RADIOACTIVE MATERIAL IN SLUDGE BIOSOLIDS



Please note:   reponsibility for determining quantities and sources of radioactive wastes dumped into public sewers
rests with the local sewage treatment plant authorities

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NATIONAL BIOSOLIDS PARTNERSHIP - CHARACTERIZATION OF RADIOACTIVITY SOURCES AT WASTEWATER
TREATMENT FACILITIES

A Guidance Document for pretreatment Coordinators & Biosolids Managers

http://www.amsa-cleanwater.org/pubs/radioactivity/guidance.pdf

Prepared by:  The National Biosolids Partnership
Association of Metropolitan Sewerage Agencies
Water Environment Federation
US Environmental protection Agency

National Biosolids partnership Report No. 1 - May 1999

EXCERPTS

Page 1 - Overview:

“Since all municipal solids will contain some NORM (naturally occurring radioactive material), and will therefore be
naturally radioactive, there is a section on evaluating your results to determine if there is an elevated level of
radioactivity.”

“If some control action is desirable, information is provided on what actions can be taken to limit discharges and the
legal authority for those actions.    In addition, information is presented on conducting inspections of discharges of
radioactive materials, radiological surveys, sampling of biosolids, and monitoring.   Finally, there is information to help
the POTW to  communicate with the public and employees about radioactivity.”

Page 2 - LOCATING THE DISCHARGERS

“NORM is present everywhere .....NORM has not generally been a problem ... in biosolids, as was illustrated by the
AMSA radiation survey conducted in 1995.   ..... For these reasons, this guidance will focus on the discharge of man-
made radioactive material.”

“Several agencies have jurisdiction over the use of radioactive materials, and the discharge of radioactive wastes.    
MOST OF THESE AGENCIES ALLOW THE REGULATED COMMUNITY OR LICENSEE TO LEGALLY DISCHARGE
RADIOACTIVE MATERIAL TO THE SEWER WITHOUT NOTICE TO ANYONE, INCLUDING THE RECEIVING POTW OR
THE REGULATOR.”

“While in most cases there are no requirements for the discharger to report such discharges, detailed discharge
records are maintained by each NRC licensee, and records may be obtained by NRC as necessary.   THE DETAILED
RECORDS ARE NOT NORMALLY COLLECTED BY THE NRC, NOR ARE LICENSEES REQUIRED TO SUBMIT THESE
RECORDS TO NRC.”

..... even in “Agreement States” .... NUCLEAR POWER PLANTS and facilities in the fuel cycle REMAIN UNDER NRC
JURISDICTION.

Page 3 - “Certain materials THAT ARE REACTOR PRODUCED (such as Iodine 131), are regulated by the NRC.”

(Helane’s NOTE:  Iodine-131 was one of the radionuclides on which they had NUMEROUS HITS in the
sewage sludge and ash in the EPA’s 9-site survey.)

“It is usually possible to obtain a list of licensees from the NRC or state radiation departments.”

“If the information is not readily available (from the NRC), the POTW MANAGEMENT SHOULD FILE THE
REQUEST IN THE FORM OF A FREEDOM OF INFORMATION ACT (FOIA) REQUEST to ensure that all of the
necessary information is forthcoming.”  !!

“While the same information may be acquired more quickly if the request is not structured as a FOIA, THE
NRC IS NOT UNDER A LEGAL OBLIGATION TO PROVIDE ALL REQUESTED PUBLIC DOCUMENTS UNLESS THE
REQUEST IS MADE UNDER FOIA.”

Page 4 - “For POTWs in major metropolitan areas, there may be hundreds of licensees in the service area.”

“A complete review of all licenses and/or site visits to facilities will allow you to estimate the degree of risk from each
facility.     WHILE INVESTIGATION OF EACH LICENSEES MAY ULTIMATELY BE DESIRABLE, it is probably not
necessary.    PRIVATE RADIATION CONSULTANTS CAN HELP DETERMINE WHICH FACILITIES SHOULD RECEIVE
YOUR PRIORITY ATTENTION.        “

“A very large percentage of POTWs most likely will be able to conclude after a review of the radioactive materials users
within its collection system that there is a very low potential for radioactive contamination of biosolids from man-made
material.  THE POTW CONTAMINATION SITUATIONS TO DATE HAVE ALL BEEN TIED BACK TO DISCHARGES FROM
PARTICULAR LICENSEES OR FACILITIES.”

