ML20206R147
| ML20206R147 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1999 |
| From: | Mo T NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | NRC |
| References | |
| NUDOCS 9905200010 | |
| Download: ML20206R147 (10) | |
Text
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.i March 31, 1999
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Dear Members of the ISCORS Sewage Subcommittee:
Enclosed is a summary of the Subcommittee meeting held on January 19,1999.
Sincerely, 1s7TMo Tin Mo, Ph.D.
Environmental Health Physicist /
Nuclear and Radiochemist Radiation Protection Environmental Risk and Waste Management Branch Division of Risk Analysis and Applications Office of Nuclear Regulatory Research
Enclosures:
As stated i
Distribution:
Central Files T. O'Brein PDR D. Schmidt
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RPERWMB R/F P.Sobel J. Hickey G. Powers
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L Abramson DOCUMENT NAME: a:\\199mtgtm. sum.wpd To receeve a cocy of tNs document. Indicate in the box *Ca a copy without attachnwWenclosure. "B" a copy with attachment / enclosure. "Pr* = No copy OFFICE:
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3/31/99 3/3//99 OFFICIAL RECORD COPY RES FILE CODE NO.: 36-3 4
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March 29,1999 DISCLAIMER These ISCORS subcommittee meeting summaries result from interagency discussions. The Sewage Subcommittee is composed of representatives from the Envire.9 mental Protection Agency, Nuclear Regulatory Commission, Department of Defense, Department of Energy, the State of New Jersey, and two Publicly Owned Treatment Works. The Subcommittee summaries have not been approved by the respective agencies and organizations and do not represent the official position of any participating organization at this time.
ISCORS SEWAGE SUBCOMMITTEE MEETING
SUMMARY
Date:
January 19,1999 Time:
9:00 a.m. to noon Location:
U.S. Nuclear Regulatory Commission One White Flint North Building, Room O-1-F-5 10555 Rockville Pike, Rockville, Maryland Attendees: NRC:
Tin Mo, George E. Powers, Phyllis Sobel, Lee Abramson, Robert Nelson, Thomas O'Brien EPA:
Robert Bastion, Mark Doehnert, Dale Hoffmeyer, Behram Shroff, Alan Rubin DOE:
James Bachmaier ORISE:
Dale Condra NAREL:
David Saunders, Scott Teloffski STATES: Jill Lipoti, New Jersey POTW:
Thomas Lenhart (NEORSD)
Agenda:
Sewage Survey Dose Modeling Work Group Guidance Document
i s
Summary:
Bob Bastian started of the meeting by passing out the summary of the December 2,1998 meeting and requesting for comments from the subcommittee members to finalize it. He also distributed the updated list of e-mail and mailing addresses and telephone End facsimile numbers for the subcommittee members and requested that members provide to him any l
changes or corrections as appropriate.
For the topics that are related to the Sewage Survey, the Quality Assurance Project Plan was the first topic on the agenda. However, Mary Wisdom who has the responsibility to prepare it was not available to participate at the beginning of the meeting. Therefore, the Subcommittee decided to go on to the next topic, namely, the recent work on the Reference Radionuclide Table by Jim Bachmaier, Phyllis Sobel and Tin Mo.
1 Jim Bachmaier, Tin Mo and Phyllis Sobel distributed the latest draft of Appendix B to the Public Document which includes the drafts of revised Reference Radionuclide Tables 1 and 2. They described and explained to the Subcommittee members how they prepared these latest drafts of the tables. As agreed to in the previous meeting on December 2,1998, Jim had included in Table 1 all the data on radionuclide concentrations that were measured and reported by NAREL and ORISE for sewage sludge and ash samples from the nine test sites of the pilot study.
Phyllis revised Table 2 to correct some errors in the previous version.
Bob Bastian asked if the data in Table 1 could be presented in either ascending or descending order of the concentrations and whether it may be more desirable to present the data in such an order. Jim Bachmaeir explained that the order data is presented in Table 1 is the same as it is recorded in the NAREL/ORISE files and that it would be easier to present it this way and to go back and match the data with those in the files if it becomes necessary. The consensus of the subcommittee members was that we do not change the format of the data in Table 1. Bob then suggested that either the text or a footnote to Table 1 should reflect Jim Bachmaeir's rationale for presenting the data as it is now in Table 1.
