SEPA
United States
Environmental Protection
Agency
United States
Nuclear Regulatory
Commission
EPA 832-R-99-900
May 1999
Joint NRC/EPA Sewage Sludge
Radiological Survey:
Survey Design And Test Site
Results
Sewage Subcommittee of the
Interagency Steering Committee on
Radiation Standards (ISCORS)
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Acknowledgments
This report, which presents the results of radioisotope analyses of sewage sludge and ash
samples from nine test sites as a trial test of the procedures planned for use in a survey of some
300 facilities across the country, was coordinated by the Sewage Subcommittee of the
Interagency Steering Committee on Radiation Standards (ISCORS). The document was based
primarily upon the detailed laboratory results on the samples reported to the Subcommittee by
the U.S. Environmental Protection Agency (EPA) National Air & Radiation Environmental
Laboratory (NAREL) in Montgomery, Alabama, and the U.S. Nuclear Regulatory Commission
(NRC) contract laboratory, the Oak Ridge Institute for Science & Education (ORISE) in Oak
Ridge, Tennessee.
Subcommittee members who participated in the planning and conduct of the nine test site
survey effort and/or preparation of this report included (listed alphabetically):
Lee Abramson, NRG/Office of Nuclear Regulatory Research
Kevin Aiello, Middlesex County Utilities Authority
Jim Bachmaier, Department of Energy
Bob Bastian, EPA/Office of Wastewater Management
Dale Condra, ORISE
Mark Doehnert, EPA/Office of Radiation and Indoor Air
Dale Hoffmeyer, EPA/Office of Radiation and Indoor Air
Tony Huffert, NRG/Office of Nuclear Material Safety and Safeguards
Tom Lenhart, Northeast Ohio Regional Sewer District
Jill Lipoti, State of New Jersey
Roy Lovett, Department of Defense
Tin Mo, NRC/Office of Nuclear Regulatory Research
Robert Neel, NRC/Office of Nuclear Material Safety and Safeguards
Bob Nelson, NRC/Office of Nuclear Material Safety and Safeguards
Tom O'Brien, NRC/Office of State Programs
George Powers, NRC/Office of Nuclear Regulatory Research
Charleen Raddatz, NRC/Office of the Executive Director for Operations
Alan Rubin, EPA/Office of Science Technology
Dave Saunders, EPA/NAREL
Duane Schmidt, NRC/Office of Nuclear Material Safety and Safeguards
Loren Setlow, EPA/Office of Radiation and Indoor Air
Behram Shroff, EPA/Office of Radiation and Indoor Air
Phyllis Sobel, NRC/Office of Nuclear Material Safety and Safeguards
Scott Telofski, EPA/NAREL
Mary Thomas, NRC/Office of Nuclear Regulatory Research
Mary Wisdom, EPA/NAREL
Photo courtesy of Water Environment Federation, Alexandria, Virginia.
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Table of Contents
Page
A. Summary 1
B. Background 2
C. Survey Design 4
D. Questionnaire Results for the Test Sites 8
E. Sample Analysis Results for the Test Sites 8
F. References 10
Appendices
A. Sewage Sludge Questionnaire
B. Radionuclides in Sewage Sludge and Ash at POTW Test Sites and Comparison
With Other Sources of Radioactivity
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DISCLAIMER
This document resulted from interagency discussions. The Interagency Steering Committee on
Radiation Standards Sewage Subcommittee is composed of representatives from the
Environmental Protection Agency, Nuclear Regulatory Commission, Department of Energy,
Department of Defense, State of New Jersey, the city of Cleveland and the county of Middlesex,
New Jersey. This document has not been approved by the respective agencies and does not
represent the official position of any participating agency at this time.
JOINT NRC/EPA SEWAGE SLUDGE RADIOLOGICAL SURVEY:
SURVEY DESIGN AND TEST SITE RESULTS
A. SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) and the U.S. Environmental Protection Agency
(EPA), through a subcommittee of the Interagency Steering Committee on Radiation Standards
(ISCORS), are sponsoring a joint survey to collect information concerning radioactive materials
in sewage sludge and ash from sewage treatment plants (referred to in the industry as publicly
owned treatment works (POTWs)). Sanitary sewer disposal of radioactive material and sludge
reconcentration became an issue in the 1980s with the discovery of elevated levels of
radioactive materials in sewage sludge/incinerator ash at several POTWs. Although neither the
NRC nor the Agreement States have seen further problems associated with POTW
reconcentration of radioactive materials since NRC's regulations were revised in 1991, NRC and
EPA are working together to conduct a survey of radioactive materials in sewage sludge and
ash from POTWs.
The objectives of this joint NRC/EPA sewage sludge/ash survey are to: (1) obtain data on the
levels of radioactive materials in sludge and ash at POTWs from across the country; (2)
estimate the extent to which radioactive contamination comes from either NRC/State licensees
or naturally-occurring radioactivity; and (3) support potential rulemaking decisions by NRC or
EPA, if necessitated by the survey results. However, because of the design limitations, the
survey alone may not be sufficient for rulemaking.
The intent is that the names of the POTWs will not be associated with the analysis results in
publicly available records and reports. The reason for the anonymous survey is to encourage
the cooperation of POTWs. However, if elevated levels of radioactive materials are detected
that are determined to be a potential health and safety concern, as determined by NRC, further
investigation will be conducted to determine the appropriate course of action.
The voluntary survey consists of two components - a questionnaire and a program to sample
and analyze sewage sludge and incinerator ash. Questionnaires will be sent to selected
POTWs associated with NRC and Agreement State licensees that have the greatest potential to
discharge radioactive materials in accordance with existing regulations and to POTWs in all
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areas of the country, including areas of relatively high background radioactivity. Using the
information from the questionnaires, NRC and EPA will identify approximately 300 POTWs to be
sampled. It is expected that it will take several months for both agencies to analyze the results
from the questionnaire and a year to complete the analysis of samples to be received from the
POTWs.
This report summarizes the results at nine POTW sites where the questionnaire methods and
sampling and analytical procedures were tested. The survey was refined based on the
experiences at the test cases and public comments on the survey. The results of the full survey
will be published as a joint NRC/EPA report for use by POTW operators, Federal agencies,
States, and local officials.
The sewage sludge/ash survey is being coordinated by a subcommittee of ISCORS, which was
formed in 1995 to coordinate resolution of interagency issues related to radiation protection.
The ISCORS Sewage Subcommittee is assisting NRC and EPA in the development of the
survey, including analysis procedures and the selection of facilities to sample.
**.
The NRC contractors and EPA's National Air and Radiation Environmental Laboratory (NAREL)
in Montgomery, Alabama, will analyze the sewage sludge and ash samples. These labs have
also assisted ISCORS with the survey design. For example, the labs collaborated to ensure that
the analytical laboratory procedures and quality assurance programs that both labs plan to use
will produce consistent, accurate, and reliable laboratory measurements.
NRC requested Office of Management and Budget (OMB) approval for this survey. Notices
were published in the Federal Register on January 6, 1997, and December 2, 1997, to solicit
public comments on the survey effort. This information request was approved by OMB
(clearance number 3150-0189), with an expiration date of June 30, 2001.
B. BACKGROUND
Federal Regulations
Specific amounts and concentrations of radioactive material are legally authorized to be
disposed into the sanitary sewage collection system by Federal and State regulations. In 1991,
NRC revised its sewer disposal criteria, partially in response to evidence that certain radioactive
materials were reconcentrating in sewage sludge or incinerator ash, The revised NRC
regulations further limited the radioactive materials that NRC licensees are allowed to discharge
to POTWs, which should preclude contamination at POTWs. The current NRC regulations in 10
CFR 20.2003 permit disposal of specific quantities of soluble material into a sanitary sewer.
