ML20133A877

Notice of Pending NRC Action to Submit Info Collection Request to OMB & Solicitation of Public Comment

ML20133A877
Person / Time
Issue date:	12/20/1996
From:	Cranford G NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
To:
References
NUDOCS 9701020152
Download: ML20133A877 (19)

Text

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[7590-01-P]

U. S. NUCLEAR REGULATORY COMMISSION Agency Information Collection Activities: P.

osed Collection; Comment request AGENCY:

U. S. Nuclear Regulatory Commission (NRC)

ACTION:

Notice of pending NRC action to submit an information collection request to OMB and solicitation of public comment.

SUMMARY

The NRC is preparing a submittal to OMB for review and approval of a new information collection under the provisions of the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35).

Information pertaining to the requirement to be submitted:

1.

The title of the information collection:

Joint NRC/ EPA Survey of Sewage Sludge / Ash 2.

Current OMB approval number None.

3.

How often the collection is required: This is a one-time collection.

Dt 010043 M tN 4(4 9701020152 961220 e

PDR ORG EUSOMB

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2-l 4.

Who is required or asked to report: Selected publicly owned treatment works (POTWs), and Agreement States.

5.

The number of annual respondents: 600 POTWs for the questionnaire, and 300 POTWs for sample collection, plus 29 Agreement States for reporting of Zip Codes.

6.

The number of hours needed annually to complete the requirement or request: An average of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per respondent for questionnaires and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> each for selected respondents for collecting samples, plus 8 s

hours each for 29 Agreement States. The total burden is 3,232 hours0.00269 days <br />0.0644 hours <br />3.835979e-4 weeks <br />8.8276e-5 months <br />.

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7.

Abstract The survey will obtain national estimates of the levels of 1

radioactive materials in sludge and ash at POTWs, estimate the extent to which radioactive contamination comes from either NRC/ Agreement

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State licensees or from naturally occurring radioactivity, and support possible rulemaking decisions by NRC and EPA. NRC and EPA will i

send questionnaires to selected POTWs. Based on the results of that survey, NRC will identify approximately 300 POTWs from which samples of sewer sludge / ash will be taken and analyzed. Results of the full survey will be published for use by Federal agencies, States, POTWs, and local POTW officials.

1

, 1 Submit, by (insert date 60 days after publication in the Federal Recister), comments that address the following questions:

i 1.

Is the proposed collection of information necessary for the NRC to 1

properly perform its functions? Does the information have practical utility?

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2.

Is the burden estimate accurate?

i 3.

Is there a way to enhance the quality, utility, and clarity of the j

information to be collected?

4.

How can the burden of the information collection be minimized, including the use of automated collection techniques or other forms of information technology?

A copy of the draft supporting statement may be viewed free of charge at the NRC Public Document Room, 2120 L Street NW, (lower level), Washington, DC. Members of the public who are in the Washington, DC, area can access this document via modem on the Public Document Room Bulletin Board (NRC's Advance Copy Document Library), NRC subsystem at FedWorid, 703-321-3339. Members of the public who are located outside of the 1

Washington, DC, area can dial FedWorid, 1-800-303-9672, or use the FedWorld Intemet address: fedworld. gov (Telnet). The document will be available on the bulletin board for 30 days after the signature date of this notice. If assistance is needed in accessing the document, please contact the FedWorld help desk at 703-487-4608. Additional assistance in

locating the document is available from the NRC Public Document Room, nationally at 1-800-397-4209, or within the Washington, DC, area at 202-634-3273.

Comments and questions about the information collection requirements may be directed to 1

the NRC Clearance Officer, Brenda Jo. Shelton, U.S. Nuclear Regulatory Commission, T-6 F33, Washington, DC,20555-0001, by telephone at (301) 415-7233, or by Intemet electronic mail at BJS1@NRC. GOV.

t Dated at Rockville, Maryland, this day of-

-M 996.

For the Nuclear Regulatory Commission.

brald F. Cran' ford, Desigrfated Senior Official for Information Resources Management i

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, ash, and related byproducts.