Tin Mo informed the subcommittee members that he and the NRC library staff performed an online literature search for published data on concentrations of radionuclides in U.S. natural background soil, fertilizers, and building materials and found values mostly for U-238, K-40, and Th-232 and some for Ra-226 but had no luck finding any data for other radionuclides such as Co-60, Cr-51,1-125,1-131, C-14, H-3, Sr-89, Sr-90, and the actinide radionuclides such as Pu-238, Pu 239, and Am-241. The Subcommittee members agreed with Tin that the acronym "NDA", (no data available), be used to fill in the gaps in Table 2 where no data currently exist in the open literature or in the public domain.
Tin Mo again questioned the appropriateness and usefulness of including ranges of Gross Alpha and Beta data for sewage sludge and ash in Tables 1 and 2 for comparison with ranges of Gross Alpha and Beta activity concentrations in U.S. background soil, fertilizers and building materials which are presented in these tables by the previous developers (EPA and NRC staff) of these tables. This is because these data can not be traced back to the reference, NCRP Report Number 94 cited by them.
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' Tin Mo also mentioned that he could not find any data for " Gross Alpha
- and " Gross Beta" radioactivity for soil, fertilizers, and building materials through his literature search on-line.
He again told the subcommittee that these crude measurements are for screening purposes only to determine qualitatively if any radioactivity is present in samples. He explained that these measurement values are inherently very inaccurate and imprecise and that a comparison of one set of very uncertain data with another set of very uncertain and variable data would not be meaningful or prove anything. Tin again recommended that the Gross Alpha and Beta values j
be deleted from both tables unless somebody in the subcommittee has compelling and convincing reasons and basis to prove that the comparison of these values in sewage samples and in natural background samples is meaningful.
Bob asked NAREL and ORISE staff if they have gross alpha and beta data on the natural background soil, etc., samples, that can be referenced to the laboratories' data base. His reasoning was that the laboratory data base might be able to be used as a reference for the gross alpha and beta values. Dale Condra said ORISE has no data like that, but David Saunders of NAREL said he thinks NAREL may have data that may be referenced back to NAREL's data base for soil, but that NAREL does not have such data for fertilizers and building materials. Tin and Jim Bachmaeir questioned David if he knows for a fact that the data is for background soil and materials and not for contaminated soil and materials David Saunders then said that he will look into it and if they have such data will provide it to Tin to enable him to finalize Table 2. Bob suggested that if available and appropriate NAREL provide the appropriate data to Tin to enable him to complete Table 2. Bob Bastian recommended that it might be worthwhile for Tin to provide copies of Table 2 to Dave Saunders and Dale Condra as soon as he completed the table for review by ORISE and NAREL before the next Subcommittee meeting
- on Tuesday, February 16,1999.
Mark Doehnert of EPA then raised the issue of consistency in the use of significant figures to
_ present the data in Table 't, since he noticed that there is no consistency as the data are presented now in the Table. Mark Doehnert suggested that there should be consistency in the number of significant figures used to present the data in both tables. Jim Bachmaier agreed to revise Table 1 so that all values are shown as rounded up to the first digit after the decimal point and the Subcommittee ~ concurred. Nobody objected to Jim Bachmaier's recommendation to present the data to one digit beyond the decimal point.
Bob Bastian and Phyllis Sobel led the next discussion of topics related to the survey including the status of responding to the ISCORS comments on the Public Report, the remaining steps
. and activities needed to publish the Final Public Report and to place it on the EPA Web Page.
