ML20195H563

Transmits State Agreements Program Info (SP-98-086) Re Joint Nrc/Epa National Survey of Sewage Sludge/Ash & Request for Comments on Draft Guidance for Sewage Treatment Plants

ML20195H563
Person / Time
Issue date:	11/04/1998
From:	Lohaus P NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP)
To:	GENERAL, MINNESOTA, STATE OF, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF, WISCONSIN, STATE OF
References
SP-98-086, SP-98-86, NUDOCS 9811240035
Download: ML20195H563 (42)

Text

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'i teroy\ . UNITED 8TATES

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1. - WASHINGTON, D.C. 300s64001

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% ,** ' November 4,1998 ALL AGREEMENT STATES MINNESOTA, OHIO, OKLAHOMA, PENNSYLVANIA, WISCONSIN i

i TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-98-086)

Your attention is invited to the enclosed correspondence which contains:

1 INCIDENT AND EVENT INFORMATION......... j PROGRAM MANAGEMENT INFORMATION.. l l

TRAINING COURSE INFORMATION..............

TECHNICAL INFORMATION...........................

OTHER INFORMATION.................................. XX JOINT NRC/ EPA NATIONAL SURVEY OF SEWAGE l SLUDGE / ASH AND REQUEST FOR COMMENTS ON DRAFT GUIDANCE FOR SEWAGE l TREATMENT PLANTS

. Supplementary Information: The purpose of this letter is to request your assistance in a joint  ;

, NRC/ EPA sewage survey, and to solicit comments on a draft guidance document developed for 1

L sewage treatment plants. l Sanitary sewer disposal of radioactive material and sewage reconcentration became an issue in the 1980s with the discovery of contaminated sewage sludge / incinerator ash, apparently L caused by reconcentration of radionuclides, at sewer treatment faciliiies. In 1991, NRC revised the sewer disposal criteria contained in 10 CFR 20.2003 to allow sewer disposal of only readily soluble materials and readily dispersible biological materials. In 1994, an advanco notice of proposed rulemaking to determine whether additional changes to sanitary sewer disposal l . regulations are necessary was published to solicit comments. Also in 1994, the General

Accounting Office (GAO) published a report entitled, " Actions Needed to Control Radioactive Contamination at Sewage Treatment Plants," which recommended that NRC determine the j extent of the contamination and establish acceptable radioactivity limits. In an October 11, l 1994 letter, the U.S, Nuclear Regulatory Commission (NRC) and the U.S. Environmental Prctection Agency (EPA) notified water and radiation safety officials of all States of the potential for reconcentration of radionuclides in sanitary sewer systems in response to the GAO report g

'and the Joint Senate / House hearing held earlier in 1994.

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, NRC and EPA staffs have also responded to the 1994 GAO report by preparing the enclosed guidance document entitled," Draft Guidance for POTWs on Radioactive Materials in Sewage L as W

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l SP-98-086 I Sludge / Ash" and by designing the proposed survey of radioactive materials in sewage sludge i and ash to determine levels present in thesc materials from publicly-owned treatment works I (POTWs) across the country. The purpose of the guidance document is to provide general information on topics such as radioactivity, why one can expect to find certain radioactive materials in sewage sludge / ash, and who has the authority to control discharges of radioactive materials to sewage systems. This draft guidance is currently under review by the Interagency Steering Committee on Radiation Standards (ISCORS) Sewage Subcommittee. However, portions of the document are incomplete, and the subcommittee would like the States' comments on the scope of the draft document. At a later date, we intend to publish a notice of the draft guidance in the Federal Reaister for public comment. Please foward your questions and/or comments on the draft guidance within 60 days of the date of this letter to Phyllis Sobel, Office of Nuclear Material Safety and Safeguards, NRC, at (301) 415-6714, INTERNET at PAS @NRC. GOV The sewage survey was designed to accomplish the following objectives: (1) obtain data on the levels of radioactive mrterials in sludge and ash at POTWs from across the country; (2) estimate the extent to which radioactive contamination comes from either NRC/ Agreement l State licensees or naturally-occurring radioactivity; (3) support rulemaking decisions; and (4) I support the need for developing criteria for radioactivity in sludge and ash. In 1997, a joint NRC/ EPA pilot survey of nine POTW sites was executed to help determine the best approach for conducting the nationwide survey and refine our OMB submittal package for obtaining approval to conduct the full survey. NRC and EPA staffs are completing a report that documents the findings of the pilot survey and makes recommendations for conducting the nationwide survey. The report should be completed in September 1998, at which time it will be j published for distribution, j l

To maximize its effectiveness, the sewage survey will focus on the POTWs associated with i I

licensees with the greatest potential to discharge radioactive material to the sanitary sewer and those in areas known to have high levels of naturally occurring uranium. For NRC licensees, NRC can identify the licensees (and the type of facility -i.e., licensees with unsealed sources or the ability to discharge) in each zip code area. For Agreement State licensees, NRC requests ,

that each Agreement State name a State point of contact who can supply similar State licensee l information by zip and program codes to identify the type of facility. This information will also i be forwarded to EPA and each POTW in your State that participates in the survey. We also invite you to suggest POTWs that you would like to be included in the survey in doing so, we l

ask that you consider POTWs which have a relatively high number of licensees, those located i in areas with a greater potential for naturally occurring radioactivity as a result of geologic  !

conditions, and where there is industry such as water purification, ceramics, electronics, mineral processing, etc., which discharge wastes into the sewer system. Please provide the name of a contact in each Agreement State and a copy of the licensee information described .

above within 60 days of the date of this letter to Tin Mo at the address below. I l We will keep you informed of any future actions being considered and welcome your comments ,

and cooperation. If you have any questions regarding the sewage survey, please contact Tin i Mo, Office of Nuclear Regulatory Research, NRC, at (301) 415-8151, INTERNET at TXM@ NRC. GOV.

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SP-98-086 i This information request has been approved by OMB 3150-0189, expiration 06/30/01. If a

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document does not display a currently valid OMB control number, the NRC may not conduct or

- sponsor, and a person is not required to respond to, a collection of information. The estimated burden per response to comply with this voluntary collection request is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Forward any comments regarding the burden estimate to the information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0052), Office of Management and Budget, Washington, DC 20503.

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bWu Paul H. Lohaus, DeKiy Director

-Office of State Programs

Enclosure:

As stated

- cc: W. Cook, EPA R. Bastian, EPA L. Setlow, EPA D. Kopsick, EPA L. Weinstock, EPA l.

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! .I

.. SP 98-086 ,

This information request has been was approved by OMB 3150-0189, expiration 06/30/01, if a document does not display a currently valid OMB control number, the NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information. The estimated burden per response to comply with this voluntary collection request is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Forward any comments regarding the burden estimate to the Information and Records Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0052), Office of Management and Budget, Washington, DC 20503.

/s/ Paul H. Lohaus Paul H. Lohaus, Deputy Director

' Office of State Programs

Enclosure:

As stated cc: W. Cook, EPA R. Bastian, EPA L. Setlow, EPA D. Kopsick, EPA L. Weinstock, EPA i

i I

I Distribution:

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SDroggitis PDR (YES.L) (NO_)

BNelson PSobel MWeber PSantiago A/S File l DOCUMENT NAME: G:\SP98086 T5o *SEE PREVIOUS CONCURRENCE.

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OFFICE OSP l OSP:DD l RES NMSS:DWM l OSP:DH,7 NAME' TO'Brien:nb:gd:kk:nb PLohaus CTrottier JGreeves RBangart No DATE 07/30/98

• 07/31/98/08/10/98

• 08/27/98

• 08/28/98

• 09/D/98 OSP FILE CODE: SP-A-4 l

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DRAFT FOR COMIENT 1 i

2L DISCLAIMER 3- This guidance document resulted from interagency discussions. The ISCORS Sewage

. -4 ; SubcommRtee is composed of representatives from the Nuclear Regulatory Commission, 5 Environmental Protection Agency, Department of Energy, and Department of Defense. This 6 document has not been approved by the respective federal agencies and does not 7- represent the official position of any participating agency at this time.

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

'10 1. What is the Purpose of this Gulde?

'11 The Nuclear Regulatory Commission (NRC) and the Environmental Protection Agency (EPA) 12 developed this guide to provide information about radioactive materials in sewage sludge and

13. ' ash from the incineration of sewage sludge at publicly owned treatment works (POTWs). It 14 also provides background information about the regulatory policies of NRC and EPA, sources of l15~ radioactive materials in sewage, guidance on sampling and analysis of these materials in

-16 . sewage sludge and ash, and methods to assess levels of radioactive materials in these 17 . byproducts of wastewater treatment. Appendix A is a background discussion about 18: radioactivity.

19' 'Although it is unlikely that radionuclide levels in sludges and ash at most POTWs across the 20 country pose a concem for treatment plant workers or the general public, it is possible that low

.' 21 - concentrations of radioactive material from natural and man-made sources could become 22 concentrated in sludge products at some POTWs. However, there is no general concern for 23 -worker safety or general public exposures because of the low amounts of radioactive materials 24 that are legally authorized to be disposed into the sanitary sewer system by Federal or State 25 law and regulations.

'26~ Even though NRC and the States regulate industrial and medical discharges of liquid wastes

- 27 i containing low levels of licensed radioactive material to the sewer system, it is important for the

~ 28 - POTW manager and operator to understand what types and amounts, if any, of radioactive 29- materials may be entering the POTW. There are several ways to develop this understanding.

~30 One way to obtain this information is by sampling and testing the sludge products. Another way

-31 to obtain information is to identify what licensed and other activities discharge into the POTW 32

'and work with the licensees and other industries to understand what they are discharging.

