ML20137Q588
| ML20137Q588 | |
| Person / Time | |
|---|---|
| Issue date: | 04/09/1997 |
| From: | Pugh N NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Raju Patel AFFILIATION NOT ASSIGNED |
| References | |
| FOIA-97-66 NUDOCS 9704110048 | |
| Download: ML20137Q588 (2) | |
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[. I,, Rt SPONSE T YPE , RESPONSE TO FREEDOM OF I "= I x I PARtiat (2nd) i INFORMATION ACT (FOIA) REQUEST o^ u FR 0 9 W ., 3,, e me QOCYL t NUMdk HtSt (If wpineble) j Rt OULSit R ! Raju H. Patel PART l.-AGENCY RECORDS RELE ASED OR NOT LOCATED (See checked boses) No cgency records subject to the request have been located. No additional agency records subject to the request have been located. Requested records are available through another public distribution program. See Comments section. Agency records subject to the request that are identified in AppendixMi are a! ready available for public inspection and copying at the NRC Public Document Room. 2120 L Street, N.W.. Washington, DC. Agency records subject to the request that are identified in Appendix {es) C are being made available for pubhc inspution and copy *ng
)( at th) NRC Publ+c Document Room,2120 L Street. N.W., Washington, DC, in a folder under this FOI A number.
Th3 nonproprietary version of the proposal (s) that you ar; reed to accept m a telephone conversation with a member of rny staff is now being made available for public inspection and copying at the NRC Public Document Room,2120 L Street, N W., Washington, DC, in a folder under this FOiA number. Agerey records subject to the request that are identified in Appendix (es) may be inspected and copied at the N RC Local Public Document Room identified in the Comments section. Enclosed 6s mformation onhow you may obtam access to and the charges for copying records located at the NHC Public Document Hoom,2120 L Street, N W., Washington, DC.
)( Agency records subject to the request are enclosed.
Records subject to the request have been referred to another f ederal agencybet) for review and direct response to you. Fees You wi ll be billed by the N RC for fees totahng 5 You will receive a refund from the NRC in the amount of $ in view of NRC's response to this request, no further action is be ng taken on appeal letter dated , No. PART 11. A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE C rtrin information in the requested records is being withheld from public disclosure pursuant to the exemptions described in and for the reasons stated in Ptrt 11,8, C, and D. Any released portions of the documents for which only part of the recond is being withheld are being made available for public insp:ction and copying in the NRC Public Document Hoom,2120 L Street, N W., Washington, DC in a folder under this FOIA number. COMME NTS The records identified on enclosed Appendix C are responsive to your request. Copies of these records are enclosed.
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Re: FOIA-97-9066 APPENDIX C RECORDS NAINTAINED IN THE PDR UNDER THE ABOVE REQUEST NUMBER NUMBER DATE DESCRIPTION /PAGES
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- 1. 11/9/93 Letter to M. Fitzgerald from M. Maisch 4 with enclosure, (14 pgs.).
- 2. 8/17/84 Memo for D. Nussbaumer from W. Mills, subject: " Request to Review Current Regulations Governing Discharges to Sanitary Sewers," (2 pgs.).
- 3. 10/22/84 Memo for R. Minogue from T. Murley, subject: " Request to Review Current Regulations Governing Discharges to Sanitary Sewer Systems," (2-pgs.).
, 4. S/94 GAO Report Nuclear Regulation - Action Needed to Control Radioactive Contamination at Sewage Treatment , Plants, (33 pgs.). ' i s C -
i Patterson Associates, Incorporated l l VIA FACSIMILE - MM caneno: 9'7-0044 February 21, 1997 g-ACUOnOft #u ~ A RelatedCase: Mr. Russell Powell Chief - FOIA/LPDR Branch United States Nuclear Regulatory Commission Mail Stop T6D8 Washington, D.C. 20555-0001
Dear Mr. Powell:
This letter is a request to you that under the Freedom of Information Act (FOIA), I would like to review all available Nuclear Regulatory Commission (NRC) associated documents on the following two issues: i
- 1. Documentation regarding development of solubility criteria for liquid effluent releases to sanitary sewerage, as regulated l under 10 CFR Part 20. I
- 2. Documentation regarding the NRC's position concerning a municipality regulating radioactive discharges to the sanitary '
l sewer on the basis of protecting economic interests. For example, see the enclosed November 9, 1993 NRC letter to Mr. Hugh McFadden, City Attorney, Laramie, Wyoming, I communicating this position in response to the municipality's inquiry. Please include all NRC responses to such municipality inquiries. If you have any comments or questions regarding the above, please l call. Cordially yours, I (LS Raju . Patel Project Engineer RHP/jg Enclosure cc: J. Patterson C. Petropoulou 960039.124 r.3.11 39 SOUTH LA SALLE STREET
- SUITE 917
- CHICAGO, ILLINOIS 60603-1008
- PHONE (312) 3721100
- FAX (312) 372 7188
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wu ecvo8. o.c. rms-o=, i NOV 0 s 19S3 i Mugh B. McFadden, Esq. , Laramie City Attorney l Corthell and King 221 South Second Street l Box 1147
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l Laramic, Wyoming 82070
Dear Mr. Mc,
Tadden: ) In your; letter to the NRC of September 9, 1993"Can you requested an a municipality i expression of vivws on the following question: discharge of radioactive
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. lawfully regulate or, prohibit the materiels into its wasteveter treatment system,.with or without an industrici pretreatment progran mandated by EPA?" We understand the context of your question to be a city plan to begin producing l sludge in 1996, and the related facts that Laramie has a hospitel l vith a nuulear r.edicine department and that the University of l Wyoming does some research with radioisotop'es..
By necessity our response has to be general, li=ited to the , principles of law that govern thisThe agency and its relationships prl=ary legal principle is l vith states and municipalities. that the Atomic Energy Act of 1954, as amended, occupies the field with respect to issues of radiation protcotion in the use of source, byproduct, and special nucicar material, es these terms crc defined in the Act. If,. however, the basis for the state or local. governmental action is something other than the protection of workers' and public from the health and safety hazards of regulated naterials, the accion is not preempted. See, e.g. Pacific ces end
, Electric Co. v. State Enercv ResourcesAs conservation a consequenceand Develooment of the Atomic commisfica, 461 U. S. 190 (1983).
Energy Act occupying the field dual Federal-State regulation is of the not radiation hazards associated with use of these caterials allowed.. See 10 C.T.R. 8.4 and 10 C.F.R. Part 150. extension of these general Federal preemption However the principios to actions of state(say or Local government entitics as owners of PoTWs) i in their additional' proprietary, capacity issues Ohich have not been resolved definitely.%raMore ses important here, however/ is that if the city of Laramie werelto { have sound reasons, other than radiation protection, to require l J pretreatment 'of vastes from such the hospital or university pretreatment vould not to falleliminate afoul of or reduce radioactivitz,Thus, the Atomic Energy'Ac,t. NRC regulations that allow users of , j regulated materials to' discharge to sanitary sewers do not compel ' a vaste water trea'tment operator to accept those radioactive naterials & We note, however-, that the materials regulated by this agency' ar$ exempted from regulation under the Federsi vster l4 l DJ% zg. ggt}I3h
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~ . Pollution Control Act and the Resource Conservation and Recovery i Act. Thus pratrontuont to clininato or reduce the regulated isotopes would not be regu, ired by these environmental statutes.
In January of 1994 ncv rules take ef fect in 10 C.F.R. Part 20 that will limit the discharge to sanitary sever syste=s to only those licensed materials which are soluble in vator or which ar's readily dispersible biological material (such as may be fou.nd in e university research laboratory), see 10 C.F.R. 20.2003.. Finally, there is no limit on radioactivity that may be discharged to a sanitary sewer in excreta rrc= patients undergoing medical diagnosis or therapy. You may wish to consult with the radiation cafety officers cf the hospital and. univorcity to gain an understanding of the technical characteristics of the isotopes used in these institutions and their fate in vaste veter treatment. The problem of certain radioactive matorials ending up in the sludges from vaste vator treatment, or in ash from the incineration of ciudges, is well known to the staff of the NRC. '. A generic study is underway to understand the dimensions of the issue and whether it poses a particular health 'and safety matter that needs to be dealt with by more specific regulation. The Atomic Energy Act encourages the useful and beneficial uses of radioisotopes in medicino and research, at the same time the NRC is highly cognizant of the health risks to third parties that may result from such uses. We believe that our regulation is appropriately balanced between the nood to protect the public from the undue hazards of the regulated naterials and also to allow their beneficini use in a controlled nanner., I hope that this response vill be helpful to you. If you have any further questions you may call either me at area code 301-504-1740, or Robert L. Fonnor at area code 301-504-1643. gineerely o ro, Martin G. Halsch Deputy General Counsel for ; Licensing and Regulation l e
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' wasmwoToN, o.c. sosssaoi NOV 0 91993 Martin J. Fitzgerald, Esq. Associate General Counsel United States General Accounting Office Washington, D.C. 20548
Dear Mr. Fitzgerald:
In your letter of october 6, 1993, addressed to the General Counsel of the Nuclear Regulatory Commission, you requested our response to a number of questions regarding the concentration of radioactive materials in publicly owned treatment works. Your questions and our responses are contained in the enclosure.to this further questions, please call me at letter. If .you have (301) 504-1740, or Robert L. Fonner at (301) 504-1643. e Sincerely Martin G. Malsch Deputy General Counsel for Licensing and Regulation
Enclosure:
As stated cc: W. Parler R. Bernero b Do h< i _q_3-$:-oClo4rl:3 (o y p . d//
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sampling and testing may be done as the consequence of an ) inspection where the NRC inspectors take samples in order to , ascertain regulatory compliance or need for regulatory action. The NRC inspectors use standard sampling techniques and normally split samples with the af fected person. The stimuli for such inspections or investigations are varied. They may be routine, stem from l allegations,. or result from survey overflights based upon other evidence of contamination'in the area being surveyed. The NRC j bears the cost of its own testing, unless, in the case of licensees, the underlying inspection is subject to a fee pursuant to 10 CFR Part 170. 1 l l OUESTION 3. Does the NRC have the authority to require that the POTWs periodically report to the NRC any. buildup of radioactive materials at their facilities? If so, 1 1 under what authority? l l , ANSWER The NRC has authority under section 161c. of the Atomic Energy Act of 1954, as amended, to obtain such information as the Commission ! may deem necessary to assist it in exercising any authority under ) i the Act, enforcement or administration of the act, or any . I i regulation or_ order issued thereunder. Pursuant to 10 CFR 2.204 a l j Demand For Information may be issued to a licensee or an unlicensed i i i 1
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9 a- 3 person. If the POTW is a licensee, section 161o. also provides
. authority to require reports.
OUESTION 4. Does the NRC have any authority to regulate the concentration,of radioactive materials _ subject to the Atomic Energy Act at a POTW if the not of a concentration of such materials is licensable amount? Please explain. ANSWER The NRC has no general regulations establishing sig minimis quantities or concentrations of material not subject to regulation. However, certain kinds and quantities of radioactive materials have been exempted by rule from regulation when possessed by unlicensed ] persons. For example, 10 CFR 40.13 establishes exemptions for source material when-it does not exceed .05% by weight of the : compound or mixture in which it is found, in bulk untreated ore, in gas lamp mantles, and certain metallurgical alloys and l counterweights. Exempt quantities and concentrations of byproduct j material are limited to specific items, such as smoke detectors, l which are manufactured or distributed under license. In these cases, the safety of the product in the hands of unlicensed persons j
- has been carefully evaluated. Thus, the concept of " licensable amount" is inappropriate. The circumstances of each situation have 1 to be reviewed against the codified regulations to determine if the I
regulatory requirements for exemption have been met. If those i
- 4 the material remains subject to requirements have not been met, regulation.