NRC regulations in 10 CFR 20.2003 currently permit licensee. disposal of certain specific quantities of soluble 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 regulations addressing the discharge of radioactive material to the sanitary sewer system.

.It will also respond to a recommendation from the General Accounting Office (GA0) to determine the extent to which radioactive contamination in sewage sludge ash, and related byproducts is occurring (GA0 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:

Dale Condra Dak Ridge Institute for Science and Education P.O. Box 117 l

Oak Ridge. Tennessee 37831-0117 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 l

Bastian. EPA, at 202-260-7378. or Phyllis Sobel. NRC. at 1-800-368-5642-extension 6714, weekdays. between 8 a.m. and 4 p.m.. EST.

Enclosure l

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i 2.

GLOSSARY OF TERHS l

End-products are the materials that leave the treatment facility or are disposed of onsite after all processing (e.g., ash from incineration, digested cake. dried or composted sludge (biosolids). etc.).

Incineration is the combustion of matter in sewage sludge by high temperatures in an enclosed device.

l.and application is the application of sewage sludge.to land to either condition the soil or fertilize crops or other vegetation grown in the soil.

Nonofills are landfills where only sewage sludge.is disposed. Mondfills include trenches and area fills.

Municipal solid waste landfill is a landfill or excavation 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, ssmi-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 solics 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 donestic 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.

Surface disposal site is an area of land that contains one or more active sewage sludge units.

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).

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i 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):

l e

Name, title, and telephone number of the person (s) who should be contacted regarding information on this questionnaire:

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1 SECTION II. GENERAL TREATMENT WORKS INFORMATION j

1.

Indicate below how this treatment works is classified.

(Mark X in one box only.)

a.

O Publicly owned treatment works b.

O Privately owned treatment works c.

O Federally owned treatment works

-2.

Indicate below the level (s) of wastewater treatment achieved by this treatment works.

(Mark X for all that apply.)

O Primary treatment a.

b.

O Secondary treatment 4

O Advanced treatment c.

3.

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 366). 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 E MGD (Circle one)

Last 12 months E last calendar year (circle one)

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4.

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).

e 4

5.

Identify the sewage sludge treatment process (es) used at your treatment

. works. '(Mark X for all that apply.)

O Treatment works did not process sewage sludge in the last 12 a.

months or the last calendar year.

Explain-b.

O Thickening I

O Mechanical dewatering by c.

r (Please fill in process (es) used.)

a d.

O Heat treatment / wet air oxidation O

Aerobic digestion

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e.

f.

O Anaerobic digestion O

Composting g.

h.

O Lime stabilization (Class B)

i. O Alkaline stabilization (Class A)

j. O Air drying beds k.

O Heat drying / Pelletizing 1.

O sewage sludge treatment / storage lagoon (s)

O sewage sludge storage bins or piles m.

O Incineration n.

O Other sewage sludge treatment processes (Please specify.)

o.

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j 6.

Check the boxes below to indicate the sewage sludge use or disposal practice employed at your facility or by others using/ disposing of your se.. ge sludge or ash.

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O Land application - liquid. dewatered cake, dried, composted.

a.

alkaline stabilized, etc. sludge or sludge incinerator ash b.

O Surface disposal (permanent piles. lagoons, sludge or ash monofills)

O Disposal in municipal solid waste landfill c.

d.

O Transfer of your sewage sludge or ash to another facility for use or disposal.

Describe the facility (type. location).

O Other use or disposal practice e.

Describe.

7.

What is the primary source of drinking water for your community?

O Municipal water supply from surface water source (s) a.

b.

O

~ Municipal water supply from groundwater wel1(si O

private wells c.

8.

Does your wastewater collection system receive dis water treatment residuals?

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0 yes O

No 1

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y..

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9.

Does your wastewater collection system include combined sanitary and

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storm water sewers?

[3 Yes

[]

No I

10, Do you receive sludge from other wastewater treatment facilities for l

processing at your facility?

O Yes O

No 11.

What percentage of the annual average daily total flow rate (r'esponserto question 3) is industrial flow?

Percent 12.

How many minutes did it take to fill out this form?

Minutes 13.

Did we miss any questions you think will develop information useful to us?-

.14.

Was this survey written clearly?

