ML20140G142

Extends Invitation to 970609 Iscors Sewage Subcommittee Meeting in Rockville,Md to Discuss Progress on Sewage Sludge/Ash Survey & Guidance Document for POTW Operators

ML20140G142
Person / Time
Issue date:	05/28/1997
From:	Sobel P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Bastian R, Doehnert M, Goode P ENVIRONMENTAL PROTECTION AGENCY
References
REF-WM-3 NUDOCS 9706160005
Download: ML20140G142 (46)

Text

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g<i4 f I May 280 1997 l l

Dear Members of the ISCORS Sewage Subcommittee:

I invite you to attend the next meeting of the ISCORS Sewage Subcommittee to be held on June 9, 1997, from 1:00 to 3:30 p.m. The meeting will be held at the U.S. Nuclear Regulatory Commission,11545 Rockville Pike, Rockville, l l Maryland in room T-7F5. The purpose of this meeting is to discuss progress on the sewage sludge / ash survey and the guidance document for POTW operators. An agenda and the summary of the last subcommittee meeting are enclosed.

I look forward to meeting with you on June 9. If you ha/e any questions about j the meeting, please call me at (301) 415-6714 or Bob Basi.ian at the U.S.

! Environmental Protection Agency at (202) 260-7378.

Sincerely,

[0RIGINAL SIGNED BYi]

l Phyllis Sobel, Project Manager j Low-Level Waste and Decommissioning i Projects Branch  !

Division of Waste Management Office of Nuclear Material Safety ]

and Safeguards

Enclosures:

As stated  !

I DISTRIBUTION: Central File PUBLIC LLDP r/f JHickey RNeel CJones CTrottier CDaily LAbramson T0Brien ACNW i l

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Robert Bastian Office of Wastewater Management (4204)

U.S. Environmental Protection Agency Washington, DC 20460 i Paula Goode j Office of Radiation and Indoor Air U.S. Environmental Protection Agency 401 M Street, S.W.

Washington, DC 20460 Mark Doehnert Office of Radiation and Indoor Air U.S. Environmental Protection Agency 401 M Street, S.W.

Washington, DC 20460

Roy Lovett l Directorate for Safety and Engineering l ATTN

MCH0-SHE i Building 1500, Ft. Detrick Frederick, MD 21702 James Bachmaier U.S. Department of Energy Mail Stop EH-412 1000 Independence Avenue SW Washington, DC 20585 Willia'm Dornsife Director, Bureau of Radiation Protection Department of Environmental Resources Commonwealth of Pennsylvania P.O. Box 2063 Harrisburg, PA 17120 Alan B. Rubin (4304)

Office of Water United States Environmental Protection Agency l 401 M Street, S.W.

Washington, D.C. 20460 Dale Condra Oak Ridge Institute for Science and Education P.O. Box 117

Oak Ridge, Tennessee 37831-0117

Dave Saunders, EPA /NAREL ,

U.S. Environmental Protection Agency /NAREL 540 South Morris Avenue Montgomery, AL 36116 1

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[ I t . t AR Rf C 8 UNITED STATES e* -4 l j j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055!M201 l  %***+/ May 28, 1997

Dear Members of the ISCORS Sewage Subcommittee:

I invite you to attend the next meeting of the ISCORS Sewage Subcommittee to be held on June 9, 1997, from 1:00 to 3:30 p.m. The meeting will be held at j the U.S. Nuclear Regulatory Commission, 11545 Rockville Pike, Rockville,  !

Maryland'in room T-7F5. The purpose of this meeting is to discuss progress on j the sewage sludge / ash survey and the guidance document for POTW operators. An agenda and the summary ~of the last subcommittee meeting are enclosed. l 1 look forward to meeting with you on June 9. If you have any questions about ,

the meeting, please call me at (301) 415-6714 or Bob Bastian at the U.S.  !

Environmental Protection Agency at (202) 260-7378.

Sincerely, j f?by, i Phyllis Sobel, Project Manager Low-level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards l

Enclosures:

As stated l l l

i e' .9 i

j i ISCORS SEWAGE SUBCOMMITTEE ,

AGENDA FOR MAY 28, 1997 MEETING l 1:30 TO 4:00 P.M. j l

SEWAGE SURVEY ,

Quality Assurance Program Plan

• Analysis of samples from test sites ,

t Status of samples from federal facilities l Report on test sites Response to public comments on January 6, 1997 Federal Register Notice I POTW GUIDANCE DOCUMENT Water Environment Federation radiation task force meeting on May 6 May 1997 draft of guidance document Letter to States j Dose modeling - dose limit (s) and scenarios  !

FUTURE ACTIONS r Summary of action items Schedule next subcommittee meeting ,

f a

Enclosures 3

c

)

l

) .o DISCLAIMER I

These ISCORS subcommittee meeting summaries result from interagency d discussions. The Sewage Subcommittee is composed of representatives from the Environmental Protection Agency, Nuclear Regulatory Commission, Department of Defense, and Department of Energy. The subcommittee meeting i summaries have not been approved by the respective federal agencies and do not represent the official position of any participating agency at this time. l

ISCORS SEWAGE SUBCOMMITTEE  !

MEETING

SUMMARY

Date: April 24, 1997 Time: 9:00 to noon Location: EPA, Judiciary Square Office Attendees: NRC: Phyllis Sobel, Bob Neel, Bob Nelson, Lee Abramson, Chris Daily EPA: Bob Bastian, Mark Doehnert DOE: Jim Bachmaier D00: Roy Lovett EPA /NAREL: Dave Saunders, Mary Wisdom, Susan Baker ORISE: Dale Condra Agenda: Sewage Survey i POTW Guidance Document

Summary:

Mary Wisdom reported that she is still waiting for some comments on the l Quality Assurance Project Plan (QAPP) and plans to distribute the next draft l to the subcommittee members by May 2.

I Dave Saunders and Dale Condra reported on the analyses of the samples from the P0TW test sites. The gamma spec analyses are complete and the results from l the two labs show good agreement. ORISE has completed the gross alpha, gross l beta, and Carbon-14 analyses and the similar analyses at NAREL should be l complete in a few weeks. ORISE will send sample collection packages to three l l DOE sites associated with the test POTWs.

There was discussion about developing data in the same format, including

reporting uncertainty in the data and the nature of the sample (as percent

! solids). The questionnaire and the Chain of Custody form will have to be

l 4 .,.

revised to reflect these discussions. ORISE and NAREL will document their l analyses of the test site samples in a letter report to NRC and EPA

! headquarters. NRC will draft the summary report on the test sites.  ;

Phyllis Sobel distributed a summary of the five public coments on the January l 6, 1997 federal Register notice on the survey. A summary of these coments and NRC's response will be incorporated in the next Federal Register notice on  !

the survey, which will be published later this Spring.

The subcommittee discussed the April 1997 draft of the guidance document.  !

l Comments from the subcommittee members are due April 30. Then the draft .

l guidance will be revised and sent to the NRC Agreement States and industry for their comment.

The next subcommittee meeting will be on May 28 at NRC. At this meeting we ,

will discuss the lab's results on the test sites, the first draft of the -

report on the test sites, the second Federal Register notice on the survey, i and dose modeling.

Action Items:

(

l. Mary Wisdom comments will distribute the next draft version of the QAPP by May 2.

2. NAREL will finish the analysis of the test samples.

l

3. ORISE and NAREL will send EPA /HQ and NRC a letter report with the results of the analyses.  ;

4. Phyllis Sobel will draft the second Federal Register notice on the survey.

i

5. The subcommittee will submit comments on the guidance document to Phyllis Sobel by April 30. l Then she will revise the guidance and forward it to the i

NRC Agreement States and industry for their comment.

)

i l-l 4

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l May 29, 1997 MEMORANDUM T0: File FROM: Phyllis Sobel, Project Manager [0riginal signed by]

Low-Level Waste and Regulatory Issues Section Low-Level Waste and Decommissioning Projects Branch Division of Waste Management, NMSS

SUBJECT:

DRAFT GUIDANCE ON RADI0 ACTIVE MATERIALS IN SEWAGE SLUDGE / ASH .

AT PUBLICLY OWNED TREATMENT WORKS (P0TWS) ,

Attached is the draft P0TW guidance document. This document is -

currently under review by the Interagency Steering Committee on Radiation Standards (ISCORS) Sewage Subcommittee. The subcommittee has not completed parts of the document, including a table of acceptable concentrations of radioactive materials. However, the subcommittee wishes to place this document in the NRC's Public Document Room at this time so that the wastewater industry and the States can comment on the scope of the document. >

l

Attachment:

As stated I cc: Paula Goode, EPA /0RIA  ;

Mark Doehnert, EPA /0RIA .

Robert Bastian, EPA /0W j Alan Rubin, EPA /0W James Bachmaier, DOE Roy Lovett, 000 Dave Saunders, EPA /NAREL Dale Condra, ORISE TICKET: N/A  !

DISTRIBUTION: Central 11_le " LLDP r/f PUBLIC RNeel

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NAME PSobefb RNelko bHickey DATE 5/I/97 5/h97 5/)7/97 0FFICIAL RECORD COPY ACNW: YES x NO Category: Proprietary or CF Only IG : YES N0 x LSS : YES NO x Delete file after distribution: Yes No

@R R(g y' t UNITED STATES  :

4 E NUCLEAR REGULATORY COMMISSION h' f WASHINGTON, D C 20MW1 l %m '+ **

} May 29, 1997 MEMORANDUM T0: File .,

FROM: Phyllis Sobel, Project Manager M1 du .

