iii

ABSTRACT

From 1998 to 2000, through the Interagency Steering Committee on Radiation Standards

(ISCORS), the U.S. Nuclear Regulatory Commission (NRC) and the U.S. Environmental

Protection Agency (EPA) conducted a joint survey (hereafter referred to as the ISCORS sewer

survey) to collect information on radioactivity in sewage sludge and ash from sewage treatment

plants referred to in the industry as publicly owned treatment works (POTWs). 

The objectives of the survey were to (1) obtain national estimates of high-probability

occurrences of elevated levels of radioactive materials in sludge and ash at POTWs, 

(2) estimate how much radioactive contamination comes from NRC and Agreement State

licensees and how much from naturally occurring radioactivity, and (3) support rulemaking

decisions by NRC and EPA.

The voluntary survey had two components: a questionnaire and a program for sampling and

analyzing sewage sludge and incinerator ash. Questionnaires were sent to 631 POTWs,

requesting information regarding wastewater sources, wastewater and sludge treatment

processes, and sewage sludge disposal practices. Using the information from the 420 returned

questionnaires, NRC and EPA selected 313 POTWs to be sampled. The selection emphasized

POTWs with the greatest potential to receive waste from licensees and in areas with higher

levels of naturally occurring radioactive material (NORM). Altogether 311 sewage sludge

samples and 35 ash samples were taken. Approximately half of the samples were analyzed by

the U.S. Department of Energy’s Oak Ridge Institute for Science and Education (ORISE) in

Oak Ridge, Tennessee, under contract to NRC, and the remainder were analyzed by the EPA's

National Air and Radiation Environmental Laboratory (NAREL) in Montgomery, Alabama. 

The results of the analyses revealed that samples primarily contained NORM such as radium. 

With the exception of NORM, most other samples were at or near the limit of detection. Based

on the results obtained, ISCORS found that the levels are generally comparable to what is

found in other media (e.g. soil and fertilizer). The specific results of the analyses and data

obtained by the questionnaire are discussed in detail in this report. 

The survey and the sampling and analysis program results respond, in part, to the

recommendations of the 1994 GAO report (GAO/RCED-94-133) that the NRC estimate the

occurrence of elevated levels of radioactive materials at POTWs. The Subcommittee is

preparing several supplemental reports (both to be published in final form after public review

and comment). The first is a dose assessment report that describes exposure scenarios for

sewage sludge processing, use, and disposal. The parameters used in the dose modeling for

the scenarios and the dose conversion factors calculated for each radionuclide detected are

included. A second report provides recommendations for POTW operators on determining

sources of radioactivity at POTWs, describe sampling and analysis procedures, and suggest

alternative courses of action if circumstances (e.g. location in a high NORM area) or actual

measurements indicate that a problem may exist. The reports and laboratory data used in the

sewage sludge analyses can be publicly accessed at http://www.iscors.org/.
v

CONTENTS

ASTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

ACKNOWLEDGMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . x

ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi

1 INTRODUCTION ......................................................1

1.1 Congressional Interest ..............................................1

1.2 POTW Industry Interest .............................................1

1.3 Sources of Radioactivity at POTWs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.4 Federal Agency Regulations and Guidance ..............................2

1.5 1998/2000 Sewage Sludge Survey .....................................3

2 SURVEY DESIGN AND IMPLEMENTATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

2.1 Survey Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

2.2 Questionnaire Phase ...............................................4

2.3 Sampling Phase . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

2.3.1 POTW Selection Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

2.3.2 Sample Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

2.3.3 General Analytical Procedures .................................7

2.3.4 Sampling and Data Quality Limitations ...........................8

3 QUESTIONNAIRE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

3.1 Characteristics of the Population of 313 POTWs . . . . . . . . . . . . . . . . . . . . . . . . . 10

4 RADIOACTIVITY DATA ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

4.1 Summary of Concentrations of Radionuclides in Sewage and Ash . . . . . . . . . . . . 13

4.2 Comparison of Radioactivity in Sewage Sludge and Ash to Radioactivity in

 Other Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

4.3 Correlation Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

4.4 Association of Questionnaire Responses with Radionuclide Concentrations . . . . 20

4.5 Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

4.5.1 Physiographic Divisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

4.5.2 Primary Source of Drinking Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

4.5.3 Average Daily Flow . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

APPENDIX A

Radiological Analysis Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

APPENDIX B

Supporting Statement for Joint NRC/EPA Survey of Sewage 

 Sludge/Ash . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1
vi

APPENDIX C

Sewage Sludge Questionnaire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1

APPENDIX D 

Quality Assurance Project Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1

Figures

Figure 1 POTWs Located by Geographic Division ..............................7

Figure D.1 Alpha Analysis Decision Tree . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-8

Figure D.2 Beta Analysis Decision Tree . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-9

Figure D.3 Gamma Analysis Decision Tree . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-10

Figure D.4 Comparison of Critical Level to Detection Limit . . . . . . . . . . . . . . . . . . . . . . D-11

Figure D.5 Data Flow Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-29

Figure D.6 RISSAD Data Handling Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-37

Tables

Table 2.1 Samples from POTWS in Each Physiographic Region ...................6

Table 3.1 Summary of Survey Questionnaire Responses of 313 Facilities Samples . . . . 11

Table 4.1 Summary of Concentrations of Detected Radionuclides in Sludge . . . . . . . . . . 14

Table 4.2 Summary of Concentrations of Detected Radionuclides in Ash . . . . . . . . . . . . 15

Table 4.3 Survey Concentration Ranges and Typical U.S. Background Concentrations of 

 Radionuclides in Soil, Fertilizer, and Common Building Materials . . . . . . . . . 17

Table 4.4 Expected Groupings/Clustering of Radionuclides Based on Process and 

 Degradation Relationships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

Table 4.5 Summary of Direction of Effect for Questionnaire Response less Predictive for 

 Radionuclide Concentration in Sludge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Table 4.6 Relationships of Physiographic Division to Concentrations of Radionuclides in 

 Sludge Samples . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Table 4.7 Relationships of Primary Drinking Water Source to the Relative Concentration 

 of Radionuclides . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Table 4.8 Effect of Average Daily Flow on Radionuclide Concentration . . . . . . . . . . . . . . 24

Table A.1 Concentrations of Radionuclides in Sludge Summarized 

 by Geographic Division . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

Table A.2 Concentrations of Radionuclides in Ash Summarized by Geographic

 Division . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-14

Table A.3 Concentrations of Radionuclides in Sludge Summarized by Level(s) of 

Wastewater Treatment Achieved by POTW . . . . . . . . . . . . . . . . . . . . . . . . A-27

Table A.4 Concentrations of Radionuclides in Ash Summarized by Level(s) of Wastewater 

 Treatment Achieved by POTW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-39

Table A.5 Concentrations of Radionuclides in Sludge Summarized by Annual Average

 Flow Rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-51

Table A.6 Concentrations of Radionuclides in Ash Summarized by Annual Average 

 Flow Rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-57

Table A.7 Concentrations of Radionuclides in Sludge Summarized by Primary Sources of

 Drinking Water for Your Community . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-63

Table A.8 Concentrations of Radionuclides in Ash Summarized by Primary Sources of

 Drinking Water for Your Community . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-78
vii

Table A.9 Concentrations of Radionuclides in Sludge Summarized by Receipt of 

Discharges of Drinking Water Treatment Residuals . . . . . . . . . . . . . . . . . . A-87

Table A.10 Concentrations of Radionuclides in Ash Summarized by Receipt of Discharges

 of Drinking Water Treatment Residuals . . . . . . . . . . . . . . . . . . . . . . . . . . . A-91

Table A.11 Concentrations of Radionuclides in Sludge Summarized by Whether or Not the 

 POTW has Combined Sanitary and Storm Water Sewers . . . . . . . . . . . . A-94

Table A.12 Concentrations of Radionuclides in Ash Summarized by Whether or Not the

 POTW has Combined Sanitary and Storm Water Sewers . . . . . . . . . . . . . A-97

Table A.13 Concentrations of Radionuclides in Sludge Summarized by Receipt of Sludge 

from other POTWs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-100

Table A.14 Concentrations of Radionuclides in Ash Summarized by Receipt of Ash from 

other POTWs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-103

Table A.15 Concentrations of Radionuclides in Sludge Summarized by Receipt of Septage 

 for Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-106

Table A.16 Concentrations of Radionuclides in Ash Summarized by Receipt of Septage

 for Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-110

Table A.17 Concentrations of Radionuclides in Sludge Summarized by Percentage of 

Industrial Annual Average Daily Total Flow Rate . . . . . . . . . . . . . . . . . . . . A-114

Table A.18 Concentrations of Radionuclides in Ash Summarized by Percentage of 

 Industrial Annual Average Daily Total Flow Rate . . . . . . . . . . . . . . . . . . . A-118

Table A.19 Concentrations of Radionuclides in Sludge Summarized by Number of Final

 Sewage Sludge Production Facility Locations . . . . . . . . . . . . . . . . . . . . . A-122

Table A.20 Concentrations of Radionuclides in Ash Summarized by Number of Final 

 Sewage Sludge Production Facility Locations . . . . . . . . . . . . . . . . . . . . . A-125

Table D.1 Format of Monthly Data Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-16

Table D.2 Minimum Detectable Concentrations for Selected Gamma Emitters . . . . . . D-20

Table D.3 Minimum Detectable Concentrations for Selected Radionuclides . . . . . . . . D-21

Table D.4 NAREL Data Handling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-31

Table D.5 ORISE Data Handling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-32
ix

FOREWORD

This report is prepared in response to a May 1994 U.S. General Accounting Office (GAO)

report, “Nuclear Regulation: Action Needed to Control Radioactive Contamination at Sewage

Treatment Plants” (GAO/RCED-94-133), and Congressional interest expressed in joint

House/Senate hearings. Through the Interagency Steering Committee on Radiation Standards

(ISCORS)*, the U.S. Nuclear Regulatory Commission (NRC) and the U.S. Environmental

Protection Agency (EPA) conducted a survey of radioactivity in sewage sludge and ash from

publicly owned treatment works (POTWs) to determine whether the public’s health and safety

and the environment are being adequately protected. The objectives of the survey were to

(1) obtain national estimates of high-probability occurrences of elevated levels of radioactive

materials in sludge and ash at POTWs, (2) estimate the extent to which radioactive

contamination comes from either NRC/Agreement State licensees or naturally occurring

radioactivity, and (3) support rulemaking decisions by NRC and EPA.

The sewage sludge/ash survey was coordinated by a subcommittee of ISCORS. The Sewage

Sludge Subcommittee was formed in 1995 to coordinate efforts to address the

recommendations of the 1994 GAO report. 

This report summarizes the information collected in the survey and developed through the

analysis of samples. It also presents the sampling results in a series of tables broken down

with respect to the characteristics of classes of POTWs that participated in the survey. 

Companion reports address the significance of the measured values of radionuclides present in

sewage sludge and ash and provide recommendations for POTW operators on how to deal with

any potential future problems. 

Farouk Eltawila, Director

Division of Systems Analysis and Regulatory 

 Effectiveness

Office of Nuclear Regulatory Research

 *ISCORS was formed in 1994 to address inconsistencies, gaps, and overlaps in current radiation

protection standards. ISCORS is co-chaired by representatives of the NRC and the EPA, and includes

representation by the Department of Defense, the Department of Energy, the Department of Labor’s

Occupational Safety and Health Administration, the Department of Transportation, and the Department

of Health and Human Services. Representatives of the Office of Management and Budget, the Office of

Science and Technology Policy, and various State and local regulatory agencies are observers at

ISCORS meetings. 
x

ACKNOWLEDGMENTS

The Sewage Sludge Subcommittee of the federal ISCORS (1) conducted a survey to collect

information concerning radioactive materials in sewage sludge and ash from POTWs; 

(2) performed dose modeling to help with the interpretation of the results of the survey; and 

(3) developed a guidance on radioactive materials in sewage sludge and ash for POTW owners

and operators. Sewage Sludge Subcommittee members who actively participated in the

development of the three reports associated with this project include (listed alphabetically):

Lee Abramson, NRC/Office of Nuclear Regulatory Research

Kevin Aiello, Middlesex County (New Jersey) Utilities Authority

James Bachmaier, DOE/Office of Environment, Safety and Health

Bob Bastian, EPA/Office of Wastewater Management

Lydia Chang, NRC/Office of Nuclear Material Safety and Safeguards

Weihsueh Chiu, EPA/Office of Research and Development

Chris Daily, NRC/Office of Nuclear Regulatory Research

Mark Doehnert, EPA/Office of Radiation and Indoor Air

Giorgio Gnugnoli, NRC/Office of Nuclear Material Safety and Safeguards

Paula Goode, EPA/EPA/Office of Radiation and Indoor Air

Jenny Goodman, New Jersey Department of Environmental Protection

Dale Hoffmeyer, EPA/Office of Radiation and Indoor Air

Rosemary Hogan, NRC/Office of Nuclear Regulatory Research

Anthony Huffert, NRC/Office of Nuclear Material Safety and Safeguards

Andrea Jones, NRC/Office of Nuclear Regulatory Research

Tom Lenhart, Northeast Ohio Regional Sewer District

Jill Lipoti, New Jersey Department of Environmental Protection

Roy Lovett, Department of Defense

Tin Mo, NRC/Office of Nuclear Regulatory Research

Donna Moser, NRC/Region II, Division of Nuclear Materials Safety

Robert Neel, NRC/Office of Nuclear Material Safety and Safeguards

Bob Nelson, NRC/Office of Nuclear Material Safety and Safeguards

Tom Nicholson, NRC/Office of Nuclear Regulatory Research

Tom O’Brien, NRC/Office of State and Tribal Programs

Judy Odoulamy, DOE/Office of General Counsel

William R. Ott, NRC/Office of Nuclear Regulatory Research

Hal Peterson, DOE/Office of Environment, Safety and Health

Alan Rubin, EPA/Office of Science and Technology

Steve Salomon, NRC/Office of State and Tribal Programs

Patricia Santiago, NRC/Office of Nuclear Material Safety and Safeguards

Dave Saunders, EPA/National Air and Radiation Environmental Laboratory

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/National Air and Radiation Environmental Laboratory

Mary Thomas, NRC/RIII, Division of Nuclear Materials 

Mary Wisdom, EPA/National Air and Radiation Environmental Laboratory

Anthony Wolbarst, EPA/Office of Radiation and Indoor Air
xi

ABBREVIATIONS

Am-241 americium-241

AMSA Association of Metropolitan Sewerage Agencies

Be-7 beryllium-7

Bi-212/214 bismuth-212/214

Bq becquerel

C-14 carbon-14

Ce-141 cerium-141

Ci curie

CFR Code of Federal Regulations

Co-57/60 cobalt-57/60

Cr-51 chromium-51

Cs-137 cesium-137

CWNS Clean Water Needs Survey

EHA Environmental Health Associates

EPA U.S. Environmental Protection Agency

Eu-154 europium-154

Fe-59 iron-59 

FR Federal Register

GAO General Accounting Office

GBq gigabecquerel

ISCORS Interagency Steering Committee on Radiation Standards

ICR information collection request

H-3 hydrogen-3 (tritium)

I-125/131 iodine-125/131

In-111 indium-111

K-40 potassium-40

kg kilogram

La-138 lanthanum-138

MDC minimum detectable concentration

MGD million gallons per day

NAREL National Air and Radiation Environmental Laboratory

NCRP National Council on Radiation Protection

ND not detected

NORM Naturally Occurring Radioactive Material

NPDES National Pollution Discharge Elimination System

NR not reported

NRC U.S. Nuclear Regulatory Commission

NSSS National Sewage Sludge Survey

OMB U.S. Office of Management and Budget

ORIA Office of Radiation and Indoor Air

P probability

Pa-234 protactinium-234

Pb-210/214 lead-210/214

PCS Permit Compliance System

PE Performance Evaluation
xii

ABBREVIATIONS (con’t)

pCi picocurie

POTWs publicly owned treatment works

QAPP Quality Assur0ance Project Plan

Ra-228 radium-228

Sm-153 samarium-153

Sr-89 strontium-89

Th-227/228/230 thorium-227/230

Tl-201/208 thalium-201/208

U-234/235/238 uranium-234/235/2388

U.S. United States

Pu-238/239 plutonium-238/239

Rn-219 radon-219

Sm-153 samarium-153

Sr-89/90 strontium-89/90

WEF Water Environment Federation

Zn-65 zinc-65
1

1 INTRODUCTION

1.1 Congressional Interest

This survey responds, in part, to recommendations in the 1994 General Accounting Office

(GAO) report, Nuclear Regulation: Action Needed to Control Radioactive Contamination at

Sewage Treatment Plants” (GAO/RCED-94-133). The GAO report recommended that NRC

determine the extent to which radioactive contamination of sewage sludge, ash, and related

byproducts from sewage treatment plants is occurring; directly notify the treatment plants that

receive discharges from NRC’s and the Agreement State’s licensees of the potential for

radioactive contamination because of the concentration of radioactive materials and of the

possibility that the plants may need to test or monitor their sludge for radioactive content; and

establish acceptable limits for radioactivity in sludge, ash, and related byproducts to protect the

health and safety of treatment workers and the public.

A joint House/Senate hearing was held in 1994 to officially release and address questions

raised in the GAO report. The hearing (U.S. Congress,1994) was prompted by concerns

associated with elevated levels of radioactivity in incinerator ash at a major sewage treatment

plant in the Cleveland, Ohio, area. The GAO stated that, over the past 20 years, NRC had

documented elevated levels of radioactivity in sewage sludge or sludge incinerator ash from

certain publicly owned treatment works (POTWs). There had been no national surveys of

radiation levels present in sewage sludge or sludge incinerator ash to determine the extent of

potential radioactive contamination.

On the basis of limited information on radiation levels in sewage sludge and ash across the

country, GAO concluded that reconcentration of radionuclides may have been associated with

authorized effluent releases from both NRC and Agreement State licensees (GAO documented

this information and used it as a basis for its 1994 report). However, these problems occurred

prior to revisions to NRC’s regulations with regard to releases from NRC licensees which 

became effective in 1991.

1.2 POTW Industry Interest

In 1996, the Association of Metropolitan Sewerage Agencies (AMSA) conducted a limited, 

confidential, voluntary survey of concentrations of radioactivity in sewage sludge and ash

samples from some of its member POTWs. The objective was to develop a better estimate of

the concentration of radioactivity in sewage sludges and sludge incinerator ashes. Samples

from 55 wastewater treatment plants in 17 States were supplied voluntarily and analyzed for

radioactivity. These plants were distributed across the country and ranged in size from small to

some of the largest POTWs in the U.S. The most significant levels of radioactivity were the

potassium and radium isotopes, which are naturally occurring radioactive materials. 

1.3 Sources of Radioactivity at POTWs

Radionuclides are found naturally throughout the United States in varying concentrations

(Eisenbud and Gesell, 1997). Levels of naturally occurring radioactive materials (NORM) vary

throughout the States in soil and water used for drinking and industrial processes. Sewage

treatment facilities receive waste flows from residential, commercial, and industrial uses. 

NORM from industrial process and drinking water treatment residuals (e.g., filter backwash, ion
1

Industrial users of radioactive materials that hold active licenses from the NRC or a State which

licenses theses activities based on an agreement with the NRC.

2

exchange fluids) may be a source of radioactive material entering a POTW. Another possible

source of radioactivity at a POTW is the authorized release of man-made radioactive materials

into the sewer system by NRC and Agreement State licensees.1

 A major source of these

releases is radioactive materials used for medical diagnosis and treatment. Patient excreta

containing medical isotopes may contribute a significant fraction of the radioactive materials

released to sewer systems, but the significance would vary by location and by the facilities and

population served by the collection system. The removal and concentration of many

contaminants into residual solids by various processes used by POTWs and the reduction of

the volume of organic solids that contain these contaminants (e.g., by digestion or incineration

of sludge solids) can cause reconcentration of radioactive materials in the sewage treatment

facility's sewage sludge or ash.

Background information on the nature of radioactivity in sewage sludge can be found in NRC

reports 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), published in 1992 and 1994 respectively. Another useful background

document is a report entitled Radioactivity of Municipal Sludge” (EPA, 1986), issued by EPA

during the development of the first round of rulemaking for the 40 CFR Part 503 Biosolids Rule. 

Two useful publications on naturally occurring radioactive materials are Environmental

Radioactivity from Natural, Industrial, and Military Sources by Eisenbud and Gesell (1997) and

Evaluation of Guidelines for Exposures to Technologically Enhanced Naturally Occurring

Radioactive Materials” by the National Academy of Sciences (1999).

1.4 Federal Agency Regulations and Guidance

Federal and State regulations allow the disposal of specific amounts and concentrations of

radioactivity into sanitary sewer systems. 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 sewer systems. The current NRC

regulations in 10 CFR 20.2003 permit release of specific quantities of soluble material into a

sanitary sewer. Monthly average concentrations must not exceed the concentrations listed in

Table 3 of Appendix B to Part 20, and the total quantities released in a year must not exceed

185 gigabecquerel (GBq) (5 curies [Ci]) of H-3, 37 GBq (1 Ci) of C-14, and 37 GBq (1 Ci) of all

other radionuclides combined. These limits do not apply to excreta from patients undergoing

diagnosis or treatment with radioactive material.

The EPA technical standard for the use and disposal of sewage sludge (biosolids) in

40 CFR Part 503 does not include limits for radioactive material. Some POTW operators have

requested that EPA regulations address radioactive materials to provide a basis for POTWs to

restrict discharges of radioactive materials to the sewage collection system. 
3

1.5 1998–2000 Sewage Sludge Survey

Based on the 1994 GAO report recommendations, NRC and EPA decided to jointly fund a

voluntary survey of POTW sewage sludge and ash to help assess the potential need for NRC

and/or EPA regulatory decisions. While developing the information collection request (ICR) and

working with the U.S. Office of Management and Budget (OMB) to receive approval to conduct

the full survey, the agencies conducted a pilot study involving nine POTWs to field-test the

questionnaire for eliciting operating information from POTWs validate the sampling methods

and analytical procedures, and obtain feedback from the participating POTWs. The results of

the pilot study were summarized in a report issued jointly by NRC and EPA in 1999 

(EPA 833-R-99-900, May 1999). The final survey procedures were slightly refined based on the

experiences with the pilot test cases and public comments on the ICR submitted to OMB for

approval of the survey. The final survey began in 1998 when the questionnaires was sent to

631 POTWs. More than 66% of the POTWs (420) responded by returning completed

questionnaires. Sewage sludge and ash samples from approximately 25 POTWs per month

were collected and shipped to the survey labs for analyses between October 1999 and

November 2000. 
2

 EPA's Permit Compliance System (PCS) is the system used by EPA to track permits issued

under the NPDES (National Pollution Discharge Elimination System) Program, which controls water

pollution by regulating point sources that discharge effluents into waters of the U.S.

3 The 1996 Needs Survey is the latest available report to Congress on the estimated clean water

needs of the U.S. The survey is a product of the Clean Water Needs Survey (CWNS), which is a joint

effort by the States and EPA to provide information on POTW collection and treatment facilities in

response to §205(a) and §516(b)(1) of the Clean Water Act.

4

2 SURVEY DESIGN AND IMPLEMENTATION

2.1 Survey Objectives

The objectives of the sewage sludge/ash survey were to (1) obtain national estimates of highprobability occurrences of elevated levels of radioactive materials in sludge and ash at POTWs,

(2) estimate the extent to which radioactive contamination comes from either NRC/Agreement

State licensees or naturally occurring radioactivity, and (3) support rulemaking decisions by

NRC and EPA.

The important parameters of the survey are as follows (1) it is a voluntary survey, (2) only one

sample was collected at most POTWs at a single point in time, and (3) the survey was biased

to POTWs with the greatest potential to receive releases of radionuclides from NRC and

Agreement State licensees and to POTWs in areas of higher concentrations of NORM. The

reason for selecting POTWs for the survey was to obtain sufficient samples with radionuclides

above the minimum detection limits to allow some characterization of the levels and sources of

radioactivity and therefore, meet the objectives of this survey. The survey results are not a

statistically valid representation of radionuclide levels in sludge and ash nationwide. However,

the survey does provide a range for the possible concentrations of radionuclides in sludge and

ash nationwide.

2.2 Questionnaire Phase

The Subcommittee developed a questionnaire (Appendix C) to obtain information from POTWs

about their wastewater sources, wastewater and sludge treatment processes, and sewage

sludge disposal practices. The questionnaire also requested the ZIP codes for their collection

systems so that NRC could match licensees to their POTWs. NRC requested from each

Agreement State the names and addresses of licensees that could discharge to sewage

treatment facility sewer systems. The questionnaire was sent to 631 POTWs selected from the

more than 16,000 POTWs across the country. The Subcommittee used information from many

sources to identify POTWs with the greatest potential to receive radionuclides from licensees or

from naturally occurring sources. Information was obtained from the EPA regional offices,

EPA’s Permit Compliance System2

 and the 1996 NEEDS Survey,3 the NRC, the Association of

Metropolitan Sewerage Agencies (AMSA), the Water Environment Federation (WEF), the State

Water Pollution Control Programs and State Radiation Programs, Agreement State licensee

lists, and various State and Federal agency reports.
4

EHA has an NRC contract to manage the database survey.

5

2.3 Sampling Phase

2.3.1 POTW Selection Process

The data from the POTWs that responded to the questionnaire were entered into a database

developed and maintained by Environmental Health Associates (EHA)4

. Each month, the

Subcommittee Co-chairs selected 25 different POTWs from this database. The selection

process considered POTWs in one or more of the following categories:

1. All geographic areas of the U.S.

2. Recommended by States

3. High NORM areas as designated in the September 1998 EPA/Office of Radiation and Indoor 

 Air (ORIA) contractor report, Identification of POTWs for NORM Analysis”

4. Receive discharges from landfills (receiving landfill leachates) or Superfund or Federal 

 cleanup sites

5. Have (or used to have had) sludge incinerators

6. Different flow rates serving different size service areas

7. Sampled in the National Sewage Sludge Survey

8. Receive drinking water treatment plant residuals

9. Serve areas with industrial uses of radioactive materials likely to discharge to the sewer 

 system

Samples were obtained from POTWs in each of the 10 physiographic regions of the US 

(Table 2.1). The divisions were obtained from Fenneman and Johnson (1946). Figure 1 shows

the approximate geographic locations of the 313 POTWs sampled.
6

TABLE 2.1 Samples From POTWS in Each Physiographic Region

Physiographic Division No. of POTWs

Alaska 2

Appalachian Highlands 91

Atlantic Plain 58

Hawaii 4

Interior Highlands 4

Interior Plains 106

Intermontane Plateaus 18

Laurentian Upland 2

Pacific Mountain System 24

Rocky Mountain System 4

Total 313

2.3.2 Sample Collection

A list of selected POTWs for sample collection and analyses was sent to ORISE each month. 

ORISE assigned survey codes and sent sampling kits to the POTWs. This process was

repeated monthly to accommodate the workload at the laboratories. The POTW operators

collected the samples using containers and guidance provided to them in the sampling kit from

ORISE. The POTWs were instructed to follow procedures similar to those they use to take

routine samples for monitoring chemical pollutants. The samples were shipped to the

designated laboratory. ORISE maintained the key to the assigned codes to ensure anonymity

(a feature of the survey intended to encourage participation). The key was later transferred to

the data management contractors (EHA) to allow reporting back to the facilities of their

individual results. 
7

Figure 1 POTWs Located by Geographic Division

2.3.3 General Analytical Procedures

Sludge/ash analyses were performed by ORISE and EPA’s National Air and Radiation

Environmental Laboratory (NAREL) in Montgomery, Alabama. Each laboratory used approved

analytical procedures for routine environmental samples. The comparability of these

procedures was previously evaluated during the pilot study. Additional information on analytical

procedures is contained in the Quality Assurance Project Plan (QAPP) (Appendix D). The

laboratories screened operate under laboratory quality assurance/quality control programs and

participate in external performance evaluation (PE) programs. Quality assurance activities

conducted on the project included an audit conducted by U.S. EPA headquarters to assess

NAREL compliance with the QAPP. The audit concluded that activities relating to the QAPP

were in compliance. The laboratories screened samples using their standard procedures for

gross alpha, gross beta, and gamma spectrometry. Each month a minimum of 10% of the

sludge/ash samples that had gross alpha or gross beta activity detected were chosen for
8

radionuclide-specific analysis. The specific radionuclides analyzed were Sr-89, Sr-90, several

isotopes of thorium and uranium, and their progeny, Pu-238, Pu-239, and Am-241. These

radionuclides are of specific interest because of their potential presence in sewage sludge and

ash. The isotopes of uranium and thorium are present in rock in the earth and leach into

surface waters on the earth by natural processes such as erosion after rain and floods. Such

radionuclides are referred to as NORM. Uranium and plutonium may be found in the effluents

of nuclear fuel processing facilities. Certain radionuclides are commonly used in medical

procedures including Co-57, Cr-51, In-111, I-125, I-131, Sm-153, Sr-89, Tl-201, and Tl-202. All

detectable radionuclides were decay corrected to the time of the sample collection. 

Uncertainties were rounded to one significant figure. Concentrations were rounded to the same

decimal place as the corresponding uncertainty. 

2.3.4 Sampling and Data Quality Limitations

The survey was not random. It was biased to favor those POTWs most likely to have

measurable levels of radioactivity. The survey was also voluntary and individual sewage

treatment facilities could choose not to participate. Because the survey was biased and

voluntary, statistical inference and probability cannot be used to interpret the results as

representative of radionuclide levels in sludge and ash nationwide. The survey was designed to

obtain data on the levels of radioactivity in sludge and ash at POTWs from across the country

emphasizing POTWs with the greatest potential to have detectable levels of radioactive

materials.

Use of this data to characterize sewage sludge at a particular POTW is inappropriate. The

results cannot be used to make any conclusions about the levels of radioactive materials in

sewage sludge and ash products over a longer period of time, nor can the results be used to

determine whether any of the measured results were in fact levels that occurred only for a

shorter period of time. This would require a much more extensive survey focused on individual

POTWs of interest. 

Some facilities have more than one type of sewage sludge product (e.g., liquid slurry,

dewatered cake, compost, heat dried pellets). These facilities were requested to send a

sample for each of their final products. Thirty-five POTWs sent ash samples resulting from

incineration of their sewage sludge. No samples were lost in transit or during analysis, and no

resampling was conducted. In total, sludge or ash samples from 313 POTWs (2 of which sent

only an ash sample) were analyzed, and these results were included in all further data analyses

conducted in this study.

The greatest uncertainty in the survey results is probably due to the field sample design. 

Specifically, the field sample design did not assess the variability over spatial and temporal

boundaries either at a particular POTW or over all POTWs or groups of POTWs. Field

uncertainty was not controlled more closely because of the voluntary participation by the

POTWs and because of a small number of samples and because the POTWs particpated

voluntarily and did the sampling. The field sample design uncertainty was not estimated and

quantitative values are not provided. 

With respect to the actual field sampling procedures used and the representativeness of each

sample, there was control in that the field sampling procedures provided to the POTWs were
9

based on the same procedures that POTWs use for compliance with the 40 CFR Part 503

Biosolids Rule (EPA, November 9, 1990). Only basic assumptions can be made about the

representativeness of a particular sample because the sample collection is based on the

judgement of the POTW operator who took the samples and on the processes sampled. Since

each POTW collected its own samples, a higher field sampling variability was expected than if

one organization collected all samples. There is also the possibility of intrasample variability,

which is more significant for certain analyses such as alpha spectrometry.

Sources of field uncertainty include sample shipping error and sample contamination (e.g.,

cross-contamination) but are assumed to be minimal. Seals and chain of custody were used

(see QAPP, Appendix D), and radioactivity likely to be the source of cross contamination was

controlled by transportation regulations. The likelihood of field bias is low because the sample

procedures are based on the same procedures that POTWs use for their routine regulatory

compliance sampling. Likelihood of field sampling loss is low because the likelihood of sample

loss (e.g., volatiles) is low for most radionuclides.

The field results are not reproducible individually, especially if there is variability of radioactivity

concentration over space and/or time. However, in the aggregate, they are considered to be

representative of the upper range of the distribution of values of radionuclide concentrations in

sludge and ash. The lab results were designed to be reproducible and comparable (a major

objective of the pilot study discussed in Section 1.5 of this document).
10

3 QUESTIONNAIRE SUMMARY

The Radiological Survey Questionnaire is reproduced in Appendix C. While 420 POTWs

responded to the survey, only 313 facilities actually supplied sludge and/or ash samples. 

Responses to the survey questionnaire from these 313 POTWs are summarized in table format

(see Table 3.1) to provide a detailed description of the population of POTWs that participated in

the full survey.

3.1 Characteristics of the Population of 313 POTWs

Although not a statistically valid representation of the more than 16,000 POTWs in operation in

the U.S. the population of 313 POTWs generally exhibits characteristics that are typical of

POTWs serving most areas of the country. The majority of the 313 POTWs in the survey

(86%) employ at least a secondary level of treatment of the wastewater stream. Many (nearly

40%) employ advanced treatment techniques. Most of the POTWs are small or medium sized. 

Approximately half of the POTWs reported a flow rate of 10 million gallons per day (MGD) or

less. Only 15 of the 313 POTWs indicated that they treat greater than 100 MGD. This size

range is comparable to that of the POTWs nationwide, where approximately 97% treat 10 MGD

or less, and less than 1% have a capacity of 100 MGD or greater. Over 90% of the POTWs

state that the industrial component of the wastewater stream is less than 50%. Approximately

30% of the POTWs have combined sanitary and storm water collection systems.
11

TABLE 3.1 Summary of Survey Questionnaire Responses of 313 Facilities Sampled

Treatment level

Primary 180

Secondary 271

Advanced 121

Flow Rate

10 MGD or less 153

More than 10 MGD, less than/equal to 50 MGD 96

More than 50 MGD, less than/equal to 100 MGD 30

Greater than 100 MGD 15

No response/no units reported 19

Treatment Process

No processing in the last 12 months 7

Thickening 239

Mechanical dewatering 239

Heat treatment/wet air oxidation 12

Aerobic digestion 64

Anaerobic digestion 146

Composting 32

Lime stabilization 34

Alkaline stabilization 16

Air drying beds 37

Heat drying/pelletizing 6

Sewage sludge treatment/storage lagoon(s) 29

Sewage sludge storage bins or piles 44

Incineration 54

Other sewage sludge treatment processes 24

Use and Disposal Practice

Land application 175

Surface disposal 21

Disposal in municipal solid waste landfill 130

Transfer to another facility 60

Other disposal 35

No Response 1

Primary Drinking Water Source

Municipal water supply from surface water(s) 193

Municipal water supply from groundwater well(s) 166

Private wells 54

Private water supply from surface water source(s) 19

No Response 3
12

TABLE 3.1 Summary of Survey Questionnaire Responses of 313

Facilities Sampled (con’t)

Receive Discharges of Drinking Water Residuals

Yes 102

No 208

No response 3

Combined Sanitary and Storm Water Sewers

Yes 94

No 219

Receive Sludge From Other Facilities for Processing

Yes 80

No 233

Receive Septage

Yes 187

No 120

No response 6

Percentage of Annual Average Daily Flow Rate That Is Industrial

Less than 50% 285

50% or greater 15

No response/unknown 13

Have Previously Tested for Radioactive Materials

Yes 61

No 249

No response 3

More Than One Final Sewage Sludge Production Facility

Yes 32

No 281

State Recommendation From Request in State Letter (NRC, 1998)

Yes 64

No 249

Located in High NORM Area From EPA/ORIA report,

Identification of POTWs for NORM Analysis” (EPA, 1998)

Yes 89

No 224

Potentially Receives From Landfill, SUPERFUND, or Federal Cleanup Sites

Yes 28

No 285

Participated in National Sewage Sludge Survey

Yes 87

No 226
13

4 RADIOACTIVITY DATA ANALYSIS

4.1 Summary of Concentrations of Radionuclides in Sewage Sludge and Ash

After the data were entered into the database, summary statistics (including median, minimum

and maximum detected concentrations, 95th percentile, and frequency of detection) were

calculated for each radionuclide in each sampled medium (ash and sludge). Negative

concentrations were treated as not detected for these calculations. In cases where there was

an even number of analyses and the median fell between a nondetected (ND) and detected

concentration, a range was reported. For example, the results of a set of four analyses were

(ND, ND, 5, and 7), the median would be reported as “ND to 5." The minimum detectable

concentration (MDC) of a radionuclide in a sample is the smallest concentration of analyte

expressed in this study as pCi/g (1 pCi/g = 37 Bq/kg) of sludge or ash that produces a signal

with a 95% confidence of exceeding a decision (detection) level. Finally, the number of times a

radionuclide was detected relative to the total number of analyses is listed to provide for a more

complete perspective for interpreting the results. These summary statistics presented in 

Tables 4.1 and 4.2 allow the reader to examine patterns of occurrence. 

No widespread or nationwide public health concern was identified by the survey because no

significant adverse condition or excessive concentrations of radioactivity were observed in

sludge or ash. The survey was not designed to identify unique or isolated instances in which

high levels of radionuclides may be present in sewage sludge or ash, and inferences to high

levels of radionuclides cannot be made from the survey results alone (see Section 3.4.4). The

dose modeling report, survey results and recommendations will provide information that may be

useful in making decisions as to site-specific sampling or testing.
14

Table 4.1 Concentrations of Radionuclides in Sludge: 

All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.

Radionuclide Min Median 95th P Max No. Detects/

No. Analyses

Alpha ND 7 34 137 309/311

Beta 1.7 13 34 93 311/311

Am-241 ND ND ND 2.5 10/311

Be-7 ND 1.2 9 22 263/311

Bi-212 ND ND 1.3 13 101/311

Bi-214 ND 0.3 2.3 16 238/311

C-14* ND ND 1 3 63/158

Ce-141 ND ND ND 0.016 1/311

Co-57 ND ND ND 0.26 6/311

Co-60 ND ND ND 5.1 13/311

Cr-51 ND ND ND 3.5 6/311

Cs-134 ND ND ND 0.04 1/311

Cs-137 ND ND 0.11 3.6 133/311

Eu-154 ND ND ND 21 1/311

Fe-59 ND ND ND 0.4 1/311

H-3* ND 0.3 5 8 111/158

I-125 ND ND ND 40 11/311

I-131 ND 1.8 51 840 246/311

In-111 ND ND 0.04 3.6 19/311

K-40 ND 4 12 26 308/311

La-138 ND ND ND 0.07 1/311

Pa-234m ND ND 7 27 80/311

Pb-210 ND ND 4 13 135/311

Pb-212 ND 0.44 1.9 15 303/311

Pb-214 ND 0.31 2.6 17 253/311

Pu-238 ND 0.01 0.07 0.19 75/92

Pu-239 ND 0.003 0.04 0.12 68/92

Ra-223 ND ND ND 0.09 2/311

Ra-224 ND ND 0.9 12 47/311

Ra-226 ND 2 13 47 289/311

Ra-228 ND 0.82 5.1 38 271/311

Rn-219 ND ND ND ND 0/311

Sm-153 ND ND ND 27 1/311

Sr-89 ND 0.35 20 70 68/98

Sr-90 ND 0.1 1 9.4 64/98

Th-227 ND ND 0.1 0.5 49/207

Th-228 0.07 0.605 4.1 9 92/92

Th-230 0.09 0.34 1 1.7 92/92

Th-232 0.02 0.2 0.6 1.6 92/92

Th-234 ND 0.6 6.7 23 191/311

Tl-201 ND ND 46 241 151/311

Tl-202 ND ND 0.53 1.16 73/311

Tl-208 ND 0.07 0.96 4.8 180/311

U-234 0.18 1.95 17 44 92/92

U-235 ND ND 0.45 3.1 112/311

U-238 0.18 1.4 12 26 92/92

Zn-65 ND ND ND 0.06 1/311

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
15

Table 4.2 Concentrations of Radionuclides in Ash:

All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.

