know will be given access to the identity of a POTW if an NRC or Agreement State licensee is likely responsible for elevated levels of radioactive materials at a POTW and follow-up testing becomes desirable. At the conclusion of the survey, an industry organization such as AMSA will receive the code book with the identity of the POTW code numbers.

11. Justification for Sensitive Questions
There will be no survey questions of a sensitive nature.

12. Estimated Burden and Burden Hour Cost
About 600 POTWs will be asked to complete the survey questionnaire. Because the survey is voluntary (and thus not all POTWs will respond to the questionnaire), additional POTWs may have to be surveyed to find enough appropriate facilities to be sent sample collection packages. The estimated time to complete the questionnaire is 1 hour. For 600 POTWs, the estimated burden would be 600 hours.

The survey was tested at nine POTWs to assess the questionnaire and sampling and analysis procedures. The test cases also gave a better basis for estimating the actual burden cost. Most of the POTW test cases took 20 minutes or less to complete the questionnaire; larger facilities required two hours to develop a list of zip codes for their collection system. Our original estimate of the time needed to complete the questionnaire was 2 hours; however, based on the results of the test cases, the revised estimated time to complete the questionnaire is 1 hour. For 600 POTWs, the estimated burden to respond to the questionnaire is 600 hours.

The questionnaire to the POTWs will ask for the zip codes for its collection system so that we can identify the licensees associated with each POTW. NRC will request from each Agreement State (depending on its information retrieval capabilities) (a) a list of licensees by zip code or (2) the list of all licensees (so that NRC can determine the licensees in the zip codes for the POTW collection systems). For 30 Agreement States at 8 hours per State, the estimated burden would be 240 hours.

Based on the method discussed in Items B.1 and B.2, about 300 POTWs will be sent sample collection packages. Each POTW will collect an average of two samples (one for each disposal practice). The estimated time for each POTW to collect and return the two samples is 6 hours. For 300 POTWs, the estimated burden is 1800 hours.

Total estimated burden = 600 + 240 + 1800 hours = 2640 hours

Estimated cost = 2640 hours x $120/hour = $316,800

13. Estimate of Other Additional Costs
There will be no additional cost burdens (beyond the cost of the hour burden discussed above) to the POTWs. There is no need to purchase additional equipment or laboratory support. For respondents to this survey, it is most likely that purchases of equipment and services were made (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

14. Estimated Cost to the Federal and State Governments
The cost to the Federal Government for this one-time-only survey includes costs for contractor support for the radioanalytical analysis, NRC and EPA Headquarters staffs, and Agreement State support.

Cost for Radioanalytical Support
Radioanalytical support will be provided by NRC's contractor, ORISE and EPA's NAREL. ORISE will assemble and distribute sample collection packages to about 300 POTWs. ORISE and NAREL will each analyze half the samples to determine the activity of radionuclides. No purchase of computers, software, or monitoring or testing equipment is needed. Monthly letter reports will be prepared containing the results of the analysis.

Tasks

ORISE Cost

EPA/NAREL
Cost

Assist NRC and EPA in development of the survey, including test cases

50,000

12,000

Phone calls to POTWs, mailing sample collection packages, and providing return postage

25,500

0

Analyze samples

146,400

110,550

Report preparation

16,100

9,750

Sample disposition

0

5,000

Subtotal

238,000

137,300

Federal Government Cost
NRC Headquarters staff will coordinate the development of the survey and analyze the survey results. NRC, EPA, ORISE, and NAREL staff will write and publish the results as a joint NRC/EPA report. There will also be costs incurred by NRC and EPA for contract management and general oversight of the work scope.

2 FTE x 2080 hours x $120/hour = $499,200

The cost for a statistical consultant to support the analysis is about $100,000.

Total estimated survey cost for the Federal government
Lab costs + Federal costs + statistical consultant =
$238,000 + $137,300 + $499,200 + $100,000 = $974,500

Agreement State Cost
See Item 12, Estimated Burden and Burden Hour Cost, above.

15. Reasons for Changes in Burden or Cost
This is a new collection. There are no changes in burden or cost.

16. Publication for Statistical Use
NRC, EPA, ORISE, and NAREL will jointly write a report summarizing the survey results. The database in the report will include, at a minimum, lists of radionuclide concentrations for each POTW (coded to disguise the names of the facilities), geographic region, and disposal practice.

The project is to be completed within two years of approval by OMB. Questionnaires will be sent to the POTWs within two months of OMB approval, sample collection will take place over a one-year period, from 6 to 18 months after OMB approval, and the final report will be published two years after OMB approval.

17. Reason for Not Displaying the Expiration Date
Not applicable. The expiration date will be displayed.

18. Exceptions to the Certification Statement
There are no exceptions.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The desire is to provide a national survey of high probability occurrences of elevated levels of radioactive materials in sewage sludge and ash. Even though this is a voluntary survey and may lack the number of samples needed to generate a comprehensive national profile, the survey will sample POTWs in all regions of the country and for a variety of NRC/Agreement State licensees. The collection of information will employ statistical methods.

