United States	United States	EPA 832-R-99-900
Environmental Protection	Nuclear Regulatory	March 1999
Agency	Commission
&EPA Joint NRC/EPA Sewage Sludge
Radiological Survey:
Survey Design & Test Site Results
Sewage Subcommittee of the
Interagency Steering Committee on
Radiation Standards (ISCORS)

-------
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, NRC/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, NRC/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.

-------
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 POTWTest Sites and Comparison
With Other Sources of Radioactivity

-------
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
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
1

-------
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.
Sources of Radioactive Materials
One possible source of radioactive material entering a POTW involves naturally-occurring
2

-------
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
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
3

-------
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
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.
4

-------
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. Wth 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.
6.	Include a small group of POTWs with low potential for elevated radioactive
materials for comparison purposes.
NRC 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.
5

-------
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
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 NORM at POTWs.
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
6

-------
samples for this survey. The POTWs will return their samples to the NRC contractor who will
assign a code to each POTWto ensure confidentiality.
It is assumed that each POTWwill, 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: strontium-89/90, carbon-14, hydrogen-3 (tritium)
alpha emitters: radium-226, thorium-227/228/230/232, uranium-234/235/238,
plutonium-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
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
7

-------
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
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,
8

-------
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.
¥ 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 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."
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
9

-------
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."
NRC, 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.
10

-------