Low-Level Waste and Regulatory Issues Sect. ion f Low-Level Waste and Decommissioning ,

Projects Branch '

Division of Waste Managerrent, NilSS

SUBJECT:

DRAFT GUIDANCE ON RADI0 ACTIVE MATERIALS IN SEWAGE SLUDGE / ASH AT PUBLICLY 0WNED TRFATMFNT W0PKS (POTWS) f Attached is the draft POTW guidance document. This document is  :

currently under review by the Interagency Steering Committee on Radiation Standards (ISCORS) Sewage Subcommittee. The subcommittee has not completed I parts of the document, including a table of acceptable concentrations of radioactive materials. However, the subccaaittee wishes to place this document in the NRC's Public Document Room at this time so that the wastewater industry and the States can comment on the scope of the document.

l

Attachment:

As stated cc: Paula Goode, EPA /0RIA l Mark Doehnert, EPA /0RIA Robert Bastian, EPA /0W Alan Rubin, EPA /0W James Bachmaier, DOE Roy Lovett, 000 i Dave Saunders, EPA /NAREL Dale Condra, ORISE l l l

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( g+ t UNITED ST ATES l j j

's NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 o ,

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• • • • • May 29, 1997 j MEMORANDUM T0: File FROM: Phyllis Sobel, Project Manager Low-Level Waste and h!c[d#s '

Regulatory Issues Section ' 1 Low-Level Waste and Decommissioning  !

Projects Branch  !

Division of Waste Management, NMSS

SUBJECT:

DRAFT GUIDANCE ON RADIOACTIVE MATERIALS IN SEWAGE SLUDGE / ASH AT PUBLICLY 0WNED TREATMENT WORKS (P0TWS) {

Attached is the draft P01,1 guidance document. This document is currently under review by the Interagency Steering Committee on Radiation Standards (ISCORS) Sewage Subcommittee. The subcommittee has not completed parts of the document, including a table of acceptable concentrations of radioactive materials. However, the subcommittee wishes to place this document in the NRC's Public Document Room at this time so that the wastewater industry and the States can comment on the scope of the document. ,

I

Attachment:

As stated I cc: Paula Goode, EPA /0RIA Mark Doehnert, EPA /0RIA Robert Bastian, EPA /0W '

Alan Rubin, EPA /0W James Bachmaier, DOE Roy Lovett, D0D Dave Saunders, EPA /NAREL Dale Condra, ORISE l

l l

I I 1 DRAFT FOR COMMENT l l

1 DISCLAIMER  !

2 This guidance document resulted from interagency discussions. The ISCORS l 3 Sewage Subcommittee is composed of representatives from the Nuclear 4 Regulatory Commission, Environmental Protection Agency, Department of 5 Energy, and Department of Defense. This document has not been approved by 6 the respective federal agencies and does not represent the official l 7 position of any participating agency at this time.

8 Guidance on Radioactive Materials in Sewage Sludge / Ash at POTWs 9 May 1997 Draft l

10 1. What is the Purpose of this Guide?

I 11 The Nuclear Regulatory Commiss'on (NRC) and the Environmental Protection 12 Agency (EPA) developed this guide to provide information about radioactive 13 materials in sewage sludge and ash from the incineration of sewage sludge at 14 publicly owned treatment works (P0TWs). It also provides background 15 information about the regulatory policies of NRC and EPA, sources of 16 radioactive materials in sewage, guidance on sampling and analysis of these 17 materials in sewage sludge and ash, and methods to assess levels of 18 radioactive materials in these byproducts of wastewater treatment. Appendix A 19 is a background discussion about radioactivity.

20 Although it is unlikely that radionuclide levels in sludges and ash at most 21 P0TWs across the country pose a concern for treatment pla-t workers or the 22 general public, it is possible that low concentrations of radioactive material 23 from natural and man-made sources could become concentrated in slt.dge products 24 at some POTWs. However, there is no general concern for worker safety or 25 general public exposures because of the low amounts of radioactive materials 26 that are legally authorized to be disposed into the sanitary sewer system by 27 Federal or State law and regulations.

28 Even though NRC and the States regulate industrial and medical discharges of 29 liquid wastes containing low levels of licensed radioactive material to the 30 sewer system, it is important for the P0TW manager and operator to understand 31 what types and amounts, if any, of radioactive materials may be entering the 32 POTW. There are several ways to develop this understanding. One way to 33 obtain this information is by sampling and testing the sludge products.

34 Another way to obtain information is to ioentify what licensed and other 35 activities discharge into the POTW and work with the licensees and other 36 industries to understand what they are discharging. Analysis of radioactive l materials can be made part of the existing analysis programs for other l

37

! 38 pollutants, or the P0TW manager or operator may want to set up a program 39 whereby any licensed discharger routinely notifies the POTW of the type, level

! 40 and timing of discharges to the system. While monitoring of the P0TW influent

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may seem to be a viable option, measurement systems may not be able to detect 2 the diluted radioactive materials. I 3

At the request of Senator John Glenn, the General Accounting Office (GA0) 4 published a report, " Actions Needed toThe Control reportRadioactive Contamination at included recommendations 5 Sewage Treatment Plants," in May 1994.

6 that NRC determine the extent of the contamination and establish acceptable 7

radioactivity limits. This guidance document is part of the NRC's response to 8 the GA0 report.

9 The operator of a POTW may decide to sample sewage sludge and ash for i radioactive materials based on the nature of industries discharging to the collection system or to establish background measurements. If measured levels 10 11 12 of radioactivity exceed the levels suggested in Section 8, it may be 13 appropriate or necessary to limit certain sludge / ash use or disposal le practices, further restrict radioactive material discharges by specific 15 licensees, or alter operations at the treatment works. ,

16 2. Who Regulates Radioactivo Material?

\

17 Regulatory responsibility for radioactive material in the U.S. is shared by

(' 18 Federal, State and local agencies. The following summary should help clarify 19 the responsibilities of the different agencies. Appendices B, C, 0 and E list 20 NRC, EPA and State contacts.

21 NRC: NRC is responsible for ensuring that discharges of radioactive materials 22 by their licensees into the sewage system are in compliance with applicable l NRC regulations under Title 10 of the Code of Federal Regulations (CFR) Part 23 24 20. Under the Atomic Energy Act of 1954, HRC regulates the civilian uses of -

25 certain radioactive materials (byproduct, source, and special nuclear 26 materials) _in the United States. These radioactive materials are used at 27 nuclear power reactors, and industrial, academic, medical, and research and 28 development facilities. NRC's mission is to ensure adequate protection of the 29 public health and safety, and to protect the environment. This mission is 30 accomplished through licensing of nuclear facilities and the possession, use

! 31 and disposal of nuclear materials; the development and implementation of 32 guidance and requirements governing licensed activities; and inspection and 33 enforcement activities to ensure compliance with these requirements. People who have a license and are regulated by NRC are called " licensees."

1 34 4 35 States: NRC has entered into agreements with 30 States to allow these States t 36 to regulate most types of radioactive material within their borders, in lieu

! 37 of NRC. These States are referred to as Agreement States. Agreement States l 38 have established regulations and proced'Jres comparable to those established by I 39 NRC. The only facilities not regulated by Agreement States are nuclear power 40 plants and Federal facilities.

! 41 Radioactive materials that occur naturally, other than uranium and thorium, 42 are not regulated by NRC. In lieu of Federal regulations, States have the 43 responsibility to regulate naturally-occurring radioactive material. At this 1 44 time, several States have issued regulations for the control of sources of 1

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i DRAFT FOR COMMENT 1 very low level radiation derived from naturally occurring materials that have l 2 been concentrated by human activities. The regulations are intended to 3 provide radiation protection to members of the public and workers who might be 1 4 exposed to that radiation. The non-federal Conference of Radiation Control l 5 Protection Directors is developing model regulations for use by State agencies l 6 in controlling these sources of radiation in their own States.

7 DOE: The Department of Energy (D0E) regulates the defense-related uses of 8 radioactive materials under authority of the Atomic Energy Act, the 9 Price-Anderson Act Amendments, and other related legislation. Nuclear weapons j 10 production, testing and research facilities, as well as former commercial '

11 radiation sites and inactive uranium mill tailings sites are subject to DOE 12 regulatory control. j 1

13 Discharges from DOE facilities of liquid wa tes containing radioactive 14 materials are regulated by internal DOE Orders and regulations. DOE Order 15 5400.5 (Radiation Protection of the Public and the Environment) establishes 16 treatment and discharge requirements for any liquid waste containing 17 radioactive materials. Any liquid wastes discharged to a sanitary sewer must 18 be below five times the Derived Concentration Guides (Chapter III of Order DOE 19 5400.5) levels at the point of discharge, or must be treated by a Best 20 Available Treatment technology to achieve levels that are at least equivalent ,

21 to these concentration limits. In addition, all releases are required to be 22 evaluated by an "As Low As Reasonably Achievable" process. Liquid wastes 23 discharged to a sanitary sewer system must also achieve levels that do not 24 interfere with handling or disposal of solids at the POTW, and that do not 25 result in general public exposures that are more than a small fraction of the 26 annual dose limit. DOE is in the process of updating these requirements in a 27 regulation (10 CFR Part 834) which, when promulgated, will replace Order DOE 28 5400.5. The proposed rule includes 10 CFR Part 20 source term limits, along 29 with the Order DOE 5400.5 concentration limits.

30 EPA: EPA is responsible for regulations to protect the health and safety of

31. workers at POTWs and the public and the environment that are exposed to sewage 32 sludge and ash produced by POTWs. EPA has responsibility for establishing 33 generally applicable standards for the protection of the environment from 34 radioactive materials under the Atomic Energy Act. EPA also administers the 35 Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA 36 or "Superfund") to provide for remedial action in response to releases or

'7 substantial threats of releases of hazardous substances into the environment.

33 EPA regulates the management of hazardous waste under the Resource 39 Conservation and Recovery Act, and toxic materials under the Toxic Substances 40 Control Act. While radioactivity is not a listed characteristic for defining 41 hazardous wastes under the Resource Conservation and Recovery Act (RCRA),

42 sites contaminated with radioactive substances have become regulated as 43 Superfund sites under CERCLA or under other regulatory programs. EPA has 44 authority to delegate these programs to State agencies while providing 45 regulatory oversight. There are currently no EPA regulations for 46 radionuclides under the Clean Air Act that apply to POTWs; however, NRC's 3

l l DRAFT FOR COMMENT 1 regulations in 10 CFR Part 20 include regulations for air emissions from its 2 licensees.