OUESTION 5. Does the NRC have the authority to require that its licensees notify the POTWs prior to the disposal of any radioactive materials? If so, under what authority? What are the pros and cons of such a requirement? ANSWER The NRC has authority under section 161o. of the Atomic Energy Act ) of 1954, as amended, to require licensees to submit such reports as It is not may be necessary to effectuate the purposes of the Act. possible without considerable study of the implications of such a requirement to identify -eaningful pros and cons. reporting ! However, the agency must comply with the requirements of the l Paperwork Reduction Act in establishing the need for such reporting. One example may illustrate the complexity of the issue. Currently excreta from patients undergoing diagnostic or therapeutic treatment with isotopes (e. g. iodine 131 for certain thyroid conditions) may be flushed to sanitary sewers without restriction. Implementation of a reporting requirement for such occurrences may be difficult to achieve.
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~OUESTION 6.- What authority, if any, do the POTWs have to refuse licensees to make disposals of to allow _ NRC radioactive materials into their systems? Please explain.
I ANSWER A recent letter to the city attorney for Laramie, Wyoming, discusses the issue raised in this question. A copy of the letter {
-is attached. As the letter explains, a POTW may under certain j i
i circums'tances refuse to allow disposals of radioactive materials into the treatment system. l 1 OUESTION 7. To address the problem of excessive concentrations of radioactive materials at POTWs, how should the I NRC and the Environmental Protection Agency coordinate their efforts? ANSWER l The NRC and the EPA have established a crordinating committee of senior of ficials to discuss matters of mutual concern on an ongoing basis. A Memorandum of Understanding between the agencies, dated March 16, 1992, establishes the basic charter for cooperation between the agencies. A copy of the MOU is attached. This matter has not been the subject of discussions by the coordinating committee and there is no reason to believe that lack of coordination has contributed to the type of problem suggested.
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.6 Nontheless,~both.NRC and EPA have a regulatory interest in' waste water treatment sludges and incinerator ash and this matter will be placed on the committee's agenda.
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'i ?('S* Le pj W ASHINGTON, D.C. 20M54001 NOV 0 9153 Hugh B.'McFadden, Esq.
Laramie City Attorney Corthell and King 221 South Second Street ! P. - O. Box 1147 Laramie, Wyoming 82070 t
Dear Mr. McFadden:
1993 you requested an In your letter to the NRC of September 9, "Can a municipality expression of views on the followingthe question: discharge of radioactive lawfully regulate or prohibit materials into its wastewater treatment system, with We or without understand an industrial pretreatment program mandated by EPA?" the context of your question to be a city plan to begin producing sludge in 1996, and the related facts that Laramie has a hospital with a nuclear medicine department and that the University of Wyoming does some research with radioisotopes. limited to the By necessity our response has to be general, princip,les of law that govern this agency and its relationships with states and municipalities. The primary legal principle is that the Atomic Energy Act of 1954, as amended, occupies the field with respect to issues of radiation protection in the use of source, byproduct, and special nuclear material, as these terms are 4 Act. If, defined in theaction is however, the basis for the state or local something other than the protection of governmental workers and public from the health and safety hazards of regulated materials, the action is not preempted. See, e.g. Pacific Gas and Electric Co. v. State E1Lezgy Resources AsConservation a consequence and ofDeveloDment the Atomic . Commission, 461 U. S. 190 (1983). l Energy Act occupying the field dual Federal-State regulation is of the not l radiation hazards associated with use of 8.4 and 10 C.F.R. Part 150. these materials allowed. See 10 C.F.R. general Federal preemption However the extension of these l principles to actions of State(say or Local government as owners of POTWs) entities in raises l their proprietary capacity More additional issues which have not ifbeen is that the resolved definitely. city of Laramie were-to important here, however, other than radiation protection, to require 4 have sound reasons, pretreatment of wastes from the hospital or university to eliminate or reduce radioactivity, such pretreatment would not fall afoul of the Atomic Energy Act. Thus, NRC regulations that allow users of regulated materials to discharge to sanitary sewers do not compel a waste water treatment operator to accept those radioactive materials. We note, however,from that the materials regulated by this regulation under the Federal Water agency are exempted 4 48traqo #
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Pollution. Control Act and the Resource Conservation and Recovery Act. Thus pretreatment to eliminate or reduce the regulated isotopes would not be required by these environmental statutes. In January of 1994 new rules take effect in 10 C.F.R. Part 20 that will limit the discharge to sanitary sewer systems to only those licensed materials which are soluble in water or which are readily dispersible biological material (such as may be found in a university research laboratory), see 10 c.F.R. 20.2003. Finally, there is no limit on radioactivity that may be discharged to a sanitary sewer in excreta frcm patients undergoing medical diagnosis or therapy. You may wish to consult with the radiation safety officers of the hospital and university to gain an understanding of the technical characteristics of the isotopes used in these institutions and their fate in waste water treatment. The problem of certain radioactive materials ending up in the sludges from waste water treatment, or in ash from the incineration of sludges, ic well known to the staff of the NRC. A generic study is underway to understand the dimensions of the issue and whether it poses a particular health and safety matter that needs to be dealt with by more specific regulation. The Atomic Energy Act encourages the useful and beneficial uses of radioisotopes in medicine and research, at the same time the NRC is highly cognizant of the health risks to third parties that may result from such uses. We believe that our regulation is appropriately balanced between' the need to protect the public from the undue hazards of the regulated materials and also to allow their beneficial use in a controlled manner. I hope that this response will be helpful to you. If you have any further questions you may call either me at area code 301-504-1740, or Robert L. Fonner at area code 301-504-1643. Sincerely o rs, Martin G. Halsch Deputy General Counsel for Licensing and Regulation I
.l GUIDING PRINCIPLES FOR EPA /NRC COOPERATION AND DECISIONMAKING !
Introduction t The Environmental Protection- Agency (EPA) and the Nuclear j Regulatory Commission (NRC), in recognition o" a mutual commitment ; 4
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to the effective and efficient protection of public health and safety and the environment, have developed this Memorandum of Understanding in order to establish a basic framework within which EPA and NRC will endeavor to resolve issues of concern to both agencies that relate to the regulation of radionuclides in the environment. au . l The goal of this Memorandum of Undarstanding is to foster i cooperation in fulfilling the responsibilities of each agency to : ensure protection of the public health and safety and the ! 3 environment in accordance with existing agency responsibilities and 1 authorities. 4-Princioles ; EPA and NRC, in carrying out the respective responsibx11 tics of the two agencies in the regulation of radionuclides, will strive to:
- 1. Base regulatory decisions on a determination that such ;
actions will result in a substantial reduction of i significant risk to the public health and safety and the environment, and in making such decisions consider, to the extent permitted by law, the importance of the risk 4 reductions to be achieved when compared to other 4 radiological risks already subject to existing j regulations, the overall economic impact on NRC~ licensees of additional regulatory requirements to achieve such reductions, and pursue the most ef ficient, cost-effective course in the regulation of those licensees. , i 2. Focus agency priorities on those significant safety and , environmental problems subject to the authority of both agencies that offer the greatest potential for
- substantial risk reduction;
- 3. Avoid unnecessary duplicative or piecemeal regulatory ,
requirements for NRC licensees, consistent with the legal responsibilities of the two agencies, and ensure that standards and regulations, when issued, can be effectively implemented; and ' F 1 ( e.+- .-- -m- -- -- - . _ , . - < - . - - -
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Effectively and responsibly carry out the provisions of
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Reorganization Plan No. 3 of 1970. Under the Plan, EPA .! issues generally applicable environmental limits on , radiation exposure or levels, or concentrations. or quantities of radioactive materials, . in the general - environment outside the boundaries of locations under the control of persons possessing or using radioactive , materials, and NRC implements these standards by the use i of its licensing and regulatory authority. Imolementation Guidance A. Scope : For certain facilities or materials licensed or regulated by the NRC, EPA is required by statute to develop environmental standards for radionuclides which are applicable directly to NRC-regulated facilities or materials. For example, EPA is required to develop . ; generally applicable environmental standards for offsite releases from radioactive material in high-level waste repositories under the Nuclear Waste Policy Act. For other program activities, such standards are authorized but, depending sometimes on the circumstances, are not legally required. With the exception of Section C,,below, this Memorandum of Understanding is intended to f address issues associated with both types of standards. Section C applies according to its terms where EPA standards are not legally mandated. This MOU does not apply to matters arising under RCRA or CERCLA. B. General Each_ agency will keep the other generally informed of its relevant plans and schedules regarding such activities, will respond to the
- other agency's requests for information to the extent reasonable and practicable, and will strive to recognize and ameliorate to the
- extent practicable anticipated problems with regard to implemen- '
L tation and consistency with other program activities. ) Each agency will deal with the other in a spirit of cooperation to achieve the goals of this Memorandum of Understanding. Agency j management will endeavor, to the maximum possible extent, to
- resolve informally and in a timely manner those differences identified as a result of the procedures contained in this Memorandum of Understanding. If differences cannot be resolved,
, the respective General counsels of each agency will arrange for the , matter to be presented by the necessary parties to the heads of both agencies for resolution.. I
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. 3-Each agency will keep the other fully informed of its priorities for the development of regulations and will endeavor to develop a common understanding of the priorities and schedules for resolution, with the highest priorities accorded to initiatives which offer the greatest potential for significant risk reduction.
If both agencies agree, in accordance with these principles and guidance, that duplicative regulation in a particular area is undesirable, but nevertheless is required by law, then the agencies will cooperate in considering and, if appropriate, supporting legislative changes. C. Governing Criteria and Procedures This Section applies to the issuance of regulations for releases applicable to NRC regulated facilities or activities for releases into the environment of source, byproduct or special nuclear materials' under the Clean Air Act. It also applies to the issuance of such regulations under the Atomic Energy Act and other provisions of law which may give rise to duplication of effort and overlapping regulation of NRC regulated facilities or activities, but only to the extent issuance of such standards is authorized but not legally mandated. Subject to the above, EPA and NRC agree as ~ follows:
- 1. Criteria e EPA's decisions not to irpose emission l
standards for hazardous air pollutants under the clean Air Act for NRC licensed materials or facilities will, in accordance with 112(d)(9) of the Clean Air Act, be based upon a determination that NRC's regulatory program provides an ample margin of safety to protect the public health. Similarly, EPA's decisions l to impose or not impose other regulations regarding NRC licensed materials or facilities l will be btsed upon a determination as to l whether NRJ's regulatory program achieves a sufficient level of protection of the public health and environment. / This determination may be influenced by particular risk reduction or risk prevention goals being pursued and ! this Memorandum of Understanding does not ! reflect agreement on such goals at thir, time. l Ideally, agreement on risk reduction or l prevention goals for radionuclides will be l reached pursuant to paragraph D. below but in l a particular case where EPA and NRC cannot l agree on such goals, this Memorandum of
Understanding is withod prejudice to - EPA , deciding to proceed. with regulation, without : NRC concurrence, based upon an EPA inability , i
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to find that NRC's- program provides a sufficient level of protection. e EPA and NRC will jointly seek to minimise un- ; 4
- necessary duplication of effort and over- .