Radionuclide Minimum Median 95th P Maximum No. Detects/

No. Analyses

Alpha 5 27 93 178 35/35

Beta 15 43 95 140 35/35

Am-241 ND ND ND 0.21 2/35

Be-7 ND 4.3 15.4 30 34/35

Bi-212 ND 1.2 3.5 15.7 25/35

Bi-214 ND 2.4 14 16 34/35

C-14* ND ND 1 1 5/18

Ce-141 ND ND ND ND 0/35

Co-57 ND ND ND 0.17 1/35

Co-60 ND ND ND 3.46 2/35

Cr-51 ND ND 0.3 35 5/35

Cs-134 ND ND ND ND 0/35

Cs-137 ND 0.07 0.23 0.37 34/35

Eu-154 ND ND ND ND 0/35

Fe-59 ND ND ND ND 0/35

H-3* ND ND 4 8 7/18

I-125 ND ND 0.4 1 4/35

I-131 ND 0.22 20 81 23/35

In-111 ND ND ND ND 0/35

K-40 7.4 14.2 20.9 22.4 35/35

La-138 ND ND ND ND 0/35

Pa-234m ND 3 11 77 30/35

Pb-210 ND ND 8.5 12.3 16/35

Pb-212 0.36 1.5 3.3 15 35/35

Pb-214 0.61 2.9 14.8 16.4 35/35

Pu-238 ND 0.015 0.1 0.1 20/28

Pu-239 ND 0.01 0.06 0.17 21/28

Ra-223 ND ND 0.2 0.8 4/35

Ra-224 ND ND 2 4.9 15/35

Ra-226 ND 3 18 22 33/35

Ra-228 0.65 2.5 17 30 35/35

Rn-219 ND ND 0.2 0.4 3/35

Sm-153 ND ND ND ND 0/35

Sr-89 ND 1 60 300 20/30

Sr-90 ND 0.2 1 6 24/30

Th-227 ND ND 0.3 1.1 14/33

Th-228 ND 1.6 6.7 14 27/28

Th-230 ND 0.75 2.3 2.6 27/28

Th-232 ND 0.505 1 1.7 27/28

Th-234 ND 3.6 11 80 31/35

Tl-201 ND 0.62 73 105 19/35

Tl-202 ND ND 0.99 1.53 7/35

Tl-208 ND 0.66 2.3 13.5 32/35

U-234 1.2 5.55 49 91 28/28

U-235 ND 0.15 0.7 3.4 30/35

U-238 0.8 3.3 35 74 28/28

Zn-65 ND ND ND 0.06 1/35

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
16

4.2 Comparison of Radioactivity in Sewage Sludge and Ash to Radioactivity in Other 

 Products

To provide a perspective for interpreting the data in this report, Table 4.3 provides a

comparison of concentrations of radionuclides detected in sludge and ash samples analyzed in

this survey to typical ranges of radionuclide concentrations previously reported in U.S. soils and

commonly used products such as phosphate fertilizers and building materials. The sources for

these values are noted in the footnotes to Table 4.3. Although concentrations for some

radionuclides in phosphate fertilizers are high relative to the other sources considered, 

phosphate fertilizers are usually blended with other fertilizer components (containing nitrogen

and potassium) before application, frequently before point-of-sale. This results in a 10% to

50% reduction of the concentrations listed in Table 4.3 at the point-of-use for typical fertilizers

or in commercially available blended fertilizer products (National Council on Radiation

Protection and Measurements [NCRP],1987). Therefore, it is inappropriate to use the values in

this table to infer possible levels of radionuclides in commercially available fertilizers, in

fertilizers at point-of-use, or in the soil after application. Values in this table do not reflect the

uncertainty associated with the ranges.
17

Table 4.3 Survey Concentration Ranges and Typical U.S. Background Concentrations of

Radionuclides in Soil, Fertilizer, and Common Building Materials

(All values are in pCi/g-dry weight)1

Radionuclide Soil2 Phosphate

Fertilizer3

Building

Materials2

Sludge

Concentrations4

Ash

Concentrations4

Bi-212 0.1 - 3.5 0.1 - 4.6 0.1 - 3.7 0 - 13 0 - 16

Bi-214 0.1 -3.8 4.0 - 140 2.5 - 5.05 0 - 16 0 - 16

Cs-137 0.1 - 0.26 NDA7 NDA 0 - 3.6 0 - 0.37

 K-40* 2.7-19 32 - 1608 0.8 - 30 0 - 26 7.4 - 22

 Pa-234m* 0.1 - 3.8 4.0 - 140 0.2 - 5.05 0 - 27 0 - 77

 Pb-212* 0.1 - 3.5 0.1 - 4.6 0.1 - 3.7 0 - 15 0.36 - 15

 Pb-214* 0.1 - 3.8 4.0 - 140 0.2 - 5.0 0 - 17 0.61 - 16

 Ra-223* <0.1 - 0.2 0.2 - 6.6 0.1 - 0.25 0 - 0.09 0.1 - 0.8

Ra-224* 0.1 - 3.5 0.1 - 4.6 0.1 - 3.72 0 - 12 0 - 4.9

 Ra-226* 0.1 - 3.8 0.1 - 24 0.1 - 3.5 0 - 47 0 - 22

 Ra-228* 0.1 - 3.5 0.1- 4.6 0.1 - 3.72 0 - 38 0.65 - 30

Th-227* <0.1 - 0.2 0.2 - 6.6 0.1 - 0.2 0 - 0.5 0 - 1.1

Th-228* 0.1 - 3.5 0.1 - 4.6 0.1 - 3.7 0.07 - 9 0 - 14

Th-230* 0.1 - 3.8 4.0 - 140 0.2 - 5.0 0.09 - 1.7 0 - 2.6

Th-232* 0.1 - 3.5 0.1 - 4.6 0.1 - 3.7 0.02 - 1.6 0 - 1.7

Th-234* 0.1 - 3.8 4.0 - 140 0.2 - 5.0 0 - 23 0 - 80

Tl-208* 0.1 - 3.5 0.1 - 4.6 0.1 - 3.7 0 - 4.8 0 - 14

U-234* 0.1 - 3.8 4.0 - 140 0.2 - 5.0 0.18 - 44 1.2 - 91

U-235*9 <0.1 - 0.2 0.2 - 6.6 0.1 - 0.2 0 - 3.1 0 - 3.4

U-238* 0.1 - 3.8 4.0 - 140 0.2 - 5.05 0.18 - 26 0.8 - 74

* Naturally occurring radionuclide

Notes:

1. The curie (Ci) 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); 1 pCi/g=37 Bq/kg.

2. Low-Level Environmental Radioactivity - Sources and Evaluation (1995) by Tykva and Sabol 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 from References 9 and 6, respectively. The

concentrations of the daughters or decay products of U-238 (such as Th-234 and Ra-226) 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.

3. NCRP Report No. 95 (pp. 24-32) is the source of data for the concentrations of radionuclides in

phosphate fertilizers (not typical blended fertilizers), except for the concentration of K-40 in phosphate

fertilizers, which came from the reference in Note 8. The concentrations of typical blended commercial

fertilizers would be 10% to 50% of these values.

4. A value of zero as the lower boundary of the range occurs when a very low concentration is rounded to

reflect the same number of decimal places as the two sigma laboratory uncertainty. Nondetected values

are not included in this range.

5. Eisenbud and Gesell, 1997.

6. The Cs-137 concentration range in soil was obtained from Figure 4-4 (p. 94) of NCRP Report No. 50, 

1976.

7. NDA means no data available

8. Source for data on K-40 in fertilizers, S. Cohen and Associates, 1997.

9. The values for U-235 in soil, fertilizer, and building materials are based on the concentrations of U-238 in

the same materials and the natural ratio of U-235 to U-238.
18

4.3 Correlation Analysis

To examine the relationships among the different radionuclide concentrations observed in the

survey, a correlation analysis was run. The analysis grouped radionuclides into clusters having

similar patterns of concentrations in the survey data. Because so few ash samples were

submitted, only the sludge samples were considered in this analysis. Data were standardized

to a distribution with a mean of zero and a standard deviation equal to one both with and

without a logarithmic transformation. Standardization of concentration values provides a

consistent variable for comparing radionuclides in the survey, and a logarithmic transformation

often increases the efficiency of the calculations used in the correlation analysis. When logtransformed, nondetected values were set to a minimal value of 0.001 pCi/g, and a sensitivity

analysis confirmed that treating nondetected values in this way did not change the overall

results. The correlations were determined by examining the correlation matrix of the data for

clusters, both by inspection of the matrix itself and through principal component analysis. 

Clusters among the members of the Ra-226 and Ra-228 decay chains in the survey (Ra-226,

Bi-214, Pb-214, Ra-228, Th-228, Ra-224, Pb-212, Bi-212, and Tl-208) indicate a not

unexpected strong association in the samples for these radionuclides. A strong clustering was

also found among the uranium isotopes U-234, U-235, U-238 and the U-238 decay chain

daughters Th-234 and Pa-234m. Again, such a relationship would be expected from the decay

chain relationship. A negative correlation was observed between detection of the radium group

and the uranium group. This correlation indicates that when radium was present in relatively

high concentrations in a sample, it is likely that uranium was present at relatively low

concentrations or not detected, and vice versa. In addition, the medical isotopes In-111, I-131,

Tl-201, Tl-202, and Co-57 tended to cluster together. Due to the limitations of the survey

design, weaker correlations were not considered adequate to support conclusions about

general relationships and are not discussed in this report. 
5

University of Arkansas for Medical Sciences, College of Pharmacy

(http://nuclearpharmacy.uams.edu/RPLIST.html)

19

These observed clusters are generally in line with what would be expected due to common

radionuclide sources and their degradation products. Examples of expected clusters are

summarized in the following table. 

Table 4.4 Expected [Groupings] Clustering of Radionuclides Based on Process and

Degradation Relationships

Group Radionuclides

Medical radionuclides5 Co-57, Cr-51, In-111, I-125, I-131, Sm-153, Sr-89, 

Tl-201, Tl-202

Fission and activation products 

other than Medical 

Radionuclides

Cr-51, Fe-59, Co-57, Co-60, Zn-65, Sr-89, Sr-90, 

Ba-140, Cs-134, Cs-137, Ce-141, Sm-153, Eu-154

C-14 and H-3 C-14 and H-3

NORM other than U or Th series Be-7, K-40, La-138

Th-232 decay series Th-232, Ra-228, Th-228, Ra-224, Pb-212, Bi-212, Tl-208

Transuranics Pu-238, Pu-239, Am-241

U-235 decay series U-235, Th-227, Ra-223, Rn-219

U-238 decay series U-238, Th-234, Pa-234m, Pa-234, U-234, Th-230, 

Ra-226, Pb-214, Bi-214, Pb-210

Physical processes in the environment and types of radionuclide releases are likely to underlie

some of the observed correlations among clusters of radionuclides. For example, the negative

correlation between radium and uranium could be explained by the pH-dependent solubility of

the two elements. In natural waters of pH 7-10, uranium ions in geologic formations form

complexes with carbonate and become soluble, thereby entering the drinking water source

(Cothern and Rebers, 1990). Radium becomes soluble at a lower pH (5 or less), and is,

therefore, most likely to be present in acidic groundwater (USGS, 1998). Little can be

concluded about other expected groups (e.g., fission/activation products) because lower

activities in these radionuclides were observed, and the correlations were weaker.

Further analyses of the data were performed to determine if geographic location or POTW

characteristics, as identified in the questionnaire responses, had any relationship to

radionuclide concentrations. The radionuclide concentrations were grouped by relationships of

source or decay series as shown in Table 4.4 above. The data were sorted by these

radionuclide groupings and by information provided by the POTWs in response to the survey

questionnaires. The tables in Appendix A show the summary statistics of minimum, median,

95th percentile, maximum radionuclide concentration, and frequency of detection. Tables 4.1

and 4.2 summarize the complete data set. The remaining tables in Appendix A summarize the

data by radionuclide group for other POTW characteristics identified in the questionnaire

responses.
20

4.4 Association of Questionnaire Responses With Radionuclide Concentrations

Analyses were performed to determine whether different questionnaire response categories

were related to shifts in radionuclide concentrations. The analyses were restricted to

radionuclides with at least a 50% frequency of detection, except for Cs-137 (detect rate = 43%). 

Cesium-137 was included because it had the highest detect rate of any radionuclide analyzed in

all 311 samples of the fission and activation product group. Altogether 23 radionuclides were

analyzed.

Performing multiple analyses (N = 23 radionuclides) for each survey question increases the

chances of defining spurious relationships in the data. In other words, because statistical

significance is defined as a relationship with a very low probability of occurrence, the more tests

performed, the more likely it is that low-probability findings will occur through chance alone. To

correct for this effect and increase the confidence that reported significant relationships were

the result of actual associations and not simply chance, only relationships with less than a

probability of 0.002 were assumed to represent a potentially useful (significant) association

between questionnaire response categories and radionuclide concentrations.

4.5 Results

Table 4.5 shows the strength of the association between the factors considered in the survey

questionnaire and against the 23 radionuclides analyzed. Physiographic division was the

POTW characteristic most strongly associated with radionuclide concentrations (Section 4.5.1). 

Other POTW characteristics showing strong associations with radionuclide concentrations were

(1) the primary source of drinking water and (2) the average daily flow in (million gallons per day

[MGD]). No questionnaire responses were associated with differences in radionuclide

concentrations in sludge for the C-14 and H-3 group.

The relationship between radionuclide concentrations and the response categories for specific

items on the questionnaire was sometimes positive and sometimes negative. In other words,

the characteristic or level of response to a questionnaire item was sometimes associated with

higher concentrations of a particular radionuclide or radionuclide group, while other categories

were sometimes associated with lower concentrations of those or other radionuclides. The

direction of association between questionnaire responses and radionuclide concentrations is

discussed in the following sections and summarized in Tables 4.6 through 4.9 for the three

POTW characteristics most strongly associated with radionuclide concentration patterns: 

physiographic province, drinking water source, and average daily flow through the POTW. 
21

Table 4.5 Summary of Direction of Effect for Questionnaire Response less Predictive for Radionuclide Concentration in

Sludge

Survey Question C14

and

H-3

Fission and

Activation

Products

Medical

Isotopes

NORM Th-232 Decay Series Transuranics U-238 Decay Series

H-3 Cs137 Sr- 89 Sr- 90 I-131 Tl- 201 Be- 7 K- 40 Pb- 212 Ra- 228 Th- 228 Th- 232 Tl- 208 Pu- 238 Pu- 239 Bi- 214 Pb- 210 Pb- 214 Ra- 226 Th- 230 Th- 234 U- 234 U- 238

Physiographicdivisions

** * **   ** * ** *** *** ** * *** *** ***

Primary sourcesof drinkingwater

** ***   **  * *** ** *

Average dailyflow (MGD)

** *** * * * *** * *

Combinedsanitary andstorm sewers

*** * *** *** * ** *

Percentindustrial flow

** * * * * * *

Highestreportedtreatment level 

* * **

More than onesludge facility

***

Receives wastefrom otherwastewaterfacilities

* * **

Receivesdrinking waterresiduals

* *

Reportedtreatment levels

*

Receivesseptage

*

The number of asterisks represents the relative strength of association (based on individual nonparametric analyses: * P<0.05, ** P<0.01, and *** P<0.001).
22

4.5.1 Physiographic Divisions

As expected, the location of POTWs within major physiographic divisions of the United States

(Figure 1) affected radionulide concentrations. Physiographic divisions represent distinctive

areas having common topography, rock types and structure, and geologic and geomorphic

history (Fenneman and Johnson, 1946) and should have similar levels of naturally occurring

radioactive materials (NORM). Concentrations of U-234 and U-238 were higher than the

average in the Intermontane Plateaus and lower than the average in the Atlantic Plain. 

However, some other members of the U-238 series (Bi-214 and Pb-214) were highest in the

Atlantic Plain and the Interior Plains. The Interior Plains showed a strong association with

higher concentrations of Ra-228, while Hawaii and the Pacific Mountains showed a strong

association with the lower concentrations. These relationships are summarized in Table 4.6.

Table 4.6 Relationships of Physiographic Division to Concentrations of Radionuclides in Sludge

Samples

Group Nuclide1 Lower concentrations2 Higher concentrations3

Fission and

Activation

Products

Cs-137 Rocky Mountains

Medical

Isotopes

Tl-201 Atlantic Plain Appalachian Highlands

NORM Be-7 Rocky Mountains, Hawaii Appalachian Highlands

K-40 Rocky Mountains

Th-232 Decay

Series

Pb-212 Intermontane Plateaus,

Pacific Mountains

Atlantic Plain

Ra-2281

 Hawaii, Pacific

Mountains

Interior Plains

Tl-208 Intermontane Plateaus,

Pacific Mountains,

Hawaii

Rocky Mountains, Interior Plains,

Atlantic Plain

U-238 Decay

Series

Bi-2141 Hawaii, Pacific

Mountains, Appalachian

Highlands

Atlantic Plain, Interior Plains

Pb-2141 Hawaii, Pacific

Mountains, Appalachian

Highlands

Atlantic Plain, Interior Plains

Ra-226 Appalachian Highlands Atlantic Plain, Interior Plains

Th-230 Atlantic Plain

Th-2341 Intermontane Plateaus, Rocky

Mountains

U-2341 Atlantic Plain Intermontane Plateaus

U-2381 Atlantic Plain Intermontane Plateaus

1. These radionuclides showed a strong association with the distribution of responses identifying 

 the physiographic location of the POTW.

2. “Lower concentrations” are significantly lower than the average concentration.

3. “Higher concentrations” are significantly higher than the average concentration.
23

4.5.2 Primary Source of Drinking Water

Concentrations of radionuclides in sludge showed a stronger association with whether drinking

water came from groundwater or surface water than with whether water supplies were public or

private. Only two radionuclides, Be-7 and Bi-214, showed strong associations with the source

of drinking water. Sludge that included groundwater sources had higher concentrations of 

Bi-214, while municipal supplies served by surface water had lower concentrations. Sludge

from areas with surface water sources showed higher concentrations of Be-7, while areas

served primarily by groundwater had lower concentrations. Table 4.7 tabulates these and the

weaker relationships observed.

Table 4.7 Relationships of Primary Drinking Water Source to the Relative Concentration

of Radionuclides

Group Nuclide Lower

Concentrations

Higher

Concentrations

Fission and Activation Products Cs-137 B A

NORM Be-7* BC, B A, ABC

Th-232 Decay Series Ra-228 A B

Th-228 A, ABC BC

Th-232 A

Tl-208 AB

U-238 Decay Series Bi-214* NR, A B

Pb-214 A B

Ra-226 A B

 A = municipal supply from surface water

 B = municipal supply from groundwater

 C = private wells

 D = private surface water

 NR = not reported

*Radionuclides showing a strong association with the questionnaire response regarding primary source 

 of drinking water.
24

4.5.3 Average Daily Flow

Daily flow volume from POTWs did not show a consistent relationship to radionuclide

concentrations. Qualitative correlation of concentrations with flow can be assessed by the

pattern of pluses and minuses in Table 4.8. The pluses and minuses indicate flow categories

with significantly higher or lower concentrations. Radionuclides with higher concentrations at

higher flow volumes have an overall positive correlation and radionuclides with higher than

average concentration at low flow volumes have an overall negative correlation with flow

volume. Based on this approach, the medical isotopes showed a strong association with

increased flow. Thorium-228 showed a strong relationship with POTWs with lower daily flow. 

Table 4.8 includes other radionuclides showing weaker relationships. 

Table 4.8 Effect of Average Daily Flow on Radionuclide Concentration

Flow (millions of gallons per day)

Group Nuclide <10 10–50 50–100 >100 NR

Medical Isotopes I-131 – +

Tl-201 – +

NORM Be-7 +

Th-232 Decay Series Pb-212 + –

Ra-228 +

Th-228 + –

Th-232 –

Transuranics Pu-239 +

Plus and minus symbols identify categories with significantly higher and lower than average

concentrations of radionuclides.*
25

REFERENCES

Code of Federal Regulations, Title 40, U.S. Environmental Protection Agency, Part 503,

National Sewage Sludge Survey: Availability of Information and Data, and Anticipated Impacts

on Proposed Regulations; Proposed Rule,” Federal Register: Vol. 55, No. 218, pp. 47210-

47283, November 9, 1990.

S. Cohen and Associates, Final Draft NORM Waste Characterization,”EPA Contract 

No. 68D20155, WA No.5-09, pp. B-3-1 to B-3-24, 1997.

Cothern, Richard C., and Rebers, Paul A., Removal of Uranium from Drinking Water by

Conventional Treatment Methods ”, Radon, Radium and Uranium in Drinking Water, Lewis

Publishers, Chelsea, Michigan,1990.

Eisenbud, M. and Gesell, T., Environmental Radioactivity from Natural, Industrial, and Military

Sources, 4th Edition, Academic Press, San Diego, 1997. 

Environmental Protection Agency (U.S.) (EPA), Radioactivity of Municipal Sludge,” Office of

Water Regulations and Standards, EPA: Washington, D.C.,1986.

———. EPA 832-R-97-003, 1996 Clean Water Needs Survey Report to Congress —

Assessment of Needs for Publicly Owned Wastewater Treatment Facilities, Correction of

Combined Sewer Overflows, and Management of Storm Water and Nonpoint Source Pollution

in the United States,” Office of Water, EPA: Washington, D.C., September 1997.

———.EPA Contract No. No. 68-D5-0174, Identification of POTWs for NORM Analysis,” 

EPA, Washington, D.C.,1998.

———. EPA 832-R-99-900, Joint NRC/EPA Sewage Sludge Radiological Survey: Survey

Design and Test Site Results,” May 1999.

———. EPA/NRC, “Quality Assurance Project Plan, EPA/NRC Sewage Sludge Survey,”

October 2001.

Fenneman, Nevin M., and Johnson, Douglas W.,Physical Divisions of the United States,” 

U.S. Geological Survey (USGS) special map, USGS, Washington, D.C, 1946.

GAO/RCED-94-133, Nuclear Regulation: Action Needed to Control Radioactive

Contamination at Sewage Treatment Plants,” May 1994.

National Academy of Sciences, Evaluation of Guidelines for Exposures to Technologically

Enhanced Naturally Occurring Radioactive Materials,” Committee on Evaluation of EPA

Guidelines for Exposure to Naturally Occurring Radioactive Materials, National Research

Council, National Academy Press, Washington, D.C. 1999.
26

National Council on Radiation Protection and Measurements (NCRP), NCRP Report No. 50. 

Environmental Radiation Measurements,” Recommendations of the National Council on

Radiation Protection and Measurements, Figure 4-4, p. 94, 1976.

———. NCRP Report No. 95, Radiation Exposure of the U.S. Population from Consumer

Products and Miscellaneous Sources,” pp. 24-32, 1987.

Nuclear Regulatory Commission (NRC) (U.S.), NUREG/CR-5814, Evaluation of Exposure

Pathways to Man From Disposal of Radioactive Materials Into Sanitary Sewer Systems,” 

NRC, Washington, D.C., 1992.

———. NUREG/CR-6289, Reconcentration of Radioactive Material Released to Sanitary

Sewers in Accordance with 10 CFR 20, 1994,” NRC, Washington, D.C., 1994.

———. (SP-98-086). Letter from Frederick C. Combs to ALL AGREEMENT STATES

MINNESOTA, OHIO, OKLAHOMA, PENNSYLVANIA, WISCONSIN, “TRANSMITTAL OF

STATE AGREEMENTS PROGRAM INFORMATION: JOINT NRC/EPA NATIONAL SURVEY

OF SEWAGE SLUDGE/ASH AND REQUEST FOR COMMENTS ON DRAFT GUIDANCE

FOR SEWAGE TREATMENT PLANTS,” November 4, 1998.

———. (SP-99-066). Letter from Frederick C. Combs to ALL AGREEMENT STATES

MINNESOTA, OKLAHOMA, PENNSYLVANIA, WISCONSIN, “OTHER INFORMATION:

AVAILABILITY OF THE JOINT NRC/EPA SEWAGE SLUDGE RADIOLOGICAL SURVEY:

SURVEY DESIGN AND TEST SITE RESULTS REPORT,” September 23, 1999.

Tykva, R., and Sabol, J., Low-Level Environmental Radioactivity — Sources and Evaluation,”

Technomic Publishing Company, Inc., Lancaster, Pennsylvania, 1995.

U.S. Congress, “Radioactive Contamination at Sewage Treatment Plants,” Joint Hearing

Before the Committee on Governmental Affairs, U.S. Senate, and the Subcommittee on

Environment, Energy, and Natural Resources of the Committee on Government Operations,

House of Representatives, One Hundred Third Congress, Second Session, June 21,1994, 

S. Hrg. 103-1034, ISBN 0-16-047201-6, U.S. Government Printing Office, Washington, D.C.,

1994.

USGS/EPA Report 00-4273, “Occurrence of Selected Radionuclides in Ground Water Used for

Drinking Water in the United States: A Reconnaissance Survey,” 1998.

28
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

Radionuclide Group: Uranium-238 Decay SeriesBi-214 Min 0.05 ND ND ND ND ND ND 0.36 

Median 0.135 0.2 0.405 ND to

0.05

1 0.38 0.24 0.38 

95th Percentile 0.22 0.9 6 0.07 1.5 4.1 0.51 0.4 Max 0.22 1.5 13 0.07 1.5 16 1 0.4 No. Detects/No. Analyses

2/2 54/84 49/60 2/4 3/4 97/110 18/20 2/2 

Pa-234m Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND 2.5 ND 95th Percentile ND 6 3 ND ND 9 20 ND Max ND 22 6 ND ND 11 27 ND No. Detects/No. Analyses

0/2 23/84 11/60 0/4 0/4 28/110 12/20 0/2 

Pb-210 Min ND ND ND ND ND ND ND ND 

Median ND to

0.3

ND ND ND to 0 0.5 ND 0.55 ND to 4 

95th Percentile 0.3 4 3.2 0.4 1.1 4.3 2 4 Max 0.3 13 6 0.4 1.1 9 3 4 No. Detects/ 1/2 38/84 19/60 2/4 3/4 47/110 12/20 1/2 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

Pb-214 Min ND ND ND ND ND ND ND 0.4 

Median ND 0.3 0.43 ND to

0.06

1.05 0.41 0.26 0.405 

95th Percentile ND 1.1 4 0.14 1.6 4.4 0.54 0.41 Max ND 1.5 15 0.14 1.6 17 0.7 0.41 No. Detects/No. Analyses

0/2 64/84 51/60 2/4 3/4 100/110 19/20 2/2 

Ra-226 Min ND ND ND ND ND ND ND 0.8 

Median ND to

0.4

1.95 3 1.2 1.4 2.15 2 0.9 

95th Percentile 0.4 9 19 4.6 2 17 8 1 Max 0.4 17 30 4.6 2 47 11 1 No. Detects/No. Analyses

1/2 74/84 57/60 3/4 3/4 106/110 19/20 2/2 

Th-230 Min -- 0.1 0.14 -- -- 0.12 0.09 -- 

Median -- 0.415 0.495 -- -- 0.28 0.29 -- 95th Percentile -- 1.6 1 -- -- 0.6 0.4 -- Max -- 1.7 1.2 -- -- 1.7 0.42 -- No. Detects/No. Analyses

-- 14/14 24/24 -- -- 39/39 11/11 -- 

Th-234 Min ND ND ND ND ND ND ND ND 

Median ND to

1.2

0.15 0.4 0.8 0.45 0.8 2.75 ND to 2 

95th Percentile 1.2 5 3 4.9 1 7.8 15 2 Max 1.2 16 4 4.9 1 12 23 2 No. Detects/ 1/2 46/84 33/60 3/4 3/4 70/110 18/20 1/2 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

U-234 Min -- 0.43 0.18 -- -- 0.39 1.1 -- 

Median -- 1.7 1.1 -- -- 2.2 12 -- 95th Percentile -- 20 2.1 -- -- 12 34 -- Max -- 25 2.3 -- -- 15.4 44 -- No. Detects/No. Analyses

-- 14/14 24/24 -- -- 39/39 11/11 -- 

U-238 Min -- 0.37 0.19 -- -- 0.18 0.55 -- 

Median -- 1.45 0.95 -- -- 1.4 6.6 -- 95th Percentile -- 15 2 -- -- 9 12 -- Max -- 16 2 -- -- 12.5 26 -- No. Detects/No. Analyses

-- 14/14 24/24 -- -- 39/39 11/11 -- 

Radionuclide Group: C-14 and H-3C-14* Min ND ND ND ND ND ND ND 0 

Median ND ND ND ND ND to 1 ND ND 0 95th Percentile ND 1 1 ND 2 1 0 0 Max ND 3 2 ND 2 2 1 0 No. Detects/No. Analyses

0/1 16/45 12/26 0/2 2/4 21/51 5/13 1/1 

H-3 * Min ND ND ND ND ND ND ND 0.7 

Median ND 0.6 0.2 ND to 1 ND to 0.1 0.3 0.3 0.7 95th Percentile ND 5 5 1 0.3 4 4 0.7 Max ND 6 7 1 0.3 6 8 0.7 No. Detects/No. Analyses

0/1 35/45 19/26 1/2 2/4 35/51 9/13 1/1 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

Radionuclide Group: Thorium-232 Decay SeriesBi-212 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND to 0.7 95th Percentile ND 1 2 ND ND 2.3 0.7 0.7 Max ND 1.3 4 ND ND 13 0.8 0.7 No. Detects/No. Analyses

0/2 28/84 23/60 0/4 0/4 41/110 2/20 1/2 

Pb-212 Min 0.08 ND ND 0.03 0 ND ND 0.4 

Median 0.165 0.435 0.585 0.105 0.27 0.48 0.3 0.49 95th Percentile 0.25 1.2 2.5 0.6 0.5 2.7 0.7 0.58 Max 0.25 1.9 3.3 0.6 0.5 15 1 0.58 No. Detects/No. Analyses

2/2 81/84 59/60 4/4 4/4 108/110 19/20 2/2 

Ra-224 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND 0.7 0.6 0.4 ND 1.4 0.7 ND Max ND 1.1 3 0.4 ND 12 5 ND No. Detects/No. Analyses

0/2 11/84 11/60 1/4 0/4 20/110 2/20 0/2 

Ra-228 Min 0.15 ND ND ND ND ND ND 0.43 

Median 0.375 0.87 0.87 ND 0.75 1.05 0.85 0.715 95th Percentile 0.6 3.1 8.9 0.14 1.4 9.7 3.4 1 Max 0.6 5 13 0.14 1.4 38 4.6 1 No. Detects/No. Analyses

2/2 74/84 54/60 1/4 3/4 101/110 19/20 2/2 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

Th-228 Min -- 0.16 0.19 -- -- 0.19 0.07 -- 

Median -- 0.75 0.7 -- -- 0.7 0.4 -- 95th Percentile -- 1.3 3.3 -- -- 6.8 0.6 -- Max -- 1.8 4.1 -- -- 9 1.1 -- No. Detects/No. Analyses

-- 14/14 24/24 -- -- 39/39 11/11 -- 

Th-232 Min -- 0.08 0.07 -- -- 0.08 0.02 -- 

Median -- 0.335 0.18 -- -- 0.18 0.2 -- 95th Percentile -- 1.1 0.56 -- -- 0.4 0.35 -- Max -- 1.6 0.9 -- -- 0.6 0.4 -- No. Detects/No. Analyses

-- 14/14 24/24 -- -- 39/39 11/11 -- 

Tl-208 Min ND ND ND ND ND ND ND ND 

Median ND to

0.02

0.08 0.085 ND to

0.02

ND 0.1 ND ND to 0.1 

95th Percentile 0.02 0.8 1.8 0.03 ND 1.3 0.32 0.17 Max 0.02 1.8 3.1 0.03 ND 4.8 0.6 0.17 No. Detects/No. Analyses

1/2 50/84 36/60 2/4 0/4 71/110 7/20 1/2 

Radionuclide Group: Medical IsotopesI-125 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND 0.8 ND ND 0.7 ND ND ND Max ND 40 5.9 ND 0.7 1.1 ND ND No. Detects/No. Analyses

0/2 6/84 3/60 0/4 1/4 1/110 0/20 0/2 

I-131 Min 3.2 ND ND ND 0.92 ND ND 0.4 

Median 22.6 1.55 0.855 1.085 12.5 1.5 3.3 4.35 95th Percentile 42 65 64 1.8 29 42 51 8.3 Max 42 230 840 1.8 29 98 105 8.3 No. Detects/No. Analyses

2/2 70/84 43/60 3/4 4/4 86/110 18/20 2/2 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

In-111 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND 0.09 ND ND 0.04 ND ND Max ND 1.19 3.5 ND ND 3.6 0.4 ND No. Detects/No. Analyses

0/2 4/84 5/60 0/4 0/4 8/110 1/20 0/2 

Tl-201 Min 2.5 ND ND ND ND ND ND ND 

Median 26.25 1.6 ND ND to

48

ND ND ND ND 

95th Percentile 50 56 26 71 176 35 42 ND Max 50 241 46 71 176 138 110 ND No. Detects/No. Analyses

2/2 48/84 23/60 2/4 1/4 52/110 9/20 0/2 

Tl-202 Min ND ND ND ND ND ND ND ND 

Median ND to

0.7

ND ND ND to

0.66

ND ND ND ND 

95th Percentile 0.7 0.54 0.51 0.88 ND 0.45 0.55 ND Max 0.7 1.16 0.95 0.88 ND 0.92 0.85 ND No. Detects/No. Analyses

1⁄2 18/84 16/60 2/4 0/4 25/110 4/20 0/2 

Radionuclide Group: NORM other than Thorium/UraniumBe-7 Min 0.5 ND ND ND ND ND ND 0.9 

Median 0.7 1.5 0.95 0.4 1.75 1.1 0.85 1.7 95th Percentile 0.9 11 4 0.56 3 8 2.4 2.5 Max 0.9 17 22 0.56 3 13.5 4 2.5 No. Detects/No. Analyses

2/2 79/84 49/60 3/4 3/4 88/110 18/20 2/2 

K-40 Min 2 ND 0.9 0.3 3.4 ND 1.3 3 

Median 2.6 4 3.8 1.75 7 4 3.85 3.95 95th Percentile 3.2 13 10.5 4 14 9.1 7.7 4.9 Max 3.2 15.9 19 4 14 22 8 4.9 No. Detects/No. Analyses

2/2 82/84 60/60 4/4 4/4 109/110 20/20 2/2 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

La-138 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND ND 0.07 ND ND ND ND ND No. Detects/No. Analyses

0/2 0/84 1/60 0/4 0/4 0/110 0/20 0/2 

Radionuclide Group: TransuranicsAm-241 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND 0.14 2.5 ND ND 0.1 0 ND No. Detects/No. Analyses

0/2 1/84 3/60 0/4 0/4 5/110 1/20 0/2 

Pu-238 Min -- ND ND -- -- ND ND -- 

Median -- 0.0005 0.01 -- -- 0.01 0.01 -- 95th Percentile -- 0.03 0.14 -- -- 0.04 0.03 -- Max -- 0.03 0.19 -- -- 0.1 0.07 -- No. Detects/No. Analyses

-- 11/14 19/24 -- -- 32/39 9/11 -- 

Pu-239 Min -- ND ND -- -- ND ND -- 

Median -- 0.001 0.01 -- -- 0.002 0 -- 95th Percentile -- 0.04 0.11 -- -- 0.01 0.01 -- Max -- 0.1 0.12 -- -- 0.04 0.04 -- No. Detects/No. Analyses

-- 8/14 21/24 -- -- 29/39 7/11 -- 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

Radionuclide Group: Actinium ( U-235) Decay SeriesRa-223 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND 0.06 ND ND ND ND ND ND No. Detects/No. Analyses

0/2 1/84 0/60 0/4 0/4 0/110 0/20 0/2 

Rn-219 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND ND ND ND ND ND ND ND No. Detects/No. Analyses

0/2 0/84 0/60 0/4 0/4 0/110 0/20 0/2 

Th-227 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND 0.07 0.1 ND ND 0.1 0.06 ND Max ND 0.19 0.2 ND ND 0.5 0.1 ND No. Detects/No. Analyses

0/1 5/50 14/40 0/2 0/4 22/73 7/20 0/1 

U-235 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND 0.095 ND 95th Percentile ND 0.31 0.19 ND ND 0.5 1.3 ND Max ND 1.1 0.3 ND ND 0.61 3.1 ND No. Detects/No. Analyses

0/2 19/84 29/60 0/4 0/4 46/110 11/20 0/2 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

Radionuclide Group: Fission and Activation ProductsCe-141 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND ND ND ND ND 0.016 ND ND No. Detects/No. Analyses

0/2 0/84 0/60 0/4 0/4 1/110 0/20 0/2 

Co-57 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND ND 0.06 ND ND 0.05 0.01 ND No. Detects/No. Analyses

0/2 0/84 2/60 0/4 0/4 1/110 1/20 0/2 

Co-60 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND 0.07 ND ND ND ND ND Max ND 0.07 1.16 ND ND 0.3 5.1 ND No. Detects/No. Analyses

0/2 2/84 4/60 0/4 0/4 4/110 1/20 0/2 

Cr-51 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND 3.5 0.8 ND ND 0.3 ND ND No. Detects/No. Analyses

0/2 2/84 2/60 0/4 0/4 1/110 0/20 0/2 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

Cs-134 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND ND 0.04 ND ND ND ND ND No. Detects/No. Analyses

0/2 0/84 1/60 0/4 0/4 0/110 0/20 0/2 

Cs-137 Min ND ND ND ND ND ND ND 0.07 

Median ND ND ND ND ND ND ND 0.09 95th Percentile ND 0.11 0.12 0.01 0.03 0.06 0.4 0.11 Max ND 1.5 3.6 0.01 0.03 0.1 1.1 0.11 No. Detects/No. Analyses

0/2 37/84 24/60 1/4 1/4 46/110 8/20 2/2 

Eu-154 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND 21 ND ND ND ND ND ND No. Detects/No. Analyses

0/2 1/84 0/60 0/4 0/4 0/110 0/20 0/2 

Fe-59 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND ND ND ND ND 0.4 ND ND No. Detects/No. Analyses

0/2 0/84 0/60 0/4 0/4 1/110 0/20 0/2 
Table A.1 Concentrations of Radionuclides in Sludge, 

Summarized by Geographic Division 

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalachian

Highlands

Atlantic

Plains

Hawaii Interior

Highlands

Interior

Plains

Intermontane

Plateaus

Laurentain

Upland

Sm-153 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND 27 ND ND ND ND ND ND No. Detects/No. Analyses

0/2 1/84 0/60 0/4 0/4 0/110 0/20 0/2 

Sr-89 Min -- ND ND -- -- ND ND -- 

Median -- 0.1 1.1 -- -- 0.3 0.3 -- 95th Percentile -- 3 20 -- -- 30 2 -- Max -- 10 30 -- -- 70 2 -- No. Detects/No. Analyses

-- 9/15 20/24 -- -- 24/38 9/13 -- 

Sr-90 Min -- ND ND -- -- ND ND -- 

Median -- 0.1 0.1 -- -- 0.1 0 -- 95th Percentile -- 9 0.4 -- -- 0.6 0.3 -- Max -- 9.4 1 -- -- 2 0.7 -- No. Detects/No. Analyses

-- 10/15 15/24 -- -- 26/38 8/13 -- 

Zn-65 Min ND ND ND ND ND ND ND ND 

Median ND ND ND ND ND ND ND ND 95th Percentile ND ND ND ND ND ND ND ND Max ND 0.06 ND ND ND ND ND ND No. Detects/No. Analyses

0/2 1/84 0/60 0/4 0/4 0/110 0/20 0/2 

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Radionuclide Group: Uranium-238 Decay SeriesBi-214 Min -- ND 2.8 -- -- 1.7 -- -- 

Median -- 2.15 3.8 -- -- 3.25 -- -- 95th Percentile -- 9 16 -- -- 14.1 -- -- Max -- 13.7 16 -- -- 14.1 -- -- No. Detects/No.Analyses

-- 15/16 5/5 -- -- 10/10 -- -- 

Pa-234m Min -- ND ND -- -- ND -- -- 

Median -- 3 3 -- -- 4.5 -- -- 95th Percentile -- 10 5 -- -- 9 -- -- Max -- 11 5 -- -- 9 -- -- No. Detects/No.Analyses

-- 14/16 4/5 -- -- 9/10 -- -- 

Pb-210 Min -- ND ND -- -- ND -- -- 

Median -- ND to 2.5 ND -- -- ND -- -- 95th Percentile -- 6.4 4.2 -- -- 8.5 -- -- Max -- 12.3 4.2 -- -- 8.5 -- -- No. Detects/No.Analyses

-- 8/16 2/5 -- -- 3/10 -- -- 

Pb-214 Min -- 0.92 3.1 -- -- 1.9 -- -- 

Median -- 2.3 4.1 -- -- 3.6 -- -- 95th Percentile -- 10 16.4 -- -- 15.1 -- -- Max -- 14.8 16.4 -- -- 15.1 -- -- No. Detects/No.Analyses

-- 16/16 5/5 -- -- 10/10 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Ra-226 Min -- ND ND -- -- 2 -- -- 

Median -- 2.5 9.5 -- -- 6.2 -- -- 95th Percentile -- 17 15 -- -- 22 -- -- Max -- 18 15 -- -- 22 -- -- No. Detects/No.Analyses

-- 15/16 4/5 -- -- 10/10 -- -- 

Th-230 Min -- 0.3 0.6 -- -- ND -- -- 

Median -- 0.8 0.7 -- -- 0.9 -- -- 95th Percentile -- 2.3 1.5 -- -- 2.2 -- -- Max -- 2.6 1.5 -- -- 2.2 -- -- No. Detects/No.Analyses

-- 11/11 5/5 -- -- 8/9 -- -- 

Th-234 Min -- ND ND -- -- ND -- -- 

Median -- 2.55 3.8 -- -- 3.75 -- -- 95th Percentile -- 7.3 21 -- -- 7.5 -- -- Max -- 10 21 -- -- 7.5 -- -- No. Detects/No.Analyses

-- 14/16 4/5 -- -- 9/10 -- -- 

U-234 Min -- 1.3 1.2 -- -- 2.7 -- -- 

Median -- 2.9 1.9 -- -- 6.9 -- -- 95th Percentile -- 13 18 -- -- 7.6 -- -- Max -- 49 18 -- -- 7.6 -- -- No. Detects/No.Analyses

-- 11/11 5/5 -- -- 9/9 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

U-238 Min -- 0.8 1.1 -- -- 2.5 -- -- 

Median -- 2.8 1.7 -- -- 4.3 -- -- 95th Percentile -- 9 6.4 -- -- 6.2 -- -- Max -- 35 6.4 -- -- 6.2 -- -- No. Detects/No.Analyses

-- 11/11 5/5 -- -- 9/9 -- -- 

Radionuclide Group: C-14 and H-3C-14* Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- 1 ND -- -- 0 -- -- Max -- 1 ND -- -- 0 -- -- No. Detects/No.Analyses

-- 1/8 0/2 -- -- 2/5 -- -- 

H-3* Min -- ND ND -- -- ND -- -- 

Median -- 0.75 ND -- -- ND -- -- 95th Percentile -- 8 ND -- -- ND -- -- Max -- 8 ND -- -- ND -- -- No. Detects/No.Analyses

-- 6/8 0/2 -- -- 0/5 -- -- 

Radionuclide Group: Thorium-232 Decay SeriesBi-212 Min -- ND 1.2 -- -- ND -- -- 

Median -- 1.3 3.5 -- -- ND to

0.8

-- -- 

95th Percentile -- 2 15.7 -- -- 1.8 -- -- Max -- 2.4 15.7 -- -- 1.8 -- -- No. Detects/No.Analyses

-- 13/16 5/5 -- -- 5/10 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Pb-212 Min -- 0.74 1.3 -- -- 0.73 -- -- 

Median -- 1.55 3.3 -- -- 1.28 -- -- 95th Percentile -- 2.5 15 -- -- 1.9 -- -- Max -- 2.6 15 -- -- 1.9 -- -- No. Detects/No.Analyses

-- 16/16 5/5 -- -- 10/10 -- -- 

Ra-224 Min -- ND ND -- -- ND -- -- 

Median -- ND to 0.4 0.4 -- -- ND -- -- 95th Percentile -- 2 4.9 -- -- 1.3 -- -- Max -- 2.4 4.9 -- -- 1.3 -- -- No. Detects/No.Analyses