33' Analysis of radioactive materials can be made part of the existing analysis programs for other 34' pollutants, or the POTW manager or operator may want to set up a program whereby any 35 licensed discharger routinely notifies the POTW of the type, level and timing of discharges to 36' . the system. While monitoring of the POTW influent may seem to be a viable option, 1

DRAFT FOR COMMENT 1 measurement systems may not be able to detect the diluted radioactive materials.

2 At the request of Senator John Glenn, the General Accounting Office (GAO) published a report, 3 " Actions Needed to Control Radioactive Contamination at Sewage Treatment Plants," in May 4 1994. The report included recommendations that NRC determine the extent of the 5 contamination and establish acceptable radioactivity limits. This guidance document is part of 6 the NRC's response to the GAO report.

7 The operator of a POTW may decide to sample sewage sludge and ash for radioactive 8- materials based on the nature of industries discharging to the collection system or to establish 9 background measurements. If measured levels of radioactivity exceed the levels suggested L.  !

10 Section 8, it may be appropriate or necessary to limit certain sludge / ash use or disposal '

11 practices, further restrict radioactive material discharges by specific licensees, or alter 12 operations at the treatment works.

13 2. Who Regulates Radioactive Material?

-14 Regulatory responsibility for radioactive material in the U.S. is shared by Federal, State and 15 local agencies. The following summary should help clarify the responsibilities of the different 16- agencies. Appendices B, C, D and E list NRC, EPA and State contacts.

17 NRC: NRC is responsible for ensuring that discharges of radioactive materials by their 18 licensees into the sewage system are in compliance with applicable NRC regulations under 19 Title 10 of the Code of Federal Regulations (CFR) Part 20. Under the Atomic Energy Act of 20 1954, NRC regulates the civilian uses of certain radioactive materials (byproduct, source, and 21 special nuclear materials) in the United States. These radioactive materials are used at nuclear 22 power reactors, and industrial, academic, medical, and research and development facilities.

23 NRC's mission is' to ensure adequate protection of the public health and safety, and to protect

. 24 the environment. This mission is accomplished through licensing of nuclear facilities and the

- 25 possession, use and disposal of nuclear materials; the development and implementation of 26 guidance and requirements governing licensed activities; and inspection and enforcement 27 activities to ensure compliance with these requirements. People who have a license and are 28 regulated by NRC are called " licensees."

29 States: NRC has entered into agreements with 30 States to allow these States to regulate 30 most types of radioactive material within their borders, in lieu of NRC. These States are 31 referred to as Agreement States. Agreement States have established regulations and 32 procedures comparable to those established by NRC. The only facilities not regulated by 33 Agreement States are nuclear power plants and Federal facilities.

. 34 Radioactive materials that occur naturally, other than uranium and thorium, are not regulated by

~ 35 NRC. In lieu of Federal regulations, States have the responsibility to regulate naturally-36 occurring radioactive material. At this time, several States have issued regulations for the 37 ' control of sources of very low level radiation derived from naturally occurring materials that

-38 have been concentrated by human activities. The regulations are intended to provide radiation protection to members of the public and workers who might be exposed to that radiation. The 2

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DRAFT FOR COMMENT 1 non-federal Conference of Radiation Control Protection Directors is developing model 2 regulations for use by State agencies in controlling these sources of radiation in their own 3 states.

4 DOE: The Department of Energy (DOE) regulates the defense-related uses of radioactive 5 materials under authority of the Atomic Energy Act, the Price-Anderson Act Amendments, and 6 other related legislation. Nuclear weapons production, testing and research facilities, as well as 7 . former commercial radiation sites and inactive uranium mill tailings sites are subject to DOE -

8 regulatory control.

9 Discharges from DOE facilities of liquid wastes containing radioactive materials are regulated 110 by intemal DOE Orders and regulations. DOE Order 5400.5 (Radiation Protection of the Public l 11 and the Environment) establishes treatment and discharge requirements for any liquid wasts 12 containing radioactive materials. Any liquid wastes discharged to a sanitary sewer must be 13 . below five times the Derived Concentration Guides (Chapter lil of Order DOE 5400.5) levels at 14 the point of discharge, or must be treated by a Best Available Treatment technology to achieve 15 levels that are at least equivalent to these concentration limits. .In addition, all releases are 16 required to be evaluated by an "As Low As Reasonably Achievable" process. Liquid wastes 17 dn, charged t< a sanitary sewer system must also achieve levels that do not interfere with 18 handling or ,>osal of solids at the POTW, and that do not result in general public exposures 19 that are mt .han a small fraction of the annual dose limit. DOE is in the process of updating 20 . these req ( nents in a regulation (10 CFR Part 834) which, when promulgated, will replace 21 Order DC2 L 400.5. The proposed rule includes 10 CFR Part 20 source term limits, along with 22 ' the Order DOE 5400.5 concentration limits.

23 EPA: EPA is responsible'for regulations to protect the health and safety of workers at POTWs 24 _ and the public and the environment that are exposed to sewage sludge and ash produced by 25 POTWs. EPA has responsibility for establishing generally applicable standards for the

~26 protection of the environment from' radioactive materials under the Atomic Energy Act. EPA 27 also adm!nisters the Comprehensive Environmental Response, Compensation, and Liability Act 28 (CERCLA or "Superfund") to provide for remedial action in response to releases or substantial 29 threats of releases of hazardous substances into the environment. EPA regulates the 30 management of hazardous waste under the Resource Conservation and Recovery Act, and -

31 toxic materials under the Toxic Substances Control Act. While radioactivity is not a listed 32 characteristic for defining hazardous wastes under the Resource Conservation and Recovery 33 Act (RCRA), sites contaminated with radioactive substances have become regulated as 34 Superfund sitos under CERCLA or under other regulatory programs. EPA has authority to )

35 delegate these programs to State agencies while providing regulatory oversight. There are 36 currently no EPA regulations for radionuclides under the Clean Air Act that apply to POTWs; 37 however, NRC's regulations in 10 CFR Part 20 include regulations for air emissions from its 38 licensees.  ;

39 EPA, under its authority to provide guidance for all Federal agencies in the formulation of 40 radiation standards and in establishing cooperative programs with the States, has issued 41- proposed guidance in 1994 for radiation protection of the general public. This authority stems 42 from an executive order of the President and the Atomic Energy Act. In addition, under the 3

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DRAFT FOR COMMENT 1 authority of the Safe Drinking Water Act, EPA limits radiation content in drinking water. EPA 2 also protects groundwater from introduction of radioactive pollution under several programs, 3 including by regulation or statute.

4 The EPA POTW "pretreatment program" under the Safe Drinking Water Act is designed to 5 protect the POTWs by (1) preventing the introduction of pollutants into sewer systems that 6 would interfere with the operation of a POTW, including interference with its use or disposal of 7 municipal sludge, (2) preventing the introduction of pollutants into POTWs which will pass 8 through the treatment works or otherwise be incompatible with such sources, and (3) improving 9 opportunities to recycle and reclaim municipal and industrial wastewaters and sludges.

10 Local Authorities: Local authorities are derived from the Federal and State statutes and 11 regulations and will vary from locality to locality. The NRC has found that if a municipality has 12 sound reasons, other than radiation protection, a municipality can require the pretreatment of 13 wastes to eliminate or reduce radioactivity. Furthermore, although NRC regulations allow users 14 of regulated materials to discharge to treatment plants, these regulations do not compel a 15 sewage treatment operator to accept radioactive materials from NRC licensees. Some 16 localities are addressing the potential problem of concentration of radioactive material at 17 POTWs by either (1) requiring pretreatment of waste by specific licensees or (2) limiting the 18 discharge of radioactive materials. For exainp!e, the State of Oregon and the city of Portland, 19 Oregon, ordered a state licensee to install a pretreatment system to control the discharge of 20 thorium oxide into sewer lines. The Metropolitan St. Louis Sewer District passed an ordinance 21 in 1991 that limits the aggregate discharge of radioactive materials into the sewage system.

22 Other cities seem unsure whether a municipality or treatment plant can lawfully regulate or 23 prohibit a licensee's discharge of radioactive materials in the sewage system. Appendix F 24 describes two examples from the cities of Albuquerque and St. Louis.

l 25 3. Why is There Radioactivity in Sewage Sludge? l 26 There are three general sources of radioactivity in the environment: a natural source, a natural 27 source but concentrated or " enhanced" by human activities, and a human-made sourca.

28 Natural sources of radioactivity are found widely spread in the environment. All geological 29 formations and soils contain uranium, radium, radon, and other radioactive elements in small 30 amounts. Water that originates in or moves through geologic deposits containing naturally-31 occurring radioisotopes could result in these radioisotopes being carried to the treatment facility '

32 with the drinking water supply, storm water runoff or infiltration entering the sewer system, and 33 water treatment plant residuals discharged to the sewer system.

34 Almost everything, including people, contain some radioactive material. Naturally-occurring 35 radioactive materials are found in the food and water we ingest, and even the air we breathe 36 contains some radioactive gases. These small amounts of radioactive materials can be 37 incidentally enhanced, either physically or chemically, by human activity and technologies 38 associated with extraction processes. Examples of sources of natural radiation which have ,

39 been enhanced by human activities include wastes from mineral ores and the pColeum  ;

40 industry, sludge and scale from drinking water treatment, wastes from the burning of coal, 41 waste from geothermal energy production, and articles made from naturally-occurring 4

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DRAFT FOR COMMENT l 1 radioactive materials such as thorium in lantern mantles, i

, 2. Sewage sludge and ash at POTWs may contain both naturally-occurring radioactive materials  ;

l 3 and radioactive materials made by humans. Industrial and medical facilities may be licensed to i 4 discharge radioactive materials to the sanitary sewer system. . In addition, radioactive materials 5 administered to patients for the diagnosis or treatment of illnesses are discharged to the sewer

-6' system. Certain radioactive materials may be exempt from licensing, and these radioactive

, 7 materials can be discharged into the sanitary sewer systems. Other industrial or residential j.