Tin Mo and Bob Bastian then discussed the current status of the responses to the NRC/ EPA letters and comments on the survey and the Guidance document from the States. Bob said that he needed to get copies of some letters and e-mail messages from the States that commented on the guidance document which were sent only to Tin so that he can generate an up-to-date list and file of the responses from the States to the NRC/ EPA letters. Lee Abramson of NRC stated that the NRC Contractor, the Los Alamos National Laboratory (LANL) will compile the responses to the questionnaires into the data base that it is developing for the Nationwide Survey Bob said that by the next Subcommittee meeting, he hoped to have the full list of candidate POTWs
3-to generate mailing lists for the survey questionnaires to be sent out in March. This list would include the names and addresses of contact persons for each POTW. Tom Lenhart of NEORSD mentioned that the sewage sludge pretreatment coordinators would be the most suitable and appropriate persons to be the POTW contact persons for the survey. Bob Bastian mentioned that we need to document criteria the basis for our choice of the POTWs selected for the survey. Bob then committed to take the lead on this action item.
Behram Shroff and Phyllis Sobel then gave an update of the status of NRC and EPA technical assistance contract support for the project. Behram reported that TECHLAW, the EPA contractor will be able to start work on the project by February 11,1999. Phyllis Sobel and Lee Abramson informed the Subcommittee that the funding for the LANL contract to support the survey project had been restored and LANL is back on board. Lee Abramson said that LANL will not be responsible for sending out the questionnaires to the POTWs chosen for the national survey, but will only work on compiling and organizing the responses to the questionnaires and the information generated by the project from then on into their data base. Mark Doehnert commented that the criteria and basis for choosing the POTWs for the national survey should be documented in the LANL data base. Bob Bastian said that we are still receiving States responses to the NRC/ EPA letters to them. These responses which provide lists of candidate POTWs, and comments on the survey design and the Guidance Document will still keep coming at least until the end of January 1999. Bob said that he will need to compile a fulllist of names und addresses based on the recommendations in the responses. Based on these considerations, he may be able to send out the questionnaires to the POTWs chosen by the end of March 1999.
The status of the QAPP was covered next. Phyllis Sobel said that NRC has had problems in receiving the revised QAPP electronically and that Mary Wisdom may need to identify the additionalinput and information she needs from the Subcommittee. Dave Saunders from NAREL said that Mary Wisdom had been trying to print out a hard copy of the revised QAPP for Subcommittee review but was having problems with the printers at NAREL and also with the date of the document due to the year 2000 testing. Dave said that Mary will try to send out, if possible, both the electronic and the hard copies of the QAPP to all Subcommittee members by the close of business on January 19,1999 (i.e. by the afternoon of the day the meeting was held). Bob Bastion said that this will be carried over as an action item for Mary and NAREL to make sure that it is done before the next Subcommittee meeting in February 1999.
Dale Hoffmeyer was then requested to brief the Subcommittee on the work activities, progress made and the current status of the efforts of the Dose Modeling Workgroup. Dale reported that the Work Group had a teleconference on December 17,1999 and that he had also distributed drafts of the QAPP and the project plans for the dose modeling work. He expected some feedback on these documents from the other Work Group members during the Work Group meeting in the aftemoon. He said that EPA's contractor, TECHLAW will be assisting him in the Dose Modeling work and that he will discuss with TECHLAW staff about how they will assist him on the dose modeling work. Dale also told the Subcommittee that he, Alan Rubin, and Bob Ba.stian from EPA will be attending the Water Environment Federation (WEF) Conference to be held in Charlotte, North Carolina during the last week of January 1999. He said that they will try to interact with the W-170 Subcommittee of WEF to consider the possibility of W-170
4 Subcommittee serving as a review body for the dose modeling work that will be performed for the full survey. The W-170 Subcommittee is made up of soil scientists who were heavily involved in developing the technical basis and important input parameters for the risk assessment behind EPA's Bio =olid Rule,40 CFR Part 503, such as distribution coefficients, Kd's for uptake of heavy toxic metals by plants grown in soils where sewage sludge was applied.
Dale said he will brief WEF and the W-170 Subcommittee about our approaches, plans and efforts of the dose modeling work group.
Dale reported that he had been reviewing the background information on the risk assessment performed for the 40 CFR Part 503 rulemaking effort with the hope of adapting the approaches, and methodology for use in modeling the potential risks from radionuclides present in sewage sludge. Dale mentioned that he is looking at different scenarios used for the 40 CFR part 503 rulemaking and said that extemal radiation exposure to people may well be the most significant radiation dose contributor and will have to be evaluated in our dose modeling work. Tin Mo asked Dale if the direct radiation exposure pathways is for workers at the treatment plant or et the site where the sludge is applied to the land as fertilizer for agricultural purposes. We also discussed considering the ingestion of crops grown on land where sewage sludge had been applied. We were thinking about the residential or home gardener for this food crop ingestion scenario for dose assessment. Children's ingestion of soil contaminated with radionuclides from sewage sludge applied to the land would appear to be the most restrictive or critical radiation exposure pathway.