3 EPA, under its authority to provide guidance for all Federal agencies in the 4 formulation of radiation standards and in establishing cooperative programs 5 with the States, has issued proposed guidance in 1994 for radiation protection 6 of the general public. This authority stems from an executive order of the 7 President and the Atomic Energy Act. In addition, under the authority of the 8 Safe Drinking Water Act, EPA limits radiation content in drinking water. EPA 9 also protects groundwater from introduction of radioactive pollution under 10 several programs, including by regulation or statute.

11 The EPA P0TW "pretreatment program" under the Safe Drinking Water Act is 12 designed to protect the POTWs by (1) preventing the introduction of pollutants 13 into sewer systams that would interfere wi'h the operation of a P0TW, 14 including interference with its use or disposal of municipal sludge, (2) 15 preventing the introduction of pollutants into POTWs which will pass through 16 the treatment works or otherwise be incompatible with such sources, and (3) 17 improving opportunities to recycle and reclaim municipal ar.d industrial 18 wastewaters and sludges.

19 Local Authorities: Local authorities are derived from the Federal and State 20 statutes and regulations and will vary from locality to locality. The NRC has 21 found that if a municipality has sound reasons, other thtn radiation 22 protection, a municipality can require the pretreatment of wastes to eliminate ,

23 or reduce radioactivity. Furthermore, although NRC regulations allow users of j 24 regulated materials to discharge to treatment plants, these regulations do not 25 compel a sewage treatment operator to accept radioactive materials from NRC i 26 licensees. Some localities are addressing the potential problem of l 27 concentration of radioactive material at POTWs by either (1) requiring 28 pretreatment of waste by specific licensees or (2) limiting the discharge of 29 radioactive materials. For example, the State of Oregon and the city of l 30 Portland, Oregon, ordered a state licensee to install a pretreatment system to 31 control the discharge of thorium oxide into sewer lines. The Metropolitan St.

32 Louis Sewer District passed an ordinance in 1991 that limits the aggregate 33 discharge of radioactive materials into the sewage system. Other cities seem 34 unsure whether a municipality or treatment plant can lawfully regulate or 35 prohibit a licensee's discharge of radioactive materials in the sewage system.

36 Appendix F describes two examples from the cities of Albuquerque and St.

37 Louis.

38 3. Why is There Radioactivity in Sewage Sludge?

39 There are three general sources of radioactivity in the environment: a 40 natural source, a natural source but concentrated or " enhanced" by human 41 activities, and a human-made source. Natural sources of radioactivity are l 42 found widely spread in the environment. All geological formations and soils 43 contain uranium, radium, radon, and other radioactive elements in small 44 amounts. Water that originates in or moves through geologic deposits 4

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. DRAFT FOR COMMENT 1 containing naturally-occurring radioisotopes could result in these 2 radioisotopes being carried to the treatment facility with the drinking water 3 supply, storm water runoff or infiltration entering the sewer system, and 4 water treatment plant residuals discharged to the sewer system.

5 Almost everything, including people, contain some radioactive material.

6 Naturally-occurring radioactive materials are found in the food and water we 7 ingest, and even the air we breathe contains some radioactive gases. These 8 small amounts of radioactive materials can be incidentally enhanced, either 9 physically or chemically, by human activity and technologies associated with .

10 extraction processes. Examples of sources of natural radiation which have .

11 been enhanced by human activities include wastes from mineral ores and the 12 petroleum industry, sludge and scale from drinking water treatment, wastes 13 from the burning of coal, waste from geothermal energy production, and 14 articles made from naturally-occurring radioactive uaterials such as thorium ,

15 in lantern mantles. '

16 Sewage sludge and ash at POTWs may contain both naturally-occurring IT radioactive materials and radioactive materials made by hu.nans. Industrial 18 and medical facilities may be licensed to discharge radioactive materials to 19 the sanitary sewer system. In addition, radioactive materials administered to 20 patients for the diagnosis or treatment of illnesses are discharged to the 21 sewer system. Certain radioactive materials may be exempt from licensing, and i 22 these radioactive materials can be discharged into the sanitary sewer systems, j 23 Other industrial or residential discharges can contain naturally-occurring i 24 radioactive materials that are not subject to licensing or regulation, such as j 25 fertilizer residues. It is also possible that industrial, commercial, or 26 medical facilities might discharge into the sanitary sewer system outside of 27 regulations or license conditions.

28 The purpose of wastewater treatment facilities is to reduce or remove 29 pollutants from wastewater in order to ensure adequate water quality before 30 the treated effluent is reused or discharged to surface waters. The removal 31 of radionuclide contaminants by various wastewater treatment processes and the 32 usual association of these contaminants with solids can cause a concentration 33 of the radionuclides in the treatment facility's other byproduct, sewage 34 sludge (or ash if the sewage sludge is incinerated). What was once disposed 35 of into the sanitary sewer in a dilute form, may be concentrated during some 36 stages of wastewater treatment or sludge processing.

37 Concentration of radioactive materials occurs in the same manner as non- l 38 radioactive materials such as heavy metals. The concentration may occur l 39 during several stages of wastewater treatment, including various physical,  ;

40 chemical, and biological wastewater treatment processes. Sludge treatment and 41 proce >'ag may result in increasing the contentration by weight of the 42 radim eve contaminant by decreasing the concentration of other components.

43 Incine,ation of sludge has proven to be the greatest concentration process.

44 Final concentration will depend on the numerous aspects of the entire 45 processes used at the treatment facility, such as the chemical form of the 5

1 DRAFT FOR COMMENT 1 radionuclide, its half-life, the processrs used, and the efficiencies of those 2 processes. A recent study by Ainsworth et al (1994) indicated that with the 3 currently available information, it was not possible to quantitatively 4 estimate concentration factors for specific processes or for wastewater 5 treatment plants in general.

6 The EPA report " Radioactivity of Municipal Sludge" and the 1994 GA0 report 7 cited in Section 1 summarize the data available on radioactive materials in 8 sewage sludge. At specific sites, the radionuclides ranged from numerous 9 radionuclides to specific radionuclides from specific sources. Most 10 radionuclides were present at very low concentrations. At most sites, sewage 11 sludge contained radionuclides from medical treatment and research facilities 12 (Iodine-131, Chromium-51 and Selenium-75). Radionuclides are released to the 13 sewer system through releases of isotopes during handling and through 14 excretion by patients. These medical c ontaminants were found to not produce a 15 significant dose when the sludge was land applied due to their short half-16 lives. (The term half-life and other background information on radioactivity 17 are discussed in Appendix A.)

18 The 1986 EPA report cites some examples of elevated levels of radionuclides 19 found at POTWs. For example, Americium-241 in the sludge at two facilities 20 was attributed to producers of foil elements in smoke detectors. At one of 21 these sites, the State of New York paid for cleaning up the treatment plant  ;

22 and sewer lines. '

23 High concentrations of Radium-226 are found in the groundwater in some areas 24 of the U.S., for example Illinois and Wisconsin. Under the Safe Drinking ,

25 Water Act, many drinking water facilities are required to treat their drinking  !

26 water to reduce radium concentrations to acceptable levels. At some POTWs, 27 radium found in sewage sludge has been attributed to residuals discharged to 28 the sewer system from drinking water treatment facilities.

29 A more recent case of contaminated sludge involves the Northeast Ohio Degional j 30 Sewer District's (NE0RSD) Southerly Sewage Treatment Plant. A 1991 n 'ial 31 radiological survey, intended to measure radiation around an NRC lict s::e, 32 detected elevated levels of radiation at the POTW, which were found i  ! from 33 Cobalt-60, Radium-226 and Cesium-137 in the ash from incinerating their sewage 34 sludge. The latter two radionuclides were in the normal range of naturally-35 occurring radioactivity found in the area. At least part of the Cobalt-60 36 contamination was due to releases from a licensed manufacturing facility.

37 NRC, the State, and NE0RSD have funded surveys of the site. NE0RSD has funded 38 site remediation activities and installed a fence to prevent public access.

39 4. What are Dackground Radiation and Naturally-Occurring Radioactive 40 Materials?

41 Background radiation is the radiation that is emitted from naturally-occurring 42 radioactive materials in and on the Earth and in space, and does not include 43 medical and occupational activities. Almost everything, including people, 6

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DRAFT FOR COMMENT 1 contains some radioactive material. Naturally-occurring radioactive materials i 2 are found in the earth, in the materials used to build our homes, and in the i 3 food and water we ingest. Even the air we breathe contains some radioactive 4 gases.

5 The average dose of radiation exposure to an individual in the U.S. is 6 slightly more than 300 mrem /yr from their exposure to background radiation.

7 (The term " dose" and other background information on radioactivity are 8 described in Appendix A.) The annual exposure to background radiation is 9 summarized in the following table (Huffert et al, 1994):

10 Average Dose Typical Range of Variability 11 Source (mrem /vr) (mrem /vr) 12 Terrestrial 30 10 - 80 13 Radon 200 30 - 500 14 Cosmic 30 30 - 80 15 Internal 40 20 - 100 16 Terrestrial radiation comes from radioactive material that is naturally 17 occurring in the environment. Radon occurs in the environment and is listed 18 separately in the following table because of the large contribution it gives ,

19 compared to the other terrestrial sources. Cosmic radiation comes from outer i 20 space and penetrates through the atmosphere covering the earth; the amount of 21 cosmic radiation will vary depending on the altitude and latitude where one ,

22 lives. Internal radiation comes from substances that are in the human body j 23 naturally, and that are naturally radioactive, primarily Potassium-40.  ;

24 As shown, these doses can vary greatly, as the various factors that contribute l 25 to background radiation are not constant from location to location, and our l 26 lifestyles and daily activities vary these amounts to some extent. Since the )

27 atmosphere serves as a shield against cosmic radiation, this dose increases i 28 with altitude; the dose at an altitude of 1 mile (for example, in the l 29 Rockies) is about double that at sea level (30 mrem /yr). Also a flight on a l 30 commercial airliner increases your dose from cosmic gamma rays about 4 to 5 l 31 mrem for each cross-country flight.