Page 5 - INSPECTING A RADIOACTIVE MATERIALS DISCHARGER

“Prior to visiting the facility, all available records should be reviewed and the licensee should be contacted.”

“ALSO, ANY SPECIAL CONDITIONS REGARDING DISPOSAL OF RADIOACTIVE WASTE SHOULD BE NOTED,
CONSIDERING THAT ALL DISCHARGERS MAY DISCHARGE UP TO ONE FULL CURIE PER YEAR AS WELL AS 5 Ci
OF TRITIUM AND 2 Ci OF CARBON-14, REGARDLESS OF WHETHER SANITARY DISPOSAL IS SPECIFICALLY
ADDRESSED IN THE FACILITY’S LICENSE.”

Page 6 - “After becoming familiar with the facility and its operations, all the steps of a normal initial inspection should be
conducted.    Items should include a review of RAW MATERIAL PURCHASES (INCLUDING RADIOACTIVE MATERIALS),
materials used, inventories, waste products (liquid, air filters, solids, etc.), waste manifests, and radioactive materials
handling policies and procedures.   IDEALLY, IT WOULD BE PRUDENT TO DETERMINE ALL POINTS FROM WHICH
RADIOACTIVE MATERIALS ARE INTENTIONALLY DISCHARGED TO THE SEWER, TO REVIEW THE LOG OF ALL
SUCH DISCHARGES, AND TO INSPECT AND/OR OBTAIN A SAMPLE FOR LABORATORY ANALYSIS FROM ALL
SUCH POINTS.”

“If a radiation survey exposure meter is available ... all possible points of discharge, both those identified as such by
the facility and those which are not authorized discharge points should be surveyed.   For example, elevated
radioactivity readings in the trap in the restroom  -- most likely an unauthorized discharge point -- is an excellent
indicating that the facility discharge log MAY NOT BE AN ACCURATE RECORD  OF ALL THAT HAS ENTERED THE
SEWER.”  

“If access is possible, lateral connection lines, outfalls and the downstream sewer should be surveyed.   Roof drains,
parking lot drains, loading dock drains, and all spots where it appears material could accumulate from either improper
dumping or poor housekeeping should be checked.”  

(Helane’s NOTE:  One would have to be incredibly gullible to believe local sewage treatment plants are
undertaking all the foregoing investigations with regard to radioactive discharges to public sewers ! )

Page 8 - SURVEY AND SAMPLING OF THE POTW FOR RADIOACTIVITY

“If it is determined that significant amounts of man-made radioactive materials (or NORM from point sources) are being
discharged into the collection system, surveying and sampling the plant will help determine what impact, if any, SUCH
DISCHARGES ARE HAVING ON THE PLANT AND ITS BIOSOLIDS.    IT IS RECOMMENDED, HOWEVER, THAT PRIOR
TO SENDING ANY SAMPLES FOR LABORATORY ANALYSIS, EXPOSURE MONITORING SHOULD BE CONDUCTED
AS A QUICK SCREENING TOOL.”

“If the direct exposure rate inside the plant is above these background rates, additional measures should be
implemented to limit the amount of radioactive material entering the collection system.”   “Laboratory analysis of the
biosolids will determine the specific radionuclides present and their concentrations.”

Page 9 - “WHILE SUCH INFORMATION WILL ASSIST IN DETERMINING THE SOURCE OF THE ELEVATED EXPOSURE
RATE READINGS, THE LABORATORY RESULTS MAY ALSO HAVE SIGNIFICANT LEGAL AND PUBLIC RELATIONS
IMPLICATIONS THAT SHOULD BE CAREFULLY CONSIDERED IN ADVANCE
THAT IS, PRIOR TO SENDING ANY SAMPLES TO A LABORATORY, THE POTW SHOULD HAVE A COMMUNICATIONS
PLAN FOR HANDLING THE RESULTS.”

