Information Notice No. 88-22:Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555
May 12, 1988
Information Notice No. 88-22: DISPOSAL OF SLUDGE FROM ONSITE
SEWAGE TREATMENT FACILITIES AT
NUCLEAR POWER STATIONS
Addressees:
All holders of operating licenses or construction permits for nuclear power
reactors.
Purpose:
This information notice is being provided to alert licensees to two recent
events indicating that not all licensees are fully aware of the potential for
contamination of sewage sludge and the relevant regulatory requirements.
It is expected that recipients will review the information for applicability
to their facilities and consider actions, as appropriate, to avoid similar
problems. However, suggestions contained in this information notice do not
constitute NRC requirements; therefore, no specific action or written response
is required.
Related Documents:
IE Bulletin 80-10 (Reference 1) requested that licensees review the design and
operation of their facilities to identify systems that are considered non-
radioactive (or described as non-radioactive in the facility's Final Safety
Analysis Report (FSAR)) but that could become radioactive through interfaces
with radioactive systems and result in unmonitored, uncontrolled releases in
liquid and gaseous effluents. This bulletin stated that special consideration
was to be given to particular systems, including the sanitary waste system;
however, sludge from the sanitary waste system was not discussed specifically.
Information Notice No. 83-05 (Reference 2) called attention to the provi-
sions of 10 CFR 20.302, "Method For Obtaining Approval Of Proposed Disposal
Procedures," as a means for obtaining approval for disposal of, among other
things, large volumes of material radioactively contaminated at very low
levels. Information Notice No. 86-90 (Reference 3) informed licensees
that, in Agreement States, applications to obtain approvals for such disposals
should be sent to the Agreement State and not to the NRC.
8805060148
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May 12, 1988
Page 2 of 4
Information Notice No. 85-92 (Reference 4) emphasized the need for careful
surveys of materials that may be contaminated and that are to be disposed of
as "clean" waste; i.e., as waste that does not contain licensed radioactive
material.
Description of Circumstances:
During an inspection at the Point Beach Nuclear Power Plant, it was found that
the licensee had made onsite disposals of slightly contaminated sludge removed
from aeration ponds and the aerobic digester in the onsite sanitary sewage
treatment facility. The sludge was spread on licensee-owned land and mixed
into the soil by plowing. Radionuclides identified by the licensee in the
sludge included chromium-51, manganese-54, cobalt-58, cobalt-60, cesium-134,
and cesium-137. The total activity for six onsite disposals was 300 micro-
curies. Licensee representatives indicated their belief that these disposals
were in compliance with regulatory requirements because (1) they met the re-
quirements of 10 CFR 20.303, "Disposal By Release Into Sanitary Sewerage
Systems," for disposal into a sanitary sewerage system and (2) their
subsequent disposition of sludge was consistent with measures that would be
taken by any operator of a sanitary sewerage system. The licensee was
informed that these disposals were contrary to 10 CFR 20.301, "General
Requirements (Waste Disposal)," and that 10 CFR 20.303 does not apply to
contaminated sludge removed from onsite sewage treatment facilities.
10 CFR 20.303 only allows a licensee to discharge radioactive material into a
sanitary sewerage system under limited conditions. It does not cover removal
and land disposal of contaminated sludge from the licensee's sanitary sewage
treatment facilities. Considering the very low level of radioactive
contamination of the sludge and the licensee's estimate that these disposals
would result in very low annual doses, the licensee ap-plied for, and obtained,
approval of future disposals of this type pursuant to 10 CFR 20.302.
Subsequently, during an inspection at the Surry Nuclear Power Station, it was
found that the licensee had disposed of dried sludge from the onsite sewage
treatment facility at the county sanitary landfill without determining if the
sludge was contaminated with licensed material. Licensed radioactive material
was found in sludge that had not yet been disposed of. The licensee was
informed that failure to determine, before disposal, if the sludge was
contaminated was contrary to 10 CFR 20.201, "Surveys," and that disposal of
contaminated sludge by this means would be contrary to 10 CFR 20.301.