32 Dose rates from terrestrial sources vary from about 10 to 100 mrem /yr across l 33 the U.S. The trajor sources in the ground are potassium, thorium, and uranium.

34 The higher doses are associated with uranium deposits in the Colorado Plateau, 35 granitic deposits in New England, and phosphate deposits in Florida. The 36 lowest rates are the sandy soils of the Atlantic and Gulf coastal plains. If 37 you live in a brick home, instead of one made of wood, you may add up to 10 38 mrem /yr to your annual dose due to naturally-occurring thorium, uranium, and 39 radium found in the clays of which bricks are made.

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DRAFT FOR COMMENT 1 Doses vary according to the amount of naturally-occurring material that people 2 ingest in food and drinking water. The principal naturally-occurring 3 radionuclides are potassium and radium. Potassium is commonly ingested from 4 bananas and one source of radium is Brazil nuts. Radium in water, 5 particularly ground water, varies across the U.S.; it is in higher 6 concentrations in some States such as Georgia, Illinois, Minnesota, Missouri, 7 and Wisconsin.

8 The following table lists background radionuclides that may be present in POTW 9 sewage sludge and ash. All these radionuclides are from terrestrial sources, 10 except Strontium-90 and Cesium-137, which are due to radioactive fallout from 11 atmospheric testing of nuclear weapons.

12 Tvoe of 13 Radionuclide Radiation _ Hal f-l i fe 14 Potassium-40 gamma 1.4 billion years 15 Rubidium-87 beta 52 billion years 16 Strontium-90 beta 28 years 17 Cesium-137 beta, gamma 30 years 18 Radon-222 alpha 4 days ,

19 Radium-226 alpha,samma 1600 years 20 Radium-228 beta 6 years 1 1

21 Thorium-232 alpha 14 billion years  !

22 Uranium-238 alpha 4.5 billion years 23 5. What are the Sources of Radioactivity in Sludge Caused by Human Activity?

24 In addition to radioactivity from a natural origin or global fallout from 25 weapons testing, a known source of radioactive materials in the influent to

, 26 P0TWs is from the disposal of radioactive materials enhanced by human activity 27 or produced by humans. This radioactive material is discharged into the 28 sanitary sewer system by licensed users of radioactive materials and other l 29 activities. ,

l 30 Laboratories and universities use radioactive materials (e.g. Carbon-14) in l 31 research, including the marking and detection of molecules in genetic 32 research, the study of human and animal organ systems, and in the development 33 of new drugs.

8

. o DRAFT FOR COMMENT ,

1 Radioactive materials may also be found in consumer products, such as smoke 2 detectors (Americium-241), luminous watches, and tobacco products. It is 3 estimated that the dose to an individual from consumer products is about 9 4 mrem /yr.

5 An individual also receives radiation exposure from medical procedures. In 6~ the practice of nuclear medicine, radioactive materials (e.g. Iodine-131, 7 Phosphorus-32, and Strontium-90) are administered to patients for the 8 diagnosis or treatment of illnesses such as cancer or Graves disease.

9 There are currently about 24,000 NRC and Agreement State licensees in the 10 United States. About one third of these are NRC licensees, while the 11 remainder are licensed by Agreement States. Licensees include utilities, 12 nuclear fuel fabricators, universities, medical institutions, radioactive 13 source manufacturers, and companies that use radioisotopes for industrial 14 purposes.

15 About 50% of NRC's materials licensees use either sealed radioactive sources  ;

16 or small amounts of short-lived radioactive materials. Sealed sources do not 17 pose a contamination problem "nless the encapsulation is broken. Examples of 18 facilities that do not discharge to the sanitary sewer because they use only j 19 sealed sources are well logging licensees, industrial radiography licensees, 1 20 and nuclear power plants. '

21 The remaining 50% of the NRC's materials licensees are conditionally 22 authorized to dispose radioactive materials into the sewer system. For 23 example, radioactive material is handled in " unsealed" forms in the nuclear j 24 fuel fabrication industry, in production of radiopharmaceutical medicines, and j 25 in research. The limits in quantities and concentrations NRC and the  ;

26 Agreement States allow to be discharged to the sanitary sewer are based on the j 27 dose limit that could be received by an individual member of the public, i 28 assuming certain conservative conditions in calculating the potential dose. l 29 The following table lists types of NRC licensees that could dispose ,

30 radioactive materials into the sewer system and isotopes previously found in  !

31 POTW sewage or those that could be present. It should be noted that a broad 32 scope licensee is usually authorized for any isotope with an atomic number ,

33 from 1 to 83, which means that many more isotopes than those listed here could 34 be found being disposed into the sanitary sewer, thus this table is not all 35 inclusive.

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DRAFT FOR COMMENT 1 Type of NRC Licensee Number of NRC Licensees Typical Radionuclides That Have the Potential That May be Found in to Discharge POTWs (as of 11/1/96)  !

2 Academic (broad scope) 75 Carbon-14 Cobalt-60 Cesium-137 Hydrogen-3 Iodine-125/131 Iron-59 Manganese-54 Phosphorus-32 Sulphur-35 3 Medical (broad scope, 1936 Carbon-14 4 nuclear pharmacies) Chromium-51 Cobalt-57 Gallium-67 Indium-111 Iodine-125/131 Iron-59 Phosphorus-32/33 Strontium-89/90 Sulphur-35 Technetium-99m Thallium-201 5 Manufacturing and 259 Americium-241 6 Distribution (broad Antimony-125 7 scope, nuclear Cobalt-60 l 8- laundries, Cesium-134/137  !

9 decontamination Hydrogen-3  ;

10 services) Manganese-54 Niobium-95 Phosphorus-32 Plutonium-238/239/240 Polonium-210 Strontium-89/90 Sulphur-35 Uranlum-233/234/235/238 Zirconium-95 10

O 6 DRAFT FOR COMMENT 1 Research and 666 Carbon-14 2 Development (broad Cesium-134 '

3 scope) Hydrogen-3 Iodine-125/131 Phosphorus-32 Sulphur-35 4 Others (e.g. mills, 149 Plutonium-238/239/240 5 uranium enrichment Radium-226 ,

6 plants) Thorium-228/232 Uranium-233/234/235/238 7 The half lives and types of radiation emitted by these radionuclides are 6 listed in Appendix A.

9 6. How Could People be Exposed to Radioactivity in Sewage?

10 Workers at POTWs could be exposed to low levels of radioactive materials (and 11 radiation emitted from the radioactive materials) in sludge and incinerator 12 ash. The most exposed workers would likely be sludge process operators, 13 workers at incinerator operations, and operators of heavy equipment loading 14 sludge or ash for transport.

15 Many facilitics dispose of their sewage sludge or ash offsite of the treatment 16 facility, for example by land application or into a solid waste landfill.

17 Land application of sewage sludge improves soil properties and serves as an 18 organic fertilizer. The P0TW worker, farmer or gardener would receive direct 19 exposure to the applied sludge and consumers could be exposed by ingesting 20 crsps. Workers at a landfill, farmers, or gardeners could also be exposed by 21 inhaling or ingesting the sludge in dust particles. Radioactivity could also 22 migrate into the groundwater and be consumed with drinking water.

23 7. How do I Analyze the Radioactive Material in Sewage Sludge and Ash?

24 Under what circumstances would I sai.1ple? The decision to sample should be 25 based on an assessment of the nature of industries discharging to the 26 collection system. The NRC or the Agreement State can help you determine the 27 licensees in your sewage collection system. Radioanalysis can be performed to 28 understand the levels of naturally-occurring radioactivity or made part of the 29 routine analyses for other pollutants. Examples are discussed in Appendix F.

30 Where do I sample? Collect samples of sewage sludge, ash, or other sludge 31 products produced at your facility. Collect the samples as close as possible 32 to the point where the material leaves the POTW. Examples of sampling 33 locations could be a digester, filter press or drying bed, lacoon or storage 34 pile.

35 Who analyzes the samples? It is generally necessary to send the samples to a 36 laboratory for analysis because POTWs do not have the equipment or training 11

a o DRAFT FOR COMMENT 1 necessary to perform analyses of radioactive materials. Laboratories that 2 perform such tests can be found in the American Society of Testing and 3 Materials Catalog of Laboratories or in the Yellow Pages of a telephone 4 directory. Professional organizations such as the Water Environment 5 Federation, American Water Works Association, or the Health Physics Society 6 will have listings of laboratories, and may have suggestions; or call your 7 State agency for radiation control for suggestions.

8 How do I sample? Samples can be collected by the POTW operator. Call the 9 laboratory first to discuss the types of analyses, confir.n sample volumes 10  ::eeded and types of containers, and discuss quality control procedures. The 11 laboratory may supply some of the sample materials. The amount of sample 12 collected will depend on the solid content of the material and the type of 13 analysis. Among the equipment and supplies needed to collect samples are 14 plastic jugs, trowels, scoops and Chain-o'-Custody forms.

15 Sample collection procedures are discussed in the 1989 EPA report "P0TW Sludge 16 Sampling and Analysis Guidance Document." If a sample is well-mixed, then a 17 representative sample can be easily obtained. If a sample is not well-mixed, 18 then incremental aliquots (small grab samples of equal volume) must be 19 collected and composited, to obtain a representative sample. For example, the -

20 sample might be collected from a digester, filter press or drying bed, truck, 21 tank, or pile. A liquid or slurry sample from a digester or tank should be 22 from an outlet stream. The outlet or sample port should be opened and allowed 23 to flow until a representative sample is available. If a sample of the total  :

24 stream cannot be collected. then the stream should be cut across for equal '

25 time periods until the sample container is full. A sample collected from a 26 filter press should be a composite of several small samples collected at ,

27 different locations across the press or within the filter cake. A sample 1 28 collected from a drying bed, truck, or pile should be scoops from various  !

