United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 88-22: Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations

                                  UNITED STATES
                          NUCLEAR REGULATORY COMMISSION
                             WASHINGTON, D.C.  20555

                                  May 12, 1988

Information Notice No. 88-22:  DISPOSAL OF SLUDGE FROM ONSITE
                                   SEWAGE TREATMENT FACILITIES AT
                                   NUCLEAR POWER STATIONS


All holders of operating licenses or construction permits for nuclear power 


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.  

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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 

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


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 

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 
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 

                              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


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 

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 
                                                            distribute, and/or 
                                                            operate radio-
                                                            graphic exposure 

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. 

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 
                                                            low-level waste 

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 
OL = Operating License
CP = Construction Permit 
Page Last Reviewed/Updated Friday, May 22, 2015