Before receiving the application from Point Beach, the NRC had received only
one application pursuant to 10 CFR 20.302 for disposal of radioactively
contaminated sewage sludge from a sanitary sewage treatment facility at a
nuclear power station. This was a request from the Duke Power Company for
disposal of contaminated sludge at its Oconee Nuclear Station. In this case,
the requested method of disposal was by transfer to a contracted vendor for
transport to a publicly owned treatment works. The NRC found the request
acceptable; however, because Oconee is in an Agreement State, South Carolina,
it was necessary for the licensee to obtain approval of the State for this
disposal of byproduct material.
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May 12, 1988
Page 3 of 4
Discussion:
Licensees may wish to consider the following:
1. Sludge from onsite sewage treatment plants may be contaminated with
licensed radioactive material which has been concentrated by the
treatment system.
2. The provisions of 10 CFR 20.303 do not apply to the disposal of contami-
nated sludge removed from sanitary sewerage systems at nuclear power
stations.
3. 10 CFR 20.201 covers surveys required before disposing of sewage
treatment sludge, to determine if the sludge is contaminated. Gamma-ray
spectrometry can be performed on representative samples of the sludge
under conditions that provide a lower limit of detection (LLD)
appropriate to measurements of environmental samples. Such measurements
make it possible to distinguish licensed material from other radioactive
materials (natural radioactive materials and world-wide fallout) that may
be present in the sludge.
4. 10 CFR 20.301 covers the disposal of sewage sludge from a licensee's
sewage treatment facility when contaminated with licensed radioactive
material.
5. Licensees may apply in accordance with the provisions of 10 CFR 20.302 to
dispose of sewage sludge containing very low levels of licensed radio-
active material in a manner not otherwise authorized in the regulations.
Applications for approval of such disposal may be made to the NRC or
Agreement State, as appropriate.
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contacts: John D. Buchanan, NRR
(301) 492-1097
W. Wayne Meinke, NRR
(301) 492-3152
Attachment: List of Recently Issued NRC Information Notices
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May 12, 1988
Page 4 of 4
References
1. IE Bulletin No. 80-10, "Contamination of Nonradioactive System and
Resulting Potential for Unmonitored, Uncontrolled Release of
Radioactivity to Environment," May 6, 1980.
2. Information Notice No. 83-05, "Obtaining Approval for Disposing of
Very-Low-Level Radioactive Waste - 10 CFR Section 20.302,"
February 24, 1983.
3. Information Notice No. 86-90, "Request to Dispose of Very-Low-Level
Radioactive Waste Pursuant to 10 CFR 20.302," November 3, 1986.
4. Information Notice No. 85-92, "Surveys of Waste Before Disposal from
Nuclear Reactor Facilities," December 2, 1985.
. Attachment
IN 88-22
May 12, 1988
Page 1 of 1
LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
_____________________________________________________________________________
Information Date of
Notice No._____Subject_______________________Issuance_______Issued to________
88-21 Inadvertent Criticality 5/9/88 All holders of OLs
Events at Oskarshamn or CPs for nuclear
and at U.S. Nuclear power reactors.
Power Plants
88-20 Unauthorized Individuals 5/5/88 All holders of OLs
Manipulating Controls and or CPs for nuclear
Performing Control Room power, test and
Activities research reactors,
and all licensed
operators.
88-19 Questionable Certification 4/26/88 All holders of OLs
of Class 1E Components or CPs for nuclear
power reactors.
88-18 Malfunction of Lockbox on 4/25/88 All NRC licensees
Radiography Device authorized to
manufacture,
distribute, and/or
operate radio-
graphic exposure
devices.
88-17 Summary of Responses to NRC 4/22/88 All holders of OLs
Bulletin 87-01, "Thinning of or CPs for nuclear
Pipe Walls in Nuclear Power power reactors.
Plants"
88-16 Identifying Waste Generators 4/22/88 Radioactive waste
in Shipments of Low-Level collection and
Waste to Land Disposal service company
Facilities licensees handling
prepackaged waste,
and licensees
operating
low-level waste
disposal
facilities.
88-15 Availability of U.S. Food 4/18/88 Medical, Academic,
and Drug Administration and Commercial
(FDA)-Approved Potassium licensees who
Iodide for Use in Emergencies possess
Involving Radioactive Iodine radioactive
iodine.
_____________________________________________________________________________
OL = Operating License
CP = Construction Permit
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