29 areas and levels of the drying bed, truck or pile. A sample of incinerator l 30 ash should be from the location where it is collected or stored. The 31 collection date and time should be close to the date that the sludge or ash 32 leaves the plant for transport to a landfill or for land application.

33 How do I ship the samples to the laboratory? The following are general 34 instructions. If you have any questions or need assistance, contact the 35 laboratory performing the analysis.

36 Ensure that the samples are properly labeled with the name of the facility, 37 location or source of the sample, the name of the person taking the sample, 38 and the sample date and time. Complete a Chain-of-Custody form with the name 39 of the facility, location or source of the sample, the name of the person 40 taking the sample, and the sample date and time. Place the samples in the ,

41 shipping container. The person taking the sample should sign the completed  !

42 Chain-of-Custody form and enclose the form uith the samples. Seal the  !

shipping container and place the security seal across the top of the 43 44 container, and attach the appropriate shipping labels. Send the sartples to ,

45 the laboratory as quickly as possible (e.g. overnight delivery) after '

12 4

DRAFT FOR COMMENT 1 collection. This will eliminate the need for refrigeration of the samples.

2 What analyses should I request? At a minimum, the laboratory should perform 3 gamma spec analysis and gross alpha / beta analysis. Consider the licensees in 4 the collection system before deciding on any additional alpha- or beta-5 emitting radionuclide analysis. Typical radionuclides from various types of 6 NRC licensees are listed in Section 5 and Appendix A. For example, Americium-7 241, an alpha and gamma emitter, could be discharged by a smoke detector 8 manufacturer. Tritium, a beta emitter, is used in manufacturing luminous 9 signs. Phosphorus-32 and Strontium-90, both beta emitters, are medical 10 isotopes.

11 What will the analysis cost? The cost will depend on the type of analysis 12 that is requested. The more detailed or complicated the analysis, the more 13 expensive and time demanding the analysis becomes. For instance, gamma 14 analysis of samples is relatively easy, as well as gross alpha and beta 15 iadiation counting. But alpha and beta energy analysis to identify specific 16 radionuclides can be time consuming and expensive. Gamma spec analysis for 17 one sample should cost several hundred collars, gross alpha / beta analysis 18 several hundred dollars, and radiochemical analysis for alpha and beta 19 emitters from several hundred to several thousand dollars, depending on the 20 radionuclides analyzed.

21 8. How Do I Evaluate the Results?

22 NOTE: NRC and EPA do not currently have regulations addressing radioactive 23 materials in sludge products at POTWs. NRC and EPA are developing the 24 following table to describe concentrations of radioactive materials in 25 sludge or ash. These estimated concentrations will be based on dose 26 modeling calculations which assume how individuals could be exposed to 27 these radioactive materials. These models, for example, assume that an 28 individual spends % of the year on site and hours a day outside. So 29 far, a dose level has not been chosen for the Eilculations. We welcome any 30 comments on the need for this table and the appropriate dose level for the 31 calculations. In the interim, the table will be developed for factors to 32 convert concentration to dose or risk.

33 Concentration to Dose (or Risk) Conversion Factors 34 for Radioactive Materials in Sewage Sludge and Ash 35 (UNDER DEVELOPMENT) 36 Radionuclide Dose (or risk) per pCi/g Dose (or risk) per pCi/g of Sludge of Ash Concentration Concentration 37 Americium-241 38 Cesium-137, etc.

13

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DRAFT FOR COMMENT l

l 1 If radioactive material exceeding these values is detected at a P0TW that is l 2 located in an Agreement State, contact the appropriate State regulatory 3 authority (Appendices B and E). If the P0TW is located in a non-Agreement 4 State, contact the NRC regional office (Appendix C). The appropriate 5 regulatory authority will help you trace the origin of the radioactive

! 6 material. For example, the NRC or the .'greement State can help you determine 7 the licensees in your sewage collection system if you provide a list of zip i

8 codes in your collection system. If measured levels of radioactivity exceed 9 the above levels, it may be necessary to further restrict discharges of wastes 10 to the sewer system by a specific licensee, alter operations at the treatment i 11 works, or limit certain sludge / ash use/ disposal practices.

12 9. Comments or Questions on this Guidance?

13 If you hav. any questions or comments regarding the information presented in ,

14 this guidance document, please contact either NRC or EPA- '

15 U.S. Nuclear Regulatory Comm':ssion  !

16 Low-Level Waste and Decommissioning Projects Branch ,

17 (301) 415-7234 or contact through NRC's operator on the toll-free )

18 telephone r. umber 800-368-5642.  !

l 19 or 20 Robert Bastian .

21 U.S. Environmental Protection Agency (4204) 22 Office of Wastewater Management 23 401 M Street, SW 24 Washington, DC 20460 25 (202) 260-7378 I

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l DRAFT FOR COMMENT 1

1 Appendices 2 A. Fundamentals of Radiation 3 B.- NRC and EPA Regional Offices by State and Identification of Agreement 4 States 5 C. NRC Regional Offices

'6 D. EPA Regional Offices 7 E. State Agencies for Radiation Control 8 F. Examples of POTWs that have Radionuclide Materials Programs 9 G. Bibliography and Sources of Additional Information '

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1 1

1 DRAFT FOR COMMENT 1 APPENDIX A 2 FUNDAMENTALS OF RADIATION l

3 What is Radiation?

4 People are subjected to natural radiation from outer space, from naturally- l 5 occurring radioactive materials in soils, in the food and water we consume, l 6 and in the buildings where we live and work. The term " radiation" as it i 7 relates to radioactive material describes the energy given off by the material  !

8 as it decays. Ionizing radiation produces charged particles, or ions, in the  !

9 material in which it encounters. At excessive levels, the process of 10 ionization can cause disease and injury to plants and animals.

11 The three most common types of ionizing radiation are:

12

• Alpha radiation - positively charged particles that are emitted from 13 naturally-occurring and man-made radioactive material. Uranium, thorium 14 and radium emit alpha rad'ation and so they are called " alpha emitters." l 15 The alpha particle has the least penetrability. Most alpha particles  :

16 can be stopped by a single sheet of paper or skin. Consequently, the i principle hazard from alpha emitters to humans is caused when the 17 18 material is ingested or inhaled. The limited penetration of the alpha l 19 particle means that the energy of the particle is deposited within the '

20 tissue (e.g., lining of the lungs) nearest the radioactive material once 21 inhaled or ingested. Examples of alpha emitters are the naturally-22 occurring radionuclides radon, radium, thorium and uranium.

23 - Beta radiation - negatively charged particles that are typically more 24 penett ating but have less energy than alpha particles. Beta particles 25 can penetrate human skin or sheets of paper, but can usually be stopped 26 by thin layers of plastic, aluminum, or other materials. Carbon-14 and 27 Hydrogen-3 (or tritium) are two common " beta emitters." Although they 28 can penetrate human skin, beta particles are similar to alpha particles 29 in that the predominant hazard to humans comes from ingesting or 30 inhaling the radioactive materials that emit beta radiation.

31

• Gamma (or X-ray) radiation - the most penetrating type of radiation.

32 They can pass through the human body and common construction materials.

33 Thick and dense layers of concrete, steel, or lead are used to stop 34 gamma radiation from penetrating to areas where humans can be exposed.

35 Gamma emitters can pose both external and internal radiation hazards to 36 humans. Technetium-99m is an example of a " gamma emitter" that is 37 widely used in medical diagnosis. Potassium-40, a common naturally-38 occurring radionuclide, is also a gamma emitter.

39 Some radionuclides emit more than one type of radiation. For example, Cesium-l 40 137 and Iodine-131 are both gamma and beta emitters.

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l i-DRAFT FOR COMMENT 1 How is Radiation Measured?

2 .

Whether it emits alpha or beta particles or gamma rays, the quantity of 3 radioactive material is typically expressed in terms of its redfoactivity or 4 simply its activity and is measured in Curies. One Curie equals 37 billion 5 atomic disintegrations per second. Activity is used to describe a material, 6 just as one would discuss the length or weight of a material. For example, 7 one would say "the activity of the uranium in the container is 2 Curies."

8 Generally, the higher the activity of the material, the greater the potential 9 health hazard associated with that material if it is not properly controlled.

10 At nuclear power reactors, the activity of radioactive material may be <

11 described in terms of hundreds to millions of Curies, whereas the units 12 typically used to describe activity in the environment and at POTWs are often 13 microcuries (pCi) or picocuries (pci). A microcurie is one one-millionth 14 (1/1,000,000) of a Curie and a picocurie is one one-trillionth

15. (1/1,000,000,000,000) of a Curie.

16 The activity of a radionuclide decreases or decays at a constant rate. The 17 time it takes the activity of . radioactive material to decrease by half is 18 called the radioactive half-life. After one half-life, the remaining activity 19 would be one-half (1/2) of the original activity. After two half-lives, the 20 remaining activity would be one fourth (1/4), after three half-lives one 21 eighth, and so on. For example, if a radionuclide has a half-life of 10 22 years, the amount of material remaining after 10 years would be 1/2 of that 23 originally present. After 100 years (10 half-lives), the remaining activity l 24 would be 1/1024 of the amount that was originally present. Some radioactive 25 materials have extremely short half-lives measured in terms o minutes or 26 hours; for example, Iodine-131, uH in medical procedures, s.as a half-life 27 of 8 days. Others have half-lives measured in terms of millions to billions 28 of years; for example, naturally occurring Thorium-232 has a half-life of 14 29 billion years, and natural Uranium-238 has a half-life of 4.5 billion years.

30 Some radioactive materials decay to form other radioactive materials. These 31 so-called decay products, in turn, decay to stable nuclides or other 32 radioactive materials. Each material formed through decay has a unique set of 33 radiological properties, such as half-life and energy given off through decay.

34 In the case of the radioactive materials at P0TWs, the radioactive materials 35 present may consist of one or more separate decay " chains" or " series." The 36 naturally-occurring uranium and thorium decay chains are summarized in the 37 following table.

