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w- , , ,. .. - . .- - - -. - t 1 (... hs.- f'R|: " ! . ' $ tate of )Tefa 3erseg : Robert C. Shinn, Jr. ! jChristine Todd Whitman: Department of Environmental Protection ' % ;icovernor: Division of Mater Quality commissioner 401 E. State Street . CN 029 : Trenton, NJ 08625 , . - ; . 1 4 ; , February 3, 1995 . 3 c.n - Richard L. Bangart, Director M , Office ~of State Programs m ! ' U.S. Nuclear Regulatory Commission- dc ATTN Document Control Desk C4 ' Washington, D.C. 20555-0001 $7 f SD- | Michael B.' Cook, Director .y~ ' Office of Wastewater. Management m U.S. Environmental Protection Agency i Washington, D.C. 20460 ; I Dear Mr. Bangart and Mr. Cook | . ! This is in response.to your letter of October.11, 1994 regarding ! _possible reconcentration of radionuclides in. sanitary sewer 7 systems. We:have reviewed'the information that you sent and.wish to -comment and seek further guidance. ; In your letter, you state that there.are approximately 1100 NRC materials licensees -in the nation that have the potential to discharge radioactive materials. You. forther state ' that some of .these licensees hold their . liquid * radio ~ active effluent for ' decay before discharge to the sewer. Although ' we have copies of all- i Nuclear Regulatory Commission (NRC) licenses for facilities in New ; Jersey, specific waste management practices are not denoted on the : . license. Since ' the NRC approves licenses and inspects licensees, .you are much more familiar with the waste practices- of each- , . licensee. ' Therefore,' we ask that you provide | a. list of~ the , licensees in New Jersey with the potential to discharge radioactive . New}ersey in an Equal Opportursty Enployer -990s1303sa ssosos saye:asrara PDR- STPRO N . .-. 9DR.~ . _ . _. - _ _ _ __ _ _ . _ _ . _ ._ _ __ _ _ _ . .. _._ . 4 - . .a . ; - -2- : materials ' to sewers, and the name of the affected ' POTW where' known, , .and further note which of these' hold their effluent for decay. This ! will . enable us to target our = outreach efforts to those sewage , -treatment plants with the potential to reconcentrate radionuclides. ! | You _have requested- that- we assist you in disseminating | information to appropriate sewage treatment plants., 'As. the | information package which was sent to us is quite extensive, _ we ! would appreciate a summary of exactly what actions you expect sewage ! treatment plant operators to given take the evidence of _ _i reconcentration. taking place in. a number of. facilities. ' Specifically, where would you recommend samples be takent. ~ Bow many samples-- should be taken? What analyses should be performed? What ! 'are acceptable analytical methods? What laboratories meet your i quality assurance standardat What criteria should sample results be i * evaluated against! : , Sample handling and preparation for analysis are especially | important. You admonish inspectors to review sample preparation, i counting, calibration, and calculation procedures. _ You even ask .j very specific questions such as "Are samples evenly dried? How are i counting efficiencies determined? Are self-absorption and | backscatter factors appropriately applied?" While we agree that these are extremely important to obtaining accurate results, the average sewage treatment plant operator will not be able to make | these determinations. Some simplified- guidance, or perhaps a list of individuals who are qualified to perform these tasks would be ; appreciated. ; 1 There are some very general sampling guidelines in a number of the attachments. We would appreciate more specific guidance, '| perhaps ' in the form of a flow chart, that would provide stepwise instructions for sampling. For example, if you expect sludge samples to be taken after anaerobic digestion in the sludge drying area, say so. While the NRC accepts single monthly grab samples for documentation of licensee discharge, there was no guidance in the ' package about the number and frequency of sampling that would be considered sufficient to determine whether radionuclide reconcentration was occurring at' a particular' wastewater treatment plant. It is our understanding from discussions with licensees that since low-level radioactive waste can no longer be disposed of out of state, they are proceding to dispose o'f all allowable radioactive materials down the sanitary sewer, up to the limits in 10 CFR 20. Since those limits are annual limitG sewer disposal could continue from, _ for example, January to August, when the limit is reached. From August to the end of December, the vaste might be collected on | site, or incinerated up to the air ' Limits in 10 CFR 20. Therefore, ' the timing of the sampling of the sludge would be an important parameter for taking a sample. i i | .! I - , . ..- - _.-_- - - . -. - _ . < - . t " -3- t ) 1 ! Obviously, it is extremely important to know what components you are looking for in the sample analysis. Certainly, the analysis ! - should be. performed for the radionuclides being discharged from the licensee, those cosmonly medically exempt, and those which are also naturally occurring. How will the sewage - tr4atment plant operator differentiate from . background? Also, since cell cultures, ground ; animal carcasses, and patient excreta are exempt, these could mask a ; discharge from a licensee. What procedures would you recommend to ! differentiate these discharges? Therefore, a complete listing of- radionuclides of concern for evaluation must be provided. | As a result of the Temporary Instruction 2800/9, inspections i were performed for two licensee discharges in New Jersey in 1986. The reports were forwarded to us on November 8, 1994. While the . discharge concentrations from Teledyne Isotopes were either well ' below the discharge limits from 10 CFR 20, or non-detectable, sludge sample #4 was above the 10 CRP 20 limits in Appendix B, Table 1, Column 2 for gross alpha. No attempt was made to ' isotopically analyze the sample to determine which specific radionuclides were in the sample. There was no discussion of the result in the report. No notification was made to the sewage treatment plant to take any actions to determine the cause of the elevated levels, or to test any of their workers who may have been exposed. The sludge was , ' - disposed of in the Atlantic Ocean. A copy of the report was provided to Steven Mizereck at the Bergen County Utility Authority, but there was no discussion of the possible implications of the elevated level, nor any follow-up guidance. In the testimony presented by Chairman Selin on June 21, 1994, j he stated that "the samples of sludge taken at the sewage treatment facilities showed either no radioactivity present, or radioactive materials present at concentrations that were well within the levels , that NRC staff would find acceptable." Since the levels are above |' the 10 CFR 20 limits used for comparison, what are the levels that NRC staff find acceptsble? Samples were also taken at Squibb in 1986 according to the : inspection report, "at a time when the licensee was not releasing liquid waste". These samples show gross alpha at 0.2% of the discharge concentration. Samples taken at the Middlesex County Utilities Authority show gross alpha levels in the sludge above the . 10 CFR '20 Appendix B, Table 1, Column 2 limits, albeit within the ' confidence limits of the sample. No isotopic analysis was done to determine which radionuclide was the major contributor to the level. There was no discussion in the report of the elevated levels , found in the sludge. A copy of the report was provided to Kevin T. | Aiello at the Middlesex County Utilities Authority, but there was no , discussion of the possible implications of the levels, nor any | follow-up guidance. ! ! ! | i i - - . - - _ . - . -- - , . .< . >g > .' *;,7 'I < 4 -4- - These inspection reports raise more questions than they answer. In' order that the New Jersey Department of Environmental Protection | does not add to the confusion .already aroused in 'the- sewage treatment plant | operators, a thorough scoping must be provided, so that who samples are taken and analyzed there is a plan for how to assess 'the J results and convey these results to the public . in an ' informative, non-threatening manner. i One very important point of comparison for the results of sewage , sludge analysis is.the standard for release of.the material - to an incinerator, a landfill, a composting facility, .or any ,other ' conceivable disposal outlet. Although the sludge analysis results in the inspection reports were compared to the limits'in 10 CFR 20, ,. j that really is not applicable to anyone except an NRC licensee. i Therefore the question remains, ' what release criteria .'should be .f used? We know the NRC. is developing- decontamination and | decommissioning standards for its licensees. Should these be the | applicable standards? The need for sludge use and disposal j practices akin to those promulgated in 40 CFR 503 must be evaluated. with regard to radionuclides. : Despite the fact that exposure levels to workers would be ! expected to be below _ a measurable dose, and indistinguishable from | background, a' question that will immediately be raised by the sewage treatment plant operators is concerti for their health. Since these are not badged radiation workers, is the limit for exposure the same ' as for the general public, even though it is an exposure which is a ! consequence of employment? Since the workers in the Tonawanda , facility in New York and the-Southerly plant in Ohio received whole .

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