1. There are approximately 11,000 POTWs in the United States that use at least secondary waste water treatment and are not simple pond treatment systems with only periodic solids cleanout. For the 1980s national survey, EPA developed categories based on flow rate and sewage sludge use and disposal practice. For the planned NRC/EPA survey, questionnaires will be sent to (1) POTWs associated with types of NRC licensees that have the highest potential to discharge radioactive material into the sewer system, (2) many of the POTWs with incinerators (these will be more heavily sampled because concentrations of radioactive material are expected to be higher in ash than in sludge), (3) POTWs in all geographic areas of the contiguous United States, and (4) POTWs requested by States and ISCORS agencies.

The survey questionnaire will ask the POTW operator to list the zip codes served by its collection system. Using this information, NRC will identify those licensees associated with each POTW that have the potential to dispose of radioactive material into its collection system.

There are currently approximately 7,000 NRC licensees and 15,000 Agreement State licensees in the United States (including Alaska and Hawaii, the District of Columbia and Puerto Rico). About half of these facilities use radioactive materials in the form of sealed sources (i.e., contained within a metal or other material casing); radioactive material in sealed sources cannot be disposed into the sewer system. Facilities that use material in unsealed form are predominantly hospitals, clinics, radiopharmacies, research and academic facilities, fuel cycle facilities, and research reactors. Nuclear power plants are not allowed to discharge to sewer systems.

2. The selection of the 300 POTWs to sample will be based on the results of the questionnaire survey. The questionnaire responses will be grouped into several categories and a random sample will be selected from each category. The categories we expect are

• Types of NRC licensees (e.g., industrial, academic, medical)
• Geographic area, especially areas of high background radioactive material
• Sludge use or disposal practice (e.g., incinerator ash, landfill)

Potential problems include a low response rate because the survey is voluntary and difficulty in finding sufficient sample respondents for each category.

3. The following actions should lead to improved response rates:

• A short and easy to complete questionnaire
• A cover letter clearly stating the objectives of the data collection effort
• Development of a program to follow up on non-respondents

4. A pilot survey of nine POTWs was executed to test the questionnaire and the sampling and laboratory analysis procedures. As a result of the pilot survey, several changes were made to the questionnaire. For example, a question was added on whether the POTW had previously sampled for radioactive material. If there is a question about the survey results at a specific POTW, and an earlier analysis is available, it may be advisable to compare the two analyses.

As a result of the pilot survey, several changes were made to the sample analysis. For example, the list of radionuclides to be analyzed was refined, and the need for analysis of some samples by both labs was dropped due to the similarity of the test site results at the two labs.

5. Statistician consulted for the statistical aspects of the survey design:

Lee Abramson
U.S. Nuclear Regulatory Commission
301-415-6180


SEWAGE SLUDGE QUESTIONNAIRE

1. GENERAL INSTRUCTIONS
1.1 Introduction

The U.S. Nuclear Regulatory Commission (NRC) and the U.S. Environmental Protection Agency (EPA) request your participation in a joint national survey of the concentrations of radioactive material in sewage sludge (biosolids), ash, and related byproducts.

NRC regulations in 10 CFR 20.2003 currently permit licensee disposal of certain specific quantities of soluble radioactive material into a sanitary sewer system. The EPA regulation that addresses the use or disposal of sewage sludge (40 CFR Part 503) currently does not address radionuclides.

This survey will help determine the adequacy of the present NRC regulations addressing the discharge of radioactive material to the sanitary sewer system. It will also respond to a recommendation from the General Accounting Office (GAO) to determine the extent to which radioactive contamination in sewage sludge, ash, and related byproducts is occurring (GAO report, "Actions Needed to Control Radioactive Contamination at Sewage Treatment Plants," May 1994).

1.2 When and Where to File
Please return the completed questionnaire within 30 days of date of receipt to the address below:

Phyllis Sobel
Mail Stop T-7F27
U.S. Nuclear Regulatory Commission
Washington, DC 20555

1.3 Reporting Period
Please report information for the last 12 months or the last calendar year.

1.4 Further Information
If you require assistance in completing this questionnaire, call Robert Bastian, EPA, at 202-260-7378, or Phyllis Sobel, NRC, at 1-800-368-5642-extension 6714, weekdays, between 8 a.m. and 4 p.m., EST.

2. GLOSSARY OF TERMS
End-products are the materials that leave the treatment facility or are disposed of onsite after all processing is completed (e.g., ash from incineration, digested liquid or dewatered cake, dried pellets, compost).

Incineration is the combustion of matter in sewage sludge by high temperatures in an enclosed device.

Land application is the application of sewage sludge to land to either condition the soil or fertilize crops or other vegetation.

Monofills are landfills where only sewage sludge is disposed. Monofills include trenches and area fills.

Municipal solid waste landfill is a landfill that receives household waste, and that is not a land application unit, surface impoundment, injection well, or waste pile. Such a landfill may be publicly or privately owned.