4 e lapping regulation of NRC-licensed materials <
! and facilities. '
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- 2. Procedures: In developing' regulations in accordance with its i authorities, if EPA, after finding that NRC's regulatory
- program fails to provide a sufficient level of protection of j the public health and safety or the environment, identifies an a area where it believes that EPA regulation applicable to NRC licensees regarding radionuclides may be necessary, EPA will, j j before developing and proposing rules in the Federal Register, f informally and promptly .. inform the NRC of the basis for its position. If NRC believes that such direct regulation of its 1
j j licensees by EPA is unnecessary, the two agencies will j endeavor to resolve any issues, including consideration of information from NRC regarding the level of protection j achieved by NRC regulatory programs and any necessary ] modifications to NRC's regulatory program, so that duplicative ) 4 regulation and implementation are avoided. Decisions rendered pursuant to this paragraph will fully consider the
- implementation of existing regulatory programs in assessing the level of protection being achieved by regulated !
facilities. Final EPA conclusions on whether EPA will impose j
- regulations applicable to NRC-licensed materials or - I facilities, and final NRC conclusions on whether NRC will i develop modifications to its program, will be accomplished in a public process based upon a full and public record. Any decision made pursuant to this memorandum is subject to review and modification based upon actual experience with its implementation. l Similarly, if NRC undertakes the development of new regu-l lations that would affect the level of protection of public l
health and safety and the environment related to an area where , EPA has authority to issue regulations applicable to NRC l
- licensees, or if NRC undertakes any rulemaking or other l regulatory activity to fulfill its agreements made pursuant to '
this Nemorandum of Understanding, NRC will promptly and informally notify and-consult with EPA before developing and
! proposing rules in the Federal Register, and before any final decision by the Commission on the proposal. l i
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i Where alther agency is developing new regulations' for radionuclides in an area not covered by an existing regulatory program, the agencies will, before proposing new regulations,
. consult conoorning what the proper division of responsibility should be.
D. Risk _ Assessment l In carrying out this Memorandum of Understanding, the agencies will , actively explore ways to harmonize risk goals and will cooperate in developin a mutually agreeable approach to risk assessment methodol les for radionuclides. E. Other Provisions
- 1. Nothing in this Memorandum of Understanding limitc the authority of either agency to exercise independently its authorities with regard to matters that are the subject of this Memorandum of Understanding.
- 2. Nothing in this Memorandum of Understanding shall be desced to establish any right nor provide a basis for any action, either legal or equitable, by any person or class of persons challenging a government action or a failure to act.
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- 3. This Manorandum of Undarstanding will remain in effect until terninated by the written notice of either party i submitted six months in advance of termination.
A/ h* _ M Ivan Selin, Chairman 4filliam K. Risi11,' J.4 minis ator U. 5. Nuciaar Regulatory U. 5. Environnen Prot ction Commission Agency . March 16, 1992 t
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s i E -), t, 7 AUG17ggy a MEMORANDUM FOR: Donald A. Nussbaumer, Assistant Director. State Agreements Program Office of. State Programs FROM: William A. Mills, Chief ' Health Effects Branch Division of Radiation Programs and Earth Sciences Office of Nuclear Regulatory Research l 2
SUBJECT:
i REQUEST TO REVIEW CURRENT REGULATIONS GOVERNING DISCHARGES TO SANITARY SEWERS i I appreciate your memor6ndum of August 1,1984 which requested further reevaluation of our -limits for disposal of radioactive wastes via sanitary l sewers. We are aware that processed sewer sludge has been suggested for use as ' fertilizer and that there has been concern over resultant heavy metal buildup j in the soil. -The two cases that are enclosed with your request document problems with contamination of sewer treatment plants and sludge and indicate that accumulation can occur with radioactive materials. One concern with the current Part 20 is that 120.303 pennits the concentration ; values listed in Appendix B, Table I, Co]umn 2, to be used as limits for release. into sanitary sewerage. The Table I values were calculated to result l in 5 rems / year, or equivalent doses to specific organs, if a " reference man" ; used water at the specified concentration as the sole source of intake of : fluids. The Table I values are approximately 30 times higher than values in l Table 11 applicable to release in effluents to unrestricted areas (620.106). ! 1 In view of this concern, the provisions applicable to release to sanitary i sewerage in the proposed revision to Part 20 include a number of modifications. The concentration limits, specified in Table' 3 of the new Appendix B, were calculated'to result in 0.5 rem / year comitted effective dose equivalent to a reference man, again with the very conservative assumption that sewerage was the only source of fluids. The term "dispersible" would be removed such that radioactive materials released to sanitary sewerage must be "readily soluble" ' in water. While'these proposed changes may not totally resolve such problems, I feel that they are in the regulatory direction requested by the correspondents. The '
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l i i AUG 171984 2-actions taken by the State of Tennessee appear to be compatiable with proposed changes. As to the suggested evaluation of " reconcentration" processes that may be involved with modern sewerage treatment technology and potential exposure pathways from materials present in sewage, we will keep this suggestion in mind but unfortunately we do not have resources available for such an evaluation in the near future. r 4(illiam A. Mills, Chief Health Effects Branch i Division of Radiation Programs and Earth Sciences Office of Nuclear Regulatory Research Distribution: RES 841721 Subj. (C.7.21) Rdg. Cir. Chron. HPeterson WAMills Econti ' KGoller Dross RMinogue ' WCoot < W 8 // G / 8 4 0FC: HEB : HER w : : : : : NAME:HPet n : WAMills : : : : :
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October 22, 1984 MEMORANDUM FOR: Robert B. Minogue, Director, Office of Nuclear Regulatory Research FROM: Thomas E. Murley, Regional' Administrator, Region I
SUBJECT:
REQUEST TO REVIEW CURRENT REGULATIONS GOVERNING DISCHARGES TO
.5ANITARY SEWER SYSTEMS Since receiving a copy of.W. A. Mills' August 17, 1984 memo to D. A. Nussbaumer,
'OSP, on the above subject, a second case involving Am-241 contamination contained in processed sewage sludge has occurred in New York State. (This case is .
described in further detail in the attached PN.) Given this incident and others which have occurred, I request that you reconsider the need to study this problem in' greater detail at an early date. ! The basic issue which these incidents have raised, and which is of concern to , the State of New York in particular at this time, is the potential for I reconcentration of radioactive material in sludge through modern sewage treatment l plant technology and potential new exposure pathways. The proposed changes l planned to Part 20 addressed in Dr. Mills' memo cover part of the concern. They do not, however, address the issue of whether reconcentration processes will lead to similar problems occurring in the future. For example, if material j reconcentrates, as it apparently has in these two cases, and is detected through i licensee or regulatory agency monitoring programs, what action and levels of control should be considered in the disposal of the sludge. Also, if the sludge is incinerated as it was in the Tonawanda case, does this open potential new airborne exposure pathways that may not have been considered when the provisions of Part 20 governing discharges to sanitary sewers were originally developed. l I I am aware that processed sewage sludge from the Metropolitan Sanitary District ' of Chicago has in the past and may continue to be, used as fertilizer on farm land in downstate Illinois. I realize funds for the establishment of new research programs are limited. I l suggest, howeve.r, that you consider assigning some funds to study this problem. Possibly, NRC could conduct an initial evaluation through a RES contract to assess representative exposure pathways from sanitary sewer discharge, and the potential for reconcentration to occur. This effort could also assess the exteint cf the problem, the potential public health and safety significance, and identify whether more detailed and extensive analysis is needed. l I Du 7-Ic"}3^ d
,O c C. .
2
+
. s. Robert.B. Minogue 2 Since this matter has current and future public health and safety ramifications, an early resolution is appropriate'. Please-let me know if you need additional , information. , b Thomas E. Murl Regional Administrator cc: W. Dircks, EDO J. R6e, EDO
- 1 V. Stello, DEDROGR :
K. Goller, RES
- W. Mills, RES '
R. Cunningham, NMSS R. Browning, NMSS , D. Nussbaumer, SP . J. Taylor,'IE utt'Cobb,.IE i l i 1 i
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I l _ United States ; General Accounting Office ; Washington, D.C. 20548 ; i Resources, Community, and Economic Development Division B-255093 May 18,1994 The Ilonorable John Glenn Chairman, Committee on 8 Governmental Affairs United States Senate
'Ihe Ifonorable Mike Synar Chairman, Environment, Energy, and NaturalResources Subcommittee Committee on Govemment Operations llouse of Representatives The Ilonomble Louis Stokes Ifouse of Representatives f
Radioactive matedals are sometimes discharged into municipal se systems by facilities such as hospitals, manufacturers, and decontamination laundries that are licensed by the Nuclear Regul Commission (NRC). This letter responds to your request that w the radioactive contammation of sewsge sludge and the status o at the Northeast Ohio Regional Sewer District's Southerly Sewage Treatment Plant (Southerly) in Cleveland, Ohio. According to N most likely source of radioactive contamination was one of its lice dischargmg radioactive material into the treatment plant. In add because of your concern that such contamination might be 'nore widespread than at the Southerly plant, we agreed to (1) deter whether other sewage treatment plants have been contaminated radioactive matedal, (2) identify what NRC and others are do and monitor the amounts of radioactive materials NRC's discharge that ultimately end up in the sludge and ash (in of treatment plants, and (3) provide information on NRC's actions to determine whether treatment plant workers and the public are exposed to radioactively contaminated sludge and ash. in April M, NRC inadvertently discovered radioactive conta Resultsin Brief the Southerly Sewage Treatment Plant while conducting an ae radiological survey of one ofits licensee's sites. According the radioactive material (cobalt-60) had concen the plant's sludge and ash. Of the 492 soil samples taken, 27 percent, exceeded NRC's acceptable level for radiation 6/4 GAo/RCEDwS4133 Radlonuclides at sewage Treatmen Paw I
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_ -j i ) B-185099 i l l ding areas for radiation, NRC surveying the treatment plant andf factors, the surrounf such aslimited ty risks to treatmen r concluded that the siteite poses disposalof the no health or sa public access to be monitored forto asthe long property. as 60 years,if An on-sNRC offic a offic contaminated soil is permitted. Southerly lated to an onsite o cleanup already spent about $1 million for f Ohio does not approve activities re st of off-site disposal could and for a security fence. If NRCh or the state o on site disposal of the contammated soil, t e co exceed $3 billion. g sludge, ash,and The full extent of the radioactive d contaminat quired testing related by-products nationwide is unknown. E to determine the extent of the radioactive sees that con adischarges. Fur discharge i treatment plants that receive radioactiveinsp radioactive material to treatment plants to determcontacted w i l ' concentratmgin sludge problem exists. 'Ihe sewage i treatment plan and ash and did not routinely test for radiattmgin t on. sludge To address the problem of radioactive materials' conc and ash, NRC has revised its regulation t to reduce tmentplan ials concentrate radioactivity that licensees can discharge to rea how effective k because of uncertainty about how the thave authority over NRC this action will be. EPA, the agency responst inty about the aspects of treatment plants' l wer districtsoperations, are do effectivenessof federaloversight,someloca li its on thelicensees' se acceptable t blished considering actions that impose more stringent d cts, local m discharges. However, i since neither N authorities are uncertain about how effect ve they would be enforceable. l t workers and The healthimplications of the d exposure of treatment the public to contammated sludge, ash, an re a(1) how much products might affect h unknown because neither d NRC nor EPA k l people. Sewage sludge, ash, and related by-pro uc Treatment Plant.s GAoMtCED-94133 RadionocUdee at sewage Page 2
B-255099 l l plants' operations are used and disposed ofin a variety of ways. Some of the sludge and ash by-products are used for agriculutral and residential purposes, as fertilizer for lawns or gardens, for instance. Sludge and ash can also be disposed of on-site at the treatment plant or oF-site at a landfill. Na issues Heenses undu um Atanic Ennor Act of N, as amended, m Background individuals and entities such as hospitals, research facilities, decontamination launddes, and manufacturers of smoke detectors and oth c devices and matedals. A license permits them to possess, use, and transfer licensed radioactive materials under controMed conditions that lindt the public's exposure to radiation. NRC regulates approximately 8,000 licensees in 21 states.1 NRC also provides the regulatory basis for 29
" agreement" states to regulate approximately 16,000 licensees.8 NRC has established riandards to protect the public health and safety. These standards are intended to minimize the risk ofincurrmg fatal cancers and genetic effects from exposure to radiation. Among other things, these standards, set forth in 10 C.F.R. part 20, set efnuent limits that licensees are not to exceed for various radionuclides that NRC is responsible for regulating under the Atomic Energy Act.