NRC plans to use the survey information in assessing whether to apply further restrictions to the
licensed radioactive material that is being discharged to sanitary sewage collection systems.
The EPA standard for the use and disposal of sewage sludge (biosolids) in 40 CFR Part 503
does not include limits for radioactive material. POTW operators have requested that EPA
regulations address radioactive materials so POTWs would have a basis to restrict discharges
of radioactive materials to the sewage collection system. EPA plans to use the survey results to
evaluate the need to include limits on radioactive materials in biosolids standards.
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Sources of Radioactive Materials
One possible source of radioactive material entering a POTW involves naturally-occurring
sources such as groundwater, which can contain elevated levels of radioactive materials in
some parts of the U.S., as well as drinking water treatment residuals disposed of into the
sanitary sewage collection system. Another possible source is the authorized disposal by users
of radioactive materials (such as NRC and Agreement State licensees) of man-made radioactive
materials into the sanitary sewage collection system. The removal of contaminants by various
methods at POTWs, and the reduction of the volume of solids that contains these contaminants
(e.g. incineration of sludge), can cause reconcentration of radioactive materials in the treatment
facility's sewage sludge or ash.
Background information on the nature of radioactivity in sewage sludge can be found in reports
published by NRC in 1992 and 1994 entitled "Evaluation of Exposure Pathways to Man From
Disposal of Radioactive Materials Into Sanitary Sewer Systems" (NUREG/CR-5814) and
"Reconcentration of Radioactive Material Released to Sanitary Sewers in Accordance with 10
CFR 20" (NUREG/CR-6289), respectively. Another useful background document is a report
entitled "Radioactivity of Municipal Sludge" issued by EPA during the development of the first
round rulemaking of the 40 CFR Part 503 sewage sludge technical rule.
Congressional Interest
This survey responds, in part, to a recommendation in the General Accounting Office (GAO)
report, "Actions Needed to Control Radioactive Contamination at Sewage Treatment Plants,"
published in May 1994. The GAO report recommended that NRC determine the extent of
elevated levels of radioactive materials at POTWs and establish acceptable limits for radioactive
materials in sewage sludge and ash.
A joint House/Senate hearing was held in 1994 to officially release and address questions raised
in the GAO report. The hearing was stimulated by concerns associated with elevated levels of
radioactive materials in incinerator ash at a major sewage treatment plant in the Cleveland,
Ohio, area. The GAO stated that, over the past 20 years, NRC documented about a dozen
situations where elevated levels of radioactive materials were identified in sewage sludge or
sludge incinerator ash; but, there has been no national survey of radiation levels present in
sewage sludge or sludge incinerator ash to determine if this is a widespread problem.
At the time of the hearing, EPA was planning to conduct a second National Sewage Sludge
Survey (NSSS) to support its efforts to develop the second round of the 40 CFR Part 503
sewage sludge technical regulations. EPA's planned survey would have included the collection
of data on concentrations of radioactive materials in a representative sampling of POTW
sludges from across the country. (The first national survey conducted in the late 1980s did not
include analysis of radioactive material.)
Testimony presented by both NRC and EPA during the 1994 hearing noted that there was no
indication of a widespread problem in this area and the Cleveland incident appeared to be an
isolated incident. Based on limited information on radiation levels in sewage sludge and ash
across the country, it appeared that reconcentration of radioactive materials may have been
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associated with authorized insoluble industrial releases from both NRC and Agreement State
licensees, which was documented and used as a basis of the GAO report. These problems
occurred prior to the revision to NRC's regulations in 1991.
Industry Interest
In 1996, the Association of Metropolitan Sewerage Agencies (AMSA) conducted a confidential
voluntary survey of concentrations of radioactive materials in some of its members' POTW
sewage sludges and ashes. The objective was to develop a better estimate of the concentration
of radioactive materials in sewage sludges and sludge incinerator ashes. Samples from 55
wastewater plants in 17 States were supplied voluntarily and analyzed for radioactive materials.
These plants were distributed across the country and ranged in size from small to among the
largest POTWs. The most significant levels of radioactive material were the potassium and
radium isotopes, which are naturally-occurring radioactive materials. The restricted nature of
the AMSA survey limited its usefulness in assessing regional background levels of radioactive
materials or the effects of licensees that dispose of radioactive material into sanitary sewers.
Current Plans
EPA is not currently planning to move forward with a second NSSS. Based on EPA's plans and
the limitations of the AMSA survey, NRC and EPA decided to jointly fund a survey of POTW
sewage sludges and ash to assess the potential need for NRC and/or EPA rulemaking. The
survey information will also be referenced in a joint NRC/EPA guidance document for POTWs,
which is currently under development by the ISCORS Sewage Subcommittee. This guidance
would provide information to help POTW operators determine sources of radioactive materials at
POTWs, describe sampling and analysis procedures, and advise whether a response is needed
to the presence of radioactive material in sludge.
C. SURVEY DESIGN
The objectives of this joint NRC/EPA sewage sludge/ash survey are to: (1) obtain data on the
levels of radioactive materials in sludge and ash at POTWs from across the country; (2)
estimate the extent to which radioactive contamination comes from either NRC/State licensees
or naturally-occurring radioactivity; and (3) support potential rulemaking decisions by NRC or
EPA, if necessitated by the survey results. However, because of the design limitations, the
survey alone may not be sufficient for rulemaking. These limitations include: (1) it is a voluntary
survey, (2) a small number of samples are collected at each POTW, (3) the samples are
collected in a snapshot in time, and (4) the survey is biased to POTWs associated with facilities
with the greatest potential to discharge radionuclides and to POTWs in areas of higher
concentrations of naturally-occurring radioactive material (NORM). Therefore, the survey
results will not be a statistically valid representation of radionuclide levels in sludges nationwide.
The survey consists of two components - a questionnaire and a program to sample and analyze
sewage sludge and incinerator ash.
Development of the Questionnaire
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NRC and EPA developed a questionnaire (Appendix A) to request information from POTWs,
such as their sludge treatment processes and disposal practices. The questionnaire also
requests the zip codes for their collection systems so NRC can identify the licensees associated
with each POTW. NRC will request from each Agreement State a list of licensees for the zip
codes associated with each POTW. In 1996, the questionnaire was sent to nine test sites to
assess the questions and to obtain a better basis for estimating the actual cost (burden hours) to
the POTWs.
POTWs That Were Selected to Receive the Questionnaire
The survey was designed to measure radioactive materials in sewage sludge and ash at
POTWs across the United States (the 50 States, the District of Columbia, and Puerto Rico). To
maximize its effectiveness, the survey will focus on the POTWs associated with licensees with
the greatest potential to discharge radioactive material to the sanitary sewer and POTWs in
areas known to have high levels of naturally-occurring isotopes such as radium, thorium, and
uranium. With these objectives in mind, the list of POTWs to be sent the questionnaire was
developed as follows:
1. Select POTWs associated with NRC and Agreement State licensees that have
the greatest potential for discharge. NRC developed a list of licensees that have
the greatest potential for discharge, and EPA established a list of POTWs
associated with these licensees.
2. Select POTWs in areas known to have higher concentrations of NORM in ground
and surface water, or that are associated with facilities that may potentially
discharge NORM into the sewage collection system.