-- 8/16 3/5 -- -- 4/10 -- -- 

Ra-228 Min -- 0.71 3.4 -- -- 1.6 -- -- 

Median -- 2.6 9.6 -- -- 2.15 -- -- 95th Percentile -- 6.3 30 -- -- 9.9 -- -- Max -- 17 30 -- -- 9.9 -- -- No. Detects/No.Analyses

-- 16/16 5/5 -- -- 10/10 -- -- 

Th-228 Min -- 0.8 1.7 -- -- ND -- -- 

Median -- 1.5 3 -- -- 1.4 -- -- 95th Percentile -- 3.4 14 -- -- 2.4 -- -- Max -- 3.7 14 -- -- 2.4 -- -- No. Detects/No.Analyses

-- 11/11 5/5 -- -- 8/9 -- -- 

Th-232 Min -- 0.3 0.46 -- -- ND -- -- 

Median -- 0.7 0.8 -- -- 0.5 -- -- 95th Percentile -- 0.9 1.7 -- -- 1 -- -- Max -- 0.9 1.7 -- -- 1 -- -- No. Detects/No.Analyses

-- 11/11 5/5 -- -- 8/9 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Tl-208 Min -- 0.23 0.4 -- -- ND -- -- 

Median -- 1.01 2 -- -- 0.415 -- -- 95th Percentile -- 2 13.5 -- -- 1.66 -- -- Max -- 2.3 13.5 -- -- 1.66 -- -- No. Detects/No.Analyses

-- 16/16 5/5 -- -- 7/10 -- -- 

Radionuclide Group: Medical IsotopesI-125 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND 0.8 -- -- 0.3 -- -- Max -- 0.4 0.8 -- -- 0.3 -- -- No. Detects/No.Analyses

-- 1/16 1/5 -- -- 1/10 -- -- 

I-131 Min -- ND ND -- -- ND -- -- 

Median -- ND to 0.1 0.68 -- -- 0.23 -- -- 95th Percentile -- 1.6 46 -- -- 4.3 -- -- Max -- 20 46 -- -- 4.3 -- -- No. Detects/No.Analyses

-- 8/16 3/5 -- -- 8/10 -- -- 

In-111 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- ND -- -- Max -- ND ND -- -- ND -- -- No. Detects/No.Analyses

-- 0/16 0/5 -- -- 0/10 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Tl-201 Min -- ND ND -- -- ND -- -- 

Median -- ND 6.8 -- -- ND -- -- 95th Percentile -- 31 105 -- -- 12.4 -- -- Max -- 35 105 -- -- 12.4 -- -- No. Detects/No.Analyses

-- 7/16 4/5 -- -- 4/10 -- -- 

Tl-202 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- 0.99 1.53 -- -- 0.1 -- -- Max -- 1.1 1.53 -- -- 0.1 -- -- No. Detects/No.Analyses

-- 3/16 1/5 -- -- 2/10 -- -- 

Radionuclide Group: NORM other than Thorium/UraniumBe-7 Min -- ND 1.2 -- -- 0.5 -- -- 

Median -- 5.95 2.3 -- -- 5.7 -- -- 95th Percentile -- 15 8.1 -- -- 30 -- -- Max -- 27 8.1 -- -- 30 -- -- No. Detects/No.Analyses

-- 15/16 5/5 -- -- 10/10 -- -- 

K-40 Min -- 7.4 8.4 -- -- 7.9 -- -- 

Median -- 15.9 9.4 -- -- 14.1 -- -- 95th Percentile -- 20 22 -- -- 20.9 -- -- Max -- 22.4 22 -- -- 20.9 -- -- No. Detects/No.Analyses

-- 16/16 5/5 -- -- 10/10 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

La-138 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- ND -- -- Max -- ND ND -- -- ND -- -- No. Detects/No.Analyses

-- 0/16 0/5 -- -- 0/10 -- -- 

Radionuclide Group: TransuranicsAm-241 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND 0.04 -- -- ND -- -- Max -- 0.21 0.04 -- -- ND -- -- No. Detects/No.Analyses

-- 1/16 1/5 -- -- 0/10 -- -- 

Pu-238 Min -- ND ND -- -- ND -- -- 

Median -- 0.01 0.02 -- -- 0.02 -- -- 95th Percentile -- 0.09 0.05 -- -- 0.1 -- -- Max -- 0.1 0.05 -- -- 0.1 -- -- No. Detects/No.Analyses

-- 7/11 3/5 -- -- 8/9 -- -- 

Pu-239 Min -- ND ND -- -- ND -- -- 

Median -- 0.008 0.02 -- -- 0.01 -- -- 95th Percentile -- 0.04 0.17 -- -- 0.04 -- -- Max -- 0.06 0.17 -- -- 0.04 -- -- No. Detects/No.Analyses

-- 9/11 3/5 -- -- 7/9 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Radionuclide Group: Actinium ( U-235) Decay SeriesRa-223 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- 0.5 ND -- -- 0.1 -- -- Max -- 0.8 ND -- -- 0.1 -- -- No. Detects/No.Analyses

-- 3/16 0/5 -- -- 1/10 -- -- 

Rn-219 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- 0.2 0.2 -- -- ND -- -- Max -- 0.4 0.2 -- -- ND -- -- No. Detects/No.Analyses

-- 2/16 1/5 -- -- 0/10 -- -- 

Th-227 Min -- ND ND -- -- ND -- -- 

Median -- ND 0.1 -- -- ND -- -- 95th Percentile -- 0.3 0.6 -- -- 0.2 -- -- Max -- 1.1 0.6 -- -- 0.2 -- -- No. Detects/No.Analyses

-- 6/14 3/5 -- -- 4/10 -- -- 

U-235 Min -- ND 0.03 -- -- ND -- -- 

Median -- 0.11 0.07 -- -- 0.24 -- -- 95th Percentile -- 0.5 0.7 -- -- 0.6 -- -- Max -- 1.7 0.7 -- -- 0.6 -- -- No. Detects/No.Analyses

-- 13/16 5/5 -- -- 9/10 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Radionuclide Group: Fission and Activation ProductsCe-141 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- ND -- -- Max -- ND ND -- -- ND -- -- No. Detects/No.Analyses

-- 0/16 0/5 -- -- 0/10 -- -- 

Co-57 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- ND -- -- Max -- 0.17 ND -- -- ND -- -- No. Detects/No.Analyses

-- 1/16 0/5 -- -- 0/10 -- -- 

Co-60 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND 3.46 -- -- 0.038 -- -- Max -- ND 3.46 -- -- 0.038 -- -- No. Detects/No.Analyses

-- 0/16 1/5 -- -- 1/10 -- -- 

Cr-51 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND 0.2 -- -- 0.3 -- -- Max -- 0.8 0.2 -- -- 0.3 -- -- No. Detects/No.Analyses

-- 1/16 1/5 -- -- 1/10 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Cs-134 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- ND -- -- Max -- ND ND -- -- ND -- -- No. Detects/No.Analyses

-- 0/16 0/5 -- -- 0/10 -- -- 

Cs-137 Min -- ND 0.03 -- -- 0.04 -- -- 

Median -- 0.075 0.04 -- -- 0.07 -- -- 95th Percentile -- 0.18 0.37 -- -- 0.23 -- -- Max -- 0.27 0.37 -- -- 0.23 -- -- No. Detects/No.Analyses

-- 15/16 5/5 -- -- 10/10 -- -- 

Eu-154 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- ND -- -- Max -- ND ND -- -- ND -- -- No. Detects/No.Analyses

-- 0/16 0/5 -- -- 0/10 -- -- 

Fe-59 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- ND -- -- Max -- ND ND -- -- ND -- -- No. Detects/No.Analyses

-- 0/16 0/5 -- -- 0/10 -- -- 
Table A.2 Concentrations of Radionuclides in Ash, Summarized by 

Geographic Division

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Alaska Appalacian

Highlands

Atlantic

Plains

Hawaii Interior 

Highlands

Interior

Plains

Intermontane

Plateaus

Laurent

Uplan

Sm-153 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- ND -- -- Max -- ND ND -- -- ND -- -- No. Detects/No.Analyses

-- 0/16 0/5 -- -- 0/10 -- -- 

Sr-89 Min -- ND ND -- -- ND -- -- 

Median -- ND to 0 2 -- -- 1 -- -- 95th Percentile -- 20 12 -- -- 300 -- -- Max -- 60 12 -- -- 300 -- -- No. Detects/No.Analyses

-- 6/12 4/5 -- -- 7/9 -- -- 

Sr-90 Min -- ND 0 -- -- ND -- -- 

Median -- 0.25 0.1 -- -- 0.4 -- -- 95th Percentile -- 1 1 -- -- 6 -- -- Max -- 1 1 -- -- 6 -- -- No. Detects/No.Analyses

-- 10/12 5/5 -- -- 8/9 -- -- 

Zn-65 Min -- ND ND -- -- ND -- -- 

Median -- ND ND -- -- ND -- -- 95th Percentile -- ND ND -- -- 0.06 -- -- Max -- ND ND -- -- 0.06 -- -- No. Detects/No.Analyses

-- 0/16 0/5 -- -- 1/10 -- -- 

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Primary 0.05 0.05 1.7 1.7 3/3

Secondary ND 0.24 1.9 16 63/90

Advanced ND 0.21 7.9 13 23/33

Primary and

Secondary

ND 0.29 2.1 16 81/101

Secondary and

Advanced

0.27 0.4 0.9 0.9 5/5

Primary,

Secondary,

and Advanced

ND 0.38 2.9 4.1 63/79

Pa-234m Primary ND ND ND ND 0/3

Secondary ND ND 8 17 26/90

Advanced ND ND 7 22 11/33

Primary and

Secondary

ND ND 4 27 20/101

Secondary and

Advanced

ND ND 1.3 1.3 2/5

Primary,

Secondary,

and Advanced

ND ND 9 17 21/79

Pb-210 Primary ND ND ND ND 0/3

Secondary ND ND - 0 5 13 45/90

Advanced ND ND 3 12 13/33

Primary and

Secondary

ND ND 3.1 9 38/101

Secondary and

Advanced

ND ND 1.2 1.2 2/5

Primary,

Secondary,

and Advanced

ND ND 4.3 6 37/79

Pb-214 Primary ND ND 1.8 1.8 1/3

Secondary ND 0.27 2 17 72/90

Advanced ND 0.28 8.3 15 25/33

Primary and

Secondary

ND 0.31 2.6 17 81/101

Secondary and

Advanced

0.24 0.4 0.9 0.9 5/5

Primary,

Secondary,

and Advanced

ND 0.4 3 4.4 69/79
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Ra-226 Primary 0.4 2.1 8 8 3/3

Secondary ND 1.95 11 47 80/90

Advanced ND 1.8 21 30 30/33

Primary and

Secondary

ND 2.2 13 27 96/101

Secondary and

Advanced

ND 1.1 2 2 4/5

Primary,

Secondary,

and Advanced

ND 2.2 10.1 25 76/79

Th-230 Primary 1.2 1.2 1.2 1.2 1/1

Secondary 0.1 0.435 0.8 1 24/24

Advanced 0.09 0.38 1.6 1.6 7/7

Primary and

Secondary

0.12 0.375 1.2 1.7 34/34

Secondary and

Advanced

0.4 0.4 0.4 0.4 1/1

Primary,

Secondary,

and Advanced

0.09 0.25 0.49 0.5 25/25

Th-234 Primary ND 1.4 1.6 1.6 2/3

Secondary ND 0.55 6.8 15 56/90

Advanced ND 0.5 5 19 22/33

Primary and

Secondary

ND 0.5 4.9 23 56/101

Secondary and

Advanced

0.4 0.6 1 1 5/5

Primary,

Secondary,

and Advanced

ND 1 7.8 15 50/79

U-234 Primary 1.9 1.9 1.9 1.9 1/1

Secondary 0.5 1.6 14 17 24/24

Advanced 0.4 2.3 20 20 7/7

Primary and

Secondary

0.56 2.2 17 44 34/34

Secondary and

Advanced

1 1 1 1 1/1

Primary,

Secondary,

and Advanced

0.18 2.1 15.4 25 25/25
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

U-238 Primary 1.7 1.7 1.7 1.7 1/1

Secondary 0.43 1.25 10.3 12 24/24

Advanced 0.4 2 16 16 7/7

Primary and

Secondary

0.5 1.55 8 26 34/34

Secondary and

Advanced

0.72 0.72 0.72 0.72 1/1

Primary,

Secondary,

and Advanced

0.18 1.3 12.5 15 25/25

Radionuclide Group: C-14 and H-3

C-14* Secondary ND ND 1 2 22/55

Advanced ND ND 2 2 6/16

Primary and

Secondary

ND ND 1 3 16/44

Secondary and

Advanced

ND 1 1 1 2/3

Primary,

Secondary,

and Advanced

ND ND 1 2 16/40

H-3* Secondary ND 0.4 5 7 41/55

Advanced ND 0.35 2 3 12/16

Primary and

Secondary

ND 0.25 5 8 28/44

Secondary and

Advanced

ND 0.3 4 4 2/3

Primary,

Secondary,

and Advanced

ND 0.3 3 6 28/40

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Primary ND ND ND ND 0/3

Secondary ND ND 1.3 13 28/90

Advanced ND ND 1 4 10/33

Primary and

Secondary

ND ND 1.4 6.8 38/101

Secondary and

Advanced

ND ND 0.6 0.6 2/5

Primary,

Secondary,

and Advanced

ND ND 1.1 3.7 23/79
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Pb-212 Primary 0.08 0.08 0.21 0.21 3/3

Secondary ND 0.45 1.5 15 89/90

Advanced 0.07 0.32 2.2 3 33/33

Primary and

Secondary

ND 0.5 1.9 5.4 100/101

Secondary and

Advanced

0.09 0.19 0.7 0.7 5/5

Primary,

Secondary,

and Advanced

ND 0.44 1.9 4.2 73/79

Ra-224 Primary ND ND 0.4 0.4 1/3

Secondary ND ND 0.6 12 9/90

Advanced ND ND 1.1 3 5/33

Primary and

Secondary

ND ND 0.7 2.7 15/101

Secondary and

Advanced

ND ND 0.6 0.6 2/5

Primary,

Secondary,

and Advanced

ND ND 1 5 15/79

Ra-228 Primary ND 0.15 0.4 0.4 2/3

Secondary ND 0.8 4 20 78/90

Advanced ND 0.7 9.7 13 29/33

Primary and

Secondary

ND 0.83 5.1 24 88/101

Secondary and

Advanced

0.3 0.6 0.64 0.64 5/5

Primary,

Secondary,

and Advanced

ND 1 4.8 38 69/79

Th-228 Primary 0.2 0.2 0.2 0.2 1/1

Secondary 0.16 0.7 6.7 9 24/24

Advanced 0.22 1.1 4.6 4.6 7/7

Primary and

Secondary

0.25 0.75 3 6.8 34/34

Secondary and

Advanced

0.23 0.23 0.23 0.23 1/1

Primary,

Secondary,

and Advanced

0.07 0.4 2.4 9 25/25
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Th-232 Primary 0.14 0.14 0.14 0.14 1/1

Secondary 0.07 0.215 0.6 0.9 24/24

Advanced 0.06 0.19 1.1 1.1 7/7

Primary and

Secondary

0.08 0.265 0.65 1.6 34/34

Secondary and

Advanced

0.15 0.15 0.15 0.15 1/1

Primary,

Secondary,

and Advanced

0.02 0.18 0.4 0.44 25/25

Tl-208 Primary 0.02 0.03 0.04 0.04 3/3

Secondary ND 0.055 0.8 4.1 48/90

Advanced ND ND 0.37 0.93 16/33

Primary and

Secondary

ND 0.09 1.4 4.8 65/101

Secondary and

Advanced

ND ND 0.22 0.22 2/5

Primary,

Secondary,

and Advanced

ND 0.08 0.88 2.5 46/79

Radionuclide Group: Medical Isotopes

I-125 Primary ND ND ND ND 0/3

Secondary ND ND 0.3 40 5/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND 4 5/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND 1.5 1/79

I -131 Primary 1.2 1.8 3.2 3.2 3/3

Secondary ND 1.35 51 220 68/90

Advanced ND 2.9 29 145 28/33

Primary and

Secondary

ND 0.87 101 840 76/101

Secondary and

Advanced

ND 0.13 34 34 4/5

Primary,

Secondary,

and Advanced

ND 3.6 50 105 67/79
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

In-111 Primary ND ND ND ND 0/3

Secondary ND ND ND 0.18 4/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND 0.12 3.6 8/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND 0.044 3.5 7/79

Tl-201 Primary ND 48 50 50 2/3

Secondary ND ND 46 207 41/90

Advanced ND ND 42 241 16/33

Primary and

Secondary

ND ND 34 176 49/101

Secondary and

Advanced

ND ND 1.8 1.8 2/5

Primary,

Secondary,

and Advanced

ND 0.35 35 189 41/79

Tl-202 Primary 0.05 0.66 0.7 0.7 3/3

Secondary ND ND 0.4 1.16 18/90

Advanced ND ND 0.14 0.85 9/33

Primary and

Secondary

ND ND 0.54 0.95 26/101

Secondary and

Advanced

ND ND 0.085 0.085 1/5

Primary,

Secondary,

and Advanced

ND ND 0.51 0.72 16/79

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Primary 0.3 0.4 0.5 0.5 3/3

Secondary ND 1.1 11 22 76/90

Advanced ND 1 4.6 9.5 27/33

Primary and

Secondary

ND 1.2 8 17 85/101

Secondary and

Advanced

ND 0.58 3 3 3/5

Primary,

Secondary,

and Advanced

ND 1.4 9.9 13.5 69/79
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

K-40 Primary 0.8 1.3 2 2 3/3

Secondary ND 4.05 13 26 88/90

Advanced 1.3 3.4 9 25 33/33

Primary and

Secondary

ND 4 13.3 22 100/101

Secondary and

Advanced

2.3 2.9 8.3 8.3 5/5

Primary,

Secondary,

and Advanced

0.9 4 10 12 79/79

La-138 Primary ND ND ND ND 0/3

Secondary ND ND ND 0.07 1/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND ND 0/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79

Radionuclide Group: Transuranics

Am-241 Primary ND ND ND ND 0/3

Secondary ND ND 0.1 2.5 5/90

Advanced ND ND ND 0.1 1/33

Primary and

Secondary

ND ND ND 0.03 1/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND 0.08 3/79

Pu-238 Primary 0.02 0.02 0.02 0.02 1/1

Secondary ND 0.0105 0.14 0.19 18/24

Advanced ND 0 0.1 0.1 5/7

Primary and

Secondary

ND 0.01 0.03 0.1 30/34

Secondary and

Advanced

0 0 0 0 1/1

Primary,

Secondary,

and Advanced

ND 0.007 0.04 0.05 20/25
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Pu-239 Primary 0.02 0.02 0.02 0.02 1/1

Secondary ND 0.0035 0.1 0.11 18/24

Advanced ND 0.01 0.03 0.03 6/7

Primary and

Secondary

ND 0.003 0.04 0.12 24/34

Secondary and

Advanced

ND ND ND ND 0/1

Primary,

Secondary,

and Advanced

ND 0.003 0.01 0.04 19/25

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Primary ND ND ND ND 0/3

Secondary ND ND ND 0.09 1/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND 0.06 1/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79

Rn-219 Primary ND ND ND ND 0/3

Secondary ND ND ND ND 0/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND ND 0/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79

Th-227 Primary 0.04 0.04 0.04 0.04 1/1

Secondary ND ND 0.06 0.5 10/65

Advanced ND ND 0.2 0.2 6/22

Primary and

Secondary

ND ND 0.1 0.19 20/64

Secondary and

Advanced

ND ND ND ND 0/3

Primary,

Secondary,

and Advanced

ND ND 0.1 0.5 12/52
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

U-235 Primary ND ND 0.12 0.12 1/3

Secondary ND ND 0.43 1.3 30/90

Advanced ND ND 0.2 0.7 7/33

Primary and

Secondary

ND ND 0.4 3.1 40/101

Secondary and

Advanced

ND 0.06 0.08 0.08 3/5

Primary,

Secondary,

and Advanced

ND ND 0.58 0.7 31/79

Radionuclide Group: Fission and Activation Products

Ce-141 Primary ND ND ND ND 0/3

Secondary ND ND ND ND 0/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND 0.016 1/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79

Co-57 Primary ND ND ND ND 0/3

Secondary ND ND ND ND 0/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND 0.26 3/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND 0.06 3/79

Co-60 Primary ND ND ND ND 0/3

Secondary ND ND 0.05 1.16 6/90

Advanced ND ND ND 0.016 1/33

Primary and

Secondary

ND ND ND 5.1 3/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND 0.1 3/79
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Cr-51 Primary ND ND ND ND 0/3

Secondary ND ND ND 2.8 1/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND 3.5 1/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND 0.8 4/79

Cs-134 Primary ND ND ND ND 0/3

Secondary ND ND ND 0.04 1/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND ND 0/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79

Cs-137 Primary ND ND ND ND 0/3

Secondary ND ND 0.19 3.6 44/90

Advanced ND ND 0.11 0.73 7/33

Primary and

Secondary

ND ND 0.11 1.1 44/101

Secondary and

Advanced

ND 0.03 0.06 0.06 4/5

Primary,

Secondary,

and Advanced

ND ND 0.08 0.3 34/79

Eu-154 Primary ND ND ND ND 0/3

Secondary ND ND ND 21 1/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND ND 0/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Fe-59 Primary ND ND ND ND 0/3

Secondary ND ND ND 0.4 1/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND ND 0/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79

Sm-153 Primary ND ND ND ND 0/3

Secondary ND ND ND 27 1/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND ND 0/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79

Sr-89 Primary 20 20 20 20 1/1

Secondary ND 0.5 5 5 22/28

Advanced ND ND 10 10 4/9

Primary and

Secondary

ND 0 10 70 19/34

Secondary and

Advanced

0 1 1 1 3/3

Primary,

Secondary,

and Advanced

ND 1 30 30 19/23

Sr-90 Primary 0.1 0.1 0.1 0.1 1/1

Secondary ND 0.1 1 9.4 16/28

Advanced ND 0.1 0.3 0.3 7/9

Primary and

Secondary

ND 0.1 0.7 9 24/34

Secondary and

Advanced

0 0.04 0.3 0.3 3/3

Primary,

Secondary,

and Advanced

ND 0.1 1 2 13/23
Table A.3 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question:

Indicate the Level(s) of Wastewater Treatment Achieved by this Treatment Works

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi = 0.037 Bq.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Zn-65 Primary ND ND ND ND 0/3

Secondary ND ND ND 0.06 1/90

Advanced ND ND ND ND 0/33

Primary and

Secondary

ND ND ND ND 0/101

Secondary and

Advanced

ND ND ND ND 0/5

Primary,

Secondary,

and Advanced

ND ND ND ND 0/79

* Indicates concentrations for this radionuclide are expressed in pCi/g wet
A-39

Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Primary 2.2 2.2 2.2 2.2 1/1

Secondary 0.64 1.7 3.1 3.1 7/7

Advanced 0.72 1.7 6.3 6.3 7/7

Primary and

Secondary

0.62 2.4 14.1 16 11/11

Secondary and

Advanced

2.8 5.9 9 9 2/2

Primary,

Secondary, and

Advanced

ND 3.2 14 14 6/7

Pa-234m Primary 3 3 3 3 1/1

Secondary 1.1 5 6 6 7/7

Advanced ND 3 11 11 6/7

Primary and

Secondary

ND 3 7 10 9/11

Secondary and

Advanced

ND ND - 2 2 2 1/2

Primary,

Secondary, and

Advanced

ND 5 77 77 6/7

Pb-210 Primary ND ND ND ND 0/1

Secondary ND ND 5 5 2/7

Advanced ND ND 5.3 5.3 3/7

Primary and

Secondary

ND 3.4 8.5 12.3 8/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND 8.9 8.9 3/7

Pb-214 Primary 2.4 2.4 2.4 2.4 1/1

Secondary 0.69 1.9 3.4 3.4 7/7

Advanced 0.74 1.9 6.8 6.8 7/7

Primary and

Secondary

0.61 2.9 15.1 16.4 11/11

Secondary and

Advanced

3.1 6.55 10 10 2/2

Primary,

Secondary, and

Advanced

0.92 3.5 14.6 14.6 7/7
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-40

Ra-226 Primary 3.4 3.4 3.4 3.4 1/1

Secondary 1.1 2.5 9.4 9.4 7/7

Advanced ND 2 7.1 7.1 5/7

Primary and

Secondary

1.1 4 17 22 11/11

Secondary and

Advanced

9.5 13.75 18 18 2/2

Primary,

Secondary, and

Advanced

1 6.6 18 18 7/7

Th-230 Primary 1.4 1.4 1.4 1.4 1/1

Secondary 0.4 0.85 2.2 2.2 4/4

Advanced 0.3 0.8 2.6 2.6 7/7

Primary and

Secondary

ND 1.1 2.3 2.3 7/8

Secondary and

Advanced

0.6 0.6 0.6 0.6 2/2

Primary,

Secondary, and

Advanced

0.55 0.65 1.3 1.3 6/6

Th-234 Primary 2.7 2.7 2.7 2.7 1/1

Secondary ND 4.7 7.2 7.2 6/7

Advanced 1 3.6 21 21 7/7

Primary and

Secondary

1 2.7 5.5 7.3 11/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND 4.7 80 80 6/7

U-234 Primary 5.3 5.3 5.3 5.3 1/1

Secondary 2.7 5.4 9 9 4/4

Advanced 1.3 2.4 19 19 7/7

Primary and

Secondary

1.2 6.05 49 49 8/8

Secondary and

Advanced

1.9 2.05 2.2 2.2 2/2

Primary,

Secondary, and

Advanced

6 7.45 91 91 6/6
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-41

U-238 Primary 4.3 4.3 4.3 4.3 1/1

Secondary 2.5 4.25 6.4 6.4 4/4

Advanced 0.8 1.9 15 15 7/7

Primary and

Secondary

1.1 3.65 35 35 8/8

Secondary and

Advanced

1.4 1.55 1.7 1.7 2/2

Primary,

Secondary, and

Advanced

2.8 4.75 74 74 6/6

Radionuclide Group: C-14 and H-3

C-14* Secondary ND 0 1 1 2/3

Advanced ND ND ND ND 0/3

Primary and

Secondary

ND ND 0 0 2/8

Primary,

Secondary, and

Advanced

ND ND 1 1 1/4

H-3* Secondary ND 3 8 8 2/3

Advanced ND ND 1 1 1/3

Primary and

Secondary

ND ND 2 2 2/8

Primary,

Secondary, and

Advanced

ND ND - 0.5 4 4 2/4

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Primary 0.9 0.9 0.9 0.9 1/1

Secondary ND 0.8 1.8 1.8 6/7

Advanced ND 0.9 5.5 5.5 4/7

Primary and

Secondary

ND 1.6 3.5 15.7 8/11

Secondary and

Advanced

1.2 1.65 2.1 2.1 2/2

Primary,

Secondary, and

Advanced

ND 1.4 1.6 1.6 4/7
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-42

Pb-212 Primary 1.14 1.14 1.14 1.14 1/1

Secondary 0.36 1.3 1.7 1.7 7/7

Advanced 0.99 1.4 6.6 6.6 7/7

Primary and

Secondary

0.73 1.8 3.3 15 11/11

Secondary and

Advanced

2 2.2 2.4 2.4 2/2

Primary,

Secondary, and

Advanced

1 1.6 1.7 1.7 7/7

Ra-224 Primary 0.8 0.8 0.8 0.8 1/1

Secondary ND ND 0.5 0.5 3/7

Advanced ND 0.8 4.9 4.9 4/7

Primary and

Secondary

ND ND 1.3 2.4 3/11

Secondary and

Advanced

0.4 1.2 2 2 2/2

Primary,

Secondary, and

Advanced

ND ND 1.8 1.8 2/7

Ra-228 Primary 2.3 2.3 2.3 2.3 1/1

Secondary 0.65 1.8 3.4 3.4 7/7

Advanced 1.46 2.5 24 24 7/7

Primary and

Secondary

0.68 3.7 9.9 30 11/11

Secondary and

Advanced

5.7 11.35 17 17 2/2

Primary,

Secondary, and

Advanced

2 3 8.2 8.2 7/7

Th-228 Primary 1.4 1.4 1.4 1.4 1/1

Secondary 0.4 1 1.7 1.7 4/4

Advanced 0.68 1.3 6.7 6.7 7/7

Primary and

Secondary

ND 2.25 14 14 7/8

Secondary and

Advanced

1.7 2.7 3.7 3.7 2/2

Primary,

Secondary, and

Advanced

0.7 1.7 2.4 2.4 6/6
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-43

Th-232 Primary 0.7 0.7 0.7 0.7 1/1

Secondary 0.22 0.75 1 1 4/4

Advanced 0.39 0.8 0.9 0.9 7/7

Primary and

Secondary

ND 0.505 1.7 1.7 7/8

Secondary and

Advanced

0.3 0.4 0.5 0.5 2/2

Primary,

Secondary, and

Advanced

0.34 0.495 0.8 0.8 6/6

Tl-208 Primary 0.36 0.36 0.36 0.36 1/1

Secondary ND 0.29 1.48 1.48 6/7

Advanced 0.3 1.05 2 2 7/7

Primary and

Secondary

0.34 1.03 3.1 13.5 11/11

Secondary and

Advanced

0.61 0.67 0.73 0.73 2/2

Primary,

Secondary, and

Advanced

ND 0.55 1.6 1.6 5/7

Radionuclide Group: Medical Isotopes

I-125 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND 0.8 1/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND 1 1 3/7

I-131 Primary 3.8 3.8 3.8 3.8 1/1

Secondary ND ND 7.4 7.4 3/7

Advanced ND 1.6 81 81 5/7

Primary and

Secondary

ND 0.22 1.17 1.2 8/11

Secondary and

Advanced

0.22 0.68 1.14 1.14 2/2

Primary,

Secondary, and

Advanced

ND 0.03 4.2 4.2 4/7
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-44

In-111 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Tl-201 Primary 1.3 1.3 1.3 1.3 1/1

Secondary ND ND 26 26 1/7

Advanced ND 0.36 105 105 4/7

Primary and

Secondary

ND 1 12.4 48 8/11

Secondary and

Advanced

1.3 47.15 93 93 2/2

Primary,

Secondary, and

Advanced

ND ND 61 61 3/7

Tl-202 Primary 0.07 0.07 0.07 0.07 1/1

Secondary ND ND 0.77 0.77 1/7

Advanced ND ND 1.1 1.1 1/7

Primary and

Secondary

ND ND 0.1 0.99 2/11

Secondary and

Advanced

0.14 0.835 1.53 1.53 2/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/79

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Primary 8.3 8.3 8.3 8.3 1/1

Secondary 0.8 1.2 13 13 7/7

Advanced ND 3.6 15 15 6/7

Primary and

Secondary

0.14 7.6 15.4 30 11/11

Secondary and

Advanced

4.3 6 7.7 7.7 2/2

Primary,

Secondary, and

Advanced

0.5 4.3 27 27 7/7
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-45

K-40 Primary 11.4 11.4 11.4 11.4 1/1

Secondary 9.7 15 22 22 7/7

Advanced 7.4 12.7 22.4 22.4 7/7

Primary and

Secondary

7.9 16 19.8 20.9 11/11

Secondary and

Advanced

9.4 11.45 13.5 13.5 2/2

Primary,

Secondary, and

Advanced

12 14 17.9 17.9 7/7

La-138 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Radionuclide Group: Transuranics

Am-241 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND 0.04 1/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND 0.21 0.21 1/7

Pu-238 Primary 0.02 0.02 0.02 0.02 1/1

Secondary ND 0.03 0.1 0.1 3/4

Advanced ND 0.01 0.06 0.06 6/7

Primary and

Secondary

ND 0.01 0.1 0.1 5/8

Secondary and

Advanced

ND ND -

0.09

0.09 0.09 1/2

Primary,

Secondary, and

Advanced

ND 0.01 0.08 0.08 4/6
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-46

Pu-239 Primary ND ND ND ND 0/1

Secondary ND 0.02 0.04 0.04 3/4

Advanced ND 0.01 0.06 0.06 6/7

Primary and

Secondary

ND 0 0.17 0.17 5/8

Secondary and

Advanced

ND ND - 0.04 0.04 0.04 1/2

Primary,

Secondary, and

Advanced

ND 0 0.01 0.04 6/6

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND 0.8 1/11

Secondary and

Advanced

ND ND - 0.5 0.5 0.5 1/2

Primary,

Secondary, and

Advanced

ND ND 0.2 0.2 2/7

Rn-219 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND 0.4 1/11

Secondary and

Advanced

0.2 0.2 0.2 0.2 2/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Th-227 Primary 0.2 0.2 0.2 0.2 1/1

Secondary ND ND -

0.04

0.2 0.2 3/6

Advanced ND 0.02 0.6 0.6 4/7

Primary and

Secondary

ND ND 1.1 1.1 2/10

Secondary and

Advanced

0.1 0.2 0.3 0.3 2/2

Primary,

Secondary, and

Advanced

ND ND 0.2 0.2 2/7
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-47

U-235 Primary 0.3 0.3 0.3 0.3 1/1

Secondary ND 0.18 0.4 0.4 5/7

Advanced 0.06 0.11 0.7 0.7 7/7

Primary and

Secondary

ND 0.14 0.7 1.7 9/11

Secondary and

Advanced

0.03 0.05 0.07 0.07 2/2

Primary,

Secondary, and

Advanced

ND 0.18 3.4 3.4 6/7

Radionuclide Group:Fission and Activation Products

Ce-141 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Co-57 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND 0.17 0.17 1/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Co-60 Primary 0.03 0.038 0.038 0.038 1/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND 3.46 1/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-48

Cr-51 Primary ND ND ND ND 0/1

Secondary ND ND 0.3 0.3 2/7

Advanced ND ND 35 35 1/7

Primary and

Secondary

ND ND 0.3 0.8 2/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Cs-134 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Cs-137 Primary 0.09 0.09 0.09 0.09 1/1

Secondary 0.02 0.06 0.09 0.09 7/7

Advanced ND 0.05 0.11 0.11 6/7

Primary and

Secondary

0.03 0.08 0.23 0.37 11/11

Secondary and

Advanced

0.04 0.055 0.07 0.07 2/2

Primary,

Secondary, and

Advanced

0 0.08 0.27 0.27 7/7

Eu-154 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-49

Fe-59 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Sm-153 Primary ND ND ND ND 0/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

Sr-89 Primary 1 1 1 1 1/1

Secondary ND 0.6 30 30 3/5

Advanced ND 0.4 20 20 4/7

Primary and

Secondary

ND 2 300 300 8/9

Secondary and

Advanced

1 6.5 12 12 2/2

Primary,

Secondary, and

Advanced

ND ND 1 1 2/6

Sr-90 Primary 0.6 0.6 0.6 0.6 1/1

Secondary ND 0.1 1 1 3/5

Advanced ND 0.1 1 1 5/7

Primary and

Secondary

ND 0.1 6 6 8/9

Secondary and

Advanced

0.1 0.55 1 1 2/2

Primary,

Secondary, and

Advanced

ND 0.3 0.9 0.9 5/6
Table A.4 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question

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

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/gm = 37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-50

Zn-65 Primary 0.06 0.06 0.06 0.06 1/1

Secondary ND ND ND ND 0/7

Advanced ND ND ND ND 0/7

Primary and

Secondary

ND ND ND ND 0/11

Secondary and

Advanced

ND ND ND ND 0/2

Primary,

Secondary, and

Advanced

ND ND ND ND 0/7

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-51

Table A.5 Concentrations of Radionuclides in Sludge Summarized by 

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 10 MGD or less ND 0.36 3.5 16 115/153

10+ MGD to 50 MGD ND 0.3 1.9 6 72/91

50+ MGD to 100 MGD ND 0.21 1 2.1 24/32

More than 100 MGD ND 0.26 1.2 1.37 16/19

NR ND 0.205 0.71 1.8 11/16

Pa-234m 10 MGD or less ND ND 8 27 36/153

10+ MGD to 50 MGD ND ND 6 17 23/91

50+ MGD to 100 MGD ND ND 6 7 10/32

More than 100 MGD ND ND 11 11 7/19

NR ND ND 3 4 4/16

Pb-210 10 MGD or less ND ND 4 13 75/153

10+ MGD to 50 MGD ND ND 4.7 12 32/91

50+ MGD to 100 MGD ND ND 4.3 11 15/32

More than 100 MGD ND ND 3.6 4 6/19

NR ND ND 1.5 2.2 7/16

Pb-214 10 MGD or less ND 0.4 3.9 17 126/153

10+ MGD to 50 MGD ND 0.31 2.1 4.4 72/91

50+ MGD to 100 MGD ND 0.255 1.4 2.2 25/32

More than 100 MGD ND 0.24 0.9 1.42 17/19

NR ND 0.285 0.78 1.9 13/16

Ra-226 10 MGD or less ND 2 18 47 141/153

10+ MGD to 50 MGD ND 2 10 19 85/91

50+ MGD to 100 MGD ND 2.05 12 16 29/32

More than 100 MGD 0 2.4 8 10.1 19/19

NR ND 2 5 9.6 15/16

Th-230 10 MGD or less 0.11 0.36 1.2 1.7 49/49

10+ MGD to 50 MGD 0.18 0.35 0.8 1.7 23/23

50+ MGD to 100 MGD 0.09 0.3 0.42 0.42 6/6

More than 100 MGD 0.17 0.4 0.8 1 11/11

NR 0.1 0.48 1.6 1.6 3/3

Th-234 10 MGD or less ND 0.7 7 23 97/153

10+ MGD to 50 MGD ND 0.3 5 19 50/91

50+ MGD to 100 MGD ND 0.9 3 5.7 22/32

More than 100 MGD ND 1.3 10.6 12 13/19

NR ND 0.45 3.4 5 9/16

U-234 10 MGD or less 0.18 1.6 25 44 49/49

10+ MGD to 50 MGD 0.5 2.1 8.5 17 23/23

50+ MGD to 100 MGD 1.2 6.95 15 15 6/6

More than 100 MGD 0.8 2.1 12 15.4 11/11

NR 2.1 4.4 14 14 3/3
Table A.5 Concentrations of Radionuclides in Sludge Summarized by 

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-52

Radionuclide Group: C-14 and H-3

C-14* 10 MGD or less ND ND 2 3 34/85

10+ MGD to 50 MGD ND ND 1 2 18/39

50+ MGD to 100 MGD ND ND ND 0.5 1/16

More than 100 MGD ND 0 0.6 0.6 7/10

NR ND ND 0 0 3/8

H-3* 10 MGD or less ND 0.3 5 8 58/85

10+ MGD to 50 MGD ND 0.3 3 4 27/39

50+ MGD to 100 MGD ND 0.45 4 4 13/16

More than 100 MGD ND 0.1 2 2 6/10

NR ND 0.1 6 6 7/8

Radionuclide Group: Thorium-232 Decay Series

Bi-212 10 MGD or less ND ND 2 13 52/153

10+ MGD to 50 MGD ND ND 0.8 1.6 32/91

50+ MGD to 100 MGD ND ND 0.3 1.1 5/32

More than 100 MGD ND ND 0.8 0.9 6/19

NR ND ND 1 3 6/16

Pb-212 10 MGD or less ND 0.51 2.7 15 151/153

10+ MGD to 50 MGD ND 0.4 1.16 2 88/91

50+ MGD to 100 MGD ND 0.275 1 2.5 30/32

More than 100 MGD 0.16 0.55 1.4 1.55 19/19

NR ND 0.255 0.8 2.5 15/16

Ra-224 10 MGD or less ND ND 1 12 25/153

10+ MGD to 50 MGD ND ND 0.6 5 12/91

50+ MGD to 100 MGD ND ND 0.4 0.8 4/32

More than 100 MGD ND ND 0.6 0.7 4/19

NR ND ND 0.4 1 2/16

Ra-228 10 MGD or less ND 1 9.7 38 138/153

10+ MGD to 50 MGD ND 0.8 2.9 6 75/91

50+ MGD to 100 MGD ND 0.55 3 4.3 26/32

More than 100 MGD ND 0.9 3 4.8 17/19

NR ND 0.67 1.3 7.8 15/16

Th-228 10 MGD or less 0.16 0.9 6.8 9 49/49

10+ MGD to 50 MGD 0.19 0.5 1.7 1.8 23/23

50+ MGD to 100 MGD 0.07 0.27 0.48 0.48 6/6

More than 100 MGD 0.19 0.6 1.4 1.7 11/11

NR 0.8 1.1 6.7 6.7 3/3
Table A.5 Concentrations of Radionuclides in Sludge Summarized by 

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-53

Th-232 10 MGD or less 0.08 0.2 0.6 0.7 49/49

10+ MGD to 50 MGD 0.07 0.17 0.4 1.6 23/23

50+ MGD to 100 MGD 0.02 0.1 0.4 0.4 6/6

More than 100 MGD 0.09 0.39 0.56 0.9 11/11

NR 0.2 0.22 1.1 1.1 3/3

Tl-208 10 MGD or less ND 0.08 1.3 4.8 87/153

10+ MGD to 50 MGD ND 0.08 0.41 1.8 55/91

50+ MGD to 100 MGD ND 0.03 0.35 2.3 17/32

More than 100 MGD ND 0.07 0.69 0.88 11/19

NR ND 0.06 0.53 2.4 10/16

Radionuclide Group: Medical Isotopes

I-125 10 MGD or less ND ND ND 0.8 4/153

10+ MGD to 50 MGD ND ND ND 40 5/91

50+ MGD to 100 MGD ND ND ND 1.5 2/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

I-131 10 MGD or less ND 0.7 37 840 111/153

10+ MGD to 50 MGD ND 2.6 101 280 75/91

50+ MGD to 100 MGD ND 4.4 34 105 29/32

More than 100 MGD ND 5.6 28 65 16/19

NR ND 2.1 27 60.5 15/16

In-111 10 MGD or less ND ND ND 1.19 3/153

10+ MGD to 50 MGD ND ND ND 1.9 5/91

50+ MGD to 100 MGD ND ND 0.12 3.5 5/32

More than 100 MGD ND ND 0.033 0.18 2/19

NR ND ND 0.13 3.6 4/16

Tl-201 10 MGD or less ND ND 25 241 61/153

10+ MGD to 50 MGD ND 0.9 56 207 49/91

50+ MGD to 100 MGD ND 4.95 42 110 24/32

More than 100 MGD ND 2.7 31 49 11/19

NR ND ND 35 40 6/16

Tl-202 10 MGD or less ND ND 0.19 1.16 22/153

10+ MGD to 50 MGD ND ND 0.53 0.92 28/91

50+ MGD to 100 MGD ND ND 0.85 0.95 12/32

More than 100 MGD ND ND 0.28 0.59 5/19

NR ND ND 0.48 0.51 6/16
Table A.5 Concentrations of Radionuclides in Sludge Summarized by 