NRC and EPA have a regulatory interest in the mdioactive materials discharged into sewage treatment plants and the subsequent use and disposal of sewage sludge, ash, and related by-products. NRC iS responsible for the low-level radioactive materials discharged by its licensees and for protecting both the workers employed by its licensees and the general public from exposure to these materials. EPA regulates certain BSpects of the sewage treatment plants' operations, such as discharges to the plants and to navigable waters, and the disposal of sewage sludge and ash. EPA also has the authority to set generally applicable environmental standards to protect the environment from radioactive materials. 'lhe states and localities may impose additional regulations.
'NRC regulated states are Alaska, Connecticut, Delaware, llawaii, Idaho, Indiana, Massachianetta, Michigan, Mmnegota, Missourt, Montana, New Jersey, ohio, Oklahoma, Pennsy1vania, south Dakota.
Vermont, Virgtrua West Virgmia, Wisconsin, and Wyoming.
'Agtvement states are the states that, through agreements with NRC, hme assumed the role of NRC in momtoring and regulating uw radsoactive materials covered under the agreementa.
Page 3 GAo/RCED-94-133 Radionuclidea at sewage Trestraent Planta
s.usoes ver the last 10 years, at least nine cases have been reported of Radioactive . radioacdve contamination at treatment plants resulting from discharges by Contamm.ation NRC's and agreement states
- licensees into municipal sewage systems. The facuiues are located in Cleveland, Ohio; Tonawanda, New York; Grand Reported at Several Island, New York; Oak Ridge, Tennessee; Royersford, Pennsylvania; Treatment Plas* bM Erwm, Tennessee; Washington, D.C.; Portland, Oregon; and Ann Arbor, Full Extent of the Michigan. With the exception of the Cleveland case, diese cases were ideadned 88
- re8"It d " 8t^te'8 or ' :'s invesugadons d the Hcmsees and Problem Is Unknown treatment plants.
The full extent of the pt oblem of radionuclides' concentratmg at the treatment plants, however, is unknown. EPA and NRC studied this issue in 1986 and 1992, respectively. EPA's study did not provide any conclusions for determining health problems from the reuse and disposal of sewage sludge.a NRC's study indicated that some radiation exposure from sewage sludge and ash can occur and suggested that further review is needed.* Furthermore, NRC has inspected only 15 of the approximately 1,100 NRC licensees that may discharge radioactive material to treatment plants to determine if a problem exists with concentrations of radioactive materials. An NRC offlCial did hot know at the time of our review how many of the estimated 2,000 agreement state licensees may have been inspected. The treatment plants we contacted were generally unaware of the potential problem of radionuclides' concentrating in sludge and ash and did not routinely test these by-products for radiation. One of the more receist and significant examples of radioactive Elevated Levels of contamination at treatment facilities was discovered inadvertently by NRC Radioactive Contamination while conducting an aerial radiological survey of a licensee's site. In Discovered at Northeast April 1991, NRC discovered elevated levels of radiological contamination Ohio Plant (cobalt.60) at the Northeast Ohio Regional Sewer District's Southerly plant. According to NRC's documentdon, the most likely source of the radioactive material found was an NRC licensee that discharged waste into the sewer lines that are connected to the treatment plant. 'lhis material (used in teletherapy equipment as a radiadon source for treating cancer patients) subsequendy concentrated at elevated levels in the ash that was left over when the plant incinerated its sludge.
'Radoadivity of Munkspal Judge, End.m.i.waal Protecuon Agency, Apr.1986
*Evaluauon of E-=m Pathways to Man Frnm Duposal of Radioncove Matenals into sarutary Sewer Symema, Paanc Northwest laboratory, May 1992.
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1 After NRC's 1991 aerial radiological survey detected elevated levels of radiation at Southerly, a subsequent preliminary radiation survey by NRC at the plant identified the radiation levels in some soil samples at 20 times the background level 8 An August 1992 characterization of the site by an NRC contractor showed that elevated concentrations of cobalt-60 were present in samples obtained from all areas suiveyed. Of the 492 soil samples taken,133 samples, or 27 percent, exceeded NRC's acceptable level for radiation in soil. For example, the cobalt-60 concentrations 8 ranged from less than 0.1 to about 31,200 picocudes per gram (pCi/g) for soil samples-a single sample was measured at 3 million pCi/g-and trom less than 0.2 to about 75 pCi/g for sedunent samples. NRC's criterion for levels that are as low as reasonably achievable7 and for unrestricted use l (no need for future regulatory control by NRC)is 8 pCi/g for cobalt-60. A threat to public health and safety may not always exist if NRC's criterion for unrestricted use is exceeded, but according to a former NRC Commissioner, exceeding the cdterion is a public health and safety concern. NRC omCials maintain that the site poses no imminent health or safety risk to the plant's workers or to the public and that removing the contammated sludge and ash off-site could be costly. A Southerly oscial said that as of February 1994, the district had spent about $900,000 on site remediation activities and $120,000 to erect a security fence around the contammated areas to prevent general public access. In addition, NRC spent about
$370,000 on a done assessment, soil samplings and analysis, and radiological site and facility surveys. An NRC omcial told us that the site may need to be monitored for as long as 50 years if on-site disposal is permitted. However,if NRC or the state of Ohio does not approve on-site disposal of the contaminated soil, the cost of off-site disposal could be about $3 billion, according to Southerly omcials. (For more information about the Southedy plant, see app. I.)
8'Ihe radiadon in the natural environment, includmg cosmic rays and radiarian from naturally occurring radioactive elements. .
'A picoew6e is onearH11onth of a cwie, which is a measwe of the rate of radiandin decay.
% low as reasonably achievable means as low as is reasonably achievable taking into account the state of technology and the economics of iniprovements in relation to the beneota to the public healm and safety, other modetal and socioeconomic considerations, and the utilization of atomic energy in the puhue treerest.
A B-255099 Radiation Contamination In addition to the Southerly case, at least eight other cases of radioactive Discovered at Other contamination at sewage treatment plants have been reported (see app. II Treatment Plants for the details of these cases). The levels of radioactive materials discovered at these plants and the cost to resolve the problem vaded significantly. To detemtine whether the levels of radiation found at these sites posed a health or safety risk to the public, NRc in 1991 sponsored a study involving five of the eight treatment plants. 'Ihe study concluded that the levels "may not be trivial" and were high enough tojustify further study. According to the Director, Office of Nuclear Material Safety and Safeguards, the study indicated that, in some scenarios, the concentration of radionuclides could produce doses that are substantial fractions of NRc's 100-millirem per year limit on public exposure to radiation.8 According to information from NRC, i for sites at Grand Island, New York, and Oak Ridge, Tennessee, each state required the licensee to reduce its release limits for discharges of the radioactive materials. , The Full Extent of NRC estimated that before January 1,1994, out of 8,000 NRC-regulated Radioactive Contamination licensees,1,100 licensees had the potential to discharge into sewem n2 Treatment Plants Is radioactive materials that could concentrate at treatment plants in the 21 NRC-regulated states. NRC periodically inspects its licensees to ensure Unknown compliance with the requirements for discharges of radioactive efDuents. Dunng the inspections, NRc reviews the licensee's records to ensure that , the discharges are in accordance with the authonzed limits. The ' inspections generally do not include a survey of the sewer lines connecting ' the licensee to a treatment plant or of the treatment plant itself. For the 29 agreement states, NRc estimated that 2,000 of the 16,000 agreement state licensees discharge radioactive matenals into sewers. Inspection of the agreement state licensees is the responsibility of the agreement states and not NRC. An NRc oincial did not know at the time of our review how many of an estimated 2,000 agreement state licensees that discharge radioactive materials to treatment plants may have been inspected for concentrations of radionuclides. In November 1984, NRC issued a temporary instI11ction to regional offices requiring them to inspect certain licensees to determine if a problem existed with radioactive materials' concentratmg in sludge at sewage
'NEC uses the 1004nilhrem per year limit as the standard for the maximum amount of radiatio.
exposurt allowed per indivxtual that it considers acceptable from a public health perspective. 'Dus limit is basM on a recommendation by the Intemataonal Comm:sanon on Radaological Protectiort
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P 3 treatment plants; to the extent that a problem was identi6ed, they were instructed to take sludge samples from the treatment plants that received the licensees' discharges. In response to this temporary instrucdon, NRC ' inspected 11 licensees and subsequently identined contaminated sludge at two treatment plante-Erwin, Tennessee, and Royersford, Pennsylvania. In addition to the temporary instruction sent to its regional of5ces, NRC >
- also notined a number ofits licensees as well as the radiation program >
ofHees in agreement states about the potential for the radioacdve I materials to concentrate at treatment plants. However, NRC did not require t the licensees and the program ofHees to take any specific actions to address the problem. The problem of radionuclides' concentrating in sludge and ash continued ' to get NRC's attention as a result of the states' and NRC's inspeedons at licensees and treatment plants between 1984 and 1986. Responding to the , ongoing concern, ntC issued a second temporary instmedon in 1987 and l I inspected four licensees. NRC identi6ed these licensees because the types l l , and amounts of radionuclides they discharged could concentrate in i sewage treatment plants. Included on NRc's 1984 and 1987 lists was a licensee that discharged radionuclides to the Southerly plant. Unlike the l 1984 notice that directed NRC's regional staff to take only liquid waste samples from the licensees, this notice speci6cally directed the staff to l take sludge samples from the treatment plants as well. NRC, however, j j found no signincant concentrations of radioactive materials present in the sludge samples from these treatment plants. l NRC has inspected only 15 of the approximately 1,100 NRC licensees that l may discharge radioactive material to treatmentplants to determine if a concentration problem exista. Furthermore, NRC, despite its two j inspections, did not identify the problem with radioactive sludge and ash at Southedy. In 1985, NRC regional officials and a contractor took a sample I of sludge from the sewer line of a licensee that was alleged to have discharged excess amounts of cobalt 40 to Southerly. The inspecdon found some rwkm4on in the licensee's sewer drain, but no tests were made of the sludge or ash at Southerly. In 1987, an NRC inspector was once again sent out to investigate whether the same licensee was contaminatmg the treatment plant. 'Ihe inspector obtained dried sludge samples from one of the Northeast Ohio Sewer District's four treatment facilities, but he did not obtain ash samples from the Southerly plant. Ash samples were not taken because the inspector was unfamiliar with Southedy's treatment process
' or unaware that incineration could concentrate radioactive material in ash.