8 discharges can contain naturally-occurring radioactive materials that are not subject to licensing 9 or regulation, such as fertilizer residues. It is also possible that industrial, commercial, or

'10_ medical facilities might discharge into the sanitary sewer system outside of regulations or.

l. 11 license conditions.

12. The purpose of wastewater treatment facilities is to reduce or remove pollutants from i

13 wastewater in order to ensure adequate water quality before the treated effluent is reused or 14 discharged to surface waters. The removal of radionuclide contaminants by various wastewater 15 treatment processes and the usual association of these contaminants with solids can cause a

! 16' concentration of the radionuclides in the treatment facility's other byproduct, sewage sludge (or 17 ash if the sewage sludge is incinerated). What was once disposed of into the sanitary sewer in

, 18 a dilute form, may be concentrated during some stages of wastewater treatment or sludge

! 19_ processing.

20 Concentration of radioactive materials occurs in the same manner as non-radioactive materials 21 such as heavy metals. The concentration may occur during several stages of wastewater 22 treatment, including various physical, chemical, and biological wastewater treatment processes, t

23 Sludge treatment and processing may result in increasing the concentration by weight of the 24 radioactive contaminant by decreasing the concentration of other components. Incineration of 25 sludge has proven to be the greatest concentration process. Final concentration will depend on 25 the numerous aspects of the entire processes used at the treatment facility, such as the 27 chemical form of the radionuclide, its half-life, the processes used, and the efficiencies of those 28 processes. A recent study by Ainsworth et al (1994) indicated that with the currently available 29 information, it was not possible to quantitatively estimate concentration factors for specific

30. processes or for wastewater treatment plants in general.

31 The EPA report " Radioactivity of Municipal Sludge" and the 1994 GAO report cited in Section 1 32 summarize the data available on radioactive materials in sewage sludge. At specific sites, the 33 radionuclides ranged from numerous radionuclides to specific radionuclides from specific 34 sources. Most radionuclides were present at very low concentrations. At most sites, sewage 35 sludge contained radionuclides from medical treatment and research facilities (lodine-131, 36 Chromium-51 and Selenium 75). Radionuclides are released to the sewer system through 37 releases of Isotopes during handling and through excretion by patients. These medical 38 contaminants were found to not produce a significant dose when the sludge was land applied 39 due to their short half-lives. (The term half-life and other background information on 40 radioactivity are discussed in Appendix A.)

41' The 1986 EPA report cites some examples of elevated levels of radionuclides found at POTWs.

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I e DRAFT FOR COMIENT l' For example, Americium-241 in the sludge at two facilities was attributed to producers of foil j- 2' elements in smoke detectors. At one of these sites, the State of New York paid for cleaning up 3 the treatment plant and sewer lines.

4 . High concentrations of Radium-226 are found in the groundwater in some areas of the U.S., for

.5 ' example Illinois and Wisconsin. Under the Safe Drinking Water Act, many drinking water

'6- facilities are required to treat their drinking water to reduce radium concentrations to acceptable 7 levels.' At some POTWs, radium found in sewage sludge has been attributed to residuals 8 discharged to the sewer system from drinking water treatment facilities.

9 A more recent case of contaminated sludge involves the Northeast Ohio Regional Sewer 10 District's (NEORSD) Southerly Sewage Treatment Plant. A 1991 aerial radiological survey, o 11' intended to measure radiation around an NRC licensee, detected elevated levels of radiation at 12 . the POTW, which were found to be from Cobalt-60, Radium-226 and Cesium-137 in the ash 13 from incinerating their sewage sludge. The latter two radionuclides were in the normal range of 14 naturally-occurring radioactivity _found in the area. At least part of the Cobalt-60 contamination 15 was due to releases from a licensed manufacturing facility. NRC, the State, and NEORSD I 16 have funded surveys of the site. NEORSD has funded site remadiation activities and installed a 17 fence to prevent public access.

l k8 4. What are Background Radiation and Naturally-Occurring Radioactive Materiala?

l 19 Background radiation is the radiation that is emitted from naturally-occurring radioactive 20- materials in and on the Earth and in space, and does not include medical and occupational c 21 ' activities. Almost everything, including people, contains some radioactive material. Naturally-

22 - occurring radioactive materials are found in the earth, in the materials used to build our homes, 23 and in the food and water we ingest. Even the air we breathe contains some radioactive gases.

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'24 The average dose of radiation exposure to an individualin the U.S. is slig'htly more than 300 25 mrem /yr from their exposure to background radiation. (The term " dose" and other background

-26 information on radioactivity are described in Appendix A.) The annual exposure to background

27. radiation is summarized in the following table (Huffert et al,1994):

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Average Dose Typical Range of Variability

2- - Source (mrem /vr) (mrem /vr) 3 ' Terrestrial 30 10 - 80 4 --

~5- Radon 200' 30 - 500

'6! Cosmic 30 30 - 80 7~ Internal 40 20 -100 -

<8 Terrestrial radiation comes from radioactive material that is naturally occurring in the environment. Radon occurs in the environment and is listed separately in the following table 10 because of the large contribution it gives compared to the other terrestrial sources. Cosmic

'll _ radiation comes from outer space and penetrates through the atmosphere covering the earth; 12^ the ' amount of cosmic radiation will vary depending on the altitude and latitude where one lives.

~13- Internal radiation comes from substances that are in the human body naturally, and that are 14 naturally radioactive, primarily Potassium-40.

15 ~ As shown, these doses can vary greatly, as the various factors that contribute to background 16 radiation are not constant from location to location, and our lifestyles and daily activities vary 17l these amounts to some extent. Since the atmosphere serves'as a shield against cosmic

'18 radiation, this dose increases with altitude; the dose at an altitude of 1 mile (for example, in the 19 Rockies) is about double that at sea level (30 mrem /yr). Also a flight on a commercial airliner 20 increases your dose from cosmic gamma rays about 4 to 5 mrem for each cross-country flight.

21' 22 Dose rates from terrestrial sources vary from about 10 to 100 mrem /yr across the U.S. _The 23 - major sources in the ground are potassium' thorium, and uranium. The higher doses are 24 ' associated with uranium deposits in the Colorado Plateau,' granitic deposits in New England, 25: < and phosphata deposits in Florida. The lowest rates are the sandy soils of the Atlantic and Gulf 26 ' coastal plains. If you live in a brick home, instead of one made of wood, you may add up to 10

+27 mrem /yr to your annual dose due to naturally-occurring thorium, uranium, and radium found in 28; the clays of which bricks are made.

[ 29 Doses vary according to the amount of naturally-occurring material that people ingest in food E30: and drinking water. The principal naturally-occurring radionuclides are potassium and radium.

31 Potassium is commonly ingested from bananas and one source of radium is Brazil nuts.

l 32 Radium in water, particularly ground water, varies across the U.S.; it is in higher concentrations 33 in some States such as Georgia, Illinois, Minnesota, Missouri, and Wisconsin.

l '34' The following table lists background radionuclides that may be present in POTW sewage

:35 sludge and ash. All these radionuclides are from terrestrial sources, except Strontium-90 and L 36 Cesium-137, which are due to radioactive fallout from atmospheric testing of nuclear weapons.

37. Tvoe of

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1 Radionuclide RadiatioD Half-life 2- Potassium-40 gamma 1.4 billion years 3 Rubidium-87 beta 52 billion years 4 Strontium-90 beta 28 years 5 Cesium-137 beta, gamma 30 years 6 Radon-222 alpha 4 days 7 Radium-226 alpha, gamma 1600 years 8 Radium-228 beta 6 years 9 Thorium 232 alpha 14 billion years 10 Uranium-238 alpha 4.5 billion years 11 5. What are the Sources of Radioactivity in Sludge Caused by Human Activity?

12 In addition to radioactivity from a natural origin or global fallout from weapons testing, a known 13 source of radioactive materials in the influent to POTWs is from the disposal of radioactive

14. materials enhanced by human activity or produced by humans. This radioactive materialis 15 discharged into the sanitary sewer system by licensed users of radioactive materials and other 16 activities.

17 1.aboratories and universities uso radioactive materials (e.g. Carbon-14) in research, including 18 the marking and detection of molecules in genetic research, the study of human and animal

19. organ systems, and in the development of new drugs.

20 Radioactive materials may also be found in consumer products, such as smoke detectors 21 (Americium-241), luminous watches, and tobacco products. It is estimated that the dose to an 22 individual from consumer products is about 9 mrem /yr.

23- An individual also receives radiation exposure from medical procedures. In the practice of 24 nuclear medicine, radioactive materials (e.g. lodine-131, Phosphorus-32, and Strontium-90) are 25 . administered to patients for the diagnosis or treatment of illnesses such as cancer or Graves 26 disease.

27 There are currently about 24,000 NRC and Agreement State licensees in the United States.

28 About one third of these are NRC licensees, while the remainder are licensed by Agreement

. 29 States. Licensees include utilities, nuclear fuel fabricators, universities, medical institutions, L 30 radioactive source manufacturers, and companies that use radioisotopes for industrial i 31 purposes.

32 About 50% of NRC's materials licensees use either sealed radioactive sources or small 8

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I amounts of short lived radioactive materials. Sealed sources do not pose a contamination 2 problem unless the encapsulation is broken. Examples of facilities that do not discharge to the 3 sanitary sewer because they use only sealed sources are well logging licensees, industrial 4 radiography licensees, and nuclear power plants.