Sewage sludge is solid, semi-solid, or liquid residue generated during the treatment of domestic sewage in a treatment works. Sewage sludge includes, but is not limited to: domestic septage; scum or solids removed in primary, secondary, or advanced wastewater treatment processes; and material derived from sewage sludge. Sewage sludge does not include ash generated during the incineration of sewage sludge or grit and screenings generated during preliminary treatment of domestic sewage in a treatment works.

Surface disposal is the placement of sewage sludge on an area of land for final disposal. It includes monofills, surface impoundments, lagoons, waste piles, and dedicated disposal sites. It does not include treatment and storage of sewage sludge, although placement on land for longer than 2 years is considered surface disposal unless the site owner/operator retains written records demonstrating that the operation constitutes a treatment or temporary storage site.

Treatment works is either a Federally owned, publicly owned, or privately owned device or system used to treat (including recycle and reclaim) either domestic sewage or a combination of domestic sewage and industrial waste of a liquid nature.

Use or disposal includes: land application of bulk sewage sludge, land application of sewage sludge sold or given away in a bag or other container, surface disposal, disposal in a municipal solid waste landfill unit, incineration, or any other use or disposal practice (e.g., vitrification, use in asphalt or brick production, etc.).

SECTION I. TREATMENT WORKS IDENTIFICATION INFORMATION
Mailing Label

Name of the treatment works and physical location (which may differ from the mailing address):

Mailing address of the treatment works (if different): _____________
_____________________________________________________

Name, title, and telephone number of the person who should be contacted regarding information on this questionnaire: ___________________
_____________________________________________________

Name, title, address, and telephone number of the person who should be sent the sample collection package: _________________________
_____________________________________________________

SECTION II. GENERAL TREATMENT WORKS INFORMATION

1. Indicate below the level(s) of wastewater treatment achieved by this treatment works. (Mark X for all that apply.)

a. ____ Primary treatment
b. ____ Secondary treatment
c. ____ Advanced treatment

2. Provide the annual average daily total flow rate for the last 12 months or the last calendar year (the total volume of wastewater treated by the treatment works in one year divided by 365). Use Gallons per Day (GPD) if your total daily flow rate is less than 10,000 GPD, or use Million Gallons per Day (MGD), but not both.

_______________________________ GPD or MGD (Circle one) over the last 12 months or last calendar year (circle one)

3. List the zip codes served by the collection system for this treatment works. This information is needed so NRC can identify licensees that can potentially discharge to your collection system. A list of these licensees will be sent to you in return for providing this information.

4. Identify the sewage sludge treatment process(es) used at your treatment works. (Mark X for all that apply.)

a. ____ Treatment works did not process sewage sludge in the last 12 months or the last calendar year.
Explain: ___________________________________________

b. ____ Thickening

c. ____ Mechanical dewatering by ______________________
(Please fill in process(es) used.)

d. ____ Heat treatment/wet air oxidation

e. ____ Aerobic digestion

f. ____ Anaerobic digestion

g. ____ Composting

h. ____ Lime stabilization (Class B)

i. ____ Alkaline Stabilization (Class A)

j. ____ Air drying beds

k. ____ Heat drying/Pelletizing

l. ____ Sewage sludge treatment/storage lagoon(s)

m. ____ Sewage sludge storage bins or piles

n. ____ Incineration

o. ____ Other sewage sludge treatment processes (Please specify.)
__________________________________________________________

5. Check the boxes below to indicate the sewage sludge use or disposal practice employed at your facility or by others using/disposing of your sewage sludge or ash. Also describe the product as one of the following: liquid, sludge, cake (dewatered sludge), compost, dried pellets, incinerator ash, or other. Note if the product is stored onsite before ultimately being disposed offsite; and if the product is stored onsite, the time stored onsite.

a. ____ Land application. Product description:
__________________________________________________________
__________________________________________________________

b. ____ Surface disposal (permanent piles, lagoons, sludge or ash monofills). Product description: __________________________
___________________________________________________________

c. ____ Disposal in municipal solid waste landfill. Product description:
___________________________________________________________
___________________________________________________________

d. ____ Transfer of your sewage sludge or ash to another facility for use or disposal. Product description:
___________________________________________________________
___________________________________________________________

Identify the facility (type, location):
___________________________________________________________

e. ____ Other use or disposal practice. Product description:
___________________________________________________________

Describe practice:
___________________________________________________________

6. What are the primary sources of drinking water for your community? Check more than one, if applicable.

a. ____ Municipal water supply from surface water source(s)
b. ____ Municipal water supply from groundwater well(s)
c. ____ Private wells
d. ____ Private water supply from surface water source(s)

7. Does your wastewater collection system receive discharges of drinking water treatment residuals? ____ Yes ____ No

8. Does your wastewater collection system include combined sanitary and storm water sewers? ____ Yes ____ No

9. Do you receive sludge from other wastewater treatment facilities for processing at your facility? ____ Yes ____ No

10. Do you receive septage for processing at your facility? ____ Yes ____ No

11. What percentage of the annual average daily total flow rate (response to question 3) is industrial flow? __________ Percent

12. Have you ever tested for radioactive materials in your sewage sludge? ____ Yes ____ No

13. Do you have more than one final sewage sludge production facility location? ____ Yes ____ No