Topics related to the May 1997 version of the Federal Guidance document were then discussed by Phyllis Sobel, Bob Bastian, Jim Bachmaier, and Behram Shroff. Phyllis said that she had compiled a set of comments to be responded to by NRC. Behram Schroff said that all the agencies involved need to sit down and look at the comments and decide which ones should be addressed in the Guidance document by revising the document and which to document separately based on their level of significance. He suggested that the Subcommittee compile a list of comments identifying the commenters and the agency responses (some of which may not be appropriate for inclusion in the TECHLAWs revised version of the document). He also mentioned about the desirability of writing a general response to comments document which discusses how the individual comments were addressed and resolved. Behram and Phyllis also discussed how to respond to the comments which specifically apply to each agency. Bob Bastian feels that there are no major issues where the agencies disagree, although the lawyers of each agency probably need to get together to sort out the respective authorities and jurisdictions of the agencies. He felt that we should attempt to have responses ready one week before the February 1999 Subcommittee meeting to facilitate reviews by the Subcommittee members at that meeting. Jim Bachmaier wondered which version of the Guidance document, the May 1997 or the September 1998 (Revision 1), the Federal agencies should be reviewing at the same time. TECHLAWwill address and resolve the Agency comments from the December 1998 Agency review. Phyllis told the Subcommittee that the Guidance document will not be finalized till after the full survey is completed and then it will be published in the Federal Register Notice for public comment - which she estimated will be in about 2 years. Phyllis then went over the schedule and GANNT chart for completion of the Guidance document. Phyllis, Bob and Behram then discussed in detail how the comments will be addressed and the guidance document will be revised by TECHLAW.
5-The last topic on the agenda was the AMSA Draft Guidance and AMSA/WEF letter. Tom Lenhart reported that the draft AMSA Guidance document which incorporated comments from the Federal agencies was sent to the AMSA pretreatment coordinators group for review. He thinks that the POTWs will not cooperate or participate in the survey unless they know what radionuclides are in their systems. He felt that the AMSA Guidance is nearly complete and that he will try to finalize it with AMSA members at the WEF Conference in Charlotte, North Carolina during the last week of January 1999.
As far as the National survey is concerned, Tom Lenhart said that AMSA management's previous reaction to his recommendation to participate was negative. Bob Bastian countered this by saying that individual POTWs such as the one in Milwaukee were very interested and enthusiastic about participation in the survey. According to Tom, AMSA's recommendation was that individual POTWs should assay their sewage sludge, ash, and other parts of their process and effluent streams before hand to find out what they have in their systems before they decide to participate in the survey. Some Subcommittee members, including Jim Bachmaier of DOE, remarked that the liability of the POTWs will be there no matter whether significant radionuclide concentration is observed during the POTWs own assay for radionuclides in their sewage sludge process or effluent streams, or during the Federal Agencies joint National radiological survey and assays of similar samples. Tom Lenhart does not agree with NRC suggestions that NRC and POTWs should have joint inspections of NRC licensees' facility that have the potential to discharge radionuclides into their sewers that might reconcentrate !n the sewage sludge process and effluent streams. He told the Subcommittee that under the EPA's Clean Water Act, POTWs have authority to inspect radionuclide generators on their own. In response to Phyllis's question on the existence of POTWs limits on exposures to radionuclides in sewage process and effluent streams, Tom said that these limits exist. He said that NEORSD's contractor developed them and wrote the guidance document for these limits. The next meeting of the Subcommittee was scheduled to be held from 9:00 a.m. to noon on Tuesday, February 16,1999 at the DOE Forrestal Building in Washington, D.C. The next meeting of the dose modeling working group was scheduled to take place from 1:00 p.m. to 4:00 p.m. also on Tuesday, February 16,1999 at the DOE Forrestal building.