5 The remaining 50% of the NRC's maierials licensees are conditionally authorized to dispose 6 radioactive materials into the sewer system. For 6xample, radioactive materialis handled in 7 " unsealed" forms in the nuclear fuel fabrication industry, in production of radiopharmaceutical 8 medicines, and in research. The limits in quantities and concentrations NRC and the 9 Agreement States allow to be discharged to the sanitary sewer are based on the dose limit that 10 could be received by an individual member of the public, assuming certain conservative 11 conditions in calculating the potential dose.

12 The following table lists types of NRC licensees that could dispose radioactive materials into the 13 sewer system and isotopes previously found in POTW sewage or those that could be present.

14 lt should be noted that a broad scope licensee is usually authorized for any isotope with an 15 atomic number from 1 to 83, which means that many more isotopes than those listed here 16 could be found being disposed into the sanitary sewer, thus this table is not all inclusive.

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1 Type of NRC Licensee Number of NRC Licensees. Typical Radionuclides That 4 That Have the Potential to May be Found in POTWs l Discharge (as of 11/1/96) 2 Academic (broad scope) 75 Carbon-14 I Cobalt-60 Cesium-137 Hydrogen-3 lodine-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 lodine-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 scope, Antimony-125 7 nuclear laundries, Cobalt-60 8' decontamination services) Cesium-134/137 Hydrogen-3.

Manganese 54 Niobium-95 Phosphorus-32 Plutonium-238/239/240 Polonium-210 Strontium-89/90 Sulphur-35 Uranium-233/234/235/238 Zirconium-95 l

10 l

l

1 Research and Development 666 Carbon-14

-2 (broad scope) Cesium-134 l Hydrogen-3 lodine-125/131 Phosphorus-32 Sulphur-35 3 Others (e.g. mills, uranium 149 Plutonium 238/239/240 4 enrichment plants) Radium-226 Thorium-228/232 Uranium-233/234/235/238 5 The half lives and types of radiation emitted by these radionuclides are listed in Appendix A.

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

7 Workers at POTWs could be exposed to low levels of radioactive materials (and radiation 8 emitted from the radioactive materials) in sludge and incinerator ash. The most exposed 9 workers would likely be sludge process operators, workers at incinerator operations, and 10 operators of heavy equipment loading sludge or ash for trcosport.

11 Many facilities dispose of their sewage sludge or ash offsite of the treatment facility, for 12 example by land application or into a solid waste landfill. Land application of sewage sludge 13 Improves soil properties and serves as an organic fertilizer. The POTW worker, farmer or 14 gardener would receive direct exposure to the applied sludge and consumers could be exposed 15 by ingesting crops. Workers at a landfill, farmers, or gardeners could also be exposed by 16 inhaling or ingesting the sludge in dust particles. Radioactivity could also migrate into the 17 groundwater and be consumed with drinking water.

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

19 Under what circumstances would I sample? The decision to sample should be based on an 20 assessment of the nature of industries discharging to the collection system. The NRC or the 21 Agreement State can help you determine the licensees in your sewage collection system.

22 Radioanalysis can be performed to understand the levels of naturally-occurring radioactivity or 23 made part of the routine analyses for other pollutants. Examples are discussed in Appendix F.

24 Where do I sample? Collect samples of sewage sludge, ash, or other sludge products 25 produced at your facility. Collect the samples as close as possible to the point where the 26 materialleaves the POTW. Examples of sampling locations could be a digester, filter press or

'27 drying bed, lagoon or storage pile.

28 Who analyzes the samples? It is generally necessary to send the samples to a laboratory for 29 analysis because POTWs do not have the equipment or training necessary to perform analyses 30 of radioactive materials. Laboratories that perform such tests can be found in the American l 31 Society of Testing and Materials Catalog of Laboratories or in the Ye!!ow Pages of a telephone 32 directory. Professional organizations such as the Water Environment Federation, American

, 33 Water Works Association, or the Health Physics Society will have listings of laboratories, and 11

l 1 nay have suggestions; or call your State agency for radiation control for suggestions.

2 How du I sample? Samples can be collected by the POTW operator. Call the laboratory first 3 to discuss the types of analyses, confirm sample volumes needed and types of containers, and 4 discuss quality control procedures. The laboratory may supply some of the sample materials.

5 The amount of sample collected will depend on the solid content of the material and the type of 6 analysis. Among the equipment 2nd supplies eded to collect samples are plastic jugs, 7 trowels, scoops and Chain-of-Custody forms.

8 Sample collection procedures are discussed in the 1989 EPA report "POTW Sludge Sampling 9 and Analysis Guidance Document." If a sample is well-mixed, then a representative sample 10 can be easily obtained. If a sample is not well-mixed, then incremental aliquots (small grab 11 samples of equal volume) must be collected and composited, to obtain a representative 12 sample. For example, the sample might be collected from a digester, filter press or drying bed, 13 truck, tank, or pile. A liquid or slurry sample from a digester or tank should be from an outlet 14 stream. The outlet or sample port should be opened and allowed to flow until a representative 15 sample is available. If a sample of the total stream cannot be collected, then the stream should 16 be cut across for equal time periods until the sample container is full. A sample collected from 17 a filter press should be a composite of several small samples collected at different locations 18 across the press or within the filter cake. A sample collected from a drying bed, truck, or pile 19 should be scoops from various areas and levels of the drying bed, truck or pile. A sample of 20 incinerator ash should be from the location where it is collected or stored. The collection date

> 21 and time should be close to the date that the sludge or ash leaves the plant for transport to a 22 landfill or for land application.

23 How do I ship the samples to the laboratory? The following are generalinstructions. If you 24 have any questions or need assistance, contact the laboratory performing the analysis.

25 Ensure that the samples are properly labeled with the name of the facility, location or source of 26 the sample, the name of the person taking the sample, and the sample date and time.

27 Complete a Chain-of-Custody form with the name of the facility, location or source of the

- 28 sample, the name of the person taking the sample, and the sample date and time. Place the

& 29 samples in the shipping container. The person taking tue sample should sign the completed 30 Chain-of-Custody form and enclose the form with the samples. Seal the shipping container and 31 place the security seal across the top of the container, and attach the appropriate shipping 32 labels. Send the samples to the laboratory as quickly as possible (e.g. overnight delivery) after 33 collection. This will eliminate the need for refrigeration of the samples.

34 What analyses should I request? At a minimum, the laboratory should perform 35 gamma spec analysis and gross alpha / beta analysis. Consider the licensees in the co!!ection 36 system before deciding on any additional alpha- or beta-emitting radionuclide analysis. Typical 37 radionuclides from various types of NRC licensees are listed in Section 5 and Appendix A. For 38 example, Americium-241, an alpha and gamma emitter, could be discharged by a smoke 39 detector manufacturer. Tritium, a beta emitter, is used in manufacturing luminous signs.

40 Phosphorus-32 and Strontium-90, both beta emitters, are medical isotopes.

41 What will the analysis cost? The cost will depend on the type of analysis that is requested.

42 The more detailed or complicated the analysis, the more expensive and time demanding the 12 1

mv s . -

1 analysis becomes. For instance, gamma analysis of samples is relatively easy, as well as 2 gross alpha and beta radiation counting. But alpha and beta energy analysis to identify specific 3 radionuclides can be time consuming and expensive. Gamma spec analysis for one sample 4 should cost several hundred dollars, gross alpha / beta analysis several hundred dollars, and 5 radiochemical analysis for alpha and beta emitters from several hundred to several thousand 6 dollars, depending on the radionuclides analyzed.

7 8. How Do l Evaluate the Results?

8 NOTE: NRC and EPA do not currently have regulations addressing radioactive 9 materials in sludge products at POTWs. NRC and EPA are developing the following 10 table to describe concentrations of radioactive materials in r;ludge or ash. These 11 estimated concentrations will be based on dose modeling calculations which assume 12 how Individuals could be exposed to these radioactive materials. These models, for 13 example, assume that an individual spends _% of the year on site and _ hours a 14 day outside. So far, a dose level has not been chosen for the calculations. We 15 welcome amj comments on the need for this table and the appropriate dose level for i 16 the calculations. In the interim, the taF ill be developed for factors to convert 17 concentration to dose or risk.

18 Concentration to Dose (or Risk) Conversion Facbrs 19 for Radioactive Materials in Sewage Sludge and Ash 20 (UNDER DEVELOPMENT) 21 Radionuclide Dose (or risk) per pCi/g of Dose (or risk) per pCi/g of Sludge Ash Concentration Concentration _

22 Americium-241 23 Cesium-137, etc.

24 if radioactive material exceeding these values is detected at a POTW that is located in an 25 Agreement State, contact the appropriate State regulatory authority (Appendices B and E). If 26 the POTW is located in a non-Agreement State, contact the NRC regional office (Appendix C).

27 The appropriate regulatory authority will help you trace the origin of the tadioactive material.

28 For example, the NRC or the Agreement State can help you determine the licensees in your 29 eewage collection system if you provide a list of zip codes in your collection system. If 30 measured levels of radioactivity exceed the above levels, it may be necessary to further restrict 31 discharges of wastes to the sewer system by a specific licensee, alter operations at the 32 treatment works, or limit certain sludge / ash use/ disposal practices.

SG 9. Comments or Questions on this Guidance?

34 If you have any questions or comments regarding the information presented in this guidance 35 document, please contact either NRC or EPA:

36 U.S. Nuclear Regulatory Commission 13

1 Low-Level Waste and Decommissioning Projects Branch 2 (301) 415-7234 or contact through NRC's operator on the toll-free telephone

3. number 800 368-5642.