Pages 9 and 10 deal with EXTERNAL EXPOSURE MONITORING ..... use of exposure/dose rate meters and
thermoluminescent dosimeters ....background radiation levels should be obtained from POTW locations similar to areas
of the POTW to be surveyed but which are unlikely to be potentially contaminated ....

typical natural background exposure rates for unrestricted use are:

5 microRem/hr above background at 3 feet for buildings/structure

10 microRem/hr above average (20 microREM/hr above background maximum) at 3 feet above ground for open land

Page 11 - CONTAMINATION MONITORING

“Radiation contamination surveys are performed to minimize the spread of contamination and to reduce the potential
for external exposure.   A SURVEY OF THIS TYPE IS ALSO APPROPRIATE FOR PERSONNEL WORKING IN AN AREA
WHERE THERE MAY BE REASON TO SUSPECT LOOSE CONTAMINATION, SUCH AS IN A SEWER AT THE OUTFALL
OF A MAJOR DISCHARGER OF RADIOACTIVE WASTE.”

“If it is determined that sampling of biosolids should be conducted (because contamination has been detected or
contamination is suspected), a carefully developed sampling program should be implemented.   Sampling and analysis
of biosolids may be costly ....”

Page 14 - IMPORTANT CONSIDERATIONS IN RADIOLOGICAL SURVEYING SAMPLING ....  proper operation of survey
instrumentation and training of personnel.

“POTW personnel require only a limited amount of basic training on the instrumentation to conduct surveys for
screening purposes only.    However, if this screening activity detects elevated readings, a more complete analysis
should be conducted by a radiological consultant.”

SURVEY AND SAMPLING LOCATIONS

“If incineration is not performed, exposure rate measurements SHOULD BE OBTAINED AT THE FINAL STAGES OF
THE BIOSOLIDS HANDLING PROCESS, WHERE RADIONUCLIDES ARE MOST HIGHLY CONCENTRATED.”

Page 15 - EXISTING CRITERIA

“Currently, no criteria exist for radionuclides that are directly applicable to water residuals, although some states have
effluent criteria.   It is highly unlikely that a POTW would have a problem meeting effluent criteria, due to the
TREMENDOUS DILUTION THAT OCCURS IN THE WET STREAM.     HOWEVER, THERE IS SUBSTANTIAL EVIDENCE
THAT CERTAIN RADIONUCLIDES, WHICH BEHAVE LIKE OTHER HEAVY METALS, CAN ACCUMULATE IN THE
SOLIDS.”

“In the prior incidents where elevated levels of radionuclides were discovered in POTW solids, the NRC (or Agreement
State) reviewed its existing criteria for radionuclide soil concentrations.    Specifically, THEY REVIEWED GUIDANCE
DOCUMENTS THAT SET ACCEPTABLE LEVELS IN THE SOIL FOR FACILITIES UNDERGOING DECOMMISSIONING
PRIOR TO BEING RELEASED FROM LICENSE CONDITIONS.” !!

(Helane’s NOTE:  NUCLEAR BROWNFIELDS BEING USED AS SOIL STANDARDS FOR AGRICULTURAL
APPLICATIONS OF “HOT” SLUDGE ??)

 “Depending on how biosolids are used or disposed, the soil concentration criteria may also be conservative if applied
to samples collected at the plant.  FOR EXAMPLE, THERE MAY BE A GREAT AMOUNT OF DILUTION IF BIOSOLIDS
ARE LAND APPLIED AND DISKED INTO THE SOIL.    DIRECTLY APPLYING THE SOIL CONCENTRATION CRITERIA
TO BIOSOLIDS COLLECTED AT THE PLANT DOES NOT TAKE THIS DILUTION INTO ACCOUNT.”

Page 17 - ELEVATED CONCENTRATIONS

“Most situations of significantly elevated radionuclides can be prevented if POTWs have identified the users of
radioactive materials in their collection systems and have controlled their discharges as deemed appropriate.    
However, it is possible that some POTWs could still find during their internal analysis that the radiation levels in their
solids are significantly above those of other POTWs.”

    “As previously stated, there are         NO LEGALLY ENFORCEABLE LIMITS OR GUIDANCE CRITERIA THAT
DIRECTLY APPLY TO THIS SITUATION.    EACH PRIOR DISCOVERY OF ELEVATED LEVELS HAS BEEN
ADDRESSED ON A CASE-BY-CASE BASIS BY THE POTW, THE APPROPRIATE REGULATORY AUTHORITY, AND
USUALLY THE DISCHARGER OF THE MATERIAL.”