T l'
i Action Items:
- 1. Reference Radionuclide Tables 1 and 2 for the Public Document to be completed with NAREL/ORISE prior to the Subcommittee meeting on February 16,1999 ( Mo, Bachmaier).
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- 2. Recirculate to the Subcommittee for revi-ew the current version of the A.P. identifying I
information still needed for updating effort (Wisdom).
- 3. Compile comments on TACKLE's Draft Guidance Document (Bastian, Shroff).
- 4. EPA complete responses to public comments on the May '97 Guidance Document by February 9,1999 (Schroff).
- 5. Provide comments on draft AMSA Guidance Document to T. Lenhart by February 20,1999 (All).
- 6. At the WEF meeting in Charlotte, North Carolina, attempt to get as positive a letter out of AMSA as possible conceming the National sewer survey (Lenhart, Bastian).
- 7. Subcommittee input to the ISCORS Annual Report (Bastian, Mo).
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- 9. Continue working on compilation of comments from the States on the survey and the l
Guidance Document (Sobel).
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ISCORS Sewage Subcommittee Distribution:
U.S. Environmental Protection Agency U.S. Nuclear Regulatory Commission ATTN: Robert Bastian ATTN: Tin Mo Office of Wastewater Management (4204)
Mail Stop T-9C24 401 M Street, S.W.
Rockville, MD 20555-0001 Washington, DC 20460 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission ATTN: Phyllis Sobel ATTN: Duane W. Schmidt Mail Stop. T-7F27 Mail Stop. T-7F27 Rockville, MD 20555-0001 Rockville, MD 20555-0001 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission ATTN: Robert Nelson ATTN: Lee Abramson Mail Stop. T-7F27 Mail Stop T-10E50 Rockville, MD 20555-0001 Rockville, MD 20555-0001 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission ATTN: Tom O'Brien ATTN: George Powers Mail Stop O-3C10 Mail Stop T-9C24 Rockville, MD 20555-0001 Rockville, MD 20555-0001 U.S. Environmental Protection Agency U.S. Environmental Protection Agency ATTN: Loren Setlow ATTN: Behram Shroff 401 M Street, S.W. - ORIA (6602J) 401 M Street, S.W. - ORIA (6602J)
Washington, DC 20460 Washington, DC 20460 U.S. Environmental Protection Agency U.S. Environmental Protection Agency ATTN: Deborah Kopsick ATTN: Mark Doehnert
-401 M Street, S.W. - ORIA (6602J) 401 M Street, S.W. - ORIA (6602J)
Washington, DC 20460 Washington, DC 20460 Roy Lovett U.S. Environmental Protection Agency Directorate for Safety and Engineering ATTN: Alan Rubin ATTN: MCHO-SHE 401 M Street, S.W. - OST (4304)
Building 1500. Ft. Detrick Washington, DC 20460 Frederick, MD 21702
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U.S. Department of Energy NJ Dept. of Environmental Protection ATTN: James Bachmaier ATTN: Dr. Jill Lipoti, Assistant Director for Mail Stop EH-412 Radiation Protection Programs 1000 Independence Avenue, S.W.
Division of Environmental Safety, Health Washington, DC 20585 and Analytical Programs - CN 415 Trenton, NJ 08625-0415 Oak Ridge Inst. for Science and Education U.S. Environmental Protection ATTN: Dale Condra Agency /NAREL P.O. Box 117 ATIN: Dave Saunders Oak Ridge, TN 37831-0117 540 South Morris Avenue Montgomery, AL 36116 U.S. Environmental Protection U.S. Environmental Protection Agency /F%REL Agency /NAREL ATTN: Mary Wisdom ATTN: Scott Telofski 540 South Morris Avenue 540 South Morris Avenue Montgomery, AL 36116 Montgomery, AL 36116 NE Ohio Regional Sewer District Middlesex County Utilities Authority ATTN: Thomas E. Lenhart ATTN: Kevin Aiello 3826 Euclid Avenue P.O. Box 159 Cleveland, OH 44115-2504 Sayreville, NJ 08872 i
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