4 or 5 Robert Bastian 6 U.S. Environmental Protection Agency (4204) 7_ Office of Wastewater Management 8 401 M Street, SW 9- Washington, DC 20460

. 10' (202) 260-7378 11

~ 12- Appendices

- 13 A. Fundamentals of Radiation

- 14 B. NRC and EPA Regional Offices by Statt .nd identification of Agreement States

' 15 C. NRC Regional Offices 16 D. EPA Regional Offices

17. - E. State Agencies for Radiation Control

18 ~ F. Examples of POTWs that have Radionuclide Materials Programs 19- ~G. Bibliography and Sources of AdditionalInformation

,< s 14 L

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DRAFT FOR COMMENT 1 APPENDIX A 2 FUNDAMENTALS OF RADIATION 3 What is Radiation? i 4 People are s',ojected to natural radiation from outer space, from naturally-occurring radioactive ,

5 materials in soils, in the food and water we consume, and in the buildings where we live and 6 work. The term " radiation" as it relates to radioactive material describes the energy given off by 1 7 the material as it decays. lonizing radiation produces charged particles, or ions, in the material

-8 in which it encounters. At excessive levels, the process of ionization can cause disease and 1 9 injury to plants and animals. l 10 The three most common types of ionizing radiation are:

11- '* Alpha radiation - positively charged particles that are emitted from naturally-occurring 12 and man-made radioactive material, t!ianium, thorium and radium emit alpha radiation 13 and so they are called " alpha emittem." The alpha particle has the least penetrability.

14 Most alpha particles can be stopped by a single sheet of paper or skin. Consequently, 15- the principle hazard from alpi a emitte rs to humans is caused when the material is 16 ingested or inhaled. The limited pcr.atration of the alpha particle means that the energy 17 of the particle is deposited within the tissue (e.g., lining of the lungs) nearest the 10 . radioactive material once inhaled or ingested. Examples of alpha emitters are the 19 naturally-occurring radionuclides radon, radium, thorium and uranium.

20

• Beta radiation.- negatively charged par 9cles that are typically more penetrating but have 21 less energy than alpha particles. Beta particles can penetrate human skin or sheets of 22 paper, but can usually be stopped by thin layers of. plastic, aluminum, or other materials.

23 Carbon-14 and Hydrogen-3 (or tritium) are two common " beta emitters." Although they 24 can penetrate human skin, beta particles are similar to alpha' particles in that the 25 predominant hazard to humans comes from ingesting or inhaling the radioactive

26. materials that emit beta radiation.

'27 e Gamma (or X-ray) radiation - the most penetrating type of radiation. They can pass 28 through the human body and common construction materials. Thick and dense layers 29- of concrete, steel, or lead are used to stop ' gamma radiation from penetrating to areas 30 where humans can be exposed. Gamma emitters can pose both external and internal iv 31 radiation hazards to humans. Technetium 99m is an example of a " gamma emitter" that

-32: is widely used in medical diagnosis. Potassium-40, a common naturally-occurring l33' radionuclide, is also a gamma emitter.

34 Some radionuclides emit more than one type of radiation. For example, Cesium-137 and 35 lodine-131 are both gamma and beta emitters.

36 How is Radiation Measured?

1

DRAFT FOR COMMENT 1 Whether it emits alpha or beta particles or gamma rays, the quantity of radioactive materialis 2 typically expressed in terms of its radioactivity or simply its activity and is measured in Curies.

3 One Curie equals 37 billion atomic disintegrations per second. Activity is used to describe a 4 material, just as one would dlscuss the length or weight of a material. For exampie, one would 5 say "the activity of the uranium in the container is 2 Curies." Generally, the higher the activity of 6 the material, the greater the potential health hazard assochted with that material if it is not 7 properly controlled. At nuclear power reactors, the activity of radioactive material may be 8 described in terms of hundreds to millions of Curies, whereas the units typically used to 9 describe activity in the environment and at POTWs are often microcuries (pCi) or picocuries 10 (pCi). A microcurie is one one-millionth (1/1,000,000) of a Curie and a picocurie is one one-11 trillionth (1/1,000,000,000,000) of a Curie.

12 The activity of a radionuclide decreases or decays at a constant rate. The time ;t takes the 13 activity of a radioactive material to decrease by half is called the radioactive half-life. After one 14 half-life, the remaining activity would be one-half (%) of the original activity. After two half-lives, .

15 the remaining activity would be one fourth (1/4), after three half-lives one eignth, and so on. j 16 For example, if a radionuclide has a half-life of 10 years, the amount cf material remaining after ,

17 10 years would be % of that originally present. After 100 years (10 half-lives), the remaining j 18 activity would be 1/1024 of the amount that was originally present. Some radioactive materials 19 have extremely short half-lives measured in terms of minutes or hours; for example, lodine-20 131, used in medical procedures, has a half-life of 8 days. Others have half-lives measured in i 21 terms of millions to billions of years; for example, naturally occurring Thorium-232 has a half-  !

22 life of 14 billion years, and natural Uranium-238 has a half-life of 4.5 billion years.

)

23 Some radioactive materials decay to form other radioactive materials. These so-called decay 24 products,in turn, decay to stable nuclides or other radioactive materials. Each material formed 25 through decay has a unique set of radiological properties, such as half-life and energy given off 26 through decay, in the case of the radioactive materials at POTWs, the radioactive materials 27 present may consist of one or more separate decay " chains" or " series." The naturally-28 occurring nranium and thorium decay chains are summarized in the following table.

29 Series: Uranium Thorium 30 Uranium-238 Thorium-232 31 1 1 32 Uranium 234 Radium-228 33 1 1 34 Thorium-230 Thorium-228 35 1 1 36 Radium-226 Radium-224 37 1 1 38 Radon-222 Radon-220 39 1 1 i 40 Lead-210 Lead (Stable) l 41 1

{

42 Lead (Stable) j l

2 i

~ .- - . - ~ - - - _ _ _ . _ . _ _ - - . . . ._._. _..-

4 DRAFT FOR COMMENT i

1 ' Some of the radioactive materials in these chains emit gamma rays when they decay. The  !

2 intensity of gamma radiation in air or exposure rate is measured in Roentgens (R) or 3 microRoentgens (pR) per unit time, usually an hour, as in R/hr or pR/hr. In the environment, 4 exposure rates are typically measured in terms of pR/hr. For example, in many parts of the 5 United States the exposure rate from natural sources of radiation is between 5 and 15 pR/hr.

6 This ambient level is referred to as the background exposure rate.

7 Many commercially available radiation detectors measure radiation fields in terms of pR/hr or

'8 counts per minute (cpm). " CPM" refers to the number of ionizing particles striking the detector 9 surface in a minute. A fraction of these particles are recorded by the detector as counts. The 10 number of counts per minute can then be related to exposure rate or radiation dose for a known

,. 11 radionuclide for which the instrument has been calibrated.

12 Radiation dose is a measurement or estimate of the body's exposure to ionizing radiation. It is

-~13 . typically measured in units of rem. . In the environment and at POTWs, doses are often 14 measured in terms of millirem (mrem). A millirem is one one-thousandth (1/1,000) of a rem; a j 15_ microrem is one-millionth of a rem (1/1,000,000). The dose rate is expressed in terms of dose 16 per unit time, again usually an hour, as millirem /hr. For external radiation, exposure rates are

17. often equated to dose rates using the conversion of 1 pR/hr = 1 microrem/hr. Doses from I 18 internal exposure to radioactive material that has been ingested or inhaled are more difficult to ,

19 determine. Computer models that account for the distribution and excretion of the radioactive i 20 material within the body are used for estimating doses and dose rates from internal radioactive 21 contamination.

22 ' What are the Effects of Radiation Exposure?  !

23 When radiation in- acts in_ and through living tissue, it may damage some cells in the body.

24 Some cells may not survive the damage and die while other cells will survive the damage and 25 reproduce normally. Other damaged cells may suntive, but in a modified form, which may later 26- result in cancer. Other health effects from low doses of radiation (tens of rems) may include 27 birth defects and genetic effects. High doses of radiation (hundreds of rems) over short periods 28 of time may cause organ damage and,if high enough, death. Doses associated with 29 exposures to natural background radiation or typical radioactive materials in POTWs are

-3T thousands of times lower than the high doses that can cause significant biological damage. 4

-31 At low doses, the principal concern associated with radiation exposure is the possible 32 occurrence of cancer years after the exposure occurs. Other effects such as birth defects and

- 33 genetic effects are less likely. For such low doses, the likelihood of producing cancer has not 34 - been directly established because it is not possible to distinguish cancers produced by such low 35 levels of radiation from cancers produced by other sources, such as harmful chemicals in the 36 environment. Therefore, in estimating the consequences of any exposure to radiation, it is

-37 assumed that the risk of developing cancer is linearly proportional to dose and that there is no 38 threshold below which there is no char ce of cancer. This chance, or risk, is expressed in terms

39. of probabilityof an adverse health effect because a given dose of radiation does not produce a 40 cancer in all cases. The NRC uses the linear assumption and the philosophy that radiation 41 exposure should be kept as low as reasonably achievable (ALARA) for purposes of regulating 3

8 e r ,- ,

w , ,-- - - -~ , ,,

! DRAFT FOR COMMENT l

1. the use of radioactive materials.

1 2 What are the types of radiation and half-lifes for the radionuclides that are caused by l 3 human activities and may be present at POTWs?