[]

Yes

[]

No 15.

Any suggestions you may have for improving this survey form.

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SUPPORTING STATEMENT f

FOR l

JOINT NRC/ EPA SURVEY OF SEWAGE SLUDGE / ASH Description of the information Collection l

The U.S. Nuclear Regulatory Commission and the U.S. Environmental Protection Agency l

(EPA) are sponsoring a joint effort to characterize radioactive materials in sewage sludge and ash from pub'icly owned treatment works (POTWs). Sanitary sewer disposal of radioactive i

material and Mudge reconcentration became issues in the 1980s with the discovery of l

elevated levals in sewage sludge or incinerator ash at several POTWs. Although the NRC expected the. compliance with revisions in its sewer disposal criteria _would prevent future reconcentration problems, NRC and EPA have continued to work together to ensure a i

coordinated regulatory review effort concoming sewage treatment with respect to radioactive material. EPA had planned to include analysis of radioactivity in sewage sludge and j

incinerator ash in its second National Sewage Sludge Survey during 1996-97. (The first

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national survey conducted in the late 1980s did not include analysis of radioactive material.)

Based on the current budget situation, EPA is not currently planning to move forward with a j

second natio" ;l survey. As a result, NRC and EPA will perform a joint survey of radioactivity i

in sewage sludge and ash at POTWs.

i Because existing information is not adequate, NRC is requesting Office of Management and Budget (OMB) approval to conduct the survey to obtain this information. The survey will sample radioactive materials in sewage sludge and ash at POTWs in all regions of the country. For the planned NRC/ EPA survey, we will build on the efforts of the 1980s survey l

by sending queshonnaires to the POTWs which participated in that survey. Questionnaires l

will also be sont to POTWs associated with types of NRC licensees that have had sewer i

reconcentration problems in the past and in areas of :.,iatively high background radiocctivity.

l Using the information from the questionnaires, NRC will identify the approximately 300 l

POTWs to be sampled. NRC and EPA are currently testing the survey methods and procedures en nine POTWs. The results of the full survey will be published as a joint j

NRC/ EPA report for use by Federal agencies, States, POTWs, and local POTW officials.

i A.

JUSTIFICATION 1.

Need for and Practical Utility of the Collection of Information i

The objectives of this joint NRC/ EPA sewage sludge / incinerator ash survey are to (1) obtain national estimates of the levels of radioactive materials in sludge and ash at j

POTWs, (2) estimate the extent to which radioactive contamination comes from either NRC/ Agreement State licensees or naturally occurring radioactivF.y (3) support l

rulemaking decisions by NRC and EPA, and (4) support the biisis for developing acceptance criteria for radioactivity in sludge and ash.

Specific amounts and concentrations of radioactive material are legally authorized to i

be disposed into the sanitary sewer system by Federal or State law. In 1994 NRC revised its sewer disposal criteria partially in response to evidence that certain radioactive materials were reconcentrating in sewage sludge or incinerator ash.

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W Reguistions in 10 CFR 20.2003 currently permit disposal into a sanitary sewer of specific quantities of soluble material. The EPA standard for the use and disposal of sewage sludge in 40 CFR Part 503 does not include radionuclides.

This survey also responds to a recommendation in the General Accounting Office (GAO) report, " Actions Needed to Control Radioactive Contamination at Sewage Treatment Plants," published in May 1994. That report recommended that NRC determine the extent of elevated levels of radionuclides at POTWs and establish acceptsble limits for radioactive materials in sewage sludge and ash.

2.

Aaency_IM of information This ;s a new collection of information.

The information could lead to additional NRC rulemaking for licensees disposing material into sanitary sewer systems or to EPA rulemaking for the use or disposal of seveage sludge.

This information will be used in developing joint NRC/ EPA guidance for POTWs. This guide. m would provide information to help characterize sources of radioactive mamrials at POTWs, describe sampling and analysis procedures, and advise whether a response is needed to the presence of radioactive material in sludge. POTWs, local sewer district officials, and EPA have requested this guidance.

3.