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-54

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 10 MGD or less ND 1.1 6 17 123/153

10+ MGD to 50 MGD ND 0.9 8 14.9 78/91

50+ MGD to 100 MGD ND 2.15 9 13.5 31/32

More than 100 MGD ND 2 19 22 17/19

NR ND 0.95 2.9 3.2 14/16

K-40 10 MGD or less ND 4 12 22 151/153

10+ MGD to 50 MGD ND 3.4 13 25 90/91

50+ MGD to 100 MGD 0.8 3.65 12 26 32/32

More than 100 MGD 2.3 5.1 10 10 19/19

NR 1.8 4.35 6 10 16/16

La-138 10 MGD or less ND ND ND ND 0/153

10+ MGD to 50 MGD ND ND ND 0.07 1/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

Radionuclide Group: Transuranics

Am-241 10 MGD or less ND ND ND 0.14 5/153

10+ MGD to 50 MGD ND ND ND 2.5 5/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

Pu-238 10 MGD or less ND 0.01 0.1 0.19 40/49

10+ MGD to 50 MGD ND 0.01 0.02 0.03 19/23

50+ MGD to 100 MGD ND 0.02 0.07 0.07 5/6

More than 100 MGD ND 0.01 0.07 0.14 10/11

NR ND ND 0 0 1/3

Pu-239 10 MGD or less ND 0.003 0.05 0.12 35/49

10+ MGD to 50 MGD ND 0.002 0.01 0.03 17/23

50+ MGD to 100 MGD ND 0 0.01 0.01 4/6

More than 100 MGD 0 0.005 0.04 0.07 11/11

NR ND ND 0.1 0.1 1/3

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 10 MGD or less ND ND ND 0.09 1/153

10+ MGD to 50 MGD ND ND ND ND 0/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND 0.06 1/19

NR ND ND ND ND 0/16
Table A.5 Concentrations of Radionuclides in Sludge Summarized by 

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-55

Rn-219 10 MGD or less ND ND ND ND 0/153

10+ MGD to 50 MGD ND ND ND ND 0/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

Th-227 10 MGD or less ND ND 0.1 0.5 26/111

10+ MGD to 50 MGD ND ND 0.05 0.15 12/51

50+ MGD to 100 MGD ND ND 0.02 0.04 4/20

More than 100 MGD ND ND 0.1 0.1 6/16

NR ND ND 0.07 0.07 1/9

U-235 10 MGD or less ND ND 0.41 3.1 59/153

10+ MGD to 50 MGD ND ND 0.42 1.3 31/91

50+ MGD to 100 MGD ND ND 0.21 0.7 6/32

More than 100 MGD ND 0.06 0.58 0.6 11/19

NR ND ND 0.3 0.6 5/16

Radionuclide Group: Fission and Activation Products

Ce-141 10 MGD or less ND ND ND ND 0/153

10+ MGD to 50 MGD ND ND ND 0.016 1/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

Co-57 10 MGD or less ND ND ND 0.01 1/153

10+ MGD to 50 MGD ND ND ND 0.05 1/91

50+ MGD to 100 MGD ND ND ND 0.06 2/32

More than 100 MGD ND ND ND 0.04 1/19

NR ND ND ND 0.26 1/16

Co-60 10 MGD or less ND ND 0.016 5.1 9/153

10+ MGD to 50 MGD ND ND ND 0.1 3/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND 0.03 1/19

NR ND ND ND ND 0/16

Cr-51 10 MGD or less ND ND ND ND 0/153

10+ MGD to 50 MGD ND ND ND ND 0/91

50+ MGD to 100 MGD ND ND 0.6 2.8 5/32

More than 100 MGD ND ND ND 3.5 1/19

NR ND ND ND ND 0/16

Cs-134 10 MGD or less ND ND ND 0.04 1/153

10+ MGD to 50 MGD ND ND ND ND 0/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16
Table A.5 Concentrations of Radionuclides in Sludge Summarized by 

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-56

Cs-137 10 MGD or less ND ND 0.11 3.6 66/153

10+ MGD to 50 MGD ND ND 0.06 0.3 32/91

50+ MGD to 100 MGD ND 0.01 0.05 0.3 17/32

More than 100 MGD ND 0.02 0.14 0.19 13/19

NR ND ND 0.3 0.73 5/16

Eu-154 10 MGD or less ND ND ND 21 1/153

10+ MGD to 50 MGD ND ND ND ND 0/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

Fe-59 10 MGD or less ND ND ND 0.4 1/153

10+ MGD to 50 MGD ND ND ND ND 0/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

Sm-153 10 MGD or less ND ND ND 27 1/153

10+ MGD to 50 MGD ND ND ND ND 0/91

50+ MGD to 100 MGD ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

Sr-89 10 MGD or less ND 1 7 30 32/49

10+ MGD to 50 MGD ND 0.2 20 70 14/23

50+ MGD to 100 MGD ND 0.5 30 30 8/10

More than 100 MGD ND 0.45 5 40 11/12

NR ND 0.05 10 10 3/4

Sr-90 10 MGD or less ND 0.1 2 9.4 31/49

10+ MGD to 50 MGD ND 0.2 0.4 1 16/23

50+ MGD to 100 MGD ND 0.05 0.5 0.5 6/10

More than 100 MGD ND 0.1 0.4 1 7/12

NR 0.1 0.1 0.1 0.1 4/4

Zn-65 10 MGD or less ND ND ND 0.06 1/153

10+ MGD to 50 MGD ND ND ND ND 0/91

Zn-6550+ MGD to 100

MGD

ND ND ND ND 0/32

More than 100 MGD ND ND ND ND 0/19

NR ND ND ND ND 0/16

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-57

Table A.6 Concentration of Radionuclides in Ash Summarized by

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g = 37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 10 MGD or less ND 2.2 16 16 6/7

10+ MGD to 50 MGD 0.62 2.8 13.7 14 15/15

50+ MGD to 100 MGD 0.64 1.7 3.8 3.8 5/5

More than 100 MGD 2.1 3.1 14.1 14.1 5/5

NR 0.72 1.7 1.8 1.8 3/3

Pa-234m 10 MGD or less ND 3 77 77 6/7

10+ MGD to 50 MGD ND 2 7 10 11/15

50+ MGD to 100 MGD 2 5 9 9 5/5

More than 100 MGD 2 5 6 6 5/5

NR 3 5 11 11 3/3

Pb-210 10 MGD or less ND 3.4 8.9 8.9 5/7

10+ MGD to 50 MGD ND ND 5.3 12.3 5/15

50+ MGD to 100 MGD ND ND 5 5 2/5

More than 100 MGD ND ND 6.4 6.4 1/5

NR 1.8 1.9 8.5 8.5 3/3

Pb-214 10 MGD or less 0.92 2.4 16.4 16.4 7/7

10+ MGD to 50 MGD 0.61 3.1 14.6 14.8 15/15

50+ MGD to 100 MGD 0.69 1.9 4.1 4.1 5/5

More than 100 MGD 2.2 3.4 15.1 15.1 5/5

NR 0.74 1.9 2 2 3/3

Ra-226 10 MGD or less 1 3.4 15 15 7/7

10+ MGD to 50 MGD ND 3.4 18 18 13/15

50+ MGD to 100 MGD 1.1 2 9 9 5/5

More than 100 MGD 2.5 4 22 22 5/5

NR 0 2 2.9 2.9 3/3

Th-230 10 MGD or less ND 0.64 2.3 2.3 6/7

10+ MGD to 50 MGD 0.3 0.8 1.5 2.6 13/13

50+ MGD to 100 MGD 0.4 0.7 1.3 1.3 3/3

More than 100 MGD 0.9 1 2.2 2.2 3/3

NR 0.55 0.595 0.64 0.64 2/2

Th-234 10 MGD or less 1.1 2.7 80 80 7/7

10+ MGD to 50 MGD ND 1.8 7.3 21 11/15

50+ MGD to 100 MGD 1.7 5.1 7.5 7.5 5/5

More than 100 MGD 1.1 3.8 5.1 5.1 5/5

NR 1.9 3.6 11 11 3/3

U-234 10 MGD or less 1.2 6 91 91 7/7

10+ MGD to 50 MGD 1.3 2.6 18 49 13/13

50+ MGD to 100 MGD 2.7 6.9 9 9 3/3

More than 100 MGD 5 5.8 7 7 3/3

NR 2.7 10.85 19 19 2/2
Table A.6 Concentration of Radionuclides in Ash Summarized by

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g = 37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-58

U-238 10 MGD or less 1.1 4.3 74 74 7/7

10+ MGD to 50 MGD 0.8 2.4 6.2 35 13/13

50+ MGD to 100 MGD 2.5 6.2 6.4 6.4 3/3

More than 100 MGD 3.8 4.7 5.1 5.1 3/3

NR 2.5 8.75 15 15 2/2

C-14* 10 MGD or less ND ND 1 1 2/5

10+ MGD to 50 MGD ND ND 0 0 1/6

50+ MGD to 100 MGD ND ND - 1 1 1 1/2

More than 100 MGD ND ND - 0 0 0 1/2

NR ND ND ND ND 0/3

H-3* 10 MGD or less ND 0.5 4 4 3/5

10+ MGD to 50 MGD ND ND 1 1 2/6

50+ MGD to 100 MGD 3 5.5 8 8 2/2

More than 100 MGD ND ND ND ND 0/2

NR ND ND ND ND 0/3

Radionuclide Group: Thorium-232 Decay Series

Bi-212 10 MGD or less ND 1.5 15.7 15.7 6/7

10+ MGD to 50 MGD ND 1.2 3.5 5.5 10/15

50+ MGD to 100 MGD 0.3 1.6 1.8 1.8 5/5

More than 100 MGD ND 0.9 1.4 1.4 4/5

NR ND ND ND ND 0/3

Pb-212 10 MGD or less 1.14 1.7 15 15 7/7

10+ MGD to 50 MGD 0.74 1.6 3.3 6.6 15/15

50+ MGD to 100 MGD 0.36 1.5 1.7 1.7 5/5

More than 100 MGD 0.91 1.42 1.5 1.5 5/5

NR 0.73 1.1 1.2 1.2 3/3

Ra-224 10 MGD or less ND ND 1.8 1.8 2/7

10+ MGD to 50 MGD ND 0.4 2.4 4.9 8/15

50+ MGD to 100 MGD ND ND 1.3 1.3 2/5

More than 100 MGD ND 0.5 1.3 1.3 3/5

NR ND ND ND ND 0/3

Ra-228 10 MGD or less 1.8 3 30 30 7/7

10+ MGD to 50 MGD 0.68 4.7 17 24 15/15

50+ MGD to 100 MGD 0.65 2.2 3.4 3.4 5/5

More than 100 MGD 1.6 2.4 9.9 9.9 5/5

NR 1.8 1.9 2.9 2.9 3/3

Th-228 10 MGD or less ND 1.3 14 14 6/7

10+ MGD to 50 MGD 0.9 2.2 3.7 6.7 13/13

50+ MGD to 100 MGD 0.4 1.7 1.7 1.7 3/3

More than 100 MGD 0.9 1.1 2.3 2.3 3/3

NR 0.68 0.84 1 1 2/2
Table A.6 Concentration of Radionuclides in Ash Summarized by

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g = 37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-59

Th-232 10 MGD or less ND 0.49 0.7 0.7 6/7

10+ MGD to 50 MGD 0.3 0.8 0.9 1.7 13/13

50+ MGD to 100 MGD 0.22 0.8 0.8 0.8 3/3

More than 100 MGD 0.5 0.7 1 1 3/3

NR 0.39 0.425 0.46 0.46 2/2

Tl-208 10 MGD or less 0.36 1.4 13.5 13.5 7/7

10+ MGD to 50 MGD ND 0.66 2.3 3.1 13/15

50+ MGD to 100 MGD 0.11 0.47 1.48 1.48 5/5

More than 100 MGD ND 0.34 1.6 1.6 4/5

NR 0.63 1.03 1.05 1.05 3/3

Radionuclide Group: Medical Isotopes

 I-125 10 MGD or less ND ND 1 1 3/7

10+ MGD to 50 MGD ND ND ND 0.3 1/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

I-131 10 MGD or less ND 0.13 3.8 3.8 5/7

10+ MGD to 50 MGD ND 0.39 20 46 9/15

50+ MGD to 100 MGD ND ND 7.4 7.4 1/5

More than 100 MGD 0.05 0.17 4.3 4.3 5/5

NR 0.22 1.2 81 81 3/3

In-111 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Tl-201 10 MGD or less ND 3.3 61 61 6/7

10+ MGD to 50 MGD ND ND 93 105 7/15

50+ MGD to 100 MGD ND ND 26 26 1/5

More than 100 MGD ND ND 35 35 2/5

NR 0.62 1 73 73 3/3

Tl-202 10 MGD or less ND ND 0.07 0.07 1/7

10+ MGD to 50 MGD ND ND 1.1 1.53 3/15

50+ MGD to 100 MGD ND ND 0.77 0.77 1/5

More than 100 MGD ND ND 0.99 0.99 2/5

NR ND ND ND ND 0/3
Table A.6 Concentration of Radionuclides in Ash Summarized by

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g = 37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-60

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 10 MGD or less 2.2 4.3 8.3 8.3 7/7

10+ MGD to 50 MGD ND 5.3 15 15.4 14/15

50+ MGD to 100 MGD 0.5 0.8 1.9 1.9 5/5

More than 100 MGD 3.5 12.5 27 27 5/5

NR 3.6 6.1 30 30 3/3

K-40 10 MGD or less 11.4 13.7 19.8 19.8 7/7

10+ MGD to 50 MGD 7.4 14 20 22.4 15/15

50+ MGD to 100 MGD 13 17.4 22 22 5/5

More than 100 MGD 11 15 16 16 5/5

NR 7.9 10.8 20.9 20.9 3/3

La-138 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND ND 0/15

 50+ MGD to 100 MGD N D ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Radionuclide Group: Transuranics

Am-241 10 MGD or less ND ND 0.21 0.21 2/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Pu-238 10 MGD or less ND ND 0.1 0.1 3/7

10+ MGD to 50 MGD ND 0.02 0.08 0.09 10/13

50+ MGD to 100 MGD ND 0.03 0.05 0.05 2/3

More than 100 MGD 0 0.01 0.1 0.1 3/3

NR 0 0.01 0.02 0.02 2/2

Pu-239 10 MGD or less ND ND 0.03 0.03 3/7

10+ MGD to 50 MGD ND 0.01 0.06 0.17 11/13

50+ MGD to 100 MGD ND 0.01 0.02 0.02 2/3

More than 100 MGD 0 0.02 0.04 0.04 3/3

NR 0.01 0.03 0.05 0.05 2/2

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 10 MGD or less ND ND 0.2 0.2 1/7

10+ MGD to 50 MGD ND ND 0.5 0.8 2/15

50+ MGD to 100 MGD ND ND 0.1 0.1 1/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3
Table A.6 Concentration of Radionuclides in Ash Summarized by

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g = 37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-61

Rn-219 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND 0.2 0.4 3/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Th-227 10 MGD or less ND ND 0.2 0.2 2/7

10+ MGD to 50 MGD ND ND-0.02 0.6 1.1 7/14

50+ MGD to 100 MGD ND 0.04 0.2 0.2 3/5

More than 100 MGD ND ND- 0.2 0.2 0.2 2/4

NR ND ND ND ND 0/3

U-235 10 MGD or less 0.07 0.3 3.4 3.4 7/7

10+ MGD to 50 MGD ND 0.11 0.7 1.7 14/15

50+ MGD to 100 MGD ND 0.18 0.6 0.6 3/5

More than 100 MGD ND 0.18 0.4 0.4 4/5

NR ND 0.14 0.7 0.7 2/3

Radionuclide Group: Fission and Activation Products

Ce-141 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Co-57 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND 0.17 1/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Co-60 10 MGD or less ND ND 0.038 0.038 1/7

10+ MGD to 50 MGD ND ND ND 3.46 1/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Cr-51 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND 0.3 0.3 2/5

More than 100 MGD ND ND 0.8 0.8 2/5

NR ND ND 35 35 1/3

Cs-134 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3
Table A.6 Concentration of Radionuclides in Ash Summarized by

Annual Average Flow Rate Expressed in Million Gallons per Day (MGD)

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g = 37 Bq/kg.)

Radionuclide Flow Rate Min Median 95th P Max No. Detects/

No. Analyses

A-62

Cs-137 10 MGD or less 0 0.07 0.11 0.11 7/7

10+ MGD to 50 MGD ND 0.06 0.18 0.37 14/15

50+ MGD to 100 MGD 0.02 0.08 0.09 0.09 5/5

More than 100 MGD 0.04 0.08 0.27 0.27 5/5

NR 0.04 0.07 0.23 0.23 3/3

Eu-154 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Fe-59 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Sm-153 10 MGD or less ND ND ND ND 0/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

Sr-89 10 MGD or less ND ND 2 2 3/7

10+ MGD to 50 MGD ND 1.15 20 60 11/14

50+ MGD to 100 MGD ND ND 30 30 1/4

More than 100 MGD 0.6 3 300 300 3/3

NR 0.4 2.7 5 5 2/2

Sr-90 10 MGD or less ND 0 1 1 6/7

10+ MGD to 50 MGD ND 0.2 1 1 12/14

50+ MGD to 100 MGD ND 0.95 1 1 3/4

More than 100 MGD ND 0.1 6 6 2/3

NR ND ND-0.4 0.4 0.4 1/2

Zn-65 10 MGD or less ND ND 0.06 0.06 1/7

10+ MGD to 50 MGD ND ND ND ND 0/15

50+ MGD to 100 MGD ND ND ND ND 0/5

More than 100 MGD ND ND ND ND 0/5

NR ND ND ND ND 0/3

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-63

Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 A ND 0.245 1.1 1.5 79/106

B ND 0.485 6.8 16 74/84

C ND 0.32 1.6 1.6 2/3

D ND 0.26 1 1.4 8/11

AB ND 0.39 1.8 4.1 33/48

AC ND 0.27 0.8 1.2 10/13

BC ND 0.4 7.9 13 14/17

CD 0.17 0.17 0.17 0.17 1/1

ABC ND 0.19 0.8 2.1 10/17

BCD ND ND ND ND 0/1

ABCD 0.17 0.34 1.23 1.23 5/5

NR ND ND 0.2 0.2 2/5

Pa-234m A ND ND 7 16 32/106

B ND ND 5 27 15/84

C ND ND 1 1 1/3

D ND ND 6 17 3/11

AB ND ND 9 20 15/48

AC ND ND 2 6 2/13

BC ND ND 6 17 3/17

CD ND ND ND ND 0/1

ABC ND ND 6 22 7/17

BCD 3 3 3 3 1/1

ABCD ND ND 2.6 2.6 1/5

NR ND ND ND ND 0/5

Pb-210 A ND ND 4 13 48/106

B ND ND 2.5 9 35/84

C ND 2.2 3.1 3.1 2/3

D ND 1.2 8 11 8/11

AB ND ND 6 12 18/48

AC ND ND 2.5 3 6/13

BC ND ND 1.4 4.7 7/17

CD ND ND ND ND 0/1

ABC ND ND 2.5 2.7 7/17

BCD ND ND ND ND 0/1

ABCD ND 1.5 3 3 3/5

NR ND ND 0 0 1/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-64

Pb-214 A ND 0.265 1.3 1.5 79/106

B ND 0.545 7.6 17 75/84

C 0.27 0.33 1.8 1.8 3/3

D ND 0.29 1.3 2 9/11

AB ND 0.4 2 4.4 36/48

AC ND 0.31 0.8 1 11/13

BC ND 0.48 8.3 15 14/17

CD 0.28 0.28 0.28 0.28 1/1

ABC ND 0.24 0.9 2.2 15/17

BCD 0.2 0.2 0.2 0.2 1/1

ABCD 0.15 0.39 1.4 1.4 5/5

NR ND 0.2 0.4 0.4 4/5

Radionuclide Group: Uranium-238 Decay Series

Ra-226 A ND 2 10 17 96/106

B ND 3 24 47 78/84

C 0 3 5.6 5.6 3/3

D ND 2.2 4 5 9/11

AB ND 2 11 15 46/48

AC 0 1.7 3 4 13/13

BC 0.3 3 19 30 17/17

CD 3.2 3.2 3.2 3.2 1/1

ABC 0 1.5 10 12 17/17

BCD 5 5 5 5 1/1

ABCD ND 1.2 2.2 2.2 4/5

NR ND 2 4 4 4/5

Th-230 A 0.1 0.435 1.2 1.6 24/24

B 0.12 0.31 0.8 1.7 38/38

C 0.61 0.61 0.61 0.61 1/1

D 0.21 0.35 1.7 1.7 3/3

AB 0.09 0.36 0.57 0.62 12/12

AC 0.49 0.49 0.49 0.49 1/1

BC 0.11 0.315 0.5 0.5 8/8

ABC 0.17 0.3 0.38 0.38 5/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-65

Th-234 A ND 0.7 7.8 15 65/106

B ND 0.5 5 23 50/84

C ND 0.5 1.3 1.3 2/3

D ND 1 2.3 11 9/11

AB ND 0.9 8 19 32/48

AC ND 1 2.3 6.8 8/13

BC ND 0.1 3.6 15 9/17

CD 1.2 1.2 1.2 1.2 1/1

ABC ND 0.5 5 16 9/17

BCD ND ND ND ND 0/1

ABCD ND 0.9 2.7 2.7 4/5

NR ND ND 3 3 2/5

U-234 A 0.43 2.1 14 15.4 24/24

B 0.39 1.95 14 34 38/38

C 1 1 1 1 1/1

D 0.71 2.1 17 17 3/3

AB 0.8 2.05 15 44 12/12

AC 2.1 2.1 2.1 2.1 1/1

BC 0.18 0.85 25 25 8/8

ABC 0.8 1.3 20 20 5/5

U-238 A 0.37 1.9 10.3 12.5 24/24

B 0.18 1.35 6.6 26 38/38

C 1 1 1 1 1/1

D 0.53 2 12 12 3/3

AB 0.7 1.6 8 12 12/12

AC 1.4 1.4 1.4 1.4 1/1

BC 0.19 0.65 15 15 8/8

ABC 0.6. 1.3 16 16 5/5

Radionuclide Group: C-14 and H-3

C-14 * A ND ND 1 2 23/58

B ND ND 1 2 15/40

C 0 0.5 1 1 2/2

D ND ND 2 2 3/8

AB ND ND 1 3 9/23

AC ND ND 0 0 2/7

BC ND 0.5 1 1 5/8

ABC ND ND 2 2 3/8

ABCD ND ND ND ND 0/3

NR ND ND ND ND 0/1
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-66

H-3* A ND 0.25 4 5 39/58

B ND 0.25 4 6 27/40

C 0 3.5 7 7 2/2

D 0.1 1 3 3 8/8

AB ND 0.5 3 5 18/23

AC ND ND 4 4 3/7

BC ND ND - 1 8 8 4/8

ABC ND 0.45 6 6 7/8

ABCD 0 0.4 4 4 3/3

NR ND ND ND ND 0/1

Radionuclide Group: Thorium-232 Decay Series

Bi-212 A ND ND 1 1.3 38/106

B ND ND 3.3 13 29/84

C ND ND 0.7 0.7 1/3

D ND ND ND 0.4 1/11

AB ND ND 1.4 2.6 12/48

AC ND ND 0.7 0.8 4/13

BC ND ND 1.3 4 6/17

CD 1 1 1 1 1/1

ABC ND ND 0.9 0.9 5/17

BCD 0.6 0.6 0.6 0.6 1/1

ABCD ND ND ND ND 0/5

NR ND 0.5 1 1 3/5

Pb-212 A ND 0.435 1 1.55 102/106

B ND 0.555 3 15 82/84

C 0.57 0.8 3.1 3.1 3/3

D 0.2 0.47 1.4 1.9 11/11

AB ND 0.4 1.9 2.9 47/48

AC ND 0.49 1.4 1.4 12/13

BC 0.07 0.47 2.5 3 17/17

CD 1.2 1.2 1.2 1.2 1/1

ABC 0.12 0.27 0.58 0.62 17/17

BCD 0.47 0.47 0.47 0.47 1/1

ABCD 0.21 0.28 2.5 2.5 5/5

NR 0.2 0.4 0.6 0.6 5/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-67

Ra-224 A ND ND 0.7 1.1 16/106

B ND ND 2.3 12 15/84

C ND ND 1 1 1/3

D ND ND ND 0.4 1/11

AB ND ND 1 2.7 8/48

AC ND ND ND 0.4 1/13

BC ND ND 0.9 3 3/17

CD 1.1 1.1 1.1 1.1 1/1

ABC ND ND ND 0.2 1/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Ra-228 A ND 0.7 1.9 5 92/106

B ND 1.2 12 38 76/84

C 0.6 0.8 8 8 3/3

D ND 0.78 1.6 2.8 9/11

AB ND 0.85 3 6 37/48

AC ND 0.56 3.1 4.8 11/13

BC ND 1.3 12 13 16/17

CD 4.5 4.5 4.5 4.5 1/1

ABC ND 0.84 1.6 2.3 16/17

BCD 0.9 0.9 0.9 0.9 1/1

ABCD 0.44 0.6 2.5 2.5 5/5

NR ND 0.7 1.1 1.1 4/5

Radionuclide Group: Thorium-232 Decay Series

Th-228 A 0.23 0.53 1.3 1.4 24/24

B 0.19 0.8 6.8 9 38/38

C 2.6 2.6 2.6 2.6 1/1

D 0.36 0.5 1.8 1.8 3/3

AB 0.07 0.495 0.8 2.4 12/12

AC 1.7 1.7 1.7 1.7 1/1

BC 0.42 1.65 4.1 4.1 8/8

ABC 0.19 0.27 0.57 0.57 5/5

Th-232 A 0.13 0.315 0.9 1.1 24/24

B 0.07 0.2 0.46 0.6 38/38

C 0.37 0.37 0.37 0.37 1/1

D 0.13 0.24 1.6 1.6 3/3

AB 0.02 0.205 0.4 0.4 12/12

AC 0.44 0.44 0.44 0.44 1/1

BC 0.08 0.105 0.31 0.31 8/8

ABC 0.09 0.1 0.27 0.27 5/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-68

Tl-208 A ND 0.08 0.69 0.99 62/106

B ND 0.09 2.4 4.8 52/84

C 0.23 0.53 2.7 2.7 3/3

D ND ND 1.4 1.8 5/11

AB ND ND 0.6 1.44 22/48

AC ND ND 0.2 0.23 6/13

BC ND 0.07 1.1 1.9 10/17

CD 0.37 0.37 0.37 0.37 1/1

ABC ND 0.05 0.17 0.27 11/17

BCD 0.11 0.11 0.11 0.11 1/1

ABCD ND 0.06 2.3 2.3 3/5

NR ND 0.11 0.15 0.15 4/5

Radionuclide Group: Medical Isotopes

I-125 A ND ND 0.8 40 6/106

B ND ND ND 0.9 1/84

C ND ND 0.3 0.3 1/3

D ND ND ND 0.5 1/11

AB ND ND ND 0.7 1/48

AC ND ND ND 4 1/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

I-131 A ND 2.35 60.5 280 88/106

B ND 1.3 42 220 65/84

C ND 0.59 2.2 2.2 2/3

D ND 4.1 51 73 9/11

AB ND 1.65 105 840 36/48

AC ND 0.56 23 106 9/13

BC ND 0.2 4.2 39 9/17

CD 0.11 0.11 0.11 0.11 1/1

ABC 0.04 4.2 19 36 17/17

BCD 2 2 2 2 1/1

ABCD 0.17 11.3 65 65 5/5

NR ND 2.2 34 34 4/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-69

In-111 A ND ND 0.04 3.6 8/106

B ND ND ND 0.17 2/84

C ND ND 0.05 0.05 1/3

D ND ND ND ND 0/11

AB ND ND ND 0.12 1/48

AC ND ND ND 0.04 1/13

BC ND ND 0.044 0.4 2/17

CD ND ND ND ND 0/1

ABC ND ND 3 3.5 4/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Tl-201 A ND 0.9 45 207 59/106

B ND ND 34 138 31/84

C ND 0.49 0.7 0.7 2/3

D ND 3.5 11.6 16 6/11

AB ND ND 110 241 20/48

AC ND 0.34 16 189 7/13

BC ND ND 7.3 19 6/17

CD 3.7 3.7 3.7 3.7 1/1

ABC ND 2.3 19 51 13/17

BCD 56 56 56 56 1/1

ABCD ND 10.2 31 31 4/5

NR ND ND 13 13 1/5

Tl-202 A ND ND 0.51 0.92 25/106

B ND ND 0.66 0.95 19/84

C ND ND ND ND 0/3

D ND ND ND 0.11 1/11

AB ND ND 0.4 0.85 8/48

AC ND ND 0.19 0.19 3/13

BC ND ND 0.09 0.55 3/17

CD 0.14 0.14 0.14 0.14 1/1

ABC ND ND 0.54 0.54 8/17

BCD 1.16 1.16 1.16 1.16 1/1

ABCD ND ND 0.59 0.59 2/5

NR ND ND 0.14 0.14 2/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-70

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 A ND 1.8 11 22 95/106

B ND 0.57 4 8 64/84

C 0.7 1.2 2.9 2.9 3/3

D 0.2 2 8 9 11/11

AB ND 0.8 4.9 8.7 38/48

AC ND 1.4 14.9 17 12/13

BC ND 0.6 5.5 8.6 12/17

CD 1.5 1.5 1.5 1.5 1/1

ABC 0.4 1.9 6.6 10.7 17/17

BCD 1.8 1.8 1.8 1.8 1/1

ABCD 0.11 1.4 4.1 4.1 5/5

NR ND 1.5 1.6 1.6 4/5

K-40 A ND 4.35 12 15.4 105/106

B ND 4 13 22 83/84

C 3.2 3.6 5.4 5.4 3/3

D 2.3 4.5 22 26 11/11

AB ND 3.25 12 25 47/48

AC 1.1 5.1 10 10 13/13

BC 1.4 3.6 6 6 17/17

CD 3 3 3 3 1/1

ABC 0.9 3.5 8.7 9 17/17

BCD 1.9 1.9 1.9 1.9 1/1

ABCD 2.5 4.8 6.7 6.7 5/5

NR 2.1 3 4 4 5/5

La-138 A ND ND ND ND 0/106

B ND ND ND ND 0/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND ND 0/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND 0.07 0.07 1/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-71

Radionuclide Group: Transuranics

Am-241 A ND ND ND 0.3 3/106

B ND ND 0 2.5 5/84

C ND ND 0.12 0.12 1/3

D ND ND ND ND 0/11

AB ND ND ND ND 0/48

AC ND ND ND ND 0/13

BC ND ND ND 0.1 1/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Pu-238 A ND 0.01 0.07 0.14 22/24

B ND 0.01 0.05 0.1 30/38

C 0.19 0.19 0.19 0.19 1/1

D ND 0.01 0.01 0.01 2/3

AB ND 0.01 0.03 0.03 10/12

AC ND ND ND ND 0/1

BC ND 0.01 0.1 0.1 6/8

ABC ND 0.01 0.02 0.02 4/5

Pu-239

A ND 0.0035 0.07 0.1 17/24

B ND 0.002 0.03 0.03 26/38

C 0.11 0.11 0.11 0.11 1/1

D ND 0.004 0.009 0.009 2/3

AB ND 0.0035 0.04 0.04 11/12

AC 0.00 0.004 0.004 0.004 1/1

BC ND 0.01 0.12 0.12 6/8

ABC ND 0.003 0.01 0.01 4/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-72

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 A ND ND ND 0.09 1/106

B ND ND ND ND 0/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND 0.06 1/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Rn-219 A ND ND ND ND 0/106

B ND ND ND ND 0/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND ND 0/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Th-227 A ND ND 0.07 0.1 7/65

B ND ND 0.1 0.5 22/62

C ND ND ND ND 0/2

D ND ND 0.04 0.04 2/10

AB ND ND 0.07 0.1 10/33

AC ND ND ND ND 0/7

BC ND ND 0.2 0.2 5/13

ABC ND ND 0.02 0.04 3/11

ABCD ND ND ND ND 0/3

NR ND ND ND ND 0/1
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-73

U-235 A ND ND 0.42 0.61 31/106

B ND ND - 0 0.5 1.3 42/84

C ND 0.06 0.17 0.17 2/3

D ND ND 0.07 1.3 3/11

AB ND ND 0.46 3.1 16/48

AC ND ND 0.15 0.31 3/13

BC ND 0.01 0.28 0.7 9/17

CD ND ND ND ND 0/1

ABC ND ND 0.1 0.7 5/17

BCD 0.3 0.3 0.3 0.3 1/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Radionuclide Group: Fission and Activation Products

Ce-141 A ND ND ND ND 0/106

B ND ND ND 0.016 1/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND ND 0/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Co-57 A ND ND ND ND 0/106

B ND ND ND 0.05 2/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND 0.26 1/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND 0.06 0.06 3/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-74

Co-60 A ND ND ND 0.1 3/106

B ND ND ND 1.16 4/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND 5.1 2/48

AC ND ND ND ND 0/13

BC ND ND ND 0.07 1/17

CD ND ND ND ND 0/1

ABC ND ND 0.04 0.08 3/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Cr-51 A ND ND ND 2.8 3/106

B ND ND ND ND 0/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND 3.5 1/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND 0.6 0.8 2/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Radionuclide Group: Fission and Activation Products

Cs-134 A ND ND ND ND 0/106

B ND ND ND 0.04 1/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND ND 0/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-75

Cs-137 A ND 0.02 0.19 1.5 63/106

B ND ND 0.08 3.6 25/84

C ND 0.03 0.07 0.07 2/3

D ND ND 0.1 0.3 4/11

AB ND ND 0.11 1.1 16/48

AC ND ND 0.05 0.07 5/13

BC ND ND 0.1 0.11 6/17

CD ND ND ND ND 0/1

ABC ND 0.014 0.06 0.11 11/17

BCD ND ND ND ND 0/1

ABCD ND ND 0.05 0.05 1/5

NR ND ND ND ND 0/5

Eu-154 A ND ND ND 21 1/106

B ND ND ND ND 0/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND ND 0/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Fe-59 A ND ND ND ND 0/106

B ND ND ND 0.4 1/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND ND 0/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-76

Radionuclide Group: Fission and Activation Products

Sm-153 A ND ND ND ND 0/106

B ND ND ND ND 0/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND 27 1/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

Sr-89 A ND 0.15 2 10 18/26

B ND 1 20 70 25/35

C 2 2 2 2 1/1

D ND ND - 0 2 2 3/6

AB ND 0.3 20 40 11/16

AC 1 1 1 1 1/1

BC ND 1 7 7 4/7

ABC ND 3 30 30 5/6

Sr-90 A ND 0.1 9 9.4 19/26

B ND 0.1 0.4 2 23/35

C ND ND ND ND 0/1

D ND 0.15 0.4 0.4 4/6

AB ND 0.05 0.3 0.7 9/16

AC 1 1 1 1 1/1

BC ND 0.1 0.4 0.4 5/7

ABC ND ND - 0.1 0.3 0.3 3/6
Table A.7 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?” 

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-77

Zn-65 A ND ND ND ND 0/106

B ND ND ND ND 0/84

C ND ND ND ND 0/3

D ND ND ND ND 0/11

AB ND ND ND 0.06 1/48

AC ND ND ND ND 0/13

BC ND ND ND ND 0/17

CD ND ND ND ND 0/1

ABC ND ND ND ND 0/17

BCD ND ND ND ND 0/1

ABCD ND ND ND ND 0/5

NR ND ND ND ND 0/5

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-78

Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 A ND 2.15 9 13.7 19/20

B 1.3 4.65 16 16 4/4

D 1.06 1.28 2.8 2.8 3/3

AB 0.72 9.9 14.1 14.1 5/5

AC 2.8 2.8 2.8 2.8 1/1

ACD 0.64 0.64 0.64 0.64 1/1

ABCD 2.2 2.2 2.2 2.2 1/1

Pa-234m A ND 4 7 10 17/20

B ND 3 77 77 3/4

D 1.1 7 11 11 3/3

AB ND 6 11 11 4/5

AC 2 2 2 2 1/1

ACD 2 2 2 2 1/1

ABCD 2 2 2 2 1/1

Pb-210 A ND 2.7 8.5 12.3 12/20

B ND 4.45 8.9 8.9 3/4

D ND ND ND ND 0/3

AB ND ND 1.8 1.8 1/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

Pb-214 A 0.61 2.3 10 14.8 20/20

B 1.32 5.1 16.4 16.4 4/4

D 1.17 1.35 3 3 3/3

AB 0.74 11.1 15.1 15.1 5/5

AC 3.1 3.1 3.1 3.1 1/1

ACD 0.69 0.69 0.69 0.69 1/1

ABCD 2.4 2.4 2.4 2.4 1/1

Ra-226 A ND 2.9 17 18 19/20

B ND 4.05 15 15 3/4

D 2.2 2.5 6.6 6.6 3/3

AB 0 16.7 22 22 5/5

AC 9.5 9.5 9.5 9.5 1/1

ACD 1.1 1.1 1.1 1.1 1/1

ABCD 4 4 4 4 1/1
Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-79

Th-230 A ND 1 2.3 2.6 14/15

B 0.64 0.95 1 1 4/4

D 0.3 0.45 0.6 0.6 2/2

AB 0.55 0.7 1.3 1.3 5/5

AC 0.6 0.6 0.6 0.6 1/1

ACD 0.4 0.4 0.4 0.4 1/1

Radionuclide Group: Uranium-238 Decay Series

Th-234 A ND 3.6 7.2 7.3 19/20

B 1.1 11.4 80 80 4/4

D ND 4.9 10 10 2/3

AB ND 4.2 11 11 4/5

AC ND ND ND ND 0/1

ACD 1.7 1.7 1.7 1.7 1/1

ABCD 1.1 1.1 1.1 1.1 1/1

U-234 A 1.3 5.1 18 49 15/15

B 1.2 1.95 91 91 4/4

D 12 12.5 13 13 2/2

AB 6.9 7.3 19 19 5/5

AC 1.9 1.9 1.9 1.9 1/1

ACD 2.7 2.7 2.7 2.7 1/1

U-238 A 0.8 3.1 6.4 35 15/15

B 1.1 1.65 74 74 4/4

D 6.2 7.6 9 9 2/2

AB 3.3 5.1 15 15 5/5

AC 1.7 1.7 1.7 1.7 1/1

ACD 2.5 2.5 2.5 2.5 1/1

Radionuclide Group: C-14 and H-3

C-14* A ND ND 0 1 4/13

B ND ND 1 1 1/3

AB ND ND ND ND 0/2

H-3* A ND ND 3 8 6/13

B ND ND 4 4 1/3

AB ND ND ND ND 0/2
Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-80

Radionuclide Group: Thorium-232 Decay Series

Bi-212 A ND 1.25 2.4 3.5 14/20

B ND 3.45 15.7 15.7 3/4

D 0.6 0.9 1.5 1.5 3/3

AB ND ND 1.6 1.6 2/5

AC 2.1 2.1 2.1 2.1 1/1

ACD 0.3 0.3 0.3 0.3 1/1

ABCD 0.9 0.9 0.9 0.9 1/1

Pb-212 A 0.73 1.5 2.6 3.3 20/20

B 1.3 4.55 15 15 4/4

D 0.74 0.99 1.7 1.7 3/3

AB 1 1.5 1.6 1.6 5/5

AC 2.4 2.4 2.4 2.4 1/1

ACD 0.36 0.36 0.36 0.36 1/1

ABCD 1.14 1.14 1.14 1.14 1/1

Ra-224 A ND ND 2 2.4 7/20

B ND ND 4.9 4.9 1/4

D 0.4 0.8 1.8 1.8 3/3

AB ND ND 1.3 1.3 2/5

AC 0.4 0.4 0.4 0.4 1/1

ACD ND ND ND ND 0/1

ABCD 0.6 0.6 0.6 0.6 1/1

Ra-228 A 0.68 2.45 9.6 17 20/20

B 2.2 15.15 30 30 4/4

D 0.71 1.46 3.2 3.2 3/3

AB 1.8 7.8 9.9 9.9 5/5

AC 5.7 5.7 5.7 5.7 1/1

ACD 0.65 0.65 0.65 0.65 1/1

ABCD 2.4 2.4 2.4 2.4 1/1

Th-228 A ND 1.3 3.4 3.7 14/15

B 0.7 4.1 14 14 4/4

D 0.9 1.4 1.9 1.9 2/2

AB 0.68 1.7 2.4 2.4 5/5

AC 1.7 1.7 1.7 1.7 1/1

ACD 0.4 0.4 0.4 0.4 1/1
Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-81

Th-232 A ND 0.8 1 1.7 14/15

B 0.4 0.475 0.9 0.9 4/4

D 0.5 0.6 0.7 0.7 2/2

AB 0.39 0.5 0.8 0.8 5/5

AC 0.5 0.5 0.5 0.5 1/1

ACD 0.22 0.22 0.22 0.22 1/1

Tl-208 A ND 0.89 2.3 3.1 19/20

B 1.16 2 13.5 13.5 4/4

D 0.23 0.3 0.55 0.55 3/3

AB ND 0.47 1.05 1.05 3/5

AC 0.73 0.73 0.73 0.73 1/1

ACD 0.11 0.11 0.11 0.11 1/1

ABCD 0.34 0.34 0.34 0.34 1/1

Radionuclide Group: Medical Isotopes

I-125 A ND ND ND 0.4 1/20

B ND ND - 0.8 1 1 2/4

D ND ND ND ND 0/3

AB ND ND 0.3 0.3 1/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

I-131 A ND 0.22 4.3 20 14/20

B ND 0.815 46 46 3/4

D ND ND ND ND 0/3

AB ND 0.05 81 81 3/5

AC 1.14 1.14 1.14 1.14 1/1

ACD 7.4 7.4 7.4 7.4 1/1

ABCD 0.61 0.61 0.61 0.61 1/1

In-111 A ND ND ND ND 0/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1
Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-82

Tl-201 A ND 0.49 35 48 11/20

B 3.3 46 105 105 4/4

D ND ND ND ND 0/3

AB ND ND 73 73 1/5

AC 93 93 93 93 1/1

ACD 26 26 26 26 1/1

ABCD 11 11 11 11 1/1

Tl-202 A ND ND 0.14 1.1 3/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND 0.1 0.1 1/5

AC 1.53 1.53 1.53 1.53 1/1

ACD 0.77 0.77 0.77 0.77 1/1

ABCD 0.99 0.99 0.99 0.99 1/1

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 A 0.14 7.65 27 30 20/20

B 2.2 3.3 15 15 4/4

D ND 1.2 2.2 2.2 2/3

AB 0.5 3.6 5.3 5.3 5/5

AC 4.3 4.3 4.3 4.3 1/1

ACD 1.9 1.9 1.9 1.9 1/1

ABCD 12.5 12.5 12.5 12.5 1/1

K-40 A 7.4 15.9 22 22.4 20/20

B 8.4 14.75 19.8 19.8 4/4

D 9.7 12 12.7 12.7 3/3

AB 10.8 13 14.2 14.2 5/5

AC 9.4 9.4 9.4 9.4 1/1

ACD 15 15 15 15 1/1

ABCD 16 16 16 16 1/1

La-138 A ND ND ND ND 0/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1
Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-83

Radionuclide Group: Transuranics

Am-241 A ND ND ND 0.21 1/20

B ND ND 0.04 0.04 1/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

Pu-238 A ND 0.03 0.1 0.1 11/15

B ND 0 0.02 0.02 3/4

D ND ND - 0.01 0.01 0.01 1/2

AB 0 0.02 0.08 0.08 5/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

Pu-239 A ND 0.01 0.06 0.17 11/15

B ND 0.009 0.02 0.02 3/4

D 0.01 0.02 0.03 0.03 2/2

AB 0 0.01 0.05 0.05 5/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 A ND ND 0.5 0.8 2/20

B ND ND ND ND 0/4

D ND ND 0.2 0.2 1/3

AB ND ND 0.1 0.1 1/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

Rn-219 A ND ND 0.2 0.4 2/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC 0.2 0.2 0.2 0.2 1/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1
Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-84

Th-227 A ND ND 0.3 1.1 7/20

B ND ND 0.6 0.6 1/4

D 0.02 0.11 0.2 0.2 2/2

AB ND ND 0.2 0.2 2/5

AC 0.1 0.1 0.1 0.1 1/1

ACD 0.04 0.04 0.04 0.04 1/1

U-235 A ND 0.14 0.7 1.7 15/20

B 0.06 0.08 3.4 3.4 4/4

D 0.15 0.4 0.5 0.5 3/3

AB 0.14 0.4 0.7 0.7 5/5

AC 0.03 0.03 0.03 0.03 1/1

ACD 0.18 0.18 0.18 0.18 1/1

ABCD 0.11 0.11 0.11 0.11 1/1

Radionuclide Group: Fission and Activation Products

Ce-141 A ND ND ND ND 0/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

Co-57 A ND ND ND 0.17 1/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

Co-60 A ND ND 0.038 3.46 2/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1
Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-85

Cr-51 A ND ND ND 0.2 1/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND 35 35 2/5

AC ND ND ND ND 0/1

ACD 0.3 0.3 0.3 0.3 1/1

ABCD 0.8 0.8 0.8 0.8 1/1

Cs-134 A ND ND ND ND 0/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

Cs-137 A ND 0.085 0.27 0.37 19/20

B 0.03 0.05 0.08 0.08 4/4

D 0.03 0.05 0.11 0.11 3/3

AB 0.04 0.05 0.08 0.08 5/5

AC 0.04 0.04 0.04 0.04 1/1

ACD 0.02 0.02 0.02 0.02 1/1

ABCD 0.08 0.08 0.08 0.08 1/1

Radionuclide Group: Fission and Activation Products

Eu-154 A ND ND ND ND 0/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

Fe-59 A ND ND ND ND 0/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1
Table A.8 Concentrations of Radionuclides in Ash 

Summarized by Response to the POTW Questionnaire Question 

“What are the primary sources of drinking water for your community?”