4 Radionuclide Type of Radiation Half-life l 5 Americium-241 alpha, gamma 458 years i 6 Antimony-125 gamma 3 years l 7. Beryllium 7 gamma 53 days

! 8 Carbon-14 beta 5730 years

9 Cesium-134 beta, gamma 2 years 10 Cesium-137 beta, gamma 30 years 11- Chromium-51 gamma 28 days l 12 Cobalt-57 gamma 271 days 13 CoMlt-60 beta, gamma 5 years 14 Gallium-67 gamma 3 days 15 Hydrogen-3 (tritium) beta 12 years 16 Indium-111 gamma 3 days 17 lodine-123 gamma 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> 18 lodine-125 gamma 60 days

19 lodine-129 beta, gamma 20 million years l

20 lodine-131 beta, gamma 8 days 21 Iridium-192 beta, gamma 74 days 22 Iron-59 gamma 45 days 23 Lead-210 a!pha, beta, gamma 22 years 24 Manganese-54 gamma 303 days

25 Niobium-95 beta, gamma 35 days

. 26 Phosphorus-32 beta 14 days 27' Phosphorus-33 beta 25 days 28 Plutonium-238 alpha 86 years 29 Plutonium-239 alpha 24,400 years 30 Plutonium 240 alpha 6580 years 31 Polonium-210 alpha 138 days 4

4 l;-

,......--.........,....q l

DRAFT FOR COMBENT 1 Radium-226 alpha, gamma 1600 years 2 Selenium 75 gamma 120 days 3 Strontium-89 beta 52 days 4 Strontium 90 beta 28 years 5 Sulphur-35 beta 87 days 6 ' Technetium-99m gamma 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 7 Thallium-201 gamma 3 days 8 Thorium-228 alpha, gamma 2 years 9- Thorium-232 alpha 14 billion years

'10 - Uranium-233 alpha, gamma 162,000 years

-)1 Uranium-234 alpha 247,000 years '

12 Uranium-235 alpha 710 million years 13 Uranium-238 alpha 4.5 billion years 14 . Xenon-133 beta, gamma 5 days

' 15 Zinc-65 beta, gamma 245 days 16 Zirconium-95 beta, gamma 64 days _

m 5

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

3 EPA standards and criteria pertinent to setting standards or guidance for levels of radioactivity 4 in sewage sludge might include:

5 Standard or Guideline Type Year Limit (dose or risk) 6 Standards for the Use or Disposal Regulation (40 1993 Concentration of carcinogens 7 of Sewage Sludge (does not include C.F.R.503) at 1 x 104risk and risk 8 radionuclides) reference doses for metals 9 Radiation Site Cleanup Draft regulation (40 1994 15 mrem / year and protection C.F.R.196) of ground water to Safe Drinking Water Act Maximum Contaminant Levels (MCLs) 10 Uranium Mill Tailings Regulation (40 C.F.R. 1983 Concentration-based criteria 192) for land, buildings, and ground water, e.g.,5 pCl/g of radium-226 over the first 15 cm of soil averaged over 100 square meters 11 Resource Conservation and Advance Notice of 1996 104to 10 4risk range and 12 Recovery Act (RCRA)- Corrective Proposed regulation protection of ground water to 13 Action for Releases From Solid (40 C.F.R 264, MCLs 14 Waste Management Units at Subpart S) 15 Hazardous Waste Management 16 Facilities

17. Management and Disposal of Spent Regulation (40 C.F.R. 1985 NRC regulated facilities: 25

.18 Fuel, High Level, and Transuranic 191, subpart A- mrem /yr whole body or critical 19 Waste management) organ; 75 thyroid; DOE regulated facilities: 25 whole body,75 critical organ 20 National Oil and Hazardous Regulation (40 CFR 1990 104to 10 4risk range, 21 Substances Pollution Contingency 300) prr.tection of ground water to

-22 Plan (Superfund) MCLs 23 Certification Criteria for WIPP Final regulation (40 1996 15 mrem /yr and MCLs 24 Compliance With 40 CFR Part 191 C.F.R.194) 6

. .- - . - - . . . . - . .. .. - - -. - . .. - - - _ - . ~ .-. - .-. - .

3 9

DRAFT FOR COBOEENT

. Standard or Guideline Type Year Limit I

(dose or risk)

[ Radiation Protection Guidance to Final guidance 17 1967' As low as reasonably L 2 Federal Agencies for Occupational

' achievable (ALARA) and not t 3_ Exposure ~ to exceed 5 rems in any year

. by an adult worker. Also includes guidance to not ~

exceed 0.5 rem to an unbom i worker's child or not exceed i'" one-tenth of the adult value for individuals under eighteen years old .

4 :: Federal Radiation Protection Proposed guidance 1994 No exposure to the'public p -5 Guidance for Exposure of the unless it is justified by an H ~6' General Public expected overall benefit from

!, activity causing exposure; p dose to individuals as low as ,

reasonably achievable

(ALARA); 100 mrem /yr from L

all sources covered by u guidance combined; .

E '

standards or regulations at a fraction of 100 for individual y sources .

7 Management and Disposal of Spent Regulation (40 C.F.R. 1993 15 mrem /yr and MCLs  ;

L .8. Fuel, High-Level, and Transuranic 191, Subpart B- <

9- Waste disposal)

L 10 National Emission Standards for - Reg'ulation (40 C.F.R. 1989 10 mrem /yr L Hazardous Air Pollutants; 61, Subparts H and I)

L .12- Radionuclides..

T13? Uranium Fuel Cycle Regulation (40 C.F.R. 1977 25 mrem /yr whole body or 190)' critical organ; 75 thyroid a

14" Drinking Water MCLs - Beta / photon '

Regulation (40 C.F.R. _1976 4 mrem /yr 15: emitters - 141) 1 16L Drinking Water MCLs - Alpha Regulation (40 C.F.R. 1976 15 pCi/l 1 17 emitters = .141) .

D .18' Drinking Water MCLs - Radium , Regulation (40 C.F.R. 1976 5 pCl/l 141) p ,

7 s

( .

s

l I i-t DRAFT FOR COMMENT l' The basic radiation protection standards formulated by the NRC for radionuclide users are 2 published in the Code of Federal Regulations (CFR), Title 10, Part 20. These standards were

! 3 prepared from the recommendations of advisory boards such as the National Council on 4 Radiation Protection and Measurements (NCRP,1971, Report 39) and the Internstional 5 Committee on Radiological Protection. The requirements for disposal of radioactive materials

6 into the sanitary sewer are in 10 CFR 20.2003.

7 Radiation protection standards applicable to DOE facilities are found in the following regulations 8 and internal DOE Orders:

9 10 CFR Part 834 - Radiation Protection of the Public and the Environment (to be issued 10 soon) 11 10 CFR Part 835 - Occupational Radiation Protection 12 Order DOE 5400.1 - General Environmental Protection Program 13 Order DOE 5400.5 - Radiation Protection of the Public and the Environment 14 Order DOE 5820.2A - Radioactive Waste Management l

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4 DRAFT FOR. COMMENT 1 APPENDlX B 2 NRC AND EPA REGIONAL OFFICES BY STATE AND 3 IDENTIFICATION OF AGREEMENT STATES 4 State

• NRC Realonal Office EPA Reaional Office

, 5 ALABAMA

• ll 4 6 ALASKA IV 10 7 ARlZONA* IV 9 8 ARKANSAS

• IV 6 9 CALIFORNIA

• IV 9 10 -COLORADO

• IV. 8 11- CONNECTICUT l 1 12 DELAiNARE l 3 13 DST OF COLUMBIA I 3 14 FLORIDA * - ll 4

'15 GEORGIA

• 11 4 16 HAWAll IV 9 17 IDAHO IV 10 18 ILLINOIS

• Ill 5 19 INDIANA lil . 5

.20 IOWA

• lil 7 21 - KANSAS

• IV ~7 22- KENTUCKY

• 11 4 23 LOUISlANA* IV 6 24 MAINE

• I 1-25 MARYLAND

• l -3 26- MASSACHUSETTS

• 1 1 27 MICHIGAN , lll 5

.28 MINNESOTA Ill 5 29 MISSISSIPPl* 11 4 30 MISSOURI til 7 31 MONTANA IV 8

.32 NEBRASKA

• IV 7 33 NEVADA * - IV 9-34 NEW HAMPSHIRE

• 1 1 35 NEW JERSEY l 2 36 NEW MEXICO

• IV 6 37 NEW YORK

• l 2 38- NORTH CAROLINA

• 11 4 39 NORTH DAKOTA

• IV 8 40 OHIO Ill 5

'41 OKLAHOMA IV 6

-~42 OREGON

• IV 10 43 PENNSYLVANIA I 3

. 9 1

DRAFT FOR COMMENT 1 RHODE ISLAND

• 1 1 2 SOUTH CAROLINA

• ll 4 3 SOUTH DAKOTA IV 8 ,

4- ' TENNESSEE

• 11 4 5 TEXAS

• IV 6 6' UTAH

• IV 8 7 = VERMONT I 1 8 VIRGINIA ll 3 9 WASHINGTON

• IV 10 1 10 WEST VIRGINIA ll 3

-11 ' WISCONSIN - lil 5

12. WYOMING IV 8 13 CANAL ZONE 11 l 14- PUERTO RICO 11 2 15 VIRGIN ISLANDS 11 2 l 16 GUAM IV 9 l

17. AMERICAN SAMOA IV 9 18

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

C l'

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4 j

~

DRAFT FOR COMMENT 1 APPENDIX C i 2 NRC REGIONAL OFFICES i

3 Division of 4 Nuclear Materials State Agreements 5 Address Safetv Officer  ;

l 6 Region I (610) 337-5281 (610) 337-5216 j 7 475 Allendale Road 8 King of Prussia, PA 19406-1415

'9 Region 11 (404) 562-4700 (404) 562 4704 1 10 Atlanta Federal Center

. 11 61 Forsyth St, SW 12 Suite 23T85  ;

13 Atlanta, Ga 30303-3415 I 14 Region 111 (630) 829-9800 (630) 829 9818

- 15 801 Warrenville Road 1 16 Lisle, IL 60532 4351 17 Region IV (817) 860-8106 (817) 860-8267 18 Harris Tower

- 19 611 Ryan Plaza Drive, Suite 400 20 Arlington, TX 76011-8064 11

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DRAFT FOR COMIENT  !