Reduction of Burden throuah information Technolooy POTWs will respond to a short questionnaire and send sewage samples to an NRC or EPA lab for analysis. There will not be an electronic collection of information because the information will be collected on a one-time-basis. Two letters co-signed by NRC and EPA will be mailed to each POTW - the first letter with the questionnaire and the second with the sample collection package. The version of the letter with the questionnaire that was sent to the test case POTWs is attached.

4.

Effort to identify Duplication and Use Similar information There is no similar information available. The only previous national sewage survey, the 1988-1989 National Sewage Sludge Survey, did not include analysis of radionuclides.

Recently, the Association of Metropolitan Sewerage Agencies (AMSA) conducted a voluntary survey of radionuclide concentrations in some of its members' POTW sewage sludge and ash. However, the AMSA survey had limited geographic coverage, involved only large urban areas, did not analyze all radionuclides of interest, and did not identify the facilities tested. Thus it is not possible to assess re@ual background levels of radionuclides or the effects of licensees that dispose of radioactive material into sanitary sewers. (See further discussion of the AMSA survey in Item 8.)

i 3-5.

Effort to Reduce Small Business Burden l

This survey does not directly involve small entities. However, because the information j

needs are the same for both large and small POTWs, it is not possible to reduoe the '

i burden on small entdies.

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6.

Consecuences to Federal Prooram or Policy Activities if the Collection is Not j

Conducted or is Conducted I.ess Freauentiv i

i If the collection is not conducted at all, NRC and EPA will not be responsive to the recommendation in the GAO report to determine the extent of elevated levels of f

radionuclides at POTWs and establish acceptable limits for radioactive materials in j

sewage sludge and ash. NRC and EPA will also not be able to obtain information providing a basis for developing potential future rulemakings and quantdathre guidance for the proposed joint NRCEPA guidance for POTWs. This is a one-time collection.

i There are no technical or legal obstacles to conducting this data collection.

I 7.

Circumstances Which Justify Variation from OMB Guidelines l

There is no variation from OMB guidelines. The POTWs will have 30 days to respond.

8.

Consultations Outside the NRC

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in an October 11,1994 letter, NRC and EPA notWied the water and radiological officials of all States of the potential for reconcentration of radioisotopes in sanitary sewer systems. This letter mentioned the planned EPA national survey and the guidance document.

On March 6,1996, EPA and NRC staff were briefed by AMSA and the Water Environment Federation (WEF) on the preliminary results of a voluntary (but anonymous) AMSA survey of radionuclide concentrations in sewage sludge and ash at POTWs (see also discussion in item 4). To date, sewage sludge and ash samples from at least 50 wastewater plants in at least 18 states have been analyzed. These plants were distributed across the country and range in siza from small to among the largest POTWs in the United States. Because of limitations in the AMSA survey, the possibility of a more extensive NRCEPA jointly funded survey of sludge and ash to aness the need for NRC rulemaking was considered. The industry representatives sta i their continued interest in a joint NRCEPA guidance document addressing retentration of radioactive material at POTWs. Further meetings with AMSA and WEF may be held to discuss the details of the NRCEPA survey and the contents of the joint guidance.

The sewage sludge / ash survey is being coordinated by a subcommittee of the interagency Steering Committee on Radiation Standards (ISCORS). ISCORS was formed in 1995 to coordinate resolution of interagency issues. The ISCORS Sewage p

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Subcommittee is awisting NRC and EPA in the development of the survey, including i

sample collection and analysis procedures and the selection of facilities to sample.

i The NRC contractor, the U.S. Department of Energy's Oak Rxige institute for Science g

and Education (ORISE), in Oak Ridge, Tennessee 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 provided input on the i

survey design. For example, ORISE collaborated with NAREL to ensure that the analytical laboratory procedures and quality assurance programs that both labs will i

use will produce consistent, accurate, and reliable measurements.

An opportunity to comment on the information collection requirements in this survey is being provided in the Federal Reaister notice published for this clearance request.

j g.

Payment or Gift to Respondents The POTWs will not receive payments or gifts; however, they will receive the results of the NRC/ EPA analysis of sewage sludge and ash samples from their POTWs.