A=Municipal/Surface, B=Municipal/Ground, C=Private Wells, D=Private/Surface

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-86

Sm-153 A ND ND ND ND 0/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

Sr-89 A ND 1 5 60 11/17

B ND ND - 1 2 2 2/4

D ND ND - 20 20 20 1/2

AB ND 0.4 300 300 4/5

AC 12 12 12 12 1/1

ACD 30 30 30 30 1/1

Sr-90 A ND 0.1 1 1 15/17

B ND 0.2 1 1 3/4

D ND ND - 0.7 0.7 0.7 1/2

AB ND 0.3 6 6 4/5

AC 0.1 0.1 0.1 0.1 1/1

ACD ND ND ND ND 0/1

Zn-65 A ND ND ND 0.06 1/20

B ND ND ND ND 0/4

D ND ND ND ND 0/3

AB ND ND ND ND 0/5

AC ND ND ND ND 0/1

ACD ND ND ND ND 0/1

ABCD ND ND ND ND 0/1

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-87

Table A.9 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“Does your wastewater collection system receive discharges of 

drinking water treatment residuals?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes ND 0.3 1.9 16 85/105

No ND 0.295 3 16 151/202

NR ND ND - 0.23 0.27 0.27 2/4

Pa-234m Yes ND ND 10 22 29/105

No ND ND 7 27 49/202

NR ND ND - 2 6 6 2/4

Pb-210 Yes ND ND 4.2 5.6 41/105

No ND ND 4 13 92/202

NR ND ND - 0.4 0.6 0.6 2/4

Pb-214 Yes ND 0.33 2 17 93/105

No ND 0.3 3.1 17 157/202

NR ND 0.2 0.31 0.31 3/4

Ra-226 Yes ND 2 10 47 100/105

No ND 2 15 30 185/202

NR 0.2 0.5 2.4 2.4 4/4

Th-230 Yes 0.14 0.39 1.6 1.7 30/30

No 0.09 0.325 0.8 1.7 62/62

Th-234 Yes ND 0.5 5 16 62/105

No ND 0.65 7 23 125/202

NR 0.1 1.25 6.8 6.8 4/4

U-234 Yes 0.39 1.85 17 20 30/30

No 0.18 2.1 17 44 62/62

U-238 Yes 0.18 1.4 12.5 16 30/30

No 0.19 1.4 12 26 62/62

Radionuclide Group: C-14 and H-3

C-14* Yes ND 0 1 2 26/49

No ND ND 1 3 35/107

NR ND ND - 0 0 0 1/2

H-3* Yes ND 0.4 3 8 35/49

No ND 0.2 5 7 74/107

NR 1 2 3 3 2/2

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND ND 1.4 13 36/105

No ND ND 1.1 6.8 63/202

NR ND ND - 0.4 0.5 0.5 2/4
Table A.9 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“Does your wastewater collection system receive discharges of 

drinking water treatment residuals?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-88

Pb-212 Yes ND 0.5 1.9 15 104/105

No ND 0.435 1.9 5.4 195/202

NR 0.09 0.23 0.49 0.49 4/4

Ra-224 Yes ND ND 0.9 12 17/105

No ND ND 1 5 30/202

NR ND ND ND ND 0/4

Ra-228 Yes ND 0.9 4 20 97/105

No ND 0.81 6.7 38 171/202

NR ND 0.275 0.53 0.53 3/4

Th-228 Yes 0.19 0.75 4.6 9 30/30

No 0.07 0.6 4.1 9 62/62

Th-232 Yes 0.08 0.23 1.1 1.6 30/30

No 0.02 0.195 0.52 0.7 62/62

Tl-208 Yes ND 0.09 1.4 4.1 70/105

No ND 0.04 0.9 4.8 108/202

NR ND ND - 0.1 0.15 0.15 2/4

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND 0.7 1/105

No ND ND ND 40 10/202

NR ND ND ND ND 0/4

I-131 Yes ND 2.9 42 840 90/105

No ND 1.45 60.5 280 154/202

NR ND ND - 0.56 0.67 0.67 2/4

In-111 Yes ND ND 0.044 3.6 7/105

No ND ND 0.03 3.5 11/202

NR ND ND 0.04 0.04 1/4

Tl-201 Yes ND 0.3 45 176 53/105

No ND ND 48 241 97/202

NR ND ND 3.1 3.1 1/4

Tl-202 Yes ND ND 0.4 0.93 24/105

No ND ND 0.56 1.16 48/202

NR ND ND 0.01 0.01 1/4

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes ND 1.2 9.9 22 90/105

No ND 1.2 7.2 17 169/202

NR 0.1 0.48 14.9 14.9 4/4

K-40 Yes ND 4 12 22 104/105

No ND 3.9 13 26 200/202

NR 2.7 4.1 5.7 5.7 4/4
Table A.9 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“Does your wastewater collection system receive discharges of 

drinking water treatment residuals?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-89

La-138 Yes ND ND ND ND 0/105

No ND ND ND 0.07 1/202

NR ND ND ND ND 0/4

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND 0.1 4/105

No ND ND ND 2.5 6/202

NR ND ND ND ND 0/4

Pu-238 Yes ND 0.01 0.1 0.14 26/30

No ND 0.01 0.05 0.19 49/62

Pu-239 Yes ND 0.0045 0.05 0.07 24/30

No ND 0.002 0.04 0.12 44/62

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND ND 0.09 2/105

No ND ND ND ND 0/202

NR ND ND ND ND 0/4

Rn-219 Yes ND ND ND ND 0/105

No ND ND ND ND 0/202

NR ND ND ND ND 0/4

Th-227 Yes ND ND 0.1 0.5 18/67

No ND ND 0.09 0.5 31/138

NR ND ND ND ND 0/2

U-235 Yes ND ND 0.42 1.1 37/105

No ND ND 0.5 3.1 73/202

NR ND ND - 0.15 0.31 0.31 2/4

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND 0.016 1/105

No ND ND ND ND 0/202

NR ND ND ND ND 0/4

Co-57 Yes ND ND ND 0.26 1/105

No ND ND ND 0.06 5/202

NR ND ND ND ND 0/4

Co-60 Yes ND ND ND 0.08 5/105

No ND ND ND 5.1 8/202

NR ND ND ND ND 0/4

Cr-51 Yes ND ND ND 3.5 3/105

No ND ND ND 0.8 3/202

NR ND ND ND ND 0/4
Table A.9 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question 

“Does your wastewater collection system receive discharges of 

drinking water treatment residuals?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses

A-90

Cs-134 Yes ND ND ND ND 0/105

No ND ND ND 0.04 1/202

NR ND ND ND ND 0/4

Cs-137 Yes ND ND 0.11 0.4 49/105

No ND ND 0.11 3.6 80/202

NR 0.01 0.02 0.04 0.04 4/4

Eu-154 Yes ND ND ND ND 0/105

No ND ND ND 21 1/202

NR ND ND ND ND 0/4

Fe-59 Yes ND ND ND ND 0/105

No ND ND ND 0.4 1/202

NR ND ND ND ND 0/4

Sm-153 Yes ND ND ND ND 0/105

No ND ND ND 27 1/202

NR ND ND ND ND 0/4

Sr-89 Yes ND 0.6 20 70 25/33

No ND 0.3 20 30 43/65

Sr-90 Yes ND 0.1 0.4 2 20/33

No ND 0.1 1 9.4 44/65

Zn-65 Yes ND ND ND ND 0/105

No ND ND ND 0.06 1/202

NR ND ND ND ND 0/4

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-91

Table A.10 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Does your wastewater collection system receive discharges of 

drinking water treatment residuals?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes 0.62 2.15 13.7 14.1 16/16

No ND 3 14 16 18/19

Pa-234m Yes ND 5 11 77 14/16

No ND 3 9 11 16/19

Pb-210 Yes ND 3.75 8.9 12.3 10/16

No ND ND 4.4 5.3 6/19

Pb-214 Yes 0.61 2.3 14.8 15.1 16/16

No 0.69 3.2 14.6 16.4 19/19

Ra-226 Yes ND 2.4 17 22 15/16

No ND 3.4 18 18 18/19

Th-230 Yes 0.6 1.1 2.6 2.6 10/10

No ND 0.64 1.4 2.2 17/18

Th-234 Yes 1 3.7 10 80 16/16

No ND 2.7 11 21 15/19

U-234 Yes 1.3 6.05 91 91 10/10

No 1.2 5.55 13 19 18/18

U-238 Yes 0.8 3.65 74 74 10/10

No 1.1 3.3 6.4 15 18/18

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND 1 1 3/10

No ND ND 0 0 2/8

H-3* Yes ND 0.7 8 8 6/10

No ND ND 0.5 0.5 1/8

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND 1.4 2.4 3.5 13/16

No ND 0.8 5.5 15.7 12/19

Pb-212 Yes 0.85 1.5 2.6 3.3 16/16

No 0.36 1.42 6.6 15 19/19

Ra-224 Yes ND ND 1.8 2.4 6/16

No ND ND 2 4.9 9/19

Ra-228 Yes 0.68 2.45 9.6 9.9 16/16

No 0.65 2.9 24 30 19/19

Th-228 Yes 0.7 2.05 3.4 3.4 10/10

No ND 1.45 6.7 14 17/18

Th-232 Yes 0.49 0.8 1.7 1.7 10/10

No ND 0.49 0.9 1 17/18

Tl-208 Yes 0.34 1.095 2.3 3.1 16/16

No ND 0.47 2 13.5 16/19
Table A.10 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Does your wastewater collection system receive discharges of 

drinking water treatment residuals?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-92

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND 1 1/16

No ND ND 0.4 0.8 3/19

I-131 Yes ND 0.09 1.17 20 10/16

No ND 0.37 46 81 13/19

In-111 Yes ND ND ND ND 0/16

No ND ND ND ND 0/19

Tl-201 Yes ND ND - 0.36 48 61 8/16

No ND 1.3 93 105 11/19

Tl-202 Yes ND ND 0.99 1.1 3/16

No ND ND 0.77 1.53 4/19

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes 0.14 7.85 27 30 16/16

No ND 4.3 13 15 18/19

K-40 Yes 7.4 15.8 20.9 22.4 16/16

No 7.9 14 19.8 22 19/19

La-138 Yes ND ND ND ND 0/16

No ND ND ND ND 0/19

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND ND 0/16

No ND ND 0.04 0.21 2/19

Pu-238 Yes ND 0.015 0.1 0.1 7/10

No ND 0.015 0.09 0.1 13/18

Pu-239 Yes ND 0.005 0.17 0.17 8/10

No ND 0.01 0.04 0.05 13/18

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND 0.2 0.8 2/16

No ND ND 0.1 0.5 2/19

Rn-219 Yes ND ND ND 0.4 1/16

No ND ND 0.2 0.2 2/19

Th-227 Yes ND ND 0.2 1.1 5/15

No ND ND - 0.02 0.3 0.6 9/18

U-235 Yes ND 0.11 1.7 3.4 11/16

No 0.03 0.18 0.6 0.7 19/19

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND ND 0/16

No ND ND ND ND 0/19
Table A.10 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Does your wastewater collection system receive discharges of 

drinking water treatment residuals?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-93

Co-57 Yes ND ND ND 0.17 1/16

No ND ND ND ND 0/19

Co-60 Yes ND ND ND 3.46 1/16

No ND ND ND 0.038 1/19

Cr-51 Yes ND ND 0.3 0.8 2/16

No ND ND 0.3 35 3/19

Cs-134 Yes ND ND ND ND 0/16

No ND ND ND ND 0/19

Cs-137 Yes ND 0.095 0.27 0.37 15/16

No 0 0.05 0.08 0.09 19/19

Eu-154 Yes ND ND ND ND 0/16

No ND ND ND ND 0/19

Fe-59 Yes ND ND ND ND 0/16

No ND ND ND ND 0/19

Sm-153 Yes ND ND ND ND 0/16

No ND ND ND ND 0/19

Sr-89 Yes ND 0.65 60 300 7/12

No ND 1 20 30 13/18

Sr-90 Yes ND 0.1 1 6 10/12

No ND 0.3 1 1 14/18

Zn-65 Yes ND ND ND ND 0/16

No ND ND ND 0.06 1/19

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-94

Table A.11 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Does your waste water collection system include 

combined sanitary and storm water sewers?”

(All concentration are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes ND 0.31 1.9 16 73/95

No ND 0.275 2.9 16 165/216

Pa-234m Yes ND ND 4 22 26/95

No ND ND 9 27 54/216

Pb-210 Yes ND ND 5.6 11 43/95

No ND ND 3 13 92/216

Pb-214 Yes ND 0.37 2 17 80/95

No ND 0.3 3 17 173/216

Ra-226 Yes ND 2.2 10 47 88/95

No ND 2 14 30 201/216

Th-230 Yes 0.14 0.415 1.7 1.7 22/22

No 0.09 0.32 0.8 1.6 70/70

Th-234 Yes ND 0.6 3 16 57/95

No ND 0.75 7.8 23 134/216

U-234 Yes 0.18 1.45 7.3 20 22/22

No 0.39 2.1 17 44 70/70

U-238 Yes 0.19 1.1 6.6 16 22/22

No 0.18 1.4 12 26 70/70

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND 1 3 20/49

No ND ND 1 2 42/109

H-3* Yes ND 0.4 6 8 39/49

No ND 0.3 4 7 72/109

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND ND 1.3 13 34/95

No ND ND 1.1 6.8 67/216

Pb-212 Yes ND 0.5 1.9 15 92/95

No ND 0.4 1.9 5.4 211/216

Ra-224 Yes ND ND 0.7 12 15/95

No ND ND 1 4 32/216

Ra-228 Yes ND 0.8 4 20 83/95

No ND 0.83 7.9 38 188/216

Th-228 Yes 0.19 0.7 6.7 9 22/22

No 0.07 0.6 4.1 9 70/70

Th-232 Yes 0.08 0.255 0.9 1.6 22/22

No 0.02 0.185 0.5 1.1 70/70

Tl-208 Yes ND 0.08 1.8 4.1 57/95

No ND 0.06 0.9 4.8 123/216
Table A.11 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Does your waste water collection system include 

combined sanitary and storm water sewers?”

(All concentration are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-95

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND 1.5 2/95

No ND ND ND 40 9/216

I-131 Yes ND 2.6 82 280 78/95

No ND 1.55 44 840 168/216

In-111 Yes ND ND 0.033 1.19 7/95

No ND ND 0.04 3.6 12/216

Tl-201 Yes ND 1.2 36 241 59/95

No ND ND 48 207 92/216

Tl-202 Yes ND ND 0.4 0.82 25/95

No ND ND 0.54 1.16 48/216

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes ND 3.5 13.5 22 88/95

No ND 0.9 3 6 175/216

K-40 Yes 1.6 5 13 26 95/95

No ND 3.5 12 25 213/216

La-138 Yes ND ND ND ND 0/95

No ND ND ND 0.07 1/216

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND 0.1 1/95

No ND ND ND 2.5 9/216

Pu-238 Yes ND 0.01 0.07 0.14 17/22

No ND 0.01 0.07 0.19 58/70

Pu-239 Yes ND 0.004 0.04 0.07 18/22

No ND 0.002 0.05 0.12 50/70

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND ND 0.06 1/95

No ND ND ND 0.09 1/216

Rn-219 Yes ND ND ND ND 0/95

No ND ND ND ND 0/216

Th-227 Yes ND ND 0.07 0.5 11/60

No ND ND 0.1 0.5 38/147

U-235 Yes ND ND 0.29 0.7 28/95

No ND ND 0.5 3.1 84/216

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND 0.016 1/95

No ND ND ND ND 0/216

Co-57 Yes ND ND ND 0.04 1/95

No ND ND ND 0.26 5/216
Table A.11 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Does your waste water collection system include 

combined sanitary and storm water sewers?”

(All concentration are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-96

Co-60 Yes ND ND ND 0.3 4/95

No ND ND ND 5.1 9/216

Cr-51 Yes ND ND ND 3.5 3/95

No ND ND ND 2.8 3/216

Cs-134 Yes ND ND ND ND 0/95

No ND ND ND 0.04 1/216

Cs-137 Yes ND 0.029 0.11 0.3 58/95

No ND ND 0.11 3.6 75/216

Eu-154 Yes ND ND ND ND 0/95

No ND ND ND 21 1/216

Fe-59 Yes ND ND ND 0.4 1/95

No ND ND ND ND 0/216

Sm-153 Yes ND ND ND ND 0/95

No ND ND ND 27 1/216

Sr-89 Yes ND 0.3 5 70 18/28

No ND 0.8 20 40 50/70

Sr-90 Yes ND 0.1 0.5 0.6 17/28

No ND 0.1 1 9.4 47/70

Zn-65 Yes ND ND ND ND 0/95

No ND ND ND 0.06 1/216

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-97

 Table A.12 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Does your waste water collection system include 

combined sanitary and storm water sewers?”

(All concentration are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses 

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes 1.06 2.2 3.8 13.7 15/15

No ND 2.9 14.1 16 19/20

Pa-234m Yes ND 5 10 11 14/15

No ND 3 11 77 16/20

Pb-210 Yes ND ND 8.5 12.3 6/15

No ND ND - 1.8 5.3 8.9 10/20

Pb-214 Yes 1.17 2.4 4.1 14.8 15/15

No 0.61 3.15 15.1 16.4 20/20

Ra-226 Yes ND 2.5 9.4 17 14/15

No ND 3.7 18 22 19/20

Th-230 Yes 0.6 1.3 2.6 2.6 9/9

No ND 0.64 1.5 2.3 18/19

Th-234 Yes ND 3.7 7.5 10 14/15

No ND 2.15 21 80 17/20

U-234 Yes 2.1 5.3 49 49 9/9

No 1.2 6 19 91 19/19

U-238 Yes 1.9 4.3 35 35 9/9

No 0.8 3.1 15 74 19/19

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND 1 1 2/7

No ND ND 0 1 3/11

H-3* Yes ND 0.4 8 8 4/7

No ND ND 2 4 3/11

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND 1.3 1.8 2.4 12/15

No ND 1.2 5.5 15.7 13/20

Pb-212 Yes 0.74 1.5 2.1 2.6 15/15

No 0.36 1.55 6.6 15 20/20

Ra-224 Yes ND 0.4 1.8 2.4 8/15

No ND ND 2 4.9 7/20

Ra-228 Yes 0.71 2.3 3.7 4.7 15/15

No 0.65 4.45 24 30 20/20

Th-228 Yes 0.9 1.7 3.4 3.4 9/9

No ND 1.5 6.7 14 18/19

Th-232 Yes 0.7 0.8 1 1 9/9

No ND 0.49 0.9 1.7 18/19

Tl-208 Yes ND 0.55 1.6 2.3 14/15

No ND 0.74 3.1 13.5 18/20
 Table A.12 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Does your waste water collection system include 

combined sanitary and storm water sewers?”

(All concentration are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses 

A-98

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND ND 0/15

No ND ND 0.8 1 4/20

I-131 Yes ND ND 3.8 4.3 7/15

No ND 0.525 46 81 16/20

In-111 Yes ND ND ND ND 0/15

No ND ND ND ND 0/20

Tl-201 Yes ND ND 11 35 5/15

No ND 5.05 93 105 14/20

Tl-202 Yes ND ND 0.07 0.99 2/15

No ND ND 1.1 1.53 5/20

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes 0.14 8.2 27 30 15/15

No ND 4.3 15 15.4 19/20

K-40 Yes 9.7 16 20.9 22.4 15/15

No 7.4 13.6 19.8 22 20/20

La-138 Yes ND ND ND ND 0/15

No ND ND ND ND 0/20

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND ND 0/15

No ND ND 0.04 0.21 2/20

Pu-238 Yes ND 0.02 0.1 0.1 6/9

No ND 0.01 0.09 0.1 14/19

Pu-239 Yes ND 0.01 0.06 0.06 7/9

No ND 0.009 0.05 0.17 14/19

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND 0.2 0.8 3/15

No ND ND ND 0.5 1/20

Rn-219 Yes ND ND ND 0.4 1/15

No ND ND 0.2 0.2 2/20

Th-227 Yes ND ND 0.2 1.1 6/13

No ND ND 0.3 0.6 8/20

U-235 Yes ND 0.15 0.6 1.7 11/15

No ND 0.145 0.7 3.4 19/20
 Table A.12 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Does your waste water collection system include 

combined sanitary and storm water sewers?”

(All concentration are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/ 

No. Analyses 

A-99

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND ND 0/15

No ND ND ND ND 0/20

Co-57 Yes ND ND ND 0.17 1/15

No ND ND ND ND 0/20

Co-60 Yes ND ND ND 0.038 1/15

No ND ND ND 3.46 1/20

Cr-51 Yes ND ND ND 0.8 1/15

No ND ND 0.3 35 4/20

Cs-134 Yes ND ND ND ND 0/15

No ND ND ND ND 0/20

Cs-137 Yes 0.03 0.09 0.23 0.27 15/15

No ND 0.05 0.1 0.37 19/20

Eu-154 Yes ND ND ND ND 0/15

No ND ND ND ND 0/20

Fe-59 Yes ND ND ND ND 0/15

No ND ND ND ND 0/20

Sm-153 Yes ND ND ND ND 0/15

No ND ND ND ND 0/20

Sr-89 Yes ND ND - 0.6 60 60 5/10

No ND 1 30 300 15/20

Sr-90 Yes ND 0.5 1 1 8/10

No ND 0.1 1 6 16/20

Zn-65 Yes ND ND ND 0.06 1/15

No ND ND ND ND 0/20

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-100

Table A.13 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Do you receive sludge from other wastewater treatment facilities for 

processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes ND 0.25 1.5 6 59/75

No ND 0.3 2.4 16 179/236

Pa-234m Yes ND ND 7 17 15/75

No ND ND 7 27 65/236

Pb-210 Yes ND ND 3 4.3 29/75

No ND ND 4.7 13 106/236

Pb-214 Yes ND 0.29 1.5 5.8 61/75

No ND 0.33 3 17 192/236

Ra-226 Yes ND 2 10.1 26 70/75

No ND 2 13 47 219/236

Th-230 Yes 0.09 0.22 0.8 1.6 24/24

No 0.09 0.4 1.2 1.7 68/68

Th-234 Yes ND 0.5 5 12 43/75

No ND 0.75 6.7 23 148/236

U-234 Yes 0.18 2.1 15.4 17 24/24

No 0.39 1.9 20 44 68/68

U-238 Yes 0.19 1.25 12 12.5 24/24

No 0.18 1.4 12 26 68/68

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND 1 2 15/34

No ND ND 1 3 48/124

H-3* Yes ND 0.3 2 6 26/34

No ND 0.35 5 8 85/124

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND ND 0.8 3.7 23/75

No ND ND 1.4 13 78/236

Pb-212 Yes ND 0.38 1.2 4.2 74/75

No ND 0.475 2 15 229/236

Ra-224 Yes ND ND 0.6 5 11/75

No ND ND 1 12 36/236
Table A.13 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Do you receive sludge from other wastewater treatment facilities for 

processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-101

Ra-228 Yes ND 0.7 4 38 68/75

No ND 0.9 6.7 24 203/236

Th-228 Yes 0.16 0.39 3.1 9 24/24

No 0.07 0.685 4.6 9 68/68

Th-232 Yes 0.06 0.17 0.5 1.1 24/24

No 0.02 0.205 0.65 1.6 68/68

Tl-208 Yes ND 0.07 0.8 1.9 47/75

No ND 0.07 0.99 4.8 133/236

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND 0.9 2/75

No ND ND ND 40 9/236

I-131 Yes ND 3.8 60.5 220 65/75

No ND 1.35 44 840 181/236

In-111 Yes ND ND 0.033 1.19 6/75

No ND ND 0.04 3.6 13/236

Tl-201 Yes ND 0.6 43 80 43/75

No ND ND 48 241 108/236

Tl-202 Yes ND ND 0.7 0.93 24/75

No ND ND 0.45 1.16 49/236

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes ND 1.1 9.1 13.5 65/75

No ND 1.2 8.6 22 198/236

K-40 Yes 0.3 3.8 10.5 22 75/75

No ND 4 13 26 233/236

La-138 Yes ND ND ND ND 0/75

No ND ND ND 0.07 1/236

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND 2.5 4/75

No ND ND ND 0.3 6/236

Pu-238 Yes ND 0.01 0.04 0.05 19/24

No ND 0.01 0.1 0.19 56/68

Pu-239 Yes ND 0.0025 0.04 0.1 20/24

No ND 0.004 0.05 0.12 48/68
Table A.13 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Do you receive sludge from other wastewater treatment facilities for 

processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-102

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND ND ND 0/75

No ND ND ND 0.09 2/236

Rn-219 Yes ND ND ND ND 0/75

No ND ND ND ND 0/236

Th-227 Yes ND ND 0.1 0.5 14/48

No ND ND 0.09 0.5 35/159

U-235 Yes ND ND 0.58 1.3 27/75

No ND ND 0.42 3.1 85/236

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND ND 0/75

No ND ND ND 0.016 1/236

Co-57 Yes ND ND ND 0.26 1/75

No ND ND ND 0.06 5/236

Co-60 Yes ND ND 0.03 1.16 5/75

No ND ND ND 5.1 8/236

Cr-51 Yes ND ND ND 0.3 1/75

No ND ND ND 3.5 5/236

Cs-134 Yes ND ND ND 0.04 1/75

No ND ND ND ND 0/236

Cs-137 Yes ND ND 0.11 3.6 34/75

No ND ND 0.11 1.5 99/236

Eu-154 Yes ND ND ND ND 0/75

No ND ND ND 21 1/236

Fe-59 Yes ND ND ND ND 0/75

No ND ND ND 0.4 1/236

Sm-153 Yes ND ND ND ND 0/75

No ND ND ND 27 1/236

Sr-89 Yes ND 0.2 10 40 15/23

No ND 0.4 20 70 53/75

Sr-90 Yes ND 0.1 0.3 0.4 17/23

No ND 0.1 1 9.4 47/75

Zn-65 Yes ND ND ND 0.06 1/75

No ND ND ND ND 0/236

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-103

Table A.14 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Do you receive sludge from other wastewater treatment facilities for 

processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes 0.62 2.7 14 14.1 21/21

No ND 2.25 13.7 16 13/14

Pa-234m Yes ND 4 9 11 18/21

No ND 3 11 77 12/14

Pb-210 Yes ND ND 6.4 8.5 7/21

No ND 2.2 8.9 12.3 9/14

Pb-214 Yes 0.61 3 14.6 15.1 21/21

No 0.69 2.55 14.8 16.4 14/14

Ra-226 Yes ND 2.9 18 22 19/21

No 0 3.2 17 18 14/14

Th-230 Yes 0.3 0.95 2.2 2.6 14/14

No ND 0.64 1.5 2.3 13/14

Th-234 Yes ND 3.8 10 21 19/21

No ND 2.15 11 80 12/14

U-234 Yes 1.5 6.35 12 13 14/14

No 1.2 3.9 49 91 14/14

U-238 Yes 1.4 4.05 6.4 9 14/14

No 0.8 2.65 35 74 14/14

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND 1 1 3/9

No ND ND 1 1 2/9

H-3* Yes ND ND 8 8 3/9

No ND ND 4 4 4/9

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND 0.9 1.8 5.5 14/21

No ND 1.5 3.5 15.7 11/14

Pb-212 Yes 0.74 1.42 2.5 6.6 21/21

No 0.36 1.85 3.3 15 14/14

Ra-224 Yes ND 0.4 1.8 4.9 11/21

No ND ND 2 2.4 4/14

Ra-228 Yes 0.68 2.4 9.9 24 21/21

No 0.65 3.35 17 30 14/14

Th-228 Yes 0.9 1.7 3.4 6.7 14/14

No ND 1.3 3.7 14 13/14

Th-232 Yes 0.4 0.7 0.9 1 14/14

No ND 0.475 0.9 1.7 13/14

Tl-208 Yes ND 0.47 2 2 18/21

No 0.11 1.105 3.1 13.5 14/14
Table A.14 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Do you receive sludge from other wastewater treatment facilities for 

processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-104

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND 0.3 1/21

No ND ND 0.8 1 3/14

I-131 Yes ND 0.13 4.3 46 12/21

No ND 0.305 20 81 11/14

In-111 Yes ND ND ND ND 0/21

No ND ND ND ND 0/14

Tl-201 Yes ND ND 48 105 8/21

No ND 5.05 73 93 11/14

Tl-202 Yes ND ND 0.1 0.99 3/21

No ND ND 1.1 1.53 4/14

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes ND 4.3 27 30 20/21

No 0.14 4.3 8.1 8.3 14/14

K-40 Yes 8.4 15 22 22.4 21/21

No 7.4 13.6 17.9 19.8 14/14

La-138 Yes ND ND ND ND 0/21

No ND ND ND ND 0/14

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND ND 0/21

No ND ND 0.04 0.21 2/14

Pu-238 Yes ND 0.02 0.08 0.1 12/14

No ND 0 0.09 0.1 8/14

Pu-239 Yes ND 0.015 0.04 0.06 12/14

No ND 0 0.05 0.17 9/14 

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND 0.1 0.2 2/21

No ND ND 0.5 0.8 2/14

Rn-219 Yes ND ND ND ND 0/21

No ND ND 0.2 0.4 3/14

Th-227 Yes ND ND 0.2 0.6 9/19

No ND ND 0.3 1.1 5/14

U-235 Yes ND 0.15 0.5 0.6 16/21

No 0.03 0.145 1.7 3.4 14/14

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND ND 0/21

No ND ND ND ND 0/14

Co-57 Yes ND ND ND 0.17 1/21

No ND ND ND ND 0/14
Table A.14 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Do you receive sludge from other wastewater treatment facilities for 

processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-105

Co-60 Yes ND ND ND 0.038 1/21

No ND ND ND 3.46 1/14

Cr-51 Yes ND ND 0.3 0.8 3/21

No ND ND 0.3 35 2/14

Cs-134 Yes ND ND ND ND 0/21

No ND ND ND ND 0/14

Cs-137 Yes 0.03 0.08 0.23 0.27 21/21

No ND 0.06 0.18 0.37 13/14

Eu-154 Yes ND ND ND ND 0/21

No ND ND ND ND 0/14

Fe-59 Yes ND ND ND ND 0/21

No ND ND ND ND 0/14

Sm-153 Yes ND ND ND ND 0/21

No ND ND ND ND 0/14

Sr-89 Yes ND 0.3 20 300 9/16

No ND 1.65 30 60 11/14

Sr-90 Yes ND 0.5 1 6 14/16

No ND 0 1 1 10/14

Zn-65 Yes ND ND ND 0.06 1/21

No ND ND ND ND 0/14

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-106

Table A.15 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question: 

Do you receive septage for processing at your facility?

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g= 37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes ND 0.27 2 16 137/177

No ND 0.305 3 16 92/124

NR ND 0.335 1.37 1.37 9/10

Pa-234m Yes ND ND 6 22 46/177

No ND ND 7 27 28/124

NR ND 2 11 11 6/10

Pb-210 Yes ND ND 4 12 84/177

No ND ND 4.2 13 50/124

NR ND ND 1 1 1/10

Pb-214 Yes ND 0.3 2.4 17 146/177

No ND 0.35 3.1 17 98/124

NR ND 0.32 1.42 1.42 9/10

Ra-226 Yes ND 2 10.4 47 166/177

No ND 2.1 17 30 113/124

NR 1.8 2.85 10.1 10.1 10/10

Th-230 Yes 0.09 0.31 0.8 1.6 48/48

No 0.09 0.36 1.2 1.7 35/35

NR 0.19 0.54 1 1 9/9

Th-234 Yes ND 0.5 5.7 19 107/177

No ND 0.75 5 23 76/124

NR ND 1.45 12 12 8/10

U-234 Yes 0.18 2.1 17 20 48/48

No 0.4 1.6 25 44 35/35

NR 0.8 1.6 15.4 15.4 9/9

U-238 Yes 0.18 1.4 9 16 48/48

No 0.37 1.4 12 26 35/35

NR 0.7 1.4 12.5 12.5 9/9

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND 1 3 42/94

No ND ND 1 2 16/59

NR ND 0.6 1 1 5/5

H-3* Yes ND 0.3 5 7 66/94

No ND 0.5 4 8 41/59

NR ND 1 1.7 1.7 4/5
Table A.15 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question: 

Do you receive septage for processing at your facility?

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g= 37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-107

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND ND 1 13 52/177

No ND ND 2 6.8 44/124

NR ND ND - 0.5 0.8 0.8 5/10

Pb-212 Yes ND 0.48 1.9 15 174/177

No ND 0.4 1.9 5.4 119/124

NR 0.15 0.615 1.55 1.55 10/10

Ra-224 Yes ND ND 1 12 28/177

No ND ND 0.7 3 16/124

NR ND ND 0.7 0.7 3/10

Ra-228 Yes ND 0.8 5.1 38 155/177

No ND 0.9 7.8 24 106/124

NR 0.6 1 1.9 1.9 10/10

Th-228 Yes 0.07 0.605 3.1 9 48/48

No 0.2 0.7 4.6 6.8 35/35

NR 0.2 0.49 1.4 1.4 9/9

Th-232 Yes 0.02 0.23 0.65 1.1 48/48

No 0.06 0.16 0.52 1.6 35/35

NR 0.1 0.4 0.9 0.9 9/9

Tl-208 Yes ND 0.06 0.96 4.1 100/177

No ND 0.07 1.1 4.8 75/124

NR ND ND - 0.11 0.26 0.26 5/10

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND 5.9 9/177

No ND ND ND 40 2/124

NR ND ND ND ND 0/10

I-131 Yes ND 2.6 73 280 146/177

No ND 1.29 42 840 93/124

NR ND 0.425 39 39 7/10

In-111 Yes ND ND 0.03 1.9 10/177

No ND ND 0.09 3.6 9/124

NR ND ND ND ND 0/10

Tl-201 Yes ND 0.45 43 176 93/177

No ND ND 56 241 55/124

NR ND ND 24 24 3/10

Tl-202 Yes ND ND 0.32 0.93 41/177
Table A.15 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question: 

Do you receive septage for processing at your facility?

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g= 37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-108

No ND ND 0.56 1.16 32/124

NR ND ND ND ND 0/10

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes ND 1.2 8.7 15.3 155/177

No ND 1.1 8.6 17 100/124

NR ND 1.15 22 22 8/10

K-40 Yes ND 4 13 26 176/177

No ND 3.9 10 16 122/124

NR 2.5 4.05 7.3 7.3 10/10

La-138 Yes ND ND ND ND 0/177

No ND ND ND 0.07 1/124

NR ND ND ND ND 0/10

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND 2.5 8/177

No ND ND ND 0.14 2/124

NR ND ND ND ND 0/10

Pu-238 Yes ND 0.01 0.07 0.19 39/48

No ND 0.01 0.03 0.1 28/35

NR ND 0.01 0.14 0.14 8/9

Pu-239 Yes ND 0.002 0.04 0.11 37/48

No ND 0.004 0.04 0.12 22/35

NR 0 0.01 0.07 0.07 9/9

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND ND 0.09 2/177

No ND ND ND ND 0/124

NR ND ND ND ND 0/10

Rn-219 Yes ND ND ND ND 0/177

No ND ND ND ND 0/124

NR ND ND ND ND 0/10

Th-227 Yes ND ND 0.09 0.5 22/116

No ND ND 0.1 0.2 22/81

NR ND ND - 0.01 0.1 0.1 5/10

U-235 Yes ND ND 0.41 1.3 60/177

No ND ND 0.5 3.1 43/124

NR ND 0.16 0.6 0.6 9/10
Table A.15 Concentrations of Radionuclides in Sludge 

Summarized by Response to the POTW Questionnaire Question: 

Do you receive septage for processing at your facility?