3. Include POTWs with incinerators because radioactive materials are expected to
be at higher concentrations in ash than in sludge. There are about 180 POTWs
with active incinerators. However, the number of POTWs with incinerators varies
from State to State, and if all the incinerators are sampled, some States will
include a disproportionately high number of samples. For these reasons, the
survey plans to sample no more than a few POTWs with incinerators in each
State.
4. Ensure that the POTWs on the list developed in Steps 1 and 2 are from all
geographic areas of the United States (Coastal Plain, Appalachians, etc.) to
reflect the regional differences in NORM. If the list developed in Steps 1 and 2
has only a few POTWs in any of the geographic areas, add POTWs from the 479
POTWs which responded to the questionnaire in the first EPA national survey,
which was conducted in the late 1980's. The list of POTWs from the 1980's
survey was chosen because it includes POTWs for various flow rates, percent
industrial flow, and use and disposal practices and is a group of nationally
representative POTWs.
5. Add POTWs requested by other ISCORS members and the States.
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6. Include a small group of POTWs with low potential for elevated radioactive
materials for comparison purposes.
NRG and EPA will jointly send the questionnaire to about 600 POTWs. The Association of
Metropolitan Sewerage Agencies and the Water Environment Federation will provide a letter to
be included with the questionnaire and will send a guidance document prepared by the National
Biosolids Partnership (1999) and regulatory alert to the POTWs preceding the mailing of the
questionnaires to help introduce the POTWs to the voluntary survey effort and provide
assistance in conducting radiation surveys of their treatment facilities and industrial contributors.
The POTWs will be requested to voluntarily complete and return the completed questionnaires
to NRC. NRC will then develop the list of licensees associated with each POTW from the zip
codes in their collection system and assign each POTW to a geographic area. This information
, will be entered into an electronic database so that NRC and EPA can select the POTWs to be
sampled. NRC will send letters to the POTWs that returned the questionnaire with lists of
licensees in their service area. NRC will also develop a sample return tracking system to follow
up on non-respondents.
Selection of POTWs for Sampling and Analysis
From the responses to the questionnaire, about 300 POTWs will be chosen for sampling and
analysis. Based on the responses to the questionnaires, the POTWs will be assigned to the
categories listed below. A number of POTWs will be sampled from each category. The actual
number of samples to be taken from each category will be determined based on the responses
to the questionnaire. It is the goal of this survey to obtain a representative number of POTWs
from each category during the course of the survey. It is recognized that some factors, such as
seasonality, may need to be studied further.
Type of NRC/Agreement State licensees that could dispose into the sewage collection
system
1. Academic
2. Medical
3. Manufacturing and Distribution
4. Research and Development
5. Other licensees
6. No licensees that discharge to the sewage collection system
Geographic area
1. Coastal Plain
2. Appalachians
3. North Central
4. Central
5. Rockies and Basin and Range
6. Colorado Plateau
7. California
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8. Pacific Northwest, Alaska, Hawaii
Sample Collection and Analysis
The sampling will take place over a one-year period. In areas of high NORM, sampling may be
adjusted during some seasons, because there may be seasonal effects to the concentrations of
NORMatPOTWs.
Each month, over a one-year period, NRC and EPA will jointly send the NRC contractor a list of
the POTWs to be sent letters and sample collection materials. The NRC contractor will contact
the POTW operators to review the sampling instructions and then mail the letters and sample
collection packages to the POTWs. Since POTWs routinely take representative sludge and ash
samples to monitor pollutants, the POTWs will use similar procedures to collect samples for this
survey. The POTWs will return their samples to the NRC contractor who will assign a code to
each POTW to ensure confidentiality.
It is assumed that each POTW win, on average, send two samples of processed sludges and/or
ashes, so the total number of samples collected from all POTWs participating in the survey will
be about 600. It is expected that each laboratory will analyze about 300 samples.
The physical sampling and analysis procedure that will be used in this survey is described in the
Quality Assurance Project Plan for this project. All analyses will be performed using methods
typically used for environmental monitoring samples. All the samples will receive gamma
spectroscopy, gross alpha, and gross beta analyses. The gross alpha and beta analyses are
considered screening analyses. To use resources most efficiently, additional isotope-specific
analyses will only be performed on samples with the highest expected concentrations of the
isotopes. Each month about ten percent of the samples (about 2 or 3 samples at each lab) will
receive additional isotope-specific alpha or beta analysis; the action level for this additional
analysis will be chosen based on the highest observed gross alpha and gross beta results from
the survey samples analyzed that month.
Additional isotope-specific analysis will be conducted for the following radioactive materials:
beta emitters: strontiunn-89/90, carbon-14, hydrogen-3 (tritium)
alpha emitters: radium-226, thorium-227/228/230/232, uranium-234/235/238,
piutonium-238/239
Radium, thorium and uranium are naturally-occurring radioactive materials. Uranium and
Plutonium are also found in the effluents from processes in nuclear facilities that are used to
produce nuclear fuel for research or power reactors. Strontium is a medical isotope. Plutonium
will be analyzed only for POTWs with fuel-cycle or weapons research and development facilities
in the collection system. Carbon-14 is both naturally occurring and man-made and is
discharged by radiopharmaceutical and research facilities. Tritium is discharged by academic,
manufacturing, and weapons research and development facilities.
During the survey, the laboratories will send the analysis results to the ISCORS Sewage
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Subcommittee in individual monthly letter reports that discuss the samples analyzed that month
and report any lab or field problems. The reviews of these monthly letter reports could lead to
changes in the analysis procedures or in the selection of POTWs to be sampled.
An NRC contractor will enter the sample analysis results into an electronic data base and
analyze the results. The ISCORS Sewage Subcommittee has formed a working group to
perform dose modeling studies to help evaluate the potential risks associated with the
radioactive materials measured in the survey. At the conclusion of the sample analyses, the
laboratories will report: their results to the subcommittee in a final report. The ISCORS Sewage
Subcommittee will prepare a final report on the survey results.
D. QUESTIONNAIRE RESULTS FOR THE TEST SITES
The questionnaire was sent to the nine test sites to obtain current site-specific information about
the sludge treatment process and disposal practices of each facility. As a result of the
experiences with the tests sites and public comments on the January 6, 1997 Federal Register
notice, minor changes were made to the questionnaire.
Originally, it was estimated that it would take two hours to complete the questionnaire. For most
of the test sites, the respondents took 20 minutes or less. Two respondents needed two hours
because of the large number of zip codes in the collection system.
The revised questionnaire is attached in Appendix A.
E. SAMPLE ANALYSIS RESULTS FOR THE TEST SITES
Following the evaluation of the responses to the questionnaires, each test site was sent sample
collection packages to obtain sewage samples for analysis at the laboratories. Samples from
the nine test POTWs were analyzed by both laboratories to ensure comparability, consistency in
sample handling, and validity of analytical methods.
To assist in the evaluation of sample collection procedures used in the survey, the laboratory
staffs observed sample collection procedures at two of the test sites. Most test sites sent two
sets of sludge or ash samples (one to each laboratory).
A joint NAREL and NRC contractor report presents the findings of the radioanalytical results of
various sewage sludge/ash matrices that were analyzed from the test sites. The report
compared the analytical results between the laboratories and made recommendations for
changes to be implemented before beginning the full survey. All the samples received gamma
spectroscopy and gross alpha and beta analyses. For the test cases, all the samples also
received additional isotope-specific alpha or beta analysis, although these analyses will only be
performed on about ten percent of the samples in the full survey. For the test sites, both labs
analyzed all the samples for all the radioactive materials for inter-lab comparisons. The results
of the analysis of the test samples are discussed in Appendix B.