Assuming an average of two samples analyzed per POTW, the analysis for each l

POTW is worth about two thousand dollars. The results will be provided to the POTWs in a joint NRC/ EPA report.

10. Confidentiality of the,Information Each POTW will be assigned a code number to ensure confidentiality. Only several EPA staff will krow the identity of the POTW code numbers. Only individuals with a need to know will be given access to the identity of a POTW if an NRC or Agreement State licensee is likely responsible for elevated levels of radioactive materials at a POTW and follow-up testing becomes desirable.

11. Justification for Sensitive Questions There will be no survey questions of a sensitive nature, j

12. Estimated Burden and Burden Hour Cost i

About 600 POTWs will be asked to complete the survey questionnaire. Because the survey is voluntary (and thus not all POTWs will respond to the questionnaire),

additional POTWs may have to be surveyed to find enough appropriate facilities to be sent sample collection packages. The estimated time to complete the questionnaire is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. For 600 POTWs, the estimated burden would be 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />.

The questionnaire to the POTWs will ask for the zip codes for its collection system so we can identify the licensees associated with each POTW. NRC will request from each Agreement State (depending on its information retrieval capabilities) (a) a list of licensees by zip code or (2) the list of all licensees (so that NRC can determine the licensees in the zip codes for the POTW collection systems). For 29 Agreement States at 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per State, the estimated burden would be 232 hours0.00269 days <br />0.0644 hours <br />3.835979e-4 weeks <br />8.8276e-5 months <br />.

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Based on the method discussed in items B.1 and B.2, about 300 POTWs will be sent sample collection packages. Each POTW will collect an average of two samples.

I The estimated time for each POT'N to collect and retum the two samples is 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

l For 300 POTWs, the estimated burden is 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />.

Total estimated burden = 1200 + 232 + 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> = 3232 hours0.0374 days <br />0.898 hours <br />0.00534 weeks <br />0.00123 months <br /> i

j Estimated cost - 3232 hours0.0374 days <br />0.898 hours <br />0.00534 weeks <br />0.00123 months <br /> x $120/ hour = $387,840 l

4 Test cases are being run with up to nine POTWs to assess the questionnaire and sampling and analysis procedures. The test cases will also give a better basis for estimating the actual burden hour cost.

13. Estimate of Other Additional Costs 4

4 There will be no additional cost burdens (beyond the cost of the hour burden discussed above) to the PO1Ws. There is no need to purchase additional equipment or laboratory support. For respondents to this survey, it is most likely that purchases i

of equipment and services were made (1) prior to October 1,1995, (2) to achieve j

regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the a

govemment, or (4) as part of customary and usual business or private practices.

1 i

14. Estimated Cost to the Federal and State Govemments l

The cost to the Federal Govemment for this one-time-only survey includes costs for contractor support for the radioanalytical analysis, NRC and EPA Headquarters staffs, i

and Agreement State support.

l Cost for Radioanalvtical Support f

Radioanalytical support will be provided by NRC's contractor, ORISE and EPA's NAREL. ORISE will assemble and distribute sample collection packages to about 300 i

POTWs. ORISE and NAREL will each analyze about half the samples to determine i

the activity of radionuclides. No purchase of computers, software, or monitoring or testing equipment is needed. Monthly letter reports will be prepared containing the

{

results of the analysis.

i i

j b

4 i

Tasks ORISE Cost EPA /NAREL Cost Assist NRC and EPA in development 13,500 12,000 of the survey, including test cases Mail sample collection packages and 33,140 0

i provide retum postage Analyze samples 190,470 134,280 Report preparation 11,800 9,750 Sample disposition 0

10,000 Subtotal 248,910 166,030 Federal Govemment Cost I

NRC Headquarters staff will coordinate the development of the survey and analyze the survey results. The need for a contractor to support this analysis is currently under consideration. NRC, EPA, ORISE, and NAREL staff will write and publish the results as a joint NRC/ EPA report. There will also be costs incurred by NRC and EPA i

for contract management and general oversight of the work scope.

