RE: Nuclear Laundry

["jskirk@mailexcite.com" <jskirk@excite.com>]

To my understanding, the NRC and EPA are planning to implement a national
survey to determine if additional regulations are needed to further restrict
discharges to sewers.  Plans for conducting this survey resulted from a
recommendation by the US General Accounting Office (GAO) report entitled
"Action Needed to Control Radioactive Contamination at Sewage Treatment
Plants" (GAO/RCED-94-133, May 1994).  The GAO questioned whether existing
regulations were sufficiently protective of public health and safety because
of an incident where radioactive contaminants were detected at elevated
concentrations at a Publicly Owned Treatment Works (POTWs) in the midwest.
The source was later  identified as a laundry facility that discharged to a
POTW in full compliance existing standards.

The NRC and EPA subsequently, published draft "Guidance for POTWs of
Radioactive Materials in Sewage/Sludge Ash" in May 1997.  This guidance
provided information to POTWs concerning the need for the national survey.
In addition, the guidance stated that the NRC or Agreement State would help
trace the origin of radioactive materials present in excess of threshold
concentrations.  The draft guidance included a blank table titled
"Concentration to Dose (or Risk) Conversion Factors for Radioactive
Materials in Sewage Sludge and Ash".  The table was left bank because the
dose/risk values had yet to be developed.  

The Health Physics Society, NEI and several licensees expressed concern that
once this guidance was formally issued to POTWs, values in the table (once
completed) would be used as the technical basis to restrict discharges to
sanitary sewers under local ordinances.  Several parties stated that the
draft guidance (and risk table); (1) would facilitate serving as a "back
door" regulation without providing opportunity for public comment, and (2)
inappropriately shifted the responsibility for developing radiation
protection standards from the NRC to local government by encouraging POTWs
to develop ordinances to further restrict sewage discharges. 

To my understanding, the national survey would involve collecting sewage
sludge samples at ~300 POTWs.  These data would be evaluated by the NRC/EPA
to determine if additional regulations would be required to protect workers
at POTWs or the public from land application of sewage sludge.  

I believe, the Office of Management and Budget approved funding for the
national survey last year.  

Scott Kirk, MS, CHP
jskirk@excite.com






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