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DRAFT FOR COMMENT 1 Series: Uranium Thorium 2 Uranium-238 Thorium-232 3 1 1 4 Uranium-234 Radium-228 5 1 1 6 Thorium-230 Thorium-228 7 1 1 8 Radium-226 Radium-224 9 4 4 10 Radon-222 Radon-220 11 4 4 12 Lead-210 Lead (Stable) 13 1 14 Lead (Stable) 15 Some of the radioactive materials in these chains emit gamma rays when they 16 decay. The intensity of gamma radiation in air or exposure rate is measured 17 in Roentgens (R) or microRoentgens (gR) per unit time, usually an hour, as in 18 R/hr or #R/hr. In the environment, exposure rates are typically measured in 19 terms of yR/hr. For example, in many parts of the United States the exposure 20 rate from natural sources of radiation is between 5 and 15 pR/hr. This 21 ambient level is referred to as the background exposure rate.

22 Many commercially available radiation detectors measure radiation fields in 23 terms of pR/hr or counts per minute (cpm). " CPM" refers to the number of 24 ionizing particles striking the detector surface in a minute. A fraction of 25 these particles are recorded by the detector as counts. The number of counts 26 per minute can then be related to exposure rate or radiation dose for a known 27 radionuclide for which the instrument has been calibrated.

28 Radiation dose is a measurement or estimate of the body's exposure to ionizing 29 radiation. It is typically measured in units of rem. In the environment and 30 at POTWs, doses are often measured in terms of millirem (mrem). A millirem is 31 one one-thousandth (1/1,000) of a rem; a microrem is one-millionth of a rem 32 (1/1,000,000). The dose rate is expressed in terms of dose per unit time, 33 again usually an hour, as millirem /hr. For external radiation, exposure rates 34 are often equated to dose rates using the conversion of 1 yR/hr = 1 35 microrem/hr. Doses from internal exposure to radioactive material that has 36 been ingested or inhaled are more difficult to determine. Computer models 37 that account for the distribution and excretion of the radioactive material 38 within the body are used for estimating doses and dose rates from internal 39 radioactive contamination.

40 What are the Effects of Radiation Exposure?

41 When radiation interacts in and through living tissue, it may damage some l 42 cells in the body. Some cells may not survive the damage and die while other l

! 3

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DRAFT FOR COMMENT 1 cells will survive the damage and reproduce normally. Other damaged cells may 2 survive, but in a modified form, which may later result in cancer. Other ,

3 health effects from low doses of radiation (tens of rems) may include birth )

4 defects and genetic effects. High doses of radiation (hundreds of rems) over  !

5 short periods of time may cause organ damage and, if high enough, death.

6 Doses associated with exposures to natural background radiation or typical 7 radioactive materials in POTWs are thousands of times lower than the high l 8 doses that can cause significant biological damage.

9 At low doses, the principal concern associated _with radiation exposure is the 10 possible occurrence of cancer years after the exposure occurs. Other effects 11 such as birth defects and genetic effects are less likely. For such low 12 doses, the likelihood of producing cancer has not been directly established 13 because it is not possible to distinguish cancers produced by such low levels 14 of radiation from cancers produced by other sources, such as harmful chemicals 15 in the environment. Therefore, in estimating the consequences of any exposure 16 to radiation, it is assumed that the risk of developing cancer is linearly 17 proportional to dose and that there is no threshold below which there is no 18 chance of cancer. This chance, or risk, is expressed in terms of probability 19 of an adverse health effect because a given dose of radiation does not produce 20 a cancer in all cases. The NRC uses the linear assumption and the philosophy 21 that radiation exposure should be kept as low as reasonably achievable (ALARA) 22 for purposes of regulating the use of radioactive materials.

23 What are the types of radiation and half-lifes for the radionuclides that are 24 caused by human activities and may be present at POTWs?

25 Radionuclide Type of Radiation Hal f-l i fe l

26 Americium-241 alpha, gamma 458 years 27 Antimony-125 gamma 3 years 28 Bery11ium-7 gamma 53 days l 29 Carbon-14 beta 5730 years l 30 Cesium-134 beta, gamma 2 years 31 Cesium-137 beta, gamma 30 years 32 Chromium-51 gamma 28 days 33 Cobalt-57 gamma 271 days .,

34 Cobalt-60 beta, gamma 5 years 35 Gallium-67 gamma 3 days 36 Hydrogen-3 (tritium) beta 12 years 37 Indium-lll gamma 3 days 4

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1 Iodine-123 gama 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> 2 Iodine-125 gamma 60 days 3 Iodine-129 beta, gamma 20 million years 4 Icdine-131 beta, gamma 8 days 5 Iridium-192 beta, gamma 74 days 1

6 Iron-59 gamma 45 days '

7 Lead-210~ alpha, beta, gamma 22 years i'

8 Manganese-54 gamma 303 days ,

9 Niobium-95 beta, gamma 35 days 10 Phosphorus-32 beta 14 days 11 Phosphorus-33 beta 25 days 12 Plutonium-238 alpha 86 years 13 Plutonium-239 alpha 24,400 years 14 Plutonium-240 alpha 6580 years 15 Polonium-210 alpha 138 days 16 Radium-226 alpha, gamma 1600 years 17 Selenium-75 gamma 120 days .

J 18 Strontium-89 beta 52 days 19 Strontium-90 beta 28 years 20 Sulphur-35 beta 87 days J 21 Technetium-99m gamma 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 22 Thallium-201 gamma 3 days 23 Thorium-228 alpha, gamma 2 years 24 Thorium-232 alpha 14 billion years 25 Uranium-233 alpha, gamma 162,000 years 26 Uranium-234 alpha 247,000 years 27 Uranium-235 alpha 710 million years j 28 Uranium-238 alpha 4.5 billion years 29- Xenon-133 beta, gamma 5 days 30 Zinc-65 beta, gamma 245 days 31 Zirconium-95 beta, gamma 64 days 5

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l l DRAFT FOR COMMENT l

1 What are the Standards for Protection of Human Health from Exposure to Hazards 2 such as Ionizing Radiation and Radioactivity in Sewage Sludge?

3 EPA standards and criteria pertinent to setting standards or guidance for <

4 levels of radioactivity in sewage sludge might include:

5 Standard or Guideline Type Year Limit (dose or risk) 6 Standards for the Use or Regulation (40 1993 Concentration of 7 Disposal of Sewage Sludge C.F.R.503) carcinogens at 1 x 10

8 (does not include risk and risk reference 9 radionuclides) doses for metals 10 Radiation Si'e t Cleanup Draft regulation 1994 15 mrem / year and (40 C.F.R. 196) protection of ground water to Safe Drinking Water Act Maximum Contaminant Levels (MCLs) i 11 Uranium Mill Tailings Regulation (40 1983 Concentration-based C.F.R. 192) criteria for land, buildings, and ground water, e.g., 5 pCi/g of radium-226 over the first 15 cm of soil averaged over 100 square meters 12 Resource Conservation and Advance Notice of 1996 10 to 10 risk range '

13 Recovery Act (RCRA) - Proposed and protection of ground 14 Corrective Action for regulation (40 water to 15 Releases From Solid Waste C.F.R 264, MCLs 16 Management Units at Hazardous Subpart S) i 17 Waste Management Facilities  ;

18 Management and Disposal of Regulation (40 1985 NRC regulated facilities: l 19 Spent Fuel, High Level, and C.F.R. 191, 25 mrem /yr whole body or J 20 Transuranic Waste subpart A- critical organ; 75 management) thyroid; DOE regulated i facilities: 25 whole body, 75 critical organ 21 National Oil 'and Hazardous Regulation (40 CFR 1990 10 to 10 risk range, 22 Substances Pollution 300) protection of ground 1 23 Contingency Plan (Superfund) water to MCLs l 24 Certification Criteria for Final regulation 1996 15 mrem /yr and MCLs )

25 WIPP Compliance With 40 CFR (40 C.F.R. 194) j 26 Part 191 l 1

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DRAFT FOR COMMENT Standard or Guideline Type Year Limit (dose or risk) 1 Radiation Protection Guidance Final guidance 1967 As low as reasonably 2 to Federal Agencies for achievable (ALARA) and 3 Occupational Exposure not to exceed 5 rems in any year by an adult worker. Also includes guidance to not exceed 0.5 rem to an unborn worker's child or not exceed one-tenth of the adult value for individuals under eighteen years old 4 Federal Radiation Protection Proposed guidance 1994 No exposure to the public 5 Guidance for Exposure of the unless it is justified by 6 General Public an expected overall benefit from activity l causing exposure; dose to individuals as low as reasonably achievable I (ALARA); 100 mrem /yr from '

all sources covered by guidance combined; standards or regulations at a fraction of 100 for individual sources 7 Management and Disposal of Regulation (40 1993 15 mrem /yr and MCLs 8 Spent Fuel, High-level, and C.F.R. 191, 9 Transuranic Waste Subpart B-disposal) 10 National Emission Standards Regulation (40 1989 10 mrem /yr 11 for Hazardous Air Pollutants; C.F.R. 61, 12 Radionuclides Subparts H and I) 13 Uranium Fuel Cycle Regulation (40 1977 25 mrem /yr whole body or C.F.R. 190) critical organ; 75 thyroid 14 Drinking Water MCLs - Regulation (40 1976 4 mrem /yr 15 Beta / photon emitters C.F.R. 141) 16 Drinking Water MCLs - Alpha Regulation (40 1976 15 pCi/l 17 emitters C.F.R. 141) 7

l.

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DRAFT FOR COMMENT l l Standard or Guideline Type Year Limit I

( (dose or risk)  !