Fase 7 GAo/RCED.s4133 mediesecedes at sewese Treatament Plants
B-255099 The treatment plants that we contacted were generally unaware of the potential problem of radioactive materials' concentrating in sludge and ash and did not routinely test these by-products for radiation. NRc did not send its 1984 and 1987 notices about this pmblem to the treatment plants. We spoke with omcials from 21 treatment plants to determine whether they were aware of the potential problem of the concentradon of radioactive materials in sludge and ash and whether they tested for radiation. In each of the 21 NRc-regulated states, we selected a treatment plant that, according to NRC officials, is most likely to be receiving low-level "dioactive waste from NRC's licensees. We found that only 5 of 21 treatment plants were aware of the problem of radioactive materials concentrating in sludge and ash. In addition, only 5 of the 21 treatment plants have tested for radiation in their sludge and ash, but none are testing on a regular basis, and some had not tested recently. For example, one treatment plant official stated that a one-time test of sludge for radioactive materials was conducted about a year ago. On the basis of the i results of this one test, the official stated that it would be a good idea to , test the treatment plant's sludge for radiation. We also contacted two national associations that represent sewer district and treatment plant officials to determine if NRc had notified them about the problem. The director of the Association of Metropolitan Sewerage Agencies, which represents about 150 members with at least 400 treatment , plants, was not aware of any NRC notification to the association about the problem of radioactive materials' concentrating at treatment plants. i Similarly, we were told by the director of Public Affairs for the Water l Environment Federation, which represents some 40,000 members who are typically chief engineem from smaller treatment plants, that his , association was also not notified by NRc about the problem. l l NR and EPA have a regulatory interest in the discharges of radicactive Radioactive Materials matenals to ti atment plants and the radioactive materials' subsequent at Treatment Facilities disposai. NRc has taken regulatory action to limit the amount of May Not Be radioactivity that its licensees can discharge to treatment plants, but it d es n t know how effective this action will be. EPA is the agency most AdeSuately Regulated knowledgeable and closely associated with treatment plants, but EPA does not directly regulate the NRc licensees' discharges of regulated radioactive materials into sewage treatment plants.8 EPA regulates the treatment
' EPA does have the authority to establish generally applicable environmental standards for these matenals but has not exercised this authonty in the context addressed by this report. EPA may ale !
regulate naturally occurnng radmactive mater.als, such as radium, under the Clean Water Act and the Resource conservauon and Recovery Act. I
^ ' '
1 1 l B-255099 l I i l l l plants' discharges to navigable waters and any discharges to a treatment Jl plant that may pass through or interfere with the treatment system. EPA also regulates the disposal of sewage sludge and ash. I The full extent of radioactive contammation in sewage sludge, ash, and related by-products nationwide is unknown. Neither NRC nor EPA has required widespread testing to determine the extent of the radioactive contamination occurnng at treatment plants receiving radioactive discharges from the NRc licensees and agreement state licensees. As a result, no assurance exists that other treatment plants are not experiencing problems with radioactive materials' concentration. To l address the potential problem, some local sewer districts are considering j l actions that impose more stringent limits on the licensees' discharges. However, without further guidance from NRc and EPA on what levels of l radiation are acceptable in sludge and ash, they do not know if their actions will be effective or enforceable. i l While both NRc and EPA can affect the discharges into sewage plants, only Impact of Regulatory NRC regulates its licensees' radioactive discharges into sewers served by Actions to Limit eatment plants. In 1991, NRc revised its regulation 10 C.F.R part 20.303, l
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Radioactive Discharges From Licensees Is regulation 10 C.F.R part 20.2003, which became effective for all licensees l Unknown on January 1,1994, limits certain types oflicensees' discharges and ' reduces the concentration levels of the radioactive materials that can discharged into a sewer system. For example, insoluble discharges, such as the form of cobalt-60 that was found at the Southerly plant, will no longer be allowed for NRc licensees because these discharges concentrate in sludge and ash. l Under NRc's former regulation,10 C.F.R part 20.303, which govemed licensees' discharges of radioactive materials, NRC permitted its licensees to discharge small quantities of radioactive materials into treatment plants. The discharges nad to be made within certain specified limits, provided that the materials were 'readily soluble or dispersible in water." NRC assumed that the radioactive materials discharged into a sewer system would remain in solution or would readily disperse in the large volumes of water discharged by the treatment plants and would become almost undetectable. NRC further assumed that the radioactive materials wou j pass through the treatment facilities' systems to streams and rivers and not settle out in the sludge. However, the materials discharged by some l licensees that were initially thought to be readily dispersible precipitated i I
---- -n.~. mm_ ..s .y......,e m ,
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, out of the wastewater and concentrated. For example, in the Southerly .
case the cobalt 40 in oxide form, which was origmally thought to be readily dispersible, concentrated during the sludge treatment process and ' accumulated in higher conceritrations after it was incinerated. 3 NRC's current regulation reduces the concentrations of radioactive , materials that can be discharged compared to what was allowed under thi : previous reguladon, but it retained the 1-curie per year limit for . , radioactive discharges. For example, NRC's licensees now have to reduce : the concentradons in their discharges containmg americium-241 and ; uranium-235 by a factor of 300 over what was required by the fomier , regulation. The concentrations of cesium-137 discharges have to be ; reduced by a factor of 40, while the concentrations of cobalt-60 discharges : have to be reduced by a factor of 30. NRC officials believe that the . reductions will address much of the problem of concentration but may not ! solve it entirely, because even soluble materials that are allowed to be j discharged could still concentrate as the result of chemical changes that could occur during the wastewater treatment process. NRC officials were unable to determine to what extent this kind of concentradon may occur. ; i-Recognizing that the current regulation could fall short of fully addressing ! the problem, NRC in September 1993 contracted for a study to examine the impact of the current reguladon on preventing the recurrence of significant incidents of concentration. NRC officials infomied us that the study would not require any testing at treatment plants but would rely on ' the existing data from prior case studies or contemination at treatment i plants. If it is determined that additional control measures are needed, NRC , will examine the possible strategies for changing its current requirements i for discharges to sewers. ne study is scheduled to be completed in September 1994. NRC also issued an advance notice of proposed i rulemaking on February 25,1994, seeking informadon to determine l whether its regulations governing the release of radionuclides from l f licensed nuclear facilities to sanitary sewer systems may need to be l F further amended. l l 1 l EPA is responsible for administering the National Pretreatment Program i under the Federal Water PoHution Control Act, commonly called the Clean ] Water Act. Industnal dischargers must comply with the national ' pretreatment standards that limit their discharges to sewage treatment i plants in order to protect receiving waters, treatment plant workers, the ; I' plant, and sewage sludge from pollutants. De states and treatment plants ; may further restrict diwharges to treatment plants in order to meet local
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Fage le GA04CED-94133 Badiomociades at sewage Treatament Plante '
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i 4 ; 1 objectives. EPA also regulates the disposal and use of Sewage sludge under this act. Ash is regulated under the Resource Consemdon and Recovery Act (RCRA) of 1976, as amended. However, according to EPA's Principal Deputy General Counsel, EPA has no authority under the Clean Water Act or RCRA to directly regulate those radioactive materials covered under the Atomic Energy Act. He noted that it has been the agency's long-standing posidon, amrmed by the U.S. Supreme Court, that EPA has no authority under the Clean Water Act to regulate the radioactive materials subject to the Atomic Energy Act.88 he Resource Conservataan and Recovery Act also specifically exempts these types of materials. Agencies Have Not Neither NRC nor EPA requires treatment plants receiving radioactive Required Widespread discharges from NRc's licensees to test for radioactive materials in their sludge and ash. NRC has the authority to promulgate rules and issue such ] Testing at Sewage rdem 88 it m8y deem nece88ary t protect the public health and safety j
'IYeatinent Plants from regulated radioactive materials. According to NRC's Deputy General q Counsel for Licensing and Reguladon, this authority may be applied to l unlicensed persons or entities, such as a treatment plant, if necessary to l protect the health or safety of the public. However, generally NRC would not issue an order to require testing at a treatment plant unless some prior evidence of a problem existed. .