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g= 37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-109

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND ND 0/177

No ND ND ND 0.016 1/124

NR ND ND ND ND 0/10

Co-57 Yes ND ND ND 0.26 2/177

No ND ND ND 0.06 4/124

NR ND ND ND ND 0/10

Co-60 Yes ND ND ND 1.16 8/177

No ND ND ND 5.1 5/124

NR ND ND ND ND 0/10

Cr-51 Yes ND ND ND 3.5 3/177

No ND ND ND 2.8 3/124

NR ND ND ND ND 0/10

Cs-134 Yes ND ND ND 0.04 1/177

No ND ND ND ND 0/124

NR ND ND ND ND 0/10

Cs-137 Yes ND ND 0.1 3.6 76/177

No ND ND 0.12 1.5 51/124

NR ND 0.02 0.19 0.19 6/10

Eu-154 Yes ND ND ND ND 0/177

No ND ND ND 21 1/124

NR ND ND ND ND 0/10

Fe-59 Yes ND ND ND ND 0/177

No ND ND ND 0.4 1/124

NR ND ND ND ND 0/10

Sm-153 Yes ND ND ND 27 1/177

No ND ND ND ND 0/124

NR ND ND ND ND 0/10

Sr-89 Yes ND 0.4 6 40 37/51

No ND 0.15 30 70 24/38

NR ND 0.3 10 10 7/9

Sr-90 Yes ND 0.04 1 9 30/51

No ND 0.1 0.6 9.4 28/38

NR ND 0.1 0.4 0.4 6/9

Zn-65 Yes ND ND ND 0.06 1/177

No ND ND ND ND 0/124

NR ND ND ND ND 0/10

** Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-110
A-110

Table A.16 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Do you receive septage for processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes 0.62 2.4 13.7 14.1 25/25

No ND 1.9 16 16 5/6

NR 2.1 6.5 14 14 4/4

Pa-234m Yes ND 4 11 11 22/25

No ND 3 77 77 5/6

NR ND 3 6 6 3/4

Pb-210 Yes ND ND 8.5 12.3 10/25

No 1.9 3.5 8.9 8.9 6/6

NR ND ND ND ND 0/4

Pb-214 Yes 0.61 2.9 14.8 15.1 25/25

No 0.92 2.05 16.4 16.4 6/6

NR 2.2 7.25 14.6 14.6 4/4

Ra-226 Yes ND 2.5 18 22 23/25

No 1 2.95 15 15 6/6

NR 2.9 13.05 18 18 4/4

Th-230 Yes 0.3 0.85 1.5 2.6 18/18

No ND 0.605 2.3 2.3 5/6

NR 0.55 0.85 2.2 2.2 4/4

Th-234 Yes ND 3.6 11 21 22/25

No 1.1 2.15 80 80 6/6

NR ND 3.95 5.1 5.1 3/4

U-234 Yes 1.3 4.1 19 49 18/18

No 1.2 5.55 91 91 6/6

NR 5 6.55 7.6 7.6 4/4

U-238 Yes 0.8 3.55 15 35 18/18

No 1.1 2.95 74 74 6/6

NR 3.3 3.55 4.7 4.7 4/4

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND 1 1 2/10

No ND ND 1 1 2/6

NR ND ND - 0 0 0 1/2

H-3* Yes ND ND 8 8 4/10

No ND ND - 0.5 4 4 3/6

NR ND ND ND ND 0/2

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND 1.3 3.5 5.5 20/25

No ND 1.6 15.7 15.7 4/6

NR ND ND 0.8 0.8 1/4
Table A.16 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Do you receive septage for processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-111

Pb-212 Yes 0.36 1.5 3.3 6.6 25/25

No 0.73 1.7 15 15 6/6

NR 0.91 1.21 1.6 1.6 4/4

Ra-224 Yes ND 0.4 2.4 4.9 14/25

No ND ND ND ND 0/6

NR ND ND 0.5 0.5 1/4

Ra-228 Yes 0.65 2.4 17 24 25/25

No 1.8 2.95 30 30 6/6

NR 1.6 4.8 8.2 8.2 4/4

Th-228 Yes 0.4 1.7 3.7 6.7 18/18

No ND 0.9 14 14 5/6

NR 0.9 1.4 2.4 2.4 4/4

Th-232 Yes 0.22 0.75 0.9 1.7 18/18

No ND 0.46 0.51 0.51 5/6

NR 0.48 0.6 1 1 4/4

Tl-208 Yes 0.11 0.66 2.3 3.1 25/25

No 0.63 1.5 13.5 13.5 6/6

NR ND ND 0.29 0.29 1/4

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND ND 0/25

No ND ND - 0.4 1 1 3/6

NR ND ND 0.3 0.3 1/4

I-131 Yes ND 0.22 46 81 15/25

No ND 0.185 1.2 1.2 5/6

NR ND 2.185 4.3 4.3 3/4

In-111 Yes ND ND ND ND 0/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Tl-201 Yes ND 0.36 93 105 13/25

No 0.62 7.85 61 61 6/6

NR ND ND ND ND 0/4

Tl-202 Yes ND ND 1.1 1.53 7/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes ND 3.6 27 30 24/25

No 2.3 5.2 7.6 7.6 6/6

NR 4.2 4.8 13 13 4/4
Table A.16 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Do you receive septage for processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-112

K-40 Yes 7.4 14.1 22 22.4 25/25

No 7.9 14.95 19.8 19.8 6/6

NR 14 14.6 15 15 4/4

La-138 Yes ND ND ND ND 0/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND ND 0/25

No ND ND 0.21 0.21 2/6

NR ND ND ND ND 0/4

Pu-238 Yes ND 0.015 0.06 0.09 13/18

No ND ND - 0 0.1 0.1 3/6

NR 0.01 0.05 0.1 0.1 4/4

Pu-239 Yes ND 0.01 0.06 0.17 14/18

No ND ND - 0 0.01 0.01 3/6

NR 0.00 0.03 0.04 0.04 4/4

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND 0.5 0.8 4/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Rn-219 Yes ND ND 0.2 0.4 3/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Th-227 Yes ND 0.04 0.6 1.1 13/23

No ND ND ND ND 0/6

NR ND ND 0.2 0.2 1/4

U-235 Yes ND 0.11 0.7 1.7 20/25

No 0.07 0.145 3.4 3.4 6/6

NR 0.14 0.18 0.4 0.4 4/4

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND ND 0/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Co-57 Yes ND ND ND 0.17 1/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Co-60 Yes ND ND 0.038 3.46 2/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4
Table A.16 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“Do you receive septage for processing at your facility?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-113

Cr-51 Yes ND ND 0.8 35 5/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Cs-134 Yes ND ND ND ND 0/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Cs-137 Yes ND 0.08 0.27 0.37 24/25

No 0 0.06 0.08 0.08 6/6

NR 0.04 0.045 0.08 0.08 4/4

Eu-154 Yes ND ND ND ND 0/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Fe-59 Yes ND ND ND ND 0/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Sm-153 Yes ND ND ND ND 0/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

Sr-89 Yes ND 1 60 300 13/20

No ND ND - 0 5 5 3/6

NR 0 0.8 3 3 4/4

Sr-90 Yes ND 0.4 1 6 16/20

No ND 0 1 1 5/6

NR ND 0.2 0.3 0.3 3/4

Zn-65 Yes ND ND ND 0.06 1/25

No ND ND ND ND 0/6

NR ND ND ND ND 0/4

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-114

Table A.17 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question, 

“What percentage of the annual average daily total flow rate is industrial flow?”

(All concentrations are expressed in pCi/g dry, unless noted;1 pCi/g=37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Less than 50% ND 0.295 2.9 16 218/284

50% or More ND 0.36 0.56 0.75 12/15

NR ND 0.22 2 2.3 8/12

Pa-234m Less than 50% ND ND 8 27 75/284

50% or More ND ND 3 4 4/15

NR ND ND ND 3 1/12

Pb-210 Less than 50% ND ND 4.2 13 123/284

50% or More ND ND 0.7 4 5/15

NR ND 0.2 3.4 6 7/12

Pb-214 Less than 50% ND 0.305 3 17 232/284

50% or More ND 0.4 0.61 0.8 12/15

NR ND 0.245 2.1 2.4 9/12

Ra-226 Less than 50% ND 2 14 47 265/284

50% or More ND 1 3 4.3 14/15

NR ND 1.55 4.6 5 10/12

Th-230 Less than 50% 0.09 0.355 1 1.7 86/86

50% or More 0.32 0.8 1.2 1.2 3/3

NR 0.12 0.21 0.24 0.24 3/3

Th-234 Less than 50% ND 0.8 7 23 179/284

50% or More ND ND 0.8 2 4/15

NR ND 0.65 4.9 5 8/12

U-234 Less than 50% 0.18 1.95 17 44 86/86

50% or More 0.9 1 2.3 2.3 3/3

NR 0.43 3.1 5.1 5.1 3/3

U-238 Less than 50% 0.18 1.4 12 26 86/86

50% or More 0.7 0.9 2.1 2.1 3/3

NR 0.37 2.2 3.7 3.7 3/3

Radionuclide Group: C-14 and H-3

C-14* Less than 50% ND ND 1 3 58/145

50% or More ND 0 1 1 3/5

NR ND ND 0 0 2/8

H-3* Less than 50% ND 0.3 5 8 102/145

50% or More ND 0.5 0.7 0.7 4/5

NR ND 0.15 3 3 5/8

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Less than 50% ND ND 1.4 13 90/284

50% or More ND 0.3 0.8 0.9 8/15

NR ND ND 1 3.3 3/12
Table A.17 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question, 

“What percentage of the annual average daily total flow rate is industrial flow?”

(All concentrations are expressed in pCi/g dry, unless noted;1 pCi/g=37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-115

Pb-212 Less than 50% ND 0.435 1.9 15 276/284

50% or More 0.03 0.4 0.67 0.82 15/15

NR 0.03 0.515 1.1 3.3 12/12

Ra-224 Less than 50% ND ND 1 12 41/284

50% or More ND ND 0.6 0.7 5/15

NR ND ND ND 1 1/12

Ra-228 Less than 50% ND 0.9 6.7 38 251/284

50% or More ND 0.56 1 1.02 11/15

NR ND 0.64 1.7 3.5 9/12

Th-228 Less than 50% 0.07 0.655 4.6 9 86/86

50% or More 0.16 0.5 0.7 0.7 3/3

NR 0.38 0.38 0.5 0.5 3/3

Th-232 Less than 50% 0.02 0.2 0.65 1.6 86/86

50% or More 0.1 0.35 0.52 0.52 3/3

NR 0.08 0.21 0.28 0.28 3/3

Tl-208 Less than 50% ND 0.07 0.99 4.8 164/284

50% or More ND 0.08 0.28 0.6 11/15

NR ND ND 0.46 3.1 5/12

Radionuclide Group: Medical Isotopes

I-125 Less than 50% ND ND ND 40 9/284

50% or More ND ND ND 1.1 1/15

NR ND ND ND 0.5 1/12

I-131 Less than 50% ND 2.2 60.5 840 229/284

50% or More ND 0.03 0.8 3.6 8/15

NR ND 1.45 10.3 98 9/12

In-111 Less than 50% ND ND 0.04 3.6 18/284

50% or More ND ND ND ND 0/15

NR ND ND ND 1.19 1/12

Tl-201 Less than 50% ND 0.375 48 241 145/284

50% or More ND ND 0.3 34 2/15

NR ND ND 3.5 71 4/12

Tl-202 Less than 50% ND ND 0.54 1.16 69/284

50% or More ND ND 0.09 0.49 3/15

NR ND ND ND 0.88 1/12

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Less than 50% ND 1.3 8.7 22 244/284

50% or More ND 0.5 2.5 10.7 10/15

NR ND 1 9.1 9.9 9/12
Table A.17 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question, 

“What percentage of the annual average daily total flow rate is industrial flow?”

(All concentrations are expressed in pCi/g dry, unless noted;1 pCi/g=37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-116

K-40 Less than 50% ND 4 13 26 281/284

50% or More 0.8 2.8 5.8 8 15/15

NR 0.3 4 8 9 12/12

La-138 Less than 50% ND ND ND ND 0/284

50% or More ND ND ND 0.07 1/15

NR ND ND ND ND 0/12

Radionuclide Group: Transuranics

Am-241 Less than 50% ND ND ND 2.5 10/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Pu-238 Less than 50% ND 0.01 0.07 0.19 69/86

50% or More 0 0 0.01 0.01 3/3

NR 0.00 0.006 0.01 0.01 3/3

Pu-239 Less than 50% ND 0.0035 0.05 0.12 64/86

50% or More ND ND 0.001 0.001 1/3

NR 0.00 0.003 0.01 0.01 3/3

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Less than 50% ND ND ND 0.09 2/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Rn-219 Less than 50% ND ND ND ND 0/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Th-227 Less than 50% ND ND 0.1 0.5 46/191

50% or More ND ND 0.07 0.07 2/7

NR ND ND 0.05 0.05 1/9

U-235 Less than 50% ND ND 0.5 3.1 104/284

50% or More ND ND 0.18 0.26 5/15

NR ND ND 0.15 0.2 3/12

Radionuclide Group: Fission and Activation Products

Ce-141 Less than 50% ND ND ND 0.016 1/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Co-57 Less than 50% ND ND ND 0.26 6/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Co-60 Less than 50% ND ND ND 5.1 13/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12
Table A.17 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question, 

“What percentage of the annual average daily total flow rate is industrial flow?”

(All concentrations are expressed in pCi/g dry, unless noted;1 pCi/g=37 Bq/kg)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-117

Cr-51 Less than 50% ND ND ND 3.5 6/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Cs-134 Less than 50% ND ND ND 0.04 1/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Cs-137 Less than 50% ND ND 0.11 3.6 118/284

50% or More ND 0.011 0.07 0.11 9/15

NR ND ND - 0.01 0.05 0.12 6/12

Eu-154 Less than 50% ND ND ND 21 1/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Fe-59 Less than 50% ND ND ND 0.4 1/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Sm-153 Less than 50% ND ND ND 27 1/284

50% or More ND ND ND ND 0/15

NR ND ND ND ND 0/12

Sr-89 Less than 50% ND 0.35 20 70 66/94

50% or More ND ND 3 3 1/3

NR 20 20 20 20 1/1

Sr-90 Less than 50% ND 0.1 0.7 9.4 61/94

50% or More 0.2 0.2 1 1 3/3

NR ND ND ND ND 0/1

Zn-65 Less than 50% ND ND ND ND 0/284

50% or More ND ND ND 0.06 1/15

NR ND ND ND ND 0/12

* Indicates concentrations for this radionuclide are expressed in pCi/g wet. 
A-118

Table A.18 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“What percentage of the annual average daily total flow rate is industrial flow?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g= 37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Less than 50% ND 2.55 14.1 16 29/30

50% or More 0.62 2.01 3.4 3.4 2/2

NR 1.6 1.7 3 3 3/3

Pa-234m Less than 50% ND 3 11 77 26/30

50% or More ND ND - 7 7 7 1/2

NR 5 5 5 5 3/3

Pb-210 Less than 50% ND ND 8.9 12.3 12/30

50% or More 2.9 3.65 4.4 4.4 2/2

NR ND 4.1 5 5 2/3

Pb-214 Less than 50% 0.69 2.95 15.1 16.4 30/30

50% or More 0.61 2.205 3.8 3.8 2/2

NR 1.7 1.9 3.2 3.2 3/3

Ra-226 Less than 50% ND 3.4 18 22 28/30

50% or More 1.1 2.05 3 3 2/2

NR 1.9 2 5.5 5.5 3/3

Th-230 Less than 50% 0.3 0.85 2.3 2.6 26/26

50% or More ND ND ND ND 0/1

NR 0.7 0.7 0.7 0.7 1/1

Th-234 Less than 50% ND 3.15 21 80 26/30

50% or More 1 3.25 5.5 5.5 2/2

NR 4.7 5.1 7.2 7.2 3/3

U-234 Less than 50% 1.2 5.2 49 91 26/26

50% or More 7.1 7.1 7.1 7.1 1/1

NR 9 9 9 9 1/1

U-238 Less than 50% 0.8 3.2 35 74 26/26

50% or More 6.1 6.1 6.1 6.1 1/1

NR 6.4 6.4 6.4 6.4 1/1

Radionuclide Group: C-14 and H-3

C-14* Less than 50% ND ND 0 1 2/14

50% or More 0 0 0 0 2/2

NR ND ND - 1 1 1 1/2

H-3* Less than 50% ND ND 2 4 5/14

50% or More ND ND ND ND 0/2

NR 3 5.5 8 8 2/2

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Less than 50% ND 1.05 5.5 15.7 21/30

50% or More ND ND - 1.8 1.8 1.8 1/2

NR 1.2 1.6 1.8 1.8 3/3
Table A.18 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“What percentage of the annual average daily total flow rate is industrial flow?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g= 37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-119

Pb-212 Less than 50% 0.36 1.5 6.6 15 30/30

50% or More 0.85 1.375 1.9 1.9 2/2

NR 1.3 1.5 1.7 1.7 3/3

Ra-224 Less than 50% ND ND 2.4 4.9 14/30

50% or More ND ND ND ND 0/2

NR ND ND 0.5 0.5 1/3

Ra-228 Less than 50% 0.65 2.8 24 30 30/30

50% or More 0.68 1.24 1.8 1.8 2/2

NR 2.2 2.4 3.4 3.4 3/3

Th-228 Less than 50% 0.4 1.6 6.7 14 26/26

50% or More ND ND ND ND 0/1

NR 1.7 1.7 1.7 1.7 1/1

Th-232 Less than 50% 0.22 0.505 1 1.7 26/26

50% or More ND ND ND ND 0/1

NR 0.8 0.8 0.8 0.8 1/1

Tl-208 Less than 50% ND 0.62 3.1 13.5 27/30

50% or More 0.75 1.205 1.66 1.66 2/2

NR 0.4 1.36 1.48 1.48 3/3

Radionuclide Group: Medical Isotopes

I-125 Less than 50% ND ND 0.8 1 4/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

I-131 Less than 50% ND 0.22 46 81 21/30

50% or More 0.24 0.705 1.17 1.17 2/2

NR ND ND ND ND 0/3

In-111 Less than 50% ND ND ND ND 0/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Tl-201 Less than 50% ND 0.795 93 105 17/30

50% or More 12.4 30.2 48 48 2/2

NR ND ND ND ND 0/3

Tl-202 Less than 50% ND ND 1.1 1.53 7/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Less than 50% ND 4.3 27 30 29/30

50% or More 7.5 11.45 15.4 15.4 2/2

NR 0.8 0.8 1.2 1.2 3/3
Table A.18 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“What percentage of the annual average daily total flow rate is industrial flow?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g= 37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-120

K-40 Less than 50% 7.4 13.85 20.9 22.4 30/30

50% or More 14.1 15.15 16.2 16.2 2/2

NR 17.4 19.3 22 22 3/3

La-138 Less than 50% ND ND ND ND 0/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Radionuclide Group: Transuranics

Am-241 Less than 50% ND ND 0.04 0.21 2/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Pu-238 Less than 50% ND 0.015 0.1 0.1 19/26

50% or More ND ND ND ND 0/1

NR 0.05 0.05 0.05 0.05 1/1

Pu-239 Less than 50% ND 0.01 0.06 0.17 20/26

50% or More ND ND ND ND 0/1

NR 0.02 0.02 0.02 0.02 1/1

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Less than 50% ND ND 0.5 0.8 4/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Rn-219 Less than 50% ND ND 0.2 0.4 3/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Th-227 Less than 50% ND ND 0.6 1.1 13/28

50% or More ND ND ND ND 0/2

NR ND ND 0.1 0.1 1/3

U-235 Less than 50% ND 0.15 1.7 3.4 28/30

50% or More ND ND -

0.31

0.31 0.31 1/2

NR ND ND 0.3 0.3 1/3

Radionuclide Group: Fission and Activation Products

Ce-141 Less than 50% ND ND ND ND 0/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Co-57 Less than 50% ND ND ND 0.17 1/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3
Table A.18 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question 

“What percentage of the annual average daily total flow rate is industrial flow?”

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g= 37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-121

Co-60 Less than 50% ND ND 0.038 3.46 2/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Cr-51 Less than 50% ND ND 0.8 35 4/30

50% or More ND ND ND ND 0/2

NR ND ND 0.2 0.2 1/3

Cs-134 Less than 50% ND ND ND ND 0/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Cs-137 Less than 50% ND 0.07 0.27 0.37 29/30

50% or More 0.07 0.085 0.1 0.1 2/2

NR 0.06 0.09 0.09 0.09 3/3

Eu-154 Less than 50% ND ND ND ND 0/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Fe-59 Less than 50% ND ND ND ND 0/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Sm-153 Less than 50% ND ND ND ND 0/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

Sr-89 Less than 50% ND 1 60 300 19/26

50% or More ND ND - 2 2 2 1/2

NR ND ND ND ND 0/2

Sr-90 Less than 50% ND 0.1 1 6 20/26

50% or More 0.1 0.55 1 1 2/2

NR 1 1 1 1 2/2

Zn-65 Less than 50% ND ND ND 0.06 1/30

50% or More ND ND ND ND 0/2

NR ND ND ND ND 0/3

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-122

Table A.19 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Do you have more than one final sewage sludge production facility location?”

(All concentrations are expressed in pCi/g dry, unless notes; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes ND 0.21 2 6 24/32

No ND 0.3 2.3 16 214/279

Pa-234m Yes ND ND 4 5 6/32

No ND ND 8 27 74/279

Pb-210 Yes ND ND 2.2 12 12/32

No ND ND 4 13 123/279

Pb-214 Yes ND 0.225 2.1 4 26/32

No ND 0.31 2.6 17 227/279

Ra-226 Yes ND 2 10.6 19 31/32

No ND 2 13 47 258/279

Th-230 Yes 0.17 0.305 0.5 0.5 6/6

No 0.09 0.34 1.2 1.7 86/86

Th-234 Yes ND 0.5 3.1 19 19/32

No ND 0.7 6.8 23 172/279

U-234 Yes 0.5 1.45 2.5 2.5 6/6

No 0.18 2 17 44 86/86

U-238 Yes 0.5 1.05 2 2 6/6

No 0.18 1.4 12 26 86/86

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND 2 3 6/14

No ND ND 1 2 57/144

H-3* Yes ND 0.1 1 2 10/14

No ND 0.35 5 8 101/144

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND ND 0.9 2 10/32

No ND ND 1.4 13 91/279

Pb-212 Yes ND 0.365 1.1 1.9 31/32

No ND 0.47 2 15 272/279

Ra-224 Yes ND ND 0.5 1 3/32

No ND ND 0.9 12 44/279

Ra-228 Yes ND 0.79 3 6 28/32

No ND 0.84 6.7 38 243/279

Th-228 Yes 0.19 0.645 1.6 1.6 6/6

No 0.07 0.605 4.6 9 86/86

Th-232 Yes 0.07 0.15 0.31 0.31 6/6

No 0.02 0.2 0.65 1.6 86/86

Tl-208 Yes ND 0.055 0.36 1.1 18/32

No ND 0.08 0.99 4.8 162/279
Table A.19 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Do you have more than one final sewage sludge production facility location?”

(All concentrations are expressed in pCi/g dry, unless notes; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-123

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND 5.9 1/32

No ND ND ND 40 10/279

I-131 Yes ND 3.25 82 153 27/32

No ND 1.5 44 840 219/279

In-111 Yes ND ND 0.18 3.6 6/32

No ND ND ND 3.5 13/279

Tl-201 Yes ND 0.595 40 80 18/32

No ND ND 48 241 133/279

Tl-202 Yes ND ND 0.4 0.92 10/32

No ND ND 0.54 1.16 63/279

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes ND 1.45 4 9.9 27/32

No ND 1.1 9.1 22 236/279

K-40 Yes 1.4 3.6 8.3 25 32/32

No ND 4 12 26 276/279

La-138 Yes ND ND ND ND 0/32

No ND ND ND 0.07 1/279

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND 2.5 2/32

No ND ND ND 0.14 8/279

Pu-238 Yes ND 0.01 0.04 0.04 5/6

No ND 0.01 0.07 0.19 70/86

Pu-239 Yes ND 0.0035 0.12 0.12 5/6

No ND 0.003 0.04 0.11 63/86

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND ND ND 0/32

No ND ND ND 0.09 2/279

Rn-219 Yes ND ND ND ND 0/32

No ND ND ND ND 0/279

Th-227 Yes ND ND 0.04 0.05 3/17

No ND ND 0.1 0.5 46/190

U-235 Yes ND ND 0.13 0.3 9/32

No ND ND 0.5 3.1 103/279

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND ND 0/32

No ND ND ND 0.016 1/279

Co-57 Yes ND ND ND 0.26 1/32

No ND ND ND 0.06 5/279
Table A.19 Concentrations of Radionuclides in Sludge

Summarized by Response to the POTW Questionnaire Question 

“Do you have more than one final sewage sludge production facility location?”

(All concentrations are expressed in pCi/g dry, unless notes; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-124

Co-60 Yes ND ND ND 0.07 1/32

No ND ND ND 5.1 12/279

Cr-51 Yes ND ND ND ND 0/32

No ND ND ND 3.5 6/279

Cs-134 Yes ND ND ND ND 0/32

No ND ND ND 0.04 1/279

Cs-137 Yes ND ND 0.06 0.11 7/32

No ND ND 0.11 3.6 126/279

Eu-154 Yes ND ND ND ND 0/32

No ND ND ND 21 1/279

Fe-59 Yes ND ND ND ND 0/32

No ND ND ND 0.4 1/279

Sm-153 Yes ND ND ND ND 0/32

No ND ND ND 27 1/279

Sr-89 Yes 0 5 40 40 7/7

No ND 0.3 20 70 61/91

Sr-90 Yes ND ND 0.2 0.2 2/7

No ND 0.1 1 9.4 62/91

Zn-65 Yes ND ND ND ND 0/32

No ND ND ND 0.06 1/279

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
A-125

Table A.20 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question

“Do you have more than one final sewage sludge production facility location?

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

Radionuclide Group: Uranium-238 Decay Series

Bi-214 Yes 1.4 3.25 14.1 14.1 4/4

No ND 2.2 13.7 16 30/31

Pa-234m Yes ND 5 9 9 3/4

No ND 3 11 77 27/31

Pb-210 Yes ND ND 5 5 1/4

No ND ND 8.5 12.3 15/31

Pb-214 Yes 1.6 3.6 15.1 15.1 4/4

No 0.61 2.4 14.6 16.4 31/31

Ra-226 Yes ND 5.5 22 22 3/4

No ND 3 17 18 30/31

Th-230 Yes 0.7 1.1 2.6 2.6 4/4

No ND 0.7 2.2 2.3 23/24

Th-234 Yes 1.7 3.7 7.5 7.5 4/4

No ND 3.6 11 80 27/31

U-234 Yes 2.1 4.9 7 7 4/4

No 1.2 5.55 49 91 24/24

U-238 Yes 1.9 4 6.2 6.2 4/4

No 0.8 3.3 35 74 24/24

Radionuclide Group: C-14 and H-3

C-14* Yes ND ND ND ND 0/1

No ND ND 1 1 5/17

H-3* Yes 1 1 1 1 1/1

No ND ND 4 8 6/17

Radionuclide Group: Thorium-232 Decay Series

Bi-212 Yes ND 1.3 1.6 1.6 3/4

No ND 1.2 3.5 15.7 22/31

Pb-212 Yes 1.3 1.5 1.6 1.6 4/4

No 0.36 1.5 3.3 15 31/31

Ra-224 Yes ND 1.1 1.3 1.3 3/4

No ND ND 2 4.9 12/31

Ra-228 Yes 1.7 2.25 9.9 9.9 4/4

No 0.65 2.7 17 30 31/31

Th-228 Yes 1.1 2 3.4 3.4 4/4

No ND 1.45 6.7 14 23/24

Th-232 Yes 0.5 0.8 0.9 0.9 4/4

No ND 0.5 1 1.7 23/24

Tl-208 Yes 0.38 0.475 1.38 1.38 4/4

No ND 0.73 2.3 13.5 28/31
Table A.20 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question

“Do you have more than one final sewage sludge production facility location?

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-126

Radionuclide Group: Medical Isotopes

I-125 Yes ND ND ND ND 0/4

No ND ND 0.4 1 4/31

I-131 Yes ND ND - 0.05 0.39 0.39 2/4

No ND 0.22 20 81 21/31

In-111 Yes ND ND ND ND 0/4

No ND ND ND ND 0/31

Tl-201 Yes ND ND 0.36 0.36 1/4

No ND 1 73 105 18/31

Tl-202 Yes ND ND 0.1 0.1 1/4

No ND ND 0.99 1.53 6/31

Radionuclide Group: NORM other than Thorium/Uranium

Be-7 Yes 0.5 5.85 11.3 11.3 4/4

No ND 4.3 15.4 30 30/31

K-40 Yes 11 16.5 22.4 22.4 4/4

No 7.4 14.2 19.8 22 31/31

La-138 Yes ND ND ND ND 0/4

No ND ND ND ND 0/31

Radionuclide Group: Transuranics

Am-241 Yes ND ND ND ND 0/4

No ND ND ND 0.21 2/31

Pu-238 Yes ND 0.015 0.06 0.06 3/4

No ND 0.015 0.1 0.1 17/24

Pu-239 Yes ND 0.005 0.06 0.06 3/4

No ND 0.01 0.05 0.17 18/24

Radionuclide Group: Actinium (U-235) Decay Series

Ra-223 Yes ND ND 0.1 0.1 1/4

No ND ND 0.2 0.8 3/31

Rn-219 Yes ND ND ND ND 0/4

No ND ND 0.2 0.4 3/31

Th-227 Yes ND 0.135 0.2 0.2 3/4

No ND ND 0.6 1.1 11/29

U-235 Yes 0.11 0.275 0.6 0.6 4/4

No ND 0.14 0.7 3.4 26/31

Radionuclide Group: Fission and Activation Products

Ce-141 Yes ND ND ND ND 0/4

No ND ND ND ND 0/31

Co-57 Yes ND ND 0.17 0.17 1/4

No ND ND ND ND 0/31
Table A.20 Concentrations of Radionuclides in Ash

Summarized by Response to the POTW Questionnaire Question

“Do you have more than one final sewage sludge production facility location?

(All concentrations are expressed in pCi/g dry, unless noted; 1 pCi/g=37 Bq/kg.)

Radionuclide Response Min Median 95th P Max No. Detects/

No. Analyses

A-127

Co-60 Yes ND ND ND ND 0/4

No ND ND ND 3.46 2/31

Cr-51 Yes ND ND 0.3 0.3 1/4

No ND ND 0.3 35 4/31

Cs-134 Yes ND ND ND ND 0/4

No ND ND ND ND 0/31

Cs-137 Yes 0.06 0.075 0.11 0.11 4/4

No ND 0.07 0.23 0.37 30/31

Eu-154 Yes ND ND ND ND 0/4

No ND ND ND ND 0/31

Fe-59 Yes ND ND ND ND 0/4

No ND ND ND ND 0/31

Sm-153 Yes ND ND ND ND 0/4

No ND ND ND ND 0/31

Sr-89 Yes ND ND 300 300 1/4

No ND 1 30 60 19/26

Sr-90 Yes 0 0.95 6 6 4/4

No ND 0.1 1 1 20/26

Zn-65 Yes ND ND ND ND 0/4

No ND ND ND 0.06 1/31

* Indicates concentrations for this radionuclide are expressed in pCi/g wet.
APPENDIX B

OMB SUPPORTING STATEMENT

FOR 

JOINT NRC/EPA SURVEY OF SEWAGE SLUDGE/ASH
B-1

APPENDIX B

DECEMBER 2, 1997

OMB SUPPORTING STATEMENT

FOR 

JOINT NRC/EPA SURVEY OF SEWAGE SLUDGE/ASH

Description of the Information Collection

The U.S. Nuclear Regulatory Commission and the U.S. Environmental Protection Agency (EPA)

are sponsoring a joint effort to characterize radioactive materials in sewage sludge and ash

from publicly owned treatment works (POTWs). Sanitary sewer disposal of radioactive material

and sludge reconcentration became issues in the 1980s with the discovery of elevated levels in

sewage sludge or incinerator ash at several POTWs. Although the NRC expected that

compliance with revisions in its sewer disposal criteria would prevent future reconcentration

problems, NRC and EPA have continued to work together to ensure a coordinated regulatory

review effort concerning sewage treatment with respect to radioactive material. EPA had

planned to include analysis of radioactivity in sewage sludge and incinerator ash in its second

National Sewage Sludge Survey during 1996-97. (The first national survey conducted in the

late 1980s did not include analysis of radioactive material.) Based on the current budget

situation, EPA did not move forward with a second national survey. As a result, NRC and EPA

will perform a joint survey of radioactivity in sewage sludge and ash at POTWs.

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 send questionnaires to the POTWs associated with types of

NRC licensees that have the highest potential to discharge radioactive material to the sewer

system and POTWs in all geographic areas of the United States. Using the information from

the questionnaires, NRC and EPA will identify approximately 300 POTWs to be sampled. NRC

and EPA tested the survey methods and procedures on nine POTWs. The results of the full

survey will be published as a joint NRC/EPA report for use by Federal agencies, States,

POTWs, local POTW officials, and other interested parties.

A. JUSTIFICATION

1. Need for and Practical Utility of the Collection of Information

The objectives of this joint NRC/EPA sewage sludge/incinerator ash survey are to

(1) obtain national estimates of high probability occurrences of elevated levels of

radioactive materials in sludge and ash at POTWs, (2) estimate the extent to which

radioactive contamination comes from either NRC/Agreement State licensees or

naturally occurring radioactivity, and (3) support rulemaking decisions by NRC and EPA.

Specific amounts and concentrations of radioactive material are legally authorized to 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
B-2

materials were reconcentrating in sewage sludge or incinerator ash. Regulations 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

acceptable limits for radioactive materials in sewage sludge and ash.

2. Agency Use of Information

This is 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

sewage sludge. EPA will determine, based on the results of this survey, whether

additional random sampling will be necessary to support its own rulemaking, if

warranted.

This information will be used in developing joint NRC/EPA guidance for POTWs. 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. 

POTWs, local sewer district officials, and EPA have requested this guidance.

3. Reduction of Burden through Information Technology

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 questionnaire 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 did not identify the facilities tested, and

thus it is not possible to assess regional 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.)
B-3

5. Effort to Reduce Small Business Burden

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

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

burden on small entities. 

6. Consequences to Federal Program or Policy Activities if the Collection is Not

Conducted or is Conducted Less Frequently

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

radionuclides at POTWs. NRC and EPA will also not be able to obtain information

providing a basis for developing potential future rulemakings and quantitative guidance

for the proposed joint NRC/EPA guidance for POTWs. This is a one-time collection.

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

7. Circumstances Which Justify Variation from OMB Guidelines

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

8. Consultations Outside the NRC

In an October 11, 1994 letter, NRC and EPA notified 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

55 wastewater plants in 17 states have been analyzed. These plants were distributed

across the country and range in size from small to among the largest POTWs in the

United States. Because of limitations in the AMSA survey, including the fact that the

POTWs were anonymous, the possibility of a more extensive NRC/EPA jointly funded

survey of sludge and ash to assess the need for NRC rulemaking was considered. The

industry representatives stated their continued interest in a joint NRC/EPA guidance

document addressing reconcentration of radioactive material at POTWs. NRC and EPA

have met with the WEF Radioactivity Task Force to discuss the status of the NRC/EPA

survey and the contents of the joint guidance. During the survey, NRC and EPA will

continue to meet with representatives of industry.

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

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

sample collection and analysis procedures and the selection of facilities to sample.
B-4

The NRC contractor, the U.S. Department of Energy's Oak Ridge Institute for Science

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 survey design. 

For example, ORISE and NAREL collaborated to ensure that the analytical laboratory

procedures and quality assurance programs that both labs will use will produce

consistent, accurate, and reliable measurements.

An opportunity to comment on the information collection requirements in this survey was

provided in the January 6, 1997 Federal Register notice on this clearance request. NRC

received comments from five members of the public. The only change to the survey

that resulted from the public comments was that one question was added to the

questionnaire to determine if a previous analysis of radioactive materials was

performed. If there is a question about the survey results at a specific POTW and an

earlier analysis is available, we may compare the earlier analysis to the survey results. 

There were no changes in the cost or hourly burden as a result of the public comments.

Some of the public comments did not address the survey, and therefore, their resolution

will have no impact on it. For example, some commenters asked the NRC to survey and

sample its licensees, not POTWs. Several commenters noted the nearly complete

absence of data in the NRC's possession regarding the licensees' discharges to the

sewers. Some commenters also asked what the NRC would do for POTWs if they are

found to have a contamination problem.

Some of the commenters objected to the survey. All the comments have been

analyzed, and an analysis of the comments is attached.

9. 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 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 NRC

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. At the conclusion of the

survey, an industry organization such as AMSA will receive the code book with the

identity of the POTW code numbers.

11. Justification for Sensitive Questions

There will be no survey questions of a sensitive nature.
B-5

12. Estimated Burden and Burden Hour Cost

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 

hour. For 600 POTWs, the estimated burden would be 600 hours.

The survey was tested at nine POTWs to assess the questionnaire and sampling and

analysis procedures. The test cases also gave a better basis for estimating the actual

burden cost. Most of the POTW test cases took 20 minutes or less to complete the

questionnaire; larger facilities required two hours to develop a list of zip codes for their

collection system. Our original estimate of the time needed to complete the

questionnaire was 2 hours; however, based on the results of the test cases, the revised

estimated time to complete the questionnaire is 1 hour. For 600 POTWs, the estimated

burden to respond to the questionnaire is 600 hours.

The questionnaire to the POTWs will ask for the zip codes for its collection system so

that 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 30 Agreement States

at 8 hours per State, the estimated burden would be 240 hours.

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 (one

for each disposal practice). The estimated time for each POTW to collect and return the

two samples is 6 hours. For 300 POTWs, the estimated burden is 1800 hours.

Total estimated burden = 600 + 240 + 1800 hours = 2640 hours

Estimated cost = 2640 hours x $120/hour = $316,800

13. Estimate of Other Additional Costs

There will be no additional cost burdens (beyond the cost of the hour burden discussed

above) to the POTWs. There is no need to purchase additional equipment or laboratory

support. For respondents to this survey, it is most likely that purchases of equipment

and services were made (1) prior to October 1, 1995, (2) to achieve regulatory

compliance with requirements not associated with the information collection, (3) for

reasons other than to provide information or keep records for the government, or (4) as

part of customary and usual business or private practices.

14. Estimated Cost to the Federal and State Governments

The cost to the Federal Government for this one-time-only survey includes costs for

contractor support for the radioanalytical analysis, NRC and EPA Headquarters staffs,

and Agreement State support.
B-6

Cost for Radioanalytical Support

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

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

Tasks ORISE Cost EPA/NAREL Cost

Assist NRC and EPA in development of the

survey, including test cases

50,000 12,000

Phone calls to POTWs, mailing sample

collection packages, and providing return

postage

25,500 0

Analyze samples 146,400 110,550

Report preparation 16,100 9,750

Sample disposition 0 5,000

Subtotal 238,000 137,300

Federal Government Cost

NRC Headquarters staff will coordinate the development of the survey and analyze the

survey results. 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 for contract

management and general oversight of the work scope.

2 FTE x 2080 hours x $120/hour = $499,200

The cost for a statistical consultant to support the analysis is about $100,000.

Total estimated survey cost for the Federal government

Lab costs + Federal costs + statistical consultant =

$238,000 + $137,300 + $499,200 + $100,000 = $974,500

Agreement State Cost

See Item 12, Estimated Burden and Burden Hour Cost, above.
B-7

15. Reasons for Changes in Burden or Cost

This is a new collection. There are no changes in burden or cost.

16. Publication for Statistical Use

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.

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. 

17. Reason for Not Displaying the Expiration Date

Not applicable. The expiration date will be displayed.

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 high probability occurrences of elevated

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, questionnaires will be sent to (1) POTWs associated with types of

NRC licensees that have the highest potential to discharge radioactive material into the

sewer system, (2) many of the POTWs with incinerators (these will be more heavily

sampled because concentrations of radioactive material are expected to be higher in

ash than in sludge), (3) POTWs in all geographic areas of the contiguous United States,

and (4) POTWs requested by States and ISCORS agencies.

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 associated

with each POTW that have the potential to dispose of radioactive material into its

collection system.
B-8

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

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

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 selection of the 300 POTWs to sample will be based on the results of the

questionnaire survey. The questionnaire responses will be grouped into several

categories and a random sample will be selected from each category. The categories

we expect 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)

Potential problems include a low response rate because the survey is voluntary 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 was executed to test the questionnaire and the

sampling and laboratory analysis procedures. As a result of the pilot survey, several

changes were made to the questionnaire. For example, a question was added on

whether the POTW had previously sampled for radioactive material. If there is a

question about the survey results at a specific POTW, and an earlier analysis is

available, it may be advisable to compare the two analyses.

As a result of the pilot survey, several changes were made to the sample analysis. For

example, the list of radionuclides to be analyzed was refined, and the need for analysis

of some samples by both labs was dropped due to the similarity of the test site results at

the two labs.

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

Lee Abramson

U.S. Nuclear Regulatory Commission

301-415-6180
APPENDIX C

SEWAGE SLUDGE QUESTIONNAIRE
C-1

APPENDIX C

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).
C-2

2. GLOSSARY OF TERMS

End-products are the materials that leave the sewage treatment facility or are disposed of

onsite after all

processing is completed (e.g., ash from incineration, digested liquid or dewatered 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.

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).

SECTION I. TREATMENT WORKS IDENTIFICATION INFORMATION

Mailing Label

Name of the treatment works and physical location (which may differ from the mailing address):
C-3

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:

SECTION II. GENERAL TREATMENT WORKS INFORMATION

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

(Mark X for all that apply.

 a. Primary treatment

 b. Secondary treatment

 c. 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.

4. Identify the sewage sludge treatment process(es) used at your treatment works. (Mark

X for all that apply.)

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

the last calendar year. Explain:_________________

 b. Thickening

 c. Mechanical dewatering by_________________

(Please fill in process(es) used.

 d. Heat treatment/wet air oxidation

 e. Aerobic digestion
C-4

 f. Anaerobic digestion

 g. Composting

 h. Lime stabilization (Class B)

 i. Alkaline Stabilization (Class A)

 j. Air drying beds

 k. Heat drying/Pelletizing

 l. Sewage sludge treatment/storage lagoon(s)

 m. Sewage sludge storage bins or piles

 n. Incineration

 o. 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. Land application. Product description:

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

Product description: __________________ 

 c. Disposal in municipal solid waste landfill.

Product description: __________________ 

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

disposal.

Product description: __________________ 

Identify the facility (type, location): __________________ 

 e. Other use or disposal practice.

Product description: __________________ 
C-5

Describe practice: __________________ 

6. What are the primary sources of drinking water for your community? Check more than

one, if applicable.

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

 b. Municipal water supply from groundwater well(s)

 c. Private wells

 d. Private water supply from surface water source(s)

7. Does your wastewater collection system receive discharges of drinking water treatment

residuals?

Yes _____ No _____

8. Does your wastewater collection system include combined sanitary and storm water

sewers?

Yes _____ No _____

9. Do you receive sludge from other wastewater treatment facilities for processing at your

facility?

Yes _____ No _____

10. Do you receive septage for processing at your facility?

Yes _____ No _____

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?