! 1 Drinking Water MCLs - Radium Regulation (40 1976 5 pCi/l l

C.F.R. 141) 2 The basic radiation protection standards formulated by the NRC for 3 radionuclide users are published in the Code of Federal Regulations (CFR),

4 Title 10, Part 20. These standards were prepared from the recommendations of 5 advisory boards such as the National Council on Radiation Protection and

, 6 Measurements (NCRP, 1971, Report 39) and the International Committee on

! 7 Radiological Protection. The requirements for disposal of radioactive  :

8 materials into the sanitary sewer are in 10 CFR 20.2003.

9 Radiation protection standards applicable to DOE facilities are found in the 10 following regulations and internal DOE Orders:

11 10 CFR Part 834 - Radiation Protection of the Public and the Environment 12 (to be issued soon) 13 10 CFR Part 835 - Occupational Radiation Protection 14 Order DOE 5400.1 - General Environmental Protection Program 15 Order DOE 5400.5 - Radiation Protection of the Public and the 16 Environment 17 Order DOE 5820.2A - Radioactive Waste Management

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DRAFT FOR COMMENT APPENDIX B NRC AND EPA REGIONAL OFFICES BY STATE AND IDENTIFICATION OF. AGREEMENT STATES i

State

• NRC Reaional Office EPA Reaional Office ALABAMA

• II 4 ALASKA IV 10 ARIZONA

• IV 9 ARKANSAS

• IV 6 CALIFORNIA

• IV 9 COLORAD0* IV 8 CONNECTICUT I I DELAWARE I 3 <

I DST OF COLUMBIA 3 FLORIDA

• II 4 GEORGIA

• II 4 HAWAII IV 9 IDAHO IV 10 ILLIN0IS* III 5 INDIANA III 5 .

IOWA

• III 7 KANSAS

• IV 7 KENTUCKY

• II 4 LOUISIANA

• IV 6 MAINE

• I 1 MARYLAND

• I 3 MASSACHUSETTS

• I 1 MICHIGAN III 5.

MINNES0TA III 5 MISSISSIPPI

• II 4 MISSOURI III 7 -

MONTANA- IV 8 NEBRASKA

• IV 7 ,

NEVADA

• IV 9 NEW HAMPSHIRE

• I 1 NEW JERSEY I 2 NEW MEXIC0* IV 6 NEW YORK

• I 2 NORTH CAROLINA

• II 4 NORTH DAK0TA* IV 8 OHIO III 5 OKLAHOMA IV 6 OREGON

• IV 10 PENNSYLVANIA I 3 RHODE ISLAND

• I I SOUTH CAROLINA

• II 4 SOUTH DAKOTA IV 8

TENNESSEE

• II 4 j TEXAS

• IV 6

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• NRC Reaional Office EPA Reaional Office  ;

UTAH

• IV 8 i VERMONT I I 1 VIRGINIA II 3 WASHINGTON

• IV 10  ;

WEST VIRGINIA II 3 WISCONSIN III 5 WY0 MING IV 8 ,

CANAL ZONE II PUERTO RICO II 2 VIRGIN ISLANDS II 2 GUAM IV 9 i AMERICAN SAM 0A IV 9  !

• indicates Agreement State as of 3/31/97 ,

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APPENDIX C NRC REGIONAL OFFICES  !

1 Division of I

Nuclear Materials State Agreements l

Address Safety Officer l i Region I (610) 337-5281 (610) 337-5216 .

475 Allendale Road  !

4 King of Prussia, PA 19406-1415 j l

. Region II (404) 562-4700 (404) 562-4704 l Atlanta Federal Center

61 Forsyth St, SW l

Suite 23T85 Atianta, Ga 30303-3415 l Region III j (630) 829-9800 (630) 629-9818 801'Warrenville Road I Lisle, IL 60532-4351 Region IV (817) 860-8106 (817) 860-8267 Harris Tower -

611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064

DRAFT FOR COMMENT APPENDIX D EPA REGIONAL OFFICES EPA Radiation Proaram Manaaers EPA Region 1 EPA Region 2 John F. Kennedy Federal Building 290 Broadway One Congress Street New York, NY 10007-1866 Boston, MA 02203-0001 (212) 264-4110 (617) 565-4602 EPA Region 3 E A Region 4 Special Program Section (3AM12) 101 Alabama St., S.W.

841 Chestnut Street Atlanta, GA 30365 Philadelphia, PA 19107 (404) 347-3907 (215) 597-8326 EPA Region 5 EPA Region 6 5AR26 Air Enforcement Branch (6T-E) 77 West Jackson Boulevard 1445 Ross Avenue Chicago, IL 60604-3507 Dallas, TX 75202-2733 (312) 886-6175 (214) 655-7224 EPA Region 7 EPA Region 8 726 Minnesota Avenue 8HWM-RP, Suite 500 Kancas City, KS 66101 999 18th Street (913) 551-7605 Denver, CO 80202-2466 (303) 293-1440 EPA Region 9 EPA Region 10 Al-1 AT-082 75 Hawthorne Street 1200 Sixth Avenue San Francisco, CA 94105 Seattle, WA 98101 (415) 744-1048 (206) 553-7660 i

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DRAFT FOR COMMENT APPENDIX E STATE AGENCIES FOR RADIATION CONTROL

! Kirksey E. Whatley, Director State Department of Public Health Division of Radiation Control ,

! State Office Building  !

434 Monroe Street Montgomery, AL 36130-1701 Phone - (334)613-53911 Bernard R. Bevill, Acting Director Department of Health Division of Radiation Control & Emergency Mgmt 4815 West Markham Street, Slot 30 l Little Rock, AR 72205-3867 Phone - (501)661-2301 Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40th Street Phoenix, AZ 85040 Phone - (602)255-4845 ext. 222 Edgar D. Bailey, C.H.P., Chief State Department of Health Services Radiologic Health Branch Food, Drugs & Radiation Safety Division 714/744 P Street 601 N 7th Street, Continental Plaza P.O. Box 942732 Sacramento, CA 94234-7320 95814 Phone - (916)322-3482 Robert M. Quillin, Director Department of Public Health & Environment Radiation Control Division 4300 Cherry Creek Drive South (RCD-D0-B1)

Denver, CO 80222-1530 4 l

Phone - (303)692-3030 William A. Passetti, Acting Chief u Department of Health & Rehabilitative Services

! Office of Radiation Control l 1317 Winewood Boulevard l 2009 Apalachee Parkway Tallahassee, FL 32399-0700 32301 i

Phone - (904)487-1004

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DRAFT FOR COMMENT Thomas E. Hill, Manager  !

Department of Natural Resources i 4l Radioactive Materials Program l 4244 International Parkway, Suite 114 Atlanta, GA 30354 Phone - (404)362-2675  !

Donald A. Flater, Chief Iowa Department of Public Health Bureau of Radiological Health j Lucas State Office Building 321 East 12th Street .

Des Moines, IA 50319 l Phone - (515)231-3478 Thomas W. Ortciger, Director '

Department of Nuclear Safety 1035 Outer Park Drive Springfield, IL 62704 i Phone - (217)785-9868  ;

Vic Cooper, Director i Bureau of Air & Radiation  !

X-Ray & RAM Control Section Department of Health & Environment Forbes Field, Building 283 J Street & 2nd North Topeka, KS 66620 Phone - (913)296-1562 Charles M. Hardin, Executive Director Conference of Radiation Control Program Directors, Inc.

205 Capital Avenue Frankfort, KY 40601 Phone - (502)227-4543 John A. Volpe, Ph.0, Manager #2 Cabinet for Health Services Radiation & Toxic Agents Control Section 275 East Main Street Frankfort, KY 40621-0001 Phone - (502)S64-3700

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William H. Spell, Administrator ,

Department of Environmental Quality Radiation Protection Division Office of Air Quality & Radiation Protection 7220 Bluebonnet Road i

P.O. Box 82135 Baton Rouge, LA 70884-2135 Phone - (504)765-0160 Robert M. Hallisey, Director Department of Public Health  !

Radiation Control Program 305 South Street, 7th Floor Jamaica P1ain, MA 02130 2 Phone - (617)727-6214 ,

Roland G. Fletcher, Manager  !

Maryland Department of the Environment i Radiological Health Program Air and Radiation Manacement Administration 2500 Broening Highway Baltimore, MD 21224 Phone - (410)631-3300 Robert J. Schell, Nuclear Engineering Specialist Radiological Health Program Division of Health Engineering l State House, Station 10  ;

157 Capitol Street j Augusta, ME 04333 i j

Phone - (207)287-5698 Robert W. Goff, Director State Department of Health Division of Radiological Health 3150 Lawson Street P.O. Box 1700 i Jackson, MS 39215-1700 39213 )

Phone - (601)354-6657 R.M. Fry, Acting Director Department of Environment, Health & Natural Resources Division of Radiation Protection 3825 Barrett Drive Raleigh, NC 27609-7221 27609-7221 Phone - (919)571-4141 .