The results from the test sites provide the beginning of the data base for the survey. By
comparing each month's lab results (by radioactive isotope and for the gross alpha and gross
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beta results) to the data collected to date, it should be possible to determine the higher
concentrations of radioactive materials. As expected from other studies, the incinerator ash
samples in the test sites contained higher concentrations of some radioactive materials than the
non-ash samples.
The following changes in the laboratory analysis resulted from the experiences with the test
sites and recommendations from the laboratories:
In general, the laboratories found good agreement between their gamma analyses.
Thus the final survey will not require that split samples be analyzed by both labs, as was
done with the test survey.
The gross alpha and gross beta analyses did not provide as good agreement, due to
differences in calibration and/or analysis procedures at the labs. Although gross alpha
and gross beta measurements are useful as gross screening tools, their accuracy should
not be assumed to be better than about an order of magnitude. Therefore, the general
magnitude of the results should be evaluated rather than detailed comparisons between
individual measurements. For example, if every month, the top few samples were to be
screened for further analysis using either gross alpha or gross beta results, the same
samples would be selected using either laboratory's data.
Although C-14 is naturally occurring, it is also man-made, and there are licensees
(radiopharmaceutical and research facilities) that could potentially discharge C-14 to
sewage collection systems. Because C-14 will not be detected readily by the sludge
screening (gross beta) analyses, the screening analyses would not be useful for
determining which samples to analyze for C-14. Instead, the association of a POTW with
a facility that could discharge C-14 will be used to determine a limited number of samples
to be analyzed for C-14.
i '
Both of the laboratories as well as the subcommittee recommended that tritium be
excluded from the analysis because tritium does not reconcentrate due to its chemical
behavior in sewage collection systems. However, since tritium was detected in several
samples, the laboratories will analyze for tritium until the results indicate that this analysis
can be discontinued.
Return time to the labs should be minimized for detection of short-lived nuclides, as well
as for sample preservation (avoidance of sample deterioration). The survey will continue
to use overnight shipments of samples to the labs.
The turnaround time at the POTWs was often not very good. This caused sample
batching problems for the labs, which in turn caused increased turnaround times and
more analysis expense. Therefore, the sampling instructions and phone calls to the
POTWs will emphasize the need for quick sampling and return. A turnaround time of no
more than one week is needed for efficient laboratory operation.
All samples will be analyzed using gross alpha, gross beta and gamma spectroscopy
analytical techniques; ten percent of the samples will receive additional isotopic-specific
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alpha or beta analyses.
F. REFERENCES
Ainsworth, C.C., Hill, R. L, Cantrell, K. J., Kaplan, D. I., Norton, R. L, Aaberg, R. L, 1994,
"Reconcentration of Radioactive Material Released to Sanitary Sewers in Accordance with 10
CFR Part 20," NUREG/CR-6289, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555.
EPA, 40 CFR Part 503, "Standards for the Use or Disposal of Sewage Sludge."
EPA, 1986, "Radioactivity of Municipal Sludge."
EPA, 1989, "POTW Sludge Sampling and Analysis Guidance Document."
EPA, 1990, "Suggested Guidelines for the Disposal of Drinking Water Treatment Wastes
Containing Naturally Occurring Radionuclides."
,'.'< ,. -'., 4'"' s!!> ,. " ,| ;, . ! .' ..: , ';
EPA/NAREL and ORISE, 1998, "Report to the ISCORS Subcommittee on the Sewage Nuclide
Concentration Test Samples," November 13,1998.
EPA/NAREL, in preparation, ''Quality Assurance Project Plan, NRC/EPA Sewage Sludge
Survey."
GAO, 1994, Nuclear Regulation, "Action Needed to Control Radioactive Contamination at
Sewage Treatment Plants."
Kennedy, Jr., W. E., Parkhurst, M. A., Aaberg, R. L., Rhoads, K. C., Hill, R. L, Martin, J. B.,
1992, "Evaluation of Exposure Pathways to Man from Disposal of Radioactive Materials into
Sanitary Sewer Systems," NUREG/CR-5814, U.S. Nuclear Regulatory Commission,
Washington, D.C. 20555.
National Biosolids Partnership, 1999, Characteristics of Radioactivity Sources at Wastewater
Treatment Facilities; A Guidance Document for Pretreatment Coordinators.
NRC, 10 CFR Part 20, "Standards for Protection Against Radiation."
NRG, January 6, 1997, Federal Register, Agency Information Collection Activities: Proposed
Collection; Comment Request, page 771.
NRC and EPA, May 29, 1997, Draft Guidance of Radioactive Materials in Sewage Sludge/Ash at
Publicly Owned Treatment Works (POTWs).
NRC, December 2,1997, Federal Register, Agency Information Collection Activities:
Submission for OMB Review; Comment Request, pages 63730-63731.
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APPENDIX A
SEWAGE SLUDGE QUESTIONNAIRE
1. GENERAL INSTRUCTIONS
1.1 Introduction
The U.S. Nuclear Regulatory Commission (NRC) and the U.S. Environmental Protection Agency
(EPA) request your participation in a joint national survey of the concentrations of radioactive
material in sewage sludge (biosolids), ash, and related byproducts.
NRC regulations in 10 CFR 20.2003 currently permit licensee disposal of certain specific
quantities of soluble or readily dispersible biological radioactive material into a sanitary sewer
system. The EPA regulation that addresses the use or disposal of sewage sludge (40 CFR Part
503) currently does not address radionuclides.
This survey will help determine the adequacy of the present NRC and EPA regulations
addressing the discharge of radioactive material to the sanitary sewer system. It will also
respond to a recommendation from the General Accounting Office (GAO) to determine the
extent to which radioactive contamination in sewage sludge, ash, and related byproducts is
occurring (GAO report, "Actions Needed to Control Radioactive Contamination at Sewage
Treatment Plants," May 1994).
1.2 When and Where to File
Please return the completed questionnaire within 30 days of date of receipt to the address
below:
U.S. Nuclear Regulatory Commission
Attn: Mary Thomas
Mail Stop T-9C24
Washington, DC 20555 .
1.3 Reporting Period
Please report information for the last 12 months or the last calendar year.
1.4 Further Information
If you require assistance in completing this questionnaire, call Robert Bastian, EPA, at 202-260-
7378, (email: bastian.robert@epa.gov) or Mary Thomas, NRC, at 1-800-368-5642-extension
6230 (email: mlt1@nrc.gov).
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2. GLOSSARY OF TERMS
End-products are the materials that leave the treatment facility or are disposed of onsite after all
processing is completed (e.g., ash from incineration, digested liquid ordewatered cake, dried
pellets, compost).
Incineration is the combustion of matter in sewage sludge by high temperatures in an enclosed
device.
Land application is the application of sewage sludge to land to either condition the soil or fertilize
crops or other vegetation.
' '"', ' ' , : , I
Monofills are landfills where only sewage sludge is disposed. Monofills include trenches and
area fills.
Municipal solid waste landfill is a landfill that receives household waste, and that is not a land
application unit, surface impoundment, injection well, or waste pile. Such a landfill may be
publicly or privately owned.