1 APPENDIX D 2 EPA REGIONAL OFFICES 3 ~ EPA Radiation Proaram Manaaers  !

~

.4' EPA Region 1 EPA Region 2 i

'5 John F. Kennedy Federal Building 290 Broadway I

6. One Congress Street ' New York, NY 10007-1866 l

'7. Boston, MA 02203-0001 (212) 264-4110 8 (617) 565-4602 1

9 EPA Region 3 EPA Region 4 )

10- Special Program Section (3AM12) 101 Alabama St., S.W. 1

11. 841 Chestnut Street Atlanta, GA 30365 l 12 Philadelphia, PA 19107 (404) 347 3907 13 (215) 597-8326

-14 EPA Region 5. EPA Region 6 i 15 5AR26 Air Enforcement Branch (6T-E) j 16- 77 West Jackson Boulevard 1445 Ross Avenue I

-17 Chicago, IL 60604-3507 Dallas, TX 75202 2733 l 18- (312) 886-6175 (214) 655-7224

.19 EPA Region 7 EPA Region 8 20 726 Minnesota Avenue 8HWM-RP, Suite 500 '

21 Kansas City, KS 66101 99018th Street 22- '

(913) 551-7605 Denver, CO 80202 2466 23- (303) 293-1440 24 EPA Region 9 . EPA Region 10 25 ' A1-1 ~ AT-082 26 75 Hawthorne Street 1200 Sixth Avenue 27- San Francisco, CA 94105 Seattle, WA 98101 28- (415) 744-1048 (206) 553-7660 i

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te DRAFT FOR ColGIENT

1 APPENDIX E 2 STATE AGENCIES FOR RADIATION CONTROL 3 (To be updated as State point of contact is identified)

-4'. Kirksey E. Whatley, D' irector 5'

.. State Department of Public Health 6 -- Division of Radiation Control 7 State Office Building

8' 434 Monroe Street

,..- 9 _ Montgomery, AL 36130 1701 10' Phone - (334)613-53911 L11 Bernard R. Bevill, Acting Director 12 . Department of Health 13 . Division of Radiation Control & Emergency Mgmt i

14 4815 West Markham Street, Slot 30 15 Little Rock, AR 72205-3867 16' Phone - (501)661-2301 Il7_ Aubrey V. Godwin, Director

18 Arizona Radiation Regulatory Agency .

19 ' 4814 South 40th Street

. 20. . Phoenix, AZ 85040 21 Phone - (602)255-4845 ext. 222 ^ i

22. Edgar D. Bailey, C.H.P., Chief .

- 23.' State Department of Health Services

-:24 Radiologic. Health Branch 25 Food, Drugs & Radiation Safety Division

-26 714/744 P Street

- 27 601 N 7th Street, Continental Plaza

- 28 P.O. Box 942732

29. Sacramento, CA 94234-7320 95814 30- Phone - (916)322-3482

~31 Robert M. Quillin, Director 32: . Department of Public Health & Environment 33 ' RadiaWn Control Division J j

-34' 4300 Cherry Creek Drive South (RCD-DO-B1)  !

35  ; Denver, CO 80222-1530 I

36-  : Phone - (303)692-3030 -

37 William'A. Passetti, Acting Chief .

38 Department of Health & Rehabilitative Services

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DRAFT FOR COMMENT

'l' Office of Radiation Control 2 1317 Winewood Boulevard 3 2009 Apalachee Parkway i 4 Tallahassee, FL' 32399-0700 32301 l 5 Phone - (904)487-1004

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6 Thomas E. Hill, Manager L 7. Department of Natural Resources

8. Radioactive Materials Program 19 ' 4244 Internatior.al Parkway, Suite 114 10 Atlanta, GA 30354 Phone - (404)362-2675 i

12 Donald A. Flater, Chief 13 lowa Department of Public Health  ;

14- Bureau of Radiological Health -  !

15 Lucas Stats Office Building 16 ' 321 East 12th Street 17 Des Moines,IA 50319 ),

18- - Phone - (515)281-3478 L - i 19 Thomas W. Ortciger, Director

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20- Department of Nuclear Safety 1 21 '1035 Outer Park Drive l 22 - Springfield, IL 62704

'23 Phone - (217)785-9868

.24 Vic Cooper, Director

.25- Bureau of Air & Radiation

.26 X Ray & RAM Control Section

-27 Department of Health & Environment- l 28' Forbes Field, Building 283 l 29 J Street & 2nd North 30! Topeka,KS 66620 '

31 ' Phone - (913)296-1562

'32- Charles M. Hardin, Executive Director -

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. 33 - Conference of Radiation Control Program Directors, Inc. l

._ 34- 205 Capital Avenue ,

j 35 ~. . Frankfort, KY 40601

36 - Phone - (502)227-4543 . I

!37 - _ John A. Volpe, Ph.D, Manager #2 L 38- Cabinet for Health Services  !

l 39: Radiation & Toxic Agents Control Section j 40 275 East Main Street l t- i i

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l DRAFT FOR COBOMNT l 1 Frankfort, KY .40621-0001 2 Phone - (502)S64-3700 o 3- William H. Spell, Administrator i 4 Department of Environmental Quality 5 Radiation Protection Division 6 Office of Air Quality & Radiation Protection

-7 ' 7220 Bluebonnet Road '

8 P.O. Box 82135 9 Baton Rouge, LA 70884-2135 10 Phone - (504)765-0160 11 Robert M. Hallisey, Director jl2 Department of Public Health -

13- Radiation Control Program 14 305 South Street,7th Floor 15 Jamaica Plain, MA 02130 16' Phone - (617)727-6214 17 Roland G. Fletcher, Manager 18 Maryland Department of the Environment 19 Radiological Health Program 20 Air and Radiation Management Administration

21. 2500 Broening Highway

22 Baltimore, MD 21224 l 23- Phone - (410)631-3300 - l 24- Robert J. Schell, Nuclear Engineering Specialist 25 Radiological Health Program 26 Division of Health Engineering 27 State House, Station 10

-28 157 Capitol Street 29 - Augusta, ME 04333-30 Phone - (207)287-5698 I

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DRAFT FOR COBOMNT L.

L 1 Robert W. Goff, Director

2- State Department of Health L 3 Division of Radiological Health 4- 3150 Lawson Street 5 P.O. Box 1700

~6 Jackson, MS 39215-1700 39213 7 Phone - (601)354-6657 8 R.M. Fry,' Acting Director 9 Department of Environment, Health & Natural Resources

10. Division of Radiation Protection 11 3825 Barrett Drive 12

• Raleigh, NC 27609-7221 27609 7221 13 Phone - (919)S71-4141 14 Dana K. Mount, Director 15 Department of Health 16 Division of Environmental Engineering 17 1200 Missouri Avenue, Room 304 18~ P.O. Box 5520 19 Bismarck, ND 58506-5520 20 Phone - (701)328-5188 .

21 Mark B. Horton, M.D., M.S.P.H., Director 22 Nebraska Department of Health 23 '. l301 Centennial Mall South

.24 P.O. Box 95007 25~ ' Lincoln, NE 68509-5007 26 Phone - (402)471-2133 27 Diane E.Tefft, Administrator 28 Division of Public Health Services 29: Radiological Health Bureau

30. Health and Welfare Building 31 - 6 Hazen Drive 32 Concord, NH 03301-6527

33' Phone - (603)271-4588 i

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'l Benito'Ga'rcia, Chief 2- Department of Environment 3 '. Bureau of Hazardous & Radioactive Materials

'4  ; .- Water and Waste Management Division

.5 2044 Galisteo Road 6' ' P.O. Box 26110 -

'7~  ! Santa Fe, NM 87502 87505 8 Phone - (505)827-1557 9- Stanley R. Marshall, Supervisor

'10 ' Department of Human Resources ill- Radiological Health Section

12 400 West King Street, Room 101 13.- Carson City, NV 89710

'14 . Phone -(702)687-5394 15' Rita Aldrich, Principal Radiophysicist

~16; New York State Department of Labor

17. Radiological Health Unit 18 Division of Safety and Health'

.19 - ' New York State Office Campus

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'20 Building 12, Room 457

' 21 Albany, NY 12240 22 Phone - (518)457-1202.

23 John P. Spath, Director #2 24- New York State Energy Research & Development Authority 25 Radioactive Waste Policy and Nuclear Coordination

26- Corporate Plaza West 27: 286 Washington Avenue Extension -

28 Albany, NY 12203 6399

. 29 Phone - (518)8621090 ext.3302, 30 ' Paul J. Merges, Ph.D., Chief ' #3

31 - Department of Environmental Conservation

.32 Bureau of Pesticides and Radiation N :33 - Division of Solid and Hazardous Materials

.: 34 50 Wolf Road, Room 402 -

1 35 ~ Albany, NY. 12233-7255 12233 136 Phone - (518)457 2225.