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DRAFT FOR COMMENT Dana K. Mount, Director Department of Health Division cf Environmental Engineering 1200 Missouri Avenue, Room 304 P.O. Box 5520 Bismarck, ND 58506-5520 Phone - (701)328-5188 Mark B. Horton, M.D., M.S.P.H., Director Nebraska Department of Health 301 Centennial Mall South P.O. Box 95007 Lincoln, NE 68509-5007 Phone - (402)471-2133 Diane E. Tefft, Administrator Division of Pu'?,1c Health Services Radiological Health Bureau Health and Welfare Building 6 Hazen Drive Concord, NH 03301-6527 Phone - (603)271-4588 Benito Garcia, Chief Department of Environment Bureau of Hazardous & Radioactive Materialt Water and Waste Management Division 2044 Galisteo Road

! P.O. Box 26110 Santa Fe, NM 87502 87505 Phone - (505)827-1557 Stanley R. Marshall, Supervisor Department of Human Resources Radiological Health Section 400 West King Street, Room 101 Carson City, NV 89710 Phone - (702)687-5394 Rita Aldrich, Principal Radiophysicist New York State Department of Labor Radiological Health Unit Division of Safety and Health New York State Office Campus Building 12, Room 457 Albany, NY 12240 Phone - (518)457-1202

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John P. Spath, Director #2 New York State Energy Research & Development Authority Radioactive Waste Policy and Nuclear Coordination ,

Corporate Plaza West '

286 Washington Avenue Extension Albany, NY 12203-6399 Phone - (518)862-1090 ext.3302 Paul J. Merges, Ph.D., Chief #3 -

Department of Environmental Conservation Bureau of Pesticides and Radiation Division of Solid and Hazardous Materials -

50 Wolf Road, Room 402 Albany, NY 12233-7255 12233 Phone - (518)457-2225 Karim Rimawi, Ph.D., Director #4 New York State Department of Health Bureau of Environmental Radiati'n Protection ,

Two University Place Albany, NY 12203 Phone - (518)458-6461 ,

Kenneth R. Daniel, Deputy Director #5 New York City Department of Health Bureau of Radiological Health 111 Livingston Street, Room 2006 Brooklyn, NY 11201-5078 Phone - (718)643-8029 Roger L. Suppes, Chief Ohio Department of Health Bureau of Radiological Health 35 East Chestnut Street P. . Box 118 Columbus, OH 43266-0118 Phone - (614)644-2727 Mike Broderick Environmental Program Administrator Department of Environmental Quality Radiation Management Section 1000 NE 10th Street Oklahoma City, OK 73117-1212 Phone - (405)271-7484

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Ray D. Paris, Manager i Department of Human Resources l Radiation Protection Services i State Health Division 800 N.E. Oregon Street 4 Portland, OR 97232  ;

Phone - (503)731-4014

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William P. Dornsife, Director )

Department of Environmental Protection l Bureau of Radiation Protection l 400 Market Street j P.O. Box 8469 I Harrisourg, PA 17101  ;

Phone - (717)787-2480 ,

Marie Stoeckel, Chief Department of Health Division of Occupational & Rad'91ogical Health 3 Capital Hill, Room 206 Providence, RI 02908-5097 Phone - (401)277-2438 l

Virgil R. Autry, Director l' Department of Health & Environmental Control Division of Radioactive Waste Management  !

Bureau of Solid and Hazardous Waste l 2600 Bull Street Columbia, SC 29201 Phone - (803)896-4244 Max K. Batavia, P.E., Chief #2 i Department of Health & Environmental Control l Bureau of Radiological Health  !

2600 Bull Street l Columbia, SC 29201 Phone - (803)737-7400 Michael H. Mobley, Director Department of Environment and Conservation i Division of Radiological Health L&C Annex,.3rd Floor 401 Church Street Nashville, TN 37243-1532 Phone - (615)532-0360 I q

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DRAFT FOR COMMENT Minor Brooks Hibbs, P.E., Director Texas Natural Resource Conservation Commission Industrial & Hazardous Waste Division .,

12015 NIH-35  :

P.O. Box 13087 i Austin, TX 78711-3087  ;

Phone - (512)239-6592 Richard A. Ratliff, P.E., Chief #2 Texas Department of Health Bureau of Radiation Control 1100 West 49th Street Austin, TX 78756-3189 Phone - (512)834-6688 i William J. Sinclair, Director Department of Environmental Quality Division of Radiation Control 163 North 1950 West P.O. Box 144850 Salt Lake City, UT 84114-4850 Phone - (801)536-4250

John L. Erickson, Director Department of Health Division of Radiation Protection Airdustrial Center Building #5 P.O. Box 47827 Olympia, WA 98504-7827 Phone - (360)664-4536 l

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DRAFT FOR COMMENT 1 APPENDIX F 2 EXAMPLES OF POTWS THAT HAVE RADIONUCLIDE MATERIALS PROGRAMS l

3 Albuquerque, New Mexico 4 The City of Albuquerque has established a Radioactive Discharge Monitoring 5 Program (RDMP). This is a voluntary program of monitoring and reporting. The 6 Albuquerque POTW has found they have the responsibility to be aware of all 7 discharges to the sewer system that could impact operations at the treatment 8 plant or impact the health and safety of employees and the public. The POTW 9 has implemented a program of discharger registration that requires dischargers 10 to (1) periodically report their radionucli e discharges, (2) allow the P0TW 11 to perform surveillance monitoring, and (3) commit to voluntarily limit their 12 discharges to levels that are as low as reasonably achievable (ALARA). These 13 registrations are issued and monitoring of the dischargers is permitted in 14 accardance with a city sewer use and wastewater control ordinance. The 15 agreement could be in the form of an amendment to an existing sewer discharge 16 permit.

17 The Albuquerque POTW obtained a list of licensed radioactive materials users .

18 in the municipal service area from the appropriate regulatory authority (New 19 Mexico is an Agreement State). Each of the licensees was evaluated to 20 determine whether or not they discharge or have the potential to discharge 21 radioactive materials to the sewer. This includes an initial walk-through to  ;

22 familiarize the RDMP staff with the nature of the operation and potential i 23 ooportunities for waste minimization.

24 The POTW negotiated discharge limits with the dischargers so that the 25 aggregate regulated discharges from all licensed facilities is ALARA and 26 produces no greater than 1 in 10,000 excess risk of fatal cancer to the "most 27 exposed" individual. The POTW also works with potential dischargers to 28 prevent accidental releases of radioactive materials.

29 The Albuquerque POTW retains a certified Health Physicist to interpret the 30 reports from the dischargers and from monitoring the dischargers and the 31 treatment facility. The health physicist uses radiation exposure models to 32 ensure the radiation dose to the "most exposed" individual is ALARA.

33 The dischargers are asked to provide annual reports regarding the discharces 34 they have made or plan to make to the sewer. In addition, the RDMP staff 35 collects samples from the facilities' sample locat' sons on a regularly 36 scheduled basis and/or unannounced. The samples are analyzed by the State.

37 To date the radioisotopes found in the sewage have been of medical origin.  :

38 Gamma radiation detectors installed at the plant have indicated that no 1 39 measurable rad'ation exposure is being received by plant workers.

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DRAFT FOR COMMENT 1 St. Louis, Missouri 2

3 The City of St. Louis has its own requirements to limit radioactive discharges 4 from industrial users. The district is concerned that low-level radioactive 5 materials being discharged to the sewer system by numerous small sources may 6 be concentrated by the district's wastewater treatment processes and possibly 7 pose a hazard disposal options.for the employees and adversely affect the district's sludge 8

9 The District Ordinance for sewer use contains a limit of I curie /yr for the 10 aggregate discharge from all users in a watershed (except excreta from individuals undergoing medical treatment or diagnosis). This number is 11 currently under review.

12 13 The district requested lists of licensees from the NRC and the State and wrote 14 the licensees letters informing them of the limits for radionuclide discha.gers.

15 Licensus are required to write the sewer district requesting 16 approval to discharge radioactive materials and indicating the isotopes T d the amounts to be discharged annuaily. The district then approves the 17 discharges.

18 The district requires quarterly reports from the licensees to 19 ensure compliance regulations. with the District Ordinance and State and Federal 20 the approval of discharges and the reporting requirements.The licens; l

21 i 22 As alternatives to discharging to the sewer system, licensees are encouraged  !

23 to consider shipping the waste to an approved low-level radioactive waste 24 disposal site or storing the waste for at least ten half-lives to allow sufficient decay to background levels prior to disposal to the sewer.

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! 1 APPENDIX G l 2 BIBLIOGRAPHY AND SOURCES OF ADDITIONAL INFORMATION 3 Ainsworth, C. C. , Hill, R. L., Cantrell, K. J., Kaplan, D. I. , Norton, R. L. ,

4 Aaberg, R. L., 1994, " Reconcentration of Radioactive Material Released to i

5 Sanitary Sewers in Accordance with 10 CFR Part 20," NUREG/CR-6289, U.S.

6 Nuclear Regulatory Comission, Washington, D.C. 20555.

l- 7 ASTM E 181-82 (Reapproved 1991), " Standard General Methods for Detector 8 Calibration and Analysis of Radionuclides," American Society for Testing and .

9 Mat: rials, Philadelphia, Pennsylvania 19103. ,

10 CRCPD Publication 94-1, " Directory of Personnel Responsible for Radiological ,

11 . Health Programs," Conference of Radiation Control Program Directors, Inc.,

12 Frankfort, Kentucky 40601.

13 EPA,1986, " Radioactivity of Municipal Sludge."

14 EPA, 1989, "POTW Sludge Sampling and Analysis Guidance Document."

15 EPA drinking water residuals management report 16 GAO, 1994, Nuclear Regulation, " Action Needed to Control Radioactive 17 Contamination at Sewage Treatment Plants." '

18 Huffert, A.M. , Meck, R. A. , Miller, K.M. ,1994, " Background as a Residual 19 Radioactivity Criterion for Decomissioning," NUREG-1501, U.S. Nuclear j 20 Regulatory Comission, Washington, DC 20555, 21 Kennedy, Jr., W. E., Parkhurst, M. A., Aaberg, R. L., Rhoads, K. C., Hill, R.

22 L., Martin, J. B.,1992, " Evaluation of Exposure Pathways to Man from Disposal 23 of Radioactive Materials into Sanitary Sewer Systems," NUREG/CR-5814, U.S.

24 Nuclear Regulatory Comission, Washington, D.C. 20555.

25 Miller, W.H., et al, 1996, "The Determination of Radioisotope Levels in 26 Municipal Sewage Sludge," Health Physics, v. 71, no. 3, p. 286. l 27 Miller, M.L., Bowman, C.R., an M.G. Garcia,1997, " Avoiding Potential Problems 28 ...

l 29 NCRP Report No. 50, " Environmental Radiation Monitoring," 1976, National 30 Council on Radiation Protection and Measurements, Bethesda, Maryland.

l 31 NCRP Report No. 58, "A Handbook of Radioactivity Measurement Procedures."  ;

i' 32 1985," National Council on Radiation Protection and Measurements, Bethesda, 33 Maryland.

i 34 Washington Suburban Sanitary Comission, " Radioactive Waste Disposal Risk

( 35 Study," October 1995. 4 l