Sewage sludge is solid, semi-solid, or liquid residue generated during the treatment of domestic
sewage in a treatment works. Sewage sludge includes, but is not limited to: domestic septage;
scum or solids removed in primary, secondary, or advanced wastewater treatment processes;
and material derived from sewage sludge. Sewage sludge does not include ash generated
during the incineration of sewage sludge or grit and screenings generated during preliminary
treatment of domestic sewage in a treatment works.
Surface disposal is the placement of sewage sludge on an area of land for final disposal. It
includes monofills, surface impoundments, lagoons, waste piles, and dedicated disposal sites. It
does not include treatment and storage of sewage sludge, although placement on land for
longer than 2 years is considered surface disposal unless the site owner/operator retains written
records demonstrating that the operation constitutes a treatment or temporary storage site.
Treatment works is either a Federally-owned, publicly-owned, or privately-owned device or
system used to treat (including recycle and reclaim) either domestic sewage or a combination of
domestic sewage and industrial waste of a liquid nature.
Use or disposal includes: land application of bulk sewage sludge, land application of sewage
sludge sold or given away in a bag or other container, surface disposal, disposal in a municipal
solid waste landfill unit, incineration, or any other use or disposal practice (e.g., vitrification, use
in asphalt or Brick production, etc.).
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SECTION I. TREATMENT WORKS IDENTIFICATION INFORMATION
Mailing Label
Name of the treatment works and physical location (which may differ from the mailing address):
Mailing address of the treatment works (if different):
Name, title, and telephone number of the person who should be contacted regarding information
on this questionnaire:
Name, title, address, and telephone number of the person who should be sent the sample
collection package:
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SECTION II. GENERAL TREATMENT WORKS INFORMATION
1 i
1. Indicate below the level(s) of wastewater treatment achieved by this treatment works.
(Mark X for allthat apply.)
a. LJ Primary treatment
b. LJ Secondary treatment
c. LJ Advanced treatment
2. Provide the annual average daily total flow rate for the last 12 months or the last
calendar year (the total volume of wastewater treated by the treatment works in one year
divided by 365). Use Gallons per Day (GPD) if your total daily flow rate is less than
10,000 GPD, or use Million Gallons per Day (MGD), but not both.
, .., , GPD or MGD (Circle one) over the
last 12 months or last calendar year (circle one)
3. List the zip codes served by the collection system for this treatment works. This
information is needed so NRC can identify licensees that can potentially discharge to
your collection system. A list of these licensees will be sent to you in return for providing
this information.
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4. Identify the sewage sludge treatment process(es) used at your treatment works. (Mark X
for all that apply.)
a. LJ Treatment works did not process sewage sludge in the last 12 months or
the last calendar year.
Explain:
b. IJ Thickening
c. II Mechanical dewatering by ., .
(Please fill in process(es) used.)
d. II Heat treatment/wet air oxidation
e. II Aerobic digestion
f. II Anaerobic digestion
g. LJ Composting
h. II Lime stabilization (Class B)
i. L-1 Alkaline Stabilization (Class A)
j. LJ Air drying beds
k. II Heat drying/Pelletizing
I. II Sewage sludge treatment/storage lagoon(s)
m. IJ Sewage sludge storage bins or piles
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n. II Incineration
I i
! , I Ğ
o. iI Other sewage sludge treatment processes (Please specify.)
5. Check the boxes below to indicate the sewage sludge use or disposal practice employed
at your facility or by others using/disposing of your sewage sludge or ash. Also describe
the product as one of the following: slurry, dewatered cake, compost, pellets, ash,
effluent, grit, or other. Note if the product is stored onsite before ultimately being
disposed offsite; and if the product is stored onsite, the time stored onsite.
a. II Land application. Product description:
b. II Surface disposal (permanent piles, lagoons, sludge or ash monofills).
Product description:
c. LJ Disposal in municipal solid waste landfill. Product description:
d. LJ Transfer of your sewage sludge or ash to another facility for use or
disposal. Product description:
Identify the facility (type, location):
e. LJ Other use or disposal practice. Product description:
Describe practice:
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6. What are the primary sources of drinking water for your community? Check more than
one, if applicable.
a. II Municipal water supply from surface water source(s)
b. I1 Municipal water supply from groundwater well(s)
c. II Private wells
d. LJ Private water supply from surface water source(s)
7. Does your wastewater collection system receive discharges of drinking water treatment
residuals?
D Yes II No
8. Does your wastewater collection system include combined sanitary and storm water
sewers?
D Yes D No
9. Do you receive sludge from other wastewater treatment facilities for processing at your
facility?
D
LJ Yes l-l No
10. Do you receive septage for processing at your facility?
D Yes iU No
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11. What percentage of the annual average daily total flow rate (response to question 3) is
industrial flow?
' Percent
12. Have you ever tested for radioactive materials in your sewage sludge?
D Yes D No
13. Do you have more than one final sewage sludge production facility location?
D Yes CH No
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APPENDIX B
Radionuclides In Sewage Sludge and Ash
at POTW Test Sites and
Comparison With Other Sources of Radioactivity
The purpose of this Appendix is to-compare published data on typical concentrations of
radionuclides in soil, fertilizer, and building materials to the concentrations of radionuclides
found in the sludge and ash samples of a pilot study of nine Publicly Owned Treatment Works
(POTWs). The pilot study was conducted by a federal interagency working group (Interagency
Steering Committee on Radiation Standards (ISCORS)) to develop sampling and analysis
procedures for a nationwide survey of radionuclide concentrations in municipal sewage sludge
and incinerator ash, to be conducted in 1999.
Over the last several decades, the U.S. Environmental Protection Agency (EPA) has conducted
surveys of sewage sludge, ash, compost, and the other products produced by POTWs, to
determine whether concentrations of pollutants that may pose a danger to members of the
public or POTW workers are present. Recently, the U.S. Nuclear Regulatory Commission
(NRC), the U.S. Department of Energy (DOE), and the U.S. Department of Defense (DOD) have
begun a collaborative effort with EPA to conduct a survey of POTWs nationwide to determine
potential concentrations of naturally-occurring and commercially utilized sources of radioactive
materials in the sludge or ash. The results of this survey will be available in about 2 years.
A pilot study of nine POTWs was conducted to assist the agencies in developing sampling and
analysis procedures. It is important to note that the purpose of this pilot study was not to assess
the relative safety or hazard of radioactive materials in sewage sludge and incinerator ash, but
rather to assess the sampling and analysis procedures. As such, no conclusions were drawn as
to the relevance of radioactive material concentrations detected in these samples. This
document is intended to help put these raw data in perspective.
SOURCES OF RADIATION EXPOSURE
Radiation in the environment from natural sources is the major source of radiation exposure to
man. Radiation exposure results from the naturally-occurring radionuclides in the environment
(terrestrial radiation) and direct cosmic (extra-terrestrial) radiation. Naturally-occurring
radionuclides are present in some plants and animals. In the human body, for example,
radioactive potassium (K-40) is present in bones and soft tissues and is the principal naturally-
occurring source of internal radiation exposure. Some sources of natural radiation have been
enhanced (concentrated) by human technological activities and include wastes from mineral
ores and the petroleum industry, sludge and scale from drinking water treatment, and articles
made from naturally-occurring radioactive materials such as thorium in lantern mantles.
Together, this radiation is often referred to as "natural" or "background" radiation. It is all around
us and cannot be completely avoided. In addition to natural or background radiation, radiation
from man-made sources, such as X-ray machines and nuclear reactors and fallout from nuclear
weapons testing in the past, also results in a relatively small source of radiation exposure to
man.