    “Because the burden of dealing with elevated radiation levels  WILL FALL PRIMARILY ON THE POTW, the first
priority should center on POSSIBLE EXPOSURES OF PLANT WORKERS AND MEMBERS OF THE PUBLIC.

“The next priority .... is to determine the SOURCE OF THE CONTAMINATION ...”
“Once again,  the NRC or state agency MIGHT BE OF SOME HELP IN LOCATING THIS FACILITY AND DETERMINING
WHETHER THE DISCHARGES HAVE VIOLATED ANY APPLICABLE REQUIREMENTS.”

(Helane’s NOTE:  They “might be” of some help to determine if there has been a violation of “ .... no legally
enforceable limits or guidance criteria ....” ????????)

Page 19 - REGULATION OF RADIATION

“The NRC regulations set limits on how much radioactive material may be discharged to a sewer in one month or over
the course of a year by NRC licensees.  

“Following publicity REGARDING CONTAMINATION AT A FEW POTWs, NRC recently added requirements THAT ALL
RADIOACTIVE MATERIALS DISCHARGED TO THE SEWER MUST BE READILY SOLUBLE (OR BE READILY
DISPERSABLE BIOLOGICAL MATERIAL) IN WATER.”

Helane’s NOTE:  I can’t believe I just read that !!

“NO PERMIT TO DISCHARGE IS REQUIRED, as long as wastes do not fall outside the NRC limits.   SOME LICENSEES
HAVE SPECIAL LICENSE CONDITIONS, HOWEVER, WHICH AUTHORIZE THEM TO EXCEED THE DISCHARGES THAT
ARE OTHERWISE ALLOWABLE.”

“MANY LICENSEES CLAIM THAT NRC REGULATIONS PREEMPT OTHER REGULATIONS AND THAT NO ONE,
INCLUDING A POTW, CAN PREVENT THEM FROM DISCHARGING AS MUCH RADIOACTIVE WASTE AS THE NRC
ALLOWS.

“The case is not so simply however.

“The Clean Water Act provides VERY POWERFUL AUTHORITY TO A POTW in terms of protecting its operations and
facilities from interference.  When radioactive materials accumulate in biosolids or elsewhere in a plant, interference
may be created.

“For example, if accepting materials from a licensee causes your biosolids to exceed EPA or NRC limits, you could no
longer legal incinerate or land apply your solids.”

Helane’s NOTE:  WHAT EPA limits on radioactive sludge ??

“This type of interference with solids handling has provided the basis for successful INJUNCTIVE ACTIONS against a
would-be discharger in both State and Federal courts (The Licensee suspended all discharges and settled with the
POTW, so the legal arguments present HAVE NOT BEEN TESTED in an appeals court).

“Other arguable types of interference COULD BE POTW WORKERS REFUSAL TO ENTER ALL OR PART OF A
PLANT, NEGATIVE IMPACT ON BIOSOLIDS MARKETING, and increased handling/disposal costs.”

“NRC statements tend to support LIMITED LOCAL AUTHORITY of a POTW to regulate discharges.    The NRC has
stated that as long as the basis for local government action IS OTHER THAN HEALTH AND SAFETY CONCERNS
(WHICH IT RESERVES TO ITSELF), the local action is not preempted.”

Helane’s NOTE:   What, pray tell, would be the basis for local regulation if it was not health and safety
concerns?

Page 20 -

“NRC has also publically (sic)  stated that WHILE ITS REGULATIONS ALLOW USERS OF REGULATED MATERIALS
TO DISCHARGE TO SANITARY SEWERS, they do NOT compel a wastewater treatment operator TO ACCEPT THOSE
RADIOACTIVE MATERIALS.”

“That is, while the POTW CANNOT STATE TO THE LICENSEE ‘YOU CANNOT DISPOSE OF YOUR NUCLEAR
WASTES,’ it can indeed state, “You cannot discharge your wastes into our collection system.”

Page 21 - COMMUNICATION WITH THE PUBLIC AND POTW EMPLOYEES

“The issues related to communication of radiation matters with THE PUBLIC AT LARGE AND THE EMPLOYEES WITHIN
A POTW ARE PROBABLY MORE DELICATE THAN ALMOST ANY OTHER MATTER FACING POTWs.

The reason is almost transparent:  in almost every other area the messages that need to be conveyed are to inform an
audience generally uninformed about the topic.