Yes _____ No _____

13. Do you have more than one final sewage sludge production facility location?

Yes _____ No _____
C-6
APPENDIX D

QUALITY ASSURANCE PROJECT PLAN

EPA/NRC SEWAGE SLUDGE SURVEY

IAG/QAPP-2

Revision 1

October 2001

Prepared by:

U.S. Environmental Protection Agency

Office of Radiation and Indoor Air

National Air and Radiation Environmental Laboratory

540 South Morris Avenue

Montgomery, AL 36115-2601
D-1

This Quality Assurance Project Plan has been prepared in accordance with requirements

described in EPA QA/R-5, ?EPA Requirements for Quality Assurance Project Plans for

Environmental Data Operations,” United States Environmental Protection Agency, Quality

Assurance Management Staff (now Quality Assurance Division), Draft Interim Final, August

1994.
D-2

Quality Assurance Project Plan

EPA/NRC Sewage Survey

Revision History

Rev. Responsible Official Date

0 Mary Wisdom .............................................. 10/27/99

1 Andrea R. Jones ............................................ 10/31/01
D-3

TABLE OF CONTENTS

Revision History ............................................................ D-2

Table of Contents ........................................................... D-3

1.0 Project Description .................................................... D-5

2.0 Project Organization and Responsibilities .................................. D-5

3.0 Project Quality Objectives ............................................... D-6

4.0 Procurement and Acceptance Requirements .............................. D-12

5.0 Instruments and Equipment ............................................ D-13

5.1 Field and Sampling Instruments and Equipment ...................... D-13

5.2 Laboratory Instruments and Equipment ............................. D-13

6.0 Documentation and Records ........................................... D-14

6.1 Document Control System ....................................... D-14

6.2 Laboratory Operating Documents ................................. D-14

6.3 Project Documentation .......................................... D-15

6.4 Project Data Package Deliverables ................................ D-16

6.5 Records Archiving and Retention Policies ........................... D-18

7.0 Sampling Process Design ............................................. D-18

8.0 Sampling Procedures ................................................. D-18

8.1 Sampling Procedures and Equipment .............................. D-18

8.2 Collection of Samples ........................................... D-18

8.3 Sample Custody, Shipping, and Notification .......................... D-18

8.4 Corrective Actions .............................................. D-22

9.0 Laboratory Sample Receipt ............................................ D-22

10.0 Laboratory Sample Preparation Procedures ............................... D-23

11.0 Analytical Procedures ................................................. D-23

11.1 Analytical Methods .............................................. D-23

11.2 Analytical Quality Assurance ...................................... D-23

11.3 Quality Control Samples ......................................... D-23

11.4 Sample Batching ............................................... D-28

11.5 Waste Disposal ................................................ D-28

12.0 Laboratory Data Management ........................................... D-28
D-4

13.0 Reports to Management ............................................... D-32

13.1 Frequency and Distribution of Reports .............................. D-32

13.2 Direct Reports to Management .................................... D-32

13.3 Reports of Audit Findings ........................................ D-33

13.4 Performance Evaluation Results ................................... D-33

13.5 Project Reports for the Sludge Survey .............................. D-33

14.0 Assessments and Responses .......................................... D-33

14.1 Performance Evaluation and Cross-Check Samples .................. D-33

14.2 QAC Laboratory Audits .......................................... D-34

14.3 Corrective Actions and Nonconformance Reports ..................... D-34

15.0 RISSAD Data Management Quality Assurance Project Plan .................. D-36

15.1 Environmental Health Associates .................................. D-36

15.2 Data Acceptance Criteria ........................................ D-36

15.3 Computer and Computer Software ................................. D-36

15.4 Record Keeping ............................................... D-37

15.5 Data Management Path ......................................... D-38

15.6 Document and File Tracking Systems and Change Control Systems ..... D-38

15.7 Data Security: Transference, Storage, Recovery and Retrieval .......... D-38

15.8 Final Quality Assurance of Database ............................... D-39

16.0 Implementation of the QAPP ............................................ D-39

16.1 Implementation Schedule ........................................ D-39

16.2 Flexibility ..................................................... D-39

16.3 Review and Approval for the Sludge Project .......................... D-39

Table D.1 Format of Monthly Data Report .................................... D-16

Table D.2 Minimum Detectable Concentrations for Selected Gamma Emitters ...... D-20

Table D.3 Minimum Detectable Concentrations for Selected Radionuclides ......... D-21

Table D.4 NAREL Data Handling Equipment ................................. D-31

Table D.5 ORISE Data Handling Equipment .................................. D-32

Figure D.1 Alpha Analysis Decision Tree ...................................... D-8

Figure D.2 Beta Analysis Decision Tree ....................................... D-9

Figure D.3 Gamma Analysis Decision Tree ................................... D-10

Figure D.4 Comparison of Critical Level to Detection Limit ....................... D-11

Figure D.5 Data Flow Process ............................................. D-29

Figure D.6 RISSAD Data Handling Process ................................... D-37

Appendix A Sampling Kit and Sample Collection Information Sent to POTWs ......... D-40

Appendix B Method and Reference SOPs for the Survey ......................... D-43

Glossary .................................................................. D-45
D-5

1.0 PROJECT DESCRIPTION

This Plan applies to the joint survey sponsored by the U.S. Nuclear Regulatory Commission

(NRC) and the U.S. Environmental Protection Agency (EPA) to collect information concerning

radioactivity in sewage sludge and ash from sewage treatment plants (referred to in the industry

as publicly owned treatment works (POTWs) which was conducted from 1998 through 2000. 

The U.S. Department of Energy's Oak Ridge Institute for Science and Education (ORISE), in

Oak Ridge, Tennessee and EPA's National Air and Radiation Environmental Laboratory

(NAREL) in Montgomery, Alabama analyzed the sewage sludge and ash samples. NAREL and

ORISE will each analyzed half the samples. Samples were collected over a 12-month period to

ensure an even flow of samples into the laboratories and to allow adjustments to the analyses

as needed.

Pilot Study

In order to evaluate sampling procedures, laboratory procedures, and laboratory comparability,

nine POTWs were selected as test cases. The samples from the test cases were collected,

shipped, analyzed, and reported under current requirements of the Quality Assurance Manual

for the Energy/Environment Systems Division, Environmental Survey and Site Assessment

Program (EESAP) of ORISE, and The Quality Assurance Plan for the National Air and Radiation

Environmental Laboratory and written NAREL and ORISE QA/QC policies for radionuclide

analysis. Split samples from the nine test POTWs were analyzed by both ORISE and NAREL. 

Results were studied to ensure comparability, consistency in sample handling, and validity of

analytical methods. The results of this study indicated that in general the laboratories had good

agreement between gamma analyses. Thus, the final survey did not require that split samples

be analyzed by both laboratories. The gross alpha and beta analyses did not provide as good

agreement due to differences in calibration and/or analysis procedures at the two laboratories. 

Although gross alpha and beta measurements are useful as screening tools, their accuracy

should not be assumed to be better than about one order of magnitude. Therefore, the general

magnitude of the results should be evaluated rather than detailed comparisons between

individual measurements.

2.0 PROJECT ORGANIZATION AND RESPONSIBILITIES

At ORISE, the Program Director and Assistant Program Director have overall responsibility for

ESSAP quality assurance. Specifically, they establish program policies and procedures;

monitor training operations; monitor data collection, development, and management; host and, if

necessary, initiate external audits; review final survey reports and approve for release; and

authorize exceptions to the requirements of the ESSAP Manual. The Quality Assurance

Manager provides independent oversight for QA/QC pertaining to projects and laboratory

activities and provides input directly to the Program Director; maintains the tracking system of

audit findings and nonconformances, and then follows their resolution and closure; reviews all

final reports prior to release; oversees maintenance of ESSAP training and certification records;

oversees ESSAP performance evaluation activities; and coordinates vendor/provider

assessments as deemed necessary by the Program Director. 

According to the NAREL Quality Management Plan, the Director of the Office of Radiation and

Indoor Air (ORIA) is responsible for ensuring that measurements performed within ORIA meet
D-6

established Data Quality Objectives (DQOs). The Office Director has delegated the

responsibility for overseeing quality assurance to the ORIA Quality Assurance Manager and has

further delegated to the NAREL Director the primary responsibility for quality assurance on

measurements in that facility. The NAREL Director has appointed a Quality Assurance

Coordinator (QAC) to direct and oversee the laboratory’s Quality Assurance Program. In

addition, the Quality Assurance Forum (QAF) has been formed to focus on all pertinent QA

issues. The QAF meets quarterly, includes all interested laboratory personnel, and uses open

forums and work groups to recommend procedures that will effectively and efficiently resolve an

identified problem.

The two laboratories will provide the analytical work, quality control and quality assurance, and

data review and internal evaluation for the project. NAREL and ORISE will cooperate fully

toward reaching agreement and closure on any issues which arise.

NAREL and ORISE staff are knowledgeable, well-trained, and experienced. Staff are trained,

qualified, and certified according to requirements in the two laboratories’ QA plans. Laboratory

staffs routinely perform radiochemical analysis and data evaluation and interpretation. 

Laboratory analysts must be trained and certified for the analytical procedures they conduct.

At ORISE, staff receives appropriate training in health and safety, first aid, and CPR as deemed

necessary by program management. The Quality Assurance manager ensures completion of

training. The Office of Human Resources schedules and tracks ORISE mandatory training and

assists with developmental training. The Office of Safety and Environmental Assurance

provides training for radiation workers as required by federal regulations, and other safety related

training as needs are identified. At NAREL, the Safety, Health, and Environmental Manager

(SHEM) and the Radiation Safety Officer (RSO) with assistance from the Branch Chiefs and the

Laboratory Director, annually assess individual needs for training in health and safety and in

radiological safety for each employee. Specific job responsibilities dictate the type, complexity,

and frequency of such training. Once an employee is identified as requiring health and safety

training, whether initial or refresher training, attendance at, and completion of, the training are

mandatory. 

3.0 PROJECT QUALITY OBJECTIVES

Data quality objectives for the laboratory analysis of project samples are the normal analytical

procedures and quality control acceptance criteria routinely followed by each of the laboratories. 

Section 11 of this QAPP provides a complete description of the analytical DQOs, their

acceptance criteria, and corrective action required if criteria are not met.

ORISE will supply the sample collection packages to the POTWs. Samples will be collected,

preserved, packaged, and shipped to the ORISE or NAREL laboratory by regular POTW

workers using information and sampling supplies furnished by the laboratories. See Appendix A

for sampling instructions and lists of sampling materials to be sent to POTWs. 
D-7

Samples collected each month will be screened by the laboratories using their standard

procedures for gross alpha and beta analysis and gamma scanning. A decision tree will be

used for the alpha, beta, and gamma screening analyses to determine if, and what, nuclide

specific analyses are indicated. Figures 1, 2, and 3 show the three decision trees. These trees

will be used to identify samples for nuclide-specific analyses from the samples sent to the

laboratories by the POTWs.
D-8

Alpha Analysis Decision Tree

Perform gross alpha

analysis on sludge or ash

samples.

Is gross alpha activity

present ?

Report no activity

detected, with the MDC

value provided.

Stop

Stop Is activity detected

for a specific nuclide?

Report no activity

detected, with the MDC

value provided, for

each nuclide.

Report activity (at 95%

confidence) of the specific

nuclide(s).

Stop

no

yes

Pool samples until end

of calendar month.

Compare samples with gamma

spectra. If presence is

confirmed, perform specific

radiochemical analyses for

U, Th, Pu, Am as indicated.

yes

yes

Report activity (at 95%

confidence).

Are the positive

samples in the top 10%

of activities detected this

calendar month for

each matrix?

no

no

Figure D.1
D-9

Beta Analysis Decision Tree

Perform gross beta

analysis on sludge or ash

samples.

Is gross beta activity

present ?

Report no activity

detected, with the MDC

value provided.

Stop

Stop Is activity detected

for a Sr?

Report no activity

detected, with the MDC

value provided, for

each nuclide.

Report activity (at 95%

confidence) of Sr.

Stop

no

yes

Pool samples until end

of calendar month.

Perform specific radiochemical

analyses for Sr.

yes

Report activity (at 95%

confidence).

Are the positive

samples in the top 10%

of activities detected this

calendar month for

each matrix?

no

no

yes

Figure D.2
D-10

Perform gamma spectroscopy

on sludge or ash samples

using standard 1000 minute

counting time.

Is activity detected ?

Report activity (at 95%

confidence) of nuclides

detected.

Stop

Report no activity detected,

with the MDC value

provided.

Gamma Analysis Decision Tree

yes

no Stop

Figure D.3
D-11

Each laboratory will report the minimum detectable concentration (MDC) for all nuclides of

interest which are not detected in a sample. The instrument signal is compared to a critical level

(Lc) which is the value of the net signal (e.g., count rate) that has a 5% probability of being

exceeded when a blank sample is analyzed. It is used as a threshold value for deciding whether

a sample contains the analyte of interest.

The minimum detectable concentration in a sample (MDC) is the smallest concentration of

analyte (expressed in this study as pCi/g of sludge or ash) that has a 95% probability of

producing a net detection-level signal (Ld) greater than the critical-level signal (Lc). It is thus the

statistically smallest concentration with a 95% probability of being detected. Figure D.4

illustrates this concept.

Figure D.4 Comparison of Critical Level to Detection Limit

Analytical results will be reported as activity ± 2s uncertainty. At NAREL, the uncertainty for all

alpha spec results includes counting error, nonzero uncertainties for the sample volume, tracer

concentration, and tracer volume, and an uncertainty in the counting efficiency, although this

uncertainty affects only thorium results and yields for other analyses. For Ra-226 analyses,

NAREL uses counting uncertainty and an uncertainty in the counting efficiency. For all other

analyses, only counting uncertainty is computed. NAREL made an administrative decision to

change the uncertainty reported for all of its gamma analyses in April 2000. The decision was to

change from reporting only counting uncertainty, to reporting an uncertainty number which

represents our best estimate of total uncertainty. The contractor who maintained the sewage

survey database applied this total uncertainty correction algorithm retroactively to the counting

uncertainties previously reported by NAREL. This makes all uncertainty numbers in the sewage

survey database (for both NAREL and ORISE) nominally equivalent ?total uncertainty”.

At ORISE, uncertainties for alpha and gamma spec include anything that has an uncertainty

associated with it, including balances, pipettes, volumes, standards, tracers, and counting error. 

Uncertainty does not include any uncertainty related to the field sampling procedure.

NAREL reports uncertainty to two significant figures. Associated activity numbers are reported

with their least significant digit being the same as the least significant digit of the uncertainty,

e.g., if the least significant digit of the uncertainty is the tenths digit, that of the activity will also be

tenths.

Of all the sludge/ash samples in which gross alpha or gross beta activity is detected, 10% will

be chosen each calendar month from both ash and sludge matrices, and submitted for nuclidespecific analysis. They constitute a population, or sample pool, from which special samples will

be selected for nuclide-specific analyses. The number of monthly samples should not exceed,

for routine analyses, about 35 samples per month for each laboratory (400 samples/lab/12

months for routine analyses consisting of gross beta, gross alpha and gamma analyses). For
D-12

nuclide-specific analyses, no more than 3 to 4 samples per month per laboratory (10% special

samples from the 400 samples/lab/12 months) should be analyzed; and for quality control

samples, about 5 per laboratory per month (60 QC samples/12 months in addition to the 300

routine samples).

It should be understood that samples which are received in a calendar month during the survey

will be analyzed in batches as soon as is practicable. All samples for which gross alpha, gross

beta, and gamma analyses are performed during a calendar month will be stored until the end of

the month at which time decisions will be made about which samples of that month’s pool will be

subjected to nuclide-specific analyses. These nuclide-specific analyses will be conducted

during the following 60 days.

Except for preparation of tritium samples at ORISE, no special or extraordinary sample

concentration or analytical procedures will be employed for analysis of the sludge samples. For

tritium analysis, ORISE will add two steps to its routine preparation procedure: 

1. All samples will be double distilled to reduce or eliminate as many interferences as

possible.

2. The chemiluminescence monitor for the instrument will be turned on and monitored.

Both laboratories will use currently approved analytical procedures for routine environmental

samples. MDCs for samples will be those usually cited by each laboratory for environmental

samples. 

There are no established guidelines or regulations, in the ranges of results expected in these

studies, which would dictate distinct actions at certain levels. Thus, any actions which might be

recommended, or any indication of the need for further regulatory decisions, cannot be

established until the results of the survey are complete. In the absence of applicable guidelines

or regulations, recommended actions will be based on professional judgement.

The Data Quality Objectives (DQOs) for these studies have been developed using a process

outlined in the guidance document EPA QA/G-4, Guidelines for the Data Quality Objective

Process. Generally, DQOs for such specific criteria as accuracy, precision, comparability, and

completeness will correspond to those routinely cited by the two laboratory quality assurance

manuals as part of the laboratories’ overall quality assurance and quality control program. 

Specific quantitative criteria for laboratory procedures are discussed within Section 11 of this

QAPP.

4.0 PROCUREMENT AND ACCEPTANCE REQUIREMENTS

For ORISE, the Quality Assurance Manual for the Energy/Environment Systems Division,

Environmental Survey and Site Assessment Program (ESSAP) identifies items or services to

be procured by description of the item or service required along with all specifications, health

and safety considerations, and quality requirements. The ORISE Financial Operations Division

is responsible for procurement processing and compliance with all applicable regulations. 

ESSAP is responsible for assessment/inspection of items or services and payment approval.
D-13

The authority to commit and/or obligate funds by purchasing and contracting has been delegated

to the NAREL Program Management Officer (PMO) and the NAREL Support Services Specialist. 

These persons and the bank card holders are the only employees authorized to handle

procurement transactions with vendors. The technical or analytical staff is responsible for

requesting supplies, reagents, and materials of adequate purity and reliability to ensure that there

will be no adverse effect on the technical or analytical data produced. Procurement officials

must not change orders for reagents or for technical supplies or services without approval from

the original requestor. Upon receipt of purchased items, it is the responsibility of the requestor to

verify that the correct items, of the expected grade and quality have been received. 

5.0 INSTRUMENTS AND EQUIPMENT

5.1 FIELD AND SAMPLING INSTRUMENTS AND EQUIPMENT

For sample collection, only new containers are to be used. 

No laboratory-supplied field sampling equipment or instruments, other than sample containers,

will be used as part of this survey. Each POTW will use its own system and equipment to

collect the appropriate samples. POTW workers are experienced in collecting samples for

various analyses.

5.2 LABORATORY INSTRUMENTS AND EQUIPMENT

Laboratory instruments and equipment at each laboratory are used, calibrated, and maintained

according to accepted good laboratory practices, each laboratory’s written policies, and each

laboratory’s SOPs. 

Regular efficiency checks (NAREL) and instrument reproducibility checks (ORISE) are

performed on every detector in use at the laboratory according to each laboratory’s standard

operating procedures and written policies. Criteria and corrective actions are in place in both

laboratories which dictate procedures when checks fail.

Regular background measurements are required for all detectors by both labs. At NAREL,

backgrounds are measured daily for proportional counters, twice a month for alpha

spectrometers, monthly for germanium detectors, and immediately before a sample is counted

on a scintillation counter. ORISE measures backgrounds daily for proportional counters and a

scintillation counter. Weekly background counts are performed for the alpha and gamma

detectors.

Each gross radiation detector has an acceptable range for background levels. Background

measurements are evaluated statistically to determine whether the true level is outside the

acceptable range. There are warning limits and rejection limits for the test. If the most recent

background level is outside the rejection limit, the detector is not used to analyze samples.

All radioactive standard solutions used for calibrations at NAREL and ORISE are NIST traceable

whenever possible. Standard reference materials are purchased directly from NIST when they

are available. If NIST traceable solutions are not available, industry accepted standards are

used.
D-14

6.0 DOCUMENTATION AND RECORDS

6.1 DOCUMENT CONTROL SYSTEM

At ORISE, the Quality Assurance Manual and procedures manuals are controlled documents. 

They are distributed to all ESSAP personnel who must use the information to perform or review

work. Agency representatives may also receive controlled documents on request. The QA

Manager ensures document control is maintained according to QA Manual procedures. 

NAREL operates under a formal document control system, described in the NAREL SOP for

Document Control, which presents the policies and procedures for the production, review,

revision, storage, and distribution of documents. Document control policies apply to all printed

internal documents that are maintained by or for NAREL personnel on a continuing basis for a

period longer than one year. Controlled documents include, but are not limited to, the NAREL

Quality Management Plan (QMP), Quality Assurance Manuals (QAMs), Quality Assurance

Project Plans (QAPPs), SOPs, technical documentation, and forms. The Document Control

Officer maintains the NAREL Document Control Logbook, maintains current copies of all

controlled documents in hard copy and electronic forms, approves any new or revised

documents in the system, and has primary responsibility for the NAREL SOP for Document

Control.

6.2 LABORATORY OPERATING DOCUMENTS

At ORISE, procedures used in the ESSAP activities are documented in the following manuals

prepared specifically for ESSAP applications: Laboratory Procedures Manual, which presents

the procedures used in handling, preparation, and analysis of samples for radioactive

constituents; Survey Procedures Manual, which presents the procedures used for radiation

measurements and sampling; and the Quality Assurance Manual. These manuals are

controlled documents. 

The NAREL Quality Management Plan (QMP) describes the Quality System at NAREL in terms

of the organizational structure, functional responsibilities of management and staff, lines of

authority, and processes for planning, implementing, documenting, and assessing activities. 

The QMP is the umbrella document for management policies, goals, and processes which

incorporate quality assurance and quality control into all aspects of work. The QMP describes

how NAREL implements its quality system and educates its staff about QA and QC processes.

A Quality Assurance Manual (QAM), formerly called a Quality Assurance Plan (QAP), presents

technical criteria for analytical and administrative tasks to ensure that all data produced will be of

known and desired quality, and that all measurements performed at NAREL are valid,

scientifically defensible, and of known precision and accuracy. The QAM addresses all phases

of the quality control, quality assurance, and quality assessment processes. A Quality

Assurance Project Plan (QAPP) describes in detail the necessary QA, QC, and other technical

activities that must be implemented to ensure that the work performed on a specific project will

satisfy the required performance criteria. Each project conducted by or for NAREL requires a

QAPP. This includes projects supported by contract, interagency agreement, or grant. 
D-15

Standard Operating Procedures (SOPs) contain specific details and procedures which ensure

that data generated by their use will be of known and adequate quality. An SOP details the

method for an operation, analysis, or action, with thoroughly described techniques and steps. 

6.3 PROJECT DOCUMENTATION

This QAPP describes the necessary QA, QC, and other technical activities that will be

implemented during the Sewer Sludge Survey project. The QAPP is written in accordance with

requirements described in EPA QA/R-5, ?EPA Requirements for Quality Assurance Project

Plans for Environmental Data Operations,” United States Environmental Protection Agency,

Quality Assurance Management Staff (now Quality Assurance Division), Draft Interim Final,

August 1994. The QAPP also incorporates specific points of agreement between EPA, NRC,

ORISE, and NAREL. It references specific documents, including SOPs, which will guide the

procedures used during this survey.

6.3.1 GAMMA ANALYSIS

The activity and 2-sigma uncertainty for radionuclides measured by gamma spectrometry are

reported only if the nuclide is detected. Nuclides that are not detected do not appear in the

report, with the exception of Co-60, Cs-137, I-131, K-40, Ra-226 and Ra-228. If one of these six

nuclides is undetected, it is reported as ?Not Detected” or ?ND”, and a sample-specific estimate

of the MDC is provided.

Due to potential spectral interferences and other possible problems associated with the

determination of the activity of certain radionuclides, the activities for Th-234, Pa-234m, Ra-226,

and U-235 are subject to greater possible uncertainty than other commonly reported

radionuclides. It should be noted that this potential uncertainty is not included in the two-sigma

counting uncertainty which is reported with each activity. Although the calculated activities for

these radionuclides are reported, it is recommended that the results be used only as a

qualitative means of indicating the presence of these radionuclides and not as a quantitative

measure of their concentration. The results for these nuclides are not used in the evaluation of

quality control samples. Furthermore, because of mutual interference between Ra-226 and

U-235, NAREL’s gamma analysis software tends to overestimate the amounts of these

nuclides whenever both are present in a sample. Lower estimates for Ra-226 activities can be

obtained from the reported activities of its decay products, Pb-214 and Bi-214, which are likely to

be somewhat less than the Ra-226 activity because of the potential escape of radon gas.

NAREL’s gamma spectrometry software corrects activities and MDCs for decay between

collection and analysis, but only up to a limit of ten half-lives. So, if the decay time for a sample

is more than ten half-lives of a radionuclide, that nuclide will almost always be undetected and

the reported MDC will be meaningless. This is usually a problem only for short-lived

radionuclides, such as I-131, when there is a long delay between collection and analysis. 

ORISE uses extrapolated efficiencies for radionuclides with energies below 59 keV, e.g., I-125

and Pb-210. The reported concentrations and MDCs for any radionuclide below 59 keV are

approximations and are reported as qualified data. At both laboratories, all preparation, survey,

sampling, analytical, reporting, and disposal activities are completely documented throughout the

life of a project.
D-16

6.3.2 GROSS ALPHA AND BETA ANALYSIS

In comparison to the methods employed to determine radionuclide-specific activities, the method

employed by NAREL to determine gross alpha and beta activity has the potential for greater

analytical bias. This is especially true for solid samples. It should be noted that this potential

analytical uncertainty is not included in the two-sigma counting uncertainty term. Therefore,

gross alpha and beta results should be used as gross approximations of the alpha and beta

activity present.

6.4 PROJECT DATA PACKAGE DELIVERABLES

Each month, the laboratories will prepare data packages for each batch of samples which has

been completed during that calendar month. The data for each completed analysis batch will be

correlated on sample summary sheets. See Table 6.1 for an example of the format and content

of the data summary sheet. Copies of the data packages and summary sheet will be sent to

project managers for EPA and NRC by the 10th day of the month following the end of the month

being summarized. Review of the monthly reports will provide a continuing input of information

about nuclides and activities seen at the POTWs in the survey and, most importantly, will allow

the reviewers and the project team to note problems and unusual results. Monthly data reports

will allow the project team to correct any problems noted, change action limits for nuclidespecific analyses if necessary, and add data to the databases to be used for analysis of survey

results. 

Table D.1

Monthly Data Report for EPA/NRC National Radiological Sewage Survey

Data Summary Sheets

Laboratory: _____________ Page __ of __

Sample ID: _____________ Other ID: __________

Collection Date and Time: _______________ Matrix: ____________

Analysis Nuclide Activity 2s Uncertainty Units % solids MDC

Gamma Pb-212

Gamma Pb-214

Gamma Bi-214

Gamma I-131

Gamma Ra-226

Gamma Ra-228

Gamma Bi-212

Gamma Be-7

Gamma Tl-208

Gamma K-40

Gamma Cs-137
Analysis Nuclide Activity 2s Uncertainty Units % solids MDC

D-17

Gamma Co-60

Gamma I-125

Alpha Gross

Beta Gross

LSC C-14

LSC H-3

a Spec U-234

a Spec U-235

a Spec U-238

a Spec Th-227

a Spec Th-228

a Spec Th-230

a Spec Th-232

a Spec Pu-238

a Spec Pu-239

a Spec Pu-242

a Spec Am-241

Prop. Ctr. Sr-89

Prop. Ctr. Sr-90

Both labs analyze samples in analytical batches; no information will be reported about a sample

or an analysis until the entire batch data package has been completed, reviewed, verified, and

approved for release from the lab according to the lab’s quality assurance and data review

policies.

For each analytical batch of samples analyzed at the laboratory, a data package will be provided

for each type of analysis. This package will include:

- tabulated sample information for the analytical batch: sample ID, client sample ID, matrix,

date collected, date received, and date analyzed.

- documentation exceptions

- holding time information if applicable

- sample preparation exceptions

- sample analytical exceptions

- general information unique to the sample batch, the analytical method, or reporting

conventions

- individual report forms for each sample which provide
D-18

C sample identification information

C analytical method 

C detector identification

C sample weight information

C activity units

C nuclides, activity, 2s uncertainty, and MDC

Instrument printouts including spectra and other raw data, calibration data, and quality control

results are compiled and maintained in the laboratory for each sample batch. Raw data will not

be included in the monthly data reports, but will be maintained by the labs and will be available to

reviewers on request.

6.5 RECORDS ARCHIVING AND RETENTION POLICIES

All records pertaining to environmentally related measurements will be archived, retained, and

disposed of according to the pertinent EPA records schedule, with concurrence of EPA and

NRC. No documents at either laboratory are disposed of without specific approval from the

client or data-user for the project.

7.0 SAMPLING PROCESS DESIGN

Owners and operators of the selected POTWs will collect and ship the samples following

guidelines provided by ORISE and NAREL.

All samples collected will be analyzed for gross alpha and beta emissions and gamma-emitting

nuclides and, if indicated by the decision tree process, (See Figures 1, 2, and 3) for uranium,

thorium, plutonium, radium-226, americium, and strontium. All samples received at ORISE will

be analyzed for carbon-14 and tritium. The NAREL and ORISE Minimum Detectable

Concentrations (MDC) for these nuclides are listed in Tables 7.1. and 7.2.

8.0 SAMPLING PROCEDURES

8.1 SAMPLING PROCEDURES AND EQUIPMENT

Procedures and equipment for field collection of samples are described in the instructions for

collection found in Appendix A of this QAPP.

8.2 COLLECTION OF SAMPLES

Container identification labels will be filled out completely in indelible ink. Labels are glued to

containers and then covered with clear waterproof tape for protection. Containers will be filled,

closed, and rinsed with water to minimize cross-contamination. Samples will be described and

identified on the appropriate Sampling Data Form and are packed for shipment to the laboratory. 

Samples must be collected and returned to the laboratory within one week of receipt of the

sampling kit at the POTW.

8.3 SAMPLE CUSTODY, SHIPPING, AND NOTIFICATION

ORISE will send appropriate sampling containers, chain-of-custody forms (COCs), and sample

collection and handling instructions to each POTW in the survey and will notify NAREL when kits
D-19

are sent and to which facilities. Copies of the COC and the collection instructions are found in

Appendix A of this QAPP. POTW operators will collect the samples, ensure that the samples

are properly labeled with the name of the facility, type of material sampled, location or source of

the sample, the name of the person taking the sample, and the date and time of sample

collection. The COC form will then be completed to include the name of the facility, the location

or source of the sample, the name of the person taking the sample, and the date and time of

sample collection.

The samples will be placed in a shipping container and security seals placed across the top and

bottom of the shipping container. Samples will be shipped priority overnight by Federal Express

for next-morning delivery to the designated laboratory. No samples should be shipped to

laboratories on Friday or the day before a holiday. ORISE will track delivery of all samples

shipped by the POTWs. NAREL will notify ORISE of shipments received.
D-20

Table D.2 Minimum Detectable Concentration (MDC) for Selected Gamma Emitters Using Gamma

Spectrometry with Ge Detector

Selected Gamma

Emitters

NAREL MDC

(pCi/L)

for 1 L of Water

Counted for 1000

min

NAREL

MDC (pCi/gwet)

 for 100 g of Sediment

Counted for 1000 min

ORISE

MDC (pCi/L)

for 1 L of Water

Counted for 1000

min

ORISE

MDC (pCi/gwet)

 for 100 g of Sediment

Counted for 1000 min

Am-241 17.7 0.0842 4.88 0.01

Cd-109 83.0 0.424 64 0.6

Th-234 52.5 0.270 68.7 0.10

U-235 56.7 0.294 14.4 0.02

Ra-226 86.1 0.446 61.0 0.6

Th-229 65.6 0.340 38.0 0.05

Pb-212 8.45 0.0439 5.41 0.01

Ra-224 91.0 0.473 59.8 0.08

Ra-223 26.7 0.139 16.0 0.01

Pb-214 11.4 0.0601 8.02 0.01

I-131 5.84 0.0307 3.04 0.01

Rn-219 69.6 0.367 39 0.3

I-125 100 0.15 10 0.2

Be-7 45.4 0.241 26.6 0.04

Ba-140 22.2 0.119 11.4 0.02

Tl-208 6.42 0.0344 3.95 0.01

Cs-134 6.67 0.0357 4.11 0.01

Bi-214 13.1 0.0704 8.29 0.01

Cs-137 7.26 0.0391 4.18 0.01

Bi-212 89.4 0.483 28.7 0.04

Pb-211 188 1.02 117 0.17

Mn-54 7.03 0.0382 3.52 0.01

Ra-228 24.4 0.133 21 0.2

Pa-234m 950 5.20 687 0.67

Co-60 10.3 0.0566 4.33 0.01

Na-22 9.38 0.0519 4.17 0.01

K-40 99.3 0.552 59.4 0.10
D-21

NOTE: MDCs will vary depending on activity in the sample, density of sample matrix, efficiency of detector, and other counting

parameters. The above MDCs were calculated based on a 1000-min count of a 1.0-L Marinelli of deionized water.

Table D.3 Minimum Detectable Concentration (MDC) for Selected Radionuclides Using Various Radiochemical Analyses

Radionuclide Matrix

NAREL ORISE

Typical

Aliquot Size

Count

Time (min) Method MDC Typical Aliquot

Size

Count Time

(min) Method MDC

Gross Alpha

Water 250 mL 100 GFP 6 pCi/L 250 mL 200 GFP 3 pCi/L

Solids

Gross Beta

Water 250 mL 100 GFP 3 pCi/L 250 mL 200 GFP 2 pCi/L

Solids

Radium-226

Water 1 L 1000 SC 0.02 pCi/L 1 L 240 AS 0.1 pCi/L

Solids 0.5 g 1000 SC 0.04 pCi/g 700g 60 GS 1.0 pCi/g

Radium-228

Water 1 L 100 GFP 1 pCi/L 1 L 60 GFP 2 pCi/L

Solids 0.5 g 100 GFP 2 pCi/g 700 g 60 GS 1 pCi/g

Iodine-131 Water 2 L 1000 GFP 0.7pCi/L 1 L 1000 GS 3.2 pCi/L

Uranium-234, 235,

238 Thorium-230,

232

Plutonium-238, 239

Water 1L 1000 AS 0.1 pCi/L 0.25L 1000 AS 0.4 pCi/L

Solids 0.5 g 1000 AS 0.2 pCi/g 1 g 1000 AS 0.1 pCi/g

Sr-89

Water 2 L 100x3 CS-PC 1 0.25 L 60 GFP 5.0

Solids 0.5 g 100x3 CS-PC 4 5 g. 60 GFP 0.5

Sr-90

Water 2 L 100x3 CS-PC 1 0.25 L 60 GFP 5.0

Solids 0.5 g 100x3 CS-PC 4 5 g. 60 GFP 0.5

Thorium-227

Water 1L 1000 AS 0.2 pCi/L 0.25 L 1000 AS 0.4 pCi/L

Solids 0.5 g 1000 AS 0.35 pCi/g 1.0 g 1000 AS 0.1 pCi/g

Thorium-228

Water 1L 1000 AS 0.15 pCi/L 0.25 L 1000 AS 0.4 pCi/L

Solids 0.5 g 1000 AS 0.3 pCi/g 1.0 g 1000 AS 0.1 pCi/g

H-3 Wet N/A N/A N/A N/A 60 g wet 60 LSC 1.0 pCi/g

C-14 N/A N/A N/A N/A N/A 0.5 g wet 60 LSC 3.0 pCi/g

AS Alpha Spectrometry

GFP Gas-Flow Proportional Counting

GS Gamma Spectrometry

LS Liquid Scintillation Counting

SC Scintillation Counting
D-22

8.4 CORRECTIVE ACTIONS

Each laboratory will receive and survey samples according to approved laboratory procedures

and policies. Discrepancies in labeling, COC information, or other documentation will be noted

on the COC for the samples and, when the discrepancy has the potential to affect sample

integrity, it will be reported to the POTW samplers and the EPA and NRC project managers. All

discrepancies and their resolution must be fully documented. Additional information about

corrective action is provided in Section 14.3 of this QAPP. Specific information regarding

corrective actions and the personnel responsible for them are documented in the QA manuals

for each laboratory.

9.0 LABORATORY SAMPLE RECEIPT

Similar procedures are used at both NAREL and ORISE to ensure complete control of samples

and clear, concise documentation of the steps in the sample chain-of-custody form.

The POTW staff initiates the chain-of-custody form for survey samples. When sample custody

is transferred (relinquished) to the laboratory, the container and its contents are inspected by the

individual accepting custody to assure that tampering has not occurred and custody has

therefore been maintained.

Samples received at ORISE will be surveyed for radioactive contamination and recorded in the

electronic sample database according to Laboratory Procedures Manual requirements. The

Laboratory Supervisor will maintain sample custody until the sample is disposed of, consumed,

transferred, or destroyed. Sample disposal must be authorized by the Program Director or

Assistant Program Director at the direction of the customer. During analysis, the samples will

remain in a locked building during working hours and in a locked room in the building during nonworking hours. Disposition information is entered into the electronic database. Archived

samples are sealed and stored in a locked building. 

Environmental samples received at NAREL are surveyed for radioactive contamination, loggedin, and stored in accordance with the NAREL SOP for Sample Receipt, Log-in, and Storage. All

samples are received by the Sample Preparation Manager (SPM) or her designee. Sample

packages are stored in a secure area until they are surveyed for radioactive contamination. The

results of the survey are recorded on the chain-of-custody. The SPM compares the samples

received to the chain-of-custody. Any discrepancies must be resolved and documented on the

COC before sample analysis begins. The samples are then logged-in to the Sample

Preparation Logbook and into the NAREL Radioanalytical Database.

After samples are logged-in and numbered, and all documentation is complete, samples are

stored at various locations at NAREL, depending on the matrix, analyses requested, and project,

until the analyses are performed. Samples are always stored in a secure area to which only
D-23

laboratory personnel have access. Access to NAREL is restricted. Outside entrances,

laboratories, the counting room, and the sample preparation area require a key-card for entry. 

Visitors must sign in at the reception area and are escorted while in the laboratory. 

10.0 LABORATORY SAMPLE PREPARATION PROCEDURES

Sample preparation procedures and required documentation are described in the specific

NAREL SOPs and the ORISE procedures manuals for each analytical method. Exceptions to

an approved procedure must be documented and explained fully in accordance with the

laboratories’ QA manuals. Corrective actions must be initiated and documented when required. 

Appendix B of this QAPP lists specific references to methods and procedures.

11.0 ANALYTICAL PROCEDURES

11.1 ANALYTICAL METHODS 

All analytical methods used for this survey at either the NAREL or ORISE laboratories have been

approved internally and are based on industry standard procedures with proven precision and

accuracy. Methods are described and techniques outlined in the individual method SOPs 

and procedures manuals for the two laboratories. Appendix B of this QAPP provides a list of

methods and procedures for each laboratory.

11.2 ANALYTICAL QUALITY ASSURANCE 

Quality control testing is performed for laboratory activities to provide an ongoing assessment of

equipment and procedures. Quality control samples are prepared using standards traceable to

NIST or to industry accepted reference materials if NIST traceability is not possible. Chemicals

used for reagent preparation are reagent grade or higher depending on specific method

requirements.

11.3 QUALITY CONTROL SAMPLES

Laboratory quality control (QC) samples will be included in the analytical scheme in accordance

with the Quality Assurance Manual for the Energy/Environment Systems Division,

Environmental Survey and Site Assessment Program (ESSAP) of ORISE, and The Quality

Assurance Plan for the National Air and Radiation Environmental Laboratory and written ORISE

and NAREL QA/QC policies for radionuclide analysis. Four types of internal quality control

samples are analyzed routinely in the NAREL and ORISE radiochemistry QA programs. The

QC analyses and their frequency are:

C duplicate analyses (NAREL - one per analysis batch, ORISE - based on client request.);

C matrix spikes, containing a known quantity of each analyte of interest added to an existing

sample (NAREL - one per analysis batch, ORISE based on client request);

C performance evaluation (PE) samples consisting of the radionuclide of interest in either

an interference free matrix (usually deionized water) or standard reference material

(SRM) that will simulate soil or ashed samples; and
D-24

Zd'

*S2&S1*

U1

2 %U22

,

RPD '

*S2&S1*

(S1%S2)/2

× 100%.

C reagent blanks, which contain only the radioactive tracer, if appropriate, and reagents

used in the analysis (one per analysis batch).

For both labs, a batch can contain 20 samples plus appropriate QC samples. 

The batch QC requirements listed above do not apply to gamma analyses. Duplicate gamma

analyses are performed on every twentieth sample through the laboratory, and performance

evaluation samples consisting of a variety of gamma emitters and matrices are submitted to the

radioanalysis laboratory at least once a month.

The result of a quality control check is a quality indicator, whose numerical value must be judged

either acceptable or unacceptable. The acceptance criteria for a quality indicator must be based

on sound statistical principles and should be formulated in terms of the estimated uncertainties

and analytical errors (standard deviations) of the quantities used to compute the value of the

indicator.

A quality indicator may have both control limits and warning limits. When an indicator value falls

in the warning region, the Project Coordinator must initiate an investigation. When the value is

outside the control limits, the Project Coordinator must report the problem to the Quality

Assurance Coordinator, who will issue a corrective action memorandum .

11.3.1 Duplicate Analyses

Duplicates are two aliquots taken from the same homogenized sample.

When precision is assessed by duplicate analyses, including matrix spike duplicates, the quality

indicator is given by

where

S1 = First of two measurements

S2 = Second of two measurements

U1 = Estimated 1-sigma total random error associated with S1

U2 = Estimated 1-sigma total random error associated with S2

When requested by the Subcommittee, NAREL will compute and report the ?relative percent

difference,” or RPD, of the two measurements, which is defined by the equation

 

Acceptance criteria based on the RPD generally require spiked activities significantly above

environmental levels and therefore are usually applicable only to matrix spike duplicates.
D-25

Ui

2 ' Ei2%?2

S1%S2

2

2

Zr'

S&B&K

Us

2 %Ub2% Uk2

,

Us

2 ' Es2 %?2 S2

,

Ub

2 ' Eb2 %?2 B2

,

If the total uncertainties Ui for the measured concentrations Si are unknown, they may be

estimated. When duplicate analyses are performed, the total uncertainties may be estimated as

follows:

where

Ei = Estimated 1-sigma counting error

? = Maximum acceptable 1-sigma total random error, excluding

counting error, expressed as a fraction of the concentration

The result of a duplicate analysis is acceptable if |Zd| # 2. An investigation is necessary if 2

< |Zd| # 3. Corrective action is required whenever |Zd| > 3.

11.3.2 Spiked Samples

An aliquot of a sample is spiked (fortified) with known quantities of specific compounds and

subjected to the entire analytical procedure.