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Naturally-occurring radioactive materials are found in soil and water as well as in materials used
to build our homes, such as bricks and stones. Geological formations and soils may contain
isotopes of uranium, thorium, radium, radon, and other radioactive elements. The public is
generally aware of the radioactive gas, radon (radon-222),which is one of the decay products of
the uranium isotope uranium-238 that is found naturally in soil. Radon is often found in the air
we breathe and the water we drink. Radon-222 and its decay products contribute most of the
radiation exposure received by members of the public.
RADIOACTIVE MATERIALS JN SEWAGE SLUDGE, ASH AND OTHER PRODUCTS
Sewage sludge and ash at POTWs may contain both naturally-occurring and man-made
radioactive materials. Water that originates in or moves through geologic deposits containing
naturally-occurring radionuclides could result in radioactivity being carried to the treatment
facility with storm water runoff or infiltration entering the sewer system, and water treatment
plant residuals discharged to the sewer system. Industrial, medical or research facilities may
also discharge radioactive materials to the sanitary sewer system in accordance with prescribed
State and Federal regulations. In addition, radioactive materials administered to patients for the
diagnosis or treatment of illnesses are excreted into the sewer system. Other industrial or
residential discharges (such as fertilizer residues) can contain naturally-occurring radioactive
materials that are not subject to licensing or regulation.
Tables 1 and 2 provide the concentrations of radionuclides detected during the pilot survey of
sludges and ash from nine POTWs, as well as typical ranges of radionuclide concentrations
commonly found in U.S. soils and common items such as fertilizers and building materials. The
curie (Ci), or fractions of a curie (e.g. picocurie), is the unit for expressing a quantity of
radioactivity. The unit normally used to describe the concentrations of radioactivity in the
environment is picocuries per gram (pCi/g). A picocurie is one one-trillionth
(1/1,000,000,000,000) of a curie. Radionuclide concentrations in these tables have been
rounded to the, .nearest decimal point. Values in these tables do not show uncertainty
calculations. Studpe and ash samples from POTWS associated with facilities known to
discharge man-made radionuclides were included in the pilot survey. Inclusion in these tables
does not imply that the range of radionuclide concentrations presented for the materials is
protective of human health.
Trje ISCORS agencies make no representation as to human or environmental health and safety
significance from exposure to radionuclides in the concentrations described in the tables.
Further information may be obtained from Robert Bastian at EPA (emailbastian.robert(5).epa.qov
or phone 202-260-7378), Behram Shroff at EPA (email schroff.behram@epa.gov or phone 202-
564-9707) or Mary Thomas at NRC (email mlfl @nrc.gov or phone 301-415-6230).
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Table 1
Pilot Survey Concentration Ranges and
Typical U.S. Background Concentrations of Radionuclides
in Soil, Fertilizer, and Common Building Materials
(All values are in pd/g-dry weight)
Radio-
nuclide
Am-241
Ba-140
Be-7*
Bi-212
Bi-214
C-14*
Co-60
Cr-51
Cs-137
H-3*
1-125
1-131
K-40"
Pa-234m"
Pb-212*
Pb-214*
Pu-238
Pu-239
Ra-223 *
Ra-224 *
Ra-226 *
Ra-228 *
Soil1
NDA3
NDA
NDA
0.1 - 3.5
0.1-3.8
NDA
NDA
NDA
0.1 - 0.26
NDA
NDA
NDA
2.7-19
0.1 -3.8
0.1 -3.5
0.1 -3.8
NDA
NDA
<0.1 - 0.2
0.1 -3.5
0.1 -3.8
0.1 -3.5
Phosphate
Fertilizer 2
NDA
NDA
NDA
0.1-4.6
4.0 - 140
NDA
NDA
NDA
NDA
NDA
NDA
NDA
32- 160 7
4.0-140
<0.1 -4.6
4.0 - 140
NDA
NDA
0.2-6.6
<0.1 -4.6
0.1 -24
<0. 1-4.6
Building
Materials 1
NDA
NDA
NDA
0.1-3.7
2.5 - 5.05
NDA
NDA
NDA
NDA
NDA
NDA
NDA
0.8 - 30
0.2 - 5.0s
0.1 - 3.7
0.2-5.0
NDA
NDA
<0.1 - 0.25
0.1 -3.71
0.1 -3.5
0.1-3.7
Pilot Study
Sludge
ND4
ND
ND - 22
ND-2.0
ND-2.0
ND
ND-6.0
ND - 4.0
ND-1.0
ND-135
ND-1.0
ND - 70
2.0-8.0
ND-15
0.2 - 2.0
ND-2.0
ND-0.03
ND-0.08
ND-0.06
ND-1.0
1.0-29
ND - 2.0
Pilot Study
Ash
ND
ND
4.0-13
ND-2.0
.02-16
ND
ND
ND
0.03 - 0.08
ND
ND - 0.3
ND-4.0
14-16
ND-9.0
1.0-2.0
2.0-17
ND-0.01
, ND-0.01
ND
0.5-4.0
3.0 - 25
2.0-9.0
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Radio-
nuclide
Sr-89
Sr-90
Th-227 '
Th-228*
Th-230 *
Th-232 "
Th-234*
TI-201
TI-208 *
U-234 *
U-235 * 8
U-238 *
Soil1
NDA
NDA
<0. 1-0.2
0.1 -3.5
0.1 - 3.8
0.1 -3.5
0.1 -3.8
NDA
0.1 -3.5
0.1 -3.8
<0.1 -0.2
0.1 -3.8
Phosphate
Fertilizer 2
NDA
NDA
0.2 - 6.6
<0.1 -4.6
4.0 - 140
<0.1 -4.6
4.0 - 140
NDA
<0.1 -4.6
4.0 - 140
0.2 - 6.6
4.0 - 140
Building
Materials 1
NDA
NDA
<0.1 -0.2
0.1 -3.7
0.2 - 5.0
0.1 -3.7
0.2-5.0
NDA
0.1 -3.7
0.2 - 5.0
<0.1 -0.2
0.2 - 5.05
Pilot Study
Sludge
ND - 7.0
ND - 0.7
ND-0.1
ND-1.0
ND-1.0
0.01 -0.9
ND-12
ND - 24
ND - 0.5
0.2 - 44
ND - 3.0
0.2-12
Pilot Study
Ash
ND-0.8
ND
ND
ND-2.0
0.5-2.0
0.4-1.0
2.0 - 5.0
ND
ND - 0.6
5.0 - 8.0
ND-1.4
2.0 - 5.0
NOTES:
i. j
1. R. Tykva and J. Sabol, "Low-Level Environmental Radioactivity - Sources and
Evaluation"TechnomicPublishing Company, Inc., Lancaster, Pennsylvania (1995).
This reference is the source of data for concentrations of radionuclides in soil and
building materials except for the concentrations of U-238, U-235, and Cs-137 which
came frorq references 5 and 6, respectively. The concentrations of the daughters or
decay products of U-238, such as Th-234, Ra-226, etc., those of U-235, such as Th-227
and Ra-223, and those of Th-232 are set equal to those of their respective parent
radionuclides by assuming that the daughters are in secular radioactive equilibrium with
the parent radionuclides.
2. Source for data on fertilizers: National Council on Radiation Protection and
Measurements, 1987, Radiation Exposure of the U.S. Population from Consumer
Products and Miscellaneous Sources; NCRP Report No. 95, pp. 24-32. This is the
spurce of data for the concentrations of radionuclides in fertilizers except for the
concentration of K-40 in soil which came from the reference in note 7.
3. NDA - No data available
4. ND - Not detected. The radionuclide was not detected in some of the samples during the
pilot study. For detection limits for radionuclides, see the tables in "Report to the
ISCORS Subcommittee on the Sewage Nuclide Concentration Test Samples," dated
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November 23, 1998.
5. M. Eisenbud and T. Gesell, "Environmental Radioactivity," Fourth Edition (1997),
Academic Press, New York, New York.
6. Cs-137 concentration range in soil obtained from Figure 4-4, p. 94 of NCRP Report No.
50, "Environmental Radiation Measurements," Recommendations of the National Council
on Radiation Protection and Measurements (1976).
7. Source for data on K-40 in fertilizer: S. Cohen and Associates, 1997, Final Draft NORM
Waste Characterization; EPA Contract No. 68D20155, WA No.5-09, pp. B-3-1 to B-3-24.
8. Values for U-235 in soil, fertilizer and building materials were based on the
concentrations of U-238 in the same materials and the natural ratio of U-235 to U-238.
9. The symbol "<" which appears throughout the table is an abbreviation for the words
"less than".
10. *-naturally-occurring radionuclide
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Table 2-
Pilot Survey Radionuclide Concentrations in Sewage Sludge and Ash
. (All values are in pCi/g-dry weight)
NUCLIDE
Am-241
Ba-140
Be-7
Bi-212
Bi-214
C-14
Co-60
Cr-51
Cs-137
H-3
1-125
1-131
K-40
Pa-234m
Pb-212
Pb-214
SEWAGE SLUDGE SAMPLE RESULTS
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND,
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND,
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND
3.2, 3.08, 2.16, 2.8, 2.21, 2.26, 1.04, 0.72, 0.13, 0.11, 0.16, ND, 0.72, 0.47,
ND, ND, 0.69, 0.42, 0.76, 0.76, 7.15, 8.73, 1.30, 1.13,22.1, 21.9,18.5,
14.2, ND, ND
ND, ND, ND, 0.81, ND, ND, ND, ND, ND, 0.18, ND, 0.55, ND, ND, ND,
ND, ND, 0.37, ND, 0.47, ND, 0.50, ND, 1.49, ND, 0.76, ND, 0.63, ND, 0.56
0.68, 0.49, 0.47, 0.47, 1.12, 0.61, 0.26, 0.38, 0.21, 0.13,0.25, 0.24, 0.26,
ND, 1.38, 0.40, 1.69, 2.24, 0.45, 0.48, 0.92, 0.57, 1.37, 0.40, 0.40, 0.25,
0.41, 0.22, 0.35, 0.19
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND,
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND
ND, 0.12, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, 6.47,
5.07, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND,
ND, ND, ND, ND, ND, 3.54, ND, ND, ND, ND, ND, 1.38, ND, ND
0..30, 0.35, 0.07, ND, ND, 0.05, 0.06, ND, 0.03, 0.01,0.03, 0.02, 0.02, ND,
1.08, 1.09, 0.02, 0.02, ND, ND, 0.06, 0.06, 0.20, 0.18,0.05, 0.05, 0.08, 0.03,
0.02, 0.02
ND, ND, ND, ND, ND, ND, 30.4, ND, 3.75, ND , ND, ND, 1.69, ND, ND,
ND, ND, ND, ND, ND, 135.0, ND, ND, ND, ND, ND, 1.65, ND, ND, ND
ND, ND, 0.91, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND,
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND
60.5, 69.8, 0.49, 0.47, 0.49, 0.49, 13.8, 14.2, ND, ND, ND, ND, 7.47, 13.7,
0.26, 0.71, 0.95, 0.96, 37.4, 38.5, 0.28, 0.51, ND, ND, 9.25, 5.14, 5.55,
2.59, ND, ND
4.99, 6.23, 2.97, 3.32, 2.80, 3.29, 3.45, 4.74, 7.70, 4.99, 7.74, 7.08, 3.33,
2.77, 2.22, 2.00, 7.36,7.87, 2.15, 2.54, 5.04, 5.52, 5.74, 5.51, 4.54, 4.76,
5.12, 4.41, 6.88, 7.29
ND, 9.47, ND, ND, ND, ND, 9.55, ND, 2.37, 1.90,13.2, 11.4, 11.1, 9.33,
14.9, 11.4, ND, ND, ND, ND, ND, 1.36, ND, 2.64, ND, 3.19,1.17, 2.49,
10.1, 10.5
0.18, 0.27, 0.57, 0.74, 0.59, 0.56, 0.25, 0.31, 0.25, 0.18, 0.56, 0.63, 0.25,
0.24, 0.22, 0.28, 0.51, 0.60, 0.23, 0.35,0.49, 0.55, 1.55, 1.53, 0.68, 0.75,
0.80, 0.65,0.52, 0.55
0.42, 0.47, 0.59, 0.50, 0.94, 0.45, 0.32, 0.34, 0.25, 0.14, 0.30, 0.24, 0.22,
ND, 0.32, 0.29, 1.76, 2.35, 0.39, 0.43, 1.00, 0.63,1.42, 0.44,0.38, 0.19,
0.46, 0.24, 0.34, 0.22
ASH SAMPLE
RESULTS
ND, ND, ND, ND,
ND, ND, ND
ND, ND, ND, ND,
ND, ND, ND
4.09, 12.7, 4.25,
4.23, 5.12, 5.34,
5.21
ND, 0.81, ND, ND,
1.24, ND, 1.54
3.15, 2.08, 3.12,
9.94, 15.5, 13.7,
15.8
ND, ND, ND, ND,
ND, ND, ND
ND, ND, ND, ND,
ND, ND, ND
ND, ND, ND, ND,
ND, ND, ND
0.03, 0.08, 0.04,
0.05, 0.08, 0.04,
0.05
ND, ND, ND, ND,
ND, ND, ND
ND, ND, ND, 0.26,
ND, ND, ND
0.16, 4.25, 0.16,
4.18, ND, ND, ND
15.2, 15.4, 15,14.2,
14.4, 14.4, 15.6
8.52, 4.02, 6.21,
2.44, ND, ND, 3.37
1.39, 0.91, 1.42,
1.50, 1.94, 1.61,
1.85
3.40, 2.23, 3.42,
11.1, 16.6, 14.6,
17.3
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Pu-238
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, 0.02, 0.02,
ND, ND, ND, ND, ND, ND, ND, ND, 0.03, ND, ND, ND, ND, ND
0.01, ND, ND, ND,
ND, ND, ND
Pu-239
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, 0.02, 0.08,
0.04, ND, ND, ND, ND, ND, 0.04, 0.07, 0.01, ND, ND, ND, ND, 0.01, ND
ND, ND, ND, ND,
ND, 0.01, ND
Ra-223
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND ND, ND
ND, ND, ND, ND, ND. 0.06, ND, ND, ND. ND, ND, ND, ND, ND
ND, ND, ND, ND,