EPA's Principal Deputy General Counselinformed us that EPA does not have ! the authority to directly regulate the concentradon of radioactive materials subject to the Atomic Energy Act that may be found in treatment I plants' sewage sludge and ash. he omcial also informed us that EPA does have the authority under the Atomic Energy Act of 1954, as amended, and the Reorganization Plan No. 3 of 1970 to establish generally applicable environmental standards for the protection of the general environment from radioactive materials. However, EPA has not determined whether this authonty would allow it to conduct testmg at those treatment plants most likely to be affected by the discharges imm NRC's licensees. 1 Even though, accordmg to EPA's Principal Deputy General Counsel, EPA does not have the authority to directly regulate the concentration of radioactive matedals subject to the Atomic Energy Act, EPA does have the authonty to regulate air emissions from incinerated sewage sludge that , may contain radionuclides. Radionuclides are included on the list of l hazardous air pollutants under the Clean Air Act. According to the Director of EPA's Criteria and Standards Division, Omce of Rmantion and "rrain v. Colorado Public Intenut Research Group,426 U.s.1 (1976). 1 Page 11 GADWaCED-ee.lSS andlesecudos at sewage Treatament Plaats
B-256009 Indoor Air, EPA could determine if sewage treatment plant incinerators need to be regulated for radioactive emissions on the basis of the repo cases of radioactive contamination of sludge and ash at treatment plants. In addition, EPA is required under the Clean Air Act to issue National Emissions Standards for Hazardous Air Pollutants for treatment plants no later than November 15,1995. According to EPA's Principal Deputy Gene Counsel, the measures required to control the emissions of hazardous air pollutants from treatment plants may indirectly affect the concentrations of radionuclides in sewage sludge and ash. Although EPA officials have not concluded that the radioactive contamination at treatment plants poses a serious health or safety problem, they informed us that they would be willing to work with Nac to assess the extent to which it is a problem. NRC and EPA discuss matters of mutual concern at a senior level or an ongoing basis. The framework for this coordination was formulated under a memorandum of undersumding signed on March 16,1992. As a result of the number of reported incidents of radioactive materials' concentrating at treatment plants and concerns about potential liability, some localities are attempting to address the problem on their own (see app. III). However, these localities still need guidance from NRC and EPA o what level of radiation in sludge and ash is acceptable and on their authority to regulate radioactive materials. since treatment plant workers and the public may come in contact with Weahem P M radioactively contanunated sewage sludge and ash and related Workers and the by. products, they may be exposed to radiation. However, the threat to ' public health and safety is unknown because studies conducted to Public May Be determine the impact on workers and the public of radioactive materials i , Exposed to sewage sludge and ash have been inconclusive. Radioactive Sludge sew, sludge, ash, and related by-products from treatment plants' and Ash, but Health' operations are used and disposed of in a variety of ways. Some of the ImpactIs Unknown sludge and ash by-products are used for agricultural and residential purposes, as fertilizer for lawns or gardens, for instance. Sludge and ash can also be disposed of on-site at the treatment plant or off-site at a landfill. For example, discussions with officials from the 21 treatment l plants indicated that many disposed of sludge and ash off-site, in some ' cases using mom than one disposal method. Thuteen treatment plants used a public landfill to dispose of their sludge and ash. Seven treatment l l Page 12 GAo/RCED-94-133 Radionucudes at sewage Treatment Plar
1 s-2ss e i l l l l l 1 plants disposed of at least some of their sludge for agricultural pumoses. Two treatment plants sold sludge to landscapers, nurseries, or retail stores l as compost. One treatment plant used ash as a surface material on l I baseball diamonds because it absorbs water well. Another treatment plant is exploring the possibility of using ash to make bricks and blocks or to pave streets. ll De health implications for treatment plant workers and the public are unknown because studies conducted to determine the impact of radioactive materials in sewage sludge and ash on workers and the public have been inconclusive. For example, NRC's 1992 study concluded that the i radiation levels at some treatment plants, while not an immediate health I and safety risk, were not trivial and required further study. A 1986 EPA ' survey of the radioactivity in sewage sludge, on the other hand, merely documented instances of radioactive contanunation in treatment plants' sludge and did not come to any conclusion. On the basis of a 1986 review by NRC's Region I of eight licensees that J discharged to sewage treatment plants, the chief of the region's Nuclear Mater: Ids Safety and Safeguards Branch recommended that NRc conduct a l l nationwide review of the concentrations of radioactive materials at ; treatment plants. His concem was that the public could be exposed to ' radioactive materials through sewage sludge applied to farmlands or to private lawns and gardens. His official suggested to NRc headquarters that the review focus on all decontammation laundries and any other licensees l of NRc or agreement states whose dischargen could reedt in radioactive ; materials' concentratmg at a treatment plant. The treatment plants that have experienced incidents of radioactive j contamination have attempted to assess the possible health effects on the workers exposed to the concentrated radioactive materials in sludge and ash. For example, when Southerly omcials became aware of the elevated levels of cobalt-60 in the plant's sludge and ash, they had the workers with the greatest exposure risk tested for radiation. Eleven workers receiv" whole-body rahation counts to detect the presence of cobalt-60. Although none of the workers were found to have detectable levels of cobalt-60, a Southerly omeial told us that it may not be possible to guarantee that no damage was done. The body naturally rids itself of cobalt-60 in a relatively short amount of time, and tests cannot be done for prior exposure to radiation. In addition, an NRC senior radiation specialist, who was present when the workers were tested, stated that cobalt-60 has a tudf-life of about 5 years, and NRc believes that the exposure of the Southerly workers Page 13 GAo/ECED-94-133 Radionuclides at sewage Treatment Planta
a-assoes t occurred about 10 years ago. 'Iherefore, the whole-body counts performed on the workers likely would not show any signs of cobalt-60 exposure. While several cases of radioactive contamination have occurred at sewage COHCILISiODS treatment plants, the full extent of this contamination nationwide is unknown. In addition, some treatment plants may use and dispose of their sludge and ash in a variety of ways that could expose plant workers and the general public to elevated levels of radioactivity. Although NRC believes that no imminent health risk exists for the treatment plant workers and the general public, on the basis of NRc's 1992 report on radioactive matedals' concentrating at five sewage treatment plants, both NRC and EPA offlCials agreed that further study is needed. Furthermore, where elevated levels of radiadon have been detected in sludge and ash, the treatment plants are , faced with concems about the disposal and/or monitoring of the I contaminated material and the prospect ofincurring future cleanup costs. l 1 1 The problem of radioactive contammation of sludge and ash in the ; reported cases was the result, in large part, of NRc's regulation, which was l incorrectly based on the assumption that radioactive materials would flow through treatment systems and not concentrate. NRC officials do not know why the radionuclides are being filtered out, and NRc has sponsored a study to determine the impact that its revised regutation will have on limiting the concentration of radioactive materials in sludge and ash. If it is determined that additional measures are needed, NRC will eXWnine possible strategies for changing its current sewage disposal requirements. Until the study is completed, treatment plant officials may need more information about the concentraticn problem so that they can take whatever action they deem appropdate. The treatment plants and local sewer distdct officials have requested guidance from NRC and EPA on what levels of radiation are acceptable in their sludge and ash and on their authority to regulate radioactive materials. Given that NP" is responsible for minimizmg the exposure of the general l public te rnAntion and that EPA could establish generally acceptable ) environmental standards for ensuring that sludge, ash, and related by-products do not harm the environment, both agencies have an interest i in addressing the problem of radioactive contamination at treatment ) plants. It is important for the federal government to take prompt and necessary actions to assure the public that the sludge and ash by-products that they may come in contact with are free from harmful levels of radiation. Even though NRc has issued an advance notice of proposed i Page 14 GAD /ECED-e4-133 Radlonodides at Sewese Trent,nent PfeMe l
s.zasoes rulemaking on the problem of radionuclides' concentradng at some l treatment plants, the treatment plan;s receiving radioactive matedals from NRC's licensees may still not be aware of the problem. Since the concentration of radionuclides is of interest to EPA, EPA officials told us l that they would be willing to asast NRC in identifying the (matment plants receiving radioactive materials from NRC's licensees and offered EPA's expertise on treatment plants' operadons. T detennine what actions may be needed to better control the spread of , j Recommendations radioactively contaminated sludge, ash, and related by-products trom sewage treatment plants that receive radioactive matedals from NRC's j licensees, we recommend that the Chairman, NRC, i
. determine the extent to which radioactive contaminadon of sewage sludge, ash, and related by-products is occurdng;
. directly notify the treatment plants that receive discharges from NRC's and the agreement states' licensees of the potential for radioactive contandnation because of radioactive matedals' concentrating and of the possibility that they may need to test or monitor their sludge for radioactive content; and
. establish acceptable limits for radioactivity in sludge, ash, and related j i
by-products that should not be exceeded in order to ensure the health and I safety of treatment workers and the public. We discussed the facts presented in this report with the Deputy Executive l Agency Comments Director for Nuclear Materials Safety, Safeguards, and Operations Support and other NRc omcials at headquarters, and the Director, Cdteria and Standards Division, Omce of Radiation and Indoor Air, and other omcials at EPA headquarters. Both NRC and EPA omcials generally agreed with the facts in this report but offered some technical cladfications that were incorporated where appropriate. Because of NRC's five reported cases of radioactive matedals' concentrating at ta catment plants, bodt NRC and EPA agreed that further study is needed to deterndne the potential risk to public health and safety. As requestzd, we did not obtain written agency comments on this report. We conducted our review from August 1993 through February 1994 in accordance with generally accepted government auditing standards. Appendix IV contams more information on our scope and methodology. GMVRCED e4-133 aadiosacildes at sewage Treetament Plaats Page3s
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B-255099 t Unless you publicly announce its contents eadier, we plan no further distribution of this report until 30 days after the date of this letter. At that time, we wil! send copies to appropriate congressional committees; the Chairman of the Nuclear Regulatory Comnussion; the Administrator, Environmental Protection Agency; and the Director, OfHce of Management and Budget. We will also make copies available to othem upon request. This report was prepared under the direction of Victor S. Rezendes, Director, Energy and , Science Issues, who may be reached at (202) 5124841. Other midor contributors to this report are listed in appendix V. Keith O. Fultz Assistant Comptroller General b l r P
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l I i l 2 I l l l l l l l Page 17 GMCED-94133 Radionuclides at Sewage Treatment Plants
Contents O Letter 1
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2 Appendix I . Summary of the I Northeast Ohio Regional Sewer District's Southerly Sewage Treatment Plant 28 Appendix II Reported Cases of ; Radioactive Contamination at Sewage Treatment Plants Appendix III 29l Localities Addressing the Radioactive Material Concentration . Problem Appendix IV ai l Scope and Methodology Appendix V as Major Contributors to This Report Page 18 GAO/ECED-94-133 Radlemoclides at Sewage Treatment Plants
.L_, , . . .
.e conseau Figure Figure LI: Southerly Sewage Treatment Plant-Areas of Elevated 21 Levels of Radiation l l l i 4 l 1 i I l l Abbreviations EPA Environmental Protection Agency ; GAO General Accounting Office ' NRc Nuclear Regidarnry Commission pcvg picocuries per gram RCRA Resource Conservation and Recovery Act m microroentgens per hour
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Summary of the Northeast Ohio Regional Sewer District's Southerly Sewage Treatment Plant l In 1972, the district was established as a regional sewer district in Ohio. At i that time, the district assumed control over the Easterly, Southerly, and Westerly sewage treatment plants; the sludge force main; the interceptor sewers flowing into the plants; and all land, facilities, equipment, and working capital that were part of Cleveland, Ohio's sewage treatment and i disposal system. Today, the distdct owns and operates four sewage treatmant plants (Easterly, Southerly, Strongville, and Westerly). The four plants serve 52 suburban communities and the city of Cleveland. The Southerly plant uses a primary and secondary process to treat sewage. ; The plant can completely treat up to 175 million gallons of wastewater per day during dry weather. In 1992, Southerly treated an avemge of 121.2 million gallons of wastewater per day, processed about 103,000 wet tons of filter cake, incinerated about 97,000 wet tons, and hauled about 5,200 wet tons off-site. The Southerly plant employs 225 persons and serves over 500,000 residents. It is one of the largest activated sludge treatment plants in the nation. The Southerly plant receives all of the sludge generated by the district's sewage treatment plants with the exception of the Westerly plant's sludge. After the sludge is incinerated, the ash is pumped in sluriy form into three settlement / evaporation ponds (referred to as the A, B, and C ponds). The ponds reach capacity in about 3 years, at which time the ash has to be removed and placed in various on site locations as fill. Southerly officials told us that none of the ash has ever been taken off-site for disposal. The sludge that is not incinerated is transported off-site to private landfills. Southerly uses several companies to haul its sludge off-site. 'Ihe companies are required to use district-approved landfills. An aerial radiological survey conducted in April 1991 over Newburgh Heights, Ohio, detected elevraed levels of radiation at the Southerly plant (see fig.1.1). The survey was done at the request of the Nuclear Regulator ' Commission (NRC) to measure the radiation in the environment arou former Chemetron (an NRC licensee) manufacturing plant and the surrounding disposal site. The survey results showed the evidence of radioactive materialin the form of cobalt-60.