In the case of a matrix spike, the accuracy indicator is defined as

where

S = Measured concentration in spiked aliquot

B = Measured concentration in unspiked aliquot

K = Known concentration of spike added

Us = Estimated 1-sigma total random error associated with S

Ub = Estimated 1-sigma total random error associated with B

Uk = Estimated 1-sigma total uncertainty associated with K

The total random uncertainties Us and Ub may be estimated as follows:

where
D-26

Zr'

S&K

Us

2 % Uk2

,

Us

2 ' Es2 %?2K2

,

%R '

S&B

K

× 100%

%R '

S

K

× 100%

Es = Estimated 1-sigma counting error for S

Eb = Estimated 1-sigma counting error for B

? = Maximum acceptable 1-sigma total random error, excluding

counting error, expressed as a fraction of the concentration

The accuracy indicator for performance spikes and standard reference materials is defined as

where

S = Measured concentration of reference material

K = Known concentration of reference material

Us = Estimated 1-sigma total error associated with S

Uk = Estimated 1-sigma total uncertainty associated with K

The total random uncertainty Us may be estimated as follows:

where

Es = Estimated 1-sigma counting error for S

? = Maximum acceptable 1-sigma total random error, excluding

counting error, expressed as a fraction of the concentration

It is permissible to use a fixed percentage of K, not to exceed 5%, for Uk. If the uncertainty in K

is assumed to be negligible, then Uk may be set equal to zero.

The indicator is acceptable if |Zr| # 2. An investigation is necessary if 2 < |Zr| # 3. Corrective

action is required if |Zr| > 3.

When requested by the Subcommittee, NAREL will compute and report the ?percent recovery,”

or %R, which is given by

for matrix spikes and by

for performance spikes and standard reference materials. Meaningful acceptance criteria for

%R generally require spiked activities significantly higher than environmental levels.
D-27

x ̄ '

1

n

j xi

,

s ' j (x i

&x ̄)

2

n&1

' j x i

2 & nx ̄2

n&1

.

11.3.3 Reagent Blanks

A reagent blank, or method blank, is an analytical control, consisting of all reagents and internal

standards or tracers, that is carried through the entire analytical procedure. The blank is used to

define the level of laboratory background and reagent contamination.

Control charts are maintained for each analysis type. The initial set-up and all subsequent

updates of a control chart should be based on a sample of at least 20 reagent blank results,

which are used to determine a sample mean x ̄ and standard deviation s.

The blank values used to compute the mean and standard deviation must first be judged

acceptable. For this purpose, any reagent blank measurement whose value differs from zero by

less than the 2-sigma counting error of the measurement is acceptable. Professional judgment

is required to accept any value that differs from zero by more than the 2-sigma counting error.

The mean and standard deviation are computed as follows:

where n denotes the number of measurements.

A reagent blank value is judged acceptable if it lies within two standard deviations of the mean. 

An investigation is required if the blank value is more than two but no more than three standard

deviations from the mean. The value is unacceptable if it is more than three standard deviations

from the mean.

When a reagent blank is unacceptable, the samples in the batch may have to be reanalyzed. 

Any sample whose measured activity is greater than the associated 2-sigma counting error and

whose total activity is less than a predetermined multiple k (generally 5) of the total blank activity

must be reanalyzed. 
D-28

%C ' 100%

V

n

11.3.4 Completeness (statistical)

Completeness is assessed by the following indicator:

where

%C = Percent completeness

V = Number of measurements judged valid

n = Total number of measurements performed.

The requirements for judging measurements as valid and the total number of measurements

necessary to achieve the desired statistical level of confidence depend on the study objectives

and, thus, are specified by the QAPP. For this project, designed as a survey study, statistical

completeness is not an indicator of concern.

11.4 SAMPLE BATCHING

Analytical batches consist of a number of samples of the same matrix to be analyzed by the

same procedure for a common set of parameters. Batches may range in size from 1 to 20

samples. At NAREL and at ORISE, a batch may contain 20 samples plus the additional QC

samples. For this survey, reports and data packages will reference analytical batches of

samples as defined by each laboratory.

11.5 WASTE DISPOSAL

All radioactive and chemical wastes from samples and reagents are properly characterized,

stored, and disposed of in full compliance with all applicable federal and state regulations and

with internal NAREL and ORISE policies. Storage and disposal of hazardous and radioactive

waste is fully documented. No samples are disposed of without specific concurrence of the

laboratory client.

12.0 DATA MANAGEMENT

A flow diagram of the general data management scheme is shown in Figure D.5. The data

collection is initiated when ORISE sends sampling kits to POTW operators. Complete

documentation is required for each step in the sampling, shipping, receipt, storage, analysis,

data production and review, and sample disposal processes.
D-29

Sample Receipt at NAREL or ORISE

Radiation Screening of Shipping Containers

Verification of Samples Received and 

Chain-of-Custody Documentation

Field Sample Collection

Sample Preparation/Preservation in Field

Prepare Samples for Shipping

 (with Chain-of-Custody)

Ship Samples to NAREL or ORISE

 Sample Log-in and Identification Assignment 

Sample Preparation

Data Flow Process

ORISE Sends Sampling

Kits to POTW's

Distribute to Analysts

Alpha/Beta Screen

Data Acquisition

Double Verification

 Data Package Preparation

Data Package Review

Finalize Data Package

Permanent Electronic

Data Storage

Data Interpretation

Compare Concentration of

Nuclides to PRDL

Preparation of Monthly

Summary Reports

EPA/NRC HQ Review and Comment

Preparation of Final Project Report

Gamma Screen

Specific Analyses Specific Analyses

Figure D.5
D-30

A sample identification code is assigned to each sample. Sample preparation activities are

performed and the samples are distributed to analysts. Samples are subjected to appropriate

analyses (alpha/beta screening, gamma spectrometry, radiochemistry/ specific nuclides

analysis), and the resulting data are subjected to review and verification. NAREL analytical data

will be reviewed according to the NAREL Standard Operating Procedure for the Review of

Radioanalysis Data (Draft, June 14, 1996). ORISE analytical data will be reviewed according to

the ESSAP QA Manual. Following verification, the data are available for inclusion in a data

package or other report formats. All data packages and reports are peer-reviewed internally and

reviewed by the laboratory’s QA staff before being sent to the data-user.

Review of the prepared reports includes verification of documentation for the following: 

C sample receipt and preparation,

C laboratory data handling (using the Laboratory Information Management System (LIMS),

or other electronic systems,

C instrumentation calibrations and efficiency checks,

C types of sample analyses performed (individual detailed procedures are available for

each type),

C data review, error detection and other problem determinations, including requirements for

recounting or reanalysis of samples,

C involvement of the project quality assurance officers for the two labs.

Record keeping will be in the form of laboratory logbooks and information and data storage in the

laboratory LIMS system (which includes a large database of storage of all data produced in the

radioanalytical laboratory). Both NAREL and ORISE have formal document control systems

which allow for documents to be either controlled or uncontrolled. Data storage and retrieval is

via the LIMS system for NAREL and the relational database for ORISE.

Methods used by the laboratories in data management activities including verification of samples

with chain-of-custody records, instrument calibration and background checks, and extensive

review of counting room data including checks by at least four persons before release. Systems

backups are performed on a routine basis. For NAREL, the backups are daily, with archival to

optical disks. ORISE performs incremental backups every 2 days with a monthly full system

backup to tape. Any calculations requiring the data extract a copy from the database, leaving the

original electronic record intact. The only chance for temporary data loss is in case of a power

failure during sample counting or hardware failure. In those instances, the sample is still

available and is simply recounted.

Data handling equipment includes radioanalytical instrumentation, PCs dedicated to counting

room applications, and the local area network or other database systems. All of this equipment

has been thoroughly tested for these applications and proven to be stable and reliable. 

Commercial software programs used by the two radioanalytical laboratories are listed in

Table D.4 and D.5.
D-31

Table D.4 NAREL Data Handling Equipment

Program Analysis System

LB4000 Tennelec LB4000 Gas-Flow Proportional Counters (raw data)

GDR High-purity Germanium Detectors (raw and reduced data)

OASIS Alpha Spectrometers (raw and reduced data)

G3000 Gamma Products G3000 Automatic Germanium Counting System

(control software)

G5000 Gamma Products G5000 Automatic Alpha/Beta Counting System (control

software)

In-house software includes the following:

Data Entry and Instrument Control

Program Analysis System

I131 Tennelec LB4000 Iodine-131

GROSS Tennelec LB4000 Gross alpha and beta

SR Tennelec LB4000 Strontium-89 and 90

RA228 Tennelec LB4000 Radium-228

TH234 Tennelec LB4000 Thorium beta tracer

GET4, GET12 Germanium counters

Calculation and Data Review

Program Analysis System

GAMMARVW Gamma spectrometry

ALPHARVW Alpha spectrometry (Am,U,Pu,Th) 

I131RVW LB4000 Iodine-131

GROSSRVW LB4000 Gross alpha and beta

SRRVW LB4000 strontium-89 and 90

RA226 Radium-226 by the radon emanation method

Data Management

CAA NAREL database system

RPT Interactive database queries

NARSS Counting Room analysis scheduling

DATAPKG Data package production

The calculations performed by all in-house analysis software are documented in the software

user manuals. Only one NAREL employee is authorized to modify in-house analysis software

and electronic and written records of software modifications are maintained. After each

modification of an analysis software system, the calculations are checked using a calculator

program, which reads equations from a text file in a form similar to that shown in the user’s

manual. The results generated by the analysis software are checked against the results given

by the calculator. 
D-32

Table D.5 ORISE Data Handling Equipment

Program Analysis Program

Alpha spectrometry Alpha Management System by Canberra

Gamma spectrometry Genie Spectroscopy by Canberra

Gross alpha/beta In-house Excel spreadsheet

GAMMA High Purity Germanium Detectors (raw and

reduced data)

AMS Alpha Spectrometers (raw and reduced 

data)

ECLIPSE Tennelec LB5100W (control software)

In-house software includes the following:

Data Entry, Calculation, and Data Review

Program Analysis Program

GROSS GAB EXCEL SPREADSHEET

SR SRB EXCEL SPREADSHEET

GAMTAB GAMMA TABLES EXCEL SPREADSHEET

AMS VAX REDUCED DATA

Strontium-90 In-house Excel spreadsheet

Strontium-89,90 In-house Excel spreadsheet

Radium-228 In-house Excel spreadsheet

Carbon-14 In-house Excel spreadsheet

Tritium In-house Excel spreadsheet

Technetium In-house Excel spreadsheet

13.0 REPORTS TO MANAGEMENT

13.1 FREQUENCY AND DISTRIBUTION OF REPORTS 

The QA staffs at NAREL and ORISE make routine reports to management on the status of the

QA program, results of evaluations, and problems. In addition, project-specific reports may be

required. 

13.2 DIRECT REPORTS TO MANAGEMENT

The NAREL QAC and the ORISE QM report to staff and management on QA or QC issues

routinely. Reports on audits and results of audits, performance evaluation results, and other QA

and QC issues which need to be brought to the attention of managers are performed in a timely

manner to ensure issue resolution.
D-33

13.3 REPORTS OF AUDIT FINDINGS

Written reports of the audit findings and recommendations from internal and external audits are

submitted to the Laboratory Director, the Associate Director, and the Branch Chiefs as

applicable to each lab, by the NAREL QAC or ORISE QM. Responsible parties are expected to

investigate and correct deficiencies noted, and to submit a written audit response to the QAC or

QM.

13.4 PERFORMANCE EVALUATION RESULTS

QA staff distributes results of performance evaluation studies to the Branch Chief, the

Laboratory Director, the Associate Director, and the analysts, as the results are evaluated. At

NAREL, unacceptable results require that the Branch Chief or a designee investigate, initiate

corrective action, and submit a written Corrective Action Report (CAR) to the QAC. At ORISE,

unacceptable results require that a nonconformance report (NCR) be initiated, including a

corrective action plan. The QM tracks the NCR through completion.

13.5 PROJECT REPORTS FOR THE SLUDGE SURVEY

Each month, a report will be submitted by each of the laboratories to the NRC and EPA. 

Reports will include results from sample analyses and information on problems and corrective

actions for that month. See Section 6.4 for a complete list of what a report will contain.

14.0 ASSESSMENTS AND RESPONSES

Technical assessments, audits, and inspections are part of the overall quality system and are

intended to provide guidance for quality improvement, to identify problems and deficiencies, and

to acknowledge what is being done well. Audits are management tools for assessment and

improvement, and are not to be viewed as punitive. The technical assessments help staff

evaluate how well expectations are being met and offer recognition for good practices and

effective work. 

14.1 PERFORMANCE EVALUATION AND CROSS-CHECK SAMPLES

A performance evaluation (PE) or cross-check sample examines the ability of the laboratory to

perform analytical procedures and obtain data of known and required precision and accuracy. 

Performance evaluation and cross-check samples are analyzed throughout the year as

continual checks on accuracy and precision for all analyses. The NAREL QA staff is also

expected to provide internally prepared single-blind PE samples on a regular schedule for

analytes and matrices of interest. Successful analysis of known reference materials is required

annually for analysts by both labs for the analytes for which he or she is certified to perform

analyses.

PE and cross-check samples must be analyzed and reviewed in the same manner as regular

analytical samples. PE or cross-check programs conducted by external agencies must be

coordinated through the QAC and the appropriate Branch Chief for NAREL and the QM for

ORISE. All results must be reviewed and approved by the QA staff before submitting data to any

outside PE program. Results and scores received from an outside program must be reported
D-34

by the outside program directly to the QA staff at NAREL. The QAC or a designee compiles the

results, conducts a statistical test for acceptability, and reports the results to the analysts, the

Branch Chief, the Associate Director, and the Laboratory Director. Unacceptable results require

an investigation, and written documentation of findings and corrective actions must be submitted

to the QAC. The QA staff monitors trends in PE and cross-check results and provides a

quarterly graphical summary of PE results to management. The ORISE QAM compiles PE

results, enters them into a database, and reports results to laboratory staff, other managers, and

Program Directors. Results found to be outside the defined PE Program criteria are entered into

the nonconformance system and tracked through resolution by the QAM.

14.2 QAC LABORATORY AUDITS

The NAREL QAC conducts at least one complete systems audit during each fiscal year. The

audit must cover all aspects of NAREL’s mission. The audit allows the QA staff to assess and

document facilities, equipment, systems, procurement, record keeping, data validation,

operations, maintenance, calibration procedures, software control, reporting requirements, and

QC procedures. The audit must assess adherence to the QMP, QAM, and SOPs, generally

accepted Good Laboratory Practices (GLP), and written policies for NAREL operations. 

An audit of data quality should be performed each year either in conjunction with the systems

audit or at a different time. This audit will assess the methods used to collect, interpret, and

report the information required to characterize data quality. Such an audit requires detailed

review of recording and transfer of raw data, calculations, documentation procedures, and data

quality indicators. Audits may be either announced or unannounced.

The QAC or a designee is required to provide documentation of the audit findings, deficiencies,

and recommendations to management within one month after completion of an audit. Findings

and deficiencies require investigation and implementation of corrective actions by the

appropriate personnel, and require a written response to the QAC within one month of the audit

report.

The ORISE QM performs assessments of 25% of all projects. Assessments evaluate all critical

activities pertinent to the particular project for procedural compliance as well as good laboratory

practice. Results are documented and provided to the management team. The appropriate

manager ensures that corrective actions are successfully carried out. At ORISE, biennial audits

providing an external independent evaluation of all systems and work practices are also required.

14.3 CORRECTIVE ACTIONS AND NONCONFORMANCE REPORTS

Corrective action is required whenever the results of a quality assessment are unacceptable, as

when quality indicators fall outside predetermined rejection limits, or when an audit reveals

deficiencies in any portion of the QA program.

The primary responsibility for corrective action belongs to management. A Branch Chief or

Supervisor who delegates responsibilities to subordinates is still responsible for monitoring the

actions of those subordinates and for ensuring that the results are satisfactory. The Quality

Assurance Coordinator and Quality Manager also take active roles in resolving serious problems
D-35

and all problems affecting more than one branch. He or she has the authority to require

corrective action and to halt operations in the event of a serious circumstance.

14.3.1 Initiation of Corrective Actions

The first person who discovers a problem should initiate the corrective action process by

reporting the problem to the laboratory’s quality assurance staff. Corrective actions must be

initiated when:

C There is a variation to or a deviation from an SOP, QAPP, QAM, or the QMP

C There is a method, protocol, or work plan violation.

C When samples or extracts are lost or otherwise cannot be handled by the usual

procedure or protocol.

C When quality control criteria are exceeded and control cannot be re-established by

means defined in an SOP.

C When there is suspect data for any reason.

C When data are found to be flawed, of questionable validity, or in violation of good

laboratory practices.

C In any other circumstances when an analyst, manager, or other staff deems it

appropriate to request investigation of a circumstance impacting on data quality.

14.3.2 Corrective Action Initiated by the QAC and QAM

At NAREL, the QAC may initiate corrective action by issuing a corrective action memorandum,

addressed to the appropriate Branch Chief, the Laboratory Director, and other concerned

parties, which describes the problem and provides a deadline for a formal response. The

Branch Chief, or a subordinate with delegated responsibility, investigates the problem, identifies

probable causes, and takes corrective action. The responsible party must report to the QAC the

steps taken to solve the problem. The QAC evaluates this corrective action report and may

accept it or require testing to prove that the problem has been solved. The QAC tracks the

progress of the corrective action until the problem has been resolved. The QAC must maintain

documentation of each corrective action. The file includes all related memoranda, paper copies

of electronic mail messages, and any computer printouts of related data.

Corrective action should generally be taken immediately. When immediate action is not

possible or required, the responsible party must issue a corrective action request, in the form of

a memorandum, to facilitate the tracking of the progress of the corrective action. The

memorandum will include:

C description of the problem;

C date of detection/identification;

C name of the person identifying the problem;
D-36

C name of the person assigned to the corrective action;

C target date for the solution;

C periodic reporting status;

C nature and date of solution; and

C documented feedback to the initiator.

When the QAC performs an audit, he or she must summarize the results in a memorandum

addressed to the Laboratory Director and the key staff members involved in the audit. If the

QAC finds that corrective action is required, the audit report has the effect of a corrective action

memorandum and requires formal written responses.

At ORISE, the QAM discusses formal audit findings with the Program Directors and Manager

and assists with the determination of corrective action plans. The cognizant Manager performs

an investigation, identifies probable cause, and recommends corrective action to the Program

Directors and the QAM. Once the corrective action plan is approved, status of the item is

tracked by the QAM through completion. Quarterly nonconformance reports are submitted to

Directors and Managers.

15.0 RADIONUCLIDES IN SEWAGE SLUDGE AND ASH DATABASE (RISSAD) DATA

MANAGEMENT QUALITY ASSURANCE PROJECT PLAN

15.1 ENVIRONMENTAL HEALTH ASSOCIATES (EHA)

Personnel working on the database have received a copy of the RISSAD Data Quality

Management Plan. This section outlines EHA team member responsibilities and the interactions

required to implement evaluation of data quality, corrective actions, and reporting activities that

ensure data quality.

15.2 DATA ACCEPTANCE CRITERIA

Dual electronic and hard copy versions of the same data sent by ORISE or NAREL will be

compared for sameness. If the data points on both copies are the same, data will be accepted. 

If not the same, the sender will be contacted for corrective action (See Figure D.6). 

15.3 COMPUTER AND COMPUTER SOFTWARE

Software is obtained through purchase of commercial packages. Computer hardware is

obtained through purchase of commercial brands. 

• Acceptability of hardware/software configuration: The RISSADatabase is designed,

because of intents and purposes, to be portable and compatible with the most commonly

used and easily accessible computer operating systems, database and data analysis

software and computer hardware.

• Original development of the database is in Microsoft Access 1997. Updates to newer

versions will be at the request of the subcommittee with agreement of NRC to support

such efforts.
D-37

15.4 RECORD KEEPING

Quality assurance documentation is made at critical control points in the form of e-mail

communication and dated logs kept by each EHA team member. All stages of the RISSAD Data

Handling Process (see flow chart) are logged for completion. Task descriptions, task

delegations, task completion details, data/file transfers, data integrity issues, error

determinations and error correction measures implemented, resource needs, and

data/database alterations are logged. The logs are consolidated by the database manager for

compilation.

Figure D.6

RISSAD Data Handling Process

Database and raw data are stored on removable media (Zip disks/CD-RW) and paper and are locked up when not in use.

Version tracking numbers are updated.

Duplicate (backup) copies of RISSAD are regularly made and any changes to the data base are logged.

Data are compared with original import, data point by data point.

Errors are corrected. Errors and error correction process is logged.

Data are merged.

The data are compared for sameness, data point by data point, with the original hard copy version.

Source of any errors is determined. Errors are corrected. Errors and error correction process is logged.

Data are imported into RISSAD.

When data integrity is established, the electronic version is re-arranged in form to allow importation into RISSAD.

No content modifications are made to any data points.

If the two data versions are the same, the laboratory is notified that data integrity is fine and this fact is recorded. If the two data versions

are different (errors), the laboratory is notified of the disparity, the process for correcting errors is initiated and logged.

Both data set versions (electronic and hard) are compared for sameness, data point by data point.

ORISE or NAERL e-mail an electronic copy of laboratory analytical data and send at the same time, by U.S. Postal Service,

a duplicate copy of the paper (hard) copy of the same data.
D-38

15.5 DATA MANAGEMENT PATH

• Task delegation: Database manager will contact EHA team members with descriptions

of assigned tasks and transfer the appropriate data/materials to each team member. 

Each EHA team member will acknowledge receipt of data/materials and understanding

of task. Team member will provide completed task product to database manager and

database manager will acknowledge receipt of task product. Database manager will

quality check product and then provide feedback to team member as to task product

quality. Any potential improvements will be discussed, decided on, and implemented. 

EHA team members will quality check any products developed by the database

manager, and any potential improvements will be discussed, decided on, and

implemented.

• Error correction and reporting: Each EHA team member will report any errors and

problems with data integrity, data/file transfer, database function and structure, and task

assignment to the database manager. Database manager and team member(s) will

then discuss problems, resolve as necessary, and implement corrective actions. Each

team member will enter each issue and subsequent solution implemented into his/her

project log.

• Task completion resources: Each EHA team members will notify the database manager

of any questions and resources needed to complete task at any time.

15.6 DOCUMENT AND FILE TRACKING SYSTEMS AND CHANGE CONTROL SYSTEMS

Paper documents are filed and kept in a locked metal storage cabinet. Electronic files are

named clearly with the most recent date of alteration, alterations/changes are logged, and each

file is backed up. All electronic files are stored on and accessed from removable media (Zip

disks/CD-RW). Removable media are locked in a metal storage cabinet when not in use.

15.7 DATA SECURITY: TRANSFERENCE, STORAGE, RECOVERY AND RETRIEVAL

• Transference: All electronic files that have data considered 'sensitive' or potentially

sensitive and that are transferred by Internet or sent by regular mail are encrypted.

• Storage: All documents and electronic files that have data considered 'sensitive' or

potentially sensitive are kept under lock and key when not in use.

• Supervision, Recovery and Retrieval: All documents and electronic files that have data

considered 'sensitive' or potentially sensitive are always under the active supervision of

the EHA team members using the data. EHA team members are responsible for locking

up all data after use. All 'sensitive' electronic files are stored on, accessed and

manipulated from removable media (Zip disks/CD-RW).

• Security: Database manager will make decisions on sensitivity of data and on security

protocols for use within EHA, Inc. Security decisions will be based on Los Alamos

National Laboratory security protocols and any additional protocols required by EHA, Inc. 
D-39

EHA team members will follow all data management/security protocols. EHA team

members will discuss data management/security issues with database manager before

implementing any self-generated alterations of data management/security protocols.

15.8 FINAL QUALITY ASSURANCE OF DATABASE

When all data sets have been entered into the RISSAD database and point comparisons with

laboratory data sets have been completed, completeness of data against the original sample

selection list is performed. Discrepancies in sample numbers, duplicate data, and missing data

will be addressed by comparing laboratory codes with POTW IDs and resolving discrepancies

with appropriate subcommittee or laboratory personnel.

Finally, summary statistics will be calculated and reviewed for any suspicious data points

(outliers) which will then be followed up to ensure they represent valid data.

16.0 IMPLEMENTATION OF QAPP

16.1 IMPLEMENTATION SCHEDULE

Under EPA policy, no environmental data operations may begin to collect data before the QAPP

has been approved by authorized EPA personnel or other persons to whom this authority has

been specifically delegated. This applies to work performed intramurally by EPA staff and

extramurally by contractors and assistance agreement holders. For the purposes of this survey,

analytical data acquired from the original nine test sites may be used as part of the project data

since these data were acquired, reviewed, and reported under requirements of the quality

manuals for each laboratory.

16.2 FLEXIBILITY

The approved QAPP must be implemented as approved. However, when conditions or

requirements change during environmental data operations, the QAPP must be revised and then

reviewed and approved in the same manner as the original QAPP.

16.3 REVIEW AND APPROVAL FOR THE SLUDGE PROJECT

The signature page of this QAPP lists the required approvals from the two laboratories for the

original QAPP and for any subsequent revisions to this document. In addition, Revision 0 of the

QAPP was formally agreed to by all members of the ISCORS Subcommittee during its

conference call on November 9, 1999.
Chain-of-Custody Form Directions - April 1997 D-40 essap\forms\c-o-c.dir

Appendix A

Sampling Kit and Sample Collection Information Sent to POTWs in the Survey

ORISE/ESSAP CHAIN-OF-CUSTODY EMERGENCY CONTACTS

P.O. BOX 117 RECORD (423) 576-3561

OAK RIDGE, TN 37830 (423) 241-3242

Site (Name of plant & city) Sample Type (List type of samples)

Samplers (List personnel who took samples)

Note: If more than one name is listed, circle the sample custodian.

ESSAP

SAMPLE

NUMBER

Sample Information

Collected

Remarks

D

a

t

e

Time

(Leave this

column blank)

(List specific sample identification,

i.e. digestor #, tank #, filter press

cake, etc. This must correlate to

information on the sample

container)

Date and time 

of sample

collection 

(Leave this column blank unless

conditions existed which may

compromise sample integrity)
D-41

Transport Method (Federal Express) Seal No. (Shipping container seal

numbers)

1. Relinquished by:

(Initial custody relinquished by sampler)

(Date and

time of

sample

transfer)

*Received in good condition by:

(Note custody transfer until received by

courier)

2. Relinquished by: Date Time *Received in good condition by:

3. Relinquished by: Date Time *Received in good condition by:

4. Relinquished by: Date Time *Received in good condition by:

*For sample received in unacceptable condition explain in ?Remarks” column.

Distribution: Original to individual having custody

Copy filed in field data

COLLECTION OF SEWAGE TREATMENT PLANT SAMPLES

Following is a list of the equipment and supplies, in the attached sample collection package, needed to

collect your sample(s):

• For liquid samples, one 1-liter translucent plastic bottle for each sample

• For de-watered or dried samples, one wide-mouth white plastic jar per sample

• One Chain-of-Custody form (for all samples)

• One return shipping container

• Return shipping labels with pre-paid shipping

• Two security seals for the shipping container closure

Collect one sample from each solids waste stream produced at your facility. This may include

sludge, dewatered sludge, filter press cake, ash compost, etc. See ?Sampling Instructions” on next

page.

Instructions for return shipment of samples:

1. Ensure that the sample(s) are properly labeled with the type of material sampled, location or

source of the sample, the name of the person taking the sample, and the sample date and

time. Your facility code, for confidentiality purposes, is already on the sample

label(s).

2. Complete the enclosed Chain-of-Custody form with the location or source of the sample,

the name of the person taking the sample, and the sample date and time. Your facility has

been given a code which already appears on the Chain-of-Custody
D-42

3. Place the sample(s) in the shipping container. The person taking the sample must sign the

completed Chain-of-Custody form as ?Relinquished by” and enclose the form with the

sample(s).

4. Reseal the shipping container and place the security seals across the top and bottom of the

shipping container.

5. Place the enclosed return shipping labels on the shipping container. The return shipping

label has your facility code and ORISE’s mailing address or NAREL’s mailing

address to help maintain confidentially.

6. Please return the sample(s) as quickly as possible after collection. Do not ship for

Saturday delivery.

If you have any questions or need assistance, please contact Dale Condra at ORISE (423) 241-3242

or Susan Baker at NAREL (334) 270-7052.

Sampling Instructions

If a sample is well-mixed, then a representative sample can be easily obtained. If a sample is not

well-mixed, then incremental aliquots must be collected and composited, to obtain a representative

sample. The collection date and time should be close to the date that the sewage treatment stream

leaves the plant for transport to a landfill or for land application.

For example, the sample might be collected from a digester, filter press or drying bed, truck, tank, or

pile. A liquid or slurry sample from a digester or tank should be from an outlet stream. The outlet or

sample port should be opened and allowed to flow until a representative sample is available. A

sample collected from a filter press should be a composite of several small samples collected at

different locations across the press or within the filter cake. A sample collected from a drying bed,

truck or pile should be scoops from various areas and levels of the drying bed, truck, or pile. A

sample of incinerator ash should be from the location where it is collected or stored.

A large-mouth plastic jug is sufficient for liquid and slurry samples. If a sample of the total stream

cannot be collected, then the stream should be cut across for equal time periods until the sample

container is full. If the sample is collected from a tank, the tank should be well-mixed; and the line

should be flushed before collecting the sample. If the sample is a slurry, the sampling procedure

could involve obtaining a representative sample from a lagoon, pond, tank, or other vessel. The

sample should be representative of the typical amount of solids and liquids in the material being

sampled. If not collected from a liquid or slurry stream, incremental aliquots should be collected that

are representative of the solids and liquid present. For some sampling, such as from lagoons, ponds,

tanks, and other vessels, grab samples of the liquid and solids may have to be collected as separate

samples (not composited).
D-43

Appendix B

Method and Reference SOPs for the Suvery

Method and SOP References for NAREL

The Quality Assurance Plan for the National Air and Radiation Environmental Laboratory.

NAREL Radiochemistry Quality Assurance Manual

QA/SOP-1 NAREL Standard Operating Procedure for Document Control

QA/SOP-2 NAREL Standard Operating Procedure for Writing Standard Operating Procedures

MAS/SOP-1 NAREL SOP for Chain of Custody

MAS/SOP-2 NAREL SOP for Calibration of Balances

MAS/SOP-3 NAREL SOP for Cleaning Laboratory Glassware and Planchets

MAS/SOP-4 NAREL SOP for Operating and Maintaining Fume Hoods

MAS/SOP-5 NAREL SOP for Use and Maintenance of Laboratory Logbooks

MAS/SOP-6 NAREL SOP for Standardization of pH Meters

MAS/SOP-7 NAREL SOP for Labeling Chemical Containers

MAS/SOP-8 NAREL SOP for Storing Chemicals and Solutions

MAS/SOP-9 NAREL SOP for Transporting Chemicals

MAS/SOP-10 NAREL SOP for Training and Certification of Laboratory Personnel

MAS/SOP-11 NAREL SOP for Preparing Alpha Spectrometry Efficiency Standards

MAS/SOP-12 NAREL SOP for Preparing Thorium-234 Tracer Solution

MAS/SOP-13 NAREL SOP for Preparing Uranium-232 Tracer Solution

MAS/SOP-14 NAREL SOP for Receipt, Log-in, and Storage of Environmental Samples

MAS/SOP-15 NAREL SOP for the Preparation of Environmental Samples for Radiochemical

Analysis

MAS/SOP-16 NAREL SOP for Calibration, Use, and Maintenance of Pipets

MAS/SOP-17 NAREL SOP for the Use of Control Charts

MAS/SOP-18 NAREL SOP for the Review of Radiochemistry Data

RAL/SOP-1 NAREL SOP for Calibration and Use of High-purity Germanium Gamma Detectors

RAL/SOP-2 NAREL SOP for the Handling of P-10 Gas

RAL/SOP-3 NAREL SOP for the Use of the Tennelec LB4000 Multi-detector Counting System

RAL/SOP-4 NAREL SOP for Use of the OASIS Alpha Spectrometry System

RAL/SOP-5 NAREL SOP for the Handling of Liquid Nitrogen

RAL/SOP-6 NAREL SOP for Calibration and Use of the Random SC-5 Scintillation Counter

RAL/SOP-7 NAREL SOP for the Calibration and Use of the Gamma Products G-3000 Automatic

Gamma Counting System

RAL/SOP-8 NAREL SOP for Automated Gross Beta Analysis Using the G5000 Series

Alpha/Beta/Gamma Counting System

RAL/SOP-9 NAREL SOP for Calibration and Use of the G5400 Auto-Quad Alpha/Beta Counting

System

RAL/SOP-10 NAREL SOP for Calibration and Use of the G542 Alpha/Beta Counting System
D-44

Method and SOP References for ORISE

Quality Assurance Manual for the Environmental Survey and Site Assessment Program

Laboratory Manual for the Environmental Survey and Site Assessment Program 

1 Introduction

Organization and Responsibilities

3 Procedure for Evaluating Operational Performance of Laboratory Instruments and

Equipment

4 Quality Control

4 (1) Training and Certification

4 (2) Balance Quality Control

4 (3) Procedure for the Preparation, Control and Traceability of Standards

4 (4) Procedure for Control of Laboratory Logbooks

4 (5) Analytical Quality Control and Sample Flow

4 (6) Radiochemical Contamination Control

4 (7) Automatic Pipet Quality Control

5 Sample Receipt and Preparation

5 (1) Sample Log-in

5 (2) Electronic Calibration of Bicron Analyst Ratemeters

5 (3) Screening Samples for Laboratory Contamination Control

6 Gross Alpha and Beta Screening for Various Matrices

7 (1) Determination of Tritium Utilizing Gas Permeable Membrane Distillation

7 (2) Determination of Tritium Using Glass Distillation

8 Determination of Iodine-131 in Milk and Water

9 Determination of Iodine-125 in Environmental Samples

10 Analysis of Polonium-210 in Water Soil, and Air Filters

11 Radium-226 in Water and Soil using Alpha Spectrometry

12 Radium-226 and -228 in Water

13 (1) Determination of Strontium-90 and -89 in Milk, Water, and Solid Samples Other than

Soil and Sediment

13 (2) Determination of Strontium-90 and -89 in Soil and Sediment

14 Determination of Technetium-99

15 Isotopic Determination of Americium, Plutonium, Uranium, Neptunium, and Thorium in Soil,

Water, Air Filters, and Biotic Material

16 (1) Gamma Spectrometry

16 (2) Direct Ratio Gamma Counting Method, Single Energy Method

16 (3) Direct Ratio Gamma Counting Method, Two Energy Method

17 Neutron Activation of Soil for Th-232, U-238, and Other Metals

18 Determination of Carbon-14 and Tritium Using the Biological Material Oxidizer

19 Determination of Nickel-63

20 Determination of Mercury by X-Ray Fluorescence

21 Mercury Analysis by the Vapor Atomic Absorption (VAA) Method

22 Alpha Spectrometry

23 Analysis of Carbon-14 in Soil, Sediment, and Water

24 Radiochemical Determination of Phosphorus-32

25 Liquid Scintillation

26 Low Background Alpha/Beta Counter
D-45

27 Analysis for Sulfur-35 in Organic Material
D-46

GLOSSARY

Acceptance criteria - Specified limits placed on characteristics of an item, process, or service

defined in requirements documents. (ASQC definitions.)

Accuracy - A measure of the closeness of an individual measurement or the average of a

number of measurements to the true value. Accuracy includes a combination of random error

(precision) and systematic error (bias) components which are due to sampling and analytical

operations.

Agreement state - A state which has signed an agreement with the NRC allowing the state to

regulate the use of radioactive material within that state.

AMSA - Association of Metropolitan Sewerage Agencies.

Assessment - The evaluation process used to measure the performance or effectiveness of a

system and its elements. Assessment is an all-inclusive term used to denote audit,

performance evaluation, management systems review, peer review, inspection, or surveillance.

Audit (quality) - A systematic and independent examination to determine whether quality

activities and related results comply with planned arrangements and whether these

arrangements are implemented effectively and are suitable to achieve objectives.

Bias - Systematic or persistent distortion of a measurement process which causes errors in

one direction.

Blank (reagent blank) - A sample which is used to monitor contamination during sampling,

transport, storage, or analysis. The blank is subjected to the complete analytical or

measurement process to establish a zero baseline or background value.

Calibration - Comparison of a measurement standard, instrument, or item with a standard or

instrument of higher accuracy to detect and quantify inaccuracies and to report or eliminate

those inaccuracies by adjustments.

Chain of custody - An unbroken trail of accountability that ensures the physical security of

samples, data, and records.

Comparability - A measure of the confidence with which one data set or method can be

compared to another.

Completeness - A measure of the amount of valid data obtained from a measurement system

compared to the amount that was expected to be obtained under correct, normal conditions.

Corrective action - Measures taken to rectify conditions adverse to quality and, where

possible, to preclude their recurrence.
D-47

Data of known quality - Data that have the qualitative and quantitative components associated

with their derivation documented appropriately for their intended use, and when such

documentation is verifiable and defensible.

Data quality indicators - Quantitative statistics and qualitative descriptors that are used to

interpret the degree of acceptability or utility of data to the user. The principal data quality 

indicators are bias, precision, accuracy (bias and precision are preferred), comparability,

completeness, representativeness, and statistical confidence.

Data Quality Objectives (DQO’s) - Qualitative and quantitative statements derived from the

DQO process that clarify study technical and quality objectives, define the appropriate type of

data, and specify tolerable levels of potential decision errors that will be used as the basis for

establishing the quality and quantity of data needed to support decisions.

Duplicate samples - Two samples taken from and representative of the same population and

carried through all steps of the sampling and analytical procedure in an identical manner. 

Duplicate samples are used to assess variance of the total method including sampling and

analysis.

Environmental data - Any parameters or pieces of information collected or produced from

measurements, analyses, or models of environmental processes, conditions, and effects of

pollutants on human health and the ecology, including results from laboratory analyses or from

experimental systems representing such processes and conditions. 

Holding time - The period a sample may be stored prior to its required analysis. While

exceeding the holding time does not necessarily negate the veracity of analytical results, it

causes the qualifying or ?flagging” of the data for not meeting all of the specified acceptance

criteria.

Incineration - the combustion of organic matter and inorganic matter in sewage sludge by high

temperatures in an enclosed devise.

ISCORS - Interagency Steering Committee on Radiation Standards. NRC and WPA formed

ISCORS to expedite the resolution and coordination of regulatory issues associated with

radiation standards. This committee was formed in response to October 27, 1994, letters from

Senator John Glenn to NRC, EPA and the Office of Science and Technology Policy (OSTP). 

The objectives of the committee include the following: (1) facilitate a consensus on acceptable

levels of radiation risk to the public and workers, (2) promote consistent risk assessment and

risk management approaches in setting and implementing standards for occupational and public

protection from ionizing radiation, (3) promote completeness and coherence of Federal

standards for radiation protection, and (4) identify interagency issues and coordinate their

resolution. In addition to NRC and EPA, ISCORS membership also includes senior managers

from the Department of Defense, the Department of Energy, the Department of Labor's

Occupational Safety and Health Administration, the Department of Transportation, and the

Department of Health and Human Services. Representatives of the Office of Management and

Budget (OMB), OSTP and the States are observers at meetings. The ISCORS Sewage

Subcommittee is assisting in the development of an NRC/EPA sewage survey and a sewage

guidance document.
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Laboratory split sample - Two or more representative portions taken from the same sample

and analyzed by different laboratories to estimate the interlaboratory precision or variability and

data comparability.

Land application - spraying or spreading of sewage sludge onto the land surface; the injection

of sewage sludge below the land surface; the incorporation of sewage sludge into the land so

that the sewage sludge can either condition the soil or fertilize crops or vegetation grown in the

soil.

Matrix spike - A sample prepared by adding a known mass of target analyte to a specified

amount of matrix sample for which an independent estimate of target analyte concentration is

available. 

Spiked samples are used, for example, to determine the effect of the matrix on a method’s

recovery efficiency.

Municipal solid waste landfill - a land 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.

Peer review - A documented critical review of work generally beyond the state of the art or

characterized by the existence of potential uncertainty. The peer review is conducted by

qualified individuals (or organization) who are independent of those who performed the work, but

are collectively equivalent in technical expertise (i.e., peers) to those who performed the original

work. The peer review is conducted to ensure that activities are technically adequate,

competently performed, properly documented, and satisfy established technical and quality

requirements. The peer review is an in-depth assessment of the assumptions, calculations,

extrapolations, alternate interpretations, methodology, acceptance criteria, and conclusions

pertaining to specific work and of the documentation that supports them. Peer reviews provide

an evaluation of a subject where quantitative methods of analysis or measures of success are

unavailable or undefined, such as in research and development.

Performance evaluation (PE) - A type of audit in which the quantitative data generated in 

a measurement system are obtained independently and compared with routinely obtained data

to evaluate the proficiency of an analyst or laboratory.

POTW - Publicly owned treatment works.

Precision - A measure of mutual agreement among individual measurements of the same

property, usually under prescribed similar conditions expressed generally in terms of variance.

Quality - The totality of features and characteristics of a product or service that bear on its ability

to meet the stated or implied needs and expectations of the user.

Quality assurance (QA) - An integrated system of management activities involving planning,

implementation, assessment, reporting, and quality improvement to ensure that a process, item,

or service is of the type and quality needed and expected by the client. 

Quality control (QC) - The overall system of technical activities that measures the attributes

and performance of a process, item, or service against defined standards to verify that they
D-49

meet the stated requirements established by the customer; operational techniques and activities

that are used to fulfill requirements for quality.

Reporting limit - The lowest concentration or amount of the target analyte required to be

reported from a data collection project. Reporting limits are generally greater than detection

limits and are usually not associated with a probability level.

Representativeness - A measure of the degree to which data accurately ad precisely

represent a characteristic of a population, parameter variation at a sampling point, a process

condition, or an environmental condition.

Reproducibility - The precision, usually expressed as variance, that measures the variability

among the results of measurements of the same sample at different laboratories.

Sewage sludge - 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.

Spike - A known quantity of a chemical that is added to a sample for the purpose of determining

(1) the concentration of an analyte by the method of standard additions, or (2) analytical recovery

efficiency, based on sample matrix effects and analytical methodology.

Standard operating procedure (SOP) - A written document that details the method for an

operation, analysis, or action with thoroughly prescribed techniques and steps, and that is

officially approved as the method for performing certain routine or repetitive tasks.

Traceability - The ability to trace the history, application, or location of an entity by means of

recorded identifications. In a calibration sense, traceability relates measuring equipment to

national or international standards, primary standards, basic physical constants or properties, or

reference materials. In a data collection sense, it relates calculations and data generated

throughout the project back to the requirements for the quality of the project.

Treatment works - 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.