“On the matter of radiation, however, there is widespread, almost pervasive, public misinformation.    Most of the
available information, however, comes from movies and television.   Thus there are great misapprehensions about the
physical risks from radiation.

“As with any communications plan, action taken regarding radiation must be coupled with a careful program describing
what needs to be done and why.  FACILITIES WITH LIMITED STAFF SUPPORT MIGHT CONSIDER CONTRACTING
WITH A PROFESSIONAL.  The up-front cost may be dwarfed by the benefits of employee trust, public understanding
and support.”

Helane’s NOTE:   Interpretation:  “Hire an EPA spin doctor experienced at confusing, dissembling and
prevaricating.  Hopefully us poor, dumb hicks-- who get all our information from “movies and television”--
will be sucked into believing you have nothing but our health and best interests at heart when you spread
your radioactive sludge on the crops growing our food supplies!!”

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IT WOULD APPEAR THAT AMSA DOES NOT WANT TO RELY SOLELY ON ITS
“GUIDANCE” DOCUMENT TO POTWs TO PROTECT THEM FROM LIABILITY IF AND WHEN THEY SPREAD
RADIOACTIVE SLUDGE ON THE LAND OF SOME UNSUSPECTING FARMER.

NOW THAT THE EPA’S 9-SITE SURVEY OF RADIOACTIVE SEWAGE SLUDGE/ASH IS COMPLETE, THEY PLAN TO
UNDERTAKE A 300 SITE SURVEY.

HERE IS WHAT AMSA HAS TO SAY;

(http://www.amsa-cleanwater.org/pubs/cleanwater/decjan97/amsavoices.htm)

“While safety and health issues do not warrant any reason for alarm, SHOULD ANY SLUDGE OR ASH BE LABELED
CONTAMINATED BY THE NRC, EFFECTED (sic) POTWs COULD FACE ENORMOUS FINANCIAL CONSEQUENCES
RELATED TO ITS DISPOSAL.

“FOR EXAMPLE, THE 40 ACRES OF CONTAMINATED ASH AT THE OHIO PLANT CONTINUES TO SIT IN A FENCED-
OFF AREA DUE TO THE PROHIBITIVE $1.5 BILLION PRICE TAG THAT GOES WITH DISPOSING OF IT.

“THE NATION’S ONLY LOW-LEVEL RADIOACTIVE WASTE DISPOSAL SITE IN BARNWELL, SOUTH CAROLINA
CHARGES $325 PER CUBIC FOOT.   

“POTWs ARE ALSO NATURALLY CONCERNED ABOUT THE SURVEY’S POTENTIAL NEGATIVE IMPACT ON THE
NATIONAL BENEFICIAL USE OF BIOSOLIDS PROGRAM.

“IT IS ESTIMATED THAT ONLY A SMALL PERCENTAGE OF THE 15,000 NRC OR STATE LICENSEES ACROSS THE
NATION ARE CAPABLE OF UNLEASHING UNSAFE LEVELS OF RADIATION INTO THE SEWER SYSTEM.    
HOWEVER, POTWs CANNOT DETERMINE THEIR EXACT LOCATIONS AND GAUGE WHAT LEVEL OF RISK EXISTS  
BECAUSE THE DETAILS OF NRC LICENSEES ARE NOT MADE AVAILABLE.”

Helane’s NOTE:   AMSA has it wrong.   There are 24,000 NRC and Agreement State Licensees discharging
into POTWs -- not “15,000” !

“ANOTHER KEY ISSUE FOR DISCUSSION, AND ONE WHICH AMSA WOULD LIKE RESOLUTION ON BEFORE NRC
AND EPA CONDUCTS THE SURVEY, IS WHETHER POTWS WOULD BE HELD LIABLE FOR ANY “UNSAFE LEVELS”
OF (RADIOACTIVE) MATERIAL WHICH SHOULD BE DISCOVERED.”

In other words ... don’t do the 300-site survey until member POTWs are taken off the hook for radioactive sludge!    

If the POTWs aren’t responsible for radioactive sludge, who is?   THE LANDOWNERS AND/OR FARMERS WHO
ALLOW THIS CONTAMINATED WASTE TO BE SPREAD ON THEIR PROPERTY AS “FERTILIZER” !