"****^ G UMicFDA4133 Radionuclides at hware TYeatment Pfaf'
Appendix I Summary of the Northeast Ohio Regional Sewer District's Southerly Sewage Treatment Plant Figure 1.1: Southerly Sew Treatment Plant-Areas of Elevated Lavels of Radiation l I Source: Nor.heast ONo Responal Sewer District. l l l According to NRc's documentation, the most likely source of the radioactive material found was an NRc licensee that discharged waste into the sewer lines that are connected to the treatment plant. Nac inspected the manufacturer's radioactive liquid waste disposal into the sanitary sewer, including a review of the disposal records, and concluded that the l l disposal did not exceed NRc's allowable limits. The manufacturer's records l GAo/RCED-94133 Radlonuclides at Sewage Treatment Plants Page 21
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;r Appendix I s-mary or the Northeast ohio Regional ,
sewer District's southerly sewage Treatment Plant . 1 d documented that a total of about .2 curies of cobalt 40 was discharged into the annitary sewers from May 1980 to May 1989. 5 On May 15,1991, an NBC radiadon specialist and two Ohio Department of. Health omcials visited the Southerly plant to conduct radiation surveys to corfirm the locadon of the ground contamination. The omcials used '
' radiation detectors to locate the ground contaminadon, and both NRC and state oscials collected soil samples for subsequent analysis. %e omcials
- primardy found elevated radioacdve readmgs around the northeast and ,
' southeast secdons of the Southerly property. According to the NRC inspecdon report, the northeast section of the property was previously a marsh and had been filled with ash from the ponds some time in the late
.1970s or early 1980s. The southeast section of the property included the three setding ponds.-
The background readings from both secdons of the property were about 10-12 microroentgens per hour (uR/hr). ne radiation readings around the northeast section were at about 20 times the background level. No ' radiation levels were above background at any of the three settling ponds. he highest radiation levels in the northeast secdon were found in animal dens. Radiation readmgs up to 200 uR/hr were obtained when a detection , instrument was placed just below the ground surface in several dens. Two , samples collected from the dens and an eroded bank measured 27 to 79 picocuries per gram (pCi/g) for cobalt 40,0.59 to 1.29 pCi/g for radium-226, and 0.13 to 0.14 pCi/g for cesium-137. According to NRC, the concentrations of radium 226 and cesium 137 were in the normal range of naturally i 7 occurnng and fallout radioacdvity found in soil. De only area exhibiting elevated radioactive readmgs at the southeast section of the property was associated with fill (about 8 feet thick) located in a diked area n the settling ponds. De maximum readmg was about 30 uR/hr. No soil samples were collected froin the southeast secdon. At this time, the district received verbal nodce from NRC that it suspected some 4 very-low-level radiadon contamination was present at Southerly. On June 19,1991, NRC confulned its suspicion in the form of a written ; preliminary notificadon" that cobalt-60 contanunadon was indeed present l at Southerty. On August 27,1991, an NRC inspector and an Ohio l Department of Ilealth inspector surveyed the district's Easterly plant for , possible cobalt-60 contaminadon because sludge from the manufacturer 01l the radioactive sources first goes to the Easterly plant before it is pumped : to Southerly for incineration. %e results of the survey were negative. All I measured radiation levels in and around the Easterly plant were within l I 1 ' Page it GAo/RCED-94-133 Radionuclides at sewage TYeatment Plants
- App u isI. . . ..
Lunamary of the Northeast ohlo Regional sewer District's southerlF sewage Treatment Plant
'L normal radiadon background Ir /els of the immediate area, except inside the plant. Inside the plant, ra6ation levels were as high as 45 uR/hr and were attributable to buildin,3 materials which were believed to have ,
a contained small quantities c.f naturally occurrmg uranium a:.d thorium and their associated decay product NRC contracted with Oak Ridge As ociated Universities to perform a detailed assessment of the Southcly plant site. This included developing a j comprehensive charactenzation of the radioactive contaminadon and
- appropdate recommendations for remediation of the site. The univemity conducted a radiological charactenzation survey of selected outdoor areas i
at the Southerly plant during the periods September 16-25,1991, and March 16-26,1992. De university surveyed an area totaling over 168,000 - square metem (approximately the size of 32 football fields) around Southerly's fill areas, sanitary ponds, steam plant, and a storage tank. The survey identified 111 locations with elevated levels of direct radiation ranging from 15 to 580 uR/hr in an area of about 9,200 square meters (about the size of 2 football fields). NRC is using an 8-pCi/g criterion for cobalt 40 to release the areas for
- unrestdcted use. he maximum concentradon found in a surface soil sample was 3 million pCi/g, and it was obtained from the pond area.
However, the university did not consider this sample to be representative of the soil concentratione present. The maximum concentration in subsurface samples taken from depths of about 1/2 foot to 11 feet was 31,200 pCi/g for the south fill area. According to NRc, while the survey indicated the presence of cobalt 40 contammation in various
' concentrations, there was no indication of significant radiaHon exposure to the public because of the isolated and secured location of the 3 contamination. In August 1992, the university issued its final report on the survey.
Although district, state, and NRC officials agree that the contamination around Southerly does not pose a public health threat, an estimate as to the amount of cobalt 40 that entered the plant is not expected until early 4
' June 1994. According to NRC, this information is needed to determine,
' among other things, how much radiaHon the pinnt workers were exposed to when the material passed through the plant. 4
. On April 15,1992,in an attempt to measure the approximate amount of radioactive materials either inhaled or ingested into the body,11 district employees participated ir. whole-body radiadon measurements at the Page SS GAo/ECED-94133 RadiomecLWes at sewage Treatament Plants
i. Appendiz I s=P="rCf the Northeast ohio Regional
- f sewer District's southerly sewage Treatment Plant i
a i i Peny Nuclear Power Plant. On the basis ofinterviews with management,; union steward, and the employees themselves, eight employees were origmally chosen as having the highest risk of exposure because they wer. involved in some way with the incinerated ash. Later, the district added three employees to the group to be examined. None of the employees examined showed detectable levels of radiation.
- According to information provided by distzict officials to its employees, any detectable radioactive materials in the employees may have already 1
disappeared. Within 2 to 3 years following the inhalation or ingestion of - cobalt-60, the body will have eliminated the great majority of the material Moreover, cobalt-60 decays at the rate of 1/2 times the total cobalt present in about 5 years. Finally, with the combir ation of the body's ability to eliminate cobalt-60 and the rapid decay of cobalt-60, an NRc senior radiation specialist said that it is very unlikely that a whole-body radiation measurement will yield any useful information about what may hee happened years ago. The district plans to perform its own study that would be more representative of the actual pattern of exposure that its employees received. Initially, NRc planned to conduct this study, but after the district reviewed the scope of NRC's proposed survey, the district decided to fund its own more comprehensive study and analysis. On April 8, l!'93, the Mayor of Cleveland requested that NRC provide a wdtten opinion as to whether the activities conducted by the mrnufacturer did at any time, pas or present, pose any risk to the public health and welfare of the citizens of the city of Cleveland. On May 24-28,1993, NRC conducted a survey of the neighborhood near the manufacturer's facility. NRC employees, accompanied by district, state, and local officials, completed a comprehensive radiological survey in and around the facility. As part of this survey, they checked the grounds of Mark Tromba Park, located on Mandalay Avenue near the facility, including a baseball field, a playgrouns and a swunming pool. No cobalt 40 was found in any of the soil samples i: the public reas. NRC held a public meeting on May 28,1993, to discuss the survey results and respond to any public concerns. i At the request of the Mayor of Cuyahoga Heights, Ohio, NRC and the Cuyahoga County Board of Health on June 24-25,1993, conducted a special inspection to assess radiation levels and ensure that no radioactis materials had migrated off-site from the Southerly plant into nearby residential areas. The inspection included eight residential yards along East 49th Street and all of the front yards of the homes along Willowbroo Page 24 GAD /ECED-94133 aedionacildes at sewage Treatment Plas -
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4 Appendiz I susumary or the Northeast oblo Regional sewer District's Southerir sewage
' Treatment Plant a
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Drive in Cuyahoga Heights. The inspection showed that no ra<harion levels above normal ambient background levels were identified and that no j radioactive materials had migrated from the Southerly plant into these areas. The results were diewaad with the Mayor of Cuyahoga Heights on July 7,1993. 1 District omcials told us that they thought the universities' initial site characterizadon work would be adequate for remediation purposes. However, because the site charactenzadon was not as comprehensive as l origmally thought for remediation purposes, the district in May 1992 hired its own consultant to thush the site characterization and develop a , remediation plan. Distdct omcials believe that the universities' site l characterization would probably have been more cost effective ifit had l i been more comprehensive. Instead, the district had to mobilize its staff twice to help with site characterizations. The district hired a consultant to provide professional services for the i completior, of the site characterization, pond (s) excavation, prepamdon of a site charactenzation report, and submittal of a site remediation plan.' Efforts to identify the source of contamination and to develop instrumentation to prevent the future contamination of the district's waste treatment plants are also included in the contract. he total esdmated cost 4 to clean and secure the site will be about $1.2 million. As of mid-February 1994, the distdct has spent about $0.9 million on site remediation activities and $120,000 to erect a fence around the north and south fill areas and the holding ponds to prevent public access. In January 1993, the district installed thermoluminescent dommeters at strategic locations throughout all four treatment plants and the pump stations. According to a Southerly [ official, the thermoluminescent dosimeters have been read quarterly since January 1993 and have not detected any radioardvity above background levels. Also, the distdct plans to get recommendations for installing survey ' equipment that will alert plant personnel when radioactive matedal enters the plant. , The district's consultant submitted project achedules to NRC on December 30,1992, for pond excavadon and on January 11,1993, for a site operations and radiological control plan. %e project schedules and the site operations and radiological control plan were reviewed by NRC and its comments submitted to the district on January 15 and February 19,1993, respectively. De distdct submitted its site charactenzation plan to NRC on
Ihe remediauon plan includes the methods the district intends to use to dhycee of the contammatson and ensure protection of workers and the environment against radiation hasards during the remediation.
Page 36 GAO/RCED-94-133 andlemmetades at sewage Treatament Plaats t
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4 l 7 A "= I sammarr of the Northeast ohloa + ==I sewer District's seetherly sewage Treatament Plant , i i April 23,1993. From June to September 199$, material from the three ponds was removed to the south fill area. %e cleaning of the ponds wl ' necessary because they were expected to reach their capacity in July 1 j Nac staff accelerated their reviews of the district's proposals so that the ' ponds could be placed in service without affecting the plant's operatio Pond C was placed in operation on July 5,1993. Ponds A and B were placed in operadon around October 1993.
' As part of the remediation, about 174,000 cubic yards of contammate from the ponds were moved to the south fill area, and about 6 inches of soll was placed over the material Seven monitoring wells were also installed in the same area. %e area where the material was mov between 1 and 2 acres. De district does not want to move the contaminated material from the north fill area because it does not 2
take a risk of getting the material airborne, spreading it, and further exposing the workers. t The district does not expect any problems with its plan to leave the contaminated material on site. The district plans to propose to NRc that r any contaminated ash removed from the ponds be combined with existing contaminated ash in the south fill area and stored in place pending ' completion ofits final remediation plan. A district official told us that the remediadon plan wul not be submitted to NRc until late June 1994. NRC and state oscials need to review the p'e to determine if on-site disposal is acceptable. Both NRc and state of Ohio officials agree that leaving the material on-site is probably the most practica! di-posal opdon. District d officials told us that disposal of the material off-site could cost at least
$3 billion.
Accordmg to the district, NRC has consistently taken the position that l unless it can prove the manufacturer exceeded the discharge limits set forth in 10 C.F.R. part 20.303, there is no action NRC can take against the manufact"~r. NRc maintains that the district is responsible for any and all costs associated with the remediation of the site since the distric possession of the contamination. District officials believe that passing on the costs of the cleanup to its rate j payers is unfair, and they are taking action to keep this from happening. s The district filed a petition (pursuant to 10 C.F.R. part 2.206) on March 3, , 1993, requesting that NRC mWilfy the manufacturer's NRC license to re ,
~ it to (1) assume all costs resulting from the release of cobalt-60 that has been deposited at the Southerly plant and (2) decontammate the sewer GAo/ECFD-94-ISS aadionoclides at sewage heatment Flam Fame 24
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-- Appendiz ! I summary of the Northeast Okto Regional j sewer District's Southerly sewage Treatment Plaat l
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i j connecting the manufacturer's facility with the public sewer and continue l decontamination of the sewers downstream as far as necessary. The district filed another petition with NRC dated August 2,1993 (pursuant to l 10 C.F.R part 2.206) requesting that NRC institute a proceeding to modify the manufacturer's NRC license to require the manufacturer to provide adequate financial assurance to cover public liability pursuant to section - 170 of the Atomic Energy Act of 1954, as amended. According to the NRC, it is taking appropriate actions on the two petitions as separate matters. In ; April 1993, the district filed a lawsuit against the manufacturer for
- damages to its Southerly plant from the cobalt-SO released into the distdct's sanitary sewen.
The district's August 2.1993, petition, noted above, raised another issue ! separate from its request for action against the manufacturer. It also i requested at least 24 hous' advance notification to the distdct from the i NRG licensees in its service areas before they release radioactive materials into the district's sanitary sewer. 'Ihe district submitted another petition on August 2,1993. 'that petition for rulemaking requested that the NRC amend its regulations to (1) require that all licensees provide at least 24 , houm' advance notice to the appropriate sewage treatment plant before releasing radioactive material to the sanitary system and (2) exempt materials that enter the sanitary waste stream from the requirements for NRC's approval for incineration under NRC's cutTent Ngulations. NRC issued l an advance notice of proposed rulemakmg on February 25,1994, seeking information to determine the need for an amendment of its regulations governing the release of radionuclides from licensed nuclear facilities to sanitt.ry sewer systems. Comments on the petition will be considered under this rulemakmg. l i i Page 27 GAOSCED-94-133 Radionnelades at sewage Treatment Plants
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Appendix II Reported Cases of Radioactive Contamination at Sewage Treatment Plants Date Sewage treatment plant's locatlon fot.nd Radionuclides found Summary Tonawanda New York (agreement 1983 Americium-241 The state of New York has paid state) $2.5 million for cleaning up the treatment plant and sewer lines. The Tonawanda landfill needs to be cleaned up; the estimated cos is $7 million. Grand Island, New York (agreement 1984 Americium-241, hydrogen-3, No cleanup was required at the state) polonium-210 treatment plant. Oak Ridge, Tennessee (agreement 1984 Cesium-134, No cleanup was required at the state) cesium-137, treatment plant cobalt-60, manganese-54 Royersford, Pennsylvania 1985 Manganese-54, No cleanup was required at the cobalt-58, treatment plant. cobalt-60, strontium-89, zinc-66, p!us 11 other radionuclides Erwin. Tennessee (agreement state) 1986 Americium-241, plutonium-239, One of the treatment plant's thorium-232, " sludge digesters' needs to be uranium-234, 235, and 238 cleaned up; the estimated cost is
$250,000.
Washington, D.C. 1986 Carbon-14, hyorogen-3, No cleanup was required at the phosphorus-32 and 33, so6um-22, treatment plant. sulfur-35, plus 21 other radionuclides Portland, Oregon (agreement state) 1989 Thorium-232 Licensee paid about $2 million for cleaning up the sewer lines and installing a pretreatment system. Ann Arbor, Michigan 1991 Cobalt-60, No cleanup was required at the manganese-54, treatment plant. silver-108m and 110m, zinc-65 Cleveland Ohio
- 1991 Cobalt-60 The district has spent about
$900,000 for site remediaton activities and $120,000 for a fence to prevent public access. Dispose of the material off site could exceed $3 billion.
*The sewage treatrnent p* . .. [cated in the Village of Cuyahoga Heights, south of Cleveland Sources: NRC Office of Nuclear Material Safety and Safeguards Report, Dose Assessment for Disposal of Radologically Contaminated Sludge at Two Landfill Sites: The Johnson City, TN and t'Re Carter County /Ehiabethton, TN. April 1993, Oak Ridge Institute fer Science and Education Report, Radological Characterization Survey _for Selected Outdoor Areas Northeast Ohio R ional Sewer Distnct Southerly Wastewater Troatment Plant Cleveland, Ohio, August 1992.
P~ct a ic thwest Laboratory Report. Evaluation of Exposure Pathways to Man From Disposal of Radoactive Matenals into Sanitary Sewer Systems, May 1992; EG&G Energy Measurements Report, An Aerial Radological Survey of tie Former Chemetron Factory Site and Surrounding Area, Newtx;rgh Heights. Ohio. September 1991; and GAO's in*orviews with NRC Ofhce of Nuclear Regulatory Research and sewage treatment plant officials. Page 28 GAOdtCED-94-133 Radlonuclides at Sewage Treatment Plant
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' Localities Addressing the Radioactive l
L Material Concentration Problem 1
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' he Metropolitan St. Louis Sewer District paased an ordmance in l ' August 1991 that limits the aggregate discharge of radioacdve materials '
into the sewage system. District officials were concerned about the potential hazani to treatment plant workers and to the general public if radioactive materials are concentrating in the sewer system. When the ordinance is enforced, all of the NRc licensees in the district can discharge only a combined total of I cude of radioactive material in 1 year, whereas 1 NRc permits each licensee to discharge up to 1 curie per year. District t. officials believe that more guidance and reguladons are neerled from NRc and the Environmental Protection Agency on what levels of radi: don in sludge are permissible and how to best address the problem ifit occurs. in Portland, Oregon, the state's health division and the city ordered a state licensee to install a pretreatment system to control the discharge of thorium oxide in sewer lines. %e city's sewer workers now have to wear protective clothing when they work in the sewers where thorin oxide-bearing sediments exist. State and local officials had considered enforcement actions to completely stop the disclages by this licensee. However, the City of Portland was concerned about a lack of clear, ' scientifically based standards addressing the discharge and the resulting accumulation of thorium oxide in the sewers. Without a clear, defensible ' standard, the city was uncertain whether it could require the licensee to ' eliminate its thorium oxide discharges, which the licensee estimated ) would cost $5 million. i The Royersford, Pennsylvania, treatment plant is havir.3 problems disposing of its radioactive sewage. According to the plant supervisor, processed sludge from the plant, which contains small quantities of radioactive materials, has been spread in a marsh area within the facihty's j grounds. Reeds growing in the marsh have absort>ed much of the radioactive materials from tLa sludge. %e facility intended _to either mulch the reeds and dispose of the solid waste in a public landfill or burn the reeds. NRc did not object to either dispoet method because, in the : i i agency's opirdon, the radioactive level of the reeds was below regulatory concem. However, the state environmental protection agency, which Yias l the regulatory responsibility for solid waste disposal and air quality l l standards, has not approved of these disposal options because of concerns that the environment could be adversely affected. Without any agreement ! i between the two agencies as to what disposal method is acceptable, the plant supervisor stated that the facility may have to store the reeds onsite l l for 30 years. l , i GAOSCED 94-133 andloesclides at sewage Treatment Plants Pese 29
i Appendia III . Locantles Addressk.g the maan , tty, Material Coocentration Problem l l 1 The city of laramie, Wyoming, is exploring the implications of privatrn ng its sewage treatment system. The city is concerned about its possible liability for the dispost.1 of sludge that might contain radioacdve materials. To obtain informadon on these issues, the city asked NRC in a September 1993 letter for its views on the legality of imposmg a municipal regulation that regulates or prohibits the discharge of radioactive materials. Specifically, the city wanted to know if such action would be preempted by the Atomic Energy Act. NRc's Deputy General Counsel for Licensing and Regulation informed the city of Laramie that, in general, if the city were to have sound reasons, other than radiation protecdon, to require the pretreatment of wastes to ehmmate or reduce radioactivity, such pretreatment would not run afoul of the Atomic Energy Act. He further stated that the NRc regulations that allow users of regulated materials to discharge to treatment plants do not compel a sewage treatment operator to accept these radioactive matenals. However, a cit., official indicated that this NRC guidance was too vague and did not answer the question of whether a municipality or a treatment plant could lawfully regulate or prohibit a licensee's discharge of radioactive materials irto its sewage treatment system. Page 30 GAOSCED 94-133 Radionuclides at sewage Treatment Pian
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l J' 'g 9, gy ' Scope and Methodology l1 I l l l I l To determine the extent to which treatment plants were having problems with radioactive sludge and ash, we examined NRC's, EPA's, and the states' studies of the occurrences of radioactive contamination at treatment j plants. We discussed treatment plant problems with NRC, EPA, and ' treatment plant association omcials. We selected a treatment plant in each ) of the 21 NRc-regulated states, which according to NRc omcfais is most likely to be receiving low-level radioactive waste from NRC's licensees, to determine whether they (1) were aware of the concentration issue,(2) had experienced any problems with radioactive materials concentratmg in l thei4 sludge or ash, and (3) had tested their sludge or ash for radioacdve l materiala. We also conducted a detailed review of the Southerly treatment plant in northeast Ohio l where NRc recently discovered elevated levels oll radioactive contamination. As part of this effort, we visited the site to observe the extent of the contamination and cleanup activities. l To determine the extent to which treatment plant workers and the public may be exposed to radioactively contammated sludge and ash and the extent of the related health implications, we reviewed the Pacific Northwest Laboratory's study sponsored by NRC to determine the possible health effects that radiological contaminated sludge and ash could have on treatment plant workers. We also spoke with treatment plant officials and reviewed documents to obtain information on what actions were undertaken to assess the health risk to treatment plant workers. We also reviewed NRc's and the treatments plants' documents to determine the
- resulta of the analyses to assess the health risks to treatment plant workers. In addition, we reviewed state information and spoke with treatment plant officials to determine the potential uses for sludge and ash by-products.
To determine what actions NRc and EPA have taken and could ta and monitor the amounts cf radiation discharged into sewer systems by licensees, we reviewed the Atomic Energy Act of 1954, as amended, the Reorganization rtan No. 3 of 1970, the Energy Reorganization Act of 1974lj {. and the Clean Water Act to determine NRC's and EPA's authority and responsibility for regulating radioactive materials in sewage systems. We also obtained information from NRc's and EPA's Omce of Genera and reviewed NRc's February 25,1994, advance notice of proposed l rulemaking on the NRC licensees' disposal of radioactihe material by release into sanitary sewer systems. At NRc, we met with various staff members, including the Director of NRc's Omce of Nuclear Material Safety l and Safeguards, and the Director of NRc's Omce of Regulatory Research to f 2 i
'm 9 8 C404tCED-94.ISS Radioniselndes at sewage Treatasent Plants
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AppendixIV > se.e. d u.a.d. soar determine what actions have been taken to limit licensees' discharges in the past. At EPA, We met with the Director and staff, Cdteria and Standards Division Omce of Radiation and Indoor Air; the Acting Director and staff, Omce of Science and Technology; the Director and staff, Health and Ecological Cdteria Division; staff from the Omce of General Counsel; staff from the Omce of Wastewater Enforcement and Compliance; and staff from the Omce of Water, Sludge Risk Assessment Branch, to determine EPA's responsibilities for regulating radioactive matedals in sewage systems. 4 i I P*** 22 GA04tCED.94131 Radinnnetideo af gewnee Treatment Pf ar >
4 _xppendix V Major Contributors to This Report 1 0 i Ji" **"">^***i^ * *** Resources 8 Gene Aloise, Assistant Director Community, and 4 PhiHp A. Olson, Assignment Manager
- Economic Mario zavaia. stanevaluatu Development Division, Washington, D.C.
Mindi G. Weisenbloom, Senior Attorney Office'of General Counsel 4 Anni ny A. Kruk wski, Regional Management Representative - Detroit ReNional Odell W. Bailey, Evaluator-m-Charge i Office Javier a. cana, stan Evaluator J r 4 Page 33 GAO/ECED-94-133 Redlemoclides at sewage Treatment Plaats
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