2 FTE x 2080 hours0.0241 days <br />0.578 hours <br />0.00344 weeks <br />7.9144e-4 months <br /> x $120/ hour = $499,200 t

Aareement State Cost j

See item 12, Estimated Burden and Burden Hour Cost, above.

j Total estimated survey cost Lab + Federal costs = $248,910 + $166,030 + $499,200 = $914,140

15. Reasons for Chanaes in Burden or Cost This is a new collection. There are no changes in burden or cost.

4

16. Publication for Statistical Use 4

i NRC, EPA, ORISE, and NAREL will jointly write a report summarizing the survey results. The database in the report will include, at a minimum, lists of radionuclide concentrations for each POTW (coded to disguise the names of the facilities),

geographic region, and disposal practice.

l The project is to be completed within two years of approval by OMB. Questionnaires will be sent to the POTWs within two months of OMB approval, sample collection will take place over a one-year period, from 6 to 18 months after OMB approval, and the final report will be published two years after OMB approval.

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17. Reason for Not Displavina the Exoiration Date Not applicable. The expiration date will isa dieplayed.

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18. Exceptions to the Certification Statement There are no exceptions.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS The desire is to provide a national survey of levels of radioactive materials in sewage sludge and ash. Even though this is a voluntary survey and may lack the number of samples needed to generate a comprehensive national profile, the survey will sample POTWs in all regions of the country and for a variety of NRC/ Agreement State licensees. The collection of information will employ statistical methods.

1. There are approximately 11,000 POTWs in the United States that use at least secondary waste water treatment and are not simple pond treatment systems with only periodic solids cleanout.. For the 1980s national survey, EPA developed categories based on flow rate and sewage sludge use and disposal practice. For the planned NRC/ EPA survey, we will build on the efforts of the 1980s survey by first sending questionnaires to the 479 POTWs selected to receive the questionnaire in the 1980s survey. This set of POTWs was drawn mostly from POTWs with higher average daily flow rates, which suggests a higher percentage of industrial users and thus a greater likelihood of receiving pollutants. Questionnaires will also be sent to POTWs associated with types of NRC licensees that have had sewer reconcentration problems in the past (for example, nuclear laundries and nuclear pharmacies).

POTWs with incinerators will be more heavily sampled because concentrations of radioactive material are expected to be higher in ash than in sludge. Finally, POTWs will be sampled in all geographic areas of the contiguous United States, and especially in areas of relatively h.igh background radioactivity.

The survey questionnaire will ask the POTW operator to list the zip codes served by its collection system. Using this information, NRC will identify those licensees

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associated with each POTW that have the potential to dispose of radioactive material j

into its collection system.

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There are currently approximately 7,000 NRC licensees and 15,000 Agreement State i

licensees in the United States (including Alaska and Hawaii, the District of Columbia and Puerto Rico). About half of these facilities use radioactive materials in the form of sealed sources (i.e., contained within a metal or other material casing); radioactive i

material in sealed sources cannot be disposed into the sewer system. Facilities that use material in unsealed form are predominantly hospitals, clinics, radiopharmacies, research and academic facilities, fuel cycle facilities, and research reactors. Nuclear power plants are not allowed to discharge to sewer systems.

, 2. The final sample design will be based on the retums of the questionnaire. After the questionnaires are retumed, the responses will be grouped into several categones and a random sample will be selected from each category. The categories we expect i

are Types of NRC licensees (e.g., industrial, academic, medical)

Geographic area, especially areas of high background radioactive material Sludge use or disposal practice (e.g., incinerator ash, landfill)

Flow rate j

These results will be used to determine (1) the 300 POTWs to sample and (2) when the POTWs will be sampled. Sampling will take place over a one-year period to i

assess seasonal variations.

i Potential problems include a low response rate and difficulty in finding sufficient sample respondents for each category.

3. The following actions should lead to improved response rates:

A short and easy to complete questionnaire A cover letter clearly stating the objectives of the data collection effort Development of a program to follow up on non-respondents

4. A pilot survey of nine POTWs is being executed to test the questionnaire and the sampling and laboratory analysis procedures.

l

5. Statistician consulted for the statistical aspects of the survey design:

Lee Abramson U.S. Nuclear Regulatory Commission 1

301-415-6180

Attachment:

Survey letter with questionnaire i

i