ND, ND, ND
Ra-224
ND, ND, ND, ND, ND, ND, ND, ND, ND, 0.19, ND, 0.70, ND, ND, ND, ND,
ND, 0.43, ND, ND, ND, 0.49, ND, 1.46, ND, 0.62, ND, ND, ND, 0.59
ND, 0.49, ND, ND,
3.72, ND, 3.31
Ra-226 4.65, 6.19,1.46, 3.02, 2.36, 1.71, 5.11, 7.82,1.46, 1.13, 8.92, 1.80, 10.1, 8.34, 2.92, 9.36,
10.6, 29.2, 6.38, 3.61, 4.53, 2.13, 4.08,2.00, 2.55, 3.09, 3.42, 2.36, 3.25, 16.7, 25.0,17.7,
2.67, 2.65, 7.83, 1.97 25.1
Ra-228 0.66, ND, 1.05, 1.23,0.61, 0.86, 0.74, 0.70, 0.37, 0.20, 0.67, 0.70, 0.91, 1.84, 1.58, 1.85,
0.55, 0.46, 0.60,1.52, 1.60, 1.20, 1.48,1.24, 1.22, 1.95, 1.77, 1.19, 1.14, 7.81, 8.60, 8.20,
1.40, 1.11, 0.64, 0.66 8.88
Sr-89 ND, ND, ND, ND, 7.12, ND, ND, ND, ND, ND, ND, ND, ND, ND, 1.17, ND, 0.75, ND, ND, ND,
ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, Q.56, ND, ND, ND ND. ND, ND
Sr-90 ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, 0.57, 0.74, ND, ND, ND, ND,
ND, ND, ND, ND, ND, ND. MD, ND, ND, ND, ND, ND, ND, ND ND, ND, ND
Th-227 alpha ND, ND, ND, 0.05, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND,
ND. ND, ND, ND, ND, 0.07, ND, ND, ND, 0.06, ND, 0.07, ND, ND ND, ND, ND
Th-227 gamma ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND,
ND, ND, ND, ND, ND. ND, ND, ND, ND, ND, .ND, ND, ND, ND . ND, ND, ND
Th-228 0.80, 0.52,0.14, 0.62, 0.49, 0.50,0.29, ND, 0.48, 0.24,0.45, ND, 0.30, 0.47, 1.30, ND, 1.13,
0.24, ND, 0.78, 0.54, 0.47, ND, 0.67, 0.63, 1.39, 0.91, 0.73, 0.71, 0.92, 2.42, 2.04, 1.65,
0.83, 0.49, ND 1.44
Th-230 alpha ND, 0.41, 0.16, 0.62,0.57, 0.58, 0.35, 0.32,0.42, 0.23, 0.25, 0.33,0.22, 2.36, 0.99, 2.17,
0.24,0.16, 0.40,0.29, 0.29, 0.11, 0.19, 0.53, 0.49, 0.78, 1.07, 0.84, 0.54, 0.74, 0.72, 0.55,
0.99. 0.60, 0.30, 0.43 0.87
Th-230 gamma ND, ND, ND, ND, ND, ND, MD, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND,
ND, ND, ND. ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND ND, ND, ND
Th-232 0.20, 0.26, 0.11, 0.40, 0.30, 0.36, 0.19, 0.35, 0.35, 0.18, 0.23, 0.42, 0.18, 1.19, 0.66, 1.02,
0.27, 0.10, 0.15, 0.24, 0.43, 0.01, 0.01,0.34, 0.39, 0.92, 0.91, 0.45, 0.55, 0.48, 0.71, 0.50,
0.56, 0.49, 0.28, 0.27 | 0.35
Th-234 5.00, 5.43,1.39, ND, 1.48, ND, 5.28, 2.79,1.88, 0.83, 12.5, 11.9, 7.78, 3.19, 5.03, 3.70, 5.08,
11.8, 7.54, 0.53, ND, 0.42, ND, 0.86, 0.86, 1.58, 1.00,1.29, 2.18, 1.25, ND, 2.37, 2.42, 4.17,
1.09, 10.6 2.09
TI-201 ND, NDi ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, ND, 14.0, ND, ND, ND, ND, ND, ND,
ND, 4.19, ND, 23.6, ND, ND, ND, ND, ND, 21.5, ND, 5.51, ND, ND ND, ND, ND
TI-208 ND, 0.1, ND, 0.26, ND, 0.19, ND, 0.09, ND, 0.06, ND, 0.20, ND, 0.06, ND, ND, 0.29, ND, ND,
0.05, ND, 0.17. ND, 0.11, ND, 0.17, ND, 0.51, ND. 0.24. ND, 0.22, ND, 0.18 0.65, ND, 0.61
U-234 14.4, 6.95,0.21, 0.81, 0.98, 0.98,13.2, 11.8, 4.93, 2.62,12.2, 12.3, 15.4, 5.16, 5.43, 5.78,
12.7, 44.5, 43.8,1.46, 1.24,4.44, 1.61,1.36, 1.31,1.61, 2.00, 1.84, 1.76, 7.34, 7.34,7.62,
1.56. 1.51,10.9, 10.8 ___ 6.01
U-235 alpha 0.55, 0.75, 0.01, 0.03, 0.19, 0.05, 0.35, 0.66, 0.16, 0.12,0.50, 0.43,0.58, 0.20, 0.42, 0.18,
0.68, 1.81, 3.06, 0.03, 0.08, 0.15, 0.08,0.09, 0.09,0.13, 0.13, 0.17^ 0.07, 0.18, ND, 0.14,
0.21, 0.09, 0.49. 0.57 0.24
0.20, ND, ND, ND, ND, ND, 0.41, 0.48,0.04, 0.07, 0.56, 0.52,0.50, 0.64,
U-235 gamma 1 87_ 2 04_ ND ND ND ND 0 07 ai5_ 0 05 ND 010 ND> 0 14 ND o.J^, u.^d, uJ4
0.50, 0.46 ' ' ' '
7
-------
U-238
Gross Alpha1
Gross Beta1
10.3,
10.0,
1 41
21.0,
19.5,
10.5,
30.8,
21.3,
18.4,
5.83, 0.18,
11.5, 12.0
1 13 863
18.6, 5.0,
50.8, 48.9,
10.7, 19.8,
22.1, 10.9,
60.1, 34.8,
16.8, 34.4,
0.75, 0.90,
0.74, 0.71
833
5.73,5.19,
12.6, 11.7
28.5
8.58, 12.1,
19.0, 15.3,
24.6
0.85,
, 0.95
8.78, 1
, 16.4,
9.36,
16.8,
6.72, 6.23,
0.73, 1.23,
3.4, 19.0, 5
22.6, 8.70,
20.4, 15.5,
10.5, 17.1,
2.74, 1.46
1.15, 1.06
.17, 7.55,
13.6, 14.9
13.8, 10.8,
15.9, 22.5
, 9.77, 9.62,
, 1.21, 1.33,
18.5, 30.8, 2
23.9, 10.2,
29.8, 26.2,
16.5, 19.0,
12.5,
1.36,
.3.7,
12.7,
35.3,
12.5,
4.25,
3.26,
2.28
24.4,
82.3,
72.9
51.5,
77.6,
47.2
3.81,
386
46.5,
97.9,
?RR
6^4
4.75,
3.33,
41.0,
92.6,
51.4,
95.4,
NOTES:
1. Gross 3lpha and Gross beta - These measurements are generally used as indicators of the
pre'sence of alpha and beta emitting radionuclides in a sample. Gross alpha and gross beta
activity analyses are used to screen samples to determine the need for nuclide-specific
analyses. They were included in the pilot study, but have no corresponding background levels,
arid"thus are not included in Table 1.
NQ - Not detected. The nuclide was not detected in some of the samples during the pilot study.
See the tables jn the EPA National Air and Radiation Environmental Laboratory "Report to the
ISCORS Subcommittee on the Sewage Nuclide Concentration Test Samples," November 13,
1998, for detection limits for nuclides.
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