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s DRAFT FOR COMMENT 1- Karim Rimawi, Ph.D., Director #4 2 New York State Department of Health

.3 Bureau of Environmental Radiation Protection 4 Two University Piace 5 Albany, NY 12203 6 -Phone - (518)458-6461 7 Kenneth R. Daniel, Deputy Director #5 8 New York City Department of Health 9 Bureau of Radiological Health 10 111 Livingston Street, Room 2006

-11 Brooklyn, NY 11201-5078 12 Phone - (718)643-8029 13 Roger L. Suppes, Chief 14 Ohio Department of Health 15 Bureau of Radiological Health .

-16 35 East Chestnut Street 17 P.O. Box 118 18 Columbus, OH 43266-0118 19 Phone - (614)644-2727 20 Mike Broderick 21 Environmental Program Administrator 22 Department of Environmental Quality.

23 Radiation Management Section 24 1000 NE 10th Street 25 -Oklahoma City, OK 73117-1212 26 . Phone - (405)2717484 27- Ray D. Paris, Manager 28 Department of Human Resources 29 F.adiation Protection Services

30. State Health Division 31 ,800 N.E. Oregon Street

-32 Portland, OR 97232

33 Phone - (503)731-4014 34 35 l

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DRAFT FOR COMIENT 1 William P. Dornsife, Director 2 Department of Environmental Protection 3 Bureau of Radiation Protection 4 400 Market Street 5 . P.O. Box 8469 6 Harrisburg, PA 17101 7 Phone - (717)787-2480 8 Marie Stoeckel, Chief 9 Department of Health 10 Division of Occupational & Radiological Health 11- 3 Capital Hill, Room 206 12 Providence, RI 02908-5097 13 Phone -(401)277 2438 14 Virgil R. Autry, Director 15 Department of Health & Environmental Control

'16 Division of Radioactive Waste Management 17 Bureau of Solid and Hazardous Waste 18 2600 Bull Street

~19 Columbia, SC 29201 20 Phone - (803)896-4244 21- Max K. Batavia, P.E., Chief #2

'22 Department of Health & Environmental Control 23 Bureau of Radiological Health 24 2600 Bull Street 25 Columbia, SC 29201 26 Phone - (803)737-7400 27 - Michael H. Mobley, Director 28 Department of Environment and Conservation 29 Division of Radiological Health 30- L&C Annex,3rd Floor 31 401 Church Street

32. Nashville, TN 37243 1532 33 g Phone - (615)532-0360 t

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I DRAFT FOR COBOMNT 1 Minor Brooks Hibbs, P.E., Director 2 Texas Natural Resource Conservation Commission 3 Industrial & Hazardous Waste Division  !

4 12015 NIH-35 5 P.O. Box 13087 6 Austin, TX 78711-3087

7. Phone - (512)239-6592 8 Richard A.'Ratliff, P.E., Chief #2 9- Texas Department of Health i, . 10- Bureau of Radiation Control

. 11- - 1100 West 49th Street 12 Austin, TX 78756-3189 13' _ Phone - (512)834-6688

14. William J. Sinclair, Director

15. Department of Environmental Quality i

. 16 Division of Radiation Control  ;

17 168 North 1950 West -

18 P.O. Box 144850

.19 . Salt Lake City, UT 84114-4850 20 Phone - (801)536-4250 21 John L. Erickson, Director

' 22 Department of Health 23 Division of Radiation Protection 24 Airdustrial Center Building #5 25 P.O. Box 47827

- 26 Olympia, WA 98504-7827 27 Phone - (360)664-4536 i

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DRAFT FOR COMBENT 1 APPENDIX F 2- EXAMPLES OF POTWS THAT HAVE RADIONUCLIDE MATERIALS PROGRAMS 3 Albuquerque, New Mexico I 4 The City of Albuquerque has established a Radioactive Discharge Monitoring Program (RDMP).

5 This is a voluntary program of monitoring and reporting. The Albuquerque POTW has found

6 they have the responsibility to be aware of all discharges to the sewer system that could impact j- 7 operations at the treatment plant or impact the health and safety of employees and the public.

8- The POTW has implemented a program of discharger registration that requires dischargers to l

l. 9 (1) periodically report their radionuclide discharges, (2) allow the POTW to perform surycillance i 10 monitoring, and (3) commit to voluntarily limit their discharges to levels that are as low as I

! 11 reasonably achievable (ALARA). These registrations are issued and monitoring of the  !

i. 12 . dischargers is permitted in accordance with a city sewer use and wastewater control ordinance. '

13 The agreement could be in the form of an amendment to an existing sewer discharge permit.

! 14 The Albuquerque POTW obtained a list of licensed radioactive materials users in the municipal l .15 service area from the appropriate regulatory authority (New Mexico is an Agreement State), l i 16 Each of the licensees was evaluated to determine whether or not they discharge or have the i

17 potential to discharge radioactive materials to the sewer. This includes an initial walk-through 18 to familiarize the RDMP staff with the nature of the operation and potential opportunities for 19 waste

ninimization.

l 20 The POTW negotiated discharge limits with the dischargers so that the aggregate regulated 21 discharges from all licensed facilities is ALARA and produces no greater than 1 in 10,000 22 excess risk of fatal cancer to the "most exposed" individual. The POTW also works with 23 potential dischargers to prevent accidental releases of radioactive materials.

24 The Albuquerque POTW retains a certified Health Physicist to interpret the reports from the

! 25 dischargers and from monitoring the dischargers and the treatment facility. The health physicist 26 uses radiation exposure models to ensure the radiation dose to the "most exposed" individual is 27 ALARA.

28 . The dischargers are asked to provide annual reports regarding the discharges they have made 29 - . or plan to make to the sewer. In addition, the RDMP staff collects samples from the facilities' ,

30 sample locations on a regularly scheduled basis and/or unannounced. The samples are  !

31 analyzed by the State. To date the radioisotopes found in the sewage have been of medical l

l. 32 origin. Gamma radiation detectors installed at the plant have indicated that no measurable  ;

E 33  : radiation exposure is being received by plant workers.

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1 St. Louis, Missourl j l

2 The City of St. Louis has its own requirements to limit radioactive discharges from industrial 3  !

users. The district is concerned that low level rariioactive materials being discharged to the 4 i sewer system by numerous small sources may be concentrated by the district's wastewater 1 5 treatment processes and possibly pose a hazard for the employees and adversely affect the l l 6 district's sludge disposal options. .

l 7 The District Ordinance for sewer use contains a limit of 1 curie /yr for the aggregate discharge 8 from all users in a watershed (except excreta from individuals undergoing medical treatment or I l 9 diagnosis). This number is currently under review.  ;

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The district requested lists of licensees from the NRC and the State and wrote tne licensees L 11 letters informing them of the limits for radionuclide aischargers. Licensees are required to write l 12 the sewer district requesting approval to discharge radioactive materials and indicating the l 13 isotopes and the amounts to be discharged annually. The district then approves the 14 discharges. The district requires quarterly reports from the licensees to ensure compliance with 15 the District Ordinance and State and Federal regulations. The licensee's discharge permit is 16 then modified to incorporate the approval of discharges and the reporting requirements.

17- As alternative to discharging to the sewer system, licensees are encouraged to consider 1 18 shipping the waste to an approved low level radioactive waste disposal site or storing the waste l 19 for at least ten half-lives to allow sufficient decay to background levels prlor to disposal to the i 20 sewer. I I

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.. I DRAFT FOR COMIENT 1 APPENDIX G 2 BIBLIOGRAPHY AND SOURCES OF ADDITIONAL INFORMATION 3 Ainsworth, C. C., Hill, R. L., Cantrell, K. J., Kaplan, D. l., Norton, R. L., Aaberg, R. L.,1994, 4 " Reconcentration of Radioactive Material Released to Sanitary Sewers in Accordance with 10

.' 5 CFR Part 20," NUREG/CR-6289, U.S. Nuclear Regulatory Commission, Washington, D.C.

6 20555.

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ASTM E 181-82 (Reapproved 1991), " Standard General Methods for Detector Calibration and

8 Analysis of Radionuclides," American Society for Testing and Materials, Philadelphia, L- 9 . Pennsylvania 19103.

10 CRCPD Publication 94-1, " Directory of Personnel Responsible for Radiological Health 11 Programs," Conference of Radiation Control Program Directors, Inc., Frankfort, Kentucky

. 12. 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 Contamination at

17. Sewage Treatment Plants."

18 Huffert, A.M., Meck, R.A., Miller, K.M.,1994, " Background as a Residual Radioactivity Criterion 19 for Decommissioning," NUREG-1501, U.S. Nuclear Regulatory Commission, Washington, DC

- 20 20555.

21 Kennedy, Jr., W. E., Parkhurst, M. A., Aaberg, R. L., Rhoads, K. C., Hill, R. L., Martin, J. B.,

22 1992, " Evaluation of Exposure Pathways to Man from Disposal of Radioactive Materials into i 23. Sanitary Sewer Systems," NUREG/CR-5814, U.S. Nuclear Regulatory Commission, 24 Washington, D.C. 20555.

. 25 Miller, W.H., et al,1996, "The Determination of Radioisotope Levels in Municipal Sewars a

- 26 Sludge," Health Physics, v. 71, no. 3, p. 286.-

27 Miller, M.L., Bowman, C.R., an M.G. Gatcla,1997 3" Avoiding Potential Problerns ,,,

28 NCRP Report No. 50, " Environmental Radiation Monitoring," 1976, National Council on

~ 29 Radiation Protection and Measurements, Bethesda, Maryland.

30 . NCRP Report No. 58, "A Handbook of Radioacdvity Measurement Procedures." 1985,"

31 National Council on Radiation Protection and Measurements, Bethesda, Maryland.

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L 1 Washington Suburban Sanitary Commission, " Radioactive Waste Disposal Risk